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Section 4: The Development Strategy and Strategic Policies


This response report contains comments received on Section 4: The Development Strategy and Strategic Policies.

Contents

Section 4 The Development Strategy and Strategic Policies

Comment No.

Name/Organisation

Response

DLP_375

Mr David Smith

Specifically, the targets for the growth in housing provision are unreasonably high and are based on figures which were revised some time ago, although central government chose to ignore the downward revisions recommended. In practical terms the fact that these are far too high is being demonstrated by the slowdown in the sales and further building on the sites already earmarked for growth in the current period.

It is understood that Sevenoaks have lodged an appeal to the growth estimates in their own plan but that TWBC have simply chosen to "wait and see" what the outcome of this is. This attitude simply does not make sense since the cases for Sevenoaks and TW are quite different so the failure of one appeal does not necessarily imply that the other would necessarily also fail. However, this TWBC attitude simply demonstrates and reinforces the widespread belief here in Paddock Wood that TWBC do not have PW interests at heart and are in fact following another more sinister agenda.

DLP_1136

Carolyn Gray

While I understand that the government wants to build loads of houses, ome of this feels a step too far for the streets and green spaces of Tunbridge Wells. But maybe by 2036 less people will own cars. At the moment driving around in a car is a nightmare, with so much on street & on road & on pavement parking - in fact with the multitude of new bins walking on a pavement can be an effort at times - bins to one side, cars to the other. In short: the town centre will stop being a pleasant place to live. 

In this I hope the edges of Calverley Grounds can be preserved now as the green spaces they are, and that will be the end of underground town centre car parks dug out under parks - although underground car parks might work well in housing developments, to keep green spaces above ground. I worry about the amunt of traffic due to be in Hawkenbury in the future.

A pity we start the precident of allowing development "on a bit of" green belt. When the green spaces are our selling point to those leaving London, and to tourists. Eventually RTW will be London? 

Glad to see mentions of culture, art and music, these elements are essential for our wellbeing, as much as the trees and cycle lanes.

DLP_1697

Frittenden Parish Council

Frittenden Overview - In respect of the Retail section, there is currently no part time shop. There are two public houses within the Parish of Frittenden, the Bell & Jorrocks and the Knoxbridge Inn.  In the Employment section, in addition to Fridays Egg Farm, there is in the Parish Larchmere House, a Nursing Home, and CWP Fencing, a fencing company.

Policy STR/FR1 - With regard to paragraphs a-g setting out the items for which contributions will be required, we would not see the items at paragraphs a, b and d as a priority. Frittenden is too small to support secondary education and healthcare facilities within the Parish, with residents accessing such facilities elsewhere in the Borough, and the Parish already has a well advanced community led scheme for improving broadband connectivity. In order of priority, we would start with the provision of a refurbished/redeveloped village community hall and a community cafe/shop. As speeding is a constant issue in the Parish, we would also add a contribution to highway improvements specifically targeted at reducing speed. Parking in the centre of the village is also a problem so the provision of additional off street parking as referred to in paragraph e is a priority.

Policy AL/FR1 - In respect of the development requirements for Late Site 28, the layout and design should also take account of the size of houses which are not in supply in the area. We see a number of new developments in the locality which offer 5 bedroom 'executive homes'. We need homes that fulfill local need, for example to include 2 or 3 bedroom homes.

DLP_1729

Mr Raymond Moon

The Strategic Policies

The Development Strategy

Section.4.

Policy STR 1 OBJECT.

The Development Strategy

  1. 2. These are well received statements but need more detail in the Draft Plan to ensure they are implemented. What are the “ Strategic Flood Risk Solutions”. The regeneration of the town centre retail sector would be greatly enhanced by reduced parking charges and part of Commercial Road being pedestrianised to enhance the shopping experience in PW. There is no detail on the delivery of new health facilities, sports hub including outside activities, new primary schools and how and who will pay for these new facilities. Again most of these need to be in place before houses are completed.

Policy STR 3 OBJECT. 

Masterplanning and use of Compulsory Purchase powers.

With the failure of a “ joined up approach” to the building approved at Church Road, Green Lane & Badsell Road where the present infrastructure is unable to cope it is imperative that a Masterplan is in place for the proposed new 4,000 houses in PW and that it is implemented before they are built and the developers adhere to it and the TWBC monitors its progress.

Compulsory Purchase powers. OBJECT.

With the £90 Million project in Calverley road TW being scrapped it is not good practice to rely on Compulsory purchase orders to ensure new development in PW.

Policy STR 4 OBJECT.

Green Belt Ref 4.47-4.52.

Green belt status should be allocated to the land East of PW to ensure that the adjacent rural villages and PW do not lose their identity to future development. Green open spaces provide wildlife corridors and maintain our rural identity

Policy STR 5 OBJECT.

Essential Infrastructure and Connectivity.

Transport.

The country lanes and residential streets in PW are already clogged with commuter cars and heavy lorries. The Maidstone road with 900 homes already approved would have increased traffic from 4,000 new houses and any new houses to the East would create “ Rat Runs” in our narrow country lanes. There needs to be a new ring road from the East to the North of PW and a new road to relieve the centre of PW.

The railway station at PW will not be able to cope with the new proposed development resulting in over crowding. Detailed discussions need to take place with Network Rail to ensure that the rail way infrastructure can cope in PW.

Water

It is clear that these 4,000 new houses need water supplies but there is no detail how this will be provided. South East Water need to submit real proposals to fulfil this requirement and give information and costs to the Masterplan.

The present surface and foul water network infrastructure can clearly not cope with the increased surface water flooding and the resultant leakage of sewage onto roads and residents property in the Town. Greg Clark MP for Tunbridge Wells has intervened concerning this problem with Southern Water but at present Southern water have not submitted any real solutions to the problem. It is common sense to provide a new Foul water ring network around PW to relieve the present problems and plan for the new 4,000 houses. A new Sewage Treatment centre should be provided on this new ring network or the present one expanded. The issue is, who pays for this in the future before the new houses are built.

Health

The healthcare facilities in PW will be stretched with the present agreed 900 new houses and will not cope with 4,000 new houses. The present Health care centre at |Woodlands will be unable to manage the potential new patients and it has ready taken on the patients that live in East Peckham. A new health centre is required to deal with increased dental, and social care provision and should be mentioned in the Draft Plan..

Policy STR 6 OBJECT. 

Transport and Parking.

As already mentioned to increase foot fall to our retail centre new free parking needs to be introduced and a joined up public transport network that offers on time reliable services at a reasonable cost.

Policy STR 7 OBJECT.

Place Shaping and Design.

As regards the type of build no mention is made of the use of renewable energy and the TWBC policy on the issue. The draft plan should insist that all new houses have solar panels installed and electric points for recharging electric cars in the future. Also an alternative to gas fired boilers to provide central heating should be mentioned..

Policy STR 8 OBJECT.

Conserving and enhancing the natural, built, and historic environment

Mature trees and hedgerows need to be protected as also our adjoining woodlands to protect our wildlife and enhance the country side around the new houses.This will reduce the risk of flooding and increase the air quality in the environment. Mitigation of replacing trees can take years to mature and should be incorporated in the Masterplan to ensure our country side is protected.

DLP_1797

Royal Tunbridge Wells Town Forum

In Paragraph 4.3, no mention is made of the landscape, heritage and water provision constraints on development which may well inhibit full provision of the development needs of the Borough as defined by central government.

In Paragraph 4.9 we support the need to take account of new data on objectively assessed housing need in the period leading up to the Regulation 19 submission, because the most recent trend seems to be towards a reduction in some need assessed according to 2016 government methodology, but we think this does not include the urgent need for affordable housing in the Borough.

In Paragraphs 4.19-4.20 we support the identified need to retain existing well located office accommodation in the centre of Royal Tunbridge Wells.

In Paragraphs 4.24-4.25 we support the aim to maintain and develop cultural opportunities within the Borough.

In Paragraphs 4.26-4.27 we broadly support the principles set out in the supporting Infrastructure Delivery Plan but are concerned that the resources needed to give effect to its objectives will not become available in time to mitigate problems arising from the planned development in the Borough.

These doubts about adequate resources particularly apply to the required development of a coherent network of active travel routes in Royal Tunbridge Wells and between settlements in the Borough and neighbouring towns. For example, in our 2015 report “Developing our Green Network”,  we advocated the establishment of an active travel route between Tunbridge Wells  and Tonbridge on existing PROW via 21st Century Way, Apple Tree and Gorse Woods to Pembury Road  in Tonbridge, avoiding the extremely challenging Quarry Hill and providing a very direct and pleasant link to Tonbridge. We are delighted that this appears to have been taken up in Table 3 of the Infrastructure Delivery Plan but how will such new infrastructure be effectively financed and in what timescale?

In Paragraphs 4.28-4.40 we consider it regrettable but inevitable that a planning policy system based on call for sites from interested landowners may not result in optimal selection of land suitable for development. We have nonetheless welcomed, and have been able to express views and information on potential allocations within Royal Tunbridge Wells through, a number of workshops with TWBC Planning Policy Officers during the Issues and Options and later stages of the Draft Plan development. Our further views on the AL/RTW Policies appear in the relevant section below.

Our views on the remaining Section 4 paragraphs appear under our comments on the accompanying STR Policies below.

DLP_1986

Brenda White

STR/HO1 Horsmonden

This is the second time that i have attempted to submit my comments as your website doesnt work on a tablet or smart phone. I strongly object to the numbers proposed for Horsmonden, the majority of people (long time residents and recent additions) live in Horsmonden because of its rural setting and village feel. This would be ruined with the proposed 300 new properties, an increase of nearly 30%. Whilst i accept that there needs to be development so that the village can be sustainable, this scale of increase is totally unsustainable. For a start why arent the majority of the dispersed development be placed in one place along the A21 corridor. This would not have a detrimental impact on the villages and could be easily linked to Tunbridge Wells and paddock Wood. I think that Horsmonden could not cope with more than 100 new properties as the current transport infrastructure is non-existent. Outside of school times, the bus service to Paddock Wood and TW is hopeless which means that people are reliant on cars. An increase of 300 new properties would result in 500 more cars. As you know there have been several serious crashes at the crossroads as there is no enforcement of any speed restrictions as there are no police ever in the village. I am also concerned about the extent of these windfall sites. Surely a limit of 10 or 15% of the total allocation should be set to avoid landowners selling their plots for an extra couple of hundred propeties. Also are there any plans for a nursing home as it would be quite nice for families to be able to stay together once they get older. I have 2 generations of family in the village and it would be nice if i could stay near them instead of being forced out for 5 or 6 bedroom houses that no-one can afford. Finally, additional speed controls such as a reduction to 20 mph in the centre and an eextension of speed reductions along lamberhurst rd would be good.

In summary:

Why not develop along the A21?

Reduce speed in the village

Limit windfall to 10% of total

Reduce overall allocation to 100 properties

New nursing home instead of a gun club for the rich and famous!

AL/HO2 - will you be providing pavements or safe access along Brenchley Road as without this, this plot would be unsustainable as you would have to drive or walk along the main road

AL/HO3 - how will this massive increase of cars safely access and egress Goudhurst Road??? Surely an accident waiting the happen. Would it be possible to provide an entertainment facilities for the teenagers in this area as there is currently nothing for them to do.

DLP_2007

Dr David Parrish

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

The figures used are out of date and not imposed by the Government as TWBC state

The ONS 2016 figures show a smaller housing need, than those used by TWBC, are valid. TWBC do not have to use the 2014 figures of the ONS who admit their planning model was wrong. The plan should reflect that. The TWBC have used the wrong figures – but even so, if they do use them, they do not need to, as stated by the NPPF, as they are not imposed by the Government under Green Belt, and other, special circumstances.

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

The distribution of Housing Allocation so uneven throughout the Borough

TWBC should build on areas of land with no Green Belt, No Flood Plain, No AONB locality and not next to Tonbridge

The “Dispersed Growth” intentions stated are not actually true due in this LP. Capel accounts for 63% of the housing allocation – of which Tudeley Garden Village is 70%. This is unfair. If it does not work the TWBC LP fails – and wastes tax payers money. There is no Plan B (which should be Plan A actually – i.e. Horsmonden and Frittenden)

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

TWBC want to create a ribbon-develop from Tonbridge to Paddock Wood

This intention will lead to a built-up conurbation from Tonbridge to Paddock Wood – over the years. This is counter to the intention of a Green Belt which exists to stop conurbations and town sprawls.

TWBC cannot ensure agreed levels of affordable housing to Local Residents – especially if Hadlow Estate controls the development – as developers cite economic conditions preventing promised financially viable development of such Affordable Housing

There are no accurate analyses of the housing needs for Tudeley and Capel

The LP will lead not to affordable housing (developers never honour their percentage affordable housing content – citing “new economic circumstances”, but to housing suited for London Commuters who will be using Tonbridge resources (roads, railways etc.) not Tunbridge Wells’ resources.

DLP_2275

Jackie Bourne

I Object:

Central Government has determined the direction of the long-term strategic planning document for every County in the Country. Where is the research for Cranbrook and Sissinghurst that shows so many houses are required, and where are the people coming from? The population has steadied, and the only Group substantially increasing is the Older Persons Group, so the DLP should focus on this Group and its needs in the next decade or so, but without disregarding the requirements of other, younger Groups, or those with a disability.

To date many of the small housing developments in the surrounding area have been larger detached houses, so where is the research to say people are moving in the housing chain to release smaller houses for younger people, and families?

Please do not argue solely the housing “numbers game” and deeply consider all residents in the Borough.

DLP_2487

Mr John Wotton

Given the extent to which the land area of the Borough consists of AONB and Green Belt, it is striking that the Council has given no serious consideration to not meeting in full the Objectively Assessed Housing Need of 13,560 homes (678 per year throughout the Plan period), assigned to it by the Government's artificial methodology. Indeed, the Plan provides for an extra 9% of homes to be built, a total of 14.776. I object to the total allocation in paragraph 4.18.

For the reasons given by CPRE Kent in their comments, the Council should have considered and adopted a lower housing allocation, having regard in particular to the requirements of paragraph 11(b) NPPF.

I also object to the following elements of Policy STR 1:

Point 3 A new "garden settlement" at Tudeley.

Points 4 and 5 to the extent that they involve major developments in the AONB

Point 7 providing for the release of Green Belt land

Point 8 concerning major development within the AONB, as the tests for such development within the AONB are not met, for the reasons given by CPRE Kent and the AONB Unit.

object to Policy STR 4. There should preferably be no loss of Green Belt in the Borough. If any green Belt land must be released to permit sustainable growth of Paddock Wood, an at least equal area of Green Belt should be designated to replace the area lost.

support Policy STR 8 Conserving and enhancing the natural, built and historic environment, but I conclude that the draft Local Plan does not adhere to this policy in many important respects.

DLP_2691

St. John's Road Residents Association

4.3. The development of a new garden village at Tudeley of some 2,500-2,800 new homes with 1,900 being delivered in this plan period.

We support the garden village development in principal but it is important to weigh the environmental factors as this will be a major new development requiring major transport connectivity plans. With the Council’s newly adopted objective to reach net zero carbon emission by 2030, it would be difficult to realise this target if large scale housing is build without the requisite rail and road connections.

We feel that attention should be given to core strategies TP3 which states councils should provide sustainable modes of public transport in the vicinity and to town centres; well connected to public transport and within range of services or facilities without use of the private car; TP4 and EN1 which state that the proposal should not cause significant harm to the area’s safety or generate excessive traffic, that there should be “safely located access with adequate visibility”;

NPPF paragraph 17 encourages full use of public transport, walking or cycling i.e. active travel

NPPF paragraph 130 relates to access and highway mitigation; if these are not met the scheme can be rejected.

Paragraph 4.57 considers the importance of the Infrastructure Delivery Plan which we fear will not be delivered in time before a development is approved or sufficiently idenify which types of infrastructure will be required as well as how it is to be delivered. This is particularly so in relation to connectivity between and within new rural settlements in the Tunbridge Wells.

We are concerned that the provisions for flood risk are insufficient in light of the extreme weather conditions which we are experiencing today and in the future.  Will the council consider flood risk proofing as a priority before even considering building on land known to comprise flood plains.

Para 4.7-4.9 Release of Green Belt

As already recognised in the NPPF, green belt land is to be respected and should not be built upon only upon exceptional circumstances. Paragraph 2.40-2.44 mentions the constraints that Green Belt and AONB imposes but due regard must be paid to 2.10 of the balancing effect of landscape which we need to value in terms of tourism and environmental benefits, not least of which is air quality and flood defences.

DLP_2725

Paddock Wood Labour Party

The Strategic Policies

The Development Strategy

Section.4.

Policy STR 1 OBJECT.

The Development Strategy

  1. 2. These are well received statements but need more detail in the Draft Plan to ensure they are implemented. What are the “ Strategic Flood Risk Solutions”. The regeneration of the town centre retail sector would be greatly enhanced by reduced parking charges and part of Commercial Road being pedestrianised to enhance the shopping experience in PW. There is no detail on the delivery of new health facilities, sports hub including outside activities, new primary schools and how and who will pay for these new facilities. Again most of these need to be in place before houses are completed.

Policy STR 3

Masterplanning and use of Compulsory Purchase powers.

With the failure of a “ joined up approach” to the building approved at Church Road, Green Lane & Badsell Road where the present infrastructure is unable to cope it is imperative that a Masterplan is in place for the proposed new 4,000 houses in PW and that it is implemented before they are built and the developers adhere to it and the TWBC monitors its progress.

Compulsory Purchase powers.

With the £90 Million project in Calverley road TW being scrapped it is not good practice to rely on Compulsory purchase orders to ensure new development in PW.

Policy STR 4 OBJECT.

Green Belt Ref 4.47-4.52.

Green belt status should be allocated to the land East of PW to ensure that the adjacent rural villages and PW do not lose their identity to future development. Green open spaces provide wildlife corridors and maintain our rural identity

Policy STR 5 OBJECT.

Essential Infrastructure and Connectivity.

Transport.

The country lanes and residential streets in PW are already clogged with commuter cars and heavy lorries. The Maidstone road with 900 homes already approved would have increased traffic from 4,000 new houses and any new houses to the East would create “ Rat Runs” in our narrow country lanes. There needs to be a new ring road from the East to the North of PW and a new road to relieve the centre of PW.

The railway station at PW will not be able to cope with the new proposed development resulting in over crowding. Detailed discussions need to take place with Network Rail to ensure that the rail way infrastructure can cope in PW.

Water

It is clear that these 4,000 new houses need water supplies but there is no detail how this will be provided. South East Water need to submit real proposals to fulfil this requirement and give information and costs to the Masterplan.

The present surface and foul water network infrastructure can clearly not cope with the increased surface water flooding and the resultant leakage of sewage onto roads and residents property in the Town. Greg Clark MP for Tunbridge Wells has intervened concerning this problem with Southern Water but at present Southern water have not submitted any real solutions to the problem. It is common sense to provide a new Foul water ring network around PW to relieve the present problems and plan for the new 4,000 houses. A new Sewage Treatment centre should be provided on this new ring network or the present one expanded. The issue is, who pays for this in the future before the new houses are built.

Health

The healthcare facilities in PW will be stretched with the present agreed 900 new houses and will not cope with 4,000 new houses. The present Health care centre at |Woodlands will be unable to manage the potential new patients and it has ready taken on the patients that live in East Peckham. A new health centre is required to deal with increased dental, and social care provision and should be mentioned in the Draft Plan..

Policy STR 6. OBJECT.

Transport and Parking.

As already mentioned to increase foot fall to our retail centre new free parking needs to be introduced and a joined up public transport network that offers on time reliable services at a reasonable cost.

Policy STR 7 OBJECT.

Place Shaping and Design.

As regards the type of build no mention is made of the use of renewable energy and the TWBC policy on the issue. The draft plan should insist that all new houses have solar panels installed and electric points for recharging electric cars in the future. Also an alternative to gas fired boilers to provide central heating should be mentioned..

Policy STR 8 OBJECT.

Conserving and enhancing the natural, built, and historic environment

Mature trees and hedgerows need to be protected as also our adjoining woodlands to protect our wildlife and enhance the country side around the new houses. |This will reduce the risk of flooding and increase the air quality in the environment. Mitigation of replacing trees can take years to mature and should be incorporated in the Masterplan to ensure our country side is protected.

DLP_2831

Helen Parrish

Cross-referenced, detailed, reasons for my Objection:

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

The figures used are out of date and not imposed by the Government as TWBC state

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

The distribution of Housing Allocation so uneven throughout the Borough

TWBC should build on areas of land with no Green Belt, No Flood Plain, No AONB locality and not next to Tonbridge

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

TWBC want to create a ribbon-develop from Tonbridge to Paddock Wood

TWBC cannot ensure agreed levels of affordable housing to Local Residents – especially if Hadlow Estate controls the development – as developers cite economic conditions preventing promised financially viable development of such Affordable Housing

There are no accurate analyses of the housing needs for Tudeley and Capel

DLP_3014

Cranbrook Conservation Area Advisory Committee

COMMENT -OBJECT

INAPPROPRIATE SCALE OF DEVELOPMENT

The scale of new housing planned for Cranbrook is out of proportion with 800 houses planned for Cranbrook, 115 for Sissinghurst plus windfalls making over 1000 new dwellings in the plan period. This represents a 35% increase in households on the current number of households (2741 in 2011 Census) ! This cannot be absorbed or integrated satisfactorily as twentieth century planning can show us - think Swindon or Harlow new town. There is also added pressure on schools, services, doctors’ surgeries plus the extra car journeys generated.

As TWBC Cllr McDermott allegedly reported to the Cranbrook PC meeting in August 2019 the housing numbers for Cranbrook and Sissinghurst are arbitrarily based on the number of sites which came forward under the Call for Sites process. He said that if no landowner had put forward sites very little housing would be allocated ! TWBC can hardly claim that this is a scientific needs based process on what Cranbrook or Sissinghurst need in housing terms.

DLP_3016

Cranbrook Conservation Area Advisory Committee

SECTION 2 2.44; SECTION 4 4.69; SECTION 4 4.70

AGREE with the aims set out in these sections

COMMENT

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

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

DLP_3017

Cranbrook Conservation Area Advisory Committee

SECTION 4 4.38; SECTION 4 4.59

COMMENT

NON SUSTAINABLE DEVELOPMENT

Too much of the growth in housing is being targeted at small towns and villages like Cranbrook, Sissinghurst and Hawkhurst. This is not sustainable in transport terms under the NPPF, as people will need to commute to larger towns for employment and other activities. As buses are limited and expensive, this means inevitably more travelling by car on already clogged roads.

Growth should be concentrated in larger towns. The small hub of economic activity proposed for Hawkhurst is not likely to meet the employment needs of many existing or new residents, who would have to use their cars to access it in any case.

The housing targets proposed for rural areas under this Plan are NOT based on local needs, which could be integrated but exceed it substantially, as discussed under 4 4.7.

DLP_3020

Cranbrook Conservation Area Advisory Committee

COMMENT

CULTURE: There is no mention of the significance of Sissinghurst castle or the 3 Conservation areas of Cranbrook, Sissinghurst and Wilsley. Nor is there any recognition of the many festivals and events that contribute to the character of the Weald (eg Apple Day, Nuts in May, Britain in Bloom etc) and which attract locals and visitors alike.

DLP_3197

Mr Peter Bird

What happened to development down the A21 corridor?

No mention of social housing thats a real need.

DLP_3544

Lynne Bancroft

The Local Plan states that the development strategy for housing growth needs are based on Option 3 (dispersed growth) and Option 5 (stand alone garden settlement).

I agree with this strategy overall but the dispersed growth option does not appear to have been applied fairly or proportionately across the borough. The eastern area of the borough, in particular Cranbrook and Sissinghurst, has much more housing allocated to it compared to a proportionally very small number of houses to be developed in Tunbridge Wells. This is contrary to policy ED 8 which states the hierarchy of development.

The Local Plan states that Tunbridge Wells is to be the economic and cultural centre so it should take more housing proportionate to its current population and additional housing due to its economic opportunities than is currently proposed. Given there will no longer be a new theatre then this area could be used to supply affordable housing.

Sissinghurst has poor connectivity with Tunbridge Wells due to a slow, infrequent no. 267 daytime only bus service that does not even directly serve the village, or via the infrequent No. 5 bus service and 2 trains via Staplehurst station or via the congested A21 through the often gridlocked village of Goudhurst.

DLP_3545

Lynne Bancroft

If housing is to be developed on a dispersed growth basis then employment opportunities through the economic growth strategy should also be on a dispersed growth basis to match increases in population and to minimise additional journeys, via public transport or car.

TWBC should not put such large quantities of housing in Sissinghurst and Cranbrook without additional economic opportunities and should have a policy to provide additional business sites, other than those already shown in the Local Plan, in The Weald. This particularly important due to the poor public and road transport system for this area in getting to Tunbridge Wells.

DLP_3546

Lynne Bancroft

This states that the growth strategy is based on the premise of infrastructure-led development. Key infrastructure required for additional housing in Sissinghurst includes greater accessibility to Tunbridge Wells on a dualled A21 between Lamberhurst and Blue Boys. This infrastructure is not in place and will not be in place before the housing in this plan is developed so the Local Plan is obviously not infrastructure led.

To be an infrastructure led Plan then much more development should be around Tunbridge Wells and the already dualled A21.

DLP_3547

Lynne Bancroft

I agree with the facilitation of sustainable transport for both pleasure and work requirements. This must include public transport in the evenings as well as the day for all villages connecting to towns, including those outside of the Borough such as Sissinghurst to Tenterden as well as Sissinghurst to Tunbridge Wells and Maidstone. The Borough should encourage cheaper and more frequent public transport to encourage additional useage, especially in the rural eastern areas of the Borough.

Strategic bus and rail services should be improved firstly for those residents who wish to travel within the Borough.

However, due to the rural nature of the eastern part of the borough, particularly Cranbrook, Sissinghurst and Goudhurst road improvements need to be made also as the A262 is congested in Sissinghurst and Goudhurst and the A21 between Blue Boys and Lamberhurst is also congested.

DLP_3548

Lynne Bancroft

As most transport is by car in the rural areas of the Borough, additional car parking on any new development must be provided, over and above that shown in the Plan as walking round any recently occupied development demonstrates the inadequacy of these levels, particularly for visitors.

DLP_3549

Lynne Bancroft

TWBC should allow more weight from Neighbourhood Development Plans (NDP) at any stage of their development regardless to whether they completely line up with the TWBC Local Plan and the Local Plan should never take precedence over NDP’s as the NDPs will have greater local knowledge of the area or item concerned.

DLP_3550

Lynne Bancroft

A further/separate Limits to Build Development (LBD) within Sissinghurst is not acceptable as it has only been put in place now to allow TWBC to put more housing in the area. The new LBD around Wilsley Pound and Mill Lane will start to connect two previously separate settlements (Mill Lane and Wilsley Pound) as TWBC policy will then allow infilling as shown in their assessment of Site 54 Policy AL/CRS 13 (land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road). This site has been assessed in the Cranbrook and Sissinghurst draft Neighbourhood Development Plan and development here is not supported by them so should not happen. This infilling is not acceptable in a newly defined LBD especially given the rural and historic nature of Mill Lane. Mill Lane is part of Sissinghurst Village and not Wilsley Pound and should not be included in the new LBD

DLP_3868

Mrs June Bell

The DLP fails to demonstrate confidence in Neighbourhood Plans, made or in progress and my concern is there is lack of due regard for Neighbourhood plans.

Reasons for comment:

These paragraphs do not confer confidence that TWBC will follow its legal duty as identified in the Localism Act to allow communities to make meaningful decisions over scale and location of development and policies to preserve and enhance their communities. Hawkhurst has a ‘Made’ (passed successful examination by independent Inspector) and locally endorsed Neighbourhood Plan.

DLP_4050

Roberta Neale

I support fully all the comments made by Brenchley and Matfield Parish Council in its excellent submission.  Given the proportion of Green Belt and AONB land in our area it is difficult to understand why the Council has accepted the Government’s unsound housing targets and furthermore concentrating development in the northern arc.  This surely makes Tunbridge Wells a target for future housing development as envisaged in the plans for Capel and Tudeley.  In fact this is envisaged in the reference to keeping targets under review in the following paragraph.  That can mean increases as well as decreases.

I feel that the Council is letting down the existing residents of the area and I find it hard to understand how the Council thinks it is protecting the AONB and historic and cultural heritage viz the developments at Tudeley and Capel where both communities have exceptional churches both widely recognized as such.  The ambience of these buildings will be destroyed if they are engulfed in new housing developments.

DLP_4441
DLP_4435

Nick Lucas
Mr James Rourke

TWBC: the standard response was submitted by the list of responders on the left:

TWBC does not need to accept the levels of housing proposed by the government. 70% of the borough is protected as an AONB, and National Policy allows for development to be reduced where valued landscapes can be damaged (NPPF, Paragraph 11).

By not getting housing numbers reduced, TWBC has created a draft local plan that has proposed major developments within the AONB, which is contrary to Policy EN21 which states that the High Weald AONB is one of the best surviving medieval landscapes in northern Europe. The NPPF states ‘great weight should be given to conserving and enhancing landscape and scenic beauty in the AONB. The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development, other than in exceptional circumstances’. Case history has proven that housing need alone does not equal exceptional circumstances.

We would ask that TWBC assess the harm that cumulative development can do to the AONB Landscape and its communities, and argue for lower housing numbers as a result.

DLP_4574

Keith Stockman

4.19 In particular, the ENS recommended that expansion of the existing Key Employment Areas would be appropriate, at North Farm/Longfield Road in Royal Tunbridge Wells, around Maidstone Road in Paddock Wood, and at Gill's Green. Additionally, it recognised the area around the A21 highway improvements as a location for significant employment growth potential, subject to further investment. The importance of Royal Tunbridge Wells town centre is also recognised in terms of existing and future office provision, and the requirement to retain existing, well located, modern office stock within the centre.

One must question why such a large proportion of housing is being targeted in Cranbrook and Sissinghurst given the expansion of existing key employment areas outlined above. All of these would necessitate travel by car on already crowded roads.

4.40 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.

There should be no large scale development unless exceptional need is proven, which it most definitely is not in the Parish of Cranbrook and Sissinghurst. The development proposed in Cranbrook and Sissinghurst is not sustainable in terms of infrastructure and nor is it ‘aware of the valued and protected landscape.’ i.e. the AONB status. There is absolutely no need to put large scale development on AONB when NDP research has shown that the housing numbers can be delivered more sensitively and appropriately in small scale, sustainably designed developments that do not impact the AONB landscape in the same way that large estates do. Local research from the NDP group also indicates that the parishioners are unanimously against large scale development.

national policy allows for development to be reduced where valued landscapes can be damaged (NPPF, Paragraph 11).

Clearly, the large scale development proposed (all of which is on AONB land) will damage the valued AONB landscape. Development must be reduced to ameliorate this impact.

62% of the Parish of Sissinghurst and Cranbrook is AONB.

DLP_4578

Keith Stockman

4.7 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 methodology as required by the NPPF(20)

It is true that more homes are needed in the Parish of Cranbrook and Sissinghurst. However, the independent research commissioned by the NDP, which proves that this need can be delivered by small scale housing developments, has been totally ignored by TWBC.

DLP_4581

Keith Stockman

4.40 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.

The development proposed is neither small scale nor sustainable and exceeds the local need hugely. Development of the scale proposed in the AONB pays no regard whatsoever to protection of the landscape.

DLP_4762

DHA Planning Ltd for Caenwood Estates and Dandara

3.3 Development Strategy and Strategic Policies

Context

3.3.1 The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the borough and where that development will be located.

3.3.2 In terms of the amount of housing, paragraph 59 of the NPPF states that to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient quantum and variety of land can come forward where it is needed. Furthermore, to determine the number of homes needed, strategic policies should be informed by a local housing needs assessment conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.

3.3.3 The Council confirm that their housing need target for the plan period 2016-2036 is 13,560 dwellings (678 dwellings per annum), which is calculated using the Government’s standard method and the 2014-based household projections.

3.3.4 In terms of the different supply components, the Council considers that the Local Plan must (as a minimum) include additional allocations to accommodate 7,593 homes. This figure was formulated taking into account:

  • completions since April 2016 (1,552);
  • extant planning permissions (3,127);
  • outstanding site allocations (588); and
  • a windfall allowance (700 dwellings).

3.3.5 The Council has applied a 10% non-delivery rate to these figures to err on the side of caution and consider that the plan would exceed the minimum housing requirement if all of the supply components were achieved. However, given the Plan’s reliance on large strategic sites, and the potential for delays in delivery as set out in our representations, we suggest it may be advisable to increase this buffer to ensure that the Council is in a position to meet its housing delivery targets throughout the plan period. If not, there is the risk of unplanned, speculative schemes coming forward.

3.3.6 We commend TWBC for seeking to meet their need in full and support this positive approach to plan-making. Likewise, we support the general thrust of the development strategy, which proposes a strategy to meet the housing needs of the borough with a dispersed growth approach.

[TWBC: seefull representation].

DLP_6750

Mrs Carol Richards

The development strategy – para 4.1

This opening statement ‘aims to set out proposals for the spatial distribution of development throughout the borough. The Local Plan is to plant 63% of TWBC housing needs between 2016 and 2036 in one long area along the boundary of its borough. How can this be throughout the borough? The plan places the burden of thousands of homes in one area-between Tudeley and Paddock Wood. This principal aim as stated in 4.1 is therefore clearly not TWBC’s intended aim. It’s aim is to concentrate the main thrust of its housing strategy in one long strip to the north of the borough, away from Tunbridge Wells. It is Totally unacceptable and unsound.

This is not as stated in 4.6 pt 2 ‘ a borough- wide spatial development strategy’

Housing Development – para 4.7

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.

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”.

TWBC has chosen to accept the government’s housing need for Tunbridge Wells borough based on the standard method of calculation. However, TWBC knows that the ONS 2016 figures show a smaller housing need, as does the more recent 2018.

TWBC can protect this 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. TWBC could reduce the number of houses delivered by the Local Plan and could plan the houses it does build -more evenly around the borough i.e. more spatially distributed and not in AONB and not in green Belt

Economic Development – paras 4.18-4.20

The rationale TWBC are following is to protect the A21 corridor as a Key Employment Area, which given the now excellent road is a very good idea. The ENS study/report states by helping to’ support the creation of new employment opportunities alongside the provision of new housing’ this would in turn help to reduce out- commuting. As one of the major requirements for a garden village is to provide employment within the village, (reducing carbon emissions)-surely placing more housing development closer to the A21 corridor and the Key Employment Area- is what should be in TWBC’s Local Plan - not a ‘Masterplan’ to develop Tudeley, Capel and Paddock Wood.

N.B. Providing industrial development in the designated North Farm site- of which a tiny part is in Capel Parish- does not count as Capel Parish employment. It is a long way from TWBC’s proposed ‘garden village.’ and divided by the A21

The Development Strategy

Formulating preferred options – paras 4.28 – 4.31

I refer to the Distribution of Development Topic Paper, in which

* In para 2.7, the study findings indicate that larger settlements tended to score more highly across the range of sustainability indicators.

* In para 2.8, there is a consideration that larger settlements may be restricted by environmental/infrastructure results and smaller settlements may become more sustainable.

Yet nowhere in Table 1 is there a mention of Tudeley. It is also worth noting that Five Oak Green sits with Goudhurst, Lamberhurst and Brenchley and yet Five Oak Green with the potential to flood is picked above all other towns in section B and the same goes for Paddock wood in Group A.

For the same reason that Tunbridge Wells and Southborough are restricted by constraints- is not Tonbridge? The logic of placing 2800 homes on the doorstep of Tonbridge is not sound.

4.29
Seemingly, without taking account of the Distribution of Development Topic Paper, TWBC has come to the conclusion that Option 3 of Table 2 and Option 5 will form the basis of TWBC’s Strategy.

However, placing 63% of the housing need from Tudeley (with a garden settlement-option 5) and stretching to Paddock Wood- hardly constitutes ‘development distribution proportional across all the borough’s settlement’- Option3.

The most concerning and subtle wording in Table 2 states, “A new settlement ………providing future development needs of the borough”. This apparently innocuous comment implies the addition of more and more houses- coalescing from Tonbridge to Five Oak Green and eventually to Paddock Wood forming a housing corridor to the North of TWB. Totally against para 134b of the NPPF.

I personally find this Draft Plan totally unsound. It is a disgrace to TWBC and the underhand manner, in which it has been dealt with locally is shameful i.e. the total lack of information in Tonbridge public spaces. If the inspectorate would like to know more about this matter and other matters, a conversation with the Save Capel Group would inform her/him of the relevant details.

Figure 4 Key Diagram page 41

This map should have a title, such as “The Proposed Distribution of New Development in TWB, also showing the extent of AONB and Greenbelt”.

The key to the map shows development sites in purple and the size of the circle indicating the size of the development. The Tudeley circle represents 1000 when in fact it should represent the ‘Garden Village’ of 1,900 homes i.e.it should be nearly 2 times the size of the circle representing 1000 homes- in fact for the full 2.800 it should be 3 times the size. As it is one of the main features of this Draft Plan, it should be more accurate. The only problem with that is there would be an almost solid line of large purple circles along the top of the map and this would not look- as if option 3 Dispersed growth was part of the Draft Plan. Perhaps more attention should be given to making a more accurate map, showing the true extent of the Tudeley/Capel/ Paddock Wood/ development and giving it a proper title.

This map however does usefully show the building constraints within the borough because of the large Areas of Outstanding National Beauty and the Green belt. A total of 70% of the area. However, what is not easy to see is the extent to which the Tudeley/ Capel/ Paddock Wood area is affected by the River Medway. This is shown on p8 Fig4 Titled Flood Risk Zones (taken from (SFRA) in the Distribution of Topic Paper for the Draft Local Plan.

These two Maps together - overlaid would show what should be considered further constraints to the Draft Plan.

A further map which should also be included is a Contour Map, overlaid by the Flood Risk Zone Map showing the low- lying land and how flat this area is!

This combination of information would demonstrate the “inappropriate development in areas at risk of flooding” para 155 of the NPPF-which goes on to state development “should be avoided- by directing development away from areas at highest risk (whether existing or future)”.

We are all aware of the impact of Climate change and the risk of the higher frequency of flood water- which will increase and therefore the risk to this area in the future is very great.

All of these Maps do visibly show, very easily, how unsuitable this proposed corridor of development is and how TWBC has failed to seriously look at alternative sites that are for example- in a far safer area, not in Green Belt and not in an AONB. There are other sites but TWBC have not looked at them seriously. The idea of a substantial garden village anywhere in this borough is unsound. Given the Constraints of ANOB, Green Belt and an aging population, Options 2 and 4 are a far better approach- far more work of course. but would keep the essentially Rural nature of the borough (Table 2 Local plan options (Issues and Options consultation 2017).

The only other approach is to look at Horsmonden and perhaps Frittenden- both outside ANOB and Green Belt and the flood risk is less and therefore more future proof.

DLP_8190

Mrs Suzi Rich

TWBC has interpreted its housing need figure to be 13,560. For various reasons, the dLP proposes that even more houses are built, a figure of 14,776. I object to this figure for the following reasons:

· The latest calculations show that much less housing is actually needed;

· Tunbridge Wells Borough is heavily constrained by the Metropolitan Green Belt (MGB) and Areas of Outstanding Natural Beauty and many other constraints;

· The Ministry of Housing, Communities and Local Government makes it clear that the housing need figure is not a mandatory target;

· The NPPF is clear that only in exceptional circumstances may a Green Belt boundary be altered, through the Local Plan process.

TWBC has based its housing need on the standard method of calculation without challenge. This is despite knowing that the ONS 2016 figures show a smaller housing need and that policy will reflect that in due course. Why build more houses than Tunbridge Wells Borough needs? Why not protect areas of MGB and AONB by following NPPF guidelines?

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

DLP_8191

Mrs Suzi Rich

TWBC has suggested that its development strategy is based on dispersed growth but the dLP is almost entirely dependent on the successful implementation of proposed garden settlement in Tudeley (AL/CA 1) and the expansion of Paddock Wood which includes development within East Capel (AL/CA 3 & AL/PW 1). These two developments form 63% of the new housing.

The development at Tudeley (AL/CA 1) is referred to as securing a long term option for the borough to deliver the needs of future generations. This makes it clear that the plan is to add more and more housing to this “garden settlement” in each five year review of future Local Plans. The MGB in this part of the Borough should be protected from further development and Capel Parish is no place for a ‘garden settlement’.
The proposed developments at Tudeley (AL/CA 1) and East Capel (AL/CA 3) are totally unsustainable due to the lack of public transport options and poor road infrastructure. The proposed measures outlined in the SWECO Transport Evidence Base are not sufficient to mitigate the effects of the proposed developments.

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

DLP_43

Thomas Weinberg

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 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 this Council to protect this 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”.

DLP_44

Thomas Weinberg

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

You are proposing a development strategy based on dispersed growth, i.e. proportional distribution of development across all of the borough’s settlements and yet over 60% of new housing will be in the settlement in Tudeley and the expansion of Paddock Wood including building on East Capel.

This is therefore inaccurate or misleading.

DLP_45

Thomas Weinberg

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

You have used NDAs to hide your plans until it was too late for residents to have a fair say. Hadlow Estate have offered one letter to residents and evicted residents to raise funds to pay their masterplanning consultants as their form of “community engagement”.

This is anachronistic feudal behaviour which cannot but be interpreted as deliberately opaque. Without due care or due process you are inflicting fear and misery on residents of three historic hamlets.

DLP_49

Thomas Weinberg

Comments on Section 4 Paragraph 4.49 (The Green Belt) p.49

Exceptional Circumstances do not exist to justify releasing any land from the Green Belt in Tudeley and East Capel.

As you will see from my comments on the Sustainability Appraisal, options for the expansion of Paddock Wood need not include East Capel.

The release of Green Belt for Tudeley New Town is totally unjustifiable.

The development described in this Local Plan will be contrary to the aims of the Green Belt, for example in terms of urban sprawl and coalescence of settlements. It will result in the development of highly valued countryside and the erosion of this buffer between settlements.

The development will be widely visible from the surrounding countryside and landscape and from existing residential areas and heritage assets in Capel. It will be visually prominent and urbanise this attractive rural area.

TWBC’s own assessment of the “broad areas” in which all the Capel Parish sites lie is that there is a very strong case against allowing any land within them to be withdrawn from the Green Belt. This is based on reports commission by TWBC from “Land Use Consultants Ltd” in 2016 and 2017.

DLP_50

Thomas Weinberg

Comments on Section 4 Paragraph 4.50 (The Green Belt) p.49

You state that the Distribution of Development Topic Paper (which draws on the Green Belt Strategy Study) provides evidence and justification to release land from the Green Belt at Tudeley. This is not true. There is no evidence that makes Tudeley a better site for a Garden Village than Horsmonden.

The justification for not placing a garden settlement at Horsmonden is that “This would be a very large scale strategic allocation that would be disproportionate to the size of the settlement, with concern about landscape and heritage”.

Tudeley is a tiny hamlet. It has 50 houses at most. The whole of the Parish of Capel has only 950 houses in it. Adding 2,800 new houses at Tudeley is a massive increase that will fundamentally alter the nature of the communities involved for the worse.

Tudeley is home to a world renowned heritage asset – All Saints Church. The only church in the entire world to have a complete set of stained glass windows designed by the renowned artist Marc Chagall.

The only heritage asset at Horsmonden is a gun foundry. Its 13th century church is nearer to Goudhurst, well outside of the village. It has an active bus route linking it to Tunbridge Wells and Paddock Wood. It has a disused railway station. Horsmonden is not in the Green Belt or AONB.

Tudeley has a beautiful, rolling landscape with abundant wildlife, fertile soil and high biodiversity scores. It is entirely within the Green Belt and the High Weald AONB is within a few yards of the proposed development site.

You state that Horsmonden has severe access difficulties. The access difficulties at Horsmonden pale in to insignificance when you look at the access difficulties on the B2017 and Hartlake Road.

You do not have the exceptional circumstances required to justify building at Tudeley rather than Horsmonden. The only argument presented anywhere is that Tudeley has a single landowner and Horsmonden has multiple landowners.

TWBC’s reluctance to deal with multiple landowners is not an “exceptional circumstance”.

It should be noted that the Leader and Deputy Leader of the Council both have personal interests in keeping the garden settlement out of Horsmonden due to the impact on their wards (they both represent Brenchley and Horsmonden). The Deputy Leader lives in Horsmonden at Swigs Hole Farm.

DLP_55

Thomas Weinberg

Comments on Section 4 Paragraph 4.87 (Limits to Built Development) p.62

You have not provided any detailed LBD information for Tudeley or East Capel, citing “the need for further masterplanning”. This plan is therefore not ready for Public Consultation.

DLP_89

Roger Bishop

The Development Strategy Section 4 - para 4.16 - p35

TWBC has chosen to accept the government’s housing need for Tunbridge Wells borough based on the standard method of calculation, i.e. 13,560, and then increased it to 14,776.

However, the Government has made clear repeatedly that the housing need figure is not one that a local authority is required to meet. It is simply a starting point in assessing need. Even when the need has been determined, planning to meet that need requires that land availability, and relevant constraints, including Green Belt, AONB etc be fully considered. For example, Jake Berry (Minister DHCLG) stated in April 2019 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. (My emphasis)

NPPF makes clear that a local authority can declare that the Government’s housing need figure is unachievable.

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

DLP_90

Roger Bishop

Development Strategy of the Draft Local Plan – para 4.38 – p39

Reference is made to “dispersed growth” and site allocations for housing “located at the majority of settlements across the borough”.  This is highly misleading given the planned dumping of over 25% of the total new houses in one parish, Capel..

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

DLP_125

Gregg Newman

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

Representations have, I understand, already been made to you in this respect, but to reiterate - 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.

You have chosen to accept the government’s housing need for Tunbridge Wells borough based on the standard method of calculation.

You know that the ONS 2016 figures show a smaller housing need and that policy will reflect that in due course.

You know that you can protect this 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:

  1. 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
  2. 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.

DLP_126

Gregg Newman

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

Your stated development strategy based on dispersed growth is cynically phrased to imply it is being achieved through numerous means. However the Local Plan is almost entirely dependent on the successful implementation of proposed garden settlement in Tudeley and the expansion of Paddock Wood including building on East Capel. They form 63% of the new housing.

This appears to be a very risky strategy and intentionally misleading to voters and the public at large.

DLP_127

Gregg Newman

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

As a resident of Hadlow, this plan lays bare the naked truth. This will become a large conurbation, with huge adverse effects upon residents of areas outside of Tunbridge Wells, but also with no real benefits to TWBC residents either.

DLP_302

Janet Sears

The housing target of 300,00 based on ONS 2014 calculation should be challenged. If these targets are reduced to 160,00 in line with the ONS recommendations of 2016 the destruction of our precious landscape, wildlife and for many residents way of life could be reduced. Surely we have learned from the problems we are now experiencing from the use of plastics which were seen as the way forward at the time. If we destroy our countryside by building houses and all the associated infrastructure there will be no going back.

DLP_854

Ian Pattenden

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

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.

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”.

You have chosen to accept the government’s housing need for Tunbridge Wells borough based on the standard method of calculation.

You know that the ONS 2016 figures show a smaller housing need and that policy will reflect that in due course so you should use it now and offer this as your compromise to protect the green belt.

You know that you can protect this 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:

  1. 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
  2. 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 and have offered no explanation.

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

You are 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 proposed garden settlement in Tudeley and the expansion of Paddock Wood including building on East Capel. They form 63% of the new housing which in my view is NOT DISPERSED GROWTH. 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. There are multiple major issues to be overcome with the proposed development, further underlining the enormous gamble TWBC are taking with this proposal. I object to such a gamble being taken on our precious green belt countryside.

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 clear 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. 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. This is urban sprawl something the green belt is in place to stop.

You have used NDAs to hide your plans until it was too late for residents to have a fair say, no local community engagement and somewhat sleezy. Hadlow Estate have sent us a sickening, self-serving and hypocritical letter trying to “justify” their appalling actions which is crass in the extreme, there is only one objective by this land owner…..grab the money and get out of farming. This important land asset deserves your protection and you as public servants have a duty to maintain it for future generations.

DLP_954

Mrs Karen Stevenson

The draft Local Plan sets out the policy framework in which the Borough Council will make planning decisions and deliver development to meet its housing target within the Plan period, 2016-2036. TWBC appear to be accepting without challenge the top-down target set by central government of 13,560 homes (in fact TWBC are proposing to set their own target actually 9% above this level at 14,776 homes).  This is based on the objectively assessed housing need for the borough over the plan period, identified by the standard methodology as required by the NPPF. Yet this methodology is flawed, being based on historic data and despite their being considerable wealth of information available to argue that this is not correct. Many other local authorities including Sevenoaks, Guildford and Uttlesford to name a few, have taken the initiative to seek a reduction of these numbers based on a more pragmatic approach based on local need and capacity.

One such piece of research which raises challenge to the out-dated approach in setting housing targets, is a paper published by UK Collaborative Centre for Housing Evidence – entitled: Tackling the UK Housing Crisis – is Supply the Answer, written by Ian Mulhern Aug 2019. (This examines and challenges the thinking that by building more house prices will come down).  Is the problem not so much a housing shortage but a housing affordability crisis?

Further to this, the Housing Needs Assessment Topic Paper (August 2019) already states that, the government will be reviewing the methodology for calculating housing numbers in the next eighteen months, because the current methodology it relies on is out of date, based on 2014 projections. The Government reasoning for continuing to use these, on an interim basis, is to provide stability and certainty to the planning system in the short-term. So these numbers should not be taken as a mandatory target for TWBC to plan for, but a starting point only.

The standard methodology is, therefore not mandatory. The target that the Plan aims to achieve could be far higher than it needs to be. It is not appropriate for the Council to adopt its ‘wait and see’ position, which could lead to its policy framework being based on a false target. The Plan needs to be based upon the most realistic assessment of need, taking into account the constraints that characterise the Borough.

Further, as 70% of the borough comprises AONB or Green Belt, which are supposed to be protected landscapes, there are further reasons why the overall number should be challenged. Such levels of development as are proposed in this draft local plan, will cause irreparable damage to the local environment.

In fact Paragraph 4.8 specifically notes that Sevenoaks District Council is not proposing to wholly meet its housing need. If, as the Plan states, the constraints that apply to Sevenoaks District Council are similar to those of TWBC, why isn’t TWBC also challenging their housing target based on standard methodology and/or proposing to not wholly meet the need identified through this method? Isn’t there a case to argue that the constraints that apply to TWBC (the extent of AONB and Green Belt land in the borough and notable affordability pressures potentially causing a fall in home ownership) constitute “exceptional circumstances”, which could justify an alternative approach to assessing housing need according to NPPF paragraph 60?

I will come to the more immediate issue of the allocation for the Parish of Brenchley and Matfield of 91-150 dwellings, further into this response document.

DLP_1102

Mr John Hurst

Section 4 - The Development Strategy

It is recommended to include in the DLP the distribution of the 3,127 dwellings that already have Planning Permission (line 3). It is currently impossible to see where they are, is greenfield or brownfield, and within or without the Green Belt.

The DLP leaflet's central diagram only records about 692 dwellings in the "already have PP" category.

Overall, same comments as for STR1 apply, ie challenge the number of new dwellings "needed".

DLP_1628

Maggie Fenton

Repeated use of the phrase “To be determined as part of masterplanning” in reference to Paddock Wood, Capel and Tudeley is ridiculous when it refers to 63% of the houses in this Local Plan. You are asking residents and businesses to consult on a largely incomplete draft. Other regions may have Local Plans that do not have a complete map of roads and other infrastructure but they omit complete infrastructure specifications for minor parts of their plans – not for the majority of their plans. This is a gaping hole in the draft Local Plan. It is therefore unsound

DLP_1690

Brenchley and Matfield Parish Council

2. The Local Plan Development Strategy

a. We are not convinced that the case for the approach of dispersed growth across the borough has been soundly made. It is too far removed from the aims of the adopted Core Strategy which recognizes that rural settlements, such as those in Brenchley and Matfield, are least able to support sustainable development. The majority of responses to the five strategy options set out in the Issues and Options consultation did not favour dispersal or semi-dispersed growth across the borough. Crucially, dispersed growth would not conform to the requirements of the National Planning Policy Framework (NPPF).

b. Attention is drawn to paragraphs 102 and 103 of the NPPF (February 2019) which concern the need for plans to locate development so as to reduce the need to travel and to increase the scope for walking, cycling and public transport. In addition, paragraphs 171 and 172, which seek to conserve and enhance Areas of Outstanding Natural Beauty (AONBs) by limiting the scale and extent of development within such designated areas: 77% of the parish is with the High Weald AONB. Accordingly, the Parish Council objects to the dispersed growth strategy for housing development, as set out in the Draft Local Plan. This is because it directs a disproportionate amount of growth to rural settlements with limited facilities and jobs, and with poorer access to public transport. These rural settlements have higher dependence on the private car and access to them is generally along low capacity rural roads and lanes.

c. The issue of a high dependency on the private car highlights a significant weakness in the strategy. It can be argued that whilst a number of the general policies in the DLP (for example STR6 and EN2) are aimed at reducing car dependency, one of the effects of the dispersed growth strategy would be to substantially undermine the intentions of those policies.

d. It is extremely disquieting to read in Section 3 of the Development Constraints Study (DCS) that “as it stands, there is not yet the evidence in place to arrive at a definitive conclusion as to how highways capacity could impact on the development strategy for the new Local Plan. The Council will work with its partners, including Kent County Council and Highways England, to carry out relevant technical work and assessments…” From that statement it is assumed the reverse is also not quantified - that is, the impact of the adopted development strategy on the highways capacity is similarly not known. This is a significant weakness in the DLP and raises questions over the deliverability of the planning strategy.

e. A further significant weakness is the incomplete Infrastructure Delivery Plan (IDP). It is disappointing to note in the column marked “Expected Funding Gap” that the contribution of all of the third-party agencies is given as “TBC”. Residents and businesses cannot see how the DLP can be considered credible and deliverable without an IDP specifying core infrastructure assets being in place and ready by construction or occupation of the first phase of house-building.

f. Given the situation with the IDP, we would urge TWBC to quantify the impact of the proposed developments on the residents and businesses in Brenchley and Matfield. In particular: the prospect of increased congestion at the junction of A21 and the B2160 at Kippings Cross; the B2160 through Matfield; and other roads that would be affected by proposed developments in Paddock Wood and Horsmonden.

g. The most significant consequence of the policy of dispersed growth is that the area covered by five local councils in the north-east of the borough would take the lion’s share of housing development. An arc, roughly comprising Horsmonden, Brenchley and Matfield, Paddock Wood, Capel, and Pembury, has been allocated in excess of 7,000 units. However, we cannot find any acknowledgement in the DLP that this “quadrant” is to be the focus of the proposed development strategy, or, if so, that it is the priority area for infrastructure investment. Nor is there any indication of the cumulative impact of development across the arc. Whilst it is recognized that a master-planning approach would be taken in the development of the strategic sites, this does not go far enough in dealing with such issues as the social, economic, and environmental infrastructure needed to support development on that scale.

h. There is also no indication that the potential coalescence of settlements and parishes has been properly addressed. An obvious example of this is the proposed extension of Paddock Wood into Capel. Within Brenchley and Matfield we are concerned that it appears (on a map on p.174) that Mile Oak, one of the historic hamlets in the parish, and a section of Chantlers Hill, would coalesce with new development in Paddock Wood – both of which would be vigorously resisted. We are also concerned that the extent of development to the south of Paddock Wood could erode the size of the gap in the landscape which separates it from Matfield. The development strategy must include the provision of a landscape policy to prevent the coalescence of settlements.

i. In addition to being contrary to the aims of the AONB designation, the proposed development strategy also rides roughshod over policy aimed at protecting the Metropolitan Green Belt. It is not clear to us what the “exceptional circumstances” are that would warrant such an approach. The intention not to replace land lost to development runs counter to the conclusions of TWBC’s own review of the Green Belt, for which no convincing evidence is offered.

j. Given the foregoing, it is clear to us that an adopted policy of dispersed growth would cause the irreversible loss of character and separate identity of some of our villages and hamlets. This will also loosen the bonds of vibrant localities that promote cohesive social interaction and which underpins the well-being of communities. We therefore do not think that the proposed development strategy would be in the public interest and, if implemented, would cause significant harm to both the AONB and Green Belt designations. TWBC is strongly urged to consider retaining a development strategy which continues to recognize the need to protect the rural areas, and which concentrates development in sustainable locations, either in or adjacent to the main urban area (Royal Tunbridge Wells and Southborough), or along transport corridors with high capacity.

3. Mitigating the Impact of Development

a. Should the proposal to concentrate development within the north-east quadrant be taken forward, the Council would argue strongly that it be conditional on significant improvements to the A228 – indeed, we would press for a re-alignment of the road to support the scale of development. It should also be conditional on all other forms of infrastructure, such as water supply, and sewerage disposal and treatment, to be delivered in tandem with development.

b. We would also press for significant development contributions from the strategic sites in Paddock Wood and Tudeley, to all five parishes within the quadrant. This would be to compensate for the individual and cumulative impact on the quality of life – particularly the substantial increase in traffic – on each parish and town.

7. Conclusion

a. We wish to underline the considerable harm that would be done to the rural areas of the borough if the proposed strategy of dispersed development were to be adopted by TWBC. The traffic that it would undoubtedly generate, compared to more centralized/brownfield development in the urban areas with existing rail infrastructure, would severely exacerbate the well-documented pressures in the rural areas. Development on the scale envisaged is unlikely to be sustainable and would fly in the face of current environmental concerns about climate-change and global-warming.

[TWBC: part of whole comment number DLP_1683].

DLP_1726

Peter Hay

The failure to consider the NPPF paragraph 11b i and ii to review the Standard Housing Formula housing figures for the borough as a whole, due to the significant area of the AONB within the borough. Thus the failure to reduce the housing / development within the borough as a whole.

Indeed, TWBC decided to increase it by 900 houses borough wide

The failure to consider NPPF paragraph 172 to maximise the call for sites opportunities within Tunbridge Wells and Southborough prior to allocating housing / development within the AONB.

Inappropriate Distribution of Development Policy

The failure to consider the results of previous consultation where only 8% supported the “Distribution Development policy” proposed by the draft local plan

DLP_1774

CPRE Kent

CPRE Kent – the Countryside Charity - is an independent charity, wholly funded by its members and supporters, which operates under the umbrella of the national CPRE charity. CPRE campaigns to protect, promote and enhance our towns and countryside to make them better places to live, work and enjoy, and to ensure the countryside is protected for now and future generations.

In general CPRE Kent supports a development strategy which meets the following criteria:

  1. Prioritises the redevelopment of appropriate, sustainably located previously developed land.
  2. Does not lead to the loss of green belt, AONB, best and most versatile agricultural land, irreplaceable habitats, dark skies and other designations.
  3. Focuses growth at existing settlements and maximises supply through increased densities at sustainable locations.
  4. Recognises the acute need for affordable housing.

CPRE Kent considers there are good reasons why the Tunbridge Wells Local Plan should not meet its housing requirement in full – reflecting the constraints clearly shown on the policies map accompanying the draft plan, including fact that 70% of the borough is designated AONB, 22% is Metropolitan Green Belt and there are areas of Ancient Woodland outside these protected landscape areas. Additional constraints arise from the location of flood plain, best and most versatile agricultural land, conservation areas and intrinsically dark skies. All of these factors limit the amount of land available for development in the borough, in accordance with the NPPF. Much of the borough consists of rural landscape, valued and designated as such and demonstrating a pattern of settlement and land use of great historical significance. The settings of the various settlements form part of their character and historic interest. The borough’s duties under the NPPF, read as a whole, are not to destroy or damage these features, but to protect and enhance them.

The Housing Need Consultation Data Table that accompanied the Planning for the Right Homes in the Right Places 2017 consultation set out that 75% of the proportion of Local Authority land area was covered by Green Belt, National Parks, Areas of Outstanding Natural Beauty or Sites of Special Scientific Interest.  Of this 93% is in the High Weald AONB.  The NPPF paragraph 172 requires great weight to be given to conserving and enhancing landscape and scenic beauty in AONBs. The Council’s Development Constraints Study October 2016 that a large part of the Borough outside the Green Belt and High Weald AONB is either Ancient Woodland, which NPPF 175 identifies as irreplaceable habitat that should be protected; lies within flood zones 2 and 3, or best and most versatile agricultural land.  Thus well over 75% of the Borough is constrained.

The Corine Land Classification 2012 indicates that around 10% of the borough was built-up.

Given that the High Weald AONB stretches across the whole length of the borough there is the potential that there will be areas of land within its setting.  Planning Practice Guidance paragraph: 042 Reference ID: 8-042-20190721 (revised 21 July 2019) sets out that “land within the setting of these areas often makes an important contribution to maintaining their natural beauty, and where poorly located or designed development can do significant harm. This is especially the case where long views from or to the designated landscape are identified as important, or where the landscape character of land within and adjoining the designated area is complementary. Development within the settings of these areas will therefore need sensitive handling that takes these potential impacts into account.”

The NPPF at paragraph 3 states “the framework should be read as a whole (including its footnotes and annexes).”

Paragraph 11(b) expands on this by stating:

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

This is explained in footnote 6 on page 6 of the NPPF as policies relating to land designated as green belt, local green space, AONB, irreplaceable habitats, designated heritage assets and areas at risk of flooding.

Or “(ii) any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”

If the delivery of housing was the sole objective of the NPPF then paragraphs 3 and 11(b) would have not been included.  Thus, for these paragraphs to be meaningful they will need to be given due consideration during this consultation.

CPRE Kent has concerns about the number of dwellings proposed in the local plan and how these new homes will be delivered.

In the 37 years since 1981/82 an average of 343 dwellings per annum have been built in the borough.  This dropped to 282 for the past 10 years and has risen to 357 for the last five years. Only twice since 1981/82 have more than 686 dwellings per annum been completed – in 1988/89 (761) and 1989/90 (886).

Population change should also be considered in terms of scale of future need. For the period 2001-2018 annual population change averaged 824, while for the last five years it has halved to 392.

This discrepancy between the borough’s OAN and any reasonable estimate of future household formation or housebuilding capacity in the borough is hardly surprising, since the standard methodology for calculating OAN no longer lays claim to being an estimate of local need, based on up-to-date data.

The Government’s published justification for the methodology is as follows: the 2014-based household projections are used within the standard method to provide stability for planning authorities and communities, ensure that historic under-delivery and declining affordability are reflected, and to be consistent with the Government’s objective of significantly boosting the supply of homes.

Leaving to one side the question of whether this represents a legally sound basis for the policy, on which we reserve our position, we would suggest that the artificial and unrealistic nature of the OAN should only add relative countervailing weight to the clear and unambiguous duties of the Council to protect the AONB, green belt, irreplaceable habitats, best and most versatile agricultural land and conservation areas in the borough, and avoid inappropriate development in areas of flood risk.

Research by BuiltPlace into house prices and transactions based on ONS/HMLR house price index demonstrates that falling house prices has not been matched by increased purchases.[1]

CPRE Kent is of the opinion that the option of only partially meeting identified needs has not been considered sufficiently, or at all (paragraph 6.1.8 of the SA), as a reasonable alternative. The only substantive reason given for not considering this option is that sufficient sites came forward in response to the calls for sites to build this number of homes. This ignores the suitability or sustainability of such sites.

Writing off this option doesn’t reflect the conclusions reached with the SA objectives. Table 8 (page 34 of the SA) demonstrates that housing meets only meets five of the 19 SA objectives, and is incompatible with nine of the 19 SA objectives – making it the only objective which is incompatible with more SA objectives, than it is compatible with. CPRE Kent considers that the borough does not have the capacity to meet its housing targets without significant harm to the green belt and AONB and other characteristics of the borough protected by, or worthy of protection under, the planning system.

The Council’s OAN is 13,560 of which 1,552 dwellings have been completed, leaving a requirement of 12,008 to be provided.  Some of this will be in the form of existing permissions, outstanding site allocations and windfall allowance.  The remaining 7,593 will be from new allocations of which 1,900 will be at Tudeley and 4,000 at Paddock Wood.  These two sites will provide 49% of outstanding new housing. In addition, the draft plan not only provides for the OAN, but also an additional 9% buffer. The justification for this is not apparent in a borough where NPPF paragraph 11(b) applies and where the Council has already taken a cautious approach to the likely yield of sites.  For this reason, CPRE Kent objects to the 9% inflation of the housing need figure.

The Housing Supply and Trajectory Topic Paper for Draft Local Plan (September 2019) at paragraphs 4.5.2 and 4.5.3 states that the Council will further engage with developers to review past and future progress of housing delivery; and will ask developers to comment on presumptions about lead-in times and delivery rates.  This indicates that the present housing trajectory is draft. It may well change, and with reliance on just two sites for almost half of the borough’s housing requirement, may not deliver at the anticipated rates.

With regard to build-out rates the Trajectory Topic Paper sets out at paragraph 4.13.4 that national studies for urban extensions in the south of England demonstrate that delivery rates have been in excess of 120 units per annum.  It is not clear which studies are being referred to or when they were published, nor the location and scale of the urban extensions.  Paragraph 4.13.5, again referring to national studies, states that sites will exhibit lower completions in their first and second years before construction on the site becomes established.  At paragraph 4.13.9 gives a build-out rate of 128 for developments of size 1000-2000, and 299 for developments of 2,000+.

Table 9 of the Trajectory Topic Paper (page 27) assumes that build-out for Tudeley will commence 2025/2026 and for the periods 2025/2026 to 2029/30 be 150 dwellings per annum and then rise to 200 dwellings per annum to the end of the plan period delivering 1,750 dwellings.

On page 30 the assumptions for the 4,000 dwellings at Paddock Wood is that 333 dwellings will be delivered from 2024/25 delivering all 4,000 dwellings by the end of the plan period.

CPRE Kent is concerned that if the trajectories prove to be over-optimistic and the Borough fails to meet the housing delivery test, then other precious AONB and green belt countryside will be put at risk.  CPRE questions these trajectories for the following reasons:

  • they do not make allowance for lower completions in the first two years as set out in paragraph 4.13.5; and
  • the Tudeley development is a new settlement and not an urban extension and build-out rates may take longer before they reach the assumed 150 dwellings per annum.

With regard to windfalls Table 10 of the Trajectory Topic Paper [Windfall (Sites of 1-9 Units) Completions (2006-2019) Including Negative Delivery] and paragraphs 5.6.4 and 5.6.6 show that the net average annual windfall was 132 dwellings.  Paragraph 5.6.4 goes on to explain that 132 dwellings per annum is unlikely to be sustained over the whole Plan period, as opportunities within LBDs are finite and many of the more achievable infills, redevelopments and conversions have been undertaken.  For this reason paragraph 5.6.6 considers that 50 per annum is justifiable.  Beyond this statement no evidence is provided to support the assumed windfall number of 50 per annum.  Hard evidence is required.

Table 9 of the Trajectory Topic Paper assumes that Tudeley will start to deliver 2025/26.  This is likely to require groundworks in 2024/25. This implies three years from Local Plan adoption to first build out.  It assumes that Paddock Wood will start to deliver 2024/25 and again this is likely to require groundworks in 2023/24. CPRE Kent queries whether there is sufficient time to prepare and agree a masterplan and outline application.

[1] https://builtplace.com/wp-content/uploads/reports/HMLR-LA/2019-10/Tunbridge_Wells.pdf

DLP_2028

Terry Everest

The Development Strategy

As stated previously this strategy is overly development led and focuses too strongly on calculated targets that fit an overall metric. These projections may well prove be to be wrong when you consider multiple factors such as declining birth rates, a volatile and potentially collapsible world market, the effect of Brexit or the ultimate outcome of these national arguments and the reduction of net immigration that this nation hopes to achieve.

Whilst some growth and housing is needed and therefore supported where it is done appropriately and at minimal cost to the environment, I would strongyl object to the enormous numbers proposed at tudely, Capel and Paddock Wood and argue that just one tenth of these homes should be built within this timeframe and those that are built should be located to the north and east of Paddock Wood - which does have some capacity to grow in these areas. Of the combined total of 6800 homes therefore just 680 should be given the go ahead thus preserving the unique village and halmet characters of Tudely and Capel where just up to 15 and 5 homes can reasonably be developed within the current limits of development.

Although a bypass to the A228 has long been argued for it is very important that the current route remains a fast through route to north and east kent and should not therefore be surrounded by development. If a bypass is still needed it should not be simply parallel as either side of the route there are historic orchards, trees and woodlands which should be preserved. A much better work around to the east then north could be achieved using sections of other roads and less sensitve areas. Much of the need for this bypass route would be obviated by reducing these rather extreme and radical developments.

DLP_3200

Mr Peter Bird

Did you look at land around Bells Yew Green. This has a main line station. Lack of public transport. The 296 bus. to. nearest main line only runs as a shopping service on Mon, Thurs & Sat. Twice a day 11:35am & 5:05pm no good for commuters.

DLP_3661

Capel Parish Council

Object

Tunbridge Wells Borough Council has interpreted its housing need figure to be 13,560 and then up-scaled it to 14,776. This is despite TWBC having strong grounds to lower its housing need figure due to the large amount of Green Belt and AONB land in the borough.

The Ministry of Housing, Communities and Local Government has repeatedly made clear 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

You have chosen to accept the government’s housing need for Tunbridge Wells borough based on the standard method of calculation. You know that the ONS 2016 figures show a smaller housing need and that policy will reflect that in due course.

You can protect this borough from the destruction of Green Belt and AONB by following NPPF guidelines, but this plan shows no interest in doing so, and in fact is planning for even more housing than your interpretation of the 2014 figures requires. For example, you could save the MGB land at East Capel (Policy AL / CA 3 & AL / PW 1) by choosing a different development option that would require 1,000 fewer houses.

Paragraph 11 of the NPPF (revised in 2019) states:

“11. Plans and decisions should apply a presumption in favour of sustainable development.

For plan-making this means that:

  • plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change;
  • 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:
    1. 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
    2. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”

Paragraphs 11(b)(i) and (ii) are of crucial importance. They provide 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, as TWBC concede at paragraph of the Non-Technical Summary of their Sustainability Appraisal, then the NPPF makes it perfectly possible for TWBC to say that this is not achievable. TWBC have chosen not to do so.

Capel Parish Council calls for a reduction in the number of houses to be delivered by the Local Plan.

DLP_3664

Capel Parish Council

Object

You are 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 proposed garden settlement in Tudeley (AL / CA 1) and the expansion of Paddock Wood including building on East Capel (AL / CA 3 & AL / PW 1). 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.

You refer to Tudeley Village securing a long term option for the borough to deliver the needs of future generations. It is clear 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.

Capel Parish Council are seriously concerned that this will be the first step in the longer term destruction of the entire MGB in this part of the Borough. It deserves to be protected and sheltered from development. A garden settlement, should there be one, would be best in the middle of the borough, to make it accessible north and south. It is totally counterproductive to put affordable housing right at the very north of the borough when so many residents live in the south. Put it in the middle of the borough or spread it right across the borough.

The developments in Tudeley and East Capel are unsustainable, having a poor road infrastructure and this doing nothing for local employment needs (it will make many local farm workers redundant). It would also put an unfair burden on the residents of Tonbridge and Malling whose infrastructure the new residents will access. ‘The ‘master planning approach’ will come to a grinding halt at the boundaries of Tonbridge, a town whose infrastructure has grown slowly over the last millennium and can hardly be expected to adjust to this challenge imposed on it by the planners of the neighbouring authority. We expect this view to be reflected by TMBC in their response to the regulation 18 consultation.

DLP_4232

Rother District Council

It is welcomed that the proposed Development Strategy indicates how the full development needs of the borough can be most appropriately met.

DLP_4233

Rother District Council

General comment

It is noted that TWBC does not propose to meet any unmet housing need from Rother. At the time of the Core Strategy, there was a shortfall in Rother of 480 dwellings over the period 2011-2028. Most of the demand stemmed from in-migration from the greater London area. Given that this information is now somewhat dated and that my Council is, in conjunction with Hastings Borough Council, in the process of undertaking a new Housing and Employment Development Needs Assessment for its respective forthcoming Local Plan Reviews, it would not seem timely or reasonable, at this juncture to expect the current TWBDLP to make provision for further housing to meet any unmet need from Rother district.

DLP_4395

Mill Lane and Cramptons Residents Association

COMMENT – OBJECT 

INAPPROPRIATE SCALE OF DEVELOPMENT

The scale of new housing planned for Sissinghurst is out of proportion. This represents a huge increase in households on the current number of households. This cannot be absorbed or integrated satisfactorily. There is also added pressure on the school, services etc plus the extra car journeys generated.

As TWBC Cllr McDermott allegedly reported to the Cranbrook Parish Council meeting in August 2019 the housing numbers for Cranbrook and Sissinghurst are arbitrarily based on the number of sites which came forward under “The Call for Sites” process. He said that if no landowner had put forward sites very little housing would be allocated !

TWBC can hardly claim that this is a scientific needs based process on what Sissinghurst need in housing terms.

DLP_4403

Mill Lane and Cramptons Residents Association

CULTURE: There is no mention of the significance of Sissinghurst Castle or the 3 Conservation Areas of Cranbrook, Sissinghurst and Wilsley Green. Nor is there any recognition of the many festivals and events that contribute to the character of the Weald (e.g. Apple Day, Nuts in May, Britain in Bloom etc) and which attract locals and visitors alike.

DLP_4604
DLP_5616
DLP_5566

Keith Stockman
Mrs J Hewitt
Mr Paul Hewitt

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

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 outcommuting 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_4644

Ann & John Furminger

local research from the NDP group indicates that the parishioners are against large scale development. According to the NPPF there should be no large scale development on AONB unless exceptional need is proven, which is not in the parish of Cranbrook and Sissinghurst.

DLP_4648

Ann & John Furminger

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 the construction phase. The areas sighted as employment growth are mainly in the T Wells area and travel to those areas will only generate yet more traffic on already overused roads eg Goudhurst, Hawkhurst

DLP_4654

CBRE Ltd for Dandara Ltd

Growth Options

3.20 The Draft Local Plan assesses five growth options as part of formulating the preferred Development Strategy:

  • Option 1: Focused growth
  • Option 2: Semi-dispersed growth
  • Option 3: Dispersed growth
  • Option 4: Growth corridor-led approach § Option 5: New settlement growth

3.21 Based on the 2017 Options Consultation, TWBC recognises that a combination of two or more of the options presented could form the preferred strategy to meet the identified growth required through the new Local Plan.

3.22 TWBC is promoting ‘Option 3’ ‘dispersed growth’ to include site allocations for new housing located at the majority of existing settlements, and ‘Option 5’ a new ‘stand-alone’ garden settlement (Tudeley Village) and the transformational expansion of an existing settlement, using garden settlement principles.

3.23 Option 3 includes the comprehensive expansion of the settlement of Paddock Wood (including land within Capel parish) following garden settlement principles.

3.24 The employment growth needs of the borough are met by a development strategy based on a combination of Option 1 (focused growth), Option 2 (semi-dispersed growth), and Option 4 (growth corridor-led approach).

3.25 Dandara supports the principle of the preferred Development Strategy, which focuses on infrastructure-led development while also addressing the identified OAN. Dandara supports the comprehensive expansion of the settlement of Paddock Wood (including land within Capel parish) as this area is considered to be suitable to support significant growth. Dandara further supports the need for dispersed planned growth through a range of site allocations for deliverable sites that can deliver new homes and be accommodated on the basis that they benefit from the support of existing infrastructure.

3.26 Dandara emphasises the importance of sustainable growth. As set out in these written representations, Dandara is supporting a series of sites which are proposed to be included as allocations for housing delivery. These sites are all allocated for new housing in the emerging Local Plan and are importantly all suitable, available and deliverable in either the short or short to medium term.

3.27 Dandara recognises that planning for strategic scale growth has the potential to make a significant contribution to meeting identified development needs. It is, however, recognised that such strategic growth is reliant on the nature and timing of infrastructure investment which typically has a long lead in period, with new homes inevitably being delivered later in the Council’s trajectory.

3.28 In respect to the expansion at Paddock Wood (AL/PW1) and housing delivery at this site, Dandara is concerned that TWBC’s housing trajectory seeks to deliver a high volume of homes (circa 333 homes per annum) relatively early in the Plan period (commencing from 2024/25 onwards until 2035/36). Whilst Dandara supports early delivery at homes at Paddock Wood, they are concerned that the annual delivery of homes forecast is consistently high. Dandara therefore suggests that in the interests of ensuring housing delivery is achievable and realistic, it would be prudent for TWBC to adopt a higher buffer to plan for any delays or underperforming years in their housing trajectory, as part of ensuring they can demonstrate a 5YHLS position.

3.29 As set out in these written representations, Dandara raises concern about the timescales of deliverability of the new garden settlement of Tudeley Village and are cautious of the reliance on this in delivering new housing within the Plan period. Tudeley Village would form an isolated ‘garden village’ and would be reliant on significant infrastructure investment to bring the site forward, as well as resolving other development challenges a scheme of this nature will likely face.

3.30 The suitability and robustness of the Tudeley Village site allocation will depend on (inter alia) reasonable confidence that the required infrastructure investment is feasible and realistic, and importantly is capable of being delivered within reasonable timescales for the Council to rely on it as part of their housing strategy and trajectory. More significantly, however, Dandara is keen to ensure the robustness of the Paddock Wood expansion by structuring this allocation such that it is not reliant on Tudeley Village for the delivery of infrastructure. The proposed allocations may need to be considered in combination, however, both allocations should be deliverable in their own right and provide all infrastructure to meets their own needs.

3.31 In order for the Plan to be robust and satisfy the appropriate policy tests to be found sound, consideration should be given to the appropriate allowance for any possible delays in housing delivery, particularly in relation to large scale strategic sites dependent upon new infrastructure to facilitate growth.

3.32 Dandara supports the approach within the Plan towards supporting more sustainable locations and concentrating growth at existing settlements, through providing urban extensions to existing settlements that benefit from a sustainable location, existing transport links and other social infrastructure, and where new growth can enhance the existing economy. Furthermore, urban extensions allow settlements to develop more organically, and typically have infrastructure capacity (which may be capable of being increased) to support sustainable new growth.

3.33 Dandara supports the allocation of the sites and planned growth at Paddock Wood, Spratsbrook Farm, Sissinghurst and Hawkhurst as part of TWBC’s growth strategy. New development in all these locations would constitute sustainable growth and combined would deliver much need housing and economic growth, whilst taking advantage of good existing infrastructure.

3.34 Accordingly, Dandara suggests TWBC should review their housing trajectory and adjust the strategy to facilitate early delivery of new homes on allocated sites wherever possible, whilst ensuring a robust position to allow for delays in strategic allocations which may require the identification of further sources of supply.

3.35 Dandara supports the overall ambitions of the Regulation 18 Local Plan in terms of responding to the scale of housing growth that needs to be accommodated within the Plan period.

[TWBC: see full representation].

DLP_4880

Berkeley Strategic Land Ltd

THE DEVELOPMENT STRATEGY & STRATEGIC POLICIES

4.1. Berkeley welcome the Borough Councils proposal to meet the objectively assessed housing need for the Borough over the plan period to 2036, which is a minimum of 13,560 homes or 678 dwellings per annum.

The Development Strategy

4.2. It is noted that there are a minimum of 7,593 dwellings need to be allocated on new sites as part of the local plan. Berkeley support the allocation of sites to meet the housing need in full.

4.3. In the previous consultation of the Plan the Council proposed a number of growth options for the local plan, which were;

* Option 1: Focused Growth: Development distribution focused as per existing Core Strategy, i.e. majority of new development directed to Royal Tunbridge Wells/Southborough, a smaller proportion to the other three main settlements of Paddock Wood, Cranbrook and Hawkhurst and limited development within the villages and rural areas.

* Option 2: Semi-Dispersed Growth: Development distribution semidispersed, with the majority of new development directed to Royal Tunbridge Wells/Southborough and a proportion distributed to the other three main settlements of Paddock Wood, Cranbrook and Hawkhurst (as per Option 1), but additionally a percentage of development directed to some of the larger villages (taking account of the updated settlement hierarchy work). Limited development within the remaining villages and rural areas.

* Option 3: Dispersed Growth: Development distribution proportional across all of the borough's settlements.

* Option 4: Growth Corridor-led Approach: Development distribution focused around the A21, close to Royal Tunbridge Wells and Pembury, as a new 'growth corridor'.

* Option 5: New Settlement Growth: New freestanding 'Garden Village' settlement. There is no location identified with this option. A new settlement could be located anywhere within the borough (we are inviting views on the principle of a new settlement in providing for the future development needs of the borough).

4.4. The Council have outlined within the Plan at paragraph 4.38 that their proposed strategy will be a combination of Option 3 and Option 5, being dispersed growth and new settlement growth.

4.5. However, we feel that the actual provision of development in particular the distribution of housing does not accord with these options and an unbalanced distribution is proposed, which does also not accord with the tiers of the settlement hierarchy.

4.6. The distribution of housing of new allocations is;

  1. Royal Tunbridge Wells & Southborough : 1,222 – 1,320 & 205 homes
  2. Paddock Wood: 4,000 homes
  3. Tudeley Village: 1,900 in Plan period (2,500 – 2,800 homes)
  4. Cranbrook: 900 homes
  5. Hawkhurst: c. 700 homes
  6. All other settlements c. 950 homes
  7. Total New allocations: 9,500 approx. dwellings in the Plan period.

4.7. Although the Council are proposing to allocate housing sites that will deliver above their need we still feel there is a disproportionate split across key settlements. Based on a rough percentage split this distribution of development is set out below;

  1. Royal Tunbridge Wells & Southborough : 15%
  2. Paddock Wood: 40%
  3. Tudeley Village: 20%
  4. Cranbrook: 10%
  5. Hawkhurst: 5%
  6. All other settlements c. 10%

4.8. It is clear from the above evidence that the distribution of development is not evenly dispersed or proportionate to the scale of settlement as is proposed by the Council within Option 3. As such the housing provision split is not consistent with Option 3 despite being the selected option.

4.9. A large imbalance in favour of Paddock Wood exists, which has over 60% more growth compared to the primary town in the Borough of Royal Tunbridge Wells, which despite being the most sustainable settlement within the Borough has a mere 15% of allocations compared to Paddock Woods 40%. Further constraints exist within the Paddock Wood allocations as outlined in para 4.21-4.23.

4.10. Similarly the newly proposed Tudeley Garden Village accounts for 20% of the total new allocations, which is a large over-reliance of meeting the Borough’s housing needs as discussed further in para 4.24 and 4.25.

4.11. We support the level of growth proposed elsewhere including the sustainable settlement of Cranbrook, which could provide for additional growth if required.

4.12. The rate or split of this distribution should be based on the settlement groupings/hierarchy, which can achieve a distribution of development, which is proportionate to the scale of each settlement. The settlements are tiered in a logical order where settlements are placed in terms of the most sustainable locations for development placed highest in the hierarchy. It is vital to continue to direct development in line with the settlement groupings/hierarchy, which will ensure that sustainable locations are developed and gives the borough the best opportunity to meet its required needs

4.13. The smaller settlements further down the hierarchy are smaller in size, less sustainable and more constrained meaning they are not capable of delivering and supporting the same level of development as settlements that are positioned in the top tiers of the settlement groupings.

4.14. The top three tiers of the hierarchy are;

  1. Primary Regional Town Centre: Royal Tunbridge Wells
  2. Town Centre: Cranbrook, Paddock Wood, Southborough
  3. Rural Service Centre: Hawkhurst

4.15. As noted above Royal Tunbridge Wells is the Primary Regional Town Centre within the Borough making it the most sustainable, however only 15% of new housing allocations have been designated to Royal Tunbridge Wells. It is our view that additional housing sites will be required due to the unsuitability and overreliance of other proposed housing allocations. The obvious rebalance of new growth is to allocate further land within Royal Tunbridge Wells.

4.16. Berkeley Strategic are promoting Tutty’s Farm for approximately 100 homes, which has not been included within the Draft Plan as a proposed allocation. The site sits in a sustainable location lying adjacent to the top tier settlement of Royal Tunbridge Wells. This site adjoins the existing Berkeley allocation at Hawkenbury Farm now known as Hollyfields, which is currently under construction for 243 homes and a primary school. The development of Tutty’s Farm would be a logical and natural extension to Hollyfields.

4.17. The site is suitable and deliverable as is outlined in Sections 12-21, is owned by Berkeley and could come forward early in the plan period to contribute to land supply in advance of larger, more complex allocations coming forward. Furthermore this would aid with the Boroughs five year housing land supply. The site lies within the Green Belt but it is our view and supported by our recent Green Belt Review and Landscape Appraisal study that is at Appendix 2 and summarised in Section 5 that the land is weakly performing Green Belt and its development would have a negligible effect on the existing landscape due to the sites enclosed nature. It is our view that based on the Boroughs requirements to meet housing need, the constrained nature of the Borough on Green Belt land and the opportunity for our site to provide local benefits is that exceptional circumstances exist.

4.18. Within para 4.32 the Council notes that the Strategic Housing and Economic Land Availability Assessment (SHELAA) was used to develop options for meeting the housing and economic needs of the borough. However, despite the suitability of the site the SHELAA deemed the site unsuitable on the basis of heritage, land use and landscape. There is also some concerns regards highways as well as impact on AONB.

4.19. However, as outlined within sections 12-21 and as demonstrated within the technical work appended to this submission we believe that the Tutty’s Farm site is suitable and deliverable and should be allocated within the local plan.

4.20. We propose that the Local Plan is amended to include Tutty’s Farm as an allocation within the Plan.

4.21. As mentioned there is a large proportion of new allocations within Paddock Wood amounting to 4,000 new homes within the Plan period or 40% of new allocations. However a large proportion of these sites lie within flood zones 2 & 3. Of the indicatively allocated sites, which amount to approx. 600 acres only 229 acres lie outside of the flood zone, meaning approximately 40% of the allocated sites are within the flood zone and should be deemed unsuitable for residential development.

4.22. Para. 163 of the NPPF states that development should be avoided from areas of flood zone and only permitted where the sequential and exception tests have been passed. As there are other suitable and deliverable sites that have not been proposed for allocation that lie outside flood risk areas we believe that the Plan fails the sequential and exception tests and as such runs the risk of being found unsound at an examination by an Inspector if the Plan was to proceed as proposed.

4.23. From our estimation using an above average net to gross ratio on a sites developable area of 60% on land located outside the floodplain (usually a developer standard is 50%) and applying a density of 15 homes per acre this would only yield 2,000 homes on sites within Paddock Wood opposed to the 4,000 proposed. This creates an undeliverable amount of 2,000 homes as is proposed within the development strategy.

4.24. Similarly the proposal for a garden village at Tudeley comprises 20% of the total new allocations, and with circa 1,900 homes included in the plan period we believe that this is overly-optimistic and practically unachievable. It is well known how new garden villages rely on large levels of strategic infrastructure in order to unlock the site for development and at a scale of 2,500 homes + it is clear that major and lengthy upfront infrastructure will be required in order for Tudeley village to be released.

4.25 From our own experience in dealing with major strategic sites Berkeley have produced an updated trajectory for Tudeley Garden Village, which we believe is a closer estimate to the likely build out rate for the scheme.

4.26. Our estimated trajectory is at Appendix 4. From our estimation we believe that within the Plan Period that Tudeley Garden Village will only provide for 1,450 homes, which is significantly less than the 1,900 homes within the proposed trajectory. This is an additional 450 homes shortfall on the proposed housing allocations. Our estimation is also based on quite optimistic delivery rates of 200 homes per year from year two on site, which could also be questionable and result in an even higher shortfall.

4.27. Together through Berkeley’s analysis a total of 2,450 homes are undeliverable on allocated sites, which results in an approximately 550 home shortfall for the Borough in meeting its housing needs.

4.28. As such, it is clear that the Council will need to allocate more deliverable sites in order to meet their need and have a sound adopted Local Plan. The land at Tutty’s Farm is a highly sustainable opportunity, which can come forward early in the plan period and deliver the vital homes that this Borough needs.

DLP_5018

Kelli O'Brien

I am hugely concerned about the 'balance' between urban and rural life on the Weald that will be affected by increases in its population, and that the Local Plan does not appear to take this into account. What I mean by 'balance' are things: like the amount of traffic on rural roads that are widely recognised (including by the DVLA) as those which have a significantly higher likelihood of accidents; increased driving on rural roads is compensated by less traffic, but this is increasingly not the case with new development; rural noises of farming equipment and rural 'smells' are compensated by views of the countryside, which are increasing being lost to new development. Also, the Weald is comprised of interdependent townships and particularly given the proximity of them, each and every development impacts all villages and this does not appear to have been taken into account in the Local Plan. Please could the Plan include some consideration of these factors and, in particular, take a more holistic approach to the Weald, understanding the interconnectedness of the way in which all of its residents depend and use facilities in each village and town, irrespective of which village or town in which they actually live.

Please can we also think about sustainable housing and wellbeing for residents including such things as safe pavements for all residents of towns and villages to walk to the town centre and connecting each village and town to the other with cycle paths for walking and riding.

DLP_5057

Mrs Rosie Bishop

The calculation of the housing need target seems to be flawed: the method is opaque, but the base figure is derived from 2014 official figures for housing needs, which have been reduced in the 2016 figures. “the Government has indicated that it will be reviewing the methodology in the next eighteen months, but this has yet to be determined. This is because the current methodology relies on dated, 2014- based projections, instead of newer projections.”

Nevertheless, the housing need target seems to be the driving influence in the DLP and has resulted in proposals for major development within the AONB and Green belt areas

DLP_5232

Tunbridge Wells Friends of the Earth

The Development Strategy - Introduction

4.3 No mention is made of the landscape, heritage and water provision constraints on development which may well inhibit full provision of the development needs of the Borough as defined by central government. We maintain that TWBC should refuse to accept the level of development that is proposed by central government due to the constraints posed as set out above (comments on §2.40 and §2.44).

Housing development

4.7 - §4.9 We would urge TWBC to follow Sevenoaks’ example and refuse to build the number of houses demanded by central government so as to protect the Green Belt, SSSI, AONB, etc. Instead, we would ask for a recalculation of truly local needs and an active search for brownfield land as a first option for development.

Infrastructure and other supporting uses

4.26 and §4.27 We are concerned that the resources needed to give effect to the Infrastructure Delivery Plan’s objectives will not become available in time to mitigate problems arising from the planned development in the Borough. This particularly applies to the required development of a coherent network of active travel routes in Royal Tunbridge Wells and between settlements in the Borough.

Preferred Option, Site submissions, Development Strategy for consultation

4.28 - §4.40 We consider it regrettable that a planning policy system based on a call for sites from interested landowners will not necessarily result in optimal selection of land suitable for development. We have nonetheless welcomed consultation and information workshops and meetings with TWBC Planning Policy Officers.

4.40 We propose TWBC refuses to meet the target of some 13,560 new homes in the borough over the 2016-2036 period, and we oppose to any potential loss of Green Belt land and further development in the High Weald AONB.

DLP_5305

Judith Ashton Associates for Redrow Homes Ltd and Persimmon Homes South East

I write with reference to the above. I act for both Redrow Homes Limited and Persimmon Homes South East who have various interests in Tunbridge Wells, including those east and south east of Paddock Wood (SHLAA sites ‘20’, ‘374’, ‘371’, ‘344’ and ‘376’), (LPA sites PW 1_7, 1_9, 1_11 and 1_12), (parcels 7, 9, 11 and 12).

Whilst, having regard to the above, Redrow and Persimmon both support the Reg 18 Plan in principle, especially the proposed allocation of the land at Paddock Wood (policies STR/PW1 and AL/PW1), they do have specific concerns about certain aspects of policies STR/PW1 and AL/PW1 and the evidence base underpinning the plan.

The Housing Requirement, Supply and Trajectory.

a) The Requirement

Table 1 of the Reg 18 Plan identifies the housing need for the period 2016 – 2036 to be 13,560 dwellings (678dpa). This is said to be based upon the standard methodology (2014 based household projections (published July 2016)), projected household growth in Tunbridge Wells for the period 2019-2029 and the affordability ratios published in April 2019. Whilst we believe the figure to be 682dpa, we note para 3.2.1 of the Housing Topic Paper (HTP) suggests the figure of 678 is being used as it is based upon submission in 2020. This being the case the plan when submitted needs to be clear on this point and all associated calculations clarified accordingly. We also believe, for the reasons set out below, that the plan period should also be amended and start in 2020 not 2016 as drafted.

b). Whether the plan should provide for more than the minimum local housing need figure

The plan should, given ID: 2a-010-20190220 of PPG, consider whether it might be appropriate to plan for a higher housing need figure than the standard method indicates given issues such as local affordability.

The housing needs survey 2018 identifies a net affordable housing need of 443dpa. As policy H5 looks to deliver 40% affordable provision on all greenfield sites of 9 (+) dwellings, and acknowledging that not all sites provide affordable housing, in order to meet 100% of the affordable requirement one would conservatively need to deliver circa 1,107 dpa over the plan period. This is clearly significantly greater than the figure generated by the standard method, (678/682dpa) and whilst the standard method takes into account affordability issues, this does beg the question as to whether TWBC need to consider whether it might be appropriate to plan for a higher housing need figure than the standard method indicates. If nothing else the SA should in our opinion assess this point.

In the context of the above we also note that the figure of 678/682dpa is the minimum local housing need figure. It is capped at 40%. The uncapped figure is in fact 762dpa [1 Based on (1) 10-year household growth 2020-2030 in the 2014-based projections of 4,915/491.5 per annum; (2) Median workplace-based affordability ratio of 12.76 (in 2018) giving an uplift of 55% (12.76-4/4 x 0.25 +1 = 1.55) (1.55 x 491.5 = 761.83) = 762dpa uncapped]. This figure would better be described as the actual housing need, with 678/682dpa simply being the minimum Local Housing Need figure defined by the standard method. Again, given the scale of the affordable housing need the HTP and the SA should in our opinion consider the issue of the plan providing for more than the minimum local housing need figure.

Finally, having regard to the issues around the Duty to Cooperate, there is the issue of Sevenoaks District Councils (SDC’s) unmet need. Whilst we note that the SA does consider a growth option that encompasses SDC’s unmet need (option 7 – see below), para 6.2.2 of the SA appears to dismiss this option on the basis that it was assumed that the additional 1,900 dwellings would essentially be located within the AONB. It is not clear how this conclusion has been reached. In addition there is nothing that allows one to undertake a like for like comparison of the SA findings on option 7 (as set out in table 14) against the options considered in the earlier SA and the chosen option – such that the rational for this decision does in our opinion require further clarification.

c). The Plan Period

The Government’s Planning Practice Guidance (ID: 2a-004-20190220) indicates that when setting the baseline, the projected average annual household growth over a 10 year period should be calculated and that “this should be 10 consecutive years, with the current year being used as the starting point from which to calculate growth over that period”. Thus, the plan period should start at 2020 if it is to address the OAHN identified by the Standard Method of 678 (2020-2030) rather than 682 (2019-2029).

d). Supply and Trajectory

Whilst not commenting upon the supply in detail, in noting the findings of the HTP on housing delivery and the phasing methodology, we are concerned that the majority of the evidence base concentrates on the period from the grant of planning permission to first completion’s and both peak and average build out rates. Little is said about the time taken to prepare and submit planning applications or the length of the determination period; both of which are crucial to the councils proposed trajectory. To whit we note that table 9 of the HTP suggests that AL/PW1 will be delivering 333dpa from 2024/25, i.e. circa 5 years from now. As the western part of the AL/PW1 allocation includes land within the Green Belt, where land can only be released once allocated for development, and where developers will thus be unlikely to progress applications to any great degree until the plans strategy is relatively safe, it is clear that to facilitate deliveries in 2024/25 the council will need to look to those promoting the land beyond the Green Belt to progress applications in tandem with the plan, if the trajectory is to be met. We say this as both the Letwin Review (2018) and Lichfields Start to Finish: How Quickly do Large Scale Housing Sites Deliver (2016) suggests lead in times for the submission and determination of applications for sites in excess of 2,000 dwellings is such that work on the component parts of the proposed AL/PW1 allocation needs to commence soon if the council’s trajectory is to be met. To this end we support policy H2 and multi developer delivery of the strategic sites as this will enable a number of smaller applications to be made thus speeding up delivery. To this end we have suggested when commenting upon policies STR3, STR/PW1 and AL/PW1 that there is no reason why a Framework Plan (rather than a Masterplan), cannot provide for the separate masterplanning and delivery of the areas to the east and west of Paddock Wood. The Framework Plan can demonstrate graphically how the requirements of policies STR/PW1 and AL/PW1 for housing, employment, schools, medical facilities and open space etc, and associated connections, can be delivered in general land use planning term; whilst a separate Strategic Infrastructure Plan can identify who is providing what, and when; and where projects such as highway improvements / drainage works are to be funded jointly, who is paying for what and when it has to be provided.

In the context of the above, in progressing the land to the east of Paddock Wood, I can advise that at Persimmon would look to submit a hybrid planning application in autumn 2021. This will however be dependent on TWBC having an approved Framework Plan/ Strategic Infrastructure Plan. Assuming, from past experience that a resolution to grant takes 12 months, and that it takes a further 9 months for the S106 to be agreed, they would anticipate a planning consent in summer 2023. They would then be taking first legal completions from summer 2024 and would deliver 20 completions in 2024. Thereafter output would be 50 / 55 completions per annum including affordable. [2 Persimmon are currently struggling to reach 50 completions per year in Paddock Wood] .

Similarly, Redrow would also look to submit a Hybrid planning application in autumn 2021, to achieve a consent in summer 2023 and to be taking first legal completions from summer 2024. Again, they would deliver 20 completions in 2024 and achieve output rates of circa 50 / 55 completions per annum including affordable thereafter. So, both developers combined could, in the area east of Paddock Wood, deliver circa 40 completions in 2024 and 100 -110 completions per annum including affordable thereafter.

Given the above, whilst we acknowledge that on strategic sites such as AL/PW1 there will be multiple sites with multiple outlets, and that at Paddock Wood there are likely to be at least 2 further developers with outlets on the land to the west of Paddock Wood, thus providing for a greater range and choice of product; we would question whether Al/PW1 will be able to deliver 300 (+) dpa. Rather we consider that Paddock Wood will deliver circa 250 - 300dpa, and that there will be a gradual increase from 50-100dpa in yr. 1 to 200 dpa in yr. 2 and then 250 – 300dpa thereafter, such that the trajectory may in our opinion need to be reviewed in this regard.

e). Gypsies and Travellers

We note that whilst policy H13 of the Reg 18 plan does not explicitly identify a need to accommodate Gypsies and Travellers on the Paddock Wood sites, para 6.5.18 of the HTP suggests that there is a requirement for 3 additional pitches in the borough over the plan period and that these could be met at Paddock Wood. To avoid confusion either the HTP needs amending when issued at Reg 19 or policy H13 needs to be explicit and the implications on the proposed allocations taken into account in the Viability Appraisal.

Duty to Cooperate

Having reviewed the interim Duty to Cooperate Statement we note that housing is seen as a cross boundary strategic issue and that a Statement of Common Ground (SoCG) has already been signed with both Maidstone Borough Council (MBC) and Sevenoaks District Council (SDC) that look to address this issue, amongst others.

In noting the above we also note that the SoCG with MBC is dated August 2016 and that with SDC is dated May 2019. We also note that the SoCG with SDC advises at paras 2.18. and 2.19 that:

2.1.8 It is understood that, at present, TWBC is unable to assist SDB with unmet housing need, due to the constraints on both local authorities, and their inability to meet housing needs beyond their own, irrespective of unmet needs elsewhere.

2.1.9 Consequently, both councils will continue to work together and identify the position as both TWBC and SDC prepare to review their Local Plan every 5 years.

Actions

  • TWBC and SDC will engage through the wider Duty to Cooperate forum with other neighbouring authorities outside the West Kent housing market area in relation to housing related matters, including unmet need, five year housing land supply, best fit HMAs, affordability, London's growth, large scale developments and opportunities for meeting any unmet need.
  • TWBC and SDC to each undertake a 5 year review of their respective Local Plans.

As the Borough Council will be aware, the Duty to Cooperate places a legal duty on local planning authorities to engage constructively, actively and on an ongoing basis to maximise the effectiveness of Local Plan preparation in the context of strategic cross boundary matters. We do not believe, given the above, that the SoCG with MBC and SDC can be seen as demonstrating active and ongoing engagement at this stage of the plan making process – we would expect there to be a rolling program of engagement to address matters as they arise through the consultation on the Reg 18 and Reg 19 plan. Thus, the SoCG would need to be updated accordingly.

In addition to the above, we are mindful of the recent correspondence between SDC and their Inspector, especially documents ED37 and ED40. It is clear from the latter that the Inspector did not accept that reliance on a review of the Plan to address the issue of SDC’s unmet need was appropriate or complied with the duty, which applies specifically to plan preparation, which as the Borough Council are aware ends when the plan is submitted for Examination. Thus, this issue needs to be thoroughly examined and addressed in the SoCG that are submitted prior to submission of the Plan. Which means TWBC need to liaise with SDC about where they now are with this issue and the TWLP needs to clearly demonstrate why it cannot, if that is the case, help address SDC’s unmet need.

Turning to the position with Tonbridge and Malling Borough Council (TMBC) it is clear, as is acknowledged in para 45 of the DtC paper that the proposed distribution of development in the TWLP will have a potential impact on parts of TMBC and that the two councils need to work closely with one another when it comes to infrastructure delivery associated with the proposals for development at Tudeley and Capel/Paddock Wood. To this end we would suggest that TWBC need to make available a working draft SoCG with TMBC as soon as is possible – this can, like the other draft SoCG be a life document that continues to be updated until such time as it is signed off prior to submission of the plan.

In the context of the above we note that the first bullet point of criterion 1 of policy STR/PW1 (Masterplanning and Delivery) refers to the need for a strategic masterplan for the provision of infrastructure for the strategic expansion of Paddock Wood to require input from Tonbridge & Malling and Maidstone Borough Councils where it impacts on Tonbridge town centre and land to the north of Tunbridge Wells borough. This clearly requires TWBC to agree a strategy with the neighbouring authorities through the DtC. As there is no evidence within the background document to suggest that this has happened to date we would stress the need for said discussions to take place as a matter of urgency so as to facilitate the delivery of the strategic allocation at Paddock Wood and fulfil the requirements of the DtC.

Finally, we note that whilst the draft Infrastructure Delivery Plan refers to LEP funding in places, especially to assist with transport infrastructure works, the interim Duty to Cooperate Statement does not appear to encompass any DtC discussions with the LEP. This is a mater we believe needs to be addressed in the next iteration of the interim Duty to Cooperate Statement.

[TWBC: see full representation].

DLP_5529

Mr Paul Hewitt

4.19 In particular, the ENS recommended that expansion of the existing Key Employment Areas would be appropriate, at North Farm/Longfield Road in Royal Tunbridge Wells, around Maidstone Road in Paddock Wood, and at Gill's Green. Additionally, it recognised the area around the A21 highway improvements as a location for significant employment growth potential, subject to further investment. The importance of Royal Tunbridge Wells town centre is also recognised in terms of existing and future office provision, and the requirement to retain existing, well located, modern office stock within the centre.

If the ENS is indicating the expansion of existing key employment areas as above, why is such a large proportion of housing being targeted in Cranbrook and Sissinghurst?

DLP_5532

Mr Paul Hewitt

4.40 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.

Local research from the NDP group indicates that the parishioners are against large scale development

There should be no large-scale development unless exceptional need is proven, which it is not in the Parish of Cranbrook and Sissinghurst

Development proposed in Cranbrook and Sissinghurst is not sustainable in terms of infrastructure and nor is it ‘aware of the valued and protected landscape.’

There is absolutely no need to put large-scale development on AONB when NDP research has shown that the housing numbers can be delivered more sensitively and appropriately in small scale, sustainably designed developments that do not impact the AONB landscape in the same way that large estates do

DLP_5534

Mr Paul Hewitt

national policy allows for development to be reduced where valued landscapes can be damaged (NPPF, Paragraph 11).

Why has TWBC not pushed back about housing numbers when 70% of the Borough is AONB? Is it because of the income generated for ‘projects’ by development?

62% of the Parish of Sissinghurst and Cranbrook is AONB, yet the large-scale developments being proposed are all on AONB.

DLP_5536

Mr Paul Hewitt

4.7 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 methodology as required by the NPPF(20)

Houses are needed in the Parish of Cranbrook and Sissinghurst. An independent provider of professional support services has been used to arrive at a figure for housing in the Parish which is a bit less and can be delivered by small scale housing developments and yet this research commissioned by the NDP, has been ignored by TWBC

DLP_5540

Mr Paul Hewitt

4.40 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.

The above statement is belied by the following statement

4.69 The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area.

DLP_5541

Mr Paul Hewitt

4.60 As identified within the Sevenoaks and Tunbridge Wells Economic Needs Study (2016), 50% of residents in the Tunbridge Wells borough commute out of the borough to work (2011 census data).

Why then are so many houses being built so far from major settlements and train stations?

e.g. Maidstone: 14 miles, Tunbridge Wells 14 miles, Hastings 18 miles, Ashford 18 miles

Staplehurst Station, 6 miles (car park full at peak), Marden Station 8.6 miles (car park full at peak)

Whilst significant traffic jams are regularly created at Hawkhurst, Goudhurst and Flimwell when people are trying to leave the Parish of Cranbrook during peak work times.

This is not infrastructure led development.

DLP_5542

Mr Paul Hewitt

4.80 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 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.

If the above statement is a policy, then the LBD of Cranbrook and Sissinghurst should NOT be re-drawn. Already, the largest development in the Parish for at least 40 years, has been allocated adjacent to the LBD and therefore justified. The proposal to re-draw the LBD to enclose this development then allows the next largest site to be bought forward using the same justification, against the wishes of the local residents

4.87 Although very close to the LBD boundary, the site at Turnden Farm, Hartley Road, to the south west of Cranbrook has also been excluded at this stage. However, it is anticipated that these sites will be reviewed and refined for the next stage of the Local Plan.

DLP_5546

Mr Paul Hewitt

4.64 A key aim of the Draft Local Plan is to plan for comprehensive development to a high standard in terms of design and place shaping.

Little attention has been paid, thus far to high standards of design and place shaping in Cranbrook and Sissinghurst. Developments just completed or nearing Outline and Detailed applications, are a poor pastiche of local vernacular, with cost being an excuse for shoddy design and a top down approach to planning design. I have no confidence that the planning department will enforce high standards, or indeed listen to the community in this respect.

DLP_5547

Mr Paul Hewitt

4.65 Sustainable design principles make efficient use of resources through location, design, positioning, specification, and sourcing of materials, as well as improving the quality of developments and enhancing their environmental performance. The Council will encourage new development to incorporate current best practice in sustainable design and construction, incorporate mitigation and adaptation measures against the future impacts of climate change, and deliver high quality developments. Public art and active spaces will be encouraged as part of good design and place shaping to help foster a sense of place and community coherence.

This is so far from what is happening in Cranbrook and Sissinghurst (which has its own design code) that I find it hard to believe that this will be enforced in any meaningful way.

Developers have stated that they build to TWBC building standards and that solar panels are not economical. Lip service is paid to sustainability and adaptation to climate change with the installation of water butts and apparently very little else

DLP_5549

Mr Paul Hewitt

4.60 As identified within the Sevenoaks and Tunbridge Wells Economic Needs Study (2016), 50% of residents in the Tunbridge Wells borough commute out of the borough to work (2011 census data).

It therefore follows from the above statement that 50% of the residents of new homes in Cranbrook and Sissinghurst will get into a car to commute out of the Borough to work. This cannot be sustainable.

In addition, a further percentage will get into a car to leave the Parish for work again this is not sustainable

The Parish has undertaken a Housing Needs Assessment which has shown how many houses need to be built to accommodate the people that live, or aspire to live in the Parish. Why is this not taken into account?

DLP_5553

Mr Paul Hewitt

4.59 In accordance with the NPPF, this Draft Local Plan will aim to facilitate all forms of sustainable transport, ranging from active travel (such as walking or cycling), public transport, car share, car club, ultra-low emission vehicles such as electric vehicles and charging points, or any provisions that arise through new technology over the course of the plan period. This should be done in all instances to reduce private car dependence in the borough where it is both feasible in relation to local circumstances,

Whilst the facilitation of sustainable transport is to be applauded, building so far away from the proposed centres where employment will be targeted cannot possibly reduce private car dependence

DLP_5565

Mr Paul Hewitt

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

DLP_5583

Mrs Jacqueline Hewitt

4.19 In particular, the ENS recommended that expansion of the existing Key Employment Areas would be appropriate, at North Farm/Longfield Road in Royal Tunbridge Wells, around Maidstone Road in Paddock Wood, and at Gill's Green. Additionally, it recognised the area around the A21 highway improvements as a location for significant employment growth potential, subject to further investment. The importance of Royal Tunbridge Wells town centre is also recognised in terms of existing and future office provision, and the requirement to retain existing, well located, modern office stock within the centre.

If the ENS is indicating the expansion of existing key employment areas as above, why is such a large proportion of housing being targeted in Cranbrook and Sissinghurst?

DLP_5584

Mrs Jacqueline Hewitt

4.40 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.

Local research from the NDP group indicates that the parishioners are against large scale development

There should be no large-scale development unless exceptional need is proven, which it is not in the Parish of Cranbrook and Sissinghurst

Development proposed in Cranbrook and Sissinghurst is not sustainable in terms of infrastructure and nor is it ‘aware of the valued and protected landscape.’

There is absolutely no need to put large-scale development on AONB when NDP research has shown that the housing numbers can be delivered more sensitively and appropriately in small scale, sustainably designed developments that do not impact the AONB landscape in the same way that large estates do

DLP_5585

Mrs Jacqueline Hewitt

national policy allows for development to be reduced where valued landscapes can be damaged (NPPF, Paragraph 11).

Why has TWBC not pushed back about housing numbers when 70% of the Borough is AONB? Is it because of the income generated for ‘projects’ by development?

62% of the Parish of Sissinghurst and Cranbrook is AONB, yet the large-scale developments being proposed are all on AONB.

DLP_5588

Mrs Jacqueline Hewitt

4.7 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 methodology as required by the NPPF(20)

Houses are needed in the Parish of Cranbrook and Sissinghurst. An independent provider of professional support services has been used to arrive at a figure for housing in the Parish which is a bit less and can be delivered by small scale housing developments and yet this research commissioned by the NDP, has been ignored by TWBC

DLP_5590

Mrs Jacqueline Hewitt

4.40 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.

The above statement is belied by the following statement

4.69 The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area.

DLP_5592

Mrs Jacqueline Hewitt

4.60 As identified within the Sevenoaks and Tunbridge Wells Economic Needs Study (2016), 50% of residents in the Tunbridge Wells borough commute out of the borough to work (2011 census data).

Why then are so many houses being built so far from major settlements and train stations?

e.g. Maidstone: 14 miles, Tunbridge Wells 14 miles, Hastings 18 miles, Ashford 18 miles

Staplehurst Station, 6 miles (car park full at peak), Marden Station 8.6 miles (car park full at peak)

Whilst significant traffic jams are regularly created at Hawkhurst, Goudhurst and Flimwell when people are trying to leave the Parish of Cranbrook during peak work times.

This is not infrastructure led development.

DLP_5594

Mrs Jacqueline Hewitt

4.80 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 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.

If the above statement is a policy, then the LBD of Cranbrook and Sissinghurst should NOT be re-drawn. Already, the largest development in the Parish for at least 40 years, has been allocated adjacent to the LBD and therefore justified. The proposal to re-draw the LBD to enclose this development then allows the next largest site to be bought forward using the same justification, against the wishes of the local residents

4.87 Although very close to the LBD boundary, the site at Turnden Farm, Hartley Road, to the south west of Cranbrook has also been excluded at this stage. However, it is anticipated that these sites will be reviewed and refined for the next stage of the Local Plan.

DLP_5596

Mrs Jacqueline Hewitt

4.64 A key aim of the Draft Local Plan is to plan for comprehensive development to a high standard in terms of design and place shaping.

Little attention has been paid, thus far to high standards of design and place shaping in Cranbrook and Sissinghurst. Developments just completed or nearing Outline and Detailed applications, are a poor pastiche of local vernacular, with cost being an excuse for shoddy design and a top down approach to planning design. I have no confidence that the planning department will enforce high standards, or indeed listen to the community in this respect.

DLP_5597

Mrs Jacqueline Hewitt

4.65 Sustainable design principles make efficient use of resources through location, design, positioning, specification, and sourcing of materials, as well as improving the quality of developments and enhancing their environmental performance. The Council will encourage new development to incorporate current best practice in sustainable design and construction, incorporate mitigation and adaptation measures against the future impacts of climate change, and deliver high quality developments. Public art and active spaces will be encouraged as part of good design and place shaping to help foster a sense of place and community coherence.

This is so far from what is happening in Cranbrook and Sissinghurst (which has its own design code) that I find it hard to believe that this will be enforced in any meaningful way.

Developers have stated that they build to TWBC building standards and that solar panels are not economical. Lip service is paid to sustainability and adaptation to climate change with the installation of water butts and apparently very little else

DLP_5598

Mrs Jacqueline Hewitt

4.60 As identified within the Sevenoaks and Tunbridge Wells Economic Needs Study (2016), 50% of residents in the Tunbridge Wells borough commute out of the borough to work (2011 census data).

It therefore follows from the above statement that 50% of the residents of new homes in Cranbrook and Sissinghurst will get into a car to commute out of the Borough to work. This cannot be sustainable.

In addition, a further percentage will get into a car to leave the Parish for work again this is not sustainable

The Parish has undertaken a Housing Needs Assessment which has shown how many houses need to be built to accommodate the people that live, or aspire to live in the Parish. Why is this not taken into account?

DLP_5600

Mrs Jacqueline Hewitt

4.59 In accordance with the NPPF, this Draft Local Plan will aim to facilitate all forms of sustainable transport, ranging from active travel (such as walking or cycling), public transport, car share, car club, ultra-low emission vehicles such as electric vehicles and charging points, or any provisions that arise through new technology over the course of the plan period. This should be done in all instances to reduce private car dependence in the borough where it is both feasible in relation to local circumstances,

Whilst the facilitation of sustainable transport is to be applauded, building so far away from the proposed centres where employment will be targeted cannot possibly reduce private car dependence

DLP_5615

Mrs Jacqueline Hewitt

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

DLP_5806

Weald of Kent Protection Society

Housing: Delivery of Housing Numbers

Comment on Para. 4.7 of the DLP:

This Draft Local Plan proposes a total of 2,000 houses within the High Weald AONB and many more adjoining the boundaries of the AONB. The preference is for development to be located outside the AONB, but the allocated sites adjoining the AONB will have a considerable impact on the setting.

The objectively assessed housing need for the borough is confirmed as 13,560 dwellings (678 per year) using the standard methodology as required by the NPPF.

This calculation calls for unprecedented levels of potential development across the borough, and the draft local plan proposes a large number of housing within the AONB.

Statistics from TWBC Development Constraints Study:

70% of the borough is within the High Weald AONB.

45 Historic Parks and Gardens

25 Conservation Areas

11 Scheduled Ancient Monuments

16% of the borough is Ancient Woodland

10 Sites of Special Scientific Interest (SSSI)

5 Local Nature Reserves (including one Community Woodland)

1 Regionally Important Geological Site, at Scotney Castle Quarry.

These statistics show considerable constraints for development in the borough, yet despite this acknowledgement in the Constraints Study and despite the NPPF, large development sites are proposed within and adjacent to the AONB.

The NPPF clearly states that new developments should be limited and small scale. Major development should only be allowed under exceptional circumstances. The allocations constitute major development which by definition will have a significant adverse impact to the character components of the landscape. The indicators are that the numbers cannot and should not be achieved.

TWBC has a statutory duty to ‘have regard to the purpose of conserving and enhancing the natural beauty’ of the High Weald AONB. The Draft Local Plan fails this custodial duty because of the many proposals for developments which can have nothing other than an adverse impact on the AONB.

WKPS urges TWBC to meet its statutory duty and seek a reduction in housing numbers to reflect local housing need, rather than the standard methodology for housing targets.

DLP_5990

Pro Vision for Cooper Estates Strategic Land

Paragraph 4.7 of the draft Local Plan sets out the objectively assessed housing need for the Borough over the plan period. The basis of this housing need target, together with assessments of the housing needs of particular groups (including older persons), is set out in the Housing Needs Assessment Topic Paper.

The Housing Needs Topic Paper explains that the Council agrees the need to provide housing for older people is ‘critical’ (paragraph 67). Paragraph 77 requires that ‘close attention’ should be given to the number, size, location and quality of dwellings needed in the future for older people. Paragraph 78 confirms that ‘planning to meet the housing needs of older people is a major, strategic challenge for the Local Plan’.

In the same way as our comments on Section 2, these key evidence base conclusions are not reflected in the plan Strategic Objectives, nor are these therefore delivered in the draft policies of the Plan (see our comments on the Strategic Objectives and policies H9- Housing for Older People and STR1- The Development Strategy).

DLP_5998
DLP_7541
DLP_7549

Alexander Fisher
William Fisher
Helena Fisher

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

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_6005

Laura Rowland

Difficult to understand why a massive proportion of housing is targeted in Cranbrook and Sissinghurst when the employment opportunities are in areas listed above.

DLP_6006

Laura Rowland

NDP group research and shows parishioners are against large scale development

No large scale development should occur unless exceptional need is proven, which it is not the case in the Parish of Cranbrook and Sissinghurst.

The infrastructure in Cranbrook and Sissinghurst is not sustainable for big housing developments.

The draft local plan doesn’t show it is ‘aware of the valued and protected landscape.’ The AONB needs to be preserved at all costs and housing needs can be addressed with small scale and sustainable developments that preserve more of the landscape. “The High Weald landscape is considered to be one of the best surviving and most coherent medieval landscapes in northern Europe; it has remained a unique, distinct, and recognisable area for at least the last 700 years.” AONB management plan June 2018

It is surprising TWBC has not pushed back against the housing numbers when 70% of the Borough is AONB. Is this possibly because there is income generated for ‘projects’ by development?

62% of the Parish of Sissinghurst and Cranbrook is AONB, yet the large scale developments being proposed are all on AONB. This is extremely difficult to comprehend. Why build on the countryside away from jobs and good transport routes?

The above statement (paragraph 4.40) is belied by the following statement

4.69 The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area.

DLP_6011

Laura Rowland

Houses are needed in the Parish of Cranbrook and Sissinghurst. An independent provider of professional support services has been used to arrive at a figure for housing in the Parish which is a bit less and can be delivered by small scale housing developments and yet this research commissioned by the NDP, has been ignored by TWBC

DLP_6013

Laura Rowland

Why then are so many houses being built so far from major settlements and train stations?

eg.Maidstone: 14 miles, Tunbridge Wells 14 miles, Hastings 18 miles, Ashford 18 miles

Staplehurst Station, 6 miles (car park full at peak), Marden Station 8.6 miles (car park full at peak)

Whilst significant traffic jams are regularly created at Hawkhurst, Goudhurst and Flimwell when people are trying to leave the Parish of Cranbrook during peak work times.

This is not infrastructure led development.

DLP_6015

Laura Rowland

If the above statement is a policy, then the LBD of Cranbrook and Sissinghurst should NOT be re-drawn. Already, the largest development in the Parish for at least 40 years, has been allocated adjacent to the LBD and therefore justified. The proposal to re-draw the LBD to enclose this development then allows the next largest site to be bought forward using the same justification, against the wishes of the local residents

4.87 Although very close to the LBD boundary, the site at Turnden Farm, Hartley Road, to the south west of Cranbrook has also been excluded at this stage. However, it is anticipated that these sites will be reviewed and refined for the next stage of the Local Plan.

DLP_6170

Dr Malcolm Butler

The current housing target for Tunbridge Wells Borough for the period 2016 – 2036 is 13,560 homes, based on the housing figures forecast in 2014 and an unexplained 40% multiplier.  The use of the 2014 figures has been questioned, as the Office for National Statistics forecast for 2016 reduced the housing need figure significantly from 300,000 to 160,000.  The use of the multiplier in Tunbridge Wells Borough appears to be based on the affordability ratio in the borough of 12.74 and an erroneous assumption that building more homes will make them affordable. This assumption is at odds with housing market data and national statistics and evidence is needed to substantiate this counter-intuitive correlation.

The Housing Needs Study published by TWBC in July 2017 stated that the population of the borough would increase from 117,700 in 2017 to 128,800 in 2033.  An increase in population of 11,100 contrasts strangely with the proposed target of 13,560 new homes over a similar time period.  It would be unfortunate if this situation has been allowed to develop solely because of the additional funding that will come to TWBC for each new house built.

It seems to us that there is a danger of getting into an “Irish” situation, in which the countryside is covered with half-built housing estates that can’t be sold.

DLP_6207

Amanda Wells

Development Strategy 

4.9, 4.9 As under my comments on the Vision in Section 3, TWBC neds to dramatically rethink the ‘objectively assessed housing need’ – the whole Local Plan is based on greatly inflated figures which do not meet the needs of the Borough.

DLP_6268

Susan Heather McAuley

4.19

Employment is proposed at the west end of the Borough (the exception being a small site at Gills Green providing limited types of jobs) – this is at the opposite end of the area to the large building projects being proposed for villages at the east end of the Borough.

Employment is to be concentrated around the west end of the Borough (apart from a small increase in size to Gills Green employment areas) which large scale housing estates are proposed to be built at the east end.  This automatically gives a mis-match between places to live and places to work.  This plan is economically and environmentally, and to some degree socially, unsustainable because it creates long, expensive journeys, increases air pollution and separates place of work from place of residence for the majority of residents in a village.

4.26

‘Well designed and sustainable communities’ Some people want to live in towns, others in villages.  Their reasons for this choice are distinct.  While extra house building in a town will not change life for most people in that town, building large numbers of extra houses in a village can take away the features that made people want to live on that village – a sense of belonging, of safety, of knowing the people that walk past your house.  In a town your group of friends may be made up of people from different streets, that you know through work, or clubs or sporting activities.  You may not know further than your immediate neighbours that well and usually don’t mind that.  In a village you know everybody and everybody knows you.  That does not suit everyone but it does suit the people who choose to live in a village.  Fill the village with so many houses that you have no hope of knowing everyone, put those houses in giant cul-de-sacs (Bramling Gardens in Sissinghurst) where people have no need to mix with other parts of the village and you destroy that village and the reason for living there.  Extra buses and parking spaces will not mitigate this.  If you have had village people work on this Local Plan they will have explained this difference to you.  Village people have the same right to a chosen way of life as town people have. You want to enhance Tunbridge Wells town by have extra work and shops and cultural activities which is wonderful for the people of Tunbridge Wells.  It will create a ‘well designed and sustainable’ community that will endure into the future.  For some of our villages this Local Plan will create a totally unsustainable community that will be a dormitory with no social structure.  This Local Plan is socially unsustainable for our village of Sissinghurst.

4.33

The call for sites seems a seriously flawed, non-planning led approach.  Instead of looking at locations and needs and suitable sites (as the relevant authorities would do if they wanted to build a strategic road or railway) the Local Plan has identified sites where people wanted to sell their gardens and land.  Therefore sites that look suitable are not included because they were not put forward by the landowners.  This is a piecemeal approach which para 2.44 says can have an adverse impact on the natural, built and historic environment.  There is no extra housing proposed for Bidborough because no-one suggested any suitable sites?  Does Bidborough not need any new houses? Compulsory purchase is mentioned in this plan but it seems it is not going to be used to identify more suitable sites for housing.

4.38

The Council is proposing a strategy based on Option 3 (dispersed growth).  Option 3 in the Issues and Options stage was described as ‘proportional across all of the Borough’s settlements’.  The Local Plan recommendations are not proportional – if my Maths is correct, assuming just 2.5 people to a house …

Cranbrook & Sissinghurst: Population: 6700 New houses 869

% increase in houses 32%

Horsmonden: Population: 2435  New houses 265

% increase in houses 27%

Frittenden: Population 888 New houses 28

% increase in houses 8%

Tunbridge Wells: Population: 48324 New houses 1271

% increase in houses 7%

Benenden: Population 2400 New houses 55

% increase in houses 6%

Southborough: Population 12459  New houses 170

% increase in houses 3%

Rusthall: Population 4976 New houses 15

% increase in houses <1%

Bidborough:  Population: 1163   New houses 0

% increase in houses 0%

The allocation is disproportionate and this is not explained by the area of the AONB.  Tunbridge Weels and its environs will get new employment and cultural and retail facilities but few new houses, Cranbrook & Sissinghurst and others will get huge amounts of new housing having a massive impact on the ‘place-shape’, but some villages get far fewer new houses.  This Local Plan must fail the equality impact assessment, it is pro-urban and broadly anti-rural, certainly anti Cranbrook and Sissinghurst and goes against the wording of Option 3.

4.39

The areas chosen for employment (Options 1,2,& 4) are different from those assigned for housing (Options 3 & 5), thus increasing the need for car or public transport to Tunbridge Well, Maidstone or Staplehurst Station.  This is not economically sustainable.

4.40

This paragraph is incorrect.

Bullet Point 2 - there is no urban expansion in this plan (less than 5%) but there is extensive rural expansion (32%) .

Bullet Point 4 – there are no significant numbers of new homes in the wider urban area – less than 5% around Tunbridge Wells town.

Bullet Point 7 – the scale of building in some smaller settlements, particularly Sissinghurst, is not at an appropriate scale – 32% increase in numbers of houses – against 5% increase in the Tunbridge Wells area.  It is not economically, environmentally or socially sustainable.

DLP_6276

Mrs Elizabeth Simpson

The draft Local Plan sets out the policy framework in which the Borough Council will make planning decisions and deliver development to meet its housing target within the Plan period, 2016-2036. However, TWBC appear to be accepting without challenge the top-down target set by central government of 13,560 homes and indeed TWBC are proposing to set their own target at 9% above this level at 14,776 homes. This is described as being based on the objectively assessed housing need for the borough over the plan period, identified by the standard methodology as required by the NPPF. Yet this methodology is flawed, having been based on historic data, and despite there being considerable wealth of information available to argue that this is not correct. TWBC should adopt a more pragmatic approach based on local need and capacity as undertaken by many other local authorities including nearby Sevenoaks to seek a reduction of these numbers.

One such piece of research which challenges the out-dated approach in setting housing targets, is a paper published by UK Collaborative Centre for Housing Evidence – entitled: Tackling the UK Housing Crisis – is Supply the Answer, written by Ian Mulhern Aug 2019. (This examines and challenges the thinking that by building more house prices will come down). The problem is not a housing shortage but a housing affordability crisis.

Further to this, the Housing Needs Assessment Topic Paper (August 2019) already states that, the government will be reviewing the methodology for calculating housing numbers in the next eighteen months, because the current methodology it relies on is out of date, based on 2014 projections. The Government reasoning for continuing to use these, on an interim basis, is to provide stability and certainty to the planning system in the short-term. Thus these numbers should not be taken as a mandatory target for TWBC to plan for, but a starting point only.

The standard methodology is, therefore not mandatory. The target that the Plan aims to achieve could well be far higher than necessary. It is not appropriate for the Council to adopt its ‘wait and see’ position, which could lead to its policy framework being based on a false target. The Plan needs to be based upon the most realistic assessment of need, taking into account the constraints that characterise the Borough.

Further, as 70% of the borough comprises AONB or Green Belt, which are supposed to be protected landscapes, there are further reasons why the overall number should be challenged. The levels of development proposed in this draft local plan, will cause irreparable damage to the local environment.

I see that Paragraph 4.8 specifically notes that Sevenoaks District Council is not proposing to wholly meet its housing need. If, as the Plan states, the constraints that apply to Sevenoaks District Council are similar to those of TWBC, why isn’t TWBC also challenging their housing target based on standard methodology and/or proposing to not wholly meet the need identified through this method? Isn’t there a case to argue that the constraints that apply to TWBC (the extent of AONB and Green Belt land in the borough and notable affordability pressures potentially causing a fall in home ownership) constitute “exceptional circumstances”, which could justify an alternative approach to assessing housing need according to NPPF paragraph 60?

DLP_6318

Susan Heather McAuley

From the results of the Issues and Options Consultation I thought the preferred options (as reported from that consultation) were Option 1 and Option 5.  The actual local Plan is not following this decision.  Option 1 says ‘limited development within the remaining villages and rural areas’.  Sissinghurst is a ‘remaining village’.  It should not be treated as part of Cranbrook and therefore should have limited development.  The same is true of Horsmonden.

However, these preferences are not reflected in the local plan.  It seems from the Local Plan that Option 3 and Option 5 have been decided upon.  Option 3 is dispersed growth described as ‘proportional across all of the Borough’s settlements’.  The Local Plan recommendations are not proportional – if my Maths is correct … assuming just 2.5 people to a house …

Cranbrook & Sissinghurst: Population: 6700 New houses 869

% increase in houses 32%

Horsmonden: Population: 2435  New houses 265

% increase in houses 27%

Frittenden: Population 888 New houses 28

% increase in houses 8%

Tunbridge Wells: Population: 48324 New houses 1271

% increase in houses 7%

Benenden: Population 2400 New houses 55

% increase in houses 6%

Southborough: Population 12459  New houses 170

% increase in houses 3%

Rusthall: Population 4976 New houses 15

% increase in houses <1%

Bidborough:  Population: 1163   New houses 0

% increase in houses 0%

The allocation is disproportionate and this is not explained by the area of the AONB.  Tunbridge Weels and its environs will get new employment and cultural and retail facilities but few new houses, Cranbrook & Sissinghurst and others will get huge amounts of new housing having a massive impact on the ‘place-shape’.  This Local Plan must fail the equality impact assessment, it is pro-urban and anti-rural and goes against the wording of Option 3.

DLP_6422

Hawkhurst Parish Council

p.33 para 4.6: A point is made about promotion of neighbourhood planning as a process. However, considering the intention to overwrite policies in TWBC NDP for Hawkhurst, part of the adopted TWBC statutory plan, and with no further explanation, we do not have confidence in these statements.

p.38, para 4.35: Statement that TWBC has actively engaged with NDP groups around site selection

We know that TWBC has asked the opinion of NDP groups about the sites it intends to include in the draft TWBC Local Plan. But at no point in the process has there been an encouragement for site allocations to be made within NDPs themselves, which is what many NDP groups want to be able to do, and is the approach of other planning authorities such as South Downs National Park.

During this process, Hawkhurst Parish Council suggested smaller sites that would comply with the TWBC NDP for Hawkhurst aims, objectives and policies. TWBC have not chosen to allocate these sites, leaving them as potential windfall sites outside of the allocation for the Parish. Why is this?

We acknowledge that the TWBC NDP for Hawkhurst does not contain direct site allocations due to the fact that at the time Hawkhurst had exceed the housing number allocated to it in the existing TWBC Local plan. However, taking Counsel advice this is a moot point. The revised version does contain housing allocations to reflect today’s climate for the preferred distribution, scale and location of new development this should be considered in the next version of the draft TWBC Local Plan.

para 4.35 – 4.37: Statement about the level of agreement between the Council and parish representatives about which sites form a set of draft site allocations for each parish

This process is not what the Localism Act describes. It is widely understood that NDPs should allow local communities to take meaningful decisions over the location of new homes. Yet the TWBC process deliberately frustrates this, by ignoring Parish Councils suggestions and taking all such decisions on behalf of local communities. This is counter to the Localism Act.

p.59: para 4.72 – 4.79 Reference to the neighbourhood planning process

This is largely a “cut and paste” from the regulations and does little to explain how TWBC sees the process of preparing an NDP should contribute to the delivery of sustainable development across the borough,

para 4.79: This states: “Notwithstanding the Council's support for neighbourhood plans, in view of the fact that their progress is variable and outside the direct control of the Council, as well as the pressing requirement to address under-delivery of housing against identified need, the Draft Local Plan includes draft allocations for the whole of the borough”

Almost all NDPs can be produced more quickly than a LP and are much more responsive to local concerns. But rather than work with the parishes to create a strong pattern of advanced and/or made NDPs across the borough, the approach taken is to include draft allocations for the whole of the borough, thereby deliberately undermining many NDP groups. In the case of Hawkhurst, it is acknowledged that the made NDP does not contain direct site allocations but it does contain criteria for the preferred distribution, scale and location of new development yet this appears to be ignored by the draft TWBC Local Plan.

DLP_6428

Hawkhurst Parish Council

p.33 footnote 19

We consider this to be a major error on the part of TWBC as it has defined the “urban area” for planning purposes as the main urban area of Royal Tunbridge Wells and Southborough, together with the rural settlements of Paddock Wood, Cranbrook, and Hawkhurst.

How can it be that rural settlements of Cranbrook and Hawkhurst, both deep within the AONB, can be given the same urban status as Royal Tunbridge Wells and Southborough?

This is critical because the definition of “urban area” then leads directly to a strategy that maximises development within existing built-up areas and optimised densities. While this strategy of maximisation and optimal density may be appropriate in genuine urban areas such as Royal Tunbridge Wells, it cannot be considered appropriate for rural communities in nationally protected landscape areas.

It is from this mistaken assumption that much disturbing content of the draft TWBC Local Plan follows. Correct this assumption (i.e. Cranbrook and Hawkhurst will not be subject to the maximisation strategy) and a whole different approach is possible

DLP_6455

Cranbrook & Sissinghurst Parish Council

  1. RESPONSE BY CRANBROOK AND SISSINGHURST NEIGHBOURHOOD DEVELOPMENT PLAN TO KEY SECTIONS OF THE DRAFT TWBC LOCAL PLAN

Neighbourhood Plans are the only part of the planning system that require consent through a local referendum. The Cranbrook and Sissinghurst NDP group has been a willing participant in the Local Plan process yet all its efforts to work constructively with TWBC to prepare a complementary planning document to the Local Plan (i.e. an NDP) have been rebuffed. The Parish is wondering what the future is for its emerging Neighbourhood Plan, now that fundamental decisions, such as the location and spatial distribution of housing has been taken away from it.

Furthermore, there is no view expressed within the draft TWBC Local Plan about the expectations for neighbourhood planning –what exactly does TWBC want them to do to complement the Local Plan? There is almost no guidance or direction within the draft TWBC Local Plan on this matter. This omission leads many to believe that neighbourhood planning is considered marginal at best (and irrelevant at worst) by the TWBC Local Plan team. If the team in TWBC genuinely consider NDPs to be a useful and practical part of the system, there would be clear expectations set out for them. There are not.

Over the last 18 months, repeated communication from the Parish to TWBC Local Plan team has made clear the wish of the Neighbourhood Plan group to make direct site allocations in the emerging NDP. We strongly believe that a Neighbourhood Plan that contains site allocations is the most effective way for the local community to “develop a shared vision” for this area and to “shape, direct and help to deliver sustainable development, by influencing local planning decisions as part of the statutory development plan” (para. 29, NPPF).

Yet the draft TWBC Local Plan, as published in September 2019, includes allocations for the whole Borough, including in those areas where Neighbourhood Plans are being prepared by Parish Councils. We see no logic for this approach, an approach that fundamentally undermines the spirit and principles of localism. The damage caused to local democracy by this approach is a major cause for concern. In such a controversial period for public engagement, Neighbourhood Plans may be one of the most democratic things going on right now and yet the wishes of local people on this matter are being ignored.

p.38, para 4.35: Statement that TWBC has actively engaged with NDP groups around site selection

We are aware that the process has involved TWBC asking the opinion of NDP groups about the sites it intends to include in the draft TWBC LP. But at no point in the process has there been an encouragement for site allocations to be made within NDPs themselves, which is what many NDP groups want to be able to do, including Cranbrook and Sissinghurst. Repeated communications have made it clear that the NDP for the Parish wanted to directly allocate land for development to give local people the maximum control over its future. Our ambition in this area has been frustrated by TWBC at every turn. Examples of this frustration include failure to honour commitments to provide information, such as backup to ‘Call for Sites’, or providing copies of minutes of meetings.

para 4.35 – 4.37: Statement about the level of agreement between the Council and Parish representatives about which sites form a set of draft site allocations for each Parish

This process is not what the Localism Act describes. It is widely understood that NDPs should allow local communities to take meaningful decisions over the location of new homes. Yet the TWBC process deliberately frustrates this, by taking all such decisions on behalf of local communities. This is counter to the Localism Act.

Despite a request to TWBC first made in June 2018 to prepare a “Memorandum of Understanding”, to better define the relationship between the TWBC Local Plan and neighbourhood plans, none has been forthcoming. This has left many NDP groups, including Cranbrook and Sissinghurst, unsure how to proceed on key matters.

p.59: para 4.72 – 4.79 Reference to the neighbourhood planning process

This is largely a “cut and paste” from the regulations and does little to explain how TWBC sees the process of preparing an NDP should contribute to the delivery of sustainable development across the Borough,

para 4.79: This states: “Notwithstanding the Council's support for neighbourhood plans, in view of the fact that their progress is variable and outside the direct control of the Council, as well as the pressing requirement to address under-delivery of housing against identified need, the Draft Local Plan includes draft allocations for the whole of the borough”

This approach and statement deliberately frustrates those NDP groups that have been willing and able to make direct site allocations through the NDP process for some time. Indeed, several NDP groups have been able to accelerate the delivery of new homes (when compared to the LP process) if only they had been given the information and required support from TWBC at the right time.

Almost all NDPs can be produced more quickly than a LP and are much more responsive to local concerns. But, rather than work with the parishes to create a strong pattern of advanced and/or made NDPs across the Borough, the approach taken is to include draft allocations for the whole of the Borough, thereby deliberately undermining many NDP groups.

[TWBC: see full response].

DLP_6463

DHA Planning for Cedardrive Ltd

3.3 Development Strategy and Strategic Policies

Context

3.3.1 The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the borough and where that development will be located.

3.3.2 In terms of the amount of housing, paragraph 59 of the NPPF states that to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient quantum and variety of land can come forward where it is needed. Furthermore, to determine the number of homes needed, strategic policies should be informed by a local housing needs assessment conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.

3.3.3 The Council confirm that their housing need target for the plan period 2016-2036 is 13,560 dwellings (678 dwellings per annum), which is calculated using the Government’s standard method and the 2014-based household projections.

3.3.4 In terms of the different supply components, the Council considers that the Local Plan must (as a minimum) include additional allocations to accommodate 7,593 homes. This figure was formulated taking into account:

* completions since April 2016 (1,552);

* extant planning permissions (3,127);

* outstanding site allocations (588); and

* a windfall allowance (700 dwellings).

3.3.5 The Council has applied a 10% non-delivery rate to these figures to err on the side of caution and consider that the plan would exceed the minimum housing requirement if all of the supply components were achieved.

3.3.6 We commend TWBC for seeking to meet their need in full and support this positive approach to plan-making. Likewise, we support the general thrust of the development strategy, which proposes a strategy to meet the housing needs of the borough with a dispersed growth approach.

[TWBC: see full representation].

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

DLP_6534

Diana Badcock

Object 

Policy Number: 4.7

If TWBC’s housing figures of 13.560 are based on NPPF guidelines (4.7), why did TWBC accept them without challenge. The ‘standard methodology’ allows for exceptions. Why did TWBC not argue for a smaller number given that 70% of the borough is in an AONB? THE ANOB and national policy allows for development to be reduced where valued landscapes can be damaged (NPPF paragraph 11).

For Cranbrook - these are entirely inappropriate numbers and the plans for several sites far too extensive, for an area set completely within an AONB, where development should only be allowed in exceptional circumstances, and if allowed, should be small scale.

DLP_6535

Diana Badcock

Object 
Quotes: ‘Development to be planned in a co-ordinated way…….’.

‘….‘It will be appropriate to deliver this through a comprehensive masterplanning process’.

The developer for Brick Kiln in Cranbrook (CRS 9) was instructed to take a masterplanning approach but this has not been done. Will TWBC enforce this requirement?

DLP_6570

Myrtle Newsom

Policy Number: Section 4 Strategic Policies Para 4.39

The areas destined for employment do not match those assigned for housing, thus increasing the need for car or public transport to Tunbridge Well, Maidstone or Staplehurst Station. This is not economically sustainable.

DLP_6572

Myrtle Newsom

Policy Number: Section 4 Strategic Policies Para 4.60

This ignores the fact that there needs to be better transport from rural areas into Tunbridge Wells or people will continue to use their own cars.

DLP_6574

Myrtle Newsom

Policy Number: Section 4 Strategic Policies Para 4.86 Point 3

Point 3 – Change to Limits to Build is being altered specifically to allow site 54 Policy AL/CRS13 (Mill Lane) to be included but Mill Lane is part of Sissinghurst Village not Wilsley Pound so does not belong in this Limits to Build.

DLP_6600

Michael Lloyd

The DLP says:

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.

This is laughable when one considers the Brick Kiln Farm and Turnden developments in Cranbrook, which will have the effect of joining Cranbrook to Hartley by eliminating the green space between.  

What happened to Limits to Built Development?

DLP_6609

AAH Planning for Future Habitat Ltd

SECTION 4 – THE DEVELOPMENT STRATEGY AND STRATEGIC POLICIES

This section of the Consultation Draft sets out the housing and economic development targets for the plan period to 2036 and describes the Council’s approach to the spatial distribution of development. It comprises a Development Strategy, at Policy STR 1, and other strategic policies that fulfil the expectations of the NPPF.

The Development Strategy

With regard to housing need, this section identifies that 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 methodology as required by the NPPF. Discounting completions up to March 2019, extant planning permissions, outstanding site allocations, and a windfall allowance of 700 dwellings, this equates to at least 7,593 new additional allocations to meet housing need. The basis of this housing need target, together with assessments of the housing needs of particular groups, is set out in the Housing Needs Assessment Topic Paper.

Whilst our Client generally supports this, the identified housing need should be a minimum requirement in line with national policy. In addition, it is considered that suitable windfall sites and additional site allocations made through the plan will be required in order to meet the identified need and assist in significantly boosting the supply of housing.

It is noted that the Council has prepared a Strategic Housing and Economic Land Availability Assessment (SHELAA) to identify a future supply of land that is suitable, available, and achievable for all housing and economic development needs over the plan period. This is welcomed by our Client and it is noted that previous representations have been prepared to support the allocation of the site for housing in the emerging Local Plan.

[TWBC: see full representation and site plan attached].

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

DLP_6644

Mr Steve Gasson

Paragraph 4.3 states that ‘in preparing this Draft Local Plan, the Council has to be mindful that national planning policy, as set out in the NPPF (2019), expects local plans to meet the identified level of development needs for their area in full, unless there are good planning reasons why this is not possible. Accordingly, the proposed Development Strategy indicates how the full development needs of the borough can be most appropriately met.’

This presumption that the full development needs as derived formulaically using the new Standard Method must be met goes against NPPF paragraph 11, which makes clear that AONB designation may provide a strong reason for restricting the overall scale, type or distribution of development in the plan, and ignores the Planning Policy Guidance updated in July 2019 which specifically comments that in order to protect such areas it may not be possible to meet the formulaically derived needs.

TWBC should carry out a transparent assessment demonstrating that in deciding the level of housing provision proposed, the type of homes and the distribution of those homes, great weight has been given to conserving and enhancing landscape and scenic beauty in the AONB; the conservation and enhancement of wildlife and heritage has been taken into account; and the scale and extent of development within the AONB has been limited.

DLP_6787

G M Whitehead

Cranbrook and Sissinghurst.

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

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

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

DLP_6793

Kember Loudon Williams for Wedgewood (New Homes) Ltd

It is noted and supported that opportunities to deliver housing in villages outside the AONB should be maximised. Horsmonden is one of the larger villages in the Borough and the settlement is one of the few villages in the Borough that is outside the AONB (noting that part of the Parish is within it).

It is queried whether the emphasis placed on this approach at 4.38 and 4.40 has followed through with sufficient emphasis on this consideration within the various Strategic and Allocation Policies. This is referred to in more detail below, and in the attached KLW Supporting Statement.

[TWBC: see Supporting Statement and Comment Numbers DLP_6793, 6797-6799, 6801, 6803-6804]

DLP_6802

G M Whitehead

4.40 final para. You say - 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.

One reason for allowing Brick Kiln Farm estate to be built was that it was only just outside the LBD. The intention of this plan seems to be to move the LBD so BKF is inside, thus allowing the same reasoning to be used again to allow an increase of the site coming all the way down to the Crane Valley. You seem not to be sufficiently aware of this protected site and its value to the setting of the Wealden Town of Cranbrook.

DLP_6817

Persimmon Homes South East

2.0 DRAFT LOCAL PLAN - DEVELOPMENT STRATEGY

2.1 As noted above Persimmon Homes are supportive of the draft Plan and the allocation AL/HO3 in particular. We are thereby keen that the Plan progresses successfully through the Local Plan process including examination. To this end we set out below a number of observations and recommendation concerning the emerging Development Strategy.

Housing Requirement

2.2 Table 1 of the Reg 18 plan identifies the housing need for the period 2016 – 2036 to be 13,560 dwellings (678dpa). This is said to be based upon the standard methodology (2014 based household projections (published July 2016)), projected household growth in Tunbridge Wells for the period 2019-2029 and the affordability ratios published in April 2019. Whilst we believe the figure to be 682dpa, we note para 3.2.1 of the Housing Topic Paper (HTP) suggests the figure of 678 is being used as it is based upon submission in 2020. This being the case the plan when submitted needs to be clear on this point and all associated calculations clarified accordingly. We also believe, for the reasons set out below, that the plan period should also be amended and start in 2020 not 2016 as drafted.

Whether the Plan should provide for more than the minimum local housing figure

2.3 The plan should, given ID: 2a-010-20190220 of the PPG, consider whether it might be appropriate to plan for a higher housing need figure than the standard method indicates given issues such as local affordability.

2.4 The housing needs survey 2018 identifies a net affordable housing need of 443dpa. As policy H5 looks to deliver 40% affordable provision on all greenfield sites of 9 (+) dwellings, and acknowledging that not all sites provide affordable housing, in order to meet 100% of the affordable requirement one would conservatively need to deliver circa 1,107 dpa over the plan period. This is clearly significantly greater than the figure generated by the standard method, (678/682dpa) and whilst the standard method takes into account affordability issues, this does beg the question as to whether TWBC need to consider whether it might be appropriate to plan for a higher housing need figure than the standard method indicates. If nothing else the SA should in our opinion assess this point.

2.5 In the context of the above we also note that the figure of 678/682dpa is the minimum local housing need figure. It is capped at 40%. The uncapped figure is in fact 762dpa . This figure would better be described as the actual housing need, with 678/682dpa simply being the minimum Local Housing Need figure defined by the standard method. Again, given the scale of the affordable housing need the HTP and the SA should 634/B1/CC/TA 4 November 2019 in our opinion consider the issue of the plan providing for more than the minimum local housing need figure.

2.6 Finally, having regard to the issues around the Duty to Cooperate, there is the issue of Sevenoaks District Councils (SDC’s) unmet need. Whilst we note that the SA does consider a growth option that encompasses SDC’s unmet need (option 7 – see below), para 6.2.2 of the SA appears to dismiss this option on the basis that it was assumed that the additional 1,900 dwellings would essentially be located within the AONB. It is not clear how this conclusion has been reached. In addition there is nothing that allows one to undertake a like for like comparison of the SA findings on option 7 (as set out in table 14) against the options considered in the earlier SA and the chosen option – such that the rational for this decision does in our opinion require further clarification.

The Plan Period

2.7 The Government’s Planning Practice Guidance (ID: 2a-004-20190220) indicates that when setting the baseline, the projected average annual household growth over a 10 year period should be calculated and that “this should be 10 consecutive years, with the current year being used as the starting point from which to calculate growth over that period”. Thus, the plan period should start at 2020 if it is to address the OAHN identified by the Standard Method of 678 (2020-2030) rather than 682 (2019-2029).

Duty to Cooperate

2.8 Having reviewed the interim Duty to Cooperate Statement we note that housing is seen as a cross boundary strategic issue and that a Statement of Common Ground (SoCG) has already been signed with both Maidstone Borough Council (MBC) and Sevenoaks District Council (SDC) that look to address this issue, amongst others. We also note that the SoCG with MBC is dated August 2016 and that with SDC is dated May 2019.

2.9 As the Borough Council will be aware, the Duty to Cooperate places a legal duty on local planning authorities to engage constructively, actively and on an ongoing basis to maximise the effectiveness of Local Plan preparation in the context of strategic cross boundary matters. We do not believe, given the above, that the SoCG with MBC and SDC can be seen as demonstrating actively and ongoing engagement at this stage of the plan making process – we would expect there to be a rolling program of engagement to address matters as they arise through the consultation on the Reg 18 and Reg 19 plan. Thus, the SoCG would need to be updated accordingly.

2.10 In addition to the above, we are mindful of the recent correspondence between SDC and their Inspector, especially documents ED37 and ED40. It is clear from the latter that the Inspector did not accept that 634/B1/CC/TA 5 November 2019 reliance on a review of the Plan to address the issue of SDC’s unmet need was appropriate or complied with the duty, which applies specifically to plan preparation, which as the Borough Council are aware ends when the plan is submitted for Examination. Thus, this issue needs to be thoroughly examined and addressed in the SoCG that are submitted prior to submission of the Plan. Which means TWBC need to liaise with SDC about where they now are with this issue and the TWLP needs to clearly demonstrate why it cannot, if that is the case, help address SDC’s unmet need.

Sustainability Appraisal

2.11 TWBC must comply with Directive 2001/42/EC (the SEA Directive) and the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA Regulations) as required by the Planning and Compulsory Purchase Act 2004 while preparing the Local Plan.

2.12 TWBC are required under Article 4 of the SEA Directive to ensure that their environmental assessment is carried out “during the preparation of the plan”. Therefore, any changes or modifications to the emerging Local Plan prior to its adoption must be considered as part of the environmental assessment.

2.13 Regulation 12(2) SEA Regulations provide that the Sustainability Appraisal of the Local Plan must identify, describe and evaluate the likely significant effects on the environment of implementing the particular development plan and reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme.

2.14 Section 6 of the Sept 2019 SA reviews the growth strategy. It demonstrates that six options were considered at Issues and Options:

  • Growth Strategy 1 – Focused Growth - growth focussed largely on existing urban areas;
  • Growth Strategy 2 – Semi Dispersed Growth - growth focussed largely on urban areas plus some larger villages;
  • Growth Strategy 3 – Dispersed Growth - growth distributed proportionally across all existing settlements;
  • Growth Strategy 4 – Growth Corridor Led Approach - growth focussed on the A21 corridor near Royal Tunbridge Wells and Pembury;
  • Growth Strategy 5 – New Freestanding Settlement - growth within a new, free-standing settlement; and
  • Growth Strategy 6 – No Local Plan. Following consultation two further options were considered:
  • Growth Strategy 7- Growth including Sevenoaks Unmet Need 634/B1/CC/TA 6 November 2019
  • Growth Strategy 8 - Dispersed Countryside Growth

2.15 Para 6.2.4 of the Sept 2019 SA suggests that Growth Strategy 5 had the highest number of positive scores and lowest number of negative scores. It also explains that: ‘This option, which has been taken to embrace an enlarged town or village based on garden settlement principles as well as a new freestanding garden settlement, is therefore proposed to be integral to the preferred development strategy for the borough.’

2.16 Notwithstanding the above the Sept 2019 SA also explains at para 6.2.6 that it would neither be reasonable in SA terms, nor practical, to focus unduly on new or expanded settlements as the solefocus of meeting the housing needs of the borough. And that as such, as set out in para 6.2.8 and 6.2.9 the growth strategy incorporates both growth strategies 3 and 5.

2.17 In order to fully understand the rationale behind the growth strategy, one has however to refer back to the Sustainability Appraisal Issues and Options Report May 2019, as it is chapters 4 and 5 of this documents that appraises each of the proposed growth options against the Sustainability Objectives, considers how one could mitigation adverse effects and maximise the beneficial effects, and recommends the further investigation of growth options 5 and 4. Whilst para 5.3.1 goes on to advise that: ‘it is pertinent to note that this recommendation is subject to locational constraints’ we are concerned that not only does one have to go on a paper chase to fully understand the rationale behind the chosen growth/ spatial strategy, but that the findings of the May 2019 SA differ from those of the Sept 2019 SA without any explanation. This needs to be rectified in the Reg 19 SA.

2.18 Whilst the SA does in our opinion review the reasonable alternatives to the growth options/ spatial strategy, and the associated options for the scale and location of growth proposed within the new settlement/ enlarged town it does in some areas require a paperchase and in others is not perhaps as clear and robust as it could be, such that we believe the SA should be reviewed and updated when the Reg 19 plan is published.

[TWBC: See full representation]

DLP_6837

John Gibson

The paragraph refers to employment areas within the Borough but makes no reference to any in Sissinghurst despite the high number of new homes being proposed.

DLP_6838

John Gibson

As there is no exceptional need for more houses in Sissinghurst the proposed development is not appropriate. It is also not sustainable in terms of infrastructure and because it is a valued and protected landscape being adjacent to the Weald AONB.

DLP_6841

John Gibson

The elected Parish Council for Cranbrook and Sissinghurst commissioned an independent assessment of the local housing needs as part of the generation of the local NDP. The conclusion was that the TWBC figure was higher than required and that the local needs could be met by small scale housing developments.

Why is this professional assessment being ignored?

DLP_6842

John Gibson

As so many people will commute to work why is this development even being considered being so away from local towns and railway stations?

DLP_6843

John Gibson

The LBD has been redrawn by TWBC against the wishes of the local Parish Council in order to make it possible to consider developments outside the existing limits to built. This appears to me to be a subversion of the Policy and an abuse of democratic power. It would seem that the Policy is meaningless if it can be altered whenever it suits.

DLP_6845

John Gibson

The planning application for this site shows little or no regard for the high standards of design and place shaping. I would expect the planning department to insist on the high standards decreed.

DLP_6846

John Gibson

The provision of sustainable transport is to be welcomed. However, allowing so many developments away from centres of employment will only increase car dependency.

DLP_6856

John Gibson

Section 4 Paragraph 18

The economic needs study (ENS) recommends that the TWBC allocates at least 14 hectares of new employment land in order to support new employment alongside the proposed new housing. No provisions at all have been planned in parallel with the extra houses being proposed in Sissinghurst. The extra commuting this will generate will result in a further failure to meet the sustainability objectives.

DLP_6944

Hallam Land Management Ltd

Housing Development

Hallam would agree that the Council have correctly recognised the objectively assessed housing need for the borough over the plan period to 2036 of 13,560 dwellings (678 per year) as identified by the standard methodology. Although the Council needs to be aware that the National Planning Policy Framework (NPPF) suggests the local housing needs represent a minimum number of homes that should be delivered. As such, the Council need to be aware of the potential unmet need from adjacent neighbouring areas, with Sevenoaks District Council (recognised in Paragraph 4.8) as not proposing to meet their housing need and the Council need to establish whether this unmet need could be accommodating in Tunbridge Wells borough. This is part of the NPPF test of soundness whereby a Plan needs to be ‘Positively Prepared’ providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.

The Development Strategy of the Draft Local Plan for consultation

Hallam recognise there are a number of factors that are important to ensuring that the Council ensures that the borough is environmentally sustainable and welcomes the housing growth needs of the borough based on Option 3 (dispersed growth). However, fundamental to this objective, is an appropriate housing distribution strategy. As referenced elsewhere in our representations, the location of new housing development should have regard to the relative sustainability of the towns / villages in the borough, focusing on those with the greatest range of services / potential to maximize the use of non-car modes of transport. This dispersed strategy should remained consistent with the sustainability of individual settlements looking to the Small Rural Towns, at first, which have a range of services and access to shopping facilities, schools and public transport bus services, (most notably Cranbrook).

DLP_7153

Kay Margaret Goodsell

4.19

New jobs aer going in Tunbridge Wells so that is where the houses should be.

Jobs are going in Tun Wells and houses at our end of the county.  This does not make sense.  The houses should go in Tun Wells there is plenty of space around the town.

4.26

‘Well designed and sustainable communities’ How is Sissinghurst being well designed by this Plan?  The houses are just being dumped where people want to make a bit of money by selling their land.

4.39

The areas chosen for employment (Options 1,2,& 4) are different from those chosen for housing (Options 3 & 5), so more people will be driving everywhere.

4.40

Where is the major urban expansion – there are no great changes to our main town – TWells, all the houses are being put at the other end of the county.

DLP_7191

John Gibson

The paragraph refers to new employment areas within the Borough but makes no reference to any in Sissinghurst despite the high number of new homes being proposed.

DLP_7192

John Gibson

As there is no exceptional need for more houses in Sissinghurst the proposed development is not appropriate. It is also not sustainable in terms of infrastructure, extra need for transport and because it is a valued and protected landscape adjacent to the Weald AONB.

DLP_7194

John Gibson

The elected Parish Council for Cranbrook and Sissinghurst commissioned an independent assessment of the local housing needs as part of the generation of the local NDP. The conclusion was that the TWBC figure was higher than required and that the local needs could be met by small scale housing developments.

Why is this professional assessment being ignored?

DLP_7195

John Gibson

As so many people will commute to work why is this site even being considered being so far away from local towns and railway stations?

DLP_7196

John Gibson

The LBD has been redrawn by TWBC against the wishes of the local Parish Council in order to make it possible to consider developments outside the existing limits to built. This appears to me to be a subversion of the Policy and an abuse of democratic power. It would seem that the Policy is meaningless if it can be altered whenever it suits.

DLP_7197

John Gibson

The provision of sustainable transport is to be welcomed. However, allowing so many developments away from centres of employment will only increase car dependency.

DLP_7206

DHA Planning for Inter-Leisure Ltd

1 Local Plan Representation

1.1 Introduction

1.1.1 This representation has been prepared on behalf of Inter-Leisure Ltd in response to the Tunbridge Wells Borough Council (‘TWBC’) Draft Local Plan Consultation, which runs until an extended deadline of 15th November 2019.

1.1.2 Our client controls Paddock Wood Garden Centre, Maidstone Road (herein ‘the Garden Centre’ or ‘the Site’) and it is their intention to promote it for allocation in the finalised draft of the Local Plan.

1.1.3 The site was not put forward as part of the Call for Sites process, however it is available and adjoins the proposed extension to Paddock Wood (Policy AL/PW1). It therefore represents a logical location to extend the allocation boundary and contribute toward meeting identified development needs. In particular, the associated additional retail needs that will arise from the increased population.

1.1.4 This representation therefore comments on the content of the draft plan, outlines why the site represents a suitable location for growth and how development could be delivered on site.

1.2 The Tunbridge Wells Draft Local Plan

Overview

1.2.1 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.

1.2.2 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.

1.2.3 This representation comments on the following elements of the plan: 

* Development Strategy and Strategic Policies; and 

* Place Shaping Policies for Paddock Wood;

[TWBC: see full representation. See also Comment No. DLP_7205 (Policy STR/PW 1].

Development Strategy and Strategic Policies

1.2.4 The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the borough and where such development will be located.

1.2.5 In terms of economic and retail development, the National Planning Policy Framework (‘NPPF’) states that planning policies should help create the conditions in which businesses can invest expand and adapt. Moreover, planning policies should set out a clear economic vision and strategy that plans positively, and proactively encourages sustainable economic growth.

1.2.6 The Sevenoaks and Tunbridge Wells Economic Needs Study (‘ENS’) was produced in 2016 to inform the plan and make recommendations for the future provision of employment land (use classes B1, B2, and B8). It recommended that the Council should plan positively to facilitate economic growth by allocating news sites, and identified a need of circa 14 hectares of new employment land to support new opportunities alongside the provision of new housing. Specifically it recommends the extension of existing employment areas, including those around Maidstone Road in Paddock Wood.

1.2.7 Moreover, the retail and leisure needs of the borough have been determined through the Retail and Leisure Study (2017), which identified a need for between 21,700 and 34,000 square metres of additional comparison floorspace and between 7,500 and 9,500 square metres of additional convenience floorspace.

1.2.8 The strategy for meeting identified development needs is consolidated by Policy STR1, which sets out the quantum of development that will be allocated within or around settlements to meet the identified needs over the plan period.

1.2.9 In this respect, the strategy seeks to expand Paddock Wood - following garden settlement principles - to deliver housing and employment growth, new and expanded education facilities and provide strategic flood risk solutions.

1.2.10 A new garden village at Tudeley is also proposed, which would deliver circa 2,500 - 2800 new houses (1,900 homes within the plan period) as well as a package of infrastructure measures. The remaining growth would be dispersed proportionately to settlements in the borough.

1.2.11 We support the overall principle of the strategy and consider that Paddock Wood represents a sustainable location to deliver housing and other development needs, through a comprehensive master-planned approach.

1.2.12 Nonetheless, given Paddock Wood Garden Centre’s geographical location to the proposed allocation boundaries, to exclude it from the masterplan area would have a negative impact upon the long term viability of the site. Instead, it should be included within the Paddock Wood site allocation, identified for intensified or new employment/retail provision.

DLP_7207

Elizabeth Daley

Local research from the NDP group indicates that the parishioners are against large scale development

According to the NPPF, there should be no largescale development on AONB unless exceptional need is proven, which it is not in the Parish of Cranbrook and Sissinghurst

DLP_7209

Elizabeth Daley

If the ENS is indicating the expansion of existing key employment areas as above, why is such a large proportion of housing being targeted in Cranbrook and Sissinghurst?

DLP_7210

Elizabeth Daley

Local research from the NDP group indicates that the parishioners are against large scale development

There should be no large scale development unless exceptional need is proven, which it is not in the Parish of Cranbrook and Sissinghurst

Development proposed in Cranbrook and Sissinghurst is not sustainable in terms of infrastructure and nor is it ‘aware of the valued and protected landscape.’

There is absolutely no need to put large scale development on AONB when NDP research has shown that the housing numbers can be delivered more sensitively and appropriately in small scale, sustainably designed developments that do not impact the AONB landscape in the same way that large estates do

The above statement (TWBC Comment - refers to para 4.40) is belied by the following statement

4.69 The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area.

DLP_7211

Elizabeth Daley

Why has TWBC not pushed back about housing numbers when 70% of the Borough is AONB? Is it because of the income generated for ‘projects’ by development?

62% of the Parish of Sissinghurst and Cranbrook is AONB, yet the large scale developments being proposed are all on AONB.

DLP_7213

Elizabeth Daley

Houses are needed in the Parish of Cranbrook and Sissinghurst. An independent provider of professional support services has been used to arrive at a figure for housing in the Parish which is a bit less and can be delivered by small scale housing developments and yet this research commissioned by the NDP, has been ignored by TWBC

DLP_7215

Elizabeth Daley

Why then are so many houses being built so far from major settlements and train stations?

eg.Maidstone: 14 miles, Tunbridge Wells 14 miles, Hastings 18 miles, Ashford 18 miles

Staplehurst Station, 6 miles (car park full at peak), Marden Station 8.6 miles (car park full at peak)

Whilst significant traffic jams are regularly created at Hawkhurst, Goudhurst and Flimwell when people are trying to leave the Parish of Cranbrook during peak work times.

This is not infrastructure led development.

It therefore follows from the above statement that 50% of the residents of new homes in Cranbrook and Sissinghurst will get into a car to commute out of the Borough to work. This cannot be sustainable.

In addition a further percentage will get into a car to leave the Parish for work again this is not sustainable

The Parish has undertaken a Housing Needs Assessment which has shown how many houses need to be built to accommodate the people that live, or aspire to live in the Parish. Why is this not taken into account?

DLP_7217

Elizabeth Daley

If the above statement is a policy, then the LBD of Cranbrook and Sissinghurst should NOT be re-drawn. Already, the largest development in the Parish for at least 40 years, has been allocated adjacent to the LBD and therefore justified. The proposal to re-draw the LBD to enclose this development then allows the next largest site to be bought forward using the same justification, against the wishes of the local residents

4.87 Although very close to the LBD boundary, the site at Turnden Farm, Hartley Road, to the south west of Cranbrook has also been excluded at this stage. However, it is anticipated that these sites will be reviewed and refined for the next stage of the Local Plan.

DLP_7219

Elizabeth Daley

Little attention has been paid, thus far to high standards of design and place shaping in Cranbrook and Sissinghurst. Developments just completed or nearing Outline and Detailed applications, are a poor pastiche of local vernacular, with cost being an excuse for shoddy design and a top down approach to planning design. I have no confidence that the planning department will enforce high standards, or indeed listen to the community in this respect.

DLP_7220

Elizabeth Daley

This is so far from what is happening in Cranbrook and Sissinghurst (which has its own design code) that I find it hard to believe that this will be enforced in any meaningful way.

Developers have stated that they build to TWBC building standards and that solar panels are not economical. Lip service is paid to sustainability and adaptation to climate change with the installation of water butts and apparently very little else

DLP_7222

Elizabeth Daley

Whilst the facilitation of sustainable transport is to be applauded, building so far away from the proposed centres where employment will be targeted cannot possibly reduce private car dependence

DLP_7224

Elizabeth Daley

There is mention of a landscape gap ‘between the two LBDs’. I assume, although it is not stated, that the second LBD is the one around Cranbrook.

As the intention appears to put a significantly large development at Turnden (AONB land) which is outside the LBD, to ‘review and refine’ this for the next stage of the plan is not acceptable. Moving any LBD is a significant step to take, and as such should be consulted on fully from the outset.

DLP_7238

Elizabeth Daley

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

DLP_7239

Elizabeth Daley

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_7260

DHA Planning for Barth-Haas UK Ltd

2.2 Development Strategy and Strategic Policies

The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the borough and where such development will be located.

In terms of economic development, the National Planning Policy Framework (herein the ‘NPPF’ or ‘the framework’) states that planning policies should help create the conditions in which businesses can invest expand and adapt. Moreover, planning policies should set out a clear economic vision and strategy that plans positively and proactively encourages sustainable economic growth.

The Sevenoaks and Tunbridge Wells Economic Needs Study (‘ENS’) was produced in 2016 to inform the plan and make recommendations for the future provision of employment land (Use Classes B1, B2, and B8). It recommended that the Council should plan positively to facilitate economic growth by allocating new sites and identified a need of circa 14 hectares of new employment land to support new opportunities alongside the provision of new housing. It also recommended that the expansion of existing Key Employment Areas would be appropriate.

In addition, the retail and leisure needs of the borough have been determined through the Retail and Leisure Study (2017), which identified a need for between 21,700 and 34,000 square metres of additional comparison floorspace and between 7,500 and 9,500 square metres of additional convenience floorspace.

The strategy for meeting identified development needs is consolidated by Policy STR 1, which sets out the quantum of development that will be allocated within or around settlements over the plan period. The strategy seeks to expand Paddock Wood by following garden settlement principles, to deliver a significant level of housing and employment growth, new and expanded education facilities and strategic flood risk solutions. It also states that the town centre will be regenerated to provide a vibrant and viable new centre for the communities it will serve.

Table 3 of the plan (included as Table 1 below) summarises how the plan will allocate land to meet these identifies needs. In terms of Paddock Wood, it states that retail and other town centre uses will be determined as part of the masterplanning process, and will include convenience and comparison retail provision. Employment uses will also be determined as part of the master-planning process, with Key Employment Areas safeguarded and intensified to provide additional B1/B2 and B8 floorspace.

Paddock Wood  Housing Allocations

Retail and Town Centre Uses

Employment

Infrastructure

Capel  Land around the settlement of Paddock Wood  4,000

To be determined as part of master planning to include convenience and comparison retail provision, as well as range of town centre uses

To be determined as part of masterplanning.

Safeguarding and intensification/ expansion of existing Key Employment Areas to provide additional B1/B2/B8 floorspace to be determined through the master planning process.

Provision of offline 1228 strategic link (Colts Hill bypass) and associated junction improvements.

Other highways and junction improvements

Contribution to link to Tudeley Village  Flood mitigation measures, including new flood storage area and on site measures

Expansion of secondary school  New primary schools

New sports hub and improved sports and recreation provision across the area, including a public swimming pool.

New medical centre

Table 1: Scale and Distribution of Development within and around Paddock Wood

We support the general thrust of the strategy and consider that Paddock Wood is a suitable and sustainable location to deliver housing and other development needs.

Further, our client’s site is well placed to contribute toward meeting these needs – in particular the associated retail and employment needs that will arise from an increased population. Therefore, BarthHaas would like to participate throughout the master-planning process.

However, the wording of policy STR 3 (Master Planning and Use of Compulsory Purchase Powers) does not make clear whom qualifies as a ‘relevant stakeholder’, and this confusion is compounded further by the wording of the place shaping policies for Capel and Paddock Wood - AL/CA 3 and AL/PW 1.

For example, the policy wording (for both policies) states that land is allocated for “ additional employment provision - including expansion of Key Employment Areas ” . It states that the makeup of this employment provision will be informed by the master-planning process.

However, it does not make clear whether the use of the term ‘allocation’ refers to the expansion of existing Key Employment Areas (listed by policy ED 1) or newly created development parcels that are earmarked for economic development – parcels 5 (North) and 6 (North East), or both of the above.

If the latter is intended, we would urge the Council to reconsider by involving stakeholders like BarthHaas in the master-planning process, particularly where redevelopment can benefit wider plan objectives - such as the revitalisation of the town centre.

Not only this, the positive wording of policy ED1 has a similar affect as an allocation, in that it provides in-principle acceptance to redevelopment subject to wider criteria being met. With this in mind, it would seem logical to involve these stakeholders in the master-planning process to ensure development is delivered comprehensively and harmoniously.

If the Council intends for landowners in Key Employment Areas to take part, the policy wording should be updated to provide greater clarity on this point.

[TWBC: see full representation. See also Comment No. DLP_7242 (Policy STR/PW 1].

DLP_7350

Wealden District Council

Paragraph Number(s): 4.7 to 4.17 (Housing Development) 

Paragraph 4.7 of the draft Tunbridge Wells Borough Local Plan confirms that based on the projected submission of the Local Plan in 2020, the objectively assessed housing needs for the borough over the plan period to 2036 is 13,560 dwellings (equivalent to 678 dwellings per annum (dpa)), identified by the standard methodology as required by the NPPF. The Plan confirms at paragraph 4.16 that the total capacity of all identified sites (completed houses since 2016, extant planning permissions, retained Site Allocations Local Plan allocations, development through windfall sites, together with new allocations proposed in the draft Local Plan) provides for some 14,776 (net) additional dwellings.

Therefore, the draft Tunbridge Wells Borough Local Plan would meet the housing needs identified under the standard methodology and would actually overprovide by approximately 9% if each site was to be brought forward as anticipated. However, it is recognised under paragraph 4.10 of the Draft Tunbridge Wells Borough Local Plan that Tunbridge Wells Borough Council (TWBC) would apply a 10% non-delivery rate for all existing extant planning permissions and sites contained within the retained Site Allocations Local Plan. It is considered, in the context of the new NPPF, that all housing sites included within supply for the Plan period should either be identified as ‘deliverable’, ‘developable’ or as a ‘broad location for growth’ in line with paragraph 67 of the NPPF.

A 10% non-delivery rate across all housing sites in the categories above, particularly for those sites with detailed planning permission, may not conform to the latest NPPF and national planning practice guidance on these matters (see the NPPF Annex 2 Glossary – Deliverable). It is noted that this non-delivery rate is subject to further information about the delivery of such sites and that further information may come forward in the next iteration of the Plan. However, it is considered that the question as to whether a housing site can be delivered or not should be on a case by case basis in line with definition of ‘deliverable’ and ‘developable’ in the latest NPPF. The application of a 10% non-delivery rate to these categories may mean that the Plan actually delivers more than the minimum housing requirement for the Borough and could potentially deliver for the housing needs of neighbouring authorities, if it was established that this was required.

Paragraph 4.8 and 4.9 of the draft Tunbridge Wells Borough Local Plan confirms that a) adjoining Councils are generally seeking to meet their own housing needs and b) that TWBC will keep the housing needs of both the borough and neighbouring councils under review and may need to update its housing targets as the Local Plan progresses. The Submission Wealden Local Plan (January, 2019) confirms that Wealden District Council is seeking to meet its own housing needs and that for the submitted Local Plan, it has not asked TWBC or other neighbouring authorities to meet its housing needs. Wealden District Council supports the position taken by TWBC relating to reviewing and where necessary updating its potential unmet housing needs of both the borough and neighbouring authorities who’s Plans are under review or will be in the near future.

Paragraph Number(s): 4.18 – 4.23 (Economic Development) 

Paragraphs 4.18 – 4.19 of the draft Tunbridge Wells Borough Local Plan states that the Sevenoaks and Tunbridge Wells Economic Needs Study (ENS) recommends that the Council should allocate sites to accommodate at least 14 hectares of new employment land in order to support the creation of new employment opportunities over the Plan period. It is noted that the target of 14 hectares will be reviewed as part of the preparation for the Regulation 19 stage of the Local Plan.

The draft Tunbridge Wells Local Plan recommends the expansion of the existing Key Employment Areas at North Farm/Longfield Road in Royal Tunbridge Wells, around Maidstone Road in Paddock Wood, and at Gill’s Green. Additionally, it is recognised the area around the A21 highways improvements as a location for significant employment growth potential. The importance of Tunbridge Wells town centre is also recognised in terms of existing and future office provision.

Wealden District Council supports the approach taken by TWBC relating to the identification of Key Employment Areas and recognises the importance of Tunbridge Wells town centre not only for residents and workers in Tunbridge Wells Borough, but also for those in surrounding areas including the Wealden District.

Paragraphs 4.22 – 4.23 states that the Retail and Leisure Study identifies a need for between 21,700 and 34,000 sqm of additional comparison floor space and between 7,500 and 9,500 sqm additional convenience floor space. It is noted that the retail market is in a current state of change and that allocated retail needs should look at least ten years in advance, with a review of needs as part of the Local Plan review process in accordance with the NPPF. The Plan includes detailed policies in relation to Royal Tunbridge Wells town centre as well as a retail hierarchy.

Wealden District Council supports the approach taken by TWBC in reviewing future retail floor space needs and the identification of a retail hierarchy to direct planning proposals. The Submission Wealden Local Plan states (January 2019) at page 30 (Table 1: Current Settlement Hierarchy) that Tunbridge Wells is at the top of the settlement hierarchy and is described as “a regional centre with accessibility to high order facilities and public transport options”. It is supported that the focus of retail development within the borough would be in Tunbridge Wells, which is recognised as an important centre for those in surrounding areas, including Wealden District.

DLP_7504

Sarah Parrish

Why use out of date figures?

DLP_7507

Sarah Parrish

Why is the distribution of Housing Allocation so uneven throughout the Borough?

Why not build on areas of land with no Green Belt, No Flood Plain, No AONB locality and not next to Tonbridge?

DLP_7508

Sarah Parrish

Why does TWBC want to ribbon-develop from Tonbridge to Paddock Wood?

How can the TWBC ensure agreed levels of affordable housing to Local Resisdents – especially if Hadlow Estates controls the development?

DLP_7526

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 4: The Development Strategy and Strategic Policies

We applaud the council for actively seeking to meet their OAN housing figure of 13,560 dwellings (678 dwellings per year) and being proactive in the allocation of strategic sites in order to deliver this. Charterhouse supports the development strategy for Paddock Wood within Policy STR 1. However wish to emphasise the importance of the garden settlement principles and betterment of the community through infrastructure, schools and the creation of strategic flood solutions to reduce flood risk around Paddock Wood. Such considerations have a large influence on how the strategic allocation for Paddock Wood will come forward. And it is essential the Council’s management of the comprehensive approach to masterplanning and the equalisation of land is implemented. In the wider context we fully support the allocation at Paddock Wood and the inclusion of our landholding as part of the allocation.

Charterhouse trusts that the above comments will be taken into account and considered constructive in assisting the council to move forward to the next phase of the Local Plan preparation. Charterhouse are pleased to be taking part in the Strategic Site Working Group and masterplanning exercise and look forward to more constructive discussion on this matter with the council and other landholder parties.

[TWBC: see site location plan].

DLP_7619

Mr J Boxall

4.38

The Local Plan states that the development strategy for housing growth needs are based on Option 3 (dispersed growth) and Option 5 (stand alone garden settlement).

I agree with this strategy overall but the dispersed growth option does not appear to have been applied fairly or proportionately across the borough.  The eastern area of the borough, in particular Cranbrook and Sissinghurst, has much more housing allocated to it compared to a proportionally very small number of houses to be developed in Tunbridge Wells.  This is contrary to policy ED 8 which states the hierarchy of development.

The Local Plan states that Tunbridge Wells is to be the economic and cultural centre so it should take more housing proportionate to its current population and additional housing due to its economic opportunities than is currently proposed.  Given there will no longer be a new theatre then this area could be used to supply affordable housing.

Sissinghurst has poor connectivity with Tunbridge Wells due to a slow, infrequent no. 267 daytime only bus service that does not even directly serve the village, or via the infrequent No. 5 bus service and 2 trains via Staplehurst station or via the congested A21 through the often gridlocked village of Goudhurst.

4.39

If housing is to be developed on a dispersed growth basis then employment opportunities through the economic growth strategy should also be on a dispersed growth basis to match increases in population and to minimise additional journeys, via public transport or car.

TWBC should not put such large quantities of housing in Sissinghurst and Cranbrook without additional economic opportunities and should have a policy to provide additional business sites, other than those already shown in the Local Plan, in The Weald.  This particularly important due to the poor public and road transport system for this area in getting to Tunbridge Wells.

4.40

This states that the growth strategy is based on the premise of infrastructure-led development.  Key infrastructure required for additional housing in Sissinghurst  includes greater accessibility to Tunbridge Wells on a dualled A21 between Lamberhurst and Blue Boys. This infrastructure is not in place and will not be in place before the housing in this plan is developed so the Local Plan is obviously not infrastructure led.

To be an infrastructure led Plan then much more development should be around Tunbridge Wells and the already dualled A21.

DLP_7621

Mr James Peace

If the ENS is indicating the expansion of key employment in Tunbridge Wells and Maidstone why is such a large proportion of housing being proposed for Cranbrook and Sissinghurst.

DLP_7623

Mr James Peace

Local NDP research indicates that parishioners are against large scale development. The need for such large scale development is not proven. Proposed development in Cranbrook and Sissinghurst is not sustainable in terms of infrastructure and there is no awareness of the valued and protectced landscape. Housing numbers can be delivered with small scale, sustainably designed developments that do not impact AONB landscape.

DLP_7645

John Gibson

Section 4  Paragraph 18

The economic needs study (ENS) recommends that the TWBC allocates at least 14 hectares of new employment land in order to support new employment alongside the proposed new housing. No provisions at all have been planned locally for the extra houses being proposed in Sissinghurst. The extra commuting this will generate will result in a further failure to meet the Sustainability objectives.

DLP_7729

Peter Smart

Response to para. 4.69

I object strongly to the development policy within the local draft plan to build 818 – 918 houses in Cranbrook and Sissinghurst and a further 681-713 in Hawkhurst village areas which sit within the High Weald Area of Outstanding Natural Beauty (AONB).

Areas of Outstanding Natural Beauty are designated under the National Parks and Access to the Countryside Act (1947) and, along with National Parks, Area of Outstanding Natural Beauty (AONB) represent the finest examples of countryside in England and Wales. Their landscape beauty, including the protection of flora, fauna, and geological interests.

Development affecting such areas is restricted under the National Planning Policy Framework and is contrary to Tunbridge Wells Borough Council (TWBC) adopted policy for the High Weald AONB set out in the AONB management plan 2019-2024, adopted by TWBC in March 2019.

Response to para. 4.70

The scale of developments within this area of outstanding natural beauty is contrary to the National Planning Policy Framework (NPPF) para. 172 which says ‘great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, The Broads and AONB, which have the highest status of protection in relation to these issues. The NPPF para 11, makes it clear that AONB designation may provide ‘a strong reason to for restriction the overall scale, type and distribution of development in the planned area’. This is reinforced by Planning Practise Guidance updated in July 2019 which makes it clear that the protection of such areas may mean it is not possible to meet objectively assessed needs for development in full.

My above arguments applies to all areas within the borough sitting within the High Weald AONB, area which seem to be disproportionately expected to provide a large number of new homes for the borough, without thought for the where people might work, the impact on the landscape and surrounding roads which are already heavily congested.

DLP_7755

Annie Hopper

The description above of intimate, small scale settlements which are characteristic of AONB’s components of natural beauty goes completely against the proposal for large scale development. There should be NO large scale development on AONB to retain its natural beauty.

DLP_7757

Annie Hopper

The ENS is recommending no key employment areas in Cranbrook and Sissinghurst therefore why is such a large proportion of housing being targeted there?

DLP_7758

Annie Hopper

The draft allocations for Cranbrook and Sissinghurst do not take into account local need which according to the AECOM housing needs assessment 2017 is considerably less than 900 houses.

Development on valued and protected landscapes should mean that no large scale, ill thought out and badly designed developments can take place in the AONB.

ALL Cranbrook’s allocations in the draft LP are within the AONB and there are at least four that are large scale developments.

Local research from the NDP group indicates that the parishioners are against large scale development, which is also supported by the AONB itself.

Development proposed in Cranbrook and Sissinghurst is not sustainable in terms of infrastructure.

NDP research has shown that the housing numbers can be delivered more sensitively and appropriately in small scale, sustainably designed developments that do not impact the AONB landscape in the same way as large development.

DLP_7759

Annie Hopper

This statement from the NPPF clearly indicates that development numbers can be reduced if there is a risk to valued landscapes – why has TWBC not pursued this in relation to housing numbers given that 70% of the Borough is AONB?

62% of the Parish of Sissinghurst and Cranbrook is AONB yet the large scale developments being proposed are all on AONB.

DLP_7764

Annie Hopper

Why are so many houses being built so far from major settlements and train stations?

The roads are already significantly congested with major traffic jams in Hawkhurst, Goudhurst and Flimwell. This is before the proposed allocations in Hawkhurst and Cranbrook.

If the above statement is correct then 50% of the residents of new homes in Cranbrook and Sissinghurst will get into a car to commute out of the Borough to work. This cannot be considered sustainable.

The Parish has undertaken a Housing Needs Assessment which has shown how many houses need to be built to accommodate the people that live, or aspire to live in the Parish. Why is this not taken into account?

This is not infrastructure led development! This is building solely to accommodate housing targets.

DLP_7765

Annie Hopper

Despite the above statement – there are several sites that could be redeveloped and infilled within the current LBD that are not in the LP draft allocations – instead TWBC have chosen large scale developments to help achieve their numbers as quickly as possible and ignored the opportunity to masterplan the town centre.

The LBD of Cranbrook and Sissinghurst should NOT be re-drawn to accommodate more large scale developments. Already, the largest development in the Parish for at least 40 years (Brick Kiln Farm), has been justified by stating that it is adjacent to the current LBD. The new proposal to re-draw the LBD to encompass this development then allows the next largest site (Turnden Farm) to be bought forward using the same justification. This is totally against the wishes of local residents and draft policy of the emerging NDP.

DLP_7766

Annie Hopper

Para 4.64

There is no evidence in the draft LP that any attention has been paid high standards of design and place shaping in Cranbrook and Sissinghurst. Planning decisions appear to involve many people with no detailed knowledge of the requirements and needs of Cranbrook and Sissinghurst – it is time to listen to the community in this respect.

Para 4.65

There is again no evidence that this is being carried out in Cranbrook and Sissinghurst – this sounds like an ‘aspiration’ only intended to tick another box in what is required when writing a local plan.

Developers have stated that they build to TWBC building standards and are not required to improve building standards to the Cranbrook and Sissinghurst design code. Lip service is paid to sustainability and adaptation to climate change with developers providing the minimum they can get away with – much more needs to be done in this regard – actions from TWBC are required rather than just words in a local plan.

DLP_7768

Annie Hopper

How is this possible when TWBC is advocating building so far away from the proposed employment centres? This cannot possibly reduce private car dependence.

DLP_7796

Robert Saunders

General Comment

I recognise the need for new dwellings in the parish, and welcome appropriately scaled, high quality developments that respect the intimate settlement pattern of the High Weald AONB, based on Dens and Hursts.

Object

National planning policy allows for development to be reduced where valued landscapes will be damaged, (NPPF, Para 11.) 62% of the civil parish is designated AONB.  Why has TWBC not argued for lower housing allocations to protect the AONB landscape and its communities?

Object

Cranbrook and Sissinghurst Parish Council have evaluated the parish’s housing need and arrived at a lesser figure than that proposed, and further have evaluated the sites and need for affordable housing.  TWBC appear to have ignored these assessments – why is this the case?  It appears to be profoundly anti-democratic.

DLP_7803

John Bancroft

Paragraph 4.10 - Has a full appraisal taken place of all brownfield sites in the Borough to examine what housing need these can provide?

Paragraph 4.09 - Housing need should address both number of new homes and type of new homes. Recent development in rural areas has favoured larger 4/5 bed homes which are out of the reach of local people. This in turn causes migration from the Borough particularly of younger people.

DLP_7847

Judith Williams

I find that the "Local Plan" makes terrifying and bewildering reading.

I understand that you are being asked to increase the number of residential properties within the borough and that this increase is beyond your control. However, I think the places that you plan to put these houses is often unwise and the impact that they will make on the roads where the new home owners will be driving out to join existing traffic will cause no end of problems and delays.

DLP_7969

Sharon Pickles

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_7998

Richard Pickles

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_8014

Penny Ansell

1.35, 4.35 and 4.36 I would draw your attention to the FACT that Hawkhurst has a Neighbourhood Development Plan which has been “made” and it is, therefore, a requirement that TWBC takes this into account when developing the Local Plan. Clearly when reading the Local Plan it is obvious that TWBC have ignored the NDP for Hawkhurst.This was produced at great expense earlier in the year and approved by popular vote. I would also draw your attention to the point made in 1.36 regarding the need to ‘ensure local development issues, needs and aspirations are understood by officers’ (of the Council) and to Strategic Objective 10 “to work with neighbourhood plan groups to ensure the formation of locally-led policies with this reflected in decisions on planning applications”

The recent experience in Hawkhurst is that TWBC takes very little notice of the views and concerns of the Parish Council and the Council’s claim (4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan.

4.7 Housing Development. The figures given propose that from 2016 - 2036 a target of 13,560 dwellings (678 per year) should be built. It is stated that this target is based on standard methodology as required by NPPF.

I would like to raise a number of points:

  1. A letter from John Hurst in the Tunbridge Wells Times 23/10/19, suggested that “the plan proposes far more houses than are needed…...the 2014 calculation method used to calculate house numbers has been superseded by a 2016 version that would halve them. A new figure of about 7,000 houses could be accommodated on Brownfield sites in Tunbridge Wells and outside the green belt” In other words, the targets could have been considerably reduced (about 7,000 dwellings as opposed to 13,560). This needs explaining
  2. Given that 70% of the borough of Tunbridge Wells comprises AONB, the Council has the option to reduce the targets set. Instead, they chose to increase them by a few ‘00s. Why did they do that?

4.8     Why does Tunbridge wells not follow the example of Sevenoaks District Council in being not prepared to meet their targets?

4.38    Plan Options.    The Council proposes a development strategy to meet housing growth based on:

Option 3 - development distributed proportionately across all boroughs, settlements and

Option 5 a new freestanding garden settlement.

More specifically, this covers 4.40:

  • The growth of Tunbridge Wells
  • Expansion of Paddock Wood
  • New Garden Village at Tudeley
  • sustainable development of an appropriate scale of smaller settlements

Referring to Option 3 which is the part that covers most of the borough and the point just made above about ‘sustainable development of an appropriate scale of smaller settlements’,

how can the following be acceptable:

Tunbridge Wells Population 48,324 (2011 Census) allocated av 1,271 dwellings Hawkhurst   Population 4,991 (2011 Census) allocated av 668 dwellings

Here we have a situation where a town with 10 times the population allocates itself less than 2 times the number of dwellings.

This is NOT proportionate or appropriate to scale and is even more outrageous when you consider that in terms of all forms of infrastructure and access to rail, road and bus networks, Tunbridge Wells is infinitely more advantaged.

How is it also proportionate when Speldhurst which has a population similar to Hawkhurst (4,978 - 2011 Census) has only been allocated 15 - 20 dwellings?

DLP_8032

Rose May McAuley

4.19

You are going to put the new jobs in Tunbridge Wells but we need new jobs here in Sissinghurst especially if there are going to be more people.  Where are we supposed to work?  There are bar jobs at the Milk House pub, a few paid jobs at Sissinghurst Castle which is a bike ride away along a very dangerous road – we are not allowed to cycle through the woods to get there – the two business in The Street employ their family members.  I have to go a mile to work and do not drive.  On the money I earn I cannot afford anywhere to live so am still at home aged 30 but there are no other jobs to move on to.  We need more work in the village.  You are assuming that everyone drives and is happy to travel 40 miles each day for work or go to London and not actually be a part of this village at all.

The jobs are going in Tun Wells and the houses are going in Cranbrook and Sissinghurst and Hawkhurst.  I do not work in a planning office but this does not make sense to me.

4.38

Cranbrook and Sissinghurst and Hawkhurst are given an unfair burden of new housing estates in this Draft plan and I cannot see why this is.  We are at the end of the Borough on the map so well out of the way of Tun Wells and it feels as though we don’t matter.  We love where we live and have had many new houses while I have lived here (all my life) but this Plan is simply unfair.

Tun Wells as a town should take far more – it will not make much difference there but it will totally change the place we love in Sissinghurst.

DLP_8096

Ashley Saunders

Tunbridge Wells Borough Council has interpreted its housing need figure to be 13,560 and then up-scaled it to 14,776. This is despite TWBC having strong grounds to lower its housing need figure due to the large amount of Green Belt and AONB land in the borough.

The Ministry of Housing, Communities and Local Government has repeatedly made clear 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

You have chosen to accept the government’s housing need for Tunbridge Wells borough based on the standard method of calculation. You know that the ONS 2016 figures show a smaller housing need and that policy will reflect that in due course.

You can protect this borough from the destruction of Green Belt and AONB by following NPPF guidelines, but this plan shows no interest in doing so, and in fact is planning for even more housing than your interpretation of the 2014 figures requires. For example, you could save the MGB land at East Capel (Policy AL / CA 3 & AL / PW 1) by choosing a different development option that would require 1,000 fewer houses.

Paragraph 11 of the NPPF (revised in 2019) states:

“11. Plans and decisions should apply a presumption in favour of sustainable development.

For plan-making this means that:

  • plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change;
  • 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:
    1. 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
    2. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”

Paragraphs 11(b)(i) and (ii) are of crucial importance. They provide 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, as TWBC concede at paragraph of the Non-Technical Summary of their Sustainability Appraisal, then the NPPF makes it perfectly possible for TWBC to say that this is not achievable. TWBC have chosen not to do so.

I call for a reduction in the number of houses to be delivered by the Local Plan.

DLP_8098

Ashley Saunders

You are 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 proposed garden settlement in Tudeley (AL / CA 1) and the expansion of Paddock Wood including building on East Capel (AL / CA 3 & AL / PW 1). 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.

You refer to Tudeley Village securing a long term option for the borough to deliver the needs of future generations. It is clear 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 am seriously concerned that this will be the first step in the longer term destruction of the entire MGB in this part of the Borough. It deserves to be protected and sheltered from development. A garden settlement, should there be one, would be best in the middle of the borough, to make it accessible north and south. It is totally counterproductive to put affordable housing right at the very north of the borough when so many residents live in the south. Put it in the middle of the borough or spread it right across the borough.

The developments in Tudeley and East Capel are unsustainable, having a poor road infrastructure and this doing nothing for local employment needs (it will make many local farm workers redundant). It would also put an unfair burden on the residents of Tonbridge and Malling whose infrastructure the new residents will access. ‘The ‘master planning approach’ will come to a grinding halt at the boundaries of Tonbridge, a town whose infrastructure has grown slowly over the last millennium and can hardly be expected to adjust to this challenge imposed on it by the planners of the neighbouring authority. We expect this view to be reflected by TMBC in their response to the regulation 18 consultation.

DLP_8158

Myriam Ruelle

Development Strategy: Strongly object

The housing need figure of 13,560 is incorrect as based on old ONS figures from 2014, and has even been upped to 14,776.  The current (2016) figures are about half of the previous (wrong methodology used in 2014) figures and MUST be revised down.   The 2016 figures themselves are also likely to be over what real needs are.  The figures must be amended.  The NPPF also clearly states the right for the Borough to reject the housing figures: there are very evident adverse impacts that do significantly outweigh any benefits.

DLP_8159

Myriam Ruelle

Development Strategy, Section4, paragraph 4.40Strongly object. Tudeley village must not be considered as a viable option.  Firstly, it is surplus to requirement.  Secondly it is on Green Belt AND AONB and there are NO exceptional circumstances.  Thirdly, it would create a conurbation that would entirely destroy the character of the area.  Fourthly, it would destroy rural landscape, local cultural heritage and make environmental concerns worse.  It would also be a grave danger to local biodiversity.

DLP_8260

Ann Gibson

4.19

If the ENS is indicating the expansion of existing key employment areas as above, why is such a large proportion of housing being targeted in Sissinghurst?

4.40

There should be no large-scale development unless exceptional need is proven, which it is not in the parish of Sissinghurst. Development proposed in Sissinghurst is not sustainable in terms of infrastructure nor is it “aware of the valued and protected landscape”.

DLP_8341

Joe Matthews

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

Paragraph 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_8369

DHA Planning for Mr and Mrs B Gear

2.3 Development Strategy and Strategic Policies (Policy STR1)

2.3.1 The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the borough and where that development will be located.

2.3.2 In terms of the amount of housing, paragraph 59 of the NPPF states that to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed. Further, to determine the number of homes needed, strategic policies should be informed by a local housing needs assessment conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.

2.3.3 The Council confirm that their housing need target for the plan period 2016-2036 is 13,560 dwellings (678 dwellings per annum), which is calculated using the Governments standard method and the 2014-based household projections.

2.3.4 In terms of the different supply components, the Council consider that the Local Plan must (as a minimum) include additional allocations to accommodate 7,593 homes. This figure was formulated taking into account; completions since April 2016 (1,552); extant planning permissions (3,127); outstanding site allocations (588) and a windfall allowance (700 dwellings). The Council have applied a 10% non-delivery rate to these figures to err on the side of caution and consider that the plan would exceed the minimum housing requirement if all of the supply components were achieved.

2.3.5 We agree that TWBC is capable of meeting its need in full and support this approach to plan-making. Likewise, we support the general thrust of the development strategy, which proposes a strategy to meet the housing needs of the borough with a dispersed growth approach. Nonetheless, we have concerns regarding the deliverability of the strategy and the potentially over optimistic housing trajectory, particularly in respect of the delivery from key strategic sites (as outlined below).

2.3.6 We note that the emerging strategy is consolidated by Policy STR1, which sets out the quantum of development that will be allocated within or around settlements to meet the identified needs of the borough over the plan period. This strategy would seek to meet the majority of the Council’s housing need through the strategic extension of Paddock Wood and via a new Garden Village at Tudeley. The remaining growth would then be dispersed proportionately to other settlements in the borough.

2.3.7 We support the general principle of proportionately spreading the benefits of growth. Adopting a pattern of dispersed growth approach would allow a number of sites to be developed at the same time, serving different segments of the local housing market, which is preferable to saturation of the market in a single area.

2.3.8 Nonetheless, we have some concerns regarding the balance between strategic and non-strategic scale allocations and the anticipated delivery trajectory. For example, 65% of new allocations would be delivered as part of the strategic extension to Paddock Wood (4,000 homes) and the new Garden Village at Tudeley (1,900 homes within the plan period), both of which require a fully master-planned approach, which is a time-consuming process. Furthermore, there are a significant number of existing commitments within Paddock Wood that have been slower at coming forward than had originally been envisaged. A cautious approach is therefore needed.

2.3.9 In this regard, we would draw the Council’s attention back to the 2016 document published by Nathaniel Lichfield’s and Partners (NLP) - ‘Start to Finish: How Quickly do Large-Scale Housing Sites Deliver’, which provides evidence pertaining to the speed and rate of delivery of large-scale housing, based on a large number of sites across England and Wales. It identifies that the average lead in time for the submission of a planning application is 3.9 years, from the date the site is first identified. In terms of the planning approval period, for larger scale sites (2,000 + homes) this is circa 6 years. After planning permission is granted, larger sites start to deliver within a year and the average build out rate thereafter is 161 dwellings per annum, although it can be as high as 301 dwellings per annum.

2.3.10 On the basis of this research, if the Local plan is adopted by 2021, planning permission approved by 2023 and delivery commences within 6 years (2029), the likely deliver for the plan period would be no more than 966 homes.

2.3.11 Despite this evidence, TWBC has set a much more optimistic trajectory for delivery of Tudeley Garden Village and the strategic extension of Paddock Wood, which is detailed in the Housing Trajectory Paper. The Council forecast that the Tudeley Garden Village will begin to deliver homes from 2025/26 onward, with an initial build out rate of 150 dwellings per-annum, rising to 200 dwellings per annum from year 6 onward. Likewise, the Council suggests that the extension to Paddock Wood will start to deliver in 2024/25 at an average build out rate of 333 dwellings per annum – which is nearly double the average rate for larger schemes identified in the NLP document. This higher build out trajectory is predicated on an assumption that there would be a number of house builders involved the construction of different parts/phases. However, by their own admission, TWBC do not currently know who or how many housebuilders will be involved.

2.3.12 Taking the above into account, our view is that the Council have applied overly optimistic development trajectory for the delivery of strategic sites, both in terms of the start date for completions and the expected build out rates. Accordingly, we would encourage the Council to increase the balance of small and medium sized sites, which can deliver quickly and usually require limited intervention to infrastructure. Furthermore, it is essential that draft allocations such as our clients are retained and encouraged given the advancement of planning applications emphasises the deliverability of the land.

2.3.13 Given the absence of any similar scale strategic sites in Tunbridge Wells Borough as a point of comparison, one could have regard to similar scale delivery in neighbouring authority Tonbridge and Malling Borough. In this respect, we provide evidence below of its three key strategic sites and the associated delivery rates (derived from the Tonbridge and Malling BV Annual Monitoring Report 2017).

2.3.14 Kings Hill is an extremely prudent example to consider in the context of the Paddock Wood extension and new garden village at Tudeley, how deliverable this would be. Indeed, Kings Hill was a new village started in 1989 near land previously occupied by RAF West Malling. The concept was for a multipurpose site of both residential and office business space. The development is still being delivered some 30 years later, despite having multiple national housebuilders delivering different phases concurrently. Based on the most up-to-date delivery data for the last decade, Kings Hill has only delivered 131 dwellings per annum, despite multiple developers delivering concurrently. Furthermore, the earlier delivery phases we delivered at lower rates given the need to front load infrastructure.

2.3.15 Therefore, we consider that whilst some development may come forward in the plan period from the two proposed strategic sites, in reality these strategic allocations are longer terms aspirations that will extend beyond 2036.

2.3.16 Accordingly, we would encourage the Council to increase the balance of small and medium sized sites, which can deliver quickly and usually require limited intervention to infrastructure, particularly settlements such as Benenden and to reduce the reliance upon Tudeley within this current plan period.

Table 1 Housing Need 2016-2036 (as at 01 April 2019)

Comment No.

Name/Organisation

Response

DLP_2552

Ms S Daniels

The time has surely come to object in the strongest terms to the amount of housing expected of this area. We are in an area of outstanding natural beauty with a high degree of green belt designation (which you are ignoring at Capel/Tudeley). There are limits to growth and are fast approaching them.

Just how much of the expected housing need is coming from local people?  And I do not mean "just" social housing. Most of the drivers for housing demand is in fact from Londoners looking to cash in on our housing market. Why should we have to supply their demands?

The housing that has been built in the town in recent years is over-weighted to flats or "town houses" that have tiny gardens and are cheek-by-jowl with their neighbours. Quality is fair to poor, insufficient detail is paid to climate-proofing these dwellings for the future, and few have any architectural merit.

Even if the town had the space to accommodate this quanity of new dwellings, the necessary infrastructure to support these new residents from cradle to grave, to enable them to move easily around town and its environs, and to have sufficient clean water and clean air is not sufficiently factored in to the local plan.

DLP_4653

CBRE Ltd for Dandara Ltd

Housing Need

3.11 The Draft Local Plan sets out an Objectively Assessed Need (‘OAN’) for the borough of 678 dwellings per annum (based on the 2014-based population projections using the standard methodology), which over the 20-year Plan period amounts to 13,560 dwellings. Of this housing target, taking into account completions, extant permissions, existing allocations and a windfall allowance, it confirms that additional allocations are needed – as a minimum – to provide 7,593 new homes as set out in Table 1 below:

[TWBC: see Table 1 on page 35 of Draft Local Plan].

3.12 It is noted that TWBC’s latest housing target is double the existing Core Strategy target of 300 dwellings per year, and therefore represents a significant challenge in terms of needing to markedly increase housing delivery.

3.13 To ensure delivery of the outstanding requirement for some 12,000 dwellings (as at 1st April 2019), TWBC considers it appropriate to make some allowance for the delay and/or nondelivery of a proportion of the identified sites.

3.14 TWBC considers that the total capacity of all identified sites (outstanding planning permissions, retained Site Allocations, together with new allocations proposed in the Draft Local Plan) provides for 14,776 net additional dwellings (as shown in the Cumulative Housing Completions 2016/17 to 2035/36 column of TWBC’s housing trajectory). This compares to a minimum requirement of 13,560 dwellings, thereby amounting to an oversupply of 1,216 homes (8.23% not 9% as incorrectly stated in the Draft Local Plan: paragraph 4.16 [2 Tunbridge Wells Borough Council:  Tunbridge Wells Borough Local Plan: Draft Local Plan Regulation 18 Consultation Draft (September 2019) Pg. 35.]).

3.15 Dandara considers that the OAN should be clearly expressed as minimum target, consistent with paragraph 73 of the NPPF.

3.16 TWBC’s Housing Supply and Trajectory Topic Paper (September 2019), confirms that independent of TWBC recently updating its 5 year housing land supply position (5YHLS) for 2018/19 which identified that the Council, inclusive of a 5% buffer as determined by the Housing Delivery Test, does not have a 5 year housing land supply, but rather 4.69 years.

3.17 In applying the housing delivery test, TWBC has applied a 9% buffer as part of the total delivery target of 14,776 dwellings to be delivered up to 2036. In the interests of managing housing delivery uncertainty, and building in more resilience over time into the new Plan, Dandara suggests that TWBC should build in a larger buffer, closer to 20%, which may be particularly important if there are delays to delivery, not least relating to Tudeley Village as a garden village settlement. This will ensure the Plan has been “positively prepared” and the housing strategy is robust in accordance with Paragraph 35(a) of the NPPF.

3.18 Dandara acknowledges TWBC’s position in terms of its identified housing need, which brings into sharp focus the importance of including new allocated sites in order to contribute to the scale of growth required, in a way that is sustainable. Dandara further emphasises the importance of including a range of sizes and types of allocated sites in the interests of spreading growth throughout the borough, and to ensure continued delivery of housing supply across the Plan period.

3.19 Dandara will support TWBC by promoting their sites in which they hold a land interest for the delivery of new homes to contribute towards meeting their housing targets.

[TWBC: see full representation].

DLP_3685

Lynne Bancroft

The housing need (row 1) is based on the 2014 household projections. It is now 2019 so this may already be out of date. What would the projections be with updated figures and the estimate of population change given the forthcoming Brexit?

What is the calculation used by TWBC to get to Row 1?

The planning permission for the 60 homes at Bloomsbury Gardens, Common Road, Sissinghurst was only given on appeal on 21st March 2016 so these properties should be within the number in Row 2 – completions April 2016 to March 2019 and therefore should be discounted from the number of homes (100-115) required in Sissinghurst in this Local Plan. The 9 houses to be developed in Cobnut Close has also not been deducted from these numbers.

DLP_2867

Chris Gow

Economic development

My previous comments apply:

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

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

Earmarked retail areas should be considered for housing development, which better serves the community.

DLP_7671

Mr J Boxall

The housing need (row 1) is based on the 2014 household projections.  It is now 2019 so this may already be out of date.  What would the projections be with updated figures and the estimate of population change given the forthcoming Brexit?

What is the calculation used by TWBC to get to Row 1?

The planning permission for the 60 homes at Bloomsbury Gardens, Common Road, Sissinghurst was only given on appeal on 21st March 2016 so these properties should be within the number in Row 2 – completions April 2016 to March 2019 and therefore should be discounted from the number of homes (100-115) required in Sissinghurst in this Local Plan.  The 9 houses to be developed in Cobnut Close has also not been deducted from these numbers.

DLP_6190

Turley for Bellway Homes Strategic

Housing Requirement and Supply

Table 1 of the draft Local Plan indicates that a total of 13,560 dwellings are required in the Borough between 2016 2036. Paragraph 4.7 of the Plan explains that this is calculated on the basis of 678 dwellings per annum to reflect the ‘standard method’. The requirement is to be achieved via the following sources:

  • Completions April 2016 to March 2019: 1,552 dwellings
  • Extant planning permissions at 1 April 2019: 3,127 dwellings
  • Outstanding site allocations: 588 dwellings
  • A windfall allowance of 700 dwellings (50 per annum from 2022 – 2036)

The draft Local Plan indicates that these sources of supply leave a minimum still to be identified of 7,593 dwellings.

We agree that the ‘standard method’ should be used to calculate the Local Housing Need figure (unless an alternative approach could be justified) in accordance with paragraph 60 of the NPPF 2019. It is clear from the ‘Housing Needs Assessment’ Topic Paper (August 2019) that the Council has applied a ‘cap’ to reflect the Planning Practice Guidance when calculating the Local Housing Need Figure. The Topic Paper indicates that if this cap were not applied then the Local Housing Need figure would equate to 749 dwellings per annum in order to reflect an uplift to reflect affordability.

The Housing Needs Assessment Topic Paper itself therefore acknowledges that the level of growth planned in the emerging Local Plan is not at a level which would address the inherent issues of affordability. The Topic Paper acknowledges that house prices continue to increase and are relatively high for Kent, with affordability ratios also “relatively high”. On this basis, Bellway consider that the housing requirement should be increased in order to help tackle the identified issues of housing affordability in the Borough. In the event that the housing requirement is not increased in this manner then this only heightens the imperative of ensuring that the Local Plan establishes a planning policy context, by virtue of the sources of supply, allocations and distribution strategy which ensures that the planned level of growth can be achieved.

Notwithstanding the comments set out above, Bellway have significant concerns regarding the approach which the Council is pursuing to meet the housing needs in the Borough.

Windfalls

Irrespective of whether or not a windfall allowance is justified, and the extent of the allowance, Bellway note that the Council expects 700 dwellings (50 per annum) to be delivered from this source. This equates to nearly 10% of all the remaining housing to be delivered once existing commitments have been discounted. Since the total supply envisaged by the Local Plan exceeds the requirement by 9%, this reliance on windfall sites represents a significant risk to the overall requirements being achieved if any other sources of supply were to slip or be delayed.

Given the concern set out above, we consider that the Council should plan for greater flexibility in the event that sites/sources of supply do not deliver as expected.

Housing Trajectory

The ‘Housing Supply and Trajectory’ Topic Paper explains that the Local Plan makes provision for 14,776 dwellings during the Plan period (including existing commitments) (a buffer of 1,216 compared to the standard method requirement of 13,560). On the basis of Table 18 in that Topic Paper, we assume that this figure is calculated on the assumption that all extant permissions, existing site allocations, windfall sites and new allocations deliver as expected in the trajectory.

The ‘Housing Supply and Trajectory’ Topic Paper indicates that the 4,000 dwellings at Paddock Wood/Capel are expected to be delivered from 2024/2025 and at a consistent rate of between 333/334 dwellings per annum until 2036. We consider that the Council has been overly optimistic over the lead in time before this scheme is delivered and then the subsequent rate of housing completions for the reasons set out below:

  • Lead in: the ‘Housing Supply and Trajectory’ envisages that development would commence on this site in 2024/2025. We understand that the Council’s Local Development Scheme envisages that the new Local Plan will be adopted in Autumn 2021. That means that there would be less than 4 years between the adoption of the Local Plan and the delivery of housing at this site. However Policy STR/PW 1 establishes that there is a significant amount of work to be undertaken in relation to this allocation. That work includes comprehensive masterplanning and the creation and adoption of one or more Supplementary Planning Documents. The Policy indicates that compulsory purchase powers may be utilised to ensure comprehensive development.

The Lichfield report ‘From Start to Finish’ identifies average ‘lead in times’ of close to 7 years for sites larger than 2,000 dwellings. The LPA’s assumptions are that the site delivers less than 4 years from when they expect the Local Plan to be adopted. This lead in time is extremely optimistic and fails to reflect the complexities of delivering large scale strategic residential sites including land assembly, the preparation of SPDs, the preparation and determination of (complex) applications, reserved matters, conditions and infrastructure delivery. In opinion, the lead in time should therefore be extended. If the delivery of housing from the Paddock Wood/Capel allocation were delayed until 7 full years after the adoption of the Plan, that would suggest the first dwellings would be completed in 2027/28, three years later than expected by the Council. The effect of this would be to remove 1,000 dwellings from the supply. Removing 1,000 from the housing trajectory would decrease supply to 13,776, representing a buffer of 256 against the overall housing requirement.

  • Completions rate: the Topic Paper seeks to justify the rate of delivery on the basis of the Letwin Review’s conclusions regarding sites with 8 or more developers). The Topic Paper (paragraph 5.5.14) explains that the Council does not know how many housebuilders would be involved in delivering this allocation (although it notes a “high possibility” that there would be 8 or more). In our opinion, the evidence to support the Council’s conclusions that 33/334 dwellings would be delivered every year has not been provided. Furthermore, there is no analysis as to how matters such as the requirement for phasing/infrastructure delivery would affect the completions rate. The Council appear to also rely on the prospect that developers may provide land to others, however there is no evidence to support that claim. Where large sites such as this are proposed for allocation, there is usually a recognition that delivery rates increase over time (rather than maintaining a continuous and consistent level). In any event, we consider that the expected completions rate is likely to be excessive, particularly due to the uncertainty over the number of developers involved. Even in the event that this site did begin delivering in 2024/2025, then a more reasonable assumption over completions rates (say an average of 250 dpa) would indicate that around 3,000 dwellings would be delivered by 2036 (however this fails to have regard to the need to extend the lead in time as explained elsewhere). Removing 1,000 from the housing trajectory would decrease supply to 13,776, representing a buffer of 256 against the overall housing requirement.

The fact that there is such uncertainty regarding the deliverability and timescales for the strategic scale development envisaged at Paddock Wood/Capel is of significance since 4,000 dwellings represents more than a quarter (27.08%) of the total expected supply to 2036. Our comments in relation to the lead in time and average completion rates both result in 1,000 dwellings being removed from the supply in their own right (i.e. without regard to wider considerations). Combining these two considerations (applying a more reasonable assumption to delivery rates, with commencement in 2027/28 at the earliest, and a more reasonable approach of 250 dwellings per annum) would result in 2,250 dwellings (1,750 fewer than the Council envisages) delivered from this allocation by 2036. This could have very severe consequences for the achievement of the housing requirement overall. Removing 1,750 dwellings from the Paddock Wood/Capel allocation by 2036 would result in 13,026 dwellings being delivered in that period (assuming all other allocations and sources of supply deliver as expected). This would represent a shortfall of 534 dwellings against the overall planned housing requirements.

The ‘Housing Supply and Trajectory’ Topic Paper indicates that 1,900 dwellings at Tudeley Village are expected to be delivered from 2025/2026 and at a rate of between 150 – 200 dwellings per annum until 2036. We consider that the Council has been overly optimistic over the lead in time before this scheme is delivered and then the subsequent rate of housing completions for the reasons set out below:

  • Lead in: the ‘Housing Supply and Trajectory’ envisages that development would commence on this site in 2025/2026. We understand that the Council’s Local Development Scheme envisages that the new Local Plan will be adopted in Autumn 2021. That means that there would be less than 4 years between the adoption of the Local Plan and the delivery of housing at this site. However Policy STR/CA 1 establishes that there is a significant amount of work to be undertaken in relation to this allocation. That work includes comprehensive masterplanning and the creation and adoption of one or more Supplementary Planning Documents. The Policy indicates that compulsory purchase powers may be utilised to ensure comprehensive development.

The Lichfield report ‘From Start to Finish’ identifies average ‘lead in times’ of close to 7 years for sites larger than 2,000 dwellings. The LPA’s assumptions are that the site delivers less than 5 years from when they expect the Local Plan to be adopted. This lead in time is extremely optimistic and fails to reflect the complexities of delivering large scale strategic residential sites including land assembly, the preparation of SPDs, the preparation and determination of (complex) applications, reserved matters, conditions and infrastructure delivery.. In opinion, the lead in time should therefore be extended. If the delivery of housing from the Tudeley Village allocation were delayed until 7 full years after the adoption of the Plan, that would suggest the first dwellings would be completed in 2027/28, two years later than expected by the Council. The effect of this would be to remove 300 dwellings from the supply.

  • Completions rate: Whilst the Council appears to have applied more reasonable completion rates to this site, we consider that evidence will still need to be provided in order to support the claimed figures. Given the overall contribution that this site makes towards housing supply to 2036, it is imperative that the Local Plan is based upon a justified housing trajectory.

In isolation the alterations referred to above to Tudeley Village scheme may not result in housing delivery falling below the overall requirements, assuming that it does indeed come forward and at the rate envisaged by the Council. More significant alterations to those referred to above could have dramatic consequences on the achievement of the overall housing requirement (irrespective of any other alterations made to supply).

In combination the reduction in supply from Paddock Wood/Capel (1,750 dwellings) and Tudeley Village (300 dwellings) would remove 2,050 dwellings from the overall housing trajectory and lead to a shortfall of 800 dwellings against the planned housing requirement of 13,560 dwellings (without any other alterations and without any consideration being given to the suitability/sustainability of those allocations).

These comments demonstrate that, without evidence to support the claimed lead in times or completion rates, the Council is overly reliant upon two sites to achieve the planned housing requirement to 2036. Additional flexibility and sources of supply are therefore required. Revising the current housing trajectory to reflect fairly modest amendments (delaying Paddock Wood/Capel by three years and Tuneley Village by two years and more realistic delivery rates) alone results in a significant undersupply of housing against the capped figure derived from the standard method. Other alterations, such reductions in the windfall allowance or reductions in the supply from other allocations/commitments would increase the extent of that shortfall.

As currently prepared, the Local Plan does not represent a vehicle by which the planned housing requirements will be achieved. In contrast, the Plan will result in an undersupply of housing. This is likely to have severe consequences for the Council’s ability to demonstrate a rolling five year supply of deliverable housing sites. This is compounded by the reliance on two large sites (1,900 at Tudeley Village and 4,000 at Paddock Wood delivering 5,900 in combination) represents 77% of the remaining level of housing expected during the Plan period (7,593 dwellings).

Accordingly, we consider that it is essential that the Council allocate a greater range and diversity of sites for residential development to ensure that the housing requirement of the Plan can be achieved.

Bellway reserve the opportunity to comment on the Council’s housing trajectory, including the other sites proposed for residential allocation, in more detail as the Local Plan progresses.

Meeting Affordable Housing Needs The Housing Needs Assessment Topic Paper (paragraph 45) explains that:

“The Council’s SHMA, 2015 found that the borough would need 341 affordable homes per annum to meet their housing needs and be eligible for affordable housing.”

The Housing Needs Assessment Topic Paper (paragraph 47) explains that:

“A separate Housing Need Study, in 2018, assessed affordable requirements by taking into account the need from existing and newly forming households within sub areas of the borough of Tunbridge Wells, and comparing this with the supply of affordable housing. Against a gross need for affordable housing of 662 dwellings each year, when the likely annual affordable supply is taken into account, the overall net imbalance is 443 affordable dwellings each year.”

Paragraph 48 of the Topic Paper concludes that:

“The corrected affordable housing need over a 15 year period, based on the HNS estimate, is actually 391 dwellings/year.”

Over a fifteen year period from 2021 – 2036, an affordable housing need of 391 dwellings per annum would equate to 5,865 dwellings.

Policy H5 of the draft Local Plan expects all greenfield sites over more than 9 dwellings to deliver a minimum of 40% affordable housing. For the sake of ease, if 40% of all 7,593 dwellings required to achieve the overall housing requirement (13,560) were delivered as affordable housing, that would provide 3,037 affordable dwellings (significantly fewer than need acknowledged by the Council). However that approach misrepresents the supply of affordable housing bearing in mind the different requirements applied by Policy H5.

In addition to the comments set out above, we note that the draft Plan does not establish the level of affordable housing to be delivered from the Paddock Wood/Tudeley Village allocations, with this left to a later stage (Regulation 19 of the Local Plan being prepared) and based on the Local Plan and CIL Stage 2 Viability Assessment. These two sites (alone and in combination) represent by far the greatest sources of housing supply envisaged in the Borough to 2036 and as such the Local Plan should clarify the quantum of affordable housing that they are expected to provided. Without such information conclusions cannot be reached about the extent to which the Local Plan will meet affordable housing needs.

On the basis of these comments alone, we consider that the Local Plan fails to represent a positive approach to addressing the need for affordable housing in the Borough. It should also be noted that the provision of affordable housing to 2036 would also be reduced in the event that the strategic allocations at Paddock Wood/Capel or Tuneley are delayed, do not achieve the delivery rates envisaged by the Council or if the further work in support of the Local Plan/CIL indicates that the sites themselves should provide fewer affordable dwellings than might otherwise be expected.

[TWBC: see full representation and Comment Numbers DLP_6189-6198].

DLP_6822

Persimmon Homes South East

Housing Requirement

2.2 Table 1 of the Reg 18 plan identifies the housing need for the period 2016 – 2036 to be 13,560 dwellings (678dpa). This is said to be based upon the standard methodology (2014 based household projections (published July 2016)), projected household growth in Tunbridge Wells for the period 2019-2029 and the affordability ratios published in April 2019. Whilst we believe the figure to be 682dpa, we note para 3.2.1 of the Housing Topic Paper (HTP) suggests the figure of 678 is being used as it is based upon submission in 2020. This being the case the plan when submitted needs to be clear on this point and all associated calculations clarified accordingly. We also believe, for the reasons set out below, that the plan period should also be amended and start in 2020 not 2016 as drafted.

Table 2 Local Plan Options (Issues and Options consultation 2017)

Comment No.

Name/Organisation

Response

DLP_113

Catherine Catchpole

The plan gives 5 options which make some sense.  However it gives no justification for the option chosen - it appears that the options chosen have been driven by the availability of the call for sites rather than any sensible objective assessment.

The dualling of the A21 to Tunbridge Wells has massively improved the traffic issues especially heading north to London.  It would make logical sense to capitalise upon this improvement by focusing development on the A21 corridor north of Kippings Cross (where the A21 reverts to single carriageway again).

DLP_1728

Peter Hay

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

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

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

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

Failure to consult

The limited consultation - in Hawkhurst only one weekday session between 4 - 7pm when many residents could not attend to offer their views

The limited access to the online consultation – not on TWBC home page and hidden “four clicks” away buried in planning section of website

A complex consultation form to complete that many residents have found baffling

DLP_2215

Rosanna Taylor-Smith

Option 1

I disagree with the classification by TWBC that Hawkhurst is classified by as a MAIN SETTLEMENT. It is a VILLAGE.

The failure by TWBC to correctly identify Hawkhurst as a 'Village' results in the incorrect implementation of urban planning policies.  

It appears that TWBC continue to disregard the Hawkhurst Neighbourhood Devlopment Plan, correctly adopted by TWBC, including the most recently updated version of the NDP in March 2019.

DLP_2029

Terry Everest

Table 2 Local Plan Issues and Options

Option 3 is clearly the best approach ( and this has been recognised I note)

However Option 5 should not be included as per my response to the vision, in addition I will say this - when it is recognised that Green Belt and AONB needs to be protected and is becoming scarce - why plan to take 5% and build on it at all? That approach will result ultimately in the destruction of all green belt land within around 340 years. Future generations will look back and see how successive portions of precious countryside were nibbled and bitten away by the arbitrary demands of government housing need and local authorities trting to be progressive - when instead a truly sustainable balanced approach with reduced development could still deliver on the true needs of the borough whilst actually safeguarding the environment and countryside for future generations.

DLP_2446

Tracy Belton

I do not agree that the allocation of dwellings has been spread evenly across settlements. Horsmonden has far more than the villages surrounding it. Horsmonden is not on a main train line, or have better transport links or facilities than any of the surrounding villages. Horsmonden has been allocated nearly as much as Penbury which is a much bigger settlement.

Paddock Wood is not on the A21, Lamberhurst is and much more housing has been allocated to Paddock Wood. Lamberhurst has not ben allocated much at all, so the focus cannot be around the A21!

DLP_2351

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_2869

Chris Gow

Green Belt land must be preserved for the benefit of everyone.

It is an easy option for a developer, and should be resisted.

Once Green Belt land is released for development, it will be hard to restrict wholesale loss of this valuable amenity land.

The benefits are not just for amenity of locals, but for eco preservation, and should be preserved to meet the Plan Vision and Objectives 2 in paragraphs 6 and 8, and Paragraph 2.40.

DLP_2868

Chris Gow

The "call for sites" is led by the developer motive for profit, and not for the benefit of borough residents, and so should be treated with some suspicion.

The need for development should be led by the members of the community for the benefit of the community, rather than the need for profit.

Figure 4 Key Diagram

Comment No.

Name/Organisation

Response

DLP_46

Thomas Weinberg

Comments on The Key Diagram (Figure 4, Section 4) p.41

Another example of misleading the public is that the circle representing housing on Tudeley is not big enough in an attempt to make it seem less damaging. Relative to the other circles it should be considerably bigger – even as it is it shows the clustering of development to be against claims of spreading it where needed.

Tudeley should not have been shortlisted when you have suitable sites outside of the AONB and Green Belt.

DLP_128

Gregg Newman

Comments on The Key Diagram (Figure 4, Section 4) p.41

The scale of your drawings is questionable at best, manipulative and misleading at worst.

Note again that Horsmonden would have better suited the actual size of the planned development.

DLP_723

Dr P Whitbourn

Given that some 75% of the borough is within an Area of Outstanding Natural Beauty or Green Belt or both; that its only large town is a major historic town of natural significance; that a number of smaller settlements and villages are of historic interest too; that some of the areas outside the AONB and Green Belt are within flood plains; and that some parts of the borough are not well served by public transport, the Borough of Tunbridge Wells is an exceptionally difficult one in which to locate new housing and other development without causing serious harm.

Thus the council is, in effect, faced with an impossible task of attempting to devise a Local Plan on the basis of large new housing numbers, dictated to it by central government, without resulting in serious damage to an outstanding environment. One might hope that central government might be mindful of this problem, and adjust housing requirements so that higher numbers can be absorbed where harm will not be caused, and lower numbers allocated to those areas where serious environmental damage would otherwise be caused. The starting point of the Plan should therefore be a thorough questioning of any housing figures handed down by central government, to ensure that environmental damage or irresponsible development in a flood plain is kept to an absolute minimum.

Previous Local Plans have sought to defend the countryside by directing new development to the town of Royal Tunbridge Wells. Such a policy did make a certain amount of sense in times past, when "brown field" sites such as the former gas works and hospital sites were becoming available. However, as sites of that kind have now been used up, such a policy clearly cannot be expected to continue, and the time has come for a fresh approach to this intractable problem.

I think, therefore, that there is now a case for seriously considering the adoption of the proposed "dispersed growth" option 3. The "garden village" option 5 could be an interesting one, although it is hard to see an uncontroversial location, in view of the many constraints just mentioned. The Key Diagram (Figure 4) illustrates the way in which the preferred option 3 might work, together with option 5, but on the basis of a very high housing figure that ought to be vigorously challenged.

DLP_855

Ian Pattenden

Comments on The Key Diagram (Figure 4, Section 4) p.41

The circle representing housing on Tudeley is misleading, it should show a circle representative of 1,900 new houses but is only a little bigger than the key circle showing 1,000 housing units. Another example of TWBC Planners being economical with the truth.

The depiction of Green Belt land and AONB land on this map is very helpful. It demonstrates, yet again, that the garden settlement should be in Horsmonden. Tudeley should not have been shortlisted when you have a suitable site outside of the AONB and Green Belt. Furthermore, there are areas to the NE of the borough without any AONB or green belt restrictions. You use the excuse that the land did not come forward in the call for land; but so far as I know there was no proactive effort to talk to landowners, or consideration to apply CPOs yet CPOs are considered likely in the Tudeley plans.

DLP_881

Anna

Difficult to understand the granular level impact (i.e. in terms of exact geographic divisions).

DLP_1026

Mr and Mrs Copping

We spent a great deal of time and effort trying to find Figure 4 within The 545 page draft Local Plan Regulation 18 consultation draft 20th September to 1st November 2019 So cannot comment on it

DLP_1028

Liz Copping

I couldn’t find Figure 4 within the 544 page Draft Local Plan – Regulation 18 Consultation Draft - 20 September to 1 November 2019.

DLP_1627

Maggie Fenton

The Key Diagram (Figure 4, Section 4) p.41

The depiction of Green Belt land and AONB land on this map is very helpful. It demonstrates, yet again, that the garden settlement should be in Horsmonden or Frittenden. North East of the borough is served by less congested A roads & is free of MGB, AONB and flood risk constraints

DLP_1792

Sacha Reeves

I am very concerned about the impact of the property developments proposed for the Tudeley area, as shown on the "Key Diagram".

The "Draft Local Plan" makes inadequate propoasls to deal with the additional strain that would be placed on nearby services and infrastructure.  In particular, road traffic and rail passenger volumes are not adequately considered.

The plan should include specific, detailed provision for addressing these issues to ensure that a very significant negative impact on the Tonbridge area is avoided.

DLP_2008

Dr David Parrish

The Key Diagram (Figure 4, Section 4) p.41

There are no detailed plans – TWBC cannot be sure of enough land being available

The TGV site is out of scale. The required housing will need much larger area. The map also shows the larger North, North East swathe of land that should be the Plan A of choice – where no flood plain, no Green Belt, no AONB exist. Capel has all of these restrictions.

It also shows the lack of fairly dispersed allocations.

DLP_2069

Canterbury Diocesan Board of Finance Ltd

The Vicarage site is a highly sustainable location for development which relates to the built- up part of Cranbrook, unlike a number of new housing allocations which are entirely separate from the settlement. The Key Diagram should be amended to include Cranbrook Vicarage as a formal allocation for housing development within the defined Limits to Built Development as shown on the existing Proposals Map adopted formally by TWBC in July 2016.

The removal of the current housing site allocation at Cranbrook Vicarage cannot be justified having regard to the principles of sustainable development as set out in the National Planning Policy Framework. The housing allocation should be reinstated to reflect the sustainability credentials of the locality which are vastly superior to some of the Draft allocations which lie in open countryside remote from community services and facilities and public transport provision.

The retention of the Vicarage within the Limits to Built Development (see above) on the Draft Proposals Map is entirely appropriate but the removal of the housing allocation cannot be justified on planning grounds. So, the allocation in the current local Plan should be retained.

DLP_2350

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_2832

Helen Parrish

Cross-referenced, detailed, reasons for my Objection:

The Key Diagram (Figure 4, Section 4) p.41

There are no detailed plans – TWBC cannot be sure of enough land being available

DLP_2968

Michael Alder

Comment already made in earlier sections should be reviewed. [TWBC: See comments DLP_2962-2967]

DLP_3033

Jacqueline Prance

Too big a site - too vague a proposal

DLP_3722

Capel Parish Council

The Key Diagram (Figure 4) is misleading.

The circle representing proposed housing in Tudeley (Policy AL / CA 1) is not big enough. It should show 1,900 new houses and is only a little bigger than the key circle showing 1,000 housing units.

It is understood that the large blue arrows are intended to signify options for a ‘Proposed Link Route’ between the proposed site at Tudeley (AL / CA 1) and either the A228 between the Badsell Roundabout and the Hop Farm (the higher arrow) or the proposed offline A228 strategic link or ‘Colts Hill bypass’ (the lower arrow). This diagram suggests that either option is being considered, which is what we were told by TWBC Head of Planning, however, it is clear from the SWECO Transport Map with proposed Local Plan Mitigation Interventions (Table 9.2 and Figure 9.2 of the Local Plan Transport Evidence Base which forms part of the supporting documents that Transport Strategy) that Scheme No. 203 comprises a ‘Link road to new Colts Hill Bypass’ (p.138) and that it has already been planned.

The depiction of Green Belt land and AONB land on this map is very helpful. It demonstrates that the garden settlement should be outside land with these designations. Tudeley should not have been shortlisted when you have suitable sites outside of the AONB and Green Belt.

DLP_4220

Tunbridge Wells District Committee Campaign to Protect Rural England

This diagram fails to show fully how much of the Green Belt will be built over, since the pink dots obscure the Green Belt in Paddock Wood and around RTW , and the large new hotel planned for Southborough is not shown.  It does, however, illustrate the huge amount of new development that is planned for the AONB and its setting.

DLP_4294

Changing Cities for 42 Leisure PLC

The Key Diagram could be clearer in its presentation of the distribution of housing and other new development and key areas for regeneration and change including the southern part of the Town Centre.

DLP_4386

Mill Lane and Cramptons Residents Association

Key Diagram and Policy STR1.

We do not agree with Sissinghurst (Item 5) having so much proposed new growth.

We have already had a large development of 60 new houses off Common Road and other new dwellings in Cobnut Close and Church Mews in this small village that has minimal facilities.

DLP_5885

Ms Sally Moesgaard-Kjeldsen

I object. Does it really matter if I object or not, I wangt

to live in a safe and healthly town and you, the council are preventing me from doing this.

I have nothing more to say but stop all the building and think of our county, wildlife and health. I am not well and am unable to concentrate any more, to continue,  sorry.

DLP_6001
DLP_6637

Alexander Fisher
Nicholas Fisher

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

Comments on The Key Diagram (Figure 4, Section 4) p.41

The circle representing housing on Tudeley is misleading, it should show a circle representative of 1,900 new houses (the minimum in the intial plan period) but is only a little bigger than the key circle showing 1,000 housing units; another example of the draft plan being inaccurate and misleading. It also demonstrates that there is no coherent plan for for a proper spread of development across the borough; something that is meant to be part of the TWBC strategy.

The depiction of Green Belt land and AONB land on this map is very helpful. It demonstrates, yet again, that the garden settlement should be in Horsmonden. Tudeley should not have been shortlisted when TWBC has a suitable site outside of the AONB and Green Belt. Furthermore, there are areas to the NE of the borough without any AONB or green belt restrictions.

DLP_6031

Mr C MacKonochie

Forgetting designations of land, land use etc. it is obvious that expansion of housing driven by transport links in any significant numbers can only happen along the A21 corridor, expansion of Tunbridge Wells / Southborough (two railway stations). A similar comment can be made about internet connectivity driving housing locations

The adopted Core Strategy recognises that rural settlements are least able to support sustainable development

DLP_6054

Kember Loudon Williams for Cranbrook School

The amount of development proposed within Cranbrook as shown on the Key Diagram, is sought to be increased and therefore the content of this map will slightly alter.  Please see Chapters 3, 6 & 7 of the attached Report for more details.

[TWBC: see full supporting statement. For Chapters 3, 6 & 7 please see Comment Numbers DLP_6026/6027 (Chapter 3), DLP_6028 (Chapter 6), and DLP_6046 (Chapter 7)].

DLP_6255

Anne Trevillion

The transport links are completely unclear. The main road from Paddock Wood to Tonbridge has been left off the map, yet this is the road that potentially will take a huge amount of extra traffic. Tonbridge is the town to which people go for most of the sporting and cultural activities, not Tunbridge Wells, simply because of the transport. For example, the Park Run in Tonbridge is accessible from Paddock Wood; that in Tunbridge Wells is not. The  swimming Pool in Tonbridge is accessible; that in Tunbridge Wells (St Johns) is not. So the B2017 is a key route. It would be helpful to show exactly how the roads are to be changed and how buses /cycle routes / new train stations are to be planned to mitigate against a huge and damaging increase in traffic congestion.

New Primary Schools seem to be left off the map.

DLP_6260

Kember Loudon Williams for Mr R Barnes

These representations are seeking to allocate an additional site (Stone Court Farm) at Pembury for residential development. The site is considered entirely suitable for development and would make a logical extension to the east of this settlement. It is therefore proposed that the Key Diagram is altered to include site number 354 (Stone Court Farm).

DLP_6317

Susan Heather McAuley

The diagram clearly indicates the imbalance in this Local Plan with so much building planned for the east end, so far away from all the new facilities (except large numbers of new houses) being put in at the west end.

The purple dots on Sissinghurst, Cranbrook and Hawkhurst far outweigh those on Tunbridge Wells.

This is disproportionately impacting on the people of Cranbrook and Sissinghurst who do not want to live in large towns.  The people of Tunbridge Wells have chosen to live in a large town and there will be minimal impact on them and their way of life by putting more of the housing allocation in RTW.

DLP_6799

Kember Loudon Williams for Wedgewood (New Homes) Ltd

The amount of development proposed within Horsmonden as shown on the Key Diagram, is sought to be increased by 35 housing units and therefore the content of this map will slightly alter to reflect this. Please see Chapters 3, and 4 of the attached KLW Supporting Statement for more details.

[TWBC: see Supporting Statement and Comment Numbers DLP_6793, 6797-6799, 6801, 6803-6804]

DLP_6858

John Gibson

I do not believe that Sissinghurst should have such a proportionately large expansion. The small rural village already has absorbed many new houses recently.

(TWBC Comment - duplicate comment received 13/11/2019 as below)

I disagree that Sissinghurst should suffer such a disproportionately large expansion. The small rural village already has absorbed many new houses recently.

DLP_6945

Hallam Land Management Ltd

Key Diagram

Hallam are in agreement that the identification of allocations and landscape areas across the borough, with the allocations being consistent with the Councils Option 3 (Dispersed Strategy) and Option 5 (New Settlement).

DLP_6975

Mrs Beryl Bancroft

Most of the improvements are being made in the centre of Tunbridge Wells which already has good transport and employment facilities. No plans seem to be in place to get people from areas such as Cranbrook, Sissinghurst and Frittenden and other rural Weald villages which are getting more housing but nothing else.

DLP_6982

Nigel Tubman

The map (Key Diagram Figure 4) is clear but the distribution of development is clearly out of balance between the east and west parts of the borough. The borough is a long and narrow strip of Kent with the main part of the population residing in the western part of TWBC requiring a more appropriate response that addresses the needs of the whole borough and the people who live there bearing in mind the difficulty in travel east to west and vice versa.

It also illustrates rather starkly how much the plan benefits and addresses the needs of the town of Tunbridge Wells to the detriment of the rural areas.

DLP_7000

Kember Loudon Williams for Mr Anthony Whetstone

These representations are seeking to allocate an additional site (Tudeley Brook Farm) within the strategic growth allocation for Paddock Wood. A detailed planning report has been prepared to support these representations. It finds that the site is entirely suitable for development and should be included as part of the comprehensive redevelopment of Paddock Wood. Accordingly, we therefore respectfully request that the Key Diagram is altered to include the Tudeley Brook Farm site.

DLP_7361

Wealden District Council

Paragraph 23 of the NPPF (February 2019) confirms that broad locations for development should be indicated on a key diagram, and land-use designations and allocations identified on a policies map. The key diagram within the draft Tunbridge Wells Local Plan (page 41) includes all housing allocations within the plan, including the two proposed garden settlements, the location of both Green Belt and the High Weald AONB, as well major transport routes and settlements.

The key diagram does include broad locations for growth amongst other matters and provides an overview for the spatial distribution of the plan. This would comply with the NPPF.

DLP_7509

Sarah Parrish

Without detailed plans – how can TWBC be sure of enough land being available?

DLP_7542
DLP_7550
DLP_7557
DLP_7565

William Fisher
Helena Fisher
Richard Fisher
Alexa Fisher

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

The circle representing housing on Tudeley is misleading, it should show a circle representative of 1,900 new houses (the minimum in the intial plan period) but is only a little bigger than the key circle showing 1,000 housing units; another example of the draft plan being inaccurate and misleading. It also demonstrates that there is no coherent plan for for a proper spread of development across the borough; something that is meant to be part of the TWBC strategy.

The depiction of Green Belt land and AONB land on this map is very helpful. It demonstrates, yet again, that the garden settlement should be in Horsmonden. Tudeley should not have been shortlisted when TWBC has a suitable site outside of the AONB and Green Belt. Furthermore, there are areas to the NE of the borough without any AONB or green belt restrictions.

DLP_7809

Mr Colin Sefton

I think this is “broadly correct”, with the majority of proposed development around Paddock Wood; however, I am concerned that proposed new infrastructure to serve proposed development looks significantly insufficient (please see comments on section 2.57 above) [TWBC: See comment 7802].

DLP_7838

Andrew Chandler

The proposed allocation for Cranbrook and Sissinghurst seems to completely change the settlement hierarchy without explanation. You have explained the approach for other locations, but not ours. See further comments on Table 3.

DLP_8144

Ashley Saunders

The Key Diagram (Figure 4) is misleading.

The circle representing proposed housing in Tudeley (Policy AL / CA 1) is not big enough. It should show 1,900 new houses and is only a little bigger than the key circle showing 1,000 housing units.

It is understood that the large blue arrows are intended to signify options for a ‘Proposed Link Route’ between the proposed site at Tudeley (AL / CA 1) and either the A228 between the Badsell Roundabout and the Hop Farm (the higher arrow) or the proposed offline A228 strategic link or ‘Colts Hill bypass’ (the lower arrow). This diagram suggests that either option is being considered, which is what we were told by TWBC Head of Planning, however, it is clear from the SWECO Transport Map with proposed Local Plan Mitigation Interventions (Table 9.2 and Figure 9.2 of the Local Plan Transport Evidence Base which forms part of the supporting documents that Transport Strategy) that Scheme No. 203 comprises a ‘Link road to new Colts Hill Bypass’ (p.138) and that it has already been planned.

The depiction of Green Belt land and AONB land on this map is very helpful. It demonstrates that the garden settlement should be in Horsmonden or Frittenden. Tudeley should not have been shortlisted when you have suitable sites outside of the AONB and Green Belt.

DLP_8213

Mrs Suzi Rich

I object to the Key Diagram (Figure 4) because it is misleading. It is understood that the large blue arrows are intended to signify options for a ‘Proposed Link Route’ between the proposed site at Tudeley (AL/CA 1) and either the A228 between the Badsell Roundabout and the Hop Farm (the higher arrow) or the proposed offline A228 strategic link or ‘Colts Hill bypass’ (the lower arrow). This diagram suggests that either option is being considered, which is what we were told by TWBC Head of Planning, however, it is clear from the SWECO Transport Map with proposed Local Plan Mitigation Interventions (Table 9.2 and Figure 9.2 of the Transport Assessment Report which forms part of the supporting documents that Transport Strategy) that Scheme No. 203 comprises a ‘Link road to new Colts Hill Bypass’ (p.138) and that it has already been planned.

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

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

DLP_8248

Jan Pike

Comments already made above should be reviewed

[TWBC: See comments DLP_8236-8248]

Policy STR 1: The Development Strategy

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_47

Thomas Weinberg

Object

Comments on Policy STR 1 (The Development Strategy) p.42 

This policy does not include any reference to development on Brownfield sites, but does refer to the release of Green Belt.
You should have a strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites.

DLP_7769

Annie Hopper

General Observation

No employment space has been identified in Cranbrook and Sissinghurst. This means that many new residents of the Parish of Cranbrook and Sissinghurst will be travelling to work, (14 miles away) entirely unsupported by appropriate infrastructure.

Why is so much development being centred in Cranbrook and Sissinghurst Parish when employment is targeted so far away?

DLP_68

The Access Group

 

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

2. THE MAJOR CONCERNS

2.1 Whilst my members appreciated "the need for housing etc" and "government targets imposed on local government", the concerns expressed were as follows:

Us of green field sites such as those in Capel, Paddock Wood, Matfield, Brenchley, Cranbrook and Tudeley must be minimised as they impinge on the High Weald AONB.

DLP_97

A W Samson

Object

I am simply appalled by the proposed development that is planned in our local rural areas, which include Green Belt designations and the High Weald Area of Outstanding Natural Beauty (AONB).

Yes we need housing to meet our housing targets, but this must only be planned and provided where proper and correct infrastructure and services are put in place. In addition I can see no detailed analysis of the impact these new developments will have on our rural communities.

Firstly, the impact of the extra traffic that will be generated on our narrow roads, together with the parking problems that will be inevitable, not only on the estates themselves but also at our stations and on our high streets.

Secondly, many of the developments are on flood plains with not only the obvious known problem of flooding, but also and most importantly the need for very careful planning and construction that is necessary regarding services, such as drainage, water, electricity and gas utilities.

Thirdly, the impact of these new developments on our existing facilities, which are already at maximum capacity, such as schools and health services will be devastating, unless these facilities are built before the new development.

If development, to the magnitude you are suggesting on the Draft Local Plan, is seriously being considered, then the impact of the above serious problems need not only to be properly considered but action taken to implement in advance of any development being allowed to proceed.

Your observations and views would be appreciated, as I feel very strongly that there is a need to review your planning and policy framework in order that the public be satisfied that all factors have been taken into consideration before planning applications are allowed to be even considered, let alone decisions made.

DLP_129

Gregg Newman

Object

This policy does not include any reference to development on Brownfield sites, but does refer to the release of Green Belt.

You have a moral and civic duty to identify and exploit Brownfield sites before bulldozing (literally) Greenbelt and AONB. There is no their way to say this!

DLP_237

Mr Graham Clark

 

The development strategy as set out in the Policy STR1 and the Key Diagram is flawed.

The National Planning Policy Framework (NPPF) makes it clear that the primary purpose of the planning system is to achieve a future development pattern that is sustainable.

Tunbridge Wells and Southborough is by far the largest urban area in the Borough with the widest range and concentration of services and facilities. The town is a sub-regional shopping centre with a wide range of shops, pubs, restaurants and places of entertainment. There are numerous primary and secondary schools and excellent medical facilities. It is located on the Hastings to London railway line, with two well connected railway stations.

The strategy should be to focus more of the housing development in Tunbridge Wells and Southborough and significantly less in Paddock Wood and Tudeley Village. It is accepted that Tunbridge Wells faces challenges, particularly in managing traffic congestion and pollution levels. The Council should however, be seeing this as an opportunity to improve the environment of the town by linking new housing development to major and transformative infrastructure improvements.

The proposal to allocate land for housing development to the west of Paddock Wood flies in the face of Government advice contained in the NPPF. Much of this land is in Flood Zone 3. Indeed, it forms part of one of the largest alluvial flood plains in Kent, where the rivers Teize, Medway and Beult converge.

The NPPF is clear that development in areas at risk of flooding should be avoided. The NPPF advises that all plans should apply a risk-based approach to the location of development and consider current and future impacts of climate change so as to avoid flood risk to people and property. To put it bluntly, the aim of the sequential test is to steer new development to areas with the lowest risk of flooding.

It is true that if enough money is thrown at an engineering problem there will usually be a solution. In the case of the land to the west of Paddock Wood this will involve flood compensation measures, which will probably involve huge amounts of ground recontouring. This will fundamentally change the landscape of this area and it is doubtful that many of the existing trees and hedgerow will survive. There must also be a question mark about the financial viability of this approach. In addition, has the Council consulted with lenders and insurers to see whether this proposal is acceptable from their perspective.

There is also a question about how sustainable a new garden village at Tudely will be. A development of 2,500 houses will not sustain a wide range of facilities. Network Rail have confirmed that they will not permit a station in this location. This will invariably mean that new residents will be reliant upon the car to access most services. This is not the most sustainable of approaches. In addition, the new road links back to the A228 will have a huge impact upon the landscape. There must also be a question mark over whether a development of this scale could finance these major pieces of infrastructure.

To conclude, the strategy is flawed and does not accord with government advice contained in the NPPF. The Council needs to withdraw this Plan and think again about its overall approach.

DLP_7862
DLP_3384
DLP_3243
DLP_3499
DLP_3521
DLP_4862
DLP_3791
DLP_4616
DLP_5790
DLP_5862
DLP_6959
DLP_6218
DLP_6509
DLP_6699
DLP_6901
DLP_7124
DLP_7162
DLP_7177
DLP_5847
DLP_5823
DLP_6757
DLP_6177
DLP_6580
DLP_7421
DLP_7436
DLP_7455
DLP_7477

Peter Felton Gerber
Mrs Lucy Howells
Sadie Dunne
Sandra Rivers
Andrew & Bronwyn Cowdery
Mr Richard Cutchey
Mr Peter Jefferies
Diana Robson
Kevin Conway
Lorraine Soares
Simon Whitelaw
Angela Thirkell
Madelaine Conway
Clive Rivers
Deborah Dalloway
Gillian Robinson
Paula Robinson
Andrew Roffey
Mrs Sarah Vernede
Charles Vernede
Linda Beverley
May Corfield
Vivien Halley
Simon Parrish
Catherine Baker
Patrick Thomson
Sally Thomson

Object

TWBC: the standard response was submitted by the list of responders on the left:

Policy Number: STR 1

I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB.

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents.

I believe that the Council’s conclusion (for example, at Paragraph 4.34) that the sites identified for mass housing estates are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper.

The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions.

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments.

Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed.

For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place.

It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them.

The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:

1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan;

2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point.

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village.

The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan.

There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development.

Non-compliance with Hawkhurst Neighbourhood Development Plan

The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment.

Lack of adequate infrastructure

Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament.

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment.

Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents.

There are very limited local employment opportunities and no secondary schools within walking distance.

The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution.

The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it.

TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103).

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF.

The “relief road” will not work

The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny.

As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes.

DLP_7864
DLP_8093
DLP_8238
DLP_7029
DLP_7450
DLP_7646

Andrew Hues
Mary Curry
Jan Pike
Sally Hookham
Catherine Pearse
Keith Peirce

Object

TWBC: the standard response was submitted by the list of responders on the left:

I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB.

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents.

I believe that the Council’s conclusion (for example, at Paragraph 4.34) that such sites are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper.

The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false.  The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections).  I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions.

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst.  A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion.  We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned.  The village has already been seriously impacted.

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst.  A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion.  We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned.  The village has already been seriously impacted.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments.

Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed.

For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations.  The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place.

It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them.

The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:

  1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects.  Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the Draft Plan;

It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point.

DLP_7892

Barry Chamberlain

 

Policy STR1 – The Development Strategy

This policy sets out the strategic framework for the Local Plan.

The Draft Local Plan is based on the need to deliver 678dpa as against the Government’s Standardised Methodology for assessing housing needs. This figure therefore amounts to the delivery of 13,560 units over the Plan period up to 2035/36.

It is important to note that this is a “capped” figure whereby market signals uplift is a maximum of 40%. We do not dispute this in line with the NPPF/PPG, however, due to affordability issues in Tunbridge Wells borough and the need to address these in the Local Plan, we consider that the market signals uplift could be “uncapped” to 55% as per the PGG methodology for the Standard Method. This would result in an uplift in need to 754dpa (15,080 dwellings over the Plan period).

In addition, affordable housing need should be addressed by the Local Plan. The Housing Topic Paper sets affordable housing need as being 391dpa. Assuming that affordable housing will be delivered at an average 35% across all sites, this would result in a further uplift in overall need to 1,114dpa (22,280 dwellings over the Plan period).

The Draft Local Plan seeks to make provision for a total supply of 14,776 units up to 2035/36.

This amounts to a 9% uplift on the housing need as against the “capped” need. The supply however falls short as against the “uncapped” need, as well as the need when factoring in affordable housing provision.

Furthermore, the total identified supply is however based on an average figure whereby sites and settlements are identified to deliver ranges/parameters of development. For example, Hawkhurst is identified for development of 643 – 693 dwellings during the Plan period. Within this quantum, Hawkhurst Golf Club (AL/HA 1) is allocated for c. 400 – 450 units and thereby an average of 425 units for this site is used in the housing supply for the Local Plan.

We do not necessarily dispute this “averaged” approach, however it may be the case that the Local Plan does not achieve the full anticipated levels of growth (i.e. 14,776 units). Considering this and the potential shortage against the “uncapped need” and meeting affordable housing need, we therefore consider that additional sites/allocations should be found.

To this extent, our land and property at Streatley, Horns Road, Hawkhurst (hereafter the ‘Site’) has been discounted from allocation on the SHEELA (Site Ref. 52) and has been considered in the accompanying Sustainability Appraisal (SA) as an ‘Reasonable Alternative Site’.

Policy STR 1 (Paragraph 4 - Hawkhurst)

This policy seeks for the following spatial growth:

New development at Hawkhurst to provide a range of new homes, as well as the delivery of significant infrastructure improvements in the form of a relief road from Cranbrook Road to Rye Road, providing significant improvements to the crossroads in the centre of Hawkhurst (Highgate), and associated public realm improvements. A package of other community benefits will also be provided in the form of new health and other local facilities, as well as employment growth by way of an extension to the existing Key Employment Area at Gill's Green;

The above Policy sets out an allocation for circa 643-693 dwellings. The Policy seeks to secure infrastructure towards a new medical centre, expansion of a primary school and a new relief road (to relieve the crossroads at Hawkhurst). In order to deliver the above infrastructure and planned growth, a range of housing over 10no. allocated Sites has been made, to deliver a planned average of 668 dwellings.

For the aforementioned reasons, we consider that there is a need to deliver additional housing in the Borough and Hawkhurst itself, given the uncapped need to be met, the affordable housing provision and to maintain an appropriate buffer. Moreover, a large amount of development in Hawkhurst is contingent on the delivery of the relief road, as planned for, notably Hawkhurst Golf Club (AL/HA 1) which may if delayed have an effect on the actual level of growth coming forwards over that anticipated, in the short to medium term – reinforcing the need to plan for further housing. In light of this, our Site has been identified as a ‘Reasonable Alternative’ in the SA (Site Ref. 52). We have questioned our Site’s assessment in the SA and consider that it has been scored unreasonably negatively against a number of the SA objectives. In this context, we consider that the Site does represent a sustainable and logical location for housing, and as such should be allocated through the Local Plan. In doing so, the Site would make a useful contribution towards the increased housing requirement we have suggested is needed and that it should be progressed in the Local Plan.

In Box 9 below, we therefore make the case for the allocation of our Site.

[TWBC: see Comment Number DLP_7894 Appendix 6]

DLP_384

Mr Terry Cload

Object

STR1

I do not agree with the release of Green Belt land for housing over and above the needs of the indigenous population. There are ample brown field sites in the UK that should be used first. National Government insists that the Green Belt will be protected from development but the proposals amount to driving a fleet of mechanised destroyers of irreplaceable countryside through beautiful areas of Tunbridge Wells.

National government is taking more and more power away from local communities to make planning decisions. Sevenoaks District Council is making a stand against goverment imposed housing targets Tunbridge Wells Borough Council should do the same.

DLP_7902

Fiona Dagger

Object

Firstly – this review comes just 9 years after the last review and claims to take us through to 2036 – but has the opportunity for a five year review – making it just a five year review and the policies proposed are totally inappropriate for this time frame.

I consider the scale and distribution of the allocation housing being imposed upon Hawkhurst and Cranbrook, within the AONB (2300 houses over 59 sites) as not consistent with its duty for protection as a national important landscape.

The designations lie within the High Weald AONB and paragraph 11 of the NPPF (footnote 6) suggests that AONB designation should constrain levels of housing provision. This is supported by Planning Practice Guidance (Paragraph: 041 Reference ID: 8-041-20190721) which makes it clear that development should be limited in AONBs, and that it may not be possible to meet ‘objectively assessed needs’ in these areas.

In the Distribution of Development Topic Paper (Para 3.11), TWBC accepts that strategic-scale urban extensions, would ‘almost certainly not be appropriate’ in the AONB under national policy, and that the statutory purpose of conserving and enhancing the AONB is ‘likely to limit its capacity to absorb new development’. However, in allocating housing numbers to the AONB, no distinction has been made between the proportion of housing allocated to the borough as a whole, and that allocated to two key AONB settlements – Cranbrook and Hawkhurst. The current district-wide allocation of 14776 represents approx. 13 houses/ 100 head of population. With less than two hundred dwellings in Hartley today and a proposal for over two hundred in the future it would be a far higher ratio in certain localities.

This is inconsistent with the local plan’s stated policy and with the NPPF.

In addition, these AONB settlements appear to be meeting need from elsewhere, most likely from outside of the AONB. Cranbrook and Sissinghurst Neighbourhood Plan assessed the local housing need of these settlements as 610, of which 250 are met by the allocation in the previous local plan at Brick Kiln Farm. This leaves a further 360 to be delivered across both settlements to meet local need.

The draft Local Plan allocates 918 to these settlements in Cranbrook. The difference between these two figures suggests need from the wider borough, and potentially nationally as other boroughs have scaled back their proposalis in AONBS (notably Sevenoaks), so with requirements for houses outside of the AONB, is being met in the AONB. This figure amounts to approximately the numbers allocated to the three largest ‘major’ sites which are likely to cause the most harm to the landscape and natural beauty of the AONB. These major allocations are not necessary and should be dropped. The allocations for Hawkhurst, Benenden and Matfield are similarly inflated above what is required to meet local need.

Even if the need to allocate development within the AONB has been demonstrated, it does not mean that such provision should be in the form of major development sites. The AONB Management Plan, adopted by Tunbridge Wells Borough Council in March 2019, explains that the High Weald is a small-scale landscape built by hand. The Plan commits authorities to ‘seek to deliver new housing primarily through small-scale developments that meet local need’ (Objective S2, page 34). Paragraph 172 of the NPPF says that ‘Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest’. The tests associated with this policy have not been properly considered and the exceptional circumstances have not been justified. Alternatives to the large allocations have not been properly considered – sites outside the AONB have been dismissed, and the option of reduced allocations on the larger sites offered in the SHELAA has not been properly examined.

The Glover Review of designated landscapes recognises the threats to AONBs, particularly in the South East, of excessive development, recommending a stronger role for AONBs in the planning system as a result. The Review highlights the damage done to AONBs through locating major development on its boundaries and within its setting. Planning Practice Guidance also highlights the need to take potential impacts on the AONB into account when considered development in its setting (Paragraph: 042 Reference ID: 8-042-20190721, revised 21 07 2019). Consideration of the new settlement at Capel and the proposed development at East End both on the boundary of the AONB have not involved proper consideration of impacts on the AONB, including the impact of cars, visitors and the impact of the loss of cultural associations with the AONB.

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W Gibson
Sheila Gibson
Mr and Mrs Hitching
R, A & A Angelis & K & N Lescure
Rupert Ward
Susan Cooper
Olive Hobday
Kelly Cooper
Simon Edward Wade
Chrissie Wade
Mr and Mrs Fitzgerald
Laura Gonzales
Jackie Ford
Ian and Susan McNeil
Jean Moss
Dorothy Beaumont
Kathleen Dowling
David and Pam Wrenn
Mary Pepper
Margaret Hutchinson
Justine Threadgold
Robin Threadgold
Ashleigh Threadgold
Esther Clements
Tanya
Mr and Mrs A Bates
Valerie Murray
Richard and Ann Waterman
Isobel Creesey
Peter A Smith
Kirsty McLauchlan
Mita Khamom
Vivienne Smith
P I Patterson
Beth Dawson
Wolff
Mrs A James
Mr William Adamson
Andrew Gent
Mrs G Cooper
Michael Foreman
J L Becker
Robin Townshend
Keith & June Murray-Jenkins
Fiona Flower
GD Stewart
Patricia Groom
Barrie Howells
Linda Howells
David Gross
Patricia Gross
John and Bronwen Verrico
Phillip Gritted
Mr and Mrs Muggeridge
Delaine Langley
Winifred Fraser
Alfred D’Avila
Stephen and Jane Brewer
D Rose
Shirley and Peter Kemp
John Weller
Christopher and Angela Sims
Lida Willingale
Alison Sharp
Michael John Sharp
S A Leipnik
George Damper
Wendy Craft
Anna Avery
Jacqueline Duncan
Andrew Duncan
R Manwaring
Shirli and Brian Edgington
Cara Goodman
Russel Smith
Gemma Joy
Claire Stewart
Jonathan & Hilary Rayner
Maclolm Bowskill
Nick Joy
Martin and Diana Ridgley
Diane Moore
James Rowe
Lin Gent
Louise Dunphy
T Seabrook
Kevin & Kathleen Hurst
Elizabeth and John Skates
Martin Creasey
Nazmal Miah
Marlene Virgili-Jarvis
Kathy Jones
Gwyneth Banks
Jennifer Mary Wharton
Margaret Pratt
J and L Jenkins
David Gillmore
Patricia Dennis
S Malek
B. E. Holcombe
Roy Freeman
Alistair Milner
Michael and Karen Clarke
Kirsty Farmer
Ashley Savage
Sandra Hoskins
Robert Gifford
Rose Patterson
Ben Willimas
Kellie Wart
Lydia Sepulcre
Elizabeth Coles
Ben Tully
Margaret Gudgeon
Jemma Askew
Richard Ballard
Simon Holtham
Karla Martin
Ange Gent
Barbara Rowe
Beryl Sayers
Patricia Sanctuary
Tony Taylor
Anna Madams
Lucinda Sparrowhawk
Molly Moynan
Leslie Moore
Mr and Mrs J Howkins
Sue Newell
Alice Holmes
Sian Sharp
Nicholas Sharp
M Hawkins
Olga Malolepzsa
Robert Avery
Charlie Tampsett
Jade Frawley
Adam Kayalli
Christine Malek
Mr and Mrs Shields
Stephen Barnes
Jason Puttock
P Brown
Martin Zizkova
Chris Patterson
Mr & Mrs Richard & Muriel Thatcher
Catherine Morley
Ashley Martin
Stacey Martin
James Sharp
Alfie Traupett
Alexandra Draper
Lucy Soames
Rhian Taylor
Anna Leppik
Debbie Tampsett-Maynard
Joe Tampsett
Nikki and Tony Howther
Ben Taylor
Tristan Tully
Daniel Holmes
Suzie Hawkins
Vladimira Lukowska
Mike and Jean Brown
June Gentry
Jack Tampsett
Freda Holmwood
Rob Shepherd
Rosemary Ballard
Lee Maynard
Victoria Adams
Paula Green
Gary Norman
Adam Willingale
Karl Coomber
Bernadette Adamson
Dmitry Goldberg
Naddine Kayyali
Kirsty Green
Theo Tully
Patricia Tiltman
Emma Heasman
Judi Best
Jacqui Avery
James Scott Lindsay
Sarah Waldock
Jack Norton
Sandra and Charles Neve
Thomas Vos
Alison Vos
Donna-Louise Brewer
Philip Brewer
Eve Gabriel
S McCurry
Samantha C S Harris
Chris Heal
Gwendolyne Taylor
Nicola Cooper
Viggo Marshall
Helena Marshall
Judy & Colin Owen
R & V Baldock
Angela Jean Mullis
Laurel Bunker
Henry Brereton & Christine Martinez
Mr and Mrs Harvey
Carol Moorby
Lynne Brown
James H Brown
David and Linda Keen
Susie Holtham
Clive Jones
Elena Monica Dragnescu
Bridget Adam
J R Leipnik
Chloe Newell
P Smallwood
Ann Tully
Nancy Tully
David Jarvis
Valerie Cunningham
Una Perrine
Carole Moore
Bernard Hoskins
John Gledhill
Mr and Mrs Vale
Donald Moorby
Trevor Piper
Cathy Waghorn
Sharon Atkins
Val Gledhill
H G Gentry
Amy Shepherd
C Chambers
Jeremy Cubitt
Marion Blackman
Paul Blackman
Debbie Webster
Peter Webster
Craig Cheeseman
Nihal Haddi
Megan Copper
Ryan Copper
Chris Williams
P & J Godman
Ann Darby
Alice Walker
Simon Darby
Bryan Darby
Sharon Darby
Claire Broadbent
Matthew Broadbent
Andrew Howard
Beth Lester
Rosemary Porter
Helen Reynolds
Natasha Saville-Smith
Holly Vos
Tracy Balcombe
Katrina Coleman
Hugh Sinclair
Gary Easton
Emily Fisher
James Barringer
William Coleman
Lawrence Coleman
Neville Coleman
Deirdre Sinclair
Susan Easton
Chris Walker
Susan Askew
Jody Williams
James Askew
Dale Richards
Oliver Williams
G. A. Oliver
Cindy Williams
Christopher Oliver
Jennifer Ashwood
Florence Bennet
Norman Bennet
Siobhan O’Connell
H Lewsey-Gillmore

Object

TWBC: the standard response was submitted by the list of responders on the left:

I challenge the need for so many houses to be built over the plan period of 2016-2036. The Office for National Statistics estimates borough population growth of 13,952 people, and with an average house occupancy rate of 2.35 people (117,140 people living in 49,880 houses), the need is for 5,937 houses (of varying sizes). TWBC must challenge the government on the number genuinely needed in the borough.

DLP_7930

Wendy Owen

Object

1b states “An enhanced town centre development at RTW, including... the provision of flexible retail, leisure, and cultural uses, as well as new office provision…”.

In December 2018 Kent Live reported “Empty shops in Tunbridge Wells could be the start of town centre shrinking as shopping habits change”. Last year the Courier reported that nearly a third of the RVP units were empty. There are still numerous empty shops so there is little point planning to build more until the current supply is exhausted. The same is true for office space. In past years office space in the town has been converted into residential space, the most obvious example being the Union House development of 127 luxury flats (none of which are affordable). Maybe AXA PPP healthcare would like to consolidate its offices at North Farm but it is not at all clear who would fill the existing/old ones if that were the case. TWBC needs to think more carefully about what the future of retail and office work is in an increasingly digitalised world rather than wishing for a return to the turn of the century’s shopping and working patterns.

DLP_457

Evolution Town Planning for Hams Travel

Support with conditions

Please find attached our representations on behalf of Hams Travel in relation to the Local Plan policy and allocations around Benenden.  As part of these representations, we are promoting an excellent Brownfield Site, which has only just been confirmed as available for redevelopment.

Unlike many of the sites proposed to be allocated, this is a brownfield site and we consider that it has the potential to support local facilities within Benenden.  The site hasn’t previously been put forward in the Call for Sites, because it is only recently that the business’s plans to enlarge their other yard (in Flimwell) and relocate the Benenden part of the business to that site have been put forward as a planning application (currently live).  That application is progressing well (certainly in relation to the yard expansion at Flimwell and proposals to relocate the Benenden operations to Flimwell).  On this basis, we are confident that the Benenden site will be available for development in the near future.  It offers an excellent opportunity to delivery housing on a brownfield site and provide visual improvements to the ANOB.   We would be grateful if the Policy Team would now consider the benefits of this site, in addition to (or in preference of) some of those allocated.   We would welcome opportunity to discuss this site with you.    We are happy to submit a Call for Sites form if you would include it in that process as well? In addition, it could be added to the Brownfield register.

Hams Coach Yard, Benenden 

Representations made on behalf of the Hams Travel

1.0 Introduction

1.1 These representations are submitted by Evolution Town Planning Ltd on behalf of our client and site owners, Hams Travel in response to consultation on the Draft Tunbridge Wells Local Plan Consultation (Regulation 18) 2019.

1.2 The representations relate to their site at Benenden, which has not previously been submitted in the ‘Call for Sites’ process (due to uncertainty about whether it would become available). However, as we will set out in this report, Hams Travel are now confident that this site can be released for development as it will shortly be surplus to requirements in the business. We consider that there are substantial benefits in developing this site over the other sites currently allocated and we therefore seek the allocation of this site in preference to, or in addition to, the other sites included around Benenden in the draft Local Plan. The extent of the site available is set out in Appendix 1.

1.3 These representations set out that we:

  • Support the Policy STR 1 (Development Strategy) and suggest that it should include greater flexibility to enable a wider range of windfall development outside of defined settlement boundaries.
  • Object to policy STR/BE1 and suggest revisions including the allocation of Hams Travel’s Surplus Yard.
  • Object to policy AL/BE2 and suggest removal or revisions.
  • Object to policy AL/BE3 and suggest removal or revisions.
  • Object to policy AL/BE4 and suggest revisions.
  • Suggest Inclusion of new allocation, to allocate Hams Travel’s Surplus Bus Yard.

2.0 POLICY STR 1 (Development Strategy)

2.1 Having reviewed the broad strategy contained in this policy, we note that the Council is relying heavily on delivery of housing around Paddock, which includes an entire new settlement at Tudeley Village on the Hadlow Estate, between Tonbridge and Paddock Wood. Tunbridge Wells, the largest settlement in the district, is only allocated 1222 to 1330 new homes. Meanwhile allocations in smaller sustainable settlements are restricted even more significantly. Benenden has received allocations for just 53-57 new homes, whereas the relatively remote site of Benenden Hospital at East End, a significant distance from Benenden, has received allocations for up to 66-72 new homes.

2.2 We object to this strategy as set out in policy STR1 since we consider it has an over- reliance on large sites at a time when economic downturns are predicted and the proposed policy does not include sufficient flexibility to guard against non-delivery.

Objections - policy STR1

2.3 The Consultation Draft Local Plan policy STR1 identifies development allocations as follows:

  • Paddock Wood and surrounding area (around 4000 new homes at Paddock Wood and an entire new settlement at Tudeley Village on the Hadlow Estate of 2500-2800 of which 1,900 are to come forward during the plan period).
  • Tunbridge Wells, the largest settlement in the district, is only allocated 1222 to 1330 new homes
  • Other settlements have been allocated sites at various levels in accordance with their sustainability credentials and opportunities. So for example, Cranbrook has received allocations for 718-807 new dwellings, whereas Bidborough has not received any allocations. Benenden has received allocations for 53-57 new homes, whereas the relatively remote site of Benenden Hospital at the very small settlement of East End, a significant distance from Benenden, has received allocations for up to 66-72 new homes.

2.4 We are not persuaded that this strategy is likely to ensure delivery at the levels the NPPF requires. NPPF states at paragraph 59 that the government’s objective is to ‘significantly boost the supply of homes’ and elsewhere the NPPF makes clear that it is not just the allocation of sites, but their delivery which is crucial. In this regard we have concerns that such a large proportion of the Borough’s housing allocations have been concentrated in such a small part of the Borough and on large sites. Since large sites are known to be vulnerable and volatile to non-delivery in economic down turns, this approach seems to be flawed and likely to place the strategy at risk.

2.5 The NPPF (paragraph 68) states that ‘small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built-out relatively quickly.’ In supporting small and medium sites to come forward, the NPPF requires LPAs to ensure that (a) at least 10% of their housing requirement is on sites no larger than one hectare; and (c) ‘support the development of windfall sites through their policies and decisions – giving great weight to the benefits of using sustainable sites within existing settlements for homes’.

2.6 By relying on a few large sites for such a large proportion of the housing supply in the Paddock Wood market (over 50% of the Borough’s 7,593 housing allocations required), we are concerned that this strategy is likely to prove highly vulnerable to obstacles to delivery, should the market experience a downturn or volatility. This is not consistent with the aims of NPPF.

2.7 Whilst we do not object to the allocation of these larger sites, to guard against non- delivery the Council should consider allocating far more small and medium sized sites and scheduling to expect a slower rate of delivery on these large sites. This will effectively program in some dips in the market and downturns, in such a way that delivery of the overall housing target is not compromised. We consider that the Local Plan is comprised and at risk of being found to be unsound, without an increase in small and medium sized sites being allocated and less reliance on the large sites around Paddock Wood.

2.8 We also object to paragraph 6 of the policy, which states that development will be supported on the following basis:

Development at the other settlements across the borough within their respective Limits to Built Development boundaries and through the delivery of allocations as per Table 3 below, and other suitable windfall developments;’

2.9 Since this policy only restricts development to ‘within their respective Limits to Built Development boundaries’; on allocated sites and ‘other suitable windfall sites’ the policy could be improved with greater clarity as to what ‘other suitable windfall sites’ will be considered to be. We believe that, in the light of the Council’s heavy reliance on large sites in the Paddock Wood area for the vast majority of housing delivery, this clause should be expanded to state the following:

Development at the other settlements across the borough within their respective Limits to Built Development boundaries and through the delivery of allocations as per Table 3 below, and other suitable windfall developments including brownfield sites outside of the Limits to Built Development;’

2.10 This would open up development options on brownfield sites in accordance with NPPF’s preference for brownfield delivery and would assist against concerns regarding the non-delivery of large allocated sites in an economic downturn.

2.11 Regarding paragraph 8 of policy STR1, we note that it states development will be supported:

Where major development is provided for at specific identified sites in the AONB, this is only where the tests set out in the NPPF are met’.

2.12 Given the scale of the housing crisis and the need to ensure delivery of housing across the Borough, we consider that this clause needs to be amended to be more flexible and to be explicitly supportive of developments which are not ‘major’ developments (especially where such proposals are on brownfield land) and where the proposals would result in visual improvements to the ANOB. We suggest a revision as follows:

Where major development is provided for at specific identified sites in the AONB, this is only where the tests set out in the NPPF are met. Proposals for housing developments which are not ‘major’ developments will be supportive especially on brownfield sites where there are opportunities for enhancements for the AONB’.

2.13 We consider that these suggested revisions will bring the plan more into line with the NPPF which requires Local Plans to support brownfield development, ensure the delivery of housing (not simply allocated sufficient sites) and be ‘positively prepared’, ‘justified’, ‘effective’ and ‘consistent with national policy’ (paragraph 33). Such amendments will place the plan in a better position for its Examination.

Summary

2.14 We would support policy STR1, if it were amended to include less reliance on the new settlement and Paddock Wood sites and a greater proportion of smaller sites across the Borough. However, in addition we have also recommended the following amendments, to ensure that the plan is positively prepared and effective, even if the Council continues to rely on such large sites to deliver its housing strategy:

(6) Development at the other settlements across the borough within their respective Limits to Built Development boundaries and through the delivery of allocations as per Table 3 below, and other suitable windfall developments including brownfield sites outside of the Limits to Built Development;’

(8) Where major development is provided for at specific identified sites in the AONB, this is only where the tests set out in the NPPF are met. Proposals for housing developments which are not ‘major’ developments will be considered positively and constructively, especially on brownfield sites where there are opportunities for enhancements for the AONB’.

2.14 Both of these amendments would help guard against non-delivery of the larger sites that the plan relies on, should there be a downturn in the housing market. These suggestions will improve the deliverability of the Council’s housing targets.

[TWBC: see Appendix 1 Land Registry document and site location plan in full representation].

DLP_7955
DLP_7993

Sharon Pickles
Richard Pickles

Object

TWBC: the standard response was submitted by the list of responders on the left:

1. C.

*If the ENS has identified the above areas for development, this is surely where many new residents of the Parish of Cranbrook and Sissinghurst will be travelling to work, (14 miles away) entirely unsupported by appropriate infrastructure

I object to placing so much development in Ctranbrook and Sissinghurst when employment is targeted so far away

DLP_8008

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

Support

3 DEVELOPMENT STRATEGY

3.1 We endorse the approach and the findings in respect of the Objectively Assessed Need (OAN) as set out the Housing Needs Assessment Topic Paper. We also consider that it is vital that sufficient land is identified and allocated to enable delivery of the full OAN rather than place a reliance on an arbitrary windfall allowance.

3.2 The character of The Borough is such that it is subject to high level environmental constraints such as an expansive AONB and Green Belt and some areas of Flood Zone 3b land. These factors influence and inhibit the ability to bring speculative windfall development forward. For this reason, the certainty of allocated housing land should be an integral component of the Local Plan policy framework to ensure delivery of the full OAN.

3.3 Policy STR 1 Development Strategy identifies that:

“New development at Hawkhurst to provide a range of new homes, as well as the delivery of significant infrastructure improvements in the form of a relief road from Cranbrook Road to Rye Road, providing significant improvements to the crossroads in the centre of Hawkhurst (Highgate), and associated public realm improvements. A package of other community benefits will also be provided in the form of new health and other local facilities, as well as employment growth by way of an extension to the existing Key Employment Area at Gill's Green”.

3.4 The policy approach is supported.

5 HOUSING

5.1 It is noted that the plan states that total capacity of all identified sites (completed houses since 2016, outstanding planning permissions, retained Site Allocations Local Plan allocations, development through windfall sites, together with new allocations proposed in this Draft Local Plan) provides for some 14,776 net additional dwellings. This compares to a minimum requirement of some 13,560 dwellings. The council’s approach provides for a modest oversupply equivalent to some 9% in order to ensure delivery of the full OAN. Where a range of housing numbers is provided in a policy for the outstanding site allocations and proposed allocations, the figure used in the above calculations the council state that this is the mid-point of this range.

5.2 However, table 1 Housing, sums to 13,560. It is therefore unclear as to where the additional 1,216 dwellings (14,776) are identified in the components of supply. This matter requires clarification.

5.3 The planned housing target for Hawkhurst is shown as a range. This approach is not supported. The target should be the specific figure of 731 dwellings as minimum. The plan allowance of windfall (equivalent to 5.16%) should be in excess the planned target for the reason set above.

5.4 Notably the implementation of allocations has often yielded less dwellings than originally planned for. By way of an up to date example, the recently submitted planning application presented to the council on site HA 1 (Land forming part of the Hawkhurst Golf Course to the north of the High Street) is proposed for 400 dwellings as opposed to the 400-450 dwelling as envisaged in the draft allocation. This demonstrates the potential fragility of the supply when relying on density assumptions on allocations in this area with identified national level environmental and policy constraints. There is need to allocate more sites in Hawkhurst to ensure delivery of the full OAN. A sensible approach would be to identify land for 10% above the 731 housing target to ensure delivery of the full OAN. Further, reserve sites should be identified to cover the eventuality, later on in the plan period, of allocations under delivering.

DLP_8017

Penny Ansell

Object

I would like to reiterate my comments made at the end of the previous section that if as they had said, the Council proposes a development strategy to meet housing growth based on:

Option 3 - development distributed proportionately across all of the boroughs and settlements

and

Option 5 - a new freestanding ‘garden village’

then Option 3 is NOT demonstrated in the draft plan.

As I have said previously, how can Tunbridge Wells (pop’n 48,324) allocate itself only 1,271 houses while it expects Hawkhurst (pop’n 4,991) to build 668. (In fact, once existing building from 2016 is taken into account, the number will be way above this). This is particularly unacceptable considering Tunbridge Wells has infinitely superior infrastructure and road and rail networks.

Also, for comparison, Speldhurst with a population more or less identical to Hawkhurst is allocated only 15 - 20 dwellings

These figures are neither proportionate nor appropriate to scale.

This is particularly so since in terms of landscape characteristics (Section 5, Place Shaping Policies) Tunbridge Wells is mainly ‘urban’ and Hawkhurst is ‘wooded farmland and forested plateau’. Of interest, Speldhurst is ‘urban and wooded farmland’.

The Draft Local Plan reveals that TWBC prefers to meet its assessed housing needs primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. It is clear that little real consideration is given to the consequences of such developments for the towns and villages concerned nor for the AONB.

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). I would add that 100% of Hawkhurst lies within the AONB!

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. In fact, it is extremely unclear from the figures given in the ‘Key Diagram and Main Proposals’ shown in the LOCAL magazine how much has already been built in each area. Given that the target for the borough is 13,560 and the number of dwellings shown in LOCAL is only about 10,700 (which refers to future plans plus a few which have permission but not yet built), how are the remaining 3,000 of already built dwellings distributed? That needs to be stated.

Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed.

For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place.

It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them.

The development strategy outlined from paragraph 4.41 onwards is seriously flawed in three respects:

  1. It is neither proportionate nor appropriate to scale
  2. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the Draft Plan;

It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point.

DLP_8037

Rose May McAuley

Object

Policy Number:  Section 4 Strategic Policies  Policy STR 1 The Development Strategy 

Point 1 - Tunbridge Wells is going to receive all the new facilities and the employment but Tunbridge Wells is receiving getting far fewer houses than Sissinghurst .  The number the Draft Plan wants in Sissinghurst are not justified.  They should be lower, more like has been suggested for Frittenden.  We already have loads of new houses that are expensive and not helping people around here who want to buy houses, no-one here can afford them.

DLP_540

Catherine Catchpole

Object

The policy states that development will be carried out within the limits to build, and yet for all 3 of the main sites in Horsmonden, the development requires the limits to build to be extended.  What is the point of setting limits to build if you just ignore them?

DLP_8102

Ashley Saunders

Object

This policy does not include any reference to development on Brownfield sites but does refer to the release of Green Belt. There should be a strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites.

You repeatedly refer to the Eastern part of Capel parish as part of Paddock Wood when it is not, and unlike Paddock Wood is in the Green Belt. It has a completely different heritage and culture from Paddock Wood. Badsell Manor is the oldest continuously inhabited houses in the parish and its historic environs would be destroyed by this proposal.

DLP_8137

Hume Planning Consultancy Ltd for Meadow View Construction Ltd

 

Policy STR 1 – The Development Strategy

Housing Targets

We broadly support the reference within the draft policy to meeting the identified needs of the Borough over the Plan period. In this regard, we note the Council consider that a minimum of 7,593 homes will need to be accommodated through new allocations in this Local Plan, as set out in Table 1 of the draft consultation document.

When identifying the relevant housing requirement for the Plan period, we encourage the Council to consider the need arising within its own authority boundaries (as indicated by the Standard Method) as well as any unmet need from elsewhere in the Housing Market Area, and also to factor in an appropriate buffer for non-delivery as well as ensuring a sufficient supply of housing within the early years of the Plan. This will be necessary in order to ensure the Plan is positively prepared in accordance with the requirements of paragraph 35 of the National Planning Policy Framework (NPPF).

Distribution of Development

Paragraph 172 of the NPPF sets out three considerations against which proposals for major development in the AONB should be assessed:

a) The need for development, including any national considerations, and the impact of permitting it, or refusing it, upon the local economy. b) The cost of and scope for, developing outside the designated area, or meeting the need for it in some other way; and c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.

The current Development Strategy has sought to minimise the development directed towards the AONB, paragraph 4.38 states that: “the Council proposes a development strategy to meet the housing needs of the Borough based on Option 3 (dispersed growth)…this also takes account of the need to maximise the amount of major development outside the High Weald AONB”.

We support the Council’s intention, at part 5 of the policy, to accommodate further development at Cranbrook in order to help meet the Borough’s identified housing need. Cranbrook is a sustainable location for growth, being located within the second tier of the settlement hierarchy (as a ‘Small Rural Town’ in the adopted Core Strategy and a ‘Group A’ settlement in the emerging Local Plan), and it is appropriate to focus growth around settlements which have a relatively good level of provision of services and facilities.

Whilst Cranbrook is ‘washed over’ by the AONB, this is the case for some 70% of the Borough, and although paragraph 172 of the NPPF places great weight on the conservation and enhancement of AONB, it does not rule out sensitively designed development in or on the edge of settlements within the AONB, as noted at paragraph 3.11 of the Council’s Distribution of Development Topic Paper. The Topic Paper goes on to note that Exceptional Circumstances exist to allocate major sites for development within the AONB at locations such as Cranbrook.

Having regard to the above, and the relatively unconstrained and sustainable nature of Cranbrook, we support the intention to identify sites for housing growth around Cranbrook, and we encourage the Council to consider the potential for Cranbrook to accommodate a greater number of new homes than the quantity (between 718-803) identified at Table 3 within the draft Plan. It is also noteworthy that the site allocation AL/CRS 9 ‘Crane Valley’ which adjoins the land promoted in these representations was already allocated within the Council’s adopted Site Allocations DPD (site allocation AL/CR 4). Although the site is yet to be delivered, it should not be considered to be a ‘new’ allocation in the emerging local plan document. As such, it could be considered that the current allocations for Cranbrook in this plan are only around 500 homes. Given the size of the settlement and the existing amenities and facilities on offer in Cranbrook, in our view a larger quantity of ‘new’ allocations should be directed toward Cranbrook over the coming plan period.

The distribution of development across the remainder of the Borough is skewed toward the delivery of homes in two large allocations at Paddock Wood/ Capel, and Tudeley Village which collectively are expected to deliver 5,900 homes out of the 9,861 homes allocated in the draft Local Plan (average figures used). This makes up around 60% of the Council’s emerging allocations, and around 44% of the Council’s required housing delivery over the plan period.

Clearly, should any issues with delivering the large-scale allocations at Paddock Wood/ Capel, and Tudeley Village occur, the ability for the Council to meet their housing requirements would fall into a critically dangerous position, which suggests that the Council are placing too much reliance on these sites. In our view, the Council should plan to be able to meet more of their immediate housing requirements through smaller allocations which are inherently quicker and easier to be delivered.

Furthermore, looking at the housing trajectory which accompanies the local plan consultation, it is anticipated by the Council that completions on the site will begin at the Tudeley Village allocation in 2025. At present, the site does not appear to benefit from planning permission, nor is there an application under consideration. In the Paddock Wood allocation (4,000 homes) it is anticipated that completions will begin in 2024, and again the site does not appear to benefit from planning permission, nor is there an application under consideration. Given the size of these schemes and the supporting information which will be required, in our view the delivery of homes this early on in the plan period is considered to be unlikely.

The settlement of Tudeley, which is allocated 1,900 homes in the draft local plan, is currently no more than a hamlet with very limited access to existing services and facilities. Tudeley is also located within the Green Belt and thus its allocation in the plan involves the removal of a large quantity of undeveloped Green Belt land for the development of housing.

On the other hand, the site at Cranbrook is not within the Green Belt, and is well contained by both the existing built form of Cranbrook, landscape buffers, as well as the proposed development to the immediate west. Cranbrook also has a wide range of existing services and amenities which will only be improved for existing residents through the introduction of additional homes.

Windfall Allocations

The draft Plan also identifies that 700 homes are expected to come forward as windfall approvals over the plan period, although this figure has been calculated utilising data from previous windfall completions in recent years, it cannot be guaranteed that this quantity of homes will come forward in this plan period and therefore cannot be relied on.

Summary

We have set out above our comments, on behalf of Meadow View Construction, on the Regulation 18 consultation draft of the Tunbridge Wells Borough Local Plan (September 2019), and we welcome the opportunity to work collaboratively with the Council to identify a sound development strategy. We support the intention to meet the identified housing needs of the Borough, and to accommodate a portion of this housing need at Cranbrook, which represents a sustainable and suitable location for growth. 

However, we encourage the Council to ensure the development strategy for Cranbrook is sufficiently justified, and in this regard, we consider that there is a compelling case for the allocation of the land west of Freight Lane for residential development given the positive SHELAA conclusions. We therefore request that the Council reconsiders the merits of allocating this site for development within the Regulation 19 draft of the Plan. 

The site is in single ownership and there are guaranteed access rights across the already allocated site to the west (Allocation AL/CRS 9) to deliver a road connection between Angley Road and Freight Lane to bypass the High Street, this would deliver transport benefits to the wider community and existing residents. 

The site also has the ability to deliver up to 100 dwellings by 2023, and would be able to do so in an approach is consistent with Paragraph 172 of the Framework. 

We respectfully ask that our comments are considered and that the necessary modifications are made to ensure the soundness of the Plan. In the meantime we would be pleased to discuss this site in further detail with officers should the opportunity arise.

DLP_8192

Mrs Suzi Rich

Object

Why does the Development Strategy contain no reference to development on Brownfield sites but instead refers to the release MGB? There should be a strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites.

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

DLP_8204

Home Builders Federation

 

Thank you for consulting the Home Builders Federation (HBF) on the draft Local Plan. The HBF is the principal representative body of the housebuilding industry in England and Wales and our representations reflect the views of discussions with our membership of national and multinational corporations through to regional developers and small local housebuilders. Our members account for over 80% of all new housing built in England and Wales in any one year. Outlined below are our comments on the approach taken by the Council to increasing the supply of land for residential development and the policies being proposed with regard to the management of new development in future.

Strategic Policies

STR1 - The Development Strategy

The Housing Requirement

Before considering whether the level of housing being planned for is appropriate, we would recommend that final housing requirement agreed is clearly set out in policy STR1 in order to provide the necessary clarity as to the minimum delivery expectations of this Local Plan. The Council should also include a housing trajectory in the local plan as required by paragraph 73 of the National Planning Policy Framework.

The Council have identified in table 1 of the draft local plan (DLP) that the application of the standard method results in a housing need for Tunbridge Wells of 13,560 homes (678 dpa) for the plan period 2016 to 2036. We would not disagree with this figure but the National Planning Policy Framework (NPPF) is clear that the local housing needs assessment only represents the minimum number of homes that should be delivered but we note that this is a capped figure with the uncapped figure being approximately 100 homes per annum higher. In such a position Planning Practice Guidance (PPG) outlines that:

  • An early review and updating of the plan may be required; and
  • Consideration is given as to whether a higher level of need can be delivered.

However, even without a cap the Government require Councils to give consideration as to whether more homes are needed to take account of:

  • Unmet housing needs within neighbouring areas
  • Growth strategies and infrastructure improvements
  • Need for affordable housing

    Each of these issues and their relevance to Tunbridge Wells District Council (TWDC) are considered below.

Unmet housing needs in neighbouring area

The Government has established in paragraph 60 of the NPPF that in addition to their own housing needs:

“…any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for”

The inclusion of this statement within the NPPF means that the Government are not merely requiring Council to consider whether they should address any unmet needs from neighbouring areas but that they must address these needs where possible and where it would be consistent with other policies in the NPPF. In preparing the local plan it is therefore vital that the Council establishes whether there are any areas that are not meeting housing needs in full. The Council have, to some extent, considered this matter within the Housing Needs Assessment Topic Paper. In this paper the Council acknowledges that there is an under supply within at least one neighbouring authority – Sevenoaks – but that the Council does not consider itself to be in a position to increase its own housing requirement to meet any unmet needs arising in Sevenoaks due to the constraints present across Tunbridge Wells.

We note that the Sustainability Appraisal (SA) does consider a growth option that includes delivering the unmet needs arising in Sevenoaks (option 7). However, paragraph 6.2.2 of the SA seemingly dismisses this option due to the assumption that the additional 1,900 dwellings would be located within the AONB. Given that there are areas of Tunbridge Wells not in the AONB it is unclear how this conclusion can be reached. Whilst we recognise that there are a number of constrains within the Borough the Council must acknowledge that these do not extend across the entirety of the Borough. As such there will potentially be more opportunities for meeting needs should Sevenoaks, or indeed other neighbouring authorities, not be able to meet their own needs.

In addition to those neighbouring authorities where needs will not be met the Council must also consider whether there are any needs in neighbouring “areas” that will not be delivered. This is an important distinction set out in paragraph 60 of the NPPF and requires Councils to consider meeting needs across a much wider area than the Council has considered as part of the preparation of this plan. In particular we would suggest that the Council examines the ability of those London boroughs which form the northern borders of the Council’s stated housing market area to meet their housing needs.

As the Council will be aware the inspectors’ examining the new London Plan have submitted their final report to the Mayor of London. Whilst the report considers the approach to assessing housing needs used by the Mayor to be sound the panel did not consider there to be sufficient evidence to show that the plan would deliver the level of homes suggested by the Mayor. Rather than a shortfall of some 10,000 homes across the plan period the inspectors stated that a more realistic level of delivery across London would see a shortfall against housing needs of some 140,000 (14,000 dpa) over the next ten years. This is a substantial shortfall and it will be incumbent on authorities in the South East to work with London Borough’s increase supply accordingly.

However, the mechanism through which it works with London at present cannot be considered an effective mechanism through which this situation can be addressed. The Panel’s report stated that the current mechanisms, as set out in SD2 and SD3 of the Draft London Plan, are ineffective. Indeed, the Panel concluded that in the light of the lack of support being provided by the wider South East for delivery of London’s unmet housing needs a strategic review of the Metropolitan Green Belt was called for. However, with limited agreement for such an approach across London and the wider south east it will be essential for the Council to work with those authorities in the South East of London to establish the level of shortfall that will occur over the next ten years and to identify how many additional homes could be delivered in TWDC.

Growth strategies and infrastructure improvements

Paragraph 2a-010 outlines those situations where a Council may need to deliver more homes than the minimum established through the local housing needs assessment. It will be important for the Council to consider whether the economic aspirations of the Borough, and Kent in general, will place additional pressure on housing needs in the Borough that will require the allocation of further sites within he Local Plan.

Need for affordable housing

Paragraph 2a-024 of Planning Practice Guidance states that an increase in the total housing figure may be required where it could help deliver the required number of affordable homes. The Council state that on major sites that will come forward through this local plan the Council expect to be able to deliver 239 homes (Table 12 Housing Supply and Trajectory topic paper) – little over 100 homes short of meeting the identified need for 443 affordable homes needed each year. Using the Council’s proposed affordable housing policy would need in the region of 1,100 homes to be delivered each year over the plan period for affordable housing needs to be met in full. This is substantially higher than the local housing needs generated using the standard method, (678/682dpa) and clearly suggests the Council examine whether it can do more to address this shortfall. However, rather than increase the supply of land for housing the Council have instead looked to require small sites of less than 10 units to deliver affordable housing units. Such an approach is not only inconsistent with national policy it will provide an increase of just 13% to the planned supply of affordable housing. We would suggest that a more appropriate, effective and policy compliant approach would be for the Council to identify and allocate additional sites that will deliver both market and affordable housing to meet the needs of the Borough and neighbouring areas. At the very least the Council must test such a scenario through the SA.

Distribution of development

In considering the distribution of development across the Borough the HBF recommends that Councils seek to ensure that they supply a wide range of housing allocations across an area. An over reliance on development in a single area or through the development of a new settlement will increase the risk that a plan will not deliver its housing requirement for the plan period. To some extent the potential risk of slow delivery can be addressed by ensuring strategic expansions and new settlements allow for a range of developers providing different products to be actively delivering new homes. However, where this is not possible the Council should provide a more cautious approach to delivery and recognise, as set out in footnote 35 of the NPPF, that homes will be delivered beyond the plan period.

Conclusion

I trust that the Council will find these comments useful. I would be happy to discuss these issues in greater detail or assist in facilitating discussions with the wider house building industry. The HBF would like to be kept informed of the progress of the document. Please use the contact details provided below for future correspondence.

DLP_721

Dr P Whitbourn

 

Paragraph 1a of Development Strategy Policy STR 1 envisages for Royal Tunbridge Wells "extensive infrastructure" including "Public Realm enhancements" and "transport provision".

We have been living for some time now, and still are while putting together this consultation response, with the very disruptive consequences of "extensive infrastructure" works in the "public realm" on Mount Pleasant. Earlier works at the Five Ways were bad enough, but those currently taking place in the vicinity of the War Memorial are causing even more chaos, with the town centre effectively divided into two; traffic congestion confusing and dire; vital bus routes re-routed in a very un-clear and highly inconvenient way; traders hit by road closures; and s chopped down , leaving a general sense of devastation at the heart of the town, leaving a general impression to some that Royal Tunbridge Wells is a somewhat disagreeable place no longer worth coming to.

This is all most regrettable especially as, although the intention behind the works was good, its execution turned out to be excessively heavy-handed and over-elaborate civil engineering that was not well managed from the point of view of the general public. I strongly support aspects of this phase II scheme, such as widening the stretch of footpath in front of the war memorial which has long been a source of congestion, with pedestrian flows obstructed by passengers waiting for, or alighting from the many buses that are so important to the life of the town centre.

The town needs to learn from this salutary experience and, in particular, not to cause even worse chaos if any stage III initiative is planned in the vicinity of Great Hall and the Central Station. Royal Tunbridge Wells is not a town in need of "extensive" infrastructure for the sake of it. Instead, it needs a more gentle approach, with "appropriate", sensitive and well-thought-out measures to address genuine problem areas, such as being able to get from the Central Station from the High Street without risking life and limb, or making a lengthy detour.

I suggest therefore that word "appropriate" be substituted for "extensive" in policy STR 1.

The same policy goes on to raise the subject of "transport provision". This could, of course be very welcome if it meant, for example, delivering better organised , more frequent and more reliable bus services in the urban area. As matters stand, however, I find it unclear what form that "transport provision" might take, and I have not found section 6 particularly enlightening on the subject.

DLP_8273

Ann Gibson

Object

STR1c A prestigious new business park will be located to the north of North Farm/Kingstanding Way that is well connected to the improved A21, providing a range of employment floorspace and jobs to meet identified needs.  The site will make a substantial contribution to the need for new employment space over the plan period.  Other employment, including leisure development, will be encouraged at North Farm/Kingstanding Way.

If the ENS has identified the above areas for development, this is surely where many new residents of Sissinghurst will be travelling to work, (14 miles away), entirely unsupported by appropriate infrastructure.  They will be forced to use private cars thereby increasing carbon emissions.

I object to placing development in Sissinghurst when employment is targeted so far away.

DLP_856

Ian Pattenden

Object

Comments on Policy STR 1 (The Development Strategy) p.42

This policy does not include any reference to development on Brownfield sites, but does refer to the release of Green Belt.

You should have a strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites. Your comment that brown field sites must be registered by the owner is yet another example of a poor excuse not to pursue these sites for development. As rate payers we expect our officers to work hard and to take the right decisions, not easy and unsound ones.

DLP_937

Mrs Karen Stevenson

Object

The Development Strategy for the delivery of the Local Plan adopts a combination of growth strategies proposed in the Issues and Options document.

Prominent in this mix is proportional distribution of growth across all existing settlements this is despite the fact that the consultation recorded a less positive response to this approach than the other strategies.  Also in the mix is growth within a new, free-standing settlement, however the feedback in the Issues and Options consultation, which recorded a slight preference this growth strategy , specified that the new settlement should not be in the Metropolitan Green Belt or the AONB. The ‘Distribution of Development Topic Paper’ presents the justification for the proposed Development Strategy, including how the Issues and Options consultation informed the Strategy. However, the outcome is at odds with the feedback and, in several instances, goes directly against the views expressed.

We oppose the proposed approach of dispersed growth across the Borough. It is inconsistent with the NPPF, which advocates focusing development in the most sustainable locations, allocating land with the least amenity value and conserving and enhancing the AONB, where the scale and extent of development within such designated areas should be limited (NPPF paragraphs 171 and 172). It is also contrary to the Council’s previous Local Plan and Core Strategy, which focussed growth in towns, recognising that villages and rural settlements are the least sustainable locations for development. So many of the proposed development sites allocated in the draft local plan go against these views expressed and are contrary to protections that should be afforded to AONB and Green Belts under the NPPF procedure.

Dispersed growth with proportional development distribution is not consistent with the three objectives of sustainable development. Looking at our own village of Matfield, this is one of the least sustainable settlements in the borough. It lacks the services and amenities to support significant growth (up to 37.5% in the number of dwellings). There is no evidence of scope for the village to become more sustainable as a result of growth, despite the Council’s untested hope in that it may. Development of this scale in settlements with low sustainability is contrary to the NPPF (paragraphs 7 and 8) and is not in the public interest.

What was the rationale for adopting the preferred approach of dispersed growth, in favour of the focused growth used in the Core Strategy? How was the ‘proportional’ aspect of ‘proportional development distribution’ determined under the ‘dispersed growth’ model applied in the Development Strategy? What methodology was applied and how has this been tested?

More should be done to promote a greater proportion of housing development on Brownfield land, particularly, in the existing urban centres. The current Brownfield Register for Royal Tunbridge Wells contains provision for only up to 950 homes, which is an incredibly small provision for a town of this scale. How exhaustive has the search been to identify land that could be redeveloped rather than building over rural areas, both in rural villages and the countryside?  Why can’t more development be allocated to such Brownfield sites, within existing towns, where transport services are already in place, rather than destroy more of the AONB countryside? Development of brownfield sites often has the benefit of removing local eyesores and breathing new life into areas of towns which are run-down and further providing homes where most young people actually want to live, near to existing infrastructure, amenities and services. Brownfield site development should be prioritised over building in idyllic rural villages and a greater search of potential sites made in not only Tunbridge Wells but other towns in the borough.

DLP_939

Tom Clarke MRTPI

Support with conditions

The Trust has had extensive engagement with the Council regarding the proposed new theatre for Royal Tunbridge Wells. We continue to support the delivery of a new theatre for the town as articulated within our formal comments in response to application 18/00076/FUL which we submitted in early 2018.  We acknowledge the current site for the new theatre, which forms part of a wider Civic and commercial development, has been subject to challenge.  Therefore our continued support for a new theatre for Tunbridge Wells is conditional upon the Assembly Rooms being retained and operational until such time as a replacement is operational so there is no break in provision.  We urge the Council to continue to engage with the Trust.

DLP_1077

Mr John Hurst

Object

Policy STR1 - Development Strategy

The numbers of dwellings proposed is excessive, and based on outdated methodology.

Notwithstanding that it is a Government edict, it must be challenged.

1. The timeline that gave rise to this is as follows:

- Government made a political statement that 300k houses are needed nationally

- Government required the ONS' "2014" methodology for calculating housing need be used (NB this results in about 240k houses nationally)

2. Impact of using updated ONS methodology

- ONS produced a revised "2016" methodology, which in the case of Tunbridge Wells would require only 67% of the 2024" figure, according to consultants Barton Willmore, see

http://www.bartonwillmore.co.uk/Knowledge/Intelligence/2018/Housing-need-will-fall-in-light-of-new-household-p

The nett new dwellings to be added are shown in the DLP in Table 1 in section 4:12, on page 35.

If the 67% factor is applied to line 1., the resulting nett new dwellings in line 6 goes down from 7,593 to 3,115, ie to much less than half.

This, together with additional brownfield developments first (see comments to Policy STR4) could obviate the need for use of Green Belt land.

Hence the importance of challenging the numbers basis.

DLP_1309

Mrs Gillian Smith

Object

Dear Tunbrdge Wells Borough Council (Local Plan Team),

Please take into account the following objection with regards to Policy STR1: - The Development Strategy (Item 2, 3 & 7 [extracts below]):

Item 2 'Capel':

"Expansion at the settlement of Paddock Wood (including land in the eastern part of Capel parish) following garden settlement principles to deliver housing and employment growth, new and expanded education facilities, and provide strategic flood risk solutions to reduce flood risk and provide betterment to particular existing areas. Regeneration of the town centre to provide a vibrant and viable new centre for the communities it will serve, as well as the delivery of a range of other community facilities and infrastructure, including new health facilities, a sports hub, new primary schools, expansion of the existing secondary school, and potentially the 'offline' A228 strategic link (i.e. the Colts Hill bypass)"

Item 3 'Tudeley Village' :

"A new garden settlement at Tudeley Village of 2,500-2,800 houses, to deliver approximately 1,900 new homes during this plan period, as well as a package of infrastructure measures, including new education facilities to serve the settlement itself and the wider catchment area, and strategic flood risk solutions to reduce existing flood risk and provide betterment to particular areas"

Item 7 'Capel'

"The release of Green Belt around the settlements of Royal Tunbridge Wells, Southborough, Paddock Wood, Pembury, and in the parish of Capel, to deliver development allocated in this Local Plan;" 

I would like to express my concerns and strong objections over the Tunbridge Wells Borough Council proposal to build over 4000 homes in the Parish of Capel.

As a resident of south Tonbridge, I am well aware that our roads are already uncomfortably congested and polluted; with long tailbacks on the High Street and at the Vauxhall roundabout along Woodgate Way and Pembury Road, during both morning and evening rush hours. Tonbridge High Street which has already been identified as an Air Quality Management Area with levels of Nitrogen Dioxide above the Council’s annual objective, must suffer further detrimental impact with the inevitable addition of extra vehicles from the excessive number of proposed homes.

Along with increased air pollution must come more noise pollution. We already have to tolerate the noise of speeding vehicles on Woodgate Way, which is clearly audible from our back garden. Heavier traffic carrying children and staff to the proposed secondary school, shoppers to the industrial estate and High Street, commuters to Tonbridge station and the A21 will impact negatively upon the quality of life and health of the residents of south Tonbridge.

The building of homes in these excessive numbers must also increase the risk of flooding in the locality, parts of which already have a history of vulnerability. Only a few years ago, despite the flood barrier, Tonbridge was flooded in several different areas – Barden Road, Tonbridge recreational grounds, the Angel area and industrial estate.

At the moment, we are lucky enough to live in an area of outstanding beauty. The Green Belt fields where the developments are proposed are both beautiful and productive and should be protected for the future benefit of all. This land provides a rich diversity of natural habitats for insects, birds and mammals which are already nationally in serious decline. The proposal to build such a substantial number of homes would have a significant and negative impact on the rural landscape, environment, wildlife and  health & wellbeing of the existing community. It would cause the loss of the all important green belt buffer from Tonbridge, which would result in an urban sprawl development from Tonbridge to Paddock Wood.

DLP_3584

Ashford Borough Council

 

Ashford Borough Council welcome the invitation to comment on the Tunbridge Wells Borough Draft Local Plan. Further we acknowledge that both this consultation process and the conference phone call held between representatives of the Local Plan teams on Wednesday 30th October provides an opportunity to not only discuss strategic and cross boundary planning issues, but also to formally cooperate as required.

A full review has been undertaken of the draft Tunbridge Wells Borough Local Plan, it is noted with interest that you intend to meet your housing requirement of 13,560 in the plan period to 2036 through a planned urban extension of Paddock Wood, the establishment of a new garden settlement named Tudeley Village, and a policy of dispersed growth with site allocations for housing growth located in close proximity to the majority of existing settlements.

Ashford Borough Council are pleased to observe that Tunbridge Wells Borough Council are capable of meeting its identified housing needs within its borough boundaries. Our review of the draft plan confirms there are no cross boundary issues, infrastructure proposals or strategic issues that require any comments or a statement of common ground at this time. All planning matters that exist in proximity of the mutual borough boundary can continue to be managed under Local Development Plan policies as is the current situation.

It is acknowledged that both authorities continue to meet the statutory duty to cooperate throughout the Plan making process and I look forward to further discussions with you in due course.

DLP_1732

Horsmonden Parish Council

 

Thank you for the opportunity to comment on the draft Tunbridge Wells Local Plan. This letter sets out the comments of Horsmonden Parish Council (HPC), agreed at a public meeting of the parish council held on Monday 4 November. The comments have been formulated with input from the Horsmonden Neighbourhood Plan Steering Group, which has been working on developing a neighbourhood plan for the parish, in parallel with work on the draft Local Plan.

We would like to make comments on three areas of the draft Local Plan. These are:

  • The overall planning strategy
  • Place shaping policies for Horsmonden
  • Planning policies
  1. The overall planning strategy

In draft policy STR1, TWBC have chosen an overall development strategy based on Option 3 (dispersed growth) and Option 5 (new settlement), which were two of the options aired in the “Issues and Options” consultation in June 2017. At that time, HPC objected to a dispersed growth strategy. We continue to object to the “dispersed growth” strategy for housing development as the basis for the Local Plan’s development strategy. We consider that this strategy is inherently unsustainable. This is because it directs a disproportionate amount of growth to rural settlements with limited facilities and jobs, and with poorer access to public transport. These settlements have higher dependence on the private car and access to them is generally along low capacity rural roads and lanes.

In our view, it would be better to direct more growth to the main urban area of Tunbridge Wells/Southborough, where by far the best range of jobs, facilities and public transport are available and opportunities for higher density development, or along a growth corridor –such as the A21 or railway lines- where there is high capacity transport by road, rail or bus. This provides new households with more sustainable access to facilities and jobs. (Options 2 and 4)

Our concerns over the “dispersed growth” strategy in the draft Local Plan are based in both the National Planning Policy Framework and the Borough Council’s own evidence base for the draft Local Plan.

The NPPF states that “planning policies and decisions should play an active part in guiding development towards sustainable locations” (paragraph 9) and that “growth … should be focused on locations which are, or can be made, sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions and improve air quality and public health” (paragraph 103). These extracts are also quoted on pages 5 and 6 of the TWBC Local Plan Transport Evidence Base: Transport Assessment Report (September 2019)

TWBC’s Transport Strategy Review: Context and Way Forward, in its section on “Rural Transport Issues” (Page 16) leads with the two following quotes (box below) which, in our view, eloquently make the case against a “dispersed growth” planning strategy which directs large scale development to rural settlements:

“It is far easier to change travel behaviour in urban areas” (Gordon Stokes, “Transport and the Rural Economy” presentation, Transport Studies Unit, Oxford University, 2016)

“On average, people living in the most rural areas travel 45% further per year than those in England as a whole, and 53% further than those living in urban areas”.  (Action with Rural Communities in Rural England, website, 2019)

Policy STR1 sets out the proposed development strategy for the Borough, but this is disconnected in some important respects with the settlement hierarchy identified earlier in local plan work. In the Issues and Options document (page 13), TWBC appear to identify a four-tier hierarchy of settlements:

Tier

Settlement hierarchy

Settlements

1.

Main Town

Royal Tunbridge Wells / Southborough

2.

Rural towns

Paddock Wood, Cranbrook, Hawkhurst

3.

Rural settlements

Langton Green, Speldhurst, Rusthall, Bidborough, Pembury, Matfield, Brenchley, Five Oak Green, Horsmonden, Goudhurst, Lamberhurst, Kilndown, Sissinghurst, Frittenden, Sandhurst, Iden Green, Benenden

4.

Smaller rural settlements

All other rural settlements

In many local plans (for example, Mid Sussex, Maidstone, Dover) this hierarchy then forms the basis of the development strategy, or a specific planning policy, where the future pattern of growth reflects the place of settlements within the hierarchy. This means that larger scale development is focused in the higher level settlements best suited to accommodate it, with lesser amounts of development as one progresses down the hierarchy. There is a significant disconnect in the draft Local Plan, in that some tier 2 settlements (such as Paddock Wood) and some tier 3 settlements (such as Horsmonden) have significantly more growth allocated to them than would be expected from their place in the hierarchy. In addition, some rural settlements in tier 3 have much higher levels of growth allocated to them than others at the same level (again Horsmonden), even though some of the others at this level are in much closer proximity to the main town of Tunbridge Wells with all its facilities, job opportunities and access to public transport.

We would like policy STR1 to have a clearer and more explicit relationship between the settlement hierarchy and the scale of development proposed in different parts of the borough.

Whilst HPC accepts that Horsmonden  should accept some growth appropriate to its location, the range of facilities available , local infrastructure capacity and the sensitive rural environment, we consider that the level of growth proposed for Horsmonden in the draft Local Plan (225 -305 dwellings) is excessive and unsustainable. This represents a 25% -30% expansion in the size of the village in a period of less than twenty years up to 2036, much higher than our neighbours in Lamberhurst, Goudhurst, Brenchley and Matfield.

Our main concerns on the scale of growth proposed for Horsmonden are:

  • Horsmonden is relatively remote from the main town of Tunbridge Wells (and to other more distant main towns which also offer a wide range of facilities and jobs, such as Tonbridge and Maidstone), from railway stations and from high frequency bus services. Horsmonden does not even have a daily bus service to Paddock Wood, the nearest rail station, let alone a bus service that will support those commuting to London and other centres, requiring early morning and evening services. As such, any growth in Horsmonden will be highly car dependent. This contradicts Government targets to reduce carbon emissions and mitigate climate change.
  • the additional traffic generated on the low capacity roads and lanes through the village and its effect on traffic congestion and safety, and the ease with which local residents can move around the village on foot or bicycle. (We are keen to promote a “walkable village”). These concerns focus on, but are not limited to, the village centre (a conservation area) and its notoriously difficult crossroads with a high accident rate. Traffic conditions in the village are exacerbated by a significant volume of through traffic (particularly on the Goudhurst and Brenchley Roads), heavy goods traffic,  extensive on-street parking, and lack of a central village car park, all ,of which can hinder the safe and smooth flow of traffic and add additional risk to vulnerable road users and pedestrians.
  • local infrastructure – including education, primary health care, community and cultural facilities, broadband speeds and mobile phone coverage – has a limited capacity and is not currently suitable to accommodate significant growth. Whilst we welcome the Local Plan’s “expectation” in draft policy STR/HO1 that developer contributions will be sought to upgrade facilities, and mitigate the impact of development, there is no guarantee that infrastructure will be provided in step with housing growth.

Our concerns are that developers will plead “lack of viability” to avoid financial contributions through section 106 agreements or that, if TWBC introduces a Community infrastructure Levy, funds raised through development in Horsmonden will not all be spent there. It is frequently the case that such developer contributions do not realise all the funds necessary to achieve timely infrastructure investment in step with development, and local authorities are usually in no position to make good any deficiencies.

  • impact on the local environment will be significant. We appreciate that the draft Local Plan contains a large number of planning policies intended to safeguard important aspects of the local environment ( policies EN1-32), but we remain concerned that some highly valued features of the local environment will be adversely affected by the proposed scale of development, in particular the local landscape, as was highlighted in TWBC’s own evidence base in  “Landscape Sensitivity of Additional Settlements in Tunbridge Wells” (July 2018).

The Local Plan sometimes has a tendency to see the landscape in a binary form (AONB= safeguard from development / other areas = negotiable). This puts parishes like Horsmonden, where parts are in the AONB and parts are on the edge of it, in a difficult position. The areas beyond the designated area contribute to the setting of the AONB and are, in themselves, attractive and locally valued landscape with a very distinctive character. The majority of the parish forms part of “The Fruit Belt” with its orchards, hop gardens, vineyards, shelter belts and twisting country lanes). TWBC’s background document (above) concludes that the Horsmonden landscape has a sensitivity of “High” or “Medium High/High” for even small-scale developments. All the proposed development allocations in Horsmonden involve loss of green field sites around the edge of the village.

[TWBC: see image taken from Borough Landscape Character Assessment].

They are by no means “small sites”, with two of the three proposed allocations delivering potentially 100 houses or more. These allocations are in addition to the 17 new houses currently under construction adjacent to Kirkin’s Close.

For all these reasons, we ask TWBC to look again at its development strategy and to reduce the scale of housing development proposed for Horsmonden.

DLP_3670

Capel Parish Council

Object

This policy does not include any reference to development on Brownfield sites but does refer to the release of Green Belt. There should be a strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites.

You repeatedly refer to the Eastern part of Capel parish as part of Paddock Wood when it is not, and unlike Paddock Wood is in the Green Belt. It has a completely different heritage and culture from Paddock Wood. Badsell Manor is the oldest continuously inhabited houses in the parish and its historic environs would be destroyed by this proposal.

DLP_1462

Mrs Wendy Coxeter

Object

The Draft Local Plan is indicating that TWBC prefers to meet its housing needs by the approval of large-scale developments in Wealden Towns and Villages. Why are you not prepared to consider the small scale developments first? Is it because the temptation of S106 Contributions are irresistible and small scale developments won’t attract such large contributions? The consequences of such developments for the AONB and the villages concerned are very real. You are selling the family silver and the damage will last forever. I understand from our Parish Council that depending upon which set of calculations are used the Housing Needs Allocation could be halved. TWBC have chosen to exceed the allocation requirements across the borough compounding the excessive allocations not just for Hawkhurst but other parishes across the borough. We also have concerns over the definition of windfall development which could lead to large scale sites being excluded from our Parish Allocation but being used by the TWBC to meet its own targets.

This Draft Local Plan will not be preserving the AONB that represents 70% of our borough. There will be no character or charm or countryside left in our borough. We will all become ‘copy and pasted’ versions of the developers’ little book of architecture.

Paragraph 4.36 suggests that there is agreement with the Parish Councils on development sites. Central Government led us down a path to develop our Neighbourhood Development Plan (at considerable expense in time and money). Now, armed with this document, the Parish Councils’ comments are being completely ignored. It’s as if you have forgotten you asked us to prepare this document and this layer of ‘consultation’ is now very inconvenient and very boring that we keep reminding you about it! This is TWBC’s NDP for Hawkhurst - you are voting against your own policy. Hawkhurst Parish Council have decided not to comment upon their preferred sites as they feel that this would compromise the planning process at a later date. The reason for not choosing preferred sites at the time of submitting the NDP was that the Parish was already delivering ahead of allocation.

4.2 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. TWBC have approved applications in the face of huge local opposition and in direct contravention of our Neighbourhood Development Plan. Our population, number of houses and properties has overwhelmed the capacity of services to cope. Hawkhurst has been playing a part in the allocations and suffered the consequences.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected. in Hawkhurst, we are constipated and we have indigestion. In targeting the larger sites you have not maximised the smaller sites before biting into the AONB. As I understand the NPPF gives TWBC the opportunity to reduce your allocation due to a high percentage of the borough being AONB. You have chosen to increase your allocation. The sites illustrated in your Draft Plan are not appropriate in scale for the AONB.

Paragraph 4.4- claims that the growth strategy is based upon the premise of infrastructure-led development. This is misleading as the Council has no control over the provision of infrastructure, services and facilities on the scale that we require to support developments of the size proposed.

A perfect illustration is the provision of sewerage services by Southern Water. Southern Water have admitted that the infrastructure is inadequate to support further housing development and recommended that no further development should be approved until the necessary improvements are made.

The fouling of waterways by Southern Water was entirely foreseeable to local residents. Improvements are not made when they should be made, if at all and residents suffer the consequences. The development plans for Heartenoak are already non-compliant and there is no provision for the Golf Course development at all. The development of Fieldways/Westfield will displace water down a steep valley and in the vicinity of historic buildings. On the south side of the village water courses are being changed by the landscaping and concreting of developments near the centre of the village.

The development strategy outlined from paragraph 4.41 onwards is flawed in two respects:

  1. It treats each proposed development in isolation from all the others and ignores the consequences for sustainability and infrastructure, of their combined effects. Developments in Cranbrook, Sissinghurst, Sandhurst and Hawkhurst impact on the infrastructure which you have not represented in your plan. We already have experience that traffic surveys conveniently do not factor in a half-finished development near us, swaying the count. We really need some reliable data based upon the Site Allocations in these Parishes and how they join to impact upon each other. For example 300 houses at Hartley on the south side of Cranbrook is bound to generate traffic into Hawkhurst. We hope that our Parish Council will challenge you to look at the Allocations in Rother and East Sussex and Ashford Borough Council to see what the overall impact from each direction might be.
  2. TWBC - have no control over the developments in neighbouring counties neither can they press neighbouring local authorities to address infrastructure needs that are generated by a TWBC decision.

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

TWBC cannot misunderstand the local opposition to this development and the destruction of the character of our village which this would cause. We have experience of TWBC pushing for approval of a large scale near us of 49 houses. We are aware of how undemocratic and oppressive TWBC and KCC Highways can be when they ‘decide’ on a plan. There is an opportunity with this consultation to listen to our community.

I have already stated that this and many other large scale developments are not compliant with our Neighbourhood Development Plan. We have no need for this quantity of housing or this type.

Lack of adequate infrastructure

Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. For many years there has been a requirement to merge the 2 doctors surgeries for reasons of economy and to attract doctors to rural practices with specialisms that would save patients traveling. This is obviously a desirable plan but burdening our village with 120 additional houses as suggested by the Fowlers Field plans is too heavy a price to pay.

Southern Water suggests that it would take 2 years for them to improve our sewerage system adequately. This has been discussed in Parliament.

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that the great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And, that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development.

The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment.

Existing facilities and services are scaled for the needs of a village; they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents.

There are limited local employment opportunities and no secondary schools within walking distance. Building on the Golf Course removes two of the very few local sports facilities and I suggest that a sports facility should have been included in the plans.

Our Parish Council make it clear that roadside air pollution is already breaching guidelines and that where traffic is static at the traffic lights there are health implications for residents even at first floor level.  They are making a request for better monitoring   and you should wait for reliable data before ignoring this factor.

There are few viable transport alternatives to the car which means Hawkhurst would not be an appropriate location for a development of this size. Public transport services are limited and expensive. They do not match with demand  for rail services at commute times and certainly do not adequately provide for young people to travel socially or for those on a limited income to access cheaper sources of food or better employment. Travelling East to West by bicycle would perhaps be fine (if you didn’t die in the process) but the topography is a deterrent for the developers idealistic view of us all popping to the shops on bicycles. Maybe in 20 years time electric bicycles will be so cheap that we can all afford them but for the moment this is not realistic.

As a community we feel that KCC Highways have provided incorrect data for traffic modelling and have relied heavily upon the traffic surveys of the developers. The traffic data for the Golf Course development included March readings during the ‘Beast from the East’ and ignores the seasonal variations of coast bound Camber traffic.

Traffic at a standstill does not add economically to our space paired as it is with inadequate central parking facilities. The relief road merely moves the issue down the road (quite literally) and shoppers will not use a car park so far from the centre. This road is being relied upon in the Sustainability Assessment but it is just a road that would have to be provided to service the properties and is substandard in terms of width and construction. It is a residential road and not fit to take the volume of heavy goods  vehicles that will use it. It will crumble. Upon the closure of the top end of Cranbrook  Road there is no allocation for a turning space further along if a vehicle should take a wrong turn. Only recently there was a well documented incident of a lorry trying to turn around at the top of Cranbrook Road at the junction with Peter Buswell’s office. There appears to be no plans for buses returning to the village centre via the relief road and Cranbrook Road residents will be marooned from the centre of the village by the closure of the Cranbrook Road at the top of the hill.

Kent Fire and Rescue have also commented upon the impact that this road closure would have on them.

This development is contrary to the NPPF which requires significant development should be focused on locations that are or can be made sustainable, by limiting the need to travel and offering a genuine choice of transport modes. Congestion, emissions and public health concerns over them will be raised by this development.

There is no environmental benefit to the proposed development. The removal of mature trees and habitats are of concern to the Woodland Trust who say that there is no wholly exceptional reason for the development as required by the NPPF.

The ‘relief road’ will not work.

The road would not provide the benefits which have been claimed. The adverse impact would extend beyond the boundaries of TWBC into Rother DC and beyond KCC into East Sussex CC. None of this seems to have been considered. The displacement of traffic across minor lanes is already a cause for concern in our village and Slip Mill, Delmonden, Whites, Water and Stream Lane all suffer damage, accidents and flooding due to poor management.

Unless Highways England have substantial plans for reclassification of the major haulage routes taking HGV’s down from Maidstone to the A21 and not via Cranbrook and Hawkhurst south the road does not provide relief. Major alterations are required to the junction with the A21 at Flimwell to enable HGV’s to turn left to travel south. There are fears otherwise that HGV’s would turn left out of the relief road and turn right at the crossroads in the centre of the village to travel south down Highgate Hill and join the A21 at Coopers Corner/Hurst Green. This is likely to make the crossroads in the centre of the village more congested and less safe for the pedestrians.

DLP_2509

Mr Guy Dagger

Object

I consider the scale and distribution of the allocation housing being imposed upon Hawkhurst and Cranbrook, within the AONB (2300 houses over 59 sites) as not consistent with its duty for protection as a national important landscape.

The designations lie within the High Weald AONB and paragraph 11 of the NPPF (footnote 6) suggests that AONB designation should constrain levels of housing provision. This is supported by Planning Practice Guidance (Paragraph: 041 Reference ID: 8-041-20190721) which makes it clear that development should be limited in AONBs, and that it may not be possible to meet ‘objectively assessed needs’ in these areas.

In the Distribution of Development Topic Paper (Para 3.11), TWBC accepts that strategic-scale urban extensions, would ‘almost certainly not be appropriate’ in the AONB under national policy, and that the statutory purpose of conserving and enhancing the AONB is ‘likely to limit its capacity to absorb new development’. However, in allocating housing numbers to the AONB, no distinction has been made between the proportion of housing allocated to the borough as a whole, and that allocated to two key AONB settlements – Cranbrook and Hawkhurst. The current district-wide allocation of 14776 represents approx. 13 houses/ 100 head of population. With less than two hundred dwellings in Hartley today and a proposal for over two hundred in the future it would be a far higher ratio in certain localities.

This is inconsistent with the local plan’s stated policy and with the NPPF.

In addition, these AONB settlements appear to be meeting need from elsewhere, most likely from outside of the AONB. Cranbrook and Sissinghurst Neighbourhood Plan assessed the local housing need of these settlements as 610, of which 250 are met by the allocation in the previous local plan at Brick Kiln Farm. This leaves a further 360 to be delivered across both settlements to meet local need.

The draft Local Plan allocates 918 to these settlements in Cranbrook. The difference between these two figures suggests need from the wider borough, and potentially nationally as other boroughs have scaled back their proposalis in AONBS (notably Sevenoaks), so with requirements for houses outside of the AONB, is being met in the AONB. This figure amounts to approximately the numbers allocated to the three largest ‘major’ sites which are likely to cause the most harm to the landscape and natural beauty of the AONB. These major allocations are not necessary and should be dropped. The allocations for Hawkhurst, Benenden and Matfield are similarly inflated above what is required to meet local need.

Even if the need to allocate development within the AONB has been demonstrated, it does not mean that such provision should be in the form of major development sites. The AONB Management Plan, adopted by Tunbridge Wells Borough Council in March 2019, explains that the High Weald is a small-scale landscape built by hand. The Plan commits authorities to ‘seek to deliver new housing primarily through small-scale developments that meet local need’ (Objective S2, page 34). Paragraph 172 of the NPPF says that ‘Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest’. The tests associated with this policy have not been properly considered and the exceptional circumstances have not been justified. Alternatives to the large allocations have not been properly considered – sites outside the AONB have been dismissed, and the option of reduced allocations on the larger sites offered in the SHELAA has not been properly examined.

The Glover Review of designated landscapes recognises the threats to AONBs, particularly in the South East, of excessive development, recommending a stronger role for AONBs in the planning system as a result. The Review highlights the damage done to AONBs through locating major development on its boundaries and within its setting. Planning Practice Guidance also highlights the need to take potential impacts on the AONB into account when considered development in its setting (Paragraph: 042 Reference ID: 8-042-20190721, revised 21 07 2019). Consideration of the new settlement at Capel and the proposed development at East End both on the boundary of the AONB have not involved proper consideration of impacts on the AONB, including the impact of cars, visitors and the impact of the loss of cultural associations with the AONB.

DLP_3049

Mr Adrian Cory

Object

Policy Number: STR 1

I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB.

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents.

I believe that the Council’s conclusion (for example, at Paragraph 4.34) that such sites are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper.

The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (vide: the Council’s behaviour over the Neighbourhood Development Plan – see above and below – and recent planning decisions taken in the face of legitimate local objections). Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. Paragraph 4.35, in claiming that the Council has encouraged the production of Neighbourhood Plans, surely evidences bad faith on the part of TWBC, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions.

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted.

The Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments.

Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. To the extent that this means anything it is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed.

This is exemplified in relation to the provision of sewage services by Southern Water, which was the subject of an adjournment debate in Parliament on 28 October (Hansard Vol. 667) in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place.

We may, therefore, assume, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. Furthermore, we can expect developers to play the old game of submitting amendments to plans, once approved, to dilute their commitments (and associated expense) and that the Council will, as usual, accede to their demands.

Later in paragraph 4.40, the Draft Local Plan refers to the need for “Sustainable development of an appropriate scale at the smaller settlements”. I argue below that the proposals relating to Hawkhurst ignore this principle.

The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:

1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan;

2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point.

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village.

The proposed development on the Hawkhurst Golf Club site would destroy the character of an important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development have simply not been properly considered in the Draft Local Plan.

There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development.

Non-compliance with Hawkhurst Neighbourhood Development Plan

The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan which provides that:

Larger developments of 10 or more houses will only be supported if it can be demonstrated that there are exceptional circumstances as prescribed by the NPPF and if it can be demonstrated that their impact on the sensitive landscape setting and the considerable environmental constraints of Hawkhurst can be effectively mitigated.

There are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment.

Lack of adequate infrastructure

Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament (see above).

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment.

Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents.

There are very limited local employment opportunities and no secondary schools within walking distance.

The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution.

The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it.

TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103).

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

There is no environmental benefit to the proposed development. It would involve the removal of many mature trees and damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF.

The “relief road” will not work

The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny.

As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes.

DLP_2540

Mr Graham Clark

Object

In my view the Plan fails to comply with paragraph 38 of the NPPF. This requires that that at least 10% of the housing need should be provided on sites of no larger than one hectare.

These small and medium sized sites make a very important contribution to meeting the overall housing requirement of an area and have the benefit of being built out relatively quickly.

Instead, the Plan is over reliant on a number of very large strategic allocations. There must be a question mark over the deliverability of some of these sites within the time frame of the Plan.

DLP_2716

St. John's Road Residents association

Support with conditions

Development Strategy

We believe that non-designated heritage buildings should be preserved with particular reference to Policy AL/RTW 2A and AL/RTW 6: the Civic Complex, Town Hall, Assembly Hall Theatre in the Town Centre in order to preserve the architectural integrity of the Civic Quarter.

1b  We support an enhanced town centre development of Royal Tunbridge Wells including a theatre, although not necessarily a new theatre where it is economically viable to refurbish and improve the present Assembly Hall Theatre as we feel that it does provide cultural amenity to the town appropriate to the catchment area and tastes of the audience.  It is flexible and is located within the Civic/Cultural Quarter alongside the new Amelia Scott Centre.  This provides the town with "a resilient and vibrant town centre to endure over the plan period.".

1c We agree with the development of a new business park giving much needed new employment space at North Farm/Kingstanding Way.

2. and 3. Whilst we support the garden village development in principal we think it is important to weigh the environmental factors as outlined in Section 4.3 and 4.7 with regard to development on Green Belt land and flood defences.

DLP_2870

Chris Gow

Object

Paragraph 1b and 1c

I object to statements contained in these paragraphs.

I contest and object to the need for the new theatre and associated development.

I contest and object to the need for wholesale provision of office space and retail space for the town centre, and I think the provision of housing would suit re-generation more in line with realistic economic predictions, and promote residential communities in the town centre.

I contest and object to prestigious new business park development in the North Farm retail park.

The loss of the motor sales franchise in the near future as the decline in the motor trade as the population realise the continued use of the motor vehicle is unsustainable in the face of global economics and especially the face of global energy consumption will leave vacant retail space.

The local Plan must contain a new radical way to examine our future, and must make commitments to a different priority for local community.

The A21, in spite of the dual carriage way improvements is a congested route, and adding to the burden of extra traffic movements is not responsible for the local community.

If you encourage new employment you have to supply further housing requirements, and the entry into an endless circle of supply and demand.

DLP_2871

Chris Gow

Object

Paragraph 2

The development of housing in flood plains is a policy that should be abandoned immediately.

The cost of flood defences is very high, and never completely secure against the risk. Climate change is a factor that should cause concern, and completely preclude any development on flood plains.

DLP_2872

Chris Gow

Object

Paragraph 7

The use of Green Belt should not be allowed under any circumstances.

DLP_3410
DLP_7364

High Weald AONB Unit
Andrew Ford

Object

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

We object to the scale and distribution of development, particularly within the AONB and its setting.

Levels of housing provision

NPPF paragraph 11 says that Councils should provide for objectively assessed needs for housing and other uses, as well as any unmet needs from neighbouring areas, unless “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”. The assets referred to are listed in footnote 6 and include Areas of Outstanding Natural Beauty (AONBs). The most relevant policy in the Framework for AONBs is paragraph 172, the first part of which states:

“Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads 54. The scale and extent of development within these designated areas should be limited”.

AONBs, along with National Parks and the Broads, have the highest status of protection in relation to landscape and scenic beauty. For National Parks “the Government recognises that the Parks are not suitable locations for unrestricted housing and does not therefore provide general housing targets for them. The expectation is that new housing will be focused on meeting affordable housing requirements, supporting local employment opportunities and key services”1 [English national parks and the broads: UK government vision and circular 2010 https://www.gov.uk/government/publications/english-national-parks-and-the-broads-uk-government-visionand-circular-2010]. This principle should apply equally to AONBs but, in the absence of a Circular for AONBs, this relies on paragraph 11 of the NPPF being applied robustly to ensure that the scale and extent of development proposed does not harm the purposes for which these areas were nationally designated.

Planning Practice Guidance (PPG), revised July 2019, states ‘The National Planning Policy Framework makes clear that the scale and extent of development in these areas should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty. Its policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’. Paragraph: 041 Reference ID: 8-041-20190721.

Seventy percent (70%) of Tunbridge Wells borough lies within the AONB, and it is our view that the extent of national protected landscape should constrain levels of housing provision in the borough. TWBC should carry out a transparent assessment demonstrating that in deciding the level of housing provision proposed, the type of homes and the distribution of those homes, great weight has been given to conserving and enhancing landscape and scenic beauty in the AONB; the conservation and enhancement of wildlife and heritage has been taken into account; and the scale and extent of development within the AONB has been limited. In our view TWBC has failed to limit the scale and extent of development proposed in the AONB, contrary to PPG. Whilst 70% of the borough is within the AONB it only accommodates about 20% of the population. The proposal is to allocate 2,339 dwellings within the AONB which is about 25% of the allocations. Given that projections of future needs are largely based on the existing population it would appear that, far from limiting the scale of development in the AONB, the Council is seeking to meet all of its housing need/demand within the AONB and some from outside of the designated area.

Major Development in the AONB

Even if the need to allocate development within the AONB has been demonstrated, it does not mean that such provision should be in the form of major development sites. The second part of paragraph 172 says “Planning permission should be refused for major development55 other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:

a) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;

b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and

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

Footnote 55 says: “For the purposes of paragraphs 172 and 173, whether a proposal is ‘major development’ is a matter for the decision maker, taking into account its nature, scale and setting, and whether it could have a significant adverse impact on the purposes for which the area has been designated or defined”.

Whilst this part of the paragraph specifically refers to planning permissions, it has also been considered relevant by Local Plan Inspectors to allocations within Local Plans 2 [ For instance, in the Vale of White Horse Local Plan Examination, the Inspector considered two proposed sites located within the North Wessex Downs AONB for 550 and 850 dwellings against the major development tests set out in paragraph 116 of the original NPPF (now incorporated into paragraph 172 of the revised NPPF). He concluded that the specific need for housing to be provided within the AONB had not been demonstrated and the sites were subsequently deleted.  (Vale of White Horse Local Plan 2031: Part 1 Inspector’s Report November 2016: http://www.whitehorsedc.gov.uk/sites/default/files/Vale%20of%20White%20Horse%20Local%20Plan%20203 1%20Part%201%20-%20Inspectors%20Report.pdf)  More recently the Inspector appointed to examine the Wealden Local Plan also considered it appropriate  to assess the approach to development against the exceptional circumstances and public interest tests set out in para 116 of the previous NPPF (Wealden Local plan Examination - Key Matters, Issues and Questions, April 2019) Matter 2, Issue 4 http://www.wealden.gov.uk/Wealden/Residents/Planning_and_Building_Control/Planning_Policy/Wealden_L ocal_Plan/Wealden_Local_Plan_Examination_Library.aspx]. Legal advice provided to the South Downs National Park Authority by Landmark Chambers also concluded that “it would arguably amount to an error of law to fail to consider paragraph 116 (now 172) at the site allocations stage of plan making for the National Park. The consequence of doing so would be to risk allocating land for major development that was undeliverable because it was incapable of meeting the major development test in the NPPF” 3 [10 October 2017 Toby Fisher, Landmark Chambers]. Tests a and b are indeed more appropriate to determine at plan-making stage when the needs for development are established and alternative options for provision fully considered. The scope for this to be done at planning application stage is much more restricted.

The starting point of this policy is that major development should only be permitted in an AONB “in exceptional circumstances, and where it can be demonstrated that the development is in the public interest”. This is a separate requirement to the tests below and is a very high bar.

When applied at Local Plan stage test a) should not assume that general housing needs must be met within the AONB or make unsubstantiated claims about the economic benefits of providing such housing. The assessment should be based on robust evidence that directly relates to the AONB and relevant settlements within it. This is supported by the findings of the Inspector for the West Oxfordshire Local Plan, who recommended deleting four allocations in the Burford – Charlbury sub-area, which forms part of the Cotswolds Area of Outstanding Natural Beauty (AONB) on the basis that there was no housing need figure for this specific sub-area and that “soundly-based decisions on the balance of the benefits and harms of further housing development in this area can only reasonably be reached based on the detailed evidence submitted as part of specific planning applications” 4 [https://www.westoxon.gov.uk/media/1887174/West-Oxfordshire-Report.pdf Issue 9 paragraphs 214-225].

Test b) should robustly explore all available options outside the AONB, and whether the need can be met in another way, such as on smaller sites. Test c) can be harder to apply at Local Plan stage when the details of the scheme are not known, but sites that are significantly constrained by environmental, landscape or recreational factors should be avoided.

In our view sites considered to be major development should not be allocated in the AONB.

The High Weald AONB Management Plan has been adopted by all the Councils with land in the AONB as their policy for the management of the area and for the carrying out of their functions in relation to it. The Management Plan defines the natural beauty of the AONB in its Statement of Significance and identifies the key landscape components of the High Weald. The Management Plan then sets objectives for these components and identifies actions that could conserve and enhance the AONB.

Settlement is one of these landscape components and the objectives for this component are:

* Objective S1: To reconnect settlements, residents and their supporting economic activity with the surrounding countryside;

* Objective S2: To protect the historic pattern and character of settlement; and

* Objective S3: To enhance the architectural quality of the High Weald and ensure development reflects the character of the High Weald in its scale, layout and design.

One of the actions for objective S2 is to “Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs”.

The Management Plan describes the High Weald as “an area of ancient countryside and one of the best surviving Medieval landscapes in Northern Europe. At first glance the High Weald appears to be a densely wooded landscape but closer examination reveals a detailed agricultural tapestry of fields, small woodlands and farmsteads. Everything in the High Weald landscape is human scale”(p8). The High Weald is characterised by irregular shaped fields and woodlands accommodating dispersed development of farmsteads, hamlets, trading villages and the small town of Battle. Small scale carefully designed development can be accommodated successfully in this landscape whilst retaining this character, but large scale developments are much more challenging to integrate successfully without detrimental effects.

The cumulative impact of such major allocations, and indeed of many smaller allocations, is also potentially significant. The impact will include the cumulative impact on the landscape, increased visitor numbers, traffic and air quality implications and the impact of all of these on the sense of naturalness, remoteness, tranquillity and dark skies which are highlighted in the Management Plan as perceptual qualities that people value.

In our view major development cannot be accommodated within the AONB without damaging the purposes of the designation.

Setting of the High Weald AONB

Another consequence of the higher housing numbers being proposed in this Local Plan is the significant increase in the amount of development being proposed in areas outside of, but close to, the boundary of the AONB. This includes significantly expanding Paddock Wood by 4,000 homes and associated facilities, and promoting a new settlement of 2,500-2,800 homes at Capel (branded as ‘Tudeley Village’). This development would include the provision of an offline A228 strategic link and a new secondary school west of Tudeley. The new settlement and school directly abut the AONB boundary and, whilst the alignment of the strategic link has yet to be determined, the current A228 runs through the AONB. The land north of the AONB boundary is low lying, forming the environs of the River Medway, with the High Weald rising steeply above it, meaning that there are significant long views across this area, particularly from Capel Church.

The Section 85 ‘duty of regard’ requires all relevant authorities to have regard to the purpose of AONBs when coming to decisions or carrying out their activities relating to, or affecting land within these areas. The PPG says of AONBs “Land within the setting of these areas often makes an important contribution to maintaining their natural beauty, and where poorly located or designed development can do significant harm. This is especially the case where long views from or to the designated landscape are identified as important, or where the landscape character of land within and adjoining the designated area is complementary. Development within the settings of these areas will therefore need sensitive handling that takes these potential impacts into account” (Paragraph: 042 Reference ID: 8-042-20190721, revised 21 07 2019).

Impacts will not just be confined to the visual or physical effects such as on habitats or watercourses connecting the AONB with its surroundings, but will also add to the visitor numbers using the AONB and the traffic travelling through it, affecting the sense of naturalness, remoteness, tranquillity and dark skies.

In our view the development of a new large village (‘Tudeley village’) of up to 2800 dwellings at Capel together with the secondary school and proposed strategic link road bordering or within the AONB and the addition of 4,000 homes around Paddock Wood close to the AONB will have a significant effect on the purposes of AONB designation. This issue has not been properly considered by the Plan or its supporting documents.

DLP_1960

Mr Jeremy Waters

Object

I object to the proposal for dispersed growth across rural villages and settlements in the Borough. Horsmonden in particular has fared much worse than other local settlements in this area such as Goudhurst, Lamberhurst and Brenchley, presumably purely the reason that it is mostly outside the AONB and a large acreage of farm land was submitted in the Call for Sites. The Local Plan allocates growth of approximately 28% which is far in excess of historic organic growth levels and would substantially add to traffic levels, infrastructure and quality of life for village populations, thereby destroying the amenity value for everyone.

The 2017 "Issues and Options" consultation offered five alternatives, however the most appropriate one of development along the A21 corridor (Option 4: Growth corridor led approach) seems to have been dropped from the draft Local Plan in favour of spreading housing growth across all rural areas. This will have the effect of spoiling a much larger area of rural Green Belt land, considerably adding to traffic loads on inadequate rural lanes and potentially destroying the very essence of the Wealden landscape and character, thereby going against the TWBC's own study into landscape sensitivity. 

I believe that the draft overall strategy is patently unsustainable, even by TWBC's own evidence base.

DLP_2985

Mr Keith Lagden

Object

The Draft Local Plan reveals that TWBC prefers to meet its assessed housing needs primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. It is clear that little real consideration is given to the consequences of such developments for the towns and villages concerned nor for the AONB.

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). I would add that 100% of Hawkhurst lies within the AONB!

I believe that the Council’s conclusion (for example, at Paragraph 4.34) that such sites are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper.

The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections).

Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. I repeat that the Hawkhurst NDP has been “made” and therefore must be taken into account when developing the Local Plan.

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted.

The Neighbourhood Development Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments.

Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed.

For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place.

It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them.

The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:

1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the Draft Plan;

2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point.

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

The proposed development on the Hawkhurst Golf Club site would destroy the character of an important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development have simply not been properly considered in the Draft Local Plan.

There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Placards saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development.

Non-compliance with Hawkhurst Neighbourhood Development Plan

As mentioned above the proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment. I would repeat Hawkhurst is a village and not an urban area.

Lack of adequate infrastructure

Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament.

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues, and that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment.

Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents.

There are very limited local employment opportunities and no secondary schools within walking distance.

The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution.

The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it.

TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103).

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

There is no environmental benefit to the proposed development. It would involve the removal of many mature trees and damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF.

The “relief road” will not work

The so-called “relief road” would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area.

As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes.

I would further add that on 24/1019 Mr James Finch Assistant Director - Corporate Services Kent Fire & Rescue Service wrote on the TWBC planning portal regarding his serious concerns for his organisations ability to provide fire and rescue services to the area around Hawkhurst should the Golf Course proposal be granted. When are TWBC planners going to realise what is glaringly obvious to all but themselves that Hawkhurst cannot entertain the numbers of houses being put forward in this ill thought out Draft Local Plan.

DLP_2009

Dr David Parrish

Object

Policy STR 1 (The Development Strategy) p.42

Existing, idle, Brown Field Sites are not being compulsorily purchased as a priority - neither Empty Properties too

This policy does not include any reference to development on Brownfield sites, but does refer to the release of Green Belt.

There is no strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites.

DLP_2785

Mrs Karen Langston

Object

The Development Strategy for the delivery of the Local Plan adopts a combination of growth strategies proposed in the Issues and Options document. Prominent in this mix is proportional distribution of growth across all existing settlements (growth strategy 3). This is despite the fact that the consultation recorded a less positive response to this than the other strategies. Also in the mix is growth within a new, free-standing settlement (growth strategy 5). However, the feedback in the Issues and Options consultation, which recorded a slight preference for growth strategy 5, specified that the new settlement should not be in the Metropolitan Green Belt or the AONB. The ‘Distribution of Development Topic Paper’ presents the justification for the proposed Development Strategy, including how the Issues and Options consultation informed the Strategy. However, the outcome is at odds with the feedback and, in several instances, goes directly against the views expressed. The views of the community, particularly when expressed through formal public consultation, should be fairly considered and fully taken into account. The proposed development strategy does not reflect the feedback in the Issues and Options consultation and is highly likely to lack community support.

I strongly oppose the proposed approach of dispersed growth across the Borough. It is inconsistent with the NPPF, which advocates focusing development in the most sustainable locations, allocating land with the least amenity value and conserving and enhancing the AONB, where the scale and extent of development within such designated areas should be limited (NPPF paragraphs 171 and 172). It is also contrary to the Council’s previous Local Plan and Core Strategy, which focussed growth in towns, recognising that villages and rural settlements are the least sustainable locations for development.

Dispersed growth with proportional development distribution is not consistent with the three objectives of sustainable development, as required by the NPPF (paragraph 8). Matfield is one of the least sustainable settlements in the Borough. It lacks the services and amenities to support significant growth (up to 37.5% in the number of dwellings). There is no evidence of scope for the village to become more sustainable as a result of growth, despite the Council’s untested hope in that it may. (Distribution of Development Topic Paper, paragraph 2.8) Development of this scale in settlements with low sustainability is contrary to the NPPF (paragraphs 7 and 8) and is not in the public interest.

DLP_1955

Ms Jacqueline Stanton

Object

Policy STR1 - this policy has chosen a plan which directs development to dispersed growth which is unsustainable because rural settlements cannot support this due to inadequate local infrastructures, lack of jobs and little or no access to public transport.  Local roads are not adequate for the volume additional development would create and the vnumber of cars required for these settlements without adequate public transport would make this unsustainable.

The settlement hierarchy is also contradicted by this strategy because it shows rural settlement as less appropriate than main and rural towns for the planned volume of growth.

DLP_1714

Peter Hay

Object

The Draft Local Plan reveals that TWBC prefers to meet its assessed housing needs primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. However, little real consideration is given to the consequences of such developments for the towns and villages concerned and for the AONB.

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough).

I believe that the Council’s conclusion (for example, at Paragraph 4.34) that such sites are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper.

The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its Policy Number: STR 1.

The Draft Local Plan reveals that TWBC prefers to meet its assessed housing needs primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. However, little real consideration is given to the consequences of such developments for the towns and villages concerned and for the AONB.

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough).

The entirety of Hawkhurst parish is within the AONB. This means that all sites in Hawkhurst are within the AONB. STR /HA1 includes a worrying mistake from the TWBC LP team who consider that some sites may not be in the AONB and reveals a deeper problem with the way TWBC consider the parish as suitable for large scale development.

I believe that the Council’s conclusion (for example, at Paragraph 4.34) that such sites are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper.

The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and the lack of recognition of the updated NDP for Hawkhurst March 2019 and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions.

The lack of conformity with, and recognition afforded by the TWBC draft Local Plan for the made TWBC Neighbourhood Development Plan for Hawkhurst (NDP) and the lack of any coordinated support through the TWBC draft Local Plan for the neighbourhood planning process as a means of delivering the aims and aspirations of the TWBC draft Local Plan on the ground.

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments.

Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed.

For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and the Home Office Minister recommended that no further developments should be approved until the necessary infrastructure is in place.

It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them.

The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:

  1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan;

It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point.

DLP_2931

Garry Pethurst

Object

Policy STR1

If most economic development is proposed for the west of the borough and a disproportionate amount of residential development is proposed for the east of the borough, there will inevitably be greater traffic movement but no mention of improved public transport for either Hawkhurst or Cranbrook. There is only a limited increase in economic development proposed for Cranbrook - where does TWBC expect the increased population will work? Is there a strategy for retail development?

DLP_1591

Maggie Fenton

Object

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 increased 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.

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 is clear in the NPPF that housing need alone DOES NOT constitute exceptional circumstances.

You have chosen to accept the government’s housing need for Tunbridge Wells borough based on the standard method of calculation.

The ONS 2016 figures show a smaller housing need and that policy will be reflected in due course and yet you persist on using outdated statistics. 

You know that you can protect this 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. 

Section 4 Paragraph 4.27 p.38

This states that proposed infrastructure is to be delivered alongside development. Given that 63% of your planned development is totally dependant on the building of the Colts Hill Strategic Link (which hasn’t happened in the past 40 years!) makes this a Daft Local Plan & not a draft one. Without the bypass, the so-called Five Oak Green bypass cannot be built and the B2017 will be completely gridlocked. This of course also applies to the flood risk “betterment”, water (both waste & potable), utilities etc. If this plan is approved the infrastructure MUST be provide BEFORE a single new dwelling is constructed.

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

The Local Plan is almost entirely dependent on the successful implementation of 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. The plan is therefore unsustainable and unsound.

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 clear 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. 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 that will dwarf Tunbridge Wells town centre and turn a grubby, dreary, semi-derelict TW Town Centre in to a ghost town (it’s almost there already) with a Disney style playground for the Hadlow Estate. You have used NDAs to hide your plans until it was too late for residents to have a fair say. Hadlow Estate have offered one letter to residents and a range of evictions to raise funds to pay their masterplanning consultants as their form of “community engagement”.  The needs of existing residents have not been met nor apparently considered. The developments in Tudeley and East Capel are unsustainable and do nothing for local employment needs (it will make many local farm workers redundant).

DLP_1613

Maggie Fenton

Object

Strategic Objective 1 P.42

At the heart of all dev in the borough will be the timely delivery of 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.

YOU CANT USE THE WORD “WILL” & THEN USE THE CAVEAT “WHEREVER POSSIBLE”. HOW IS IT POSSIBLE TO USE THE TERM MITIGATION TO DESCRIBE HUGE INCREASES IN TRAFFIC, NEW ROADS, NOISE & OTHER POLLUTION, LOSS OF OUR BEAUTIFUL COUNTRYSIDE, CPO’S, PRESSURE ON UTILITIES, EDUCATION & HEALTH SERVICES? ANY NEW FACILITIES WILL BE WITHIN THE NEW DEVELOPMENTS. THERE IS NO CONSIDERATION AT ALL FOR EXISTING RESIDENTS. EXACTLY HOW IS THIS “BETTERMENT?” 

This policy does not include any reference to development on Brownfield sites, but does refer to the release of Green Belt.

You should have a strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites. TWBC does not encourage the registration of brownfield sites. Why not? Because its easier to deal with single large landowners. The excuse that piecemeal development does not provide the necessary infrastructure is weak.

Section 4 Paragraph 4.49 (The Green Belt) p.49

Exceptional Circumstances do not exist to justify releasing any land from the Green Belt in Tudeley and East Capel.

Options for the expansion of Paddock Wood need not include East Capel. One option not taken by TWBC was expansion to the EAST of Paddock Wood …this land is not constrained by MGB. WHY was it not taken forward to feasibility?

The release of Green Belt for Tudeley New Town is totally unjustifiable. The 1,900 houses delivered there in this plan period are either not required by TWBC (who can easily reduce their plan to provide 13,560 rather than 14,776 new houses) or can be provided elsewhere outside of the Green Belt and AONB (for example at Horsmonden and Frittenden). Innovative use of Brownfield sites may also provide the housing that TWBC would like to provide by punching a massive, 400 acre hole in the Green Belt.

DLP_3553
DLP_7630

Lynne Bancroft
Mr J Boxall

Support with conditions

TWBC: the standard response was submitted by the list of responders on the left:
The facilities to be provided for Tunbridge Wells far exceed the facilities provided to small villages in the eastern part of the Borough which TWBC are proposing should take on proportionately far greater housing numbers than Tunbridge Wells. The housing numbers in Cranbrook and Sissinghurst, should be reduced due to the lack of additional facilities and poor transport infrastructure, both public transport and road system, especially with congestion on the A21 between Lamberhurst and Blue Boys at key travel times for work.

The housing need numbers in Cranbrook and Sissinghurst which have been assessed by the Cranbrook and Sissinghurst Parish Council are lower than the housing numbers included in the Local Plan by TWBC for this parish. The number of houses to be developed in Sissinghurst should therefore be reduced as this development is unsustainable with inadequate facilities, poor public transport and connectivity to key employment areas and no employment opportunities in the village.

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.

Sissinghurst’s proposed numbers of housing developments outweighs the size of the village and is unsustainable development. Development can only be sustainable if it is done close to existing urban sites due to lack of employment, transport and the destruction of the rural nature of the villages.

If housing is to be developed on a dispersed growth basis then employment opportunities through the economic growth strategy should also be on a dispersed growth basis to match increases in population and to minimise additional journeys, via public transport or car.

TWBC should not put such large quantities of housing in Sissinghurst and Cranbrook without additional economic opportunities and should have a policy to provide additional business sites, other than those already shown in the Local Plan, in The Weald.

DLP_2030

Terry Everest

Object

1a is ok

1b is ok but not on the site currently proposed, other sites are available nearby such as the old cinema site.

1c is not ok, expansion at North Farm has been rampant and uncontrolled (seemingly) in recent years and the infrastructure has lagged behind by over a decade. The case for a large new business park on land which should be retained as a buffer between the town and the A21 is not as strong as supposed. Hundreds if not thousands of square feet of business space lies unused in and around the town. The land proposed contains multiple ponds, trees and scrub habitats which should be left alone as vital habitats and an environmental buffer for the enlarged A21.

2 needs severe reduction in the housing numbers to make it sustainable and balanced. To triple the size of a town should be unthinkable really, and to massivley develop around a tiny hamlet or village is totally unnacceptable.

3 is totally unacceptable and needs removing from the proposal

4 needs reduction by between 50 and 75% to achieve a more balanced and sustainable development

5 needs reduction by between 60 and 75% to achieve a more balanced and sypathetic development considering how many historic buildings exist in Cranbrook and its special character

6 is ok

7 is unnaceptable, Green Belt is precious and needs protection, if subsequent plans used Green Belt at the same rate as this one it would all be developed and gone by 2360 - which is not that long in the scheme of things. This should not happen.

8 should not be needed if my other recommendations are followed

DLP_1775

CPRE Kent

Object

STR1 sets out the Council’s development strategy.  In accordance with paragraph 21 of the NPPF there should be a clear distinction between strategic and non-strategic policies. Table 3 lists the scale and distribution of development (by parish/settlement). For clarity it is considered that the strategic allocations should be identified separately.

Furthermore, it would be helpful to understand the distribution of development in terms of its relationship to the Council’s settlement hierarchy for confirmation that development is being planned in the most sustainable locations across the borough – in accordance with policy STR2. In terms of the development strategy the Settlement Role and Function Study (February 2017) hasn’t assessed the need for new development at settlements to support or enhance existing facilities.  Going through such an exercise would help inform whether the proposed strategy for growth is the most appropriate in terms of keeping existing settlements alive. As such, it is considered that it hasn’t been clearly demonstrated that the balance of growth between the main urban areas of Tunbridge Wells and Southborough; Paddock Wood, Cranbrook, Hawkhurst, Rusthall and Pembury; and the smaller villages is appropriate.

A development strategy based on options 3 and 5 for housing (dispersed and new settlement) does not sit well with the stated strategy for employment being based on options 1, 2 and 4 (focussed growth, semi-dispersed and growth corridor). This means that the spatial distribution of future housing and employment needs are not matched – which will result in unsustainable patterns of development as movement takes place between home and work.

Of the 7,593 dwellings to be allocated in the plan 1,900 are to be delivered within the plan period at Tudeley Village (better described as a new town than a “village”, given that it is planned to grow up to [2,800] homes and support a population comparable to that of Cranbrook) and 4,000 at Paddock Wood. Relying on two sites to yield 49% of the borough’s housing requirement (after completions, existing permissions, outstanding allocations and windfalls have been taken into account) places a lot of pressure on delivering these sites.  Lead-in time for large sites are long, compared to small and medium sized sites.  As such the Council’s development strategy should be reviewed.

It is difficult to understand how the Council’s stated aims of optimising density (to minimise loss of green belt) has been applied across the proposed allocations. Will schemes be built out at low, medium or high density in the interests of minimising green belt release?

In addition to the yield ranges listed in table 3 (scale and distribution of development) these figures have been averaged. Has this average been used to calculate the contribution of allocations towards the Council’s housing requirement? If so, then this figure should be used as an indication of the likely yield. It would be clearer if yields were identified as a minimum dwelling figure.

Paragraph 3.29 of the Council’s SHELAA explains that housing yield has been calculated on developable site area using a standard yield of 30dpa.  It goes on to say that “a more refined density calculation will be used at a later stage in plan making to inform site allocation policies”. This is lower than the density usually associated with suburban development (40dph) – there appears to be no explanation of what this more refined density calculation is with regard to individual allocations.

With 5.35% of green belt in the borough being released for development, CPRE Kent is concerned that the Council does not intend to designate additional land as replacement green belt – and seeks clarification as to why this is. Assurances are also sought as to how compensatory improvements to environmental quality and accessibility of the remaining green belt will actually be delivered (policy STR4).

In actual fact this 5.35% figure is not a true reflection of the amount of green belt that will be built on. Several sites are allocated for development but, according to the Distribution of Development topic paper, are not to be released from the green belt – for example: AL/PE6 (land at Tunbridge Wells hospital); AL/RTW13 (Colebrook House); AL/CA2 (secondary school Capel/Tonbridge); AL/SO3 (Mabledon/Nightingale) and AL/SO4 (hotel at Mabledon House). Nor does it include green belt to be taken by the A228 Colts Hill bypass or the new road from Tonbridge to the A228 via Tudeley.

Exceptional circumstances

The Council has set out in its evidence base the exceptional circumstances for releasing 5.35% of its green belt (see paragraph 6.48 of Distribution of Development Topic Paper), which can be summarised as follows:

  • Heavily constrained borough – green belt/AONB
  • Growth in sustainable parts of the borough will impact on green belt
  • Development requirements are higher than previous local plans – housing requirement is more than double that required in the 2010 Core Strategy
  • Without release of green belt identified development need cannot be met – including employment uses and delivering a secondary school (in fact, under this draft plan two major new secondary schools are proposed within the green belt but for reasons which are not adequately explained only one of them, at Ramslye/Spratsbrook, is proposed to be released from the green belt)
  • All reasonable options to deliver development have been fully examined – development within existing built up areas, optimised densities, brownfield sites within built up areas,
  • SHELAA and SA have identified all suitable sites outside the green belt (and for major sites outside the AONB).

The fallacy in accepting such matters as constituting ‘exceptional circumstances’ is they have the consequence that, the greater the proportion of a district that comprises protected areas, the weaker their protection under the planning system. The correct conclusion under the NPPF, properly construed, is that the greater the proportion of a district that consists of protected areas, the less scope there is for development in that district.

Tests of ’exceptional circumstances‘, whether in relation to the designation of green belt, or major development in the AONB, should be used only in relation to very specific circumstances affecting a particular development on a particular site, not general issues relating to the district or region as a whole. CPRE Kent considers that there are good reasons why the Tunbridge Wells Local Plan should not meet its housing requirement in full - reflecting the fact that 70% of the borough is designated AONB (and 22% is green belt). Furthermore, if for instance, the proposed secondary school at Tudeley was provided at the proposed Tudeley Village and/or Paddock Wood this would perhaps reduce the amount of green belt land to be developed as well as locating the new school closer to the new development and hence being more sustainably.

Moreover CPRE Kent remains to be convinced that the Council has placed sufficient emphasis on increasing density within the towns or on insisting on high density development on green field sites. The result is that far too much AONB and Green Belt countryside is allocated for development.

AONB

With regard to the AONB, paragraph 172 of the NPPF states:

“Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest”.

Planning Practice Guidance, July 2019, states:

“The National Planning Policy Framework makes clear that the scale and extent of development in these areas should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty. Its policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas. [CPRE Kent emphasis]

Paragraph: 041 Reference ID: 8-041-20190721.

AONBs together with National Parks have the highest status of protection in relation to landscape and scenic beauty.  For National Parks “the Government recognises that the Parks are not suitable locations for unrestricted housing and does not therefore provide general housing targets for them. The expectation is that new housing will be focused on meeting affordable housing requirements, supporting local employment opportunities and key services”[1].

This principle equally applies to AONBs - through paragraph 11(b)(ii) of the NPPF – which seeks to ensure that the scale and extent of development proposed does not harm the purposes for which these areas were nationally designated.

On this point the Glover Review (Landscapes Review 2019) sets out how important it is that the “needs and requirements of the local community will be met within the broader context of achieving sustainable development appropriate to these nationally important landscapes” and how  AONBs “should not be the place for major intrusive development” (pages 62/63). Building homes in the AONB isn’t ruled out completely, with the report acknowledging that “we need more homes in the countryside, including in national landscapes, but in small numbers, built beautifully and made affordable” (page 105).

Dark Skies

The rural areas of the borough, including within the High Weald AONB benefit from dark skies [https://www.nightblight.cpre.org.uk/maps/]. Paragraph 180(c) of the NPPF requires plans to limit the impact of light pollution from artificial light on local amenity, intrinsically dark landscapes and nature conservation.

Sustainability and climate change

The NPPF sets out at paragraph 7 that “the purpose of the planning system is to contribute to the achievement of sustainable development.  At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without comprising the ability of future generations to meet their own needs.”

Footnote 4 to this paragraph refers to Resolution 42/187 of the United Nations General Assembly.

This is often referred to as the Brundtland Report of 1987.  Whilst it was intended as a response to the conflict between the nascent order promoting globalized economic growth and the accelerating ecological degradation occurring on a global scale it can also relate to climate change.

Paragraph 9 continues:

“So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development (paragraph 11).”

Whilst 11(b) states:

“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 areas5, unless:

  1. 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 area6, or
  2. Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”

Where footnote 5 states “As established through statements of common ground (see paragraph 27)’ and footnote 6 ‘The policies referred to are those in this Framework (rather than those in development plans) relating to: habitats sites (and those sites listed in paragraph 176) and /or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty: …; irreplaceable habitats; designated heritage assets (and other heritage assets of archaeological interest referred to in footnote 63); and areas at risk of flooding or coastal change.”

The NPPF at paragraph 149 requires plans to take a proactive approach to mitigation and adapting to climate change.

On 12 June 2019 the Prime Minister announced that the UK will eradicate its net contribution to climate change by 2050. A statutory instrument was laid in Parliament which amended the net UK carbon account target from 80% to 100%[2].

The foreword to the recent Committee on Climate Change (July 2019) points out tougher targets do not in themselves reduce emissions – new plans must be drawn up to deliver them, that climate change will continue to warm in the short-term, and sea level will continue to rise and that we must plan for this reality[3].

The recent House of Commons Science and Technology Committee report[4] in its conclusions and recommendations encourages the Government “to develop and act on policies to ensure that the UK is on track to meet a 2050 net-zero emissions target” and that “it must seek to achieve this through, wherever possible, domestic emissions reduction.”[5] With regard to decarbonising transport the Committee state The Government’s current long-term for decarbonising transport focus heavily on reducing exhaust emissions and increasing sales of low-emissions vehicles, rather than delivering a low-emissions transport system.  In the long-term, widespread personal vehicle ownership does notappear to be compatible with significant decarbonisation.  The Government should not aim to achieve emission reductions simply by replacing existing vehicles with lower-emission vehicles.”  And continues “it must develop a strategy to stimulate a low-emissions transport system, with the metrics and targets to match.  This should aim to reduce the number of vehicles required, for example by: promoting and improving public transport; reducing its cost relative to private transport; encouraging vehicle usership in place of ownership; and encouraging and supporting increased levels of walking and cycling.”[6] [CPRE Kent emphasis].

Siting new development in locations well supported by, or that will support, sustainable transport will help achieve this.  This local plan should promote development in locations well served by regular public transport services and social and community facilities, that are in safe walking and cycling distance or would support, or result in, sustainable settlement.  Such routes need to feel safe, be well lit, especially for children and women who have to use them after dark - otherwise cars will be the preferred mode of transport.

With regard to the Council’s development strategy it appears that it is primarily roads-led, with development securing provision of the Colts Hill bypass, new roads at Tudeley Village and the Hawkhurst relief road, rather than genuinely seeking to achieve sustainable development and less reliance on the private car.

Housing delivery

The Council’s OAN is 13,560 of which 1,552 have been completed, leaving the need for 12,008 to be provided.  Some of this will be in the form of existing permissions, outstanding site allocations and windfall allowance.  The remaining 7,593 will be from new allocations of which 1,900 will be at Tudeley and 4,000 at Paddock Wood.  These two sites will provide 49% of outstanding new housing.

The Housing Supply and Trajectory Topic Paper for Draft Local Plan (September 2019) at paragraphs 4.5.2 and 4.5.3 states that the Council will further engage with developers to review past and future progress of housing delivery; and will ask developers to comment presumptions about lead-in times and delivery rates.  This indicates that the present housing trajectory is draft. It may well change, and with reliance on just two sites for almost half of the borough’s housing requirement, may not deliver at the anticipated rates.

With regard to build-out rates the Trajectory Topic Paper sets out at paragraph 4.13.4 that national studies for urban extensions in the south of England demonstrate that delivery rates have been in excess of 120 units per annum.  It is not clear which studies are being referred to or when they were published, nor the location and scale of the urban extensions.  Paragraph 4.13.5, again referring to national studies, states that sites will exhibit lower completions in their first and second years before construction on the site becomes established.  At paragraph 4.13.9 gives a build-out rate of 128 for developments of size 1000-2000, and 299 for developments of 2,000+.

Table 9 of the Trajectory Topic Paper at page 27 assumes that build-out for Tudeley will commence 2025/2026 and for the periods 2025/2026 to 2029/30 be 150 dwellings per annum and then rise to 200 dwellings per annum to the end of the plan period delivering 1,750 dwellings.

On page 30 the assumptions for the 4,000 dwellings at Paddock Wood is that 333 dwellings will be delivered from 2024/25 delivering all 4,000 dwellings by the end of the plan period.

CPRE Kent questions these trajectories for the following reasons:

  • they do not make allowance for lower completions in the first two years as set out in paragraph 4.13.5; and
  • the Tudeley development is a new settlement and not an urban extension and build-out rates may take longer before they reach the assumed 150 dwellings per annum.

With regard to windfalls Table 10 of the Trajectory Topic Paper [Windfall (Sites of 1-9 Units) Completions (2006-2019) Including Negative Delivery] and paragraphs 5.6.4 and 5.6.6 show that the net average annual windfall was 132 dwellings.  Paragraph 5.6.4 goes on to explain that 132 dwellings per annum is unlikely to be sustained over the whole Plan period, as opportunities within LBDs are finite and many of the more achievable infills, redevelopments and conversions have been undertaken.  For this reason paragraph 5.6.6 considers that 50 per annum is justifiable.  Beyond this statement no evidence is provided to support the assumed of 50 per annum.  Hard evidence is required.

Table 9 of the Trajectory Topic Paper assumes that Tudeley will start to deliver 2025/26 this is likely to require groundworks in 2024/25. This implies three years from Local Plan adoption to first build out.  It assumes that Paddock Wood will start to deliver 2024/25 and again this is likely to require groundworks in 2023/24. CPRE Kent queries whether there is sufficient time to prepare and agree a masterplan and outline application.

[1] English national parks and the broads: UK government vision and circular 2010 https://www.gov.uk/government/publications/english-national-parks-and-the-broads-uk-government-vision-and-circular-2010

[2] The Climate Change Act 2008 (2050 Target Amendment) Order 2019: 2.—(1) Section 1 of the Climate Change Act 2008

[3] Committee on Climate Change 2019 Progress Report to Parliament July 2019

[4] House of Commons Science and Technology Committee 20th Report – Clean Growth: Technologies for meeting the UK’s emissions reduction targets. https://publications.parliament.uk/pa/cm201719/cmselect/cmsctech/1454/145402.htm

[5] Ibid Conclusions and recommendations paragraph 3

[6] Ibid Conclusions and recommendations paragraph 31

DLP_1369

Mr and Mrs Leach

Object

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.

2. Policy STR 1 - The Development Strategy

We do not believe that the development strategy, including the massive expansion of villages within Capel parish, is justified, in our opinion, and we specifically object to Paragraphs 3, 7 and 8 of this Policy. We also object to the proposed garden settlement in Paragraph 2.

Our concerns and comments are further outlined, as follows:

2.1 With regard to Paragraph 35 of the NPPF (2019), another of the criteria that Local Plans are assessed against is whether it is justified, as stated below.

Justified - an appropriate strategy, taking into account reasonable alternatives, and based on proportionate evidence.

2.2 With references to Figure 4 Key Diagram, in the Draft Local Plan, it shows the massively enlarged Tudeley Village extending over land presently designated as Green Belt and as part of the High Weald Area of Outstanding Natural Beauty (AONB). Whereas, other northern areas of the Borough, further east, are outside both the Green Belt and the AONB have relatively very little development proposed.

2.3 The justification for allocating a quarter of the Borough's allocation, for this Plan period, at an enlarged Tudeley village is questionable and appears unsound in our opinion. Since other compatible villages outside the AONB and Green Belt, only have small portion of new the housing, for instance Horsmonden only has c.2% of the allocation.

2.4 We cannot see how there is a justification for building on the Green Belt, when alternative suitable sites were put forward earlier in the process. Also, this Policy is not consistent with National planning policy that seeks to protect established Green Belts. For instance, Paragraph 136 of the NPPF (2019) states:

Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, ... Green Belt boundaries ... [should] ... endure beyond the plan period.

2.5 Due to there being other suitable sites, within the Borough that can be developed outside the Green Belt; these sites should be taken forward before releasing the Green Belt land and currently as such, it is unlikely that exceptional circumstances exist.

2.6 In addition, it is not clear whether the proposed Green Belt encroachment and the Sustainability Appraisal3 reflect the larger post-Plan (even more unsustainable) Tudeley settlement, with the possible coalescence of villages/towns, as noted in 1.11di. If not, this would be at odds with the NPPF (2019), i.e. Paragraphs 134 and 136. The former lists the Green Belt purposes that this LP might be inconsistent with, including:

  • to check the unrestricted sprawl of large built-up areas;
  • to prevent neighbouring towns merging into one another;
  • to assist in safeguarding the countryside from encroachment;
  • to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

Although, a Sustainability Appraisal3 has been prepared, as part of the process, we do not agree with the specific scoring/conclusions that support this Policy and the Plan.

2.8 Our points in-relation to the Sustainability Appraisal Table 25 (Capel Parish Sites):

a) We have the view that some of the Sustainability Objective scores are questionable and may not take account of wider impacts. For instance, Employment - there will be a loss of local rural employment, with relatively little new retail/service jobs created at in Tudeley and so the outcome is more likely to be neutral on this basis. However, when you consider the impact on Tonbridge, with the resulting congestion likely to harm the viability of many local businesses (see Section 1) that offsets increased commuter trade, this score could actually be slightly negative.

b. Travel should not be shown as positive, since it is a car reliant development (1.11c).

c. We agree that the Capel parish Environmental Objectives have mostly negative scores, with some of these issues highlighted above (in item 1.11diii). However, when considering the wider impact of the development, for instance air quality limits likely to be exceeded in Tonbridge - with the loss of trees and resulting town centre congestion; a more realistic outcome should be a double negative score (i.e. "--").

d. Due to the poor scoring of the Environmental Objectives,  such a large development in the Capel parish is questionable; as it could be argued that there are insufficient net gains across the two other overarching Objectives (economic and social) to offset the immense environmental harm of the current proposals. Thus, we do not believe that the proposed massive village expansions can be considered as being sustainable developments and so are contrary to the NPPF (2019), Paragraph 8.

e. In addition, these garden village proposals are also incompatible with the strategic objectives set out in this Draft Local Plan, including Objective 8 (see item 1.11).

f. Land use rightly scores the worst (typically double / triple negative, i.e. "--/--"). This helps to both highlight how unsustainable this development is and shows that the proposed development strategy is at odds with National planning policy, which promotes brownfield development and the protection of the Green Belt (item 2.6).

g. Some of these comments also apply to the other garden village in Paddock Wood.

2.9 We also note that in this Policy (STR 1) there is the absence of a specific Borough wide approach for developing brownfield sites. Conversely, reference is made to releasing land for development that is presently designated as Green Belt or an AONB.

2.10 The apparent Borough-wide greater emphasis for promoting Green Belt development, over proactively encouraging brownfield redevelopment, is completely at odds with National planning policy (see item 2.6) and is certainly not the basis of a sound Plan.

2.11 In light of the Policy (STR 1) shortcomings identified, which do not appear to favour the Borough-wide brownfield redevelopment, and with the poor land/environmental scores obtained for many of the proposed sites, in the Sustainability Appraisal3. We would advocate that the all sites originally put forward are re-apprised on the basis of favouring the reuse of brownfield land and then sites outside the Green Belt. In addition, this Policy, should set out the approach for positively encouraging the release of brownfield land for development within this Plan period. Without such a strategy and site re-appraisal, the basis of this Local Plan and the justification for the developments might be considered fundamentally flawed and unsound in terms of the NPPF (2019).

2.12 A strategy and site appraisal that may not promote the development of derelict and non-Green Belt land, could have resulted in an approach that favoured unsustainable large scale village developments; instead of smaller developments, equitably spread across the Borough, to unlock the greatest amount of brownfield re-development. By giving developers the nod to build on the easier Green Belt sites, they are likely to keep ignoring other more sustainable brownfield sites that may require remediation.

2.13 We believe that is not sound nor sustainable, with a questionable basis (Items 2.11-12_, for building ober-half (61%, 2,800 + 4,000 new homes at Tudeley and Paddock Wood respectively) of the housing allocation, in two large nearby village developments, at the edge of the Borough with poor public transport links. It is also not fair to push the brunt of the development impacts on to an adjoining Borough Council  and its residents.

2.14 We are also concerned about the deliverability of the Local Plan, with such a large amount housing proposed in these garden villages. In Tudeley it is proposed that 1,900 of the 2,800 homes will be built during the Plan period. However, as noted above (in item 1.11a) the average build-out rate2, for this period of 15 years, is just 1,000 houses. This is likely to result in a short-fall of around 1,000 homes built in this period.

2.15 In addition, a further 4,000 homes proposed in nearby Paddock Wood, within same Plan period, so it is likely that the local housing market will be super-saturated with new builds. Thus, in reality there is likely to be a short-fall of c.5,000 homes built and so it would be better to disperse new houses across the Borough, to reduce the local market saturation. It is also questionable how many buyers would choose these houses in developments; with such poor public transport links and limited local facilities, considering the forecast economic downturn and the current over-supply of houses.

2.16 Futhermore, with a possible 45% (c.5,000) of the housing proposed potentially undeliverable, due to the limited build-out rates (see Items 1.11a, 2.14-2.15), there apepars to be a significant risk that the Borough council will to fail demonstrate it's five housing supply within a decade. As such the proposed Plan is unlikley to meet the requirements of the NPPF (2019), including Plan-making in paragraph 16 that states.

Plans should: ...b) be prepared positively, ... aspirational but deliverable;

2.17 Additionally, if there was a large shortfall in house sales, this might undermine the viability of delivering the Masterplans and the required infrastructure improvements, including a station. This is also likely to compound the issues highlighted in Section 1.

2.18 In summary and in light of the apparent short-fall in deliverable housing (Item 2.16), and the short-comings that favour Green Belt developments (Item 2.11), we are of the opinion that Paragraph 3 (Policy STR 1) should be removed and replaced with more sustainable polices that are more deliverable, with a better spread of housing across the Borough. Otherwise, we strongly contest that this Draft Local Plan is unsound.

2.19 Our objection to Paragraph 7 (Policy STR 1) relates to the release of Green Belt, as we do not believe that exceptional circumstances exist, with alternative sites available. This is contrary to the NPPF (including Para. 136 and 137 - as other sites are available to meet this need) and this will erode the countryside buffers between settlements.

2.20 Our objection to Paragraph 8 (Policy STR 1) relates to permitting development on land designated as an AONB, with alternative sites available. The large scale of the Tudeley development, within AONB and 1km buffer zone, is likely to harm the landscape setting.

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_2760

Cllr Keith Obbard
Wealden Green Party

Object

WEALDEN GREEN PARTY RESPONSE TO TWBC DRAFT LOCAL PLAN

We wish to register our objections to the TWBC Draft Local Plan for the following reasons.

Policy STR1 - Development Strategy

We object to the scale and distribution of development, particularly within the Area of Outstanding Natural Beauty (AONB) and its setting.

Levels of housing provision

The National Planning Policy Framework (NPPF) paragraph 11 says that Councils should provide for objectively assessed needs for housing and other uses.

The most relevant policy in the Framework for AONBs is paragraph 172, the first part of which states:

“Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within these designated areas should be limited”.

Seventy percent (70%) of Tunbridge Wells borough lies within the AONB, and it is our view that the extent of national protected landscape should constrain levels of housing provision in the borough. TWBC should carry out a transparent assessment demonstrating that in deciding the level of housing provision proposed, the type of homes and the distribution of those homes, great weight has been given to conserving and enhancing landscape and scenic beauty in the AONB; the conservation and enhancement of wildlife and heritage has been taken into account; and the scale and extent of development within the AONB has been limited.

In our view TWBC has failed to limit the scale and extent of development proposed in the AONB, contrary to the guidance.

Furthermore, the numbers of dwellings proposed is excessive, and based on outdated methodology.

The Office for National Statistics has produced a revised "2016" methodology, which in the case of Tunbridge Wells would require only 67% of the stated figure, If this factor is applied the resulting net number of new dwellings required goes down from 7,593 to 3,115, ie.  to much less than half.

This, together with additional brownfield developments first could obviate the need for use of Green Belt land.

DLP_1640

Richard Bysouth

General Observation

STR 1:

"a prestigious new business park will be located to the north of North Farm/Kingstanding Way" is mentioned several times. Yes, it is connected to the A21, but this assumes that everyone would be commuting there from other towns. For many of those commuting/visiting from Tunbridge Wells, they would be accessing via the single-lane railway bridge at North Farm Road, which is already over capacity. This would have to be resolved (i.e. bridge changed to 2 lanes) before completion of the business park to prevent further congestion.

DLP_2019

Penelope Ennis

Object

The Draft Local Plan is indicating that TWBC prefers to meet its housing needs by the approval of large-scale developments in Wealden Towns and Villages. Why are you not prepared to consider the small scale developments first? Is it because the temptation of S106 Contributions are irresistible and small scale developments wont attract such large contributions?  The consequences of such developments for the AONB and the villages concerned are very real. You are selling the family silver and the damage will last forever. I understand from our Parish Council that depending upon which set of calculations are used the Housing Needs Allocation could be halved. TWBC have chosen to exceed the allocation requirements across the borough compounding the excessive allocations not just for Hawkhurst but other parishes across the borough. We also have concerns over the definition of windfall development which could lead to large scale sites being excluded from our Parish Allocation but being used by the TWBC to meet its own targets.

This Draft Local Plan will not be preserving the AONB that represents 70% of our borough. There will be no character or charm or countryside left in our borough. We will all become 'copy and pasted' versions of the developers' little book of architecture.

Paragraph 4.36 suggests that there is agreement with the Parish Councils on development sites.  Central Government led us down a path to develop our Neighbourhood Development Plan (at considerable expense in time and money). Now, armed with this document, the Parish Councils' comments are being completely ignored. It's as if you've forgotten you asked us to prepare this document and this later of 'consultation' is now very inconvenient and very boring that we keep reminding you about it!  This is TWBC's NDP for Hawkhurst - you are voting against your own policy. Hawkhurst Parish Council have decided not to comment upon their preferred sites as they feel this would compromise the planning process at a later date. The reason for not choosing preferred sites at the time of submitting the NDP was that the Parish was already delivering ahead of allocation.

4.2 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst.  TWBC have approved applications in the face of huge local opposition and in direct contravention our Neighbourhood Development Plan. Our population, number of houses and properties has overwhelmed the capacity of services to cope. Hawkhurst has been playing a part in the allocations and suffered the consequences.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected. in Hawkhurst, we are constipated and we have indigestion.  In targeting the larger sites you have not maximised the smaller sites before biting into the AONB. As I understand the NPPF gives TWBC the opportunity to reduce your allocation due to a high percentage of the borough being AONB. You have chosen to increase your allocation.  The sites illustrated in your Draft Plan are not appropriate in scale for the AONB.

Paragraph 4.4- claims that the growth strategy is based upon the premise of infrastructure-led development. This is misleading as the Council has no control over the provision of infrastructure, services and facilities on the scale that we require to support developments of the size proposed.

A perfect illustration is the provision of sewerage by Southern Water. Southern Water have admitted that the infrastructure is inadequate to support further housing development and recommended that no further development should be approved until the necessary improvements are made.

The fouling of waterways by Southern Water was entirely foreseeable to local residents. Improvements are not made when they should be made, if at all and residents suffer the consequences.  The development plans for Heartenoak are already non-compliant and there is no provision for the Golf Course development at all. The development of Fieldways/Westfield will displace water down a steep valley and in the vicinity of historic buildings. On the south side of the village water courses are being changed by the landscaping and concreting of developments near the centre of the village.

The development strategy outlined from paragraph 4.41 onwards is flawed in two respects:

1. It treats each proposed development in isolation from all the others and ignores the consequences for sustainability and infrastructure, of their combined effects. Developments in Cranbrook, Sissinghurst, Sandhurst and Hawkhurst impact on the infrastructure which you have not represented in your plan. We already have experience that traffic surveys conveniently do not factor in a half-finished development near us, swaying the count. We really need some reliable data based upon the Site Allocations in these Parishes and how they join to impact upon each other.  For example 300 houses at Hartley on the south side of Cranbrook is bound to to generate traffic into Hawkhurst. We hope that our Parish Council will challenge you to  look at the Allocations in Rother and East Sussex and Ashford Borough Council to see what the overall impact from each direction might be.

2. TWBC - have no control over the developments in neighbouring counties neither can they press neighbouring local authorities to address infrastructure needs that are generated by a TWBC decision.

DLP_2145

Michael O'Brien

Object

The Draft Local Plan is indicating that TWBC prefers to meet its housing needs by the approval of large-scale developments in Wealden Towns and Villages. Why are you not prepared to consider the small scale developments first? Is it because the temptation of S106 Contributions are irresistible and small scale developments wont attract such large contributions?  The consequences of such developments for the AONB and the villages concerned are very real. You are selling the family silver and the damage will last forever. I understand from our Parish Council that depending upon which set of calculations are used the Housing Needs Allocation could be halved. TWBC have chosen to exceed the allocation requirements across the borough compounding the excessive allocations not just for Hawkhurst but other parishes across the borough. We also have concerns over the definition of windfall development which could lead to large scale sites being excluded from our Parish Allocation but being used by the TWBC to meet its own targets.

This Draft Local Plan will not be preserving the AONB that represents 70% of our borough. There will be no character or charm or countryside left in our borough. We will all become 'copy and pasted' versions of the developers' little book of architecture.

Paragraph 4.36 suggests that there is agreement with the Parish Councils on development sites.  Central Government led us down a path to develop our Neighbourhood Development Plan (at considerable expense in time and money). Now, armed with this document, the Parish Councils' comments are being completely ignored. It's as if you've forgotten you asked us to prepare this document and this later of 'consultation' is now very inconvenient and very boring that we keep reminding you about it! This is TWBC's NDP for Hawkhurst - you are voting against your own policy. Hawkhurst Parish Council have decided not to comment upon their preferred sites as they feel this would compromise the planning process at a later date. The reason for not choosing preferred sites at the time of submitting the NDP was that the Parish was already delivering ahead of allocation.

4.2 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst.  TWBC have approved applications in the face of huge local opposition and in direct contravention our Neighbourhood Development Plan. Our population, number of houses and properties has overwhelmed the capacity of services to cope. Hawkhurst has been playing a part in the allocations and suffered the consequences.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected. in Hawkhurst, we are constipated and we have indigestion.  In targeting the larger sites you have not maximised the smaller sites before biting into the AONB. As I understand the NPPF gives TWBC the opportunity to reduce your allocation due to a high percentage of the borough being AONB. You have chosen to increase your allocation.  The sites illustrated in your Draft Plan are not appropriate in scale for the AONB.

Paragraph 4.4- claims that the growth strategy is based upon the premise of infrastructure-led development. This is misleading as the Council has no control over the provision of infrastructure, services and facilities on the scale that we require to support developments of the size proposed.

A perfect illustration is the provision of sewerage by Southern Water. Southern Water have admitted that the infrastructure is inadequate to support further housing development and recommended that no further development should be approved until the necessary improvements are made.

The fouling of waterways by Southern Water was entirely foreseeable to local residents. Improvements are not made when they should be made, if at all and residents suffer the consequences.  The development plans for Heartenoak are already non-compliant and there is no provision for the Golf Course development at all. The development of Fieldways/Westfield will displace water down a steep valley and in the vicinity of historic buildings. On the south side of the village water courses are being changed by the landscaping and concreting of developments near the centre of the village.

The development strategy outlined from paragraph 4.41 onwards is flawed in two respects:

1. It treats each proposed development in isolation from all the others and ignores the consequences for sustainability and infrastructure, of their combined effects. Developments in Cranbrook, Sissinghurst, Sandhurst and Hawkhurst impact on the infrastructure which you have not represented in your plan. We already have experience that traffic surveys conveniently do not factor in a half-finished development near us, swaying the count. We really need some reliable data based upon the Site Allocations in these Parishes and how they join to impact upon each other.  For example 300 houses at Hartley on the south side of Cranbrook is bound to to generate traffic into Hawkhurst. We hope that our Parish Council will challenge you to  look at the Allocations in Rother and East Sussex and Ashford Borough Council to see what the overall impact from each direction might be.

2. TWBC - have no control over the developments in neighbouring counties neither can they press neighbouring local authorities to address infrastructure needs that are generated by a TWBC decision.

DLP_2431

J Coleman

Object

The development in the eastern part of the Borough is too high and is disproportional to that taken by Tunbridge Wells. The development in the eastern area of the borough is not sustainable due to the distance to key employment sites and poor public transport links.

It will also damage the high sensitivity landscape around Cranbrook and Sissinghurst.

DLP_2470

G Baker

Object

The proposed new housing numbers in Sissinghurst is too high and is disproportional to that taken by Tunbridge Wells. There are a lack of facilities in the area and the developments are not sustainable due to the distance to key employment sites and poor public transport links.

DLP_2674

Rebecca Cubitt

Object

I challenge the need for so many houses to be built over the plan period of 2016-2036. The Office for National Statistics estimates borough population growth of 13,952 people, and with an average house occupancy rate of 2.35 people (117,140 people living in 49,880 houses), the need is for 5,937 houses (of varying sizes).

TWBC must challenge the government on the number genuinely needed in the borough.

Other comments: Traffic in Tunbridge Wells is bad enough. Why add to the problem? Air quality will become terrible and ruin this beautiful area.

DLP_2833

Helen Parrish

Object

Existing, idle, Brown Field Sites are not being compulsorily purchased as a priority - neither Empty Properties too

DLP_2965

Michael Alder

Object

The Draft Local Plan emphasises that TWBC prefers to meet its assessed housing needs by approving large-scale developments. It is clear that no consideration had been given to the consequences of this when related to the preservation of the ANOB where Hawkhurst is 100% covered by the ANOB criteria.

The claim by TWBC ( para 4.36 ) that there is a level of agreement with Parish Councils on development sites is incorrect, certainly in the case of Hawkhurst. The NDP for Hawkhurst submitted in March 2019 has been ignored by TWBC -- if read at all -- although it has be "made" and must be taken into account when preparing the Local Plan.

There has been much speculative housing development recently in Hawkhurst despite the fact that numbers of properties identified in earlier Neighbourhood Development Plans have already been exceeded. The calculations for the TWBC Draft Local Plan assume a zero base which is a basic error. Hawkhurst has already been seriously impacted by this.

Paragraph 4.40 claims that the growth strategy is based on infrastructure-led development. The experience in Hawkhurst is that statutory think otherwise. Sewage and transport provision for the existing demand of Hawkhurst is failing dismally. Southern Water themselves have admitted that their infrastructure is inadequate for further development. Transport, education and health services are facing the same situation.

DLP_3089

Tony Fullwood

Object

Policy STR 1 - The Development Strategy is a key strategic policy in the draft Local Plan.

Criterion 6 applies to a large number of smaller settlements in the Borough:

  1. Development at the other settlements across the borough within their respective Limits to Built Development boundaries and through the delivery of allocations as per Table 3 below, and other suitable windfall developments;

Policy STR/BE 1 - The Strategy for Benenden Parish is dependent on Policy STR 1, which makes the definition of other suitable windfall developments even more imperative:

Policy STR/BE 1 - The Strategy for Benenden Parish is a key policy for Benenden Parish. Criterion 2 states:

Additional housing may be delivered through the redevelopment of appropriate sites and other windfall development in accordance with Policy STR 1;

The draft Local Plan therefore contains two inter-related policies which employ different wording. Importantly, the draft Local Plan does not clearly define the terms ‘other suitable windfall developments’ (though by definition criterion 6 of Policy STR 1 indicates that it must be on sites outside the LBD) or ‘other windfall development’.

The NPPF states:

  1. Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. To promote the development of a good mix of sites local planning authorities should:

c) support the development of windfall sites through their policies and decisions – giving great weight to the benefits of using suitable sites within existing settlements for homes;

Policy STR 1 criterion 6 partially follows this approach but without a definition of ‘other suitable windfall developments’, it is not clear whether Policy STR 1, or by association Policy STR/BE, is consistent with national policy.

In this respect, provided a number of criteria are met, the draft Local Plan already permits the following types of windfall development outside the LBDs:

  • Rural Exception Sites where no alternative site is available to meet local housing needs inside the Limits to Built Development (Policy H7)
  • Rural Workers' Dwellings (Policy H10)
  • Replacement Dwellings outside the Limits to Built Development (Policy H14)
  • Use of poorly located or unviable existing employment sites and buildings (Policy ED 2)
  • Conversion of Rural Buildings outside the Limits to Built Development in exceptional circumstances (Policy ED 5)

The NPPF also allows limited infilling or the partial or complete redevelopment of previously developed land in the Green Belt (Para 145) and this would presumably apply elsewhere in the Borough. This would facilitate Policy AL/BE 4 where there is no existing LBD.

The draft Local Plan makes it clear that 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 (Para 4.81).

As set out in the Council's Limits to Built Development Topic Paper, the following principle is one which is used to define LBDs:

  1. There may be some fringe areas beyond a settlement’s more consolidated core, as well as smaller villages/hamlets and enclaves of development in the countryside that do not have a LBD, in order to maintain the overall rural character of an area.

It is therefore implied, given 70% of the Borough is covered by the High Weald Area of Outstanding Natural Beauty (AONB) and 22% is within the Metropolitan Green Belt (MGB), that greenfield sites outside the LBDs do not constitute ‘other suitable windfall developments’.

This is contradicted by the paragraph in Policy STR/BE1 which permits major development larger than approximately 100 residential units on greenfield windfall sites anywhere in Benenden Parish. Given that there is no spatial precision to this policy, or any limit to the number of times it could be applied, as worded this policy is not consistent with national policy (Para 172 or draft Local Plan Policy EN 21 - High Weald Area of Outstanding Natural Beauty) in respect of most of the parish which is within the High Weald AONB. Nor is Policy STR/BE1 justified (an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence) and would lead to unsustainable development.

Policy STR 10 - Limits to Built Development Boundaries states:

..Outside the Limits to Built Development, development will normally be limited to that which accords with specific policies of this Plan and/or that for which a rural location is demonstrated to be necessary.

However, without a clearer definition of ‘other suitable windfall developments’ it is not clear whether proposed development would accord with Policy STR 1 and Policy STR BE1 or not.

Change required 

Policy STR 1 requires greater clarity by defining the term ‘other suitable windfall sites’. The following are given as a definition which would be consistent with other policies in the draft Local Plan (see Objection to STR BE1) and the NPPF:

  • Rural Exception Sites where no alternative site is available to meet local housing needs inside the Limits to Built Development (Policy H7)
  • Rural Workers' Dwellings (Policy H 10)
  • Replacement Dwellings outside the Limits to Built Development (Policy H 14)
  • Use of poorly located or unviable existing employment sites and buildings (Policy ED 2)
  • Conversion of Rural Buildings outside the Limits to Built Development in exceptional circumstances (Policy ED 5)
  • Limited infilling or the partial or complete redevelopment of previously developed land in the Green Belt (NPPF Para 145)
  • A house of exceptional design quality (NPPF Para 79)

Policy STR1 should make it clear that other suitable windfall development does not include greenfield sites unless it involves Rural Exception Sites; Rural Workers' Dwellings or a house of exceptional design quality in accordance with Local Plan policies and the NPPF.

The following Paragraph should be deleted from Policy STR/BE 1:

Any major development larger than approximately 100 residential units on greenfield windfall sites is expected to provide suitable employment floorspace, to be discussed with the Local Planning Authority and Benenden Parish Council through pre-application discussions.

DLP_3168

Kent County Council (Growth, Environment and Transport)

Object

Highways and Transportation

The County Council, as Local Highway Authority objects to the policy.

The policy states under paragraph 4 “…delivery of significant infrastructure improvements in the form of a relief road from Cranbrook Road to Rye Road, providing significant improvements to the crossroads in the centre of Hawkhurst (Highgate)”. Based on assessments to date, the provision of the new road as part of the live Hawkhurst Golf Club application (Ref 19/02025/HYBRID) does not achieve any improvement to the flow of traffic through the junction.

The Hawkhurst Golf Club allocation, plus subsequent allocations in Hawkhurst, will not be supported by the Local Highway Authority owing to the severe cumulative impact on the crossroads in the village.

DLP_3169

Kent County Council (Growth, Environment and Transport)

General Observation

Provision and Delivery of County Council Community Services

Paragraph 5 - The County Council would welcome more specific commentary about the social care and community facilities requirement within this policy

DLP_3423
DLP_6019

Sally Marsh
Laura Rowland

Object

TWBC: the standard response was submitted by the list of responders on the left:

Policy Number: STR 1 The Development Strategy

I object to the scale and distribution of development within the AONB, and particularly within Cranbrook and Hawkhurst. An additional 2300 houses across 50 sites within the AONB is not consistent with its protection as a national important landscape.

Seventy percent (70%) of Tunbridge Wells borough lies within the High Weald AONB and paragraph 11 of the NPPF (footnote 6) suggests that AONB designation should constrain levels of housing provision. This is supported by Planning Practice Guidance (Paragraph: 041 Reference ID: 8-041-20190721) which makes it clear that development should be limited in AONBs, and that it may not be possible to meet ‘objectively assessed needs’ in these areas.

In the Distribution of Development Topic Paper (Para 3.11), TWBC accepts that strategic-scale urban extensions, would ‘almost certainly not be appropriate’ in the AONB under national policy, and that the statutory purpose of conserving and enhancing the AONB is ‘likely to limit its capacity to absorb new development’. However, in allocating housing numbers to the AONB, no distinction has been made between the proportion of housing allocated to the borough as a whole, and that allocated to two key AONB settlements – Cranbrook and Hawkhurst. The current district-wide allocation of 14776 represents approx. 13 houses/ 100 head of population. Similarly, the allocations within the AONB in Cranbrook and Benenden ward, and Hawkhurst and Sandhurst ward also represent 13 houses/ 100 head of population, respectively. This is inconsistent with the local plan’s stated policy and with the NPPF.

In addition, these AONB settlements appear to be meeting need from elsewhere, most likely from outside of the AONB. Cranbrook and Sissinghurst Neighbourhood Plan assessed the local housing need of these settlements as 610, of which 250 are met by the allocation in the previous local plan at Brick Kiln Farm. This leaves a further 360 to be delivered across both settlements to meet local need. The draft Local Plan allocates 918 to these settlements. The difference between these two figures suggests need from the wider borough, most likely outside of the AONB, is being met in the AONB. This figure amounts to approximately the numbers allocated to the three largest ‘major’ sites which are likely to cause the most harm to the landscape and natural beauty of the AONB. These major allocations are not necessary and should be dropped. The allocations for Hawkhurst, Benenden and Matfield are similarly inflated above what is required to meet local need.

Even if the need to allocate development within the AONB has been demonstrated, it does not mean that such provision should be in the form of major development sites. The AONB Management Plan, adopted by Tunbridge Wells Borough Council in March 2019, explains that the High Weald is a small-scale landscape built by hand. The Plan commits authorities to ‘seek to deliver new housing primarily through small-scale developments that meet local need’ (Objective S2, page 34). Paragraph 172 of the NPPF says that ‘Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest’. The tests associated with this policy have not been properly considered and the exceptional circumstances have not been justified. Alternatives to the large allocations have not been properly considered – sites outside the AONB, for example at Colliers Green, have been dismissed, and the option of reduced allocations on the larger sites offered in the SHELAA has not been properly examined.

The Glover Review of designated landscapes recognises the threats to AONBs, particularly in the South East, of excessive development, recommending a stronger role for AONBs in the planning system as a result. The Review highlights the damage done to AONBs through locating major development on its boundaries and within its setting. Planning Practice Guidance also highlights the need to take potential impacts on the AONB into account when considered development in its setting (Paragraph: 042 Reference ID: 8-042-20190721, revised 21 07 2019). Consideration of the new settlement at Capel and the proposed development at East End both on the boundary of the AONB have not involved proper consideration of impacts on the AONB, including the impact of cars, visitors and the impact of the loss of cultural associations with the AONB.

DLP_3761

Martin Robeson Planning Practice for Tesco Stores Ltd

Support with conditions

STR1 – The Development Strategy (support with conditions)

Tesco broadly supports the Council’s development strategy, particularly the intention to make provision for all development needs inside the Borough boundary (ie, without the assistance of neighbouring authorities). Tesco also supports the proposed growth of Paddock Wood (see later) but questions, in terms of the scale of new development to be directed there, and to Capel/Tudeley, whether the full potential of existing settlements to accommodate growth has been explored, and in so doing, enhancing their sustainability. Indeed, there appears to be an imbalance between the scale of development directed to certain settlements relative to their scale and sustainability. Such distribution must be fully justified and, if maintained as currently proposed, accompanied by proposals for commensurate improvements in local infrastructure, including convenience retail facilities.

DLP_4234

Rother District Council

 

Paragraph 4.38 and Policy STR1

Support

The proposed development strategy for the borough, and specifically the way in which it takes account of the need to maximise the amount of major development outside of the High Weald AONB, is consistent with this Council’s approach.

DLP_4360

British Horse Society

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”.

The new developments at Hawkenbury, particularly the new sports hub, should provide horse riding routes that link to the existing public bridleways nearby.  In some London Boroughs, horse riding routes have been created around the perimeter of playing fields and the same could be done here.

DLP_4381

Frant Parish Council

Object

Frant Parish Council (herein after referred to as ‘the Council’) has considered in depth the content of the Draft Local Plan (‘the Plan’) and the accompanying documents and wishes to make the following representations.

As a neighbouring parish to the Borough, the Council is only too aware of the way in which, over time, built development has made its steady march toward the parish boundary (which marks the change in county), outwards from Tunbridge Wells.  Para 2.44 of the Plan states that “the cumulative impact of minor piecemeal development and small changes in land use can have a significant overall adverse impact on the natural, built and historic environment, and on the character and settlement patterns within, and adjacent to, the High Weald AONB”.  A very good example of this increasing encroachment, in part comprised of piecemeal development, is that which has been occurring adjacent to Bells Yew Green in recent years, with ongoing residential development.

A significant by-product of this is the deleterious effect on the local road network, of which much lies within the parish.  This road network is made up of C- and D-class roads. They are by their nature narrow, mostly single-track country lanes, peppered with sharp turns and bends, historic features such as an old bridge and walling, overhanging vegetation, no road markings, wildlife and so on.  These roads, particularly Dundale Road, Hawkenbury Road, Benhall Mill Lane and Ivy Lane are suffering immeasurably already from the excessive number of vehicles using these routes as a way to access the A21; many of these vehicles are large, articulated lorries that simply cannot navigate these C- and D-class roads, regularly making the roads impassable as they attempt to reverse away from or squeeze past other road users.  New development simply adds to the burden on these local roads – roads that were never designed to or anticipated to accommodate this load of traffic.

A high concentration of traffic on these types of roads also detracts from their rural quality and character, particularly where they lie within the AONB.

The Plan appears to be relying on developer contributions to improve the more major roads to accept the consequences of new development, rather than to establish the capacity of the roads first to in turn then help to inform what level of development would be acceptable. Para 2.9 acknowledges highway capacity as a constraint to future growth.  Para 2.23 identifies “…the significant transport challenges, particularly in terms of managing existing congestion and future growth…” and lists the various A-class roads, including those which affect the parish – the A21, A267 and A26.  As above, the parish is used as a ‘cut through’ to the A21; para 2.23 again acknowledges the problems in and around this location where it states “…congestion on the A21 at Kippings Cross… remain(s) unresolved”.  This situation reflects the current, baseline scenario and further development can only worsen this.

Turning to infrastructure more generally, para 2.18 states that a “…new Infrastructure Delivery Plan will identify all infrastructure requirements as a result of the new development proposed”.  This methodology suggests that rather than the level of infrastructure required to sustain a development inform the extent of the development that can be achieved, it would appear to be the other way round   - the level of development is decided upon and then the extent of infrastructure required is then determined.  The reality for many areas in both Wealden and Tunbridge Wells is that the provision of effective and sufficient infrastructure is often an after-thought and, as above, relies on several providers delivering the infrastructure in a timely way and on budget,  on delivering infrastructure that will be sustainable and on the input of developer contributions.

A case in point is the new development proposed at land to the west of Eridge Road at Spratsbrook Farm at Policy  AL/RTW 18 (SHELAA Site Number 137).  The doctors’ surgery serving the Ramslye Estate has now closed. While the Council is not privy to the reasons why, it suspects the ever-growing decline in GP numbers may well be one reason. Thus, in reality, a new surgery building can be provisioned for in a new scheme, but the commitment of GPs for the surgery cannot be assured. A significant shortfall in infrastructure delivery of a key service thus immediately becomes a problem.

In 2017, Wealden District Council made a call for sites and Dandara (housebuilders) submitted a ‘SHELAA’ for the site in question.  After consideration of the sites submitted, Wealden District Council did not include the 176-acre site as a development site in its draft Local Plan.  At that time, the Council submitted comments dated January 2018 to TWBC, raising concerns about the prospect of future development in this area.  The Council wrote:

“There are a number of constraints related to the site, including that parts of it are located within the AONB, the Green Belt and a designated SSSI.  It is also sited within near proximity of the Ashdown Forest and you will be aware of the ongoing issues surrounding any development that exacerbates those issues.

For the reasons set out above, the Parish Council are concerned about the impact that such a development would have on the environment within which it is located. The Council is also concerned about the impact and pressure this scale of new development would pose on the local infrastructure, particularly the local road network, the local school and other amenities”.

The Council would reiterate those comments now, in relation to Policy AL/RTW 18 and would note that this new development will be in close proximity to Eridge (within the parish) and will be served in part by the A26. Traffic along the A26 is already excessive and this new development, as well development ongoing in Crowborough, will add to this significantly. The existing hotspot around Sainsburys and onto the roundabout at Major York’s Road will not be able to cope with further demands on it arising out of new development.  The site is within the 15k Ashdown Forest zone and thus an increase in traffic can only have a negative impact on the Forest’s already vulnerable  ecology.  There will be negative consequences for the neighbouring SSSIs at High Rocks and Eridge Park, itself registered as an Historic Park and Garden, and the Broadwater Warren Reserve, which is within one mile of the site.  The site is located on an exposed ridge and a vast development such as that which is proposed will be readily discernible in this AONB landscape.

Despite the requirements contained in the Interim Duty to Cooperate Statement for the Draft Local Plan (Regulation 18) September 2019 for local authorities to ‘engage, collaborate and cooperate’ with one another (para 2), the above allocation of the site at Spratsbrook suggests that the problems with encroaching on a rural parish from either side (Crowborough at one end and the south side of Tunbridge Wells at the other) have not been considered in a joined-up way by the neighbouring authorities involved.  Setting aside the obvious pressures arising from new development, particularly on roads and wider infrastructure, the very qualities that make up the parish (as an example) and, indeed, the Spratsbrook site itself, are clearly at risk – those qualities that define the AONB, the Green Belt, agricultural land and rural areas in general. The Council considers that the premise asserted at para 2.44  of the Plan (below) cannot be adequately met through such allocations:

“A challenge for the new Local Plan will therefore be to provide for, and balance, the competing pressures of housing, employment and other development with the preservation and enhancement of local character and distinctiveness”

Indeed, the release of Green Belt land is of particular concern and the Council would wish to see evidence of how exceptional circumstances for the release of such land, in accordance with the NPFF at paras 136 and 137, have been demonstrated by the Borough Council.  Again, taking the Spratsbrook development as an example, the Council does not consider that the proposals accord with the NPFF at paras 170 and 172, whereby great weight is given to the preservation (at the very least) and enhancement (as a gain) of the AONB.

In summary, the Council considers that the Plan allows for the further encroachment of development on the borders of the parish, compromising its unique character and distinctiveness, affecting its rural quality and character, all in the absence of a coherent and coordinated approach between the neighbouring authorities.  The Council considers the approach to the provision of new development and the necessary infrastructure is short-sighted and, ‘on the ground’, will simply add to the already congested road network and over-burdened services in the wider area.

DLP_4534

Historic England

 

Policy STR 1: The Development Strategy – while we respect the Council’s determination to achieve its projected growth needs via the preferred options set out in the policy, it is not clear that these have been arrived at following an assessment of the likely or effects, as far as they are measurable at the strategic scale, of the distribtuion of development under this scenario on the historic environment and the significances of heritage assets.  Historic England cannot give support to this policy unless is is made clear that it has been framed in the light of such assessments, and that these are reflected in the wording of the policy to the effect that harm can be avoided or mitigated, or enhancement achieved, through its implementation.

DLP_3803

Natural England

 

Natural England advises that this strategy is not justified because insufficient evidence has been provided to demonstrate that the strategy is deliverable without resulting in an adverse impact on the High Weald Area of Outstanding Natural Beauty (AONB), considered against reasonable alternatives. The allocation is not consistent with national policy with regard to conserving landscape and scenic beauty within a nationally protected landscape (NPPF para 172).

Natural England has significant concerns regarding the proposed development strategy and the quantum of development which this plan proposes within the AONB. Natural England has an in- principle objection to major development within designated landscapes proposed within this draft local plan. The inclusion of 17 allocation sites within the AONB which are considered to constitute major development is of significant concern. Further advice on the Distribution of Development Topic Paper which underpins this strategy, is contained in Appendix 2. Comments on individual allocations are provided in Appendix 3.

The NPPF advises (in paragraph 11 and footnote 6) that AONBs are areas of particular importance that provide a strong reason for restricting the overall scale, type or distribution of development in the plan area. The NPPF also provides clear guidance (paragraph 172) that 'Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues.'

Paragraph 172 further states that ‘The scale and extent of development within these designated areas should be limited’ and that ‘Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.’ The NPPF then states that consideration of such applications should include an assessment of:

a) The need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;

b) The cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and

c) Any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated

Given the quantum of development proposed within the AONB, we do not consider that the development strategy is in accordance with above criteria to limit the scale and extent of development and to conserve landscape and scenic beauty of the AONB.

Point 8 of the strategy indicates that the tests set out in the NPPF must be met for major development sites in the AONB. Taking this to mean the abovementioned criteria in paragraph 172, Natural England does not consider that adequate evidence has been provided to demonstrate how these sites meet the criteria.

Subject to the provision of further information to support the proposed site allocations, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to Development Strategy STR 1. Advice on specific allocations, including major development sites, is provided in Appendix A.

With regard to the exceptional circumstances criteria set out in NPPF para 172, Natural England advises the following:

Natural England cannot provide advice on meeting housing needs, delivery of housing numbers or affordability of housing in the borough. However as the statutory adviser for protected landscapes, we advise that major development is located outside of the AONB, and that designated landscapes should not be relied upon for the provision of significant contributions towards the Borough’s housing needs. We further advise that impacts to the setting of the AONB are also avoided.

We advise that the Development Strategy, which proposes considerable direct and permanent change to a nationally important designated landscape, cannot be mitigated to reduce adverse impacts to an acceptable level.

We therefore strongly advise that the proposed Development Strategy does not meet the exceptional circumstances criteria set out in NPPF para 172.

DLP_3902

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.

In addition –

Policy STR 1: 2 – there needs to be clarity that the sports centre is an outdoor sports centre, as opposed to Putlands, which is an indoor sports hub which requires development, including a swimming pool.

DLP_5602
DLP_5555

Mrs Jacqueline Hewitt
Mr Paul Hewitt

General Observation

TWBC: the standard response was submitted by the list of responders on the left:

Policy STR1 c. A prestigious new business park will be located to the north of North Farm/Kingstanding Way that is well connected to the improved A21, providing a range of employment floorspace and jobs to meet identified needs. The site will make a substantial contribution to the need for new employment space over the plan period. Other employment, including leisure development, will be encouraged at North Farm/Kingstanding Way;

If the ENS has identified the above areas for development, this is surely where many new residents of the Parish of Cranbrook and Sissinghurst will be travelling to work, (14 miles away) entirely unsupported by appropriate infrastructure

I object to placing so much development in Cranbrook and Sissinghurst when employment is targeted so far away

DLP_3991

Lamberhurst Parish Council

 

STR1 – Development Strategy: Delivery of Housing Numbers

The DLP is considering a total of 2000 houses within the AONB and many more along the boundaries with a great impact on its 'setting'.

The new housing calculator has pushed TWBC to have an unprecedented level of potential building across its borough. Evidence suggests a major part of the requirement is for more affordable and local needs housing for the young and elderly people including those wanting to downsize.

The Glover recommendations from the reviews of AONB's & National Parks also reflects the need for real affordable housing. Building more houses will not equate to more affordable accommodation, especially in desirable areas within Rural Parishes such as Lamberhurst. In common with other Local Councils in the borough, this parish is engaged upon preparation of a Neighbourhood Plan and has conducted its own housing needs survey which clearly reflected that there is a local requirement for smaller affordable units, rural exception and social housing.

The NPPF clearly states that new building within the AONB should be limited and small scale. Major development should only be allowed under exceptional circumstances, which again has not been evidenced in the many major developments in the Draft Plan.

Therefore only genuine housing needs should be met within the AONB. If the numbers allocated can only be achieved by major development, which by definition will have a significant adverse impact on the character components of the landscape, this is an indicator that the numbers proposed cannot and should not be achieved.

LPC therefore supports a more realistic and sustainable approach which recognises the constraints of the AONB and ask that TWBC takes on its responsibilities not to put forward these volumes and look to the Government to reduce its numbers in line with sustainable local housing need.

DLP_4869

DHA Planning for Berkeley Homes (Eastern Counties) Ltd

 

2.3 Development Strategy and Strategic Policies (Policy STR1)

2.3.1 The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the Borough and where that development will be located.

2.3.2 In terms of the amount of housing, paragraph 59 of the NPPF states that to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed. Further, to determine the number of homes needed, strategic policies should be informed by a local housing needs assessment conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.

2.3.3 The Council confirm that their housing need target for the plan period 2016-2036 is 13,560 dwellings (678 dwellings per annum), which is calculated using the Governments standard method and the 2014-based household projections.

2.3.4 In terms of the different supply components, the Council consider that the Local Plan must (as a minimum) include additional allocations to accommodate 7,593 homes. This figure was formulated taking into account; completions since April 2016 (1,552); extant planning permissions (3,127); outstanding site allocations (588) and a windfall allowance (700 dwellings). The Council have applied a 10% non-delivery rate to these figures to err on the side of caution and consider that the plan would exceed the minimum housing requirement if all of the supply components were achieved.

2.3.5 We commend TWBC for seeking to meet their need in full and support this positive approach to plan-making. Likewise, we support the general thrust of the development strategy, which proposes a strategy to meet the housing needs of the borough with a dispersed growth approach. Nonetheless, we are concerned that the strategy is too heavily reliant on the Tudeley Garden Village and the Strategic Expansion of Paddock Wood. Furthermore, the Council have made optimistic assumptions about the delivery of these sites, which we expand upon below.

2.3.6 The strategy is consolidated by Policy STR 1, which sets out the quantum of development that will be allocated within or around settlements to meet the identified needs of the borough over the plan period. This strategy would seek to meet the majority of the Councils housing through the strategic expansion of Paddock Wood and via a new Garden Village at Tudeley. The remaining growth would then be dispersed proportionately to settlements in the borough, to areas including but not limited to Sissinghurst, Cranbrook, Matfield and Benenden.

2.3.7 We support the principle of the strategy, given that it would proportionately spread the benefits of growth and recognises the opportunity to direct a greater level of growth to Cranbrook than in previous plan periods. Further, adopting a pattern of dispersed growth approach would allow a number of sites to be developed at the same time, serving different segments of the local housing market, which is preferable to saturation of the market in a single area.

2.3.8 Nonetheless, we have some concerns regarding the balance between strategic and non-strategic scale allocations and the anticipated delivery trajectory. For example, 65% of new allocations would be delivered as part of the strategic extension to Paddock Wood (4,000 homes) and the new Garden Village at Tudeley (1,900 homes within the plan period). Both require a fully master-planned approach, which is a timely process. Furthermore, there are a significant number of existing commitments within Paddock Wood that have been slower at coming forward than had originally been envisaged. A cautious approach is therefore needed. Likewise, a number of the allocated sites in Paddock Wood are located within flood zone 3 and the NPPF states that development should be directed away from these sequentially undesirable areas.

2.3.9 To further emphasise our concerns about housing delivery, we would draw the Council’s attention back to the 2016 document published by Nathaniel Lichfield’s and Partners (NLP) - ‘Start to Finish: How Quickly do Large-Scale Housing Sites Deliver’, which provides evidence pertaining to the speed and rate of delivery of large-scale housing, based on a large number of sites across England and Wales. It identifies that the average lead in time for the submission of a planning application is 3.9 years, from the date the site is first identified. In terms of the planning approval period, for larger scale sites (2,000 + homes) this is circa 6 years. After planning permission is granted, larger sites start to deliver within a year and the average build out rate thereafter is 161 dwellings per annum - although it can be as high as 301 dwellings per annum.

2.3.10 On the basis of this research, if the Local plan is adopted by 2021, planning permissions approved at Paddock Wood by 2023 and delivery commences within 6 years (2029), the likely delivery for the plan period would be circa 966 homes. This highlights that the Council would fall short of their projections for Paddock Wood by more than 3,000 homes. Similarly, delivery at Tudely would fall short by approximately 1,000 homes.

2.3.11 Figure 1 below is taken from the NLP report, which shows the average planning approval period and delivery of first dwelling by site size.

[TWBC: for Figure 1, see page 6 of full representation].

2.3.12 Whilst the NLP report does not represent practice guidance, it is widely accepted as being a reliable and credible source of evidence and it is referenced by TWBC in their Housing Trajectory Paper.

2.3.13 Despite evidence elsewhere, TWBC has set a very optimistic trajectory for delivery of Tudeley Garden Village and the strategic extension of Paddock Wood, which is detailed in the Housing Trajectory Paper.

2.3.14 The Council forecast that the Tudeley Garden Village will begin to deliver homes from 2025/26 onward, with an initial build out rate of 150 dwellings per-annum, rising to 200 dwellings per annum from year 6 onward. Likewise, they suggest that the extension to Paddock Wood will start to deliver in 2024/25 at an average build out rate of 333 dwellings per annum – which is nearly double the average rate for larger schemes identified in the NLP document. This higher build out trajectory is predicated on the basis that there would be a number of house builders involved the construction of different parts/phases. However, by their own admission, TWBC do not currently know how many housebuilders will be involved.

2.3.15 With the above in mind, our view is that the Council have applied an overly optimistic development trajectory for the delivery of strategic sites, both in terms of the start date for completions and the expected build out rates. Accordingly, we would encourage the Council to increase the balance of small and medium sized sites around higher tier settlements, which can deliver quickly and usually require limited intervention to infrastructure. This would also provide a greater degree of flexibility for the plan in the event that strategic sites are delayed.

2.3.16 Given the absence of any similar strategic sites in Tunbridge Wells Borough, as a point of comparison one could have regard to similar scale delivery in neighbouring authority Tonbridge and Malling Borough. In this respect, we provide evidence below of its three key strategic sites and the associated delivery rates (derived from the Tonbridge and Malling BV Annual Monitoring Report 2017).

2.3.17 Kings Hill is an extremely prudent example to consider in the context of the Paddock Wood extension and new garden village at Tudeley, how deliverable this would be. Indeed, Kings Hill was a new village which started in 1989, near land previously occupied by RAF West Malling. The concept was for a multipurpose site of both residential and office business space. The development is still being delivered some 30 years later, despite having multiple national housebuilders delivering different phases concurrently. Based on the most up-to-date delivery data for the last decade, Kings Hill has only delivered 131 dwellings per annum. Furthermore, the earlier delivery phases were delivered at lower rates given the need to front load infrastructure.

2.3.18 Therefore, we consider that whilst some development may come forward in the plan period from the two proposed strategic sites, in reality these strategic allocations are longer terms aspirations that will extend beyond 2036.

2.3.19 Accordingly, we would encourage the Council to allocate additional sites, which can deliver quickly and usually require limited intervention to infrastructure, particularly sustainable settlements such as Cranbrook and to reduce the reliance upon Tudeley within this current plan period.

2.3.20 Within section 3.5 we illustrate opportunities within our client’s land to deliver more homes than currently permitted by the draft allocation. These homes would deliver early in the plan period and help to ensure the plan is effective.

[TWBC: see full representation and separate Appendix (a) and Appendix (b)].

DLP_6032

Mr C Mackonochie

Object

Policy Number: STR1

1. c ‘A prestigious new business park will be located north of North Farm/ Kingstanding Way etc.’ this is in AONB. Yet elsewhere in the Plan it is stated that AONB is the last type of land to be considered for development

Also there is a presumption that no building should be carried out in the AONB and yet guidelines are produced for building in the AONB

2. No mention is made preventing the coalescence of Paddock Wood and Five Oak Green nor that building on the east side would require less flood measures than the west side or East Capel

3. Mention is made of flood-risk measures, at present the only flood measures required in Tudeley is ensuring the highways’ gullies are cleaned. However housing may well producing flooding that will required measures

6. This is in contradiction to the adopted Core Strategy recognises that rural settlements are least able to support sustainable development

7. However this release of Green Belt can/will lead to the creation of a city with Tunbridge Wells, Southborough becoming suburbs

8. A similar statement should be made about Green Belt

DLP_4261

RTW Civic Society

Support with conditions

Para 4.38 We support the adoption of Option 3 – dispersed growth across the borough.  Our remit is to the town of Tunbridge Wells so we feel it is for others to comment on where non-town developments should be.

para 1a.   Subject to the reservation re Vision, we welcome the intention to achieve “extensive infrastructure, including public realm enhancements”.  We believe there is already a substantial deficit in basic infrastructure and the state of the public realm requiring to be addressed, in addition to needs arising from increases in population and employment under the Plan.  The implementation of the high standards described here will require much better integration and attention to detail than we have seen recently (eg. in the public realm works in the town centre).

Para 1b needs amendment to reflect recent Council decisions.  For example “new theatre” should be reworded as “new or upgraded theatre, or community performance space”, or similar.

DLP_4316

Town and Country Planning Solutions for Gleeson Strategic Land

Object

  1. These representations are submitted on behalf of Gleeson Strategic Land (Gleeson) and relate to the Borough Council’s proposed Development Strategy set out in draft Policy STR1 (Development Strategy) of the Consultation Draft version of the Borough Local Plan (2016 – 2036) published on 20th September 2019. Gleeson object to the Council’s draft Policy in being fundamentally flawed in failing to have regard to all options to accommodate future growth and a failure to properly assess and give appropriate proportional weight to alternative sites suitable for housing, and in particular, land at Sandown Park on the northern side of Pembury Road at Royal Tunbridge Wells (RTW).
  2. Gleeson welcome the Council’s intention to meet in full the Borough’s Objectively Assessed Housing Requirement over the period 2016 – 2036 for 13,560 additional dwellings (at an average of 678 dwellings per year) based upon the 2014 household projection. It is also noted that the draft Plan aims to deliver a total 14,776 dwellings so as to provide a 9% buffer should some of the sites not come forward or where the delivery might be delayed to beyond the Plan period.
  3. It is clear that while the focus should rightly be upon making the best use of previously developed and underutilised land within the existing ‘Limits to Development Boundaries’ (LBDs) of settlements, the Council’s housing requirement cannot be met without expanding suitable settlements and without releasing currently undeveloped (green field) land. Within this context it is also noted that the opportunity for accommodating growth and in particular, the housing requirement, are constrained by 22% (7,134 hectares) of the Borough being within the Green Belt and 69% being washed over by the High Weald Area of Outstanding Natural Beauty (HWAONB). Given these policy and landscape constraints (and given that 74.5% of the Green Belt is also within the HWAONB), it is also inevitable that to meet housing requirements, some land will need to be released within the Green Belt and also at sustainable locations within the HWAONB.
  4. In addition to these constraints, it is also noted that some 7% of the Borough is affected by Zone 3 flood risk and that options for meeting sustainable growth required within the areas of the Borough that are both outside the Green Belt and HWAONB are limited.
  5. In producing the ‘Issues and Options’ consultation document in May 2017, the Council identified six possible options for meeting such needs or indeed, a combination of such options. The Distribution of Development Topic Paper (September 2019) confirms (at paragraph 5.5) that the option identified to potentially deliver development along the A21 on the eastern side of RTW as a ‘Growth Corridor’ was by far the most supported of the options by respondents (60%).
  6. The Council’s current Core Strategy Development Plan Document adopted in June 2010 recognises RTW (together with Southborough) as the ‘Main Urban Area’ as being by far the most sustainable settlement in the Borough with a wide range of facilities and which the former South East Plan (May 2009) recognised as performing an important role as a ‘Regional Hub’. Indeed, the former South East Plan identified a need to review Green Belt land around RTW and Southborough as a potential location to accommodate future development needs in a sustainable manner.
  7. Given this background, draft Policy ST1 – Development Strategy, is seriously flawed by seeking to adopt a proposal for the expansion of Paddock Wood (including removal of land from the Green Belt), the creation of a new settlement at Tudeley Village (again including removal of land from the Green Belt) and by proposing a ‘dispersed housing growth strategy’ involving the spreading of housing allocations across the Borough, that includes 13 sites amounting to what the Council accepts would amount to ‘major’ development in the HWAONB.
  8. The ‘Distribution of Development Topic Paper’ (September 2019) seeks to justify the Council’s approach. Paragraph 6.13 provides a hierarchy of sustainable deliverability with the priority being to meet the Borough’s development needs by making the best use of land within built up settlements and where appropriate, by increasing densities in town centres and locations well served by public transport. Given that it would not be possible to meet future development requirements by this approach alone and while the Topic Paper includes an assessment of Option 1 (Focused Growth), Option 2 (Dispersed Growth) and Option 5 (New Settlement) previously identified in the Issues and Options Consultation Documents, there is no detailed assessment of Option 4 (Growth Corridor) notwithstanding that this approach was the most supported in the consultation response.
  9. Moreover, notwithstanding that RTW (with Southborough) is by far the largest and most sustainable settlement within the Borough, there has been no joined- up approach in assessing housing potential on sites around the eastern side that are also located within the potential A21 Growth Corridor, and this potential has not been assessed or weighed against alternatives. Instead, the Council’s Green Belt study (Final Report dated July 2017) has in the main, ruled out the release of Green Belt land for housing purposes on the eastern side of RTW because of the claimed effect of this being ‘high’ when assessed against Green Belt Policy functions set out in paragraph 134 of the National Planning Policy Framework (NPPF) February 2019.
  10. A clear example of this is the land being promoted for housing purposes by Gleeson at Sandown Park on the northern side of Pembury Road at RTW. Gleeson’s proposals are shown on an illustrative masterplan (Appendix 1) submitted to the Council previously, which should be considered in conjunction with other detailed supporting documents submitted as part of Gleeson’s other representations in relation to the Council’s Strategic Housing and Employment Land Availability Assessment (SHELAA) documents (August 2019) and Appendix 6 of the draft Local Plan (regarding site no. 99).
  11. While this proposal would result in the removal of some 3 hectares of Green Belt land in order to provide 70 – 80 dwellings, this can be achieved in the form of a minor urban extension that would round off development within this eastern part of Tunbridge Wells. This can also be achieved without giving rise to any harm to the extent of the retained Green Belt land that would continue to prevent the urban coalescence of Tunbridge Wells with Pembury, which is located on the opposite side of the A21 to the east.
  12. As part of Gleeson’s proposals, some 3.3 hectares of associated land located between the proposed housing allocation and the A21 would be retained within the Green Belt, but managed and enhanced by new structural landscape planting and set aside for informal recreational use. This would therefore, not only retain the land’s Green Belt function, but would also make compensatory strengthening improvements by landscape enhancement and future management, as well as providing new public access on informal open recreational space.
  13. For reasons set out in other current representations submitted by Gleeson, the Council’s Green Belt Study is seriously flawed in the way that it has assessed the potential of the land for housing purposes, because it assumes the removal of all of the Green Belt land between the current built up confines of RTW and the A21 Pembury by-pass and by concluding that the degree of harm would be ‘high’. As the Council was already aware from previous consultations with Gleeson in relation to this site, this is not what is being proposed and the Gleeson scheme has not been assessed in any fair, reasonable or proportional way, nor has it been assessed against the much greater potential harm of removing land from the Green Belt at a wholly unsustainable location at Tudeley Village (which has also been assessed in the Green Belt Study as also having a high adverse impact), or proposals that would result in ‘major’ development on land within the HWAONB contrary to paragraph 172 of the NPPF.
  14. The Council’s proposed Development Strategy should therefore, be reviewed in order to assess the full potential of the releasing Green Belt land around RTW within the A21 corridor, as one of the most sustainable options to help meet the housing requirement, before considering and assessing other less sustainable options such as removal of the land from the Green Belt at more remote locations or by releasing the land for a major development within the HWAONB.

List of Appendices

1. Illustrative Masterplan Drawing no. 1232/02. 

DLP_5807

Weald of Kent Protection Society

Object

Policy STR 1 The Development Strategy:

Development will be provided across the borough on the following basis:

8 paragraphs containing specifics about where development is to be delivered.

Para. 6 (page 43 of the PDF) ‘Development at the other settlements across the borough within their respective limits to built development boundaries and through delivery of allocations as per Table 3 below, and other suitable windfall developments.’

’Other suitable windfall developments’ is not defined anywhere in the Local Plan. As written, any piece of land anywhere could be regarded as a suitable windfall development site.

We request a definition of the term ‘other suitable windfall developments’ within the Local Plan.

Policy STR 1 The Development Strategy:

Para 8 (page 43 of the PDF): ‘Where major development is provided for at specific identified sites in the AONB, this is only where the tests set out in the NPPF are met.’

  1. This is a broad-sweeping presumptive statement. The tests to meet the NPPF have not and cannot be met because major development is not permitted in the AONB.

DLP_5995

Pro Vision for Cooper Estates Strategic Land

Object

Policy STR1 sets out the scale of development required across the plan period to meet the identified needs of the borough but does not contain an explicit numerical housing requirement for C2 use development.

This policy would therefore not address the need for C2 use development in the Borough across the plan period.

The policy (like Policy H9) does not bring forward the need for housing for older people as identified in paragraph 2.30 and 2.31 of the draft Local Plan, does not support the evidence base on the need for C2 use development in the Borough across the plan period, and does not comply with policy in the NPPF or guidance in the PPG (as set out in full in the comments to policy H9-Housing for Older People).

Policy STR1 also sets out the proposed development strategy to meet the housing growth needs of the borough based on Option 3 (dispersed growth) and Option 5 (new settlement growth), as also explained at paragraph 4.38 of the draft Local Plan.

C2 use development, for example in the form of ‘care communities’, generally requires a critical mass of units of at least 60 or above (and usually 100 plus). Notwithstanding the failures in our comments on Section 2, Paragraph 4.7 and Policy H9, the dispersed growth strategy fundamentally anyway limits the number of large housing sites that the Plan allocates and therefore will inherently provide a barrier to the delivery of C2 use development. In contrast Option 1 (focussed growth) or Option 2 (semi-dispersed growth) would allow a greater number of larger sites to be allocated which are more likely to be suitable for C2 use development and as well located in more sustainable locations at or next to higher tier settlements, such as Royal Tunbridge Wells rather than across the Borough’s rural areas under the ‘dispersed growth’ strategy.

Option 5 (new settlement growth) might allow in principle some opportunity for C2 use development because of possible larger scale housing site allocations (though there are no specific proposed C2 site allocations at the new settlement in the draft Local Plan). It would nonetheless limit the opportunity to just one area of the Borough when it is clear from the Councils own evidence base and the draft Local Plan itself that meeting the accommodation and care needs of older persons is a Borough wide objective. Furthermore, it is also clear from the Council’s own evidence base that the proposed new settlement is significantly influenced by development constraints and may not be deliverable in whole or in part, for example because of acknowledged serious flood risk.

DLP_6026

Kember Loudon Williams for Cranbrook School

Support

This submission is made in response to the Tunbridge Wells Borough Council’s (TWBC) Consultation Draft Local Plan (Regulation 18). It is made by Kember Loudon Williams on behalf of the Trustees and Governors of Cranbrook School.

A separate report has been prepared to accompany these representations (See Chapter 3), which supports Cranbrook town as a suitable and sustainable location for a modest amount of additional housing to that which is currently allocated.

[TWBC: see full supporting statement. Chapter 3 is copied below]:

3 Strategic Growth

Relevant Policies: STR1, STR/CRS 1 and Key diagram 4. Housing

3.1 Policy STR1 of the Tunbridge Wells Borough Council Local Plan Regulation 18 Consultation details the development strategy for the Borough. Part 5 of the Policy lists the Parish of Cranbrook and Sissinghurst as being suitable for further housing development and table 3 lists the proposed allocations for housing as a maximum of 803.

3.2 For the reasons set out in Chapters 6 & 7 (Big Side and Rammell Field), we consider there is the potential to increase the total housing allocations in Cranbrook in the region of 50-60 more dwellings. The first opportunity is to extend the proposed housing allocation at Big Side Playing Field to the north of the town by 10 dwellings in order to accommodate up to 25 units; and the second is to reconsider part of Rammell Field as a suitable housing site for 40-50 units.

3.3 The development strategy (STR1) has already recognised Cranbrook as being a sustainable location for new housing due to the range of services and facilities offered within the town. In addition, being located outside of the Green Belt, Cranbrook is considered more suitable for new development than many other locations in the Borough.

3.4 Rammell Field is considered well suited in terms of its central location to accommodate new local needs housing, particularly in light of the surrounding residential character to the site and, potentially, playing a key role in supporting local housing needs – discussed more fully in Chapter 7. Although the site is proposed as a Local Green Space designation under the Regulation 18 consultation we are objecting to this classification for the entire site, and would argue that a part green space allocation and part housing allocation, to include affordable and local needs housing, would make more efficient use of land within this central location, whilst representing an overall gain to the local community.

3.5 The north/east corner of Big Side Playing Field, to the north of the town, has already been considered as a suitable site for a housing allocation of up to 15 units. However, given the proposed location of housing has already been accepted here within the Draft Local Plan and would already involve the partial loss of a playing field, in our view, it would make sense to expand the housing allocation to reach a capacity of up to 25 dwellings. Chapter 6 considers this proposition in more detail in relation to draft allocation AL/CRS 2 and the option of being able to replace the displaced playing pitch in a more suitable location closer to the School.

3.6 The Key Diagram Figure 4 of the Draft Local Plan illustrates the spatial strategy and broad distribution of housing development across the Borough. In light of the above comments, we propose this Diagram be updated to reflect the additional growth proposed at the Big Side and Rammell Field sites. We also seek an amendment to Table 3, which follows Policy STR1 and identifies the scale and distribution of development. To account for the additional development in Cranbrook being sought through our representations we seek an increase to the current maximum number of allocations provided for the settlement of Cranbrook of up to 863 units.

3.7 In line with the above proposals we recommend Part 1 of draft Policy STR/CRS 1 (The Strategy for Cranbrook and Sissinghurst Parish) also be updated to reflect the 50-60 additional housing units proposed to be accommodated in Cranbrook. We refer to part two of the policy which acknowledges that additional housing to the draft allocations may be delivered through the redevelopment of appropriate sites and other windfall development. Given the number of additional units proposed at Rammell Field, we consider it appropriate to include this site as an additional allocation, under Part 1 of the Policy.

Playing Fields

3.8 Cranbrook School has a rich sporting heritage and the School is committed to ensuring that sport continues to thrive in the future. The School continues to successfully compete with the best locally available School opposition (including larger independent Schools) and the keen intent, high quality facilities and teaching is a major contributing factor to the School’s appeal for boarders. It is therefore vital that the School continues its commitment to improve the existing sports equipment and facilities.

3.9 Three of the sites we are promoting/supporting through this Local Plan process involve existing playing fields, two of which are already proposed to be allocated in part for some housing development in addition to the retention of the majority of the respective sites as playing fields. It is therefore important we consider the national guidance relating to proposals which affect existing playing fields, as part of our representations for these sites.

3.10 It should be noted that Sport England’s policy is to oppose the granting of planning permission for any development which would lead to the loss of, or prejudice the use of, all or any part of a playing field, unless one or more of the five exceptions stated in its policy apply:

Sport England Policy

Summary of Exceptions

 

Sport England Policy

 

Summary of Exceptions

E1

An assessment has demonstrated that there is an excess of playing fields in the catchment and the site has no special significance for sport

E2

The development is ancillary to the principal use of the playing field and does not affect the quantity/quality of pitches

E3

The development only affects land incapable of forming part of a playing pitch and

would lead to no loss of ability to use/size of playing pitch

E4

Playing field lost would be replaced, equivalent or better in terms of quantity, quality and accessibility

E5

The proposed development is for an indoor/outdoor sports facility of sufficient

benefit to sport to outweigh the detriment caused by the loss of playing field

3.11 In this case of Rammell Field, Jaegers Field and Big Side Field the main exceptions are likely to fall under ‘E1’ or ‘E4’.

3.12 The school is committed to improving its facilities including the quality of sports provision. Currently playing fields are dispersed and fragmented which is not ideal in terms of overall efficiency, pupil safety and maintenance. There are opportunities to consolidate and improve the quality and quantity of pitches and for pitches to be provided more centrally within the campus. This may include opportunities to create additional levelled playing pitches on land adjacent to the ‘grounds maintenance complex’ as well as potential opportunities to look to expand the land available in these locations.

3.13 In the case of Rammell Field, our proposal will result in the loss of a playing pitch which may need to be relocated elsewhere subject to further analysis. However, there will be general recreational provision provided in the form of the open space to be retained at the north of the field, fronting Bakers Hill. This recreational space will now be publicly accessible which will be a major benefit to the community.

3.14 The school intends to produce a comprehensive Playing Fields Assessment and Strategy in due course that would inform future planning applications on all three sites.

DLP_4657

CBRE Ltd for Dandara Ltd

 

Draft Local Plan Policy STR1: ‘The Development Strategy’ 

3.39 Policy STR1 sets out TWBC’s broad development strategy for development within the Plan period. Dandara supports the general borough-wide release of suitable Green Belt land to provide new housing, employment opportunities and social infrastructure.

3.40 In relation to Part 1 of Policy STR1, Dandara supports the planned expansion of the Main Urban Area of Royal Tunbridge Wells and the opportunity to deliver new homes at Spratsbrook Farm, on the south-western periphery of the Town.

3.41 With regard to Part 2 of Policy STR1, comprising the expansion of Paddock Wood, Dandara supports this and welcomes the opportunity for housing and employment growth.

3.42 With regard to Part 3 of Policy STR1, and the proposed new garden settlement at Tudeley Village, as explained above Dandara is concerned about the extent to which it is being relied upon to contribute to meeting identified development needs within the Plan period, and the timing of delivery as set out in TWBC’s housing trajectory.

3.43 It is considered that the policy and trajectory in relation to Tudeley Village needs to be robust and demonstrable of delivery. It may therefore be necessary to amend the yield within the Plan period as part of ensuring that any allocation for Tudeley Village satisfies the appropriate policy tests in accordance with paragraph 23 of the NPPF.

3.44 Dandara supports Part 4 of Policy STR1 and the proposed new housing growth and social infrastructure at Hawkhurst.

3.45 Dandara welcomes Part 5 of Policy STR1 and the proposed growth around Cranbrook itself, Sissinghurst, and at Hartley.

3.46 Further comments in respect of Policy STR1 are provided in Section 4 within the Site Specific Representations.

[TWBC: see full representation].

DLP_4464

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.

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.

Building upon sites presently prone to flooding 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.

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.

In addition –

Policy STR 1: 2 – The Sports &Recreation group welcome the inclusion of the sports hub but it should be explicit that this is an outdoor sports hub & should be called just that, as the NP proposes development of Putlands to include indoor sports and a swimming pool.

In 4.41 Table it identifies a swimming pool in the Paddock Wood/Capel area, but this is not reflected in the policies specific to Paddock Wood.  Under Paddock Wood Overview it explicitly states there is no swimming pool – this has been the number one facility requested by PW residents for many years past, which we have included in the Neighbourhood Plan and we would like to see it identified explicitly in the Local Plan.

A 2-4-6 athletics training track is also located on the Putlands Field.  The Neighbourhood Plan group supports the development of this to 6 lanes all round to enable athletic competitions to be held.

DLP_5108

Mr Peter Brudenall

 

I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB.

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents.

I believe that the Council’s conclusion (for example, at Paragraph 4.34) that the sites identified for mass housing estates are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper.

The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false.  The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections).  I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions.

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst.  A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion.  We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned.  The village has already been seriously impacted.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments.

Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed.

For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations.  The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place.

It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them.

The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:

  1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan;
  2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point.

[TWBC: see also Comment Number DLP_5110 - Policy STR/HA 1].

DLP_5176

Bloomfields for Fernham Homes

 

Development Strategy and Strategic Policies (Policy STR1)

The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the borough and where that development will be located.

In terms of the amount of housing, paragraph 59 of the NPPF states that to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed. Further, to determine the number of homes needed, strategic policies should be informed by a local housing needs assessment conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.

The Council confirm that their housing need target for the plan period 2016-2036 is 13,560 dwellings (678 dwellings per annum), which is calculated using the Governments standard method and the 2014-based household projections.

In terms of the different supply components, the Council considers that the Local Plan must (as a minimum) include additional allocations to accommodate 7,593 homes. This figure was formulated taking into account; completions since April 2016 (1,552); extant planning permissions (3,127); outstanding site allocations (588) and a windfall allowance (700 dwellings). The Council have applied a 10% non-delivery rate to these figures to err on the side of caution and consider that the plan would exceed the minimum housing requirement if all of the supply components were achieved.

The general principle of proportionately spreading the benefits of growth is supported. Adopting a pattern of dispersed growth approach would allow a number of sites to be developed at the same time, serving different areas of the Borough and segments of the local housing market, which is preferable to saturation of the market in a single area.

Tunbridge Wells is a constrained Borough. There are a number of archaeological and heritage sites, including 45 Historic Parks and Gardens, 25 Conservation Areas and 11 Scheduled Ancient Monuments. In addition, there are approximately 3,000 Listed Buildings. The landscape of the High Weald AONB contains numerous historic landscape features, including field patterns, settlements and ancient woodland, whilst the borough also hosts a number of, or is close to, areas of ecological importance. These include:

(1) Ancient Woodland (approximately 16% of the borough)

(2) Circa 60 Local Wildlife Sites (approximately 11% of the borough)

(3) Ten Sites of Special Scientific Interest (SSSI)

(4) Five Local Nature Reserves (including one Community Woodland)

(5) One Regionally Important Geological Site, at Scotney Castle Quarry.

The nearby Ashdown Forest is a designated Special Area of Conservation (SAC) and Special Protection Area (SPA). Although not an environmental constraint, the Metropolitan Green Belt covers 22% of Tunbridge Wells Borough. Given these constraints, it is acknowledged that planning for housing requires the need to balance a number of core environmental and planning matters in order to reach a sensitive future development strategy.

Accordingly, the Council is encouraged to increase the number of medium-sized sites, particularly in sustainable settlements such as Sissinghurst where there is none or minimal impact upon key environmental landscape designations. Such sites could be delivered quickly, particularly as there will be limited intervention to infrastructure. Furthermore, it is essential that draft allocations such as AL/CRS14 are retained and encouraged given the advancement of planning applications emphasises the deliverability of the land.

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

DLP_3772

Mary Jefferies

Object

Policy Number: STR 1

It appears that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019)..

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents.

The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions.

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments.

Given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them.

The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:

1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan;

2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point.

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village.

The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan.

There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development.

Non-compliance with Hawkhurst Neighbourhood Development Plan

The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment.

Lack of adequate infrastructure

Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment.

Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents.

There are very limited local employment opportunities and no secondary schools within walking distance.

The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution.

The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it.

TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103).

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has objected to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF.

The “relief road” will not work

The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny.The TWBC Local Plan has not considered the wider impact on Hawkhurst’s traffic problems with the propsed development in neighbouring areas such as Hartley and Cranbrook.

As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes.

DLP_3833

Liane & Alan Chambers

Object

Policy Number: STR1

The policy sets out the intention to provide for the predicted development need of the Borough. However given the NPPF policy set out in para 1.29, there does not appear to be sufficient justification for this approach given the landscape and infrastructure constraints of the Borough.

Paragraph 4.8 points out that Sevenoaks Borough, with similar constraints, is not seeking to meet its own housing needs. Tunbridge Wells Borough Council should take a similar approach and encourage the Government to seek a housing strategy that is less dependent on significant further house building in the South East.

We do not agree with the proposals for Hawkhurst. The village cannot cope with the housing allocation put forward in the plan. The proposals for a relief road would add to traffic congestion, air pollution and adversely affect the quality of life of the residents.

Both the proposed housing and road would significantly affect the Area of Outstanding Natural Beauty (AoNB) and is contrary to provisions set out in the national guidance. Paragraph 172 of the National Planning Policy Framework (NPPF) states that major development in an AoNB should be refused “other than in exceptional circumstances”.

Please note that unlike Paddock Wood and Cranbrook, Hawkhurst is a village not a town.

DLP_3981
DLP_3938
DLP_3906
DLP_3887
DLP_3955
DLP_3864
DLP_4066

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

Object

TWBC: the standard response was submitted by the list of responders on the left:

Policy Number: STR 1

I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB.

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents.

I believe that the Council’s conclusion (for example, at Paragraph 4.34) that the sites identified for mass housing estates are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper.

The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is totally disingenuous. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions.

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments.

Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed.

For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place.

It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. This is exemplified by the omission to mention sewage treatment under topics of infrastructure provision on the display boards used in the recent exhibitions. Those responsible for producing this information should be severaly censured for this omission.

The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:

1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan;

2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point.

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village.

The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan.

There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development.

Non-compliance with Hawkhurst Neighbourhood Development Plan

The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment.

Lack of adequate infrastructure

Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament.

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment.

Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents.

There are very limited local employment opportunities and no secondary schools within walking distance.

The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution.

The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it.

TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103).

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has objected to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF.

The “relief road” will not work

The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny.

If the ‘relief road’ is planned as a standard 7.3m single carriageway then any parking or other temporary obstruction will result in no improvement whatsoever. The suggestion that HGVs etc will turn right at the roundabout at the southern end and then proceed westwards towards Flimwell cross roads will be exposed as totally flawed unless significant property appropriation is made. It should not be forgotten that this section of road lies within a different county boundary who may hold higher priorities for road improvement provision. 

The expectation that large vehicles would be able to make a left turn under the current geometric circumstances would be revealed as over optimistic. In addition congestive build up of traffic at this cross roads will lead to further delay and disruption resulting in traffic resorting to the use of the cross roads in the centre of the village. Under these circumstances the term ‘relief road’ is something of a misnomer.

As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes.

DLP_4387

Mill Lane and Cramptons Residents Association

Object

Key Diagram and Policy STR1.

We do not agree with Sissinghurst (Item 5) having so much proposed new growth.

We have already had a large development of 60 new houses off Common Road and other new dwellings in Cobnut Close and Church Mews in this small village that has minimal facilities.

DLP_4406

Alison Adams

Object

I am a resident of Horsmonden and have lived here for the last 6 years.  During my time I have been the Chair of the local Horsmonden Kindergarten and I have been very busy renovating my home and garden.  I love living in this village with its community spirit and feel very involved and integrated in the society here.

Although I appreciate that new housing is inevitable and do not object to sensitive and structured new building I am concerned greatly by the idea of large scale new development which does not take into account the requirements of the existing community or the actual requirements of the prospective purchasers of the homes.

Horsmonden like most villages provides a mixture of housing and there are many residents living here who do not foresee living anywhere else. Houses however do come onto the market and at present there are a number in the village that have been up for sale for over a year. My question is therefore, how have the “powers that be” come up with the decision that we need to create 13,560 new homes (Para 4.7)?  If we do need these homes I sincerely hope that the main priority is to create homes that will fulfil the specifications that these new prospective owners are looking for.  In my view one of the biggest problems that we face is that large family homes continue to be occupied by parents well after their children have left, couples in their 60s, 70s and 80s are reluctant to downsize due to the lack of smaller but prestigious, spacious, convenient houses/apartments/bungalows that also offer attractive outside space. This creates a barrier to the upward movement of younger families who wish to gain more space.  Space in the South East is at a premium so there needs to be some incentive to free up these family homes for the new generation.

I would also like to be 100% certain that the companies that are employed to build all these new homes are actually controlled so that the new homes are good quality and sustainable with eco-friendly initiatives being used. Why is it not compulsory to have solar panels, permeable paving, grey water storage?  All these design features are available and if every builder was enforced to use them there would be economies of scale so the price of these technologies would ultimately come down.

In terms of the Consultation I would like to comment on the following:

STR1 - The Development Strategy – In particular HO1 Horsmonden Parish

Para 4.38 talks about dispersed growth – this option however will put an enormous strain on minor country roads which are already dangerous and have very limited public transport.  The essence of village life is that the community should feel comfortable walking to the village shop, to school, to meet with friends and to take dogs for walks.  With the increasing number of cars and lorries on the road this pleasure turns to a nightmare. In May this year an elderly lady, my neighbour, was knocked down by a car outside my house. She spent 5 months recovering. Such incidents will only increase with the increased volume of traffic.  Despite the seriousness of this incident nothing has been done to promote new pavements and make the village centre safer.  How are we supposed to feel confident about future development when problems that already exist are not taken seriously or mitigated by the local authority

It is not just the cars owned by the people moving into the new properties that put a strain on the roads.  Horsmonden is not on mains gas so most householders require oil to be delivered for heating. The 265 proposed extra homes will need more oil tankers to name but one of the many knock-on effects rural housing will create.

I appreciate the opportunity to comment and hope that the Borough Council will take into account the many and varied views of the people of the borough.  Maybe building thousands of new homes will boost the economy in the short term but once built these homes cannot be removed so let’s hope there is a real demand and that the houses built actually satisfy that demand.

DLP_4443

James Whitehorn

Object

a] I disagree with the fundamental assumption that we need another 13,560 houses in the borough over the 20 year plan period, 678 per annum. From the Housing Needs Assessment Topic Paper there were evidently 47,174 households in 2011 [Census figure] and Dr Bullock [Housing Needs Study 2018] assumed a total of 49,442 households and 48,559 dwellings in 2018, an increase of 4.8%. However an extra 13,560 houses represents a massive 28% increase over the 18 years from 2018-36.

b] According to Dr Bullock, the population of the borough was estimated to be 117,700 in 2017 and projected to increase by 9.4% to 128,800 in 2033. He also projects the total number of households will increase by 15.5% from 49,904 to 57,661 in 2033. More recent Govt data suggests a potential 6.4% population increase in the South East from 2016-26, but there is no reliable data available for the next decade up to 2036. The Local Plan should acknowledge this uncertainty and include a range of options for future housing provision rather than attempting to meet an unproven demand.

c] There is no explanation offered in Dr Bullock’s report to justify the assumed population increase or to explain where all these extra people will be coming from. It can partly be attributed to a larger number and increasing proportion of older people, but if we build many more houses at the right size and price then, in addition to addressing a backlog need, we will also attract more people into the borough. If on the other hand we allow an incremental rise in housing stock primarily through windfall sites we could potentially meet much of the internal and backlog need without encouraging net migration into the borough.

d] Our highway infrastructure especially on the primary routes through Royal Tunbridge Wells is already way over capacity for much of the day. If we build an extra 13,560 houses over the Local Plan period with a typical 1.4 cars per household in the South East, we could be adding around 19,000 extra cars to our already overloaded network. The additional car trips would create misery for existing and new residents alike.

DLP_4590

Keith Stockman

General Observation

Policy STR1 c. A prestigious new business park will be located to the north of North Farm/Kingstanding Way that is well connected to the improved A21, providing a range of employment floorspace and jobs to meet identified needs. The site will make a substantial

contribution to the need for new employment space over the plan period. Other employment, including leisure development, will be encouraged at North Farm/Kingstanding Way;

It is ridiculous that, given the location of the new employment, large scale development is proposed for Cranbrook & Sissinghurst, which is 15 miles or more from the new employment areas. Inevitably, it will lead to a huge increase in car usage on a road system which is already struggling to cope. I object most strongly to the proposed development for this and other reasons.

DLP_4646

Ann & John Furminger

Object

Policy Number: STR1 c

Areas for development of employment opportunites to serve the housing in Cranbrook and Sissinghurst are 14miles away and are supported by completely inadequate infrastructure, This does not make sense as puts more strain on already stretched infrastructure.

DLP_4728

Mike & Felicity Robinson

Object

Policy Number: STR 1

We understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB.

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents.

We believe that the Council’s conclusion (for example, at Paragraph 4.34) that the sites identified for mass housing estates are “suitable for development” prejudge issues which properly fail to be considered during the planning approval process, and that this is improper.

The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions.

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments.

Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed.

For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place.

It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them.

The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:

1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan;

2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point.

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village.

The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan.

There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development.

Non-compliance with Hawkhurst Neighbourhood Development Plan

The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment.

Lack of adequate infrastructure

Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament.

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment.

Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents.

There are very limited local employment opportunities and no secondary schools within walking distance.

The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution.

The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it.

TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103).

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF.

The “relief road” will not work

The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny.

As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes.

DLP_4765

DHA Planning Ltd for Caenwood Estates and Dandara

 

Comments on Policy STR1

3.3.7 The strategy is consolidated by Policy STR1, which sets out the quantum of development that will be allocated within or around settlements to meet the identified needs of the borough over the plan period. This strategy would seek to meet the majority of the Council’s housing need through the strategic extension of Paddock Wood and via a new Garden Village at Tudeley. The remaining growth would then be dispersed proportionately to other settlements in the borough.

3.3.8 We have no objection to the overall thrust of the strategy and adopting a pattern of dispersed growth given that it would spread the benefits of growth to more locations than in previous plan periods. Furthermore, adopting a pattern of dispersed growth approach would allow a number of sites to be developed at the same time, serving different segments of the local housing market, which is preferable to saturation of the market in a single area.

3.3.9 However, we are concerned that the overall balance of this strategy is wrong, and that a greater proportion of development should be directed towards the Borough’s main settlement at Royal Tunbridge Wells. This is a sustainable location for growth, being the main focus in the borough, and indeed the wider region, for employment, retail, education, services and local public transport.

3.3.10 We agree that the strategic growth proposals at Paddock Wood are also sustainable, but the proposals at Tudeley are much less so. In our view the development quantum proposed at Tudeley should instead be reallocated elsewhere, with a large proportion going to Royal Tunbridge Wells.

3.3.11 Whilst we recognise the wish to make various improvements to strategic transport links and education provision at Tudeley, these are complex, high cost items that will not be quick or easy to deliver. These include:

  • Delivery of the A228 Strategic Transport Link (the Colts Hill bypass), a proposal which has been discussed for several decades but which, despite proposals being drawn up in the early 1990s, has never come close to materialising;
  • Significant upgrades to various local junctions;
  • The creation of a new, thus far unplanned, bus only link between Paddock Wood and Tudeley; and
  • A new, thus far unplanned, cycle link between Paddock Wood and Tudeley;
  • New primary and secondary schools;
  • Potentially extensive flood mitigation measures; and
  • The creation of additional wastewater treatment capacity.

3.3.12 Despite the railway running through the site, there are no plans for a railway station to serve the new settlement. The reality is that the garden village at Tudeley is in danger of being an unsustainable suburban development without the benefit of good connections to existing development and services. There are also substantial concerns in relation to flood risk.

3.3.13 In this regard, we question whether the proposed settlement at Tudeley meets the tests set out in NPPF paragraph 138, in particular the requirement that:

“Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.”

3.3.14 Unlike the A26 corridor, which Caenwood Farm is located on, Tudeley is not currently well-served by public transport. Whilst it is recognised that the Local Plan intends public transport improvements to be brought forward, at present at Tudeley there is usually only one bus per hour in each direction during the daytime, and no rail services. By contrast, there are nine bus services per hour serving the nearest bus stops to Caenwood on the A26 corridor, whilst High Brooms station is also within walking distance. Just like at Tudeley, there would be opportunities to further enhance public transport to serve the site. However, given the requirements of NPPF paragraph 138, we believe that if Green Belt is to be released, sites such as Caenwood Farm that are already close to a good public transport corridor should be prioritised over sites like Tudeley where there is little existing provision.

3.3.15 In any event, we have some concerns regarding the balance between strategic and non-strategic scale allocations and the anticipated delivery trajectory. For example, 65% of new allocations would be delivered as part of the strategic extension to Paddock Wood (4,000 homes) and the new Garden Village at Tudeley (1,900 homes within the plan period), both of which require a fully master-planned approach, which is a time-consuming process. Furthermore, there are a significant number of existing commitments within Paddock Wood that have been slower at coming forward than had originally been envisaged. A cautious approach is therefore needed.

3.3.16 In this regard, we would draw the Council’s attention back to the 2016 document published by Nathaniel Lichfield’s and Partners (NLP) - ‘Start to Finish: How Quickly do Large-Scale Housing Sites Deliver’, which provides evidence pertaining to the speed and rate of delivery of large-scale housing, based on a large number of sites across England and Wales.

3.3.17 It identifies that the average lead in time for the submission of a planning application is 3.9 years, from the date the site is first identified. In terms of the planning approval period, for larger scale sites (2,000 + homes) this is circa 6 years. After planning permission is granted, larger sites start to deliver within a year and the average build out rate thereafter is 161 dwellings per annum, although it can be as high as 301 dwellings per annum.

3.3.18 Figure 1 below is taken from the NLP report, which shows the average planning approval period and delivery of first dwelling by site size.

[TWBC: for Figure 1 seefull representation].

3.3.19 Whilst the NLP report does not represent practice guidance, it is widely accepted as being a reliable and credible source of evidence and is referenced by TWBC in their Housing Trajectory Paper.

3.3.20 Despite evidence elsewhere, TWBC has set a very optimistic trajectory for delivery of Tudeley Garden Village and the strategic extension of Paddock Wood, which is detailed in the Housing Trajectory Paper.

3.3.21 The Council forecasts that the Tudeley Garden Village will begin to deliver homes from 2025/26 onward, with an initial build out rate of 150 dwellings per-annum, rising to 200 dwellings per annum from year 6 onward. Likewise, they suggest that the extension to Paddock Wood will start to deliver in 2024/25 at an average build out rate of 333 dwellings per annum – which is nearly double the average rate for larger schemes identified in the NLP document. This higher build out trajectory is predicated on the basis that there would be a number of house builders involved the construction of different parts/phases.

3.3.22 Taking the above into account, our view is that the Council have applied an overly optimistic development trajectory for the delivery of strategic sites, both in terms of the start date for completions and the expected build out rates.

3.3.23 Given the absence of any similar strategic sites in Tunbridge Wells Borough as a point of comparison, one could have regard to similar scale delivery in neighbouring authority Tonbridge and Malling Borough. In this respect, we provide evidence below of its three key strategic sites and the associated delivery rates (derived from the Tonbridge and Malling BV Annual Monitoring Report 2017).

3.3.24 Kings Hill is an extremely prudent example when considering potential delivery at the Paddock Wood extension and the new garden village at Tudeley. Kings Hill was effectively a new village started in 1989 near land previously occupied by RAF West Malling. The concept was for a multi-purpose site of both residential and office business space. The development is still being delivered some 30 years later, despite having multiple national housebuilders delivering different phases concurrently. Based on the most up-to-date delivery data for the last decade, Kings Hill has only delivered 131 dwellings per annum, despite multiple developers delivering concurrently. Furthermore, the earlier delivery phases were delivered at lower rates given the need to front load infrastructure.

3.3.25 Therefore, even if the Council was to pursue Tudeley Garden Village, we consider that whilst some development may come forward in the plan period from the two proposed strategic sites, in reality these strategic allocations are longer term aspirations that, at best, are not likely to begin to deliver housing until well into the Plan period and will inevitably extend beyond 2036. This is likely to be exacerbated by the fact that, by virtue of their proximity, Tudeley Garden Village and an expanded Paddock Wood would be serving similar markets and therefore allocations there will, to some extent, be competing with each other.

3.3.26 Accordingly, we would strongly encourage the Council to make more efficient use of other medium-sized sites around the borough, such as our client’s site. As set out elsewhere in these representations, Caenwood Farm is in a highly sustainable and logical location, which can be delivered early within the plan period.

[TWBC: seefull representation].

DLP_4853

Robin & Diana Morton

Object

STR1

We strongly object to the’dispersed growth’ strategy for housing development on which the Local Plan’s development is based. There is totally disproportionate growth planned in rural v. urban areas. Horsmonden appears to have been viewed alongside other small rural villages, simply because potential sites were put forward, without our unique central crossroads being considered properly. KCC and experts can find no solution to the problem of two heavily used main roads crossing in the centre of the village, where there is no space to widen the roads, nor provide proper pavements. Neither is there opportunity to avoid the centre crossroads. The problem is major, and would be greatly exacerbated by large housing development, with the accompanying local traffic adding to the existing heavy through traffic, which has no alternative route. At best, a much smaller, mixed development, might be possible under AL/ HO 3 (sites 82, 108, 297 and 324) if safe access to the main road can be found, but this should only be maximum 100, and only that if the HO2 site falls With windfall sites at a maximum of 10% the village could grow over time, but not disproportionately.

DLP_4985

Kristina Edwards

 

Policy Number:  STR 1

I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB.

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents.

I believe that the Council’s conclusion (for example, at Paragraph 4.34) that the sites identified for mass housing estates are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper.

The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false.  The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections).  I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions.

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst.  A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion.  We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned.  The village has already been seriously impacted.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments.

Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed.

For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations.  The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place.

It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them.

The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:

  1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan;
  2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point.

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

[TWBC: see Comment Number DLP_4988].

DLP_5127

Alistair Nichols

 

I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB.

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents.

I believe that the Council’s conclusion (for example, at Paragraph 4.34) that the sites identified for mass housing estates are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper.

The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false.  The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections).  I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions.

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst.  A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion.  We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned.  The village has already been seriously impacted.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments.

Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed.

For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations.  The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place.

It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them.

The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:

  1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan;
  2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point.

[TWBC: see also Comment Number DLP_5128 - Policy STR/HA 1].

DLP_5157

Cushman Wakefield for Ministry of Justice

 

Policy Number: STR 1 The Development Strategy

This policy sets out the development strategy for the whole of the borough. It identifies locations for new development at various settlements within their ‘Limits to Built Development’ or on land identified for release for development (i.e. Tudeley Village and the release of green belt around Royal Tunbridge Wells, Southborough, Paddock Wood, Pembury and in the parish of Capel). There is no acknowledgement within this strategy that development could appropriately be brought forward on sites outside the Limits to Built Development in accordance with the NPPF or indeed other council policies (e.g. H14 and ED5). The policy is consequently unsound as it fails to accord with the approach of the NPPF which promotes brownfield development, and which clearly accepts that development in the countryside where justified by local circumstances (paragraph 79). The policy consequently needs to be amended to include the flexibility inherent in national policy and in draft local policies elsewhere in the emerging document as part of the overall strategy for the borough. We propose that an extra point be added to accept that development will be accepted outside the limits to Built Development where the relevant policy criteria are met, defining these in line with the policy approach set out in the NPPF and cross-referencing the other relevant policies in the plan (subject to our comments in respect of these policies).

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

DLP_5263

Tunbridge Wells Friends of the Earth

Object

Policy Number:  STR 1 The Development Strategy

Object , Support with conditions

We request a new calculation is made of the net “Minimum additional allocations to meet housing need” as set out in §4.12 above, as we have been made aware that these are likely too high an estimate and that when one applies the revised and updated 2016 ONS methodology, only 67% of total new development (i.e. 13,560 indicated in row 1 of table 1, §4.12) is required. This would bring down the net number of houses needed from 7,593 to 3,118.

We object to point 7 as we object to the release of Green Belt land for development. If a recalculation is done of housing needs and brownfield sites are actively located and developed as a priority, one should not need to build in the Green Belt. Even if there is no recalculation, we would still object to new development in the Green Belt.

DLP_5776

Rose Harrild

Object

I am deeply concerned with many aspects of the proposed Local Plan.

First the calculations made of the number of new homes needed by 2036 in the Borough.

Apparently the borough will require 13,560 new dwellings by 2036.Where did this figure come from? The council should robustly resist this as there are sound planning reasons to do so.

Indeed Sevenoaks District Council has done just that and is not proposing to wholly meet the figure put forward for its housing needs.

Government wording on this issue is quoted in the Development Strategy and Strategic Policies  -Section 4 of the draft local plan.It states that

4.3 " In preparing this draft local plan the council has to be mindful that national planning policy expects local plans to meet the identified level of development needs for their area in full UNLESS there are good planning reasons why this is not possible." In other words if there are sound planning reasons, this figure may not be met. And there are sound planning reasons in the borough. - there is Green Belt, High Weald AONB and villages with Limits to Built Environment.

However the next sentence does not follow on from this

"Accordingly the proposed Development Strategy indicates how the FULL development needs of the borough can be appropriately met." The Council should not be looking to meet the full development needs because of the many constraints.

One constraint on village development and enlargement is LBDs (lLimits to Built Development) - These have very successfully ensured villages do not grow too big and swamp areas of countryside. However it is proposed in many cases to change these boundaries to allow more development to occur. .This is in nearly every case completely unacceptable.

The High Weald AONB has its own restrictive policies. Yet new housing is proposed within the AONB  for example at Matfield. Again totally unacceptable.

Green Belt too has restrictive policies which have very successfully limited sprawl into the countryside and in some cases prevented the joining of settlements. Again building in the green belt should not be sanctioned.

Many of the sites put forward for possible development by the Council are therefore totally unsuitable.

[TWBC: see also Comment Numbers DLP_5777 (Brenchley) and DLP_5778 (Horsmonden).

To conclude, as it stands the Draft Local Plan is unacceptable. There are planning policies in place to resist development on the scale that is proposed. They must be used.

DLP_5932
DLP_5976

Rachel Jones
Simon Steddon and Sue Cox

Object

TWBC: the standard response was submitted by the list of responders on the left:

We writing to you to register our concerns and objections to the following:

  • the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy
  • the suitability of Lamberhurst to accommodate additional dwellings
  • the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for 30 dwellings (site reference AL/LA2).

Planning Strategy

1) The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that 60% of respondents would like to see housing growth along “growth corridors”, whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. The Council would need to be able to demonstrate that it has reacted appropriately to the consultation feedback so a far greater emphasis on growth in established centres rather than rural locations would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on private cars as a means of travel – which surely must be of paramount importance given climate change commitments.

2) With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the Limits to Build Development boundary, but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a clear and consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage. With this conflict in mind, we question the viability of the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the strategy to create relatively large developments which are not connected to the centre of the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has evolved and developed slowly over time and has a limited range of services as a result. The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal. These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops: There is only one shop in the village. The shop is very small and useful only for essentials like milk and a newspaper. The Post Office only opens for 2 short mornings a week. The nearest supermarket for a bigger shop is being Tesco which is 7.8 miles away and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service: There is only a very limited bus service for the village with irregular times. In the mornings, the bus is always full with school children which has been a topic of much public debate with support from local MPs. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work. New residents are therefore likely to be using private cars for both work and transporting children to school (as the current bus is already over capacity).

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Lamberhurst Neighbourhood Plan. The Neighbourhood Plan is promoting developments that are well designed and reflect local character. The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

DLP_6855

Barton Willmore for Crest Nicholson

 

i) Policy STR1: The Development Strategy

5.5 Policy ST1 sets out the broad development strategy for the Borough and how it intends to provide for its identified housing requirement. This focusses development in and around existing urban centres at Royal Tunbridge Wells, Southborough, Paddock Wood and Hawkhurst, with provision made for a new Garden Settlement at Tudeley – plus at smaller rural (AONB) settlements (i.e. Cranbrook, Sissinghurst).

5.6 TWBC’s “Distribution of Development Topic Paper” (TWBC, Sept 2019) provides a comprehensive overview as to the basis (and “justification”) for the spatial development strategy being pursued and helps in reinforcing the soundness of this policy.

5.7 From a transport perspective, Policy STR 1 will minimise the need to travel by increasing the capacity of Paddock Wood to serve its residents with a range of facilities which best meet local needs.

5.8 Having reviewed the housing need and supply, along with the Draft Local Plan housing trajectory [4 Housing Supply and Trajectory Topic Paper: TWBC – Reg 18 Consultation (Sept 2019)], we support the above assessment and agree that the need can largely be met within the Plan period through sites presently allocated in the Draft Local Plan, windfalls and extant permissions.

5.9 Whilst housing need is set out in Table 1, identified economic need is set out in paras 4.18- 4.23, and the means by which these will be delivered set out in Table 3 (p.43). We consider the housing and economic needs should also be specified within the text of Policy STR1 which is something which has previously been raised by Inspector’s such as in relation to Aylesbury Vale District Council’s emerging Local Plan which also had text setting out information better placed to be in the policies themselves. This is a simple change that should be readily able to be accommodated in the Regulation 19 version of the Draft Local Plan.

5.10 Table 3 of the Draft Local Plan regarding the Allocation Sites’ responsibilities under Policy STR1 states that the sites allocated around Paddock Wood are expected to make a “contribution to link to Tudeley Village”. Indeed according to the same table, development at Tudeley is not expected to contribute to highway infrastructure in its vicinity but in Paddock Wood, which suggests that this is a drafting error. We recommend that TWBC remove this requirement from the Paddock Wood area sites.

5.11 In the Draft Infrastructure Delivery Plan (TWBC, August 2019), the Five Oak Green by-pass is presented as either “a link road to the Colts Hill bypass” or “a route to Paddock Wood to the north”. It is considered that TWBC should clarify which option(s) has been modelled in the Transport Assessment Report (SWECO, Sept 2019), as the effects on the local road network and, in particular, the Colts Hill roundabout may be significantly different. It is requested that TWBC clarifies this.

5.12 The potential for the strategic growth of Paddock Wood to also contribute towards other off- site infrastructure schemes will deliver further benefits for existing and new residents, which Policy STR1 lists as including potentially the 'offline' A228 strategic link (ie. the Colts Hill bypass). Given the location of the proposed Tudeley Garden Village (Policy AL/CA1), it is considered more appropriate for the Tudeley Garden Village development to deliver the A228 strategic link scheme in its entirety given that it will serve as Tudeley Garden Village’s primary means of strategic access.

5.13 The Distribution of Development Topic Paper (TWBC, Sept 2019) outlines the sustainability scores of each settlement as outlined in the Settlement Role and Function Study carried out by TWBC in 2017 and identifies key environmental constraints, including the AONB, Green belt, flood risk, and environment and heritage designations. The document then sets out TWBC’s housing and employment land need and the five development options that were considered in the Issues and Options consultation. Taking into account the outcome of the Issues and Options in balance with the outcome of the ‘Call For Sites’, TWBC has adopted an approach that includes elements of both Option 3 (dispersed growth) and Option 5 (standalone new settlement and the expansion of an existing settlement). For employment growth the strategy has drawn from Options 1, Option 2 and option 4.

5.14 In allocating land at Paddock Wood as a town suitable for significant expansion, TWBC considered the strategy against the NPPF (para 72). The assessment concludes that Tunbridge Wells is significantly constrained by landscape and flooding designations, and that development at Paddock Wood, whilst resulting in some Green Belt release, provides a sustainable location for settlement growth that is capable of delivering a larger scale development that will meet the requirements of the NPPF (para 71), whilst not conflicting with NPPF Green Belt policy (Para 136). We agree with the conclusion of that report and support the inclusion of Paddock Wood and the associated Green Belt release. Appendix 2 contains our own detailed Green Belt Review of the sites around Paddock Wood.

5.15 With the exception of a small number of minor clarifications, we support the overall development strategy outlined in Policy STR1, which seeks to deliver the majority of new dwellings in sustainable locations with a focus on established settlements well served by public transport, or developments of a scale capable of delivering sustainable development. The Development Strategy meets the requirements of NPPF (para 103), which states that “significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes”.

[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_6403

Hawkhurst Parish Council

Object

STR1 - The Development Strategy

Hawkhurst Parish Council has significant concerns in terms of the Development Strategy. We have already outlined concerns regarding the calculation of housing numbers, the decision to adopt a dispersed growth strategy, and the lack of weight given to the AONB status of much of the borough. We believe that TWBC could significantly reduce its proposed housing numbers, whilst still meeting its obligations, and in doing so, would protect the sensitive landscape of the borough.

Throughout the many documents produced in support of the Draft Local Plan, it is repeatedly emphasised that the potential for development outside the AONB has been maximised prior to allocating sites within the AONB. It is hard to see how this can be the case when Cranbrook, Hawkhurst and Sandhurst have allocations totalling 1089 to 1561 dwellings on sites that are wholly within the AONB (not just within the parishes) compared to allocations of 1222 to 1320 and 135 to 205 for the urban areas of Royal Tunbridge Wells and Southborough respectively.

The choice to set an arbitrary figure of fewer than 10 units as the “first filtering stage” to determine allocation flies in the face of the made NDP for Hawkhurst. This conflicts with the guidance on plan-making from the Ministry of Housing, Communities & Local Government. “Where a neighbourhood plan has been brought into force, the local planning authority should take its policies and proposals into account when preparing the local plan. Local plan policies should not duplicate those in the neighbourhood plan, and do not need to supersede them unless changed circumstances justify this. It is important for local plans to make appropriate reference to neighbourhood plan policies and proposals, and similarly for neighbourhood plans to acknowledge local plan policies that they relate to.” Paragraph: 006 Reference ID: 61-006-20190723 Revision date: 23 07 2019

We doubt that Hawkhurst is the only parish to be impacted by this approach, which is concerning when the High Weald AONB Management Unit makes it clear that the High Weald AONB is a small-scale landscape best suited to small-scale development. The cut-off figure of 10 is higher than that used by other Local Planning Authorities, which is surprising given the sensitive landscape setting of the borough. This figure should be reduced to 5 units.

This is even more concerning given that these sites were excluded from the Sustainability Appraisal and, therefore, were not included in the cumulative sustainability appraisal for the parish, let alone how this would impact on neighbouring parishes. The SHELAA identifies seven such sites for Hawkhurst that are considered potentially suitable for development but have not been allocated. The majority of these would accommodate more than 5 houses. From Hawkhurst’s perspective, this is all the more concerning when sites with similar capacity have been included in the allocations for other parishes.

As noted above, the reference to the “relief” road for Hawkhurst is extremely misleading. It is an additional road within the village and all references to it as a “relief” road should be removed from the Local Plan.

We would question whether TWBC has fully discharged its Duty to Cooperate given the concerns raised by TMBC in relation to the draft Local Plan.

DLP_6989

Sigma Planning Services for Rydon Homes Ltd

Support with conditions

The reference to the Tudeley Village new garden settlement will need to be removed if, as is likely, it is withdrawn or delayed beyond the current plan.

[TWBC: See full representation].

DLP_6972

Mrs Beryl Bancroft

Object

Good policy for Tunbridge Wells Town Centre but no real policy for the Rural areas. More houses planned for Cranbrook and Sissinghurst than Tunbridge Wells but no plans for more businesses in this area. No infrastructure plans and no transport plans so that people can get to areas with increased business facilitiesfrom Rural areas. Our local school in Sissinghurst is over subscribed so children cannot walk to school. The needs of older people in Rural areas have not been recognised. Lack of affordable and smaller bungalows. No footpaths on rural roads, and no safe way of road crossing due to speed of traffic in the villages.

DLP_6257

Kember Loudon Williams for Mr R Barnes

Support with conditions

This submission is made in response to the Tunbridge Wells Borough Council’s (TWBC) Consultation Draft Local Plan (Regulation 18). It is made by Kember Loudon Williams on behalf of a private landowner, Mr R Barnes, who is seeking to promote his site at Stone Court Farm (identified as Site Number 354 in the Council’s Strategic Housing and Economic Land Availability Assessment).

Strategic Policy STR1 details the development strategy for the Borough and includes the release of Green Belt around Pembury and a number of other settlements. The release of Green Belt land around Pembury is supported. However, we believe that an additional housing site should also have its Green Belt designation removed (Site number 354: Stone Court Farm). With the release of this additional site, the housing allocation given to Pembury should be therefore increased by a further 50 units. (For further details about the Stone Court Farm site and why it is considered suitable for development please refer to the representations provided in Comment Box 9).

The emerging Local Plan recognises that the High Weald Area of Outstanding Natural Beauty (AONB) has the highest status of protection nationally in relation to landscape and scenic beauty. The supporting text to Strategic Policy STR 1 explains at Paragraphs 4.38 to 4.40 that the preferred strategy for growth (based on Option 3 - dispersed growth - and Option 5 - new settlements) has taken account of the need “to maximise the amount of major development outside the High Weald (AONB)”. In other words, a sequential approach to site selection has been adopted and sites that lie outside the AONB have been considered first.

It is important to recognise that the Stone Court Farm Site is not located in the AONB yet some of the other sites identified for housing in Pembury in the emerging Local Plan are affected by this designation. It is not clear therefore why the site has been dismissed, whilst others with stronger landscape designations have been allocated as land suitable for housing.

In order to ensure to ensure consistency with the sequential approach, an urgent review of all the sites in Pembury should be carried out and the subject site should be re-examined. This will ensure that the Plan is ‘sound’ and has been positively prepared in accordance with the requirements of the National Planning Policy Framework (NPPF).

DLP_7313
DLP_7040

Mr Richard Gill
Philippa Gill

Object

TWBC: the standard response was submitted by the list of responders on the left:

Policy Number: STR 1 The Development Strategy 

I object to the scale and distribution of development within the AONB and its setting with reference to NPPF paragraph 172 “Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues.  The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads.  The scale and extent of development within these designated areas should be limited”. TWBC has failed to limit development and contrary to PPG it has sought to meet the needs of adjoining non-designated areas within the borough through allocating increased housing numbers to the AONB. In the Parish of Cranbrook and Sissinghurst the Housing Need Assessment completed by an independent assessor AECOM for the emerging NDP was 610, of which 250 were met by the Brick Kiln Farm allocation in the previous local plan leaving a further 360 to be delivered.  The Draft Plan allocates 918 to these settlements.

With reference to NPPF Paragraph 173 that major development should only be permitted in an AONB “in exceptional circumstances, and where it can be demonstrated that the development is in the public interest”, the Draft Plan also fails. There are chronic affordability issues in the Parish of Cranbrook and Sissinghurst and the developments are not going to meet these affordable housing requirements.

DLP_7351

Wealden District Council

General Observation

The scale and distribution of development within Tunbridge Wells Borough is set out in Table 3 (associated with Policy STR 1). This identifies the three main locations for housing development in Royal Tunbridge Wells and Southborough, Paddock Wood and Tudeley Village. Further development will be located in other settlements across the Borough and will largely be provided on a proportional basis relative to the size of each settlement.

A new garden settlement at Paddock Wood will deliver around 4,000 new homes and Tudeley Village will deliver approximately 1,900 new homes within the Plan period (a maximum of between 2,500 and 2,800 dwellings in total), which equates to almost half of the housing requirement over the Plan period. These allocations are located away from the High Weald AONB and Green Belt (in the case of Paddock Wood) to the north of the Borough where constraints are less prohibitive. This stance is supported by Wealden District Council given the more substantial planning constraints in the south of the Borough.

It is identified that 90,000 sqm of new employment floor space is allocated within the North Farm/Longfield Road Key Employment Area and a further 1,000 sqm allocated within the Gill’s Green Key Employment Area. These employment allocations equal a total of 9.1 hectares.

As stated previously, the Tunbridge Wells ENS recommended the Plan should allocate sites to accommodate at least 14 hectares of employment floor space. Therefore, it could be argued that there is some uncertainty towards the remaining 4.9 hectares of floor space to be allocated within the Borough, especially if the target of 14 hectares is to remain after a review as part of the preparation for the Regulation 19 stage of the Local Plan.

Wealden District Council supports the North Farm/Longfield Road allocation in principle, as the approach is similar in nature to the A22 Employment Sector in the Submission Wealden Local Plan (January 2019) and is associated with the major settlement in the Tunbridge Wells Borough.

DLP_7627

Mr James Peace

Object

Policy Number:  STR1 Para 5

Reference is made to the need to provide new homes based on growth around Cranbrook, Sissinghurst and Hartley. What evidence supports this statement? There is a need to provide affordable homes for local families but the plan makes little or no provision for genuinely affordable homes within these parishes.

DLP_7245

Mr John Telling

Object

What proportion of the projected extra houses is to be for young local people? The lowest price I saw for the new Hawkenbury 'Hollyfields' development was £580,000. These are not starter homes for local people, they are for incomers selling up in even more expensive areas (London). The town is full of mansions. Why do we need more? Why does the Council permit this sort of development? It leads one to speculate on the relationship between the Council and developers.

The scale of housing proposed will destroy the town/countryside interface we currently have, reduce Greenbelt land, impact on the AONB and informal wildlife habitats. The character of the SE, in our location characterised by the distinctive landscapes of the Weald and Medway Valley, is under enormous threat as it is nibbled away.

I therefore challenge the need for so many houses to be built over the plan period of 2016-2036. On the basis of the Office for National Statistics estimates of borough population growth of 13,952 people with an average house occupancy rate of 2.35 people (117,140 people living in 49,880 houses), the projected need is for 5,937 houses.

TWBC must challenge the government on the methodology of the NPPF (Ref para 4.7) and the number genuinely needed in the borough.

I also suggest that more consideration is given to building ‘upwards’ within the existing developed area rather than ‘out’ at the expense of farmland and natural habitats. Clearly this should not be to the detriment of historic areas of significant architectural value. But it would be a way of coping with the increasing population whilst preserving the Greenbelt, agricultural land and habitats. It would also make the provision of convenient public transport more viable.

DLP_7063

Bloomfields for Giles MacGregor

 

Development Strategy and Strategic Policies (Policy STR1)

The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the Borough and where that development will be located.

In terms of the amount of housing, paragraph 59 of the NPPF states that to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed. Further, to determine the number of homes needed, strategic policies should be informed by a local housing needs assessment conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.

The Council confirm that their housing need target for the plan period 2016-2036 is 13,560 dwellings (678 dwellings per annum), which is calculated using the Governments standard method and the 2014-based household projections.

In terms of the different supply components, the Council considers that the Local Plan must (as a minimum) include additional allocations to accommodate 7,593 homes. This figure was formulated taking into account; completions since April 2016 (1,552); extant planning permissions (3,127); outstanding site allocations (588) and a windfall allowance (700 dwellings).

The Council have applied a 10% non-delivery rate to these figures to err on the side of caution and consider that the plan would exceed the minimum housing requirement if all of the supply components were achieved.

The general principle of proportionately spreading the benefits of growth is supported. Adopting a pattern of dispersed growth approach would allow a number of sites to be developed at the same time, serving different areas of the Borough and segments of the local housing market, which is preferable to saturation of the market in a single area.

Tunbridge Wells is a constrained Borough. There are a number of archaeological and heritage sites, including 45 Historic Parks and Gardens, 25 Conservation Areas and 11 Scheduled Ancient Monuments. In addition, there are approximately 3,000 Listed Buildings. The landscape of the High Weald AONB contains numerous historic landscape features, including field patterns, settlements and ancient woodland, whilst the borough also hosts a number of, or is close to, areas of ecological importance. These include:

(1) Ancient Woodland (approximately 16% of the borough)

(2) Circa 60 Local Wildlife Sites (approximately 11% of the borough)

(3) Ten Sites of Special Scientific Interest (SSSI)

(4) Five Local Nature Reserves (including one Community Woodland)

(5) One Regionally Important Geological Site, at Scotney Castle Quarry.

The nearby Ashdown Forest is a designated Special Area of Conservation (SAC) and Special Protection Area (SPA). Although not an environmental constraint, the Metropolitan Green Belt covers 22% of Tunbridge Wells Borough. Given these constraints, it is acknowledged that planning for housing requires the need to balance a number of core environmental and planning matters in order to reach a sensitive future development strategy.

Accordingly, the Council is encouraged to increase the number of medium-sized sites, particularly in sustainable settlements such as Horsmonden where there is none or minimal impact upon key environmental landscape designations. Such sites could be delivered quickly, particularly as there will be limited intervention to infrastructure. Furthermore, it is essential that draft allocations such as AL/CRS14 are retained and encouraged given the advancement of planning applications emphasises the deliverability of the land.

[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; Transport Statement, Site Layout Plan, Existing Site Layout Plan, Schedule of Accommodation, Preliminary Ecological Appraisal and Highways Definition Team Letter].

DLP_7103

Williams Gallagher for Canada Life Ltd

Support with conditions

Policy STR1 – The Development Strategy

The strategy to ensure that the development needs are met through the local plan provisions is welcomed, particularly the proposals for enhanced town centre development in Royal Tunbridge Wells that seek to enable flexible retail, leisure, and cultural uses as well as new office and residential use as part of mixed-use developments. In order to be consistent with NPPF guidance (para 60), the amount of new housing proposed should be identified as the minimum requirement.

We trust that you find these comments constructive and look forward to on-going dialogue with the Council. Please keep us informed of progress with the local plan preparation.

Should you have any queries, please do not hesitate to contact us.

[TWBC: see also Comment Nos. DLP_7102-7117].

DLP_6997

Kember Loudon Williams for Mr Anthony Whetstone

Support

Policy Number: Policy STR 1 The Development Strategy

This submission is made in response to the Tunbridge Wells Borough Council’s (TWBC) Consultation Draft Local Plan (Regulation 18). It is made by Kember Loudon Williams on behalf of private landowners, Mr and Mrs A Whetstone, who are seeking to promote their site at Tudeley Brook Farm, Whetsted Road, Paddock Wood, TN12 6QD.

Strategic Policy STR1 sets out the overarching development strategy for the Borough. It explains that part of the strategy for meeting the growth needs of the Borough includes the transformational expansion of Paddock Wood (using garden settlement principles). The allocation of land for development around the settlement of Paddock Wood is strongly supported.

DLP_6645

Mr Steve Gasson

Object

Policy Number:  Development Strategy STR1

Paragraph 4.3 states that ‘in preparing this Draft Local Plan, the Council has to be mindful that national planning policy, as set out in the NPPF (2019), expects local plans to meet the identified level of development needs for their area in full, unless there are good planning reasons why this is not possible. Accordingly, the proposed Development Strategy indicates how the full development needs of the borough can be most appropriately met.’

This presumption that the full development needs as derived formulaically using the new Standard Method must be met goes against NPPF paragraph 11, which makes clear that AONB designation may provide a strong reason for restricting the overall scale, type or distribution of development in the plan, and ignores the Planning Policy Guidance updated in July 2019 which specifically comments that in order to protect such areas it may not be possible to meet the formulaically derived needs.

TWBC should carry out a transparent assessment demonstrating that in deciding the level of housing provision proposed, the type of homes and the distribution of those homes, great weight has been given to conserving and enhancing landscape and scenic beauty in the AONB; the conservation and enhancement of wildlife and heritage has been taken into account; and the scale and extent of development within the AONB has been limited.

DLP_6752

Mrs Carol Richards

 

STR 1 (The Development Strategy)

This policy does not include any reference to development on Brownfield sites, but does refer to the release of Green Belt. You should have a strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites. Does TWBC have a Brownfield Register and if so is every site planned to be built on?

Point 2 Paddock Wood

I believe TWBC should be providing betterment for Paddock Wood as it EXISTS now, not adding to the problem.

The Colt’s Hill bypass has been an issue for the last 20 years and should have been sorted years ago- rather like the A21 which took 40years.

I suppose it is ’potential’ as you need developer funding to build it.

Point 3 Tudeley

A Garden Village is totally unsuitable for the Tudeley site and unsound. It should be withdrawn from the plan.

Points 4-6 other settlements

I hope you are planning development for the older person in towns and villages around the borough

Point 7

Small parcels of Greenbelt around the A21 and North Farm may be acceptable but the Green Belt at Tudeley is an important Green Belt feature and I am surprised the hinterland behind Tudeley and Five Oak Green is not protected as a Special Protection Area (SPA) because of its wildlife and wetlands.

I would like to note at this point that TWBC have not prepared a landscape sensitivity report for the area covering the area they are planning to build 7000 homes on, as can be seen from the study area boundary depicted on Figure 1.1 of the Landscape Sensitivity Assessment of Countryside around Tunbridge Wells (Feb 2017) – see also:

Exhibit 1 (TWBC commentsee attachment)

Para 1.3 of that report states its identified purpose “to help to inform the preparation of the Local Plan and, alongside consideration of other aspects of development potential such as feasibility, viability and availability, will assist in Development Management decisions regarding potential development areas or sites for allocation”. The report fails to cover the areas of Tudeley (and its floodplain), Five Oak Green and Paddock Wood as part of the process for deciding if these areas were suitable. The absence of this vital evidence renders STR/1 unsound.

Table 3 (Scale and Distribution of Development) p.43

Repeated use of the phrase “To be determined as part of masterplanning” in reference to Paddock Wood, Capel and Tudeley is ridiculous when it refers to 63% of the houses in this Local Plan. You are asking residents and businesses to consult on a largely incomplete draft. Other regions may have Local Plans that do not have a complete map of roads and other infrastructure but they omit complete infrastructure specifications for minor parts of their plans – not for the majority of their plans. This is a gaping hole in the draft Local Plan. The Draft Plan Reg 18 is not fit for consultation. It is incomplete and unsound.

Entry in Table 3 - Main Urban areas - RTW

I note under “Employment” there is provision for up to 90000 sqm. I presume this is to be sited on the 14 hectares set aside. It would be useful to plan to build homes along this corridor as is a far better area than Tudeley/Capel/ Paddock Wood. The policy of concentrating the bulk of the development in one area is not sound. TWBC need to spread the building requirement throughout the borough. Choosing option 3/ 4 and directing to some of the larger villages as in option 2.

Entry in Table 3 - Paddock Wood/ Capel/ Tudeley

I note here columns titled ‘Retail and other town uses and Employment’ all seem to be TBC part of the ‘Masterplan’. It is very strange that a Reg 18 Draft Plan to be consulted on seems to have ‘to be confirmed- TBC- at its heart.

I am beginning to wonder if the whole idea of this cobbled together LP has come about to build the Colt’s Hill by pass with developers contributions, and the late windfall site of Hadlow Estate Land at Tudeley and Capel has made option 5 very attractive for all the wrong reasons. Maybe TWBC would like to rewrite their Reg 18 plan again? This Draft Plan is completely unsatisfactory and unsound.

Entry in Table 3 - Other Parish settlements- Cranbrook to Speldhurst

Many of these Parishes have small increases to the housing numbers which I am pleased to see-at least some tiny amount of ‘spatial distribution’. What I am not seeing is a plan to develop a larger Parish settlement (with Transport Bus links and local shops) perhaps more, away from the main urban areas of Tunbridge Wells/ Pembury/ Paddock Wood/ Tonbridge (I put in Tonbridge as TWBC seem to think it is part of their fiefdom to run rough shod over) that will provide the appropriate housing for the over 60+.

More generally, I am not convinced the needs of an increasingly elderly population have been taken into account in terms of the type of housing needed. Specifically:

* The joint Sevenoaks and Tunbridge Wells Strategic Housing Market Assessment (Sep 2015) (Table 14) identifies a projected 37% increase in the size of the 60-74 age group and an 83% increase in the size of the over 75 age group (both for the TWBC area). By 2033, those over 60 will account for just over 30% of the population (joint area)

* Recent research by KCC (Strategic Commissioning Statistical Bulletin Jul 2019 - http://www.kent.gov.uk/__data/assets/pdf_file/0018/14724/Mid-year-population-estimates-total-population-of-Kent-bulletin.pdf) identifies a significant increase in the proportion of females in the 80+ age group. See Exhibit 2 (TWBC comment - see full representation) Noting that many females will have been affected by the recent pension age increase, there is therefore likely to be a greater need to provide social housing for elderly females.

In conclusion, more consideration should be given to developing appropriate housing – typically bungalows - to accommodate the over 60s in more rural locations, as retired persons often contribute to volunteer work within a community and make a very valuable contribution. Building large greenfield settlements is the wrong answer to this problem.

I don’t see any consideration of the above population issues in Policy STR1. If you follow the train of thoughts above, there is no sound reason to develop along the Tudeley / Capel/ Paddock Wood corridor, as all you are accommodating are dormitory towns for London and not addressing the really big local issues of providing for your LOCAL POPULATION!

DLP_7269

Mrs Katie Lee-Amies

 

Comments on Section 2 & 3

I object to the proposed Vision and Strategic Objectives, the provisions of STR1 and STR/PW1, AL/PW1, AL/PW2, AL/PW3, AL/PW4, STR/CA1, AL/CA2, AL/CA3,  for the reasons explained above [TWBC: See comments DLP_7265-7267]. To summarise:

  • the evidence base is inadequate and inconsistent,
  • the evidence base does not support a new settlement allocation in Tudeley,
  • the growth option 5 development strategy is not justified,
  • ‘exceptional circumstances’ to release Green Belt are not provided – housing need is not an exceptional circumstance,
  • the strategic site selection process is skewed to favour an area with one landowner,
  • the AONB setting and High Weald National Character Area are given low priority
  • The low priority placed on Green Belt, the HW AONB and its setting and the environment conflicts with the high priority placed on the natural environment in the previous Local Plan, the NPPF, Core Strategy 2010, Public Consultation Boards and by local residents,
  • Grade 2 and grade 3 agricultural land at site CA1 is not acknowledged,
  • A settlement 3-5km from the nearest town and train station creates unsustainable transport patterns, current residents are predominantly car dependent and current road network is at capacity.
  • Tudeley Garden Village will harm the landscape character, and have significant impact on long distance and panoramic views of the locality. Green Belt will be released and the HW AONB and its setting will be considerably harmed,
  • The existing land within site CA1 is undeveloped agricultural land, rich in ecosystems and biodiversity.
  • There are no existing or proposed transport links to support a new settlement at Tudeley,
  • The railway divides the proposed new settlement at Tudeley into two settlements, north and south of the railway,
  • The proposed location for a new secondary school on the Somerhill roundabout is unsustainable. It is too far from any settlement and train station and it will encourage further car-dependency, congestion and air pollution. Children cannot be safeguarded on a school site with a railway line running across it.
  • The expectation that new cycle paths will attract hundreds of new cyclists away from their cars is unrealistic given the local topography and British weather,
  • The Climate Emergency should be driving development away from the countryside and focussing on built-up areas and extending settlements – Objective 8 cannot be met with the current Draft Local Plan,
  • The flood risk will increase in Paddock Wood, East Capel and Tudeley with the loss of hundreds of hectares of woods, trees, hedges and fields,
  • The setting of 71 Listed buildings in Tudeley, including the Grade 1 Listed Tudeley Church visited by thousands each year, will be harmed by the new settlement and associated infrastructure,
  • The TWB is too constrained to accommodate the OAN 2014 housing growth and TWBC should challenge the figures,
  • 6,000+ proposed new homes within 5 miles of each other in Paddock Wood and Tudeley is unreasonable and far exceeds TWBC’s evidenced local need. With additional homes proposed at Mabledon Farm/Bidborough, and the loss of Green Belt to proposed quarry sites and existing Solar Farm in Capel parish, the local area will be swamped, unrecognisable and destroyed. Strategic site allocations are being considered in isolation and their cumulative impact is not being assessed or considered,
  • Increasing the number of homes in a small parish by 500% is unreasonable, unnecessary and unjustified,
  • A new settlement with 2,500-2,800 homes close to the boundary of TMB warrants consultation with Tonbridge residents. Tonbridge will bear the impact of the development and its infrastructure. A new settlement should not follow the same planning procedure as a development of 10-20 homes. Use some common sense.

Tudeley Garden Village is a vague outline on a plan in the Reg 18 Draft Local Plan. A schematic or zoning diagram indicating transport links, railway crossings, footpaths and green infrastructure should be included for a large new settlement comprising 63% of TWBC’s new homes. Too much information has been held back for the ‘masterplanning phase’ to enable objective assessment. TWBC are seeking comments on an incomplete Draft.

DLP_6213

Amanda Wells

Object

Policy Number:  STR1

Paragraphs 2 and 3 talk about establishing large housing developments following garden settlement princples.

Garden settlements look to the past not the future – with climate change at the top of the agenda, land use planning determines that development should be in compact settlements where all housing is within walking distance of frequent public transport -not spread out over 600 acres, as in the case at Tudely, taking up precious agricultural land which has an important carbon sequestration function and plays an important role in flood prevention. These settlements will also almost certainly be creating housing estates where there will be intensive reliance on private cars.

Paragraph 7 talks about releasing Green Belt land to deliver this development and paragraph 8 mentions the use of AONB sites where the tests in the NPPF are met.

The NPPF is clear that only in exceptional circumstances may a Green Belt boundary be altered, through the Local Plan process – “unmet housing need alone will not amount to these special circumstances”. (Brandon Lewis – Housing Minister 2015)

Para 137 of the NPPF states that before changes to GB boundaries are proposed, councils should examine fully all other options, make as much use of brownfield as possible and optimise the density of development.  There is no evidence that TWBC has an up to date brownfield register and has thoroughly examined the use of brownfield sites or empty properties which could be brought back into residential use within the borough. It seems that instead of making a case for constraint based on much of the district being Green Belt and AONB, TWBC has attempted to meet unrealistic housing figures by altering the existing Green Belt status of large tracts of countryside.

DLP_7225

Elizabeth Daley

Support with conditions

If the ENS has identified the above areas for development, this is surely where many new residents of the Parish of Cranbrook and Sissinghurst will be travelling to work, (14 miles away) entirely unsupported by appropriate infrastructure

I object to placing so much development in Ctranbrook and Sissinghurst when employment is targeted so far away

Therefore I support the policy on condition that so much residential development is not placed as far as 14 miles away.

DLP_7236

Elizabeth Daley

Support with conditions

STR1 point 5

The statement is made that new healthcare and other facilities (which are?????) will be provided, despite the fact that no land has been allocated for a medical centre.

DLP_7560

Mark Beales

General Observation

Policy STR1 c.A prestigious new business park will be located to the north of North Farm/Kingstanding Way that is well connected to the improved A21, providing a range of employment floorspace and jobs to meet identified needs. The site will make a substantial contribution to the need for new employment space over the plan period. Other employment, including leisure development, will be encouraged at North Farm/Kingstanding Way

If the ENS has identified the above areas for development, this is surely where many new residents of the Parish of Cranbrook and Sissinghurst will be travelling to work, (14 miles away) entirely unsupported by appropriate infrastructureI object to placing so much development in Ctranbrook and Sissinghurst when employment is targeted so far away

DLP_6282

Mrs Elizabeth Simpson

Object

Policy Number: STR1

The Development Strategy for the delivery of the Local Plan adopts a combination of growth strategies proposed in the Issues and Options document.

Prominent in this mix is proportional distribution of growth across all existing settlements, despite the fact that the consultation recorded a less positive response to this approach than the other strategies. Also in the mix is growth within a new, free-standing settlement - however the feedback in the Issues and Options consultation, which recorded a slight preference for this growth strategy , specified that the new settlement should not be in the Metropolitan Green Belt or the AONB. The ‘Distribution of Development Topic Paper’ presents the justification for the proposed Development Strategy, including how the Issues and Options consultation informed the Strategy. However, the outcome is at odds with the feedback and, in several instances, goes directly against the views expressed.

I oppose the proposed approach of dispersed growth across the Borough. It is inconsistent with the NPPF, which advocates focusing development in the most sustainable locations, allocating land with the least amenity value and conserving and enhancing the AONB, where the scale and extent of development within such designated areas should be limited (NPPF paragraphs 171 and 172). It is also contrary to the Council’s previous Local Plan and Core Strategy, which focussed growth in towns, recognising that villages and rural settlements are the least sustainable locations for development. So many of the proposed development sites allocated in the draft local plan go against these views expressed and are contrary to protections that should be afforded to AONB and Green Belts under the NPPF procedure.

Dispersed growth with proportional development distribution is not consistent with the three objectives of sustainable development. Looking at our own village of Matfield, this is one of the least sustainable settlements in the borough. It lacks the services and amenities to support significant growth (up to 37.5% in the number of dwellings). There is no evidence of scope for the village to become more sustainable as a result of growth, despite the Council’s untested hope in that it may. Development of this scale in settlements with low sustainability is contrary to the NPPF (paragraphs 7 and 8) and is emphatically not in the public interest.

What was the rationale for adopting the preferred approach of dispersed growth, in favour of the focused growth used in the Core Strategy? Was it simply a case of spreading the misery? How was the ‘proportional’ aspect of ‘proportional development distribution’ determined under the ‘dispersed growth’ model applied in the Development Strategy? What methodology was applied and how has this been tested?

More should be done to promote a greater proportion of housing development on Brownfield land, particularly, in the existing urban centres. The current Brownfield Register for Royal Tunbridge Wells contains provision for only up to 950 homes, which is an incredibly small provision for a town of this scale. How exhaustive has the search been to identify land that could be redeveloped rather than building over rural areas, both in rural villages and the countryside? Why can’t more development be allocated to such Brownfield sites, within existing towns, where transport services are already in place, rather than destroy more of the AONB countryside? Development of brownfield sites often has the benefit of removing local eyesores and breathing new life into areas of towns which are run-down and further providing homes where most young people actually want to live, near to existing infrastructure, amenities and services. Brownfield site development should be prioritised over building in idyllic rural villages and a greater search of potential sites made in not only Tunbridge Wells but other towns in the borough.

DLP_6984

Nigel Tubman

Object

I object to this policy because it is not about the whole of the borough with the focus on Tunbridge Wells and Southborough. Paddock Wood and Tudeley get mentioned in some detail but not the rest of the borough. The infrastructure improvements are minimal compared to the intention to build large housing estates in rural areas.

DLP_7198

Mr Michael Armitage

Object

Sewage services are under scrutiny, as they are already unable to cope with demand. New development is therefore out of the question.

Hawkhurst golf club with the service road would make the village unsustainable, with no appreciation of the impact on schools, services, surgeries and infrastructure.

The AONB is being deliberately ignored. Terms of an AONB cannot assume that as the village will be the size of a ‘town’, the restrictions do not apply. Hawkhurst’s village status obviates this.

There are grave concerns that the proposed service road will make anything but a negative impact on traffic flow in the village.

DLP_7200

John Gibson

Object

Policy Number: STR1 5.5

Infrastructure is intended to precede the development, which is clearly not the case at present.

DLP_6848

John Gibson

General Observation

Policy Number: STR1 c

By expanding North Farm/Kingstanding Way as an area for employment it follows that many of the proposed new residents in the Cranbrook and Sissinghurst Parish will be traveling by private cars. More employment opportunities need to be planned closer to the Parish. Also, better public transport options need to be provided.

DLP_6850

John Gibson

General Observation

Policy Number: STR1 5.5

Inadequate infrastructure is in place to allow approval of the Dandara planning application for AL/CRS13. The infrastructure is intended to precede the development, which is clearly not the case.

DLP_7641

John Gibson

General Observation

Policy Number:  STR1 c

By expanding North Farm/Kingstanding Way as an area for employment it follows that many of the proposed new residents in the Cranbrook and Sissinghurst Parish will be traveling by private cars. More employment opportunities need to be planned closer to the Parish. Also, better public transport options need to be provided.

DLP_6144

Turley for Taylor Wimpey UK Ltd

 

Second Paragraph

For transparency and clarity, it is recommended the Policy defines what the ‘identified needs of the borough over the Local Plan period’ are. This is set out in the preceding paragraphs, but not in the policy itself.

Housing Development

Preceding paragraphs 4.7 to 4.17 of Policy STR1 set out the Council’s proposed definition of ‘identified needs’ for housing over the plan period. Whilst we would broadly agree with the conclusions reached in respect of the baseline housing requirement or starting point, we would suggest further work is needed to quantify the contribution TWBC is able to make towards the unmet needs of adjoining authorities; and to addressing more of the shortfall in the borough’s supply of affordable housing.

Unmet Needs

Whilst the Council acknowledge the unmet needs of Sevenoaks (1900 homes), no further assessments appear to have been undertaken to assess whether some or all of this could be met through the emerging Local Plan. Paragraph 4.8 of the Draft Local Plan does not reference robust evidence to conclude no contribution can be made to such needs, only that TWBC has a ‘limited ability to meet any unmet housing needs from other Councils.’ To accord fully with NPPF paragraph 60 and justify the emerging Development Strategy in Policy STR1, we would suggest further work and statements of common ground are progressed on the ability or otherwise to address unmet needs of adjoining authorities; and importantly the strategy and implications for those needs that cannot be met.

In addition, TWBC will be aware of the significant unmet needs identified in the recent examiners report for the new London Plan. No mention is made of this by TWBC in either the Draft Local Plan or the Housing Needs Assessment Topic Paper (TWBC, 2019). This merits further consideration in our opinion to accord with paragraph 60 of the NPPF.

As paragraphs 28-35 of the Housing Needs Assessment Topic Paper (TWBC, 2019) outline, there is also a number of adjoining authority draft Local Plans at various stages of production at present. As acknowledged at para 33 of that document, some submitted plans may be subject to change. In addition emerging plans at Maidstone and Rother may also reveal needs that are still to be quantified. These merit further monitoring and cooperation to facilitate the drafting of statements of common ground on such matters.

Affordable Housing

Paragraph 6.1.5 of the Housing Supply and Trajectory Topic Paper (TWBC, 2019) indicates the Council are forging a plan that will fail to meet affordable housing needs identified in paragraph 48 of the Housing Needs Assessment Topic Paper (TWBC, 2019). A supply of 249 homes a year is planned against a conservative need for 341 dwellings per year. However, ten of the 249 units per year are proposed to be delivered from financial contributions secured from sites under 10 units. This is contrary to paragraph 63 of NPPF which states that “affordable housing should not be sought for residential developments that are not major developments”. This paragraph was introduced by the government as a signal of support for SME developers who tend to deliver such sites; and whom would otherwise struggle to deliver such sites viably. Further viability evidence is required in our view to support such a requirement against paragraph 63 of the NPPF. Nevertheless, even if this were to be evidenced, affordable housing provision will still significantly undershoot need. This provides compelling evidence in our opinion, in addition to that which may arise from assessments of unmet needs of adjacent authorities, to justify testing a higher borough housing requirement through the emerging Draft Local Plan. Higher than the 14,776 proposed to be delivered through Policy STR1. As our clients site submission herein has shown, there are sites that may have been overlooked in error, sites that are available, suitable and deliverable and could be making a contribution to affordable housing provision.

Development Distribution and Delivery

As set out in Policy STR1 and Table 18 of the Housing Supply and Trajectory Topic Paper (TWBC, 2019), the Council are seeking to deliver around 67% of total new site allocations at or adjacent to Capel Parish, largely around the areas of Tudeley and Paddock Wood.

Whilst centred on a rail line, the garden settlement proposal is not served by an existing or it seems proposed safeguarded rail station. Instead reliance is placed on the delivery of significant strategic road infrastructure to service this alongside that proposed at Paddock Wood. It is not clear how this serves to reduce the need to travel by car, a key sustainability objective, nor is it clear what the implications of this are for the delivery rates proposed for both sites. Particularly as the routes, funding and delivery timetable of such significant infrastructure, including an offline A228 strategic link, has not been determined as yet. The implications of delivering this and other associated infrastructure in areas of flood risk pose significant engineering and viability challenges; and with them potential for reduced capacities and delays. Further analysis of this is therefore suggested to determine the implications for site delivery rates. We would therefore wish to reserve the right to comment further on this as more detail emerges.

Turning to delivery rates assumed for these two large growth areas. The proximity of these proposals to each other may well have an impact on the speed with which such sites come forward and the rate at which homes are delivered and absorbed into the market. The absorption rate of development in such a small market area and competition between the two sites for sales may significantly impact delivery rates. The Housing Supply and Trajectory Topic Paper (TWBC, 2019) does not appear to assess the implications of absorption rates or the proximity of these sites to each other. Instead, reliance appears to be placed on national delivery rates on sites that do not mirror the characteristics of delivering such large sites in proximity to each other and in this borough.

TWBC rely on an assumed delivery rate for the allocations proposed in Capel/Paddock Wood of 333 homes a year. The Council acknowledge at paragraph 5.5.14 of the Housing Supply and Trajectory Topic Paper (TWBC, 2019), that this is higher than the evidenced national average of 299 homes. Whilst the latter may well be the case nationally, it does not account for the specific circumstances arising from the proximity of two large scale proposals in Tunbridge Wells Borough. Particularly the implications of expected absorption rates on delivery rates, given the proximity of these two large growth areas in such a small market area. We would suggest therefore further work is undertaken on such matters; and that a more cautious approach to delivery is taken than that proposed accordingly.

TWBC acknowledge the proposed delivery rates for both Tudeley and Paddock Wood is also dependent on the number of developers and sales outlets, which are as yet unknown. In addition, Draft Local Plan Policy STR/CA1 (‘Masterplanning and Delivery’ bullet points 3 and 4) indicate a need for potential equalisation agreements and potentially even compulsory purchase orders, to deliver planned growth. All of which contribute to a need for a more cautious approach to delivery than using uplifted national average site delivery rates. We would suggest further work is undertaken on such matters to build in a greater level of certainty; alongside the allocation of additional smaller, more deliverable sites as necessary, to help maintain a rolling five year supply of housing land. Our client’s site being an example of one such opportunity, one we would welcome further discussion with TWBC on.

The above serves to highlight the importance and exceptional need for delivering the smaller allocations around other sustainable settlements, such as Cranbrook. We support, as a minimum, the quantum of growth directed to Cranbrook through Policy STR1 in this context. Indeed, an argument could be made in light of the above for further modest growth at this settlement.

The population of Cranbrook is rapidly ageing. Since 2011, the number of residents aged 50 plus has increased by 14% while other cohorts have reduced by 10% [ONS (2019) Population estimates for small areas, Cranbrook - Cranbrook BUASD]. In parallel, average house prices in Cranbrook having risen at a faster rate (39%) than the wider borough (32%) over the past five years (2013-2018). The average price paid for housing in Cranbrook last year was the highest in at least a decade [Turley analysis of Land Registry price paid data, based on postcodes in built-up area of Cranbrook]. A failure to retain and replenish the younger population could therefore threaten the long-term vitality of the settlement if such trends continue.

In light of this, we support the proportion of growth directed to Cranbrook, as a minimum, but recommend a reassessment of our client’s lands (SHELAA Site ref: 25) alongside proposed allocations CRS6, CRS7 and CRS4. As outlined in the introduction to our letter, our client’s site appears to have been scored incorrectly against the Council’s own SA criteria and in the Council’s SHELAA (2019). Our initial analysis suggests the site is a suitable opportunity for a modest allocation (circa 70 homes); and is superior in many respects to proposed allocations CRS6, CRS7 and CRS4. We therefore respectfully commend this site for allocation in addition to or instead of one of these allocations. We provide further comments on the allocations proposed in the Cranbrook section of the draft Local Plan below.

[TWBC: see full representation and supporting document A, supporting document B, supporting document C, and supporting document D]. 

DLP_6191

Turley for Bellway Homes Strategic

 

Policy STR1 is accompanied by Table 1 of the draft Local Plan which sets out the scale and distribution of development. That table identifies Tunbridge Wells as the Main Urban Area where allocations are expected to deliver 1,222-1,320 dwellings (average 1,271). Notably Tunbridge Wells is expected to accommodate significantly fewer dwellings than Tudeley Village during the Plan period despite the clear and obvious disparity between the two settlements/areas. Fundamentally, Tunbridge Wells is a sustainable location for growth now, Tudeley Village is not and will never be in a position where it exhibits the same overall sustainability credentials as Tunbridge Wells.

Overall we note that the quantum of development directed to Tunbridge Wells is disproportionately low compared to the levels of development expected to be provided at other, less sustainable, settlements within the Borough. This is despite the availability of sites at Tunbridge Wells which have been assessed as being suitable, sustainable and logical.

Whilst we note that the consultation is accompanied by a Topic Paper on the ‘Distribution of Development’, this appears to be an explanation as to why sites have been selected, rather than an explanation why other approaches, such as a wider distribution of development without reliance on a garden settlement, or a refocus towards Tunbridge Wells have been excluded.

In addition, we consider that the Policy should define the ‘identified needs of the borough over the Local Plan period’. This is set out in the preceding paragraphs, but not in the policy itself.

[TWBC: see full representation and Comment Numbers DLP_6189-6198].

DLP_6250

Anne Trevillion

Object

Policy Number: STR1 The Development Strategy

The additional housing in Paddock Wood and Capel will make this a substantial conurbation. Yet in the Development Strategy you have a completely different attitude to ‘Royal’ Tunbridge Wells and Southborough than to Paddock Wood.

Tunbridge Wells and Southborough will get extensive infrastructure, public realm enhancement, a new theatre, art gallery, museum, library, as well as a new ‘prestigious business park’, with the aim of securing a vibrant and resilient town centre.

Why not put some of these civic amenities in Paddock Wood? We have no direct affordable public transport link to Tunbridge Wells (the bus is ridiculously expensive, infrequent, and the last bus to Paddock Wood is at 17:30 on a Saturday, so you could not use it for an evening out; and to use the train means you have to change at Tonbridge), yet all the desirable civic amenities offering cultural opportunities are planned for places inaccessible to people in Paddock Wood and Capel unless they drive.

DLP_6290

Susan Heather McAuley

Object

Policy Number:  Section 4 Strategic Policies  Policy STR 1 The Development Strategy 

Point 1 - Tunbridge Wells is going to receive all the new facilities and the employment but Tunbridge Wells is receiving proportionately far fewer houses than Sissinghurst (5% in TWells compared to 32% for Sissinghurst).  The numbers for Sissinghurst make no sense based on the current size of the settlements, transport facilities and infrastructure – the numbers for Sissinghurst should be reduced.

Point 5 – says there are high numbers proposed for Sissinghurst because of the growth in the area – what growth is that?  There is no employment locally and no high pressure on housing at the moment.

Point 6 – other settlements are to get new housing within their Limits to Build boundaries whereas the LBD in Sissinghurst has been specifically altered by TWBC to allow extra new housing.

DLP_6321

Susan Heather McAuley

 

Table 3 Scale and Distribution of Development

For Sissinghurst – 108 houses is totally out of scale and this allocation should be reduced.  This would increase the size of the village by one third.  There is absolutely no justification for doing this to Sissinghurst. There is no great pressure on housing in Sissinghurst; the recently built new estate is taking ages to sell and even the shared ownership on it has not sold.  Sissinghurst seems to be being penalised here, 108 more houses, but zero increase in employment.  This is economically, environmentally and socially unsustainable.

DLP_6323

Persimmon Homes South East

 

3. Development Strategy

Persimmon Homes recognises that accommodating the housing requirement for Plan period is challenging given that much of the Borough is constrained by either the High Weald AONB and/or the Metropolitan Green Belt.

Persimmon Homes further acknowledges the broadly proactive approach that the Council has taken to accommodating their growth requirements within a comparatively constrained area. Most notably we are entirely supportive of the proposed large scale expansion of Paddock Wood, given that the settlement is already a sustainable locations (see Settlement Role & Function Study). The proposed expansion allows the existing sustainability advantages of this location to be leveraged to deliver significant growth.

Despite the broadly proactive approach that has been taken, Persimmon Homes is concerned that the proposed distribution of growth is not ‘sound’ in three important respects:

* Firstly, several comparatively unsuitable and unsustainable sites around Cranbrook have identified as draft allocations at the expense of alternative more sustainable locations (include the Site);

* Secondly, insufficient growth has been directed Cranbrook as a whole, with too much growth allocated at Hawkhurst which is demonstrably less sustainable settlement;

* Thirdly, too much reliance has been placed upon the delivery of a new settlement at Tudeley Village, which is not currently a sustainable location and cannot viably be made a sustainable location.

Summary

Whilst the Council have taken a proactive approach to accommodating the housing requirement over the plan period, the development strategy as current conceived is subject to several shortfalls which make is ‘unsound’. These issues can be addressed by directing additional growth toward sustainable locations around Cranbrook, most notably toward the Site [land at Freight Lane, Cranbrook].

6. Summary and Conclusion

These representations have been prepared by Persimmon Homes in respect of the Land West of Freight Lane, Cranbrook, Kent.

These representation have demonstrated that the Site is a situated in a sustainable location on the edge of Cranbrook which is the most sustainable settlement in the Borough outside of the Main Urban Area.

These representation have shown that, whilst the Site is subject to some limited environmental constraints, these can be mitigated through careful design and the delivery of a comprehensive green infrastructure scheme.

Whilst the Council have taken a proactive approach to accommodating the housing requirement over the plan period, the development strategy as current conceived is subject to several shortfalls which make is ‘unsound’. These representations have highlighted that, these issues can be addressed by directing additional growth toward sustainable locations around Cranbrook, most notably toward the Site. 

In light of the preceding analysis, these representations have demonstrated that, whilst the Site is situated within the AONB, directing major development toward the Site would be entirely in accordance with the NPPF Paragraph 172 tests. There is a clear need for the development which cannot be accommodated in locations outside of the AONB and furthermore the limited detrimental environmental impacts of the development can be mitigated through sensitive design. 

In summary, these representations have demonstrated that the Site can deliver sustainable development and we respectfully request that the Site is allocated in the emerging Plan.

[TWBC: see full representation. Also see Comment Nos. DLP_6319, 6323-6326, 6328, 6830-6835, 6837-6839].

DLP_6427

Gary Birch

Object

Policy Number: STR 1

I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB.

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents.

The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is not applicable to Hawkhurst Parish Council, which (I understand) doesn’t supports the development proposed in the Draft Local Plan.

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments.

Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed.

For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place.

The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:

1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan;

2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point.

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village.

The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan.

There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development.

Non-compliance with Hawkhurst Neighbourhood Development Plan

The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment.

Lack of adequate infrastructure

Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament.

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment.

Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents.

There are very limited local employment opportunities and no secondary schools within walking distance.

The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution.

The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it.

TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103).

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF.

The “relief road” is not a proven means of mitigating traffic

The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply my not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny.

As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes.

DLP_6452

L Noakes

Object

The Development Strategy

I am disappointed that our Borough Council has so easily accepted the figures produced and imposed by Central government. The figures produce a scale of housing which, given the constraints with AONB, Metropolitan Green Belt and considerations to the likely effects on the Special Protection Area of the Ashdown Forest; pays no regard to the unique character of many of the rural villages and will cause considerable harm to the protected status of the landscape in the Borough. As the Council has admitted through its own documentation that trying to allocate housing within  these restrictions has been difficult task, and clearly understands the problems it will cause, I am at a loss to understand why the allocation for the Borough has been so easily accepted and why a case to try and reduce the numbers has not been brought forward by TWBC. Instead TWBC seem to be allowing for an ‘over supply’ of around 9% in their allocations, which given the difficulty in finding suitable sites, seems very inappropriate.

The NPPF, paragraphs 102&103 state that there is a need to locate development so as to reduce travel and increase the scope for walking, cycling and public transport. The climate change emergency which we are also facing would indicate this is a good response to planning.

Paragraphs 171 & 172 seek to conserve and enhance AONB’s by limiting the scale and extent of development in such designated areas. Unfortunately, as the Draft Plan itself explains, in the Borough of Tunbridge Wells this leaves very little land available for large scale development and pushes a disproportionate amount of development in to our rural settlements. These same rural areas have very little in the way of public transport and infrastructure. The BC’s attempts to solve this problem with the ‘expectation’ for developer contributions to assist with this and promised liaison with KCC Highways and other infrastructure bodies, does little to allay my personal fears that this is an inadequate solution to this problem.

The BC held a consultation in June 2017 to seek public opinion on the preferred option with regards to the placing new development in the Borough. Since this early consultation,  they have chosen to follow a ‘dispersed growth strategy’ which promises to  put the majority of the development in rural areas, rather than directing it towards urban areas such as Tunbridge Wells, Southborough and/or along a growth corridor such as the A21, where there is better access to road and rail networks. This again seems contradictory to the NPPF which tries to encourage development in more sustainable areas.

The most significant consequence of the policy of dispersed growth is that the area covered by five local councils in the north-east of the borough would take most of this housing development. An area, roughly comprising Horsmonden, Brenchley and Matfield, Paddock Wood, Capel, and Pembury, has been allocated in excess of 7,000 units. However, despite this, there seems to be no indication in the Plan, that it is the priority area for infrastructure investment. Nor is there any indication of the cumulative impact of development across this area. Whilst I understand that a master-planning approach would be taken in the development of the strategic sites, this does not go far enough in dealing with such issues as the social, economic, and environmental infrastructure needed to support development on that scale.

The large-scale development of this area will have a knock-on effect on all the surrounding villages and settlements, residents of whom will suffer the consequences of blocked roads, overcrowded schools and doctors’ surgeries. As plans and timescales for any increase in infrastructure is unclear, it cannot be assumed that these facilities will be expanded quickly enough to cope with the increased demands.  The resultant increase in population in this area will have a major impact on the already overstretched train services to London as well as the resultant car parking facilities required at local stations, many of which already operate a waiting list for spaces.

DLP_6480

Woolf Bond Planning for Millwood Designer Homes Ltd

 

Site 2: Chittenden Fields, adjacent to High Street and Slip Mill Road, Hawkhurst

Policy STR 1: The Development Strategy

Representation

The Council has followed the Standard Method approach to identifying the housing need for the Plan period. This approach is supported as it is compliant with the requirements set out in the NPPF.

The resulting minimum housing requirement of 13,560 dwellings (678 per year) is therefore considered to be appropriate in terms of plan-making.

However, the housing requirement needs to be embedded into the actual policy wording, i.e. within the green policy box. As presently drafted it is located in the supporting text and within tables 1 and 3. This will provide for greater clarity and certainty in relation to the policy requirements.

Additionally, to be in accordance with the NPPF and the Government’s objective to significantly boost the supply of homes (para. 59, NPPF, 2019), the housing requirement should be highlighted as a minimum figure, and not a ceiling target.

In respect of Table 1, we note that the table sets out the requirement for 13,560 dwellings to be met in the period 2016 – 2036. This should be clearly expressed as a minimum target.

The components of supply in Table 1 suggest the need to allocate a minimum of 7,593 dwellings to meet the remaining requirement (after taking into account of completions, commitments and windfalls).

The deliverability of the other elements of supply depends upon whether the sites within rows 3, 4 and 5 come forward. Their deliverability has yet to be tested through the examination process.

Paragraph 4.15 of the draft Local Plan refer to the need to make an allowance for the delay and/or non-delivery of a proportion of the identified sites. This approach is supported.

Paragraph 4.16 states that the total capacity of all of the identified components of supply, including the proposed allocations, could deliver around 14,776 dwellings during the plan period. It is said that this is 9% in excess of the 13,560 minimum target requirement.

However, including for the reasons set out in our representations upon Policies STR/CA1 and STR/PW1, we have concerns about the Council’s housing trajectory and the assumptions in relation to the timing for and delivery of dwellings from certain of the strategic site allocations.

If realised during the plan period, the purported delivery of 14,776 net additional dwellings would be 1,216 dwellings in excess of the minimum requirement. However, and with reference to pages 27 and 30 of the Housing Supply and Trajectory Topic Paper, even if delivery at Tudeley (AL/CA1) and Paddock Wood (AL/PW1) is delayed by only 2 years the ‘surplus’ against the minimum requirement would be reduced to less than 200 dwellings. This assumes all of the other components of supply deliver at the point envisaged.

Given the inherent delays with the planning for and delivery of strategic sites, the approach to site allocation cannot be said to be justified and is likely to fail to provide for a flexible supply of housing land.

In any event row 6 in Table 1 should be re-worded to increase the allocations required, in order to provide not only for the planned housing requirement, but also to identify additional sites for choice, flexibility and competition in the market in line with national policy.

We agree with the approach to disperse housing allocations across the Borough and allocate land for additional housing at many of the smaller (and sustainable) settlements.

As a general note, it is unclear from the wording of the draft site allocations, where a range of dwellings is indicated, how many dwellings are required to be delivered from each site in order to meet the housing requirement.

Suggested Change

The housing requirement needs to be embedded into the actual policy wording, i.e. within the green policy box. As presently drafted it is located in the supporting text and within tables 1 and 3. This will provide for greater clarity and certainty in relation to the policy requirements.

The 13,560 dwelling housing target should be clearly expressed as a minimum. The Council should review the delivery assumptions for and of the strategic sites.

Additional small scale deliverable sites at sustainable locations should be allocated for housing development in order to ensure an adequate and flexible supply of deliverable housing land.

[TWBC: see full representation, site plan and Landscape and Visual Statement]. 

[TWBC: see also Comment Numbers DLP_6479-6484]

DLP_6487

Woolf Bond Planning for Millwood Designer Homes Ltd

 

Policy STR 1: The Development Strategy

Representation

Site 222: Land on the west side of Iden Green Road, Benenden, TN17 4ES

The Council has followed the Standard Method approach to identifying the housing need for the Plan period. This approach is supported as it is compliant with the requirements set out in the NPPF.

The resulting minimum housing requirement of 13,560 dwellings (678 per year) is therefore considered to be appropriate in terms of plan-making.

However, the housing requirement needs to be embedded into the actual policy wording, i.e. within the green policy box. As presently drafted it is located in the supporting text and within tables 1 and 3. This will provide for greater clarity and certainty in relation to the policy requirements.

Additionally, to be in accordance with the NPPF and the Government’s objective to significantly boost the supply of homes (para. 59, NPPF, 2019), the housing requirement should be highlighted as a minimum figure, and not a ceiling target.

In respect of Table 1, we note that the table sets out the requirement for 13,560 dwellings to be met in the period 2016 – 2036. This should be clearly expressed as a minimum target.

The components of supply in Table 1 suggest the need to allocate a minimum of 7,593 dwellings to meet the remaining requirement (after taking into account of completions, commitments and windfalls).

The deliverability of the other elements of supply depends upon whether the sites within rows 3, 4 and 5 come forward. Their deliverability has yet to be tested through the examination process.

Paragraph 4.15 of the draft Local Plan refers to the need to make an allowance for the delay and/or non-delivery of a proportion of the identified sites. This approach is supported.

Paragraph 4.16 states that the total capacity of all of the identified components of supply, including the proposed allocations, could deliver around 14,776 dwellings during the plan period. It is said that this is 9% in excess of the 13,560 minimum target requirement.

However, including for the reasons set out in our representations upon Policies STR/CA1 and STR/PW1, we have concerns about the Council’s housing trajectory and the assumptions in relation to the timing for and delivery of dwellings from certain of the strategic site allocations.

If realised during the plan period, the purported delivery of 14,776 net additional dwellings would be 1,216 dwellings in excess of the minimum requirement. However, and with reference to pages 27 and 30 of the Housing Supply and Trajectory Topic Paper, even if delivery at Tudeley (AL/CA1) and Paddock Wood (AL/PW1) is delayed by only 2 years the ‘surplus’ against the minimum requirement would be reduced to less than 200 dwellings. This assumes all of the other components of supply deliver at the point envisaged.

Given the inherent delays with the planning for and delivery of strategic sites, the approach to site allocation cannot be said to be justified and is likely to fail to provide for a flexible supply of housing land.

In any event row 6 in Table 1 should be re-worded to increase the allocations required, in order to provide not only for the planned housing requirement, but also to identify additional sites for choice, flexibility and competition in the market in line with national policy.

We agree with the approach to disperse housing allocations across the Borough and allocate land for additional housing at many of the smaller (and sustainable) settlements.

As a general note, it is unclear from the wording of the draft site allocations, where a range of dwellings is indicated, how many dwellings are required to be delivered from each site in order to meet the housing requirement.

Suggested Change

The housing requirement needs to be embedded into the actual policy wording, i.e. within the green policy box. As presently drafted it is located in the supporting text and within tables 1 and 3. This will provide for greater clarity and certainty in relation to the policy requirements.

The 13,560 dwelling housing target should be clearly expressed as a minimum. The Council should review the delivery assumptions for and of the strategic sites.

Additional small scale deliverable sites at sustainable locations should be allocated for housing development in order to ensure an adequate and flexible supply of deliverable housing land.

[TWBC: see full representation, Figure 3 Landscape Strategy, Heritage & LGS Assessment, and site location plan].

[TWBC: see also Comment Numbers DLP_6485, 6487-6489, 6491-6494]

DLP_6550

Woolf Bond Planning for Millwood Designer Homes Ltd

 

Site 60: The Paddocks, Home Farm, 92 Lower Green Road, Rusthall TN4 8TT

Policy STR 1: The Development Strategy

Representation

The Council has followed the Standard Method approach to identifying the housing need for the Plan period. This approach is supported as it is compliant with the requirements set out in the NPPF.

The resulting minimum housing requirement of 13,560 dwellings (678 per year) is therefore considered to be appropriate in terms of plan-making.

However, the housing requirement needs to be embedded into the actual policy wording, i.e. within the green policy box. As presently drafted it is located in the supporting text and within tables 1 and 3. This will provide for greater clarity and certainty in relation to the policy requirements.

Additionally, to be in accordance with the NPPF and the Government’s objective to significantly boost the supply of homes (para. 59, NPPF, 2019), the housing requirement should be highlighted as a minimum figure, and not a ceiling target.

In respect of Table 1, we note that the table sets out the requirement for 13,560 dwellings to be met in the period 2016 – 2036. This should be clearly expressed as a minimum target.

The components of supply in Table 1 suggest the need to allocate a minimum of 7,593 dwellings to meet the remaining requirement (after taking into account of completions, commitments and windfalls).

The deliverability of the other elements of supply depends upon whether the sites within rows 3, 4 and 5 come forward. Their deliverability has yet to be tested through the examination process.

Paragraph 4.15 of the draft Local Plan refers to the need to make an allowance for the delay and/or non-delivery of a proportion of the identified sites. This approach is supported.

Paragraph 4.16 states that the total capacity of all of the identified components of supply, including the proposed allocations, could deliver around 14,776 dwellings during the plan period. It is said that this is 9% in excess of the 13,560 minimum target requirement.

However, including for the reasons set out in our representations upon Policies STR/CA1 and STR/PW1, we have concerns about the Council’s housing trajectory and the assumptions in relation to the timing for and delivery of dwellings from certain of the strategic site allocations.

If realised during the plan period, the purported delivery of 14,776 net additional dwellings would be 1,216 dwellings in excess of the minimum requirement. However, and with reference to pages 27 and 30 of the Housing Supply and Trajectory Topic Paper, even if delivery at Tudeley (AL/CA1) and Paddock Wood (AL/PW1) is delayed by only 2 years the ‘surplus’ against the minimum requirement would be reduced to less than 200 dwellings. This assumes all of the other components of supply deliver at the point envisaged.

Given the inherent delays with the planning for and delivery of strategic sites, the approach to site allocation cannot be said to be justified and is likely to fail to provide for a flexible supply of housing land.

In any event row 6 in Table 1 should be re-worded to increase the allocations required, in order to provide not only for the planned housing requirement, but also to identify additional sites for choice, flexibility and competition in the market in line with national policy.

We agree with the approach to disperse housing allocations across the Borough and allocate land for additional housing at many of the smaller (and sustainable) settlements.

As a general note, it is unclear from the wording of the draft site allocations, where a range of dwellings is indicated, how many dwellings are required to be delivered from each site in order to meet the housing requirement.

Suggested Change

The housing requirement needs to be embedded into the actual policy wording, i.e. within the green policy box. As presently drafted it is located in the supporting text and within tables 1 and 3. This will provide for greater clarity and certainty in relation to the policy requirements.

The 13,560 dwelling housing target should be clearly expressed as a minimum. The Council should review the delivery assumptions for and of the strategic sites.

Additional small scale deliverable sites at sustainable locations should be allocated for housing development in order to ensure an adequate and flexible supply of deliverable housing land.

[TWBC: see full representation, site context plan, access improvements and site location plan].

[TWBC: see also Comment Numbers DLP_6548-6450, 6452-6453, 6456-6457, 6459]

DLP_6490
DLP_6508
DLP_6538
DLP_6647
DLP_6705
DLP_6728
DLP_8049
DLP_7675

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

Object

TWBC: the standard response was submitted by the list of responders on the left:

I object to the excessive number of dwellings proposed within the AONB at Cranbrook and at Hawkhurst.  No distinction has been made between the proportion of housing allocated to the borough as a whole, and that allocated to Cranbrook and Hawkhurst.

Moreover, the proposal is not in accordance with the requirements for strategic policies applicable to AONBs specified in paragraph 11 of the NPPF:

“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:

  1. 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
  2. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”

Planning Practice Guidance (Paragraph: 041 Reference ID: 8-041-20190721[1]) supports the principle that development within AONBs should be limited in view of the importance of conserving and enhancing their landscapes and scenic beauty:

“Its [the NPPF’s] policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas

[1] https://www.gov.uk/guidance/natural-environment

The proposal is also inconsistent with the AONB Management Plan, adopted by Tunbridge Wells Borough Council in March 2019.  The Plan explains that the High Weald is a small-scale landscape built by hand.  It commits authorities to ‘seek to deliver new housing primarily through small-scale developments that meet local need’ (Objective S2, page 34).

Paragraph 172 of the NPPF says that ‘Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest’. The tests associated with this policy have not been properly considered and the exceptional circumstances have not been justified. Alternatives to the large allocations have not been properly considered and the option of reduced allocations on the larger sites offered in the Strategic Housing and Economic Land Availability Assessment has not been properly examined.

I specifically object to the statement at item no.5 (new homes based on growth around Cranbrook itself, Sissinghurst, and at Hartley). This statement is unclear and potentially misleading so as to conceal the reality that growth generated by Royal Tunbridge Wells is proposed to be accommodated by a hugely disproportionate number of new dwellings in Cranbrook & Sissinghurst Parish.

Furthermore, the statement “Further development at Cranbrook to provide new homes based on growth around Cranbrook itself, Sissinghurst, and at Hartley” is ambiguous.  It isn’t clear whether “and at Hartley” is referring to the location of further development, or to growth around Hartley.  This policy item should make it clear that the extent of any development around Cranbrook & Sissinghurst Parish should be limited to local needs and that the multiple listed buildings and nature of the topography at Hartley mean that major development there would unavoidably cause irreversible damage to the character of the AONB which would not be forgiven by the community or future generations.

DLP_6541

Diana Badcock

Support with conditions

Policy Number: STR1 1.5

I support the need for a new medical centre in Cranbrook although the need is not determined merely by further population growth, as the need for a modern centre exists now.

Its placement will be crucial. Although the centre of Cranbrook would be ideal (perhaps where the community hub was originally planned – in CRS8) the site would need to allow for full ancillary facilities (and future expansion?).

DLP_6571

Myrtle Newsom

Object

Policy Number: Section 4 Strategic Policies Policy STR 1 The Development Strategy

Tunbridge Wells is going to receive all the new facilities and the employment but Tunbridge Wells is receiving proportionately far fewer houses than Sissinghurst. The numbers for Sissinghurst make no sense based on the current size of the settlements, transport facilities and infrastructure – the numbers for Sissinghurst should be reduced.

Point 5 – says there are high numbers proposed for Sissinghurst because of the growth in the area – what growth is that? There is no employment locally and no high pressure on housing at the moment.

DLP_6610

AAH Planning for Future Habitat Ltd

 

Policy STR 1 – The Development Strategy

Policy STR 1 sets out the overarching Development Strategy for the Local Plan. The Key Diagram illustrates the spatial strategy and the broad distribution of development. The supporting table to the policy identifies a range of 643-693 housing allocations, as well as other infrastructure for Hawkhurst.

It is considered that the wording in the supporting text in relation to the number of new homes should specify “at least” or “a minimum of”, rather than an approximate range, in order to boost significantly the supply of housing in accordance with the NPPF. Furthermore, Policy STR/HA 1 sets out specific requirements for development within Hawkhurst and identifies that approximately 681-731 new dwellings will be delivered through site allocations. It is unclear as to why these ranges differ and some clarity is required to explain this.

In addition, in order to ensure that the overall aims and objections of the Local Plan can be met, it is important that the development strategy allows for future expansion and flexibility. This is essential to ensure that the 

identified housing need can be delivered should some allocations not come forward. The identified development strategy should therefore not be overly restrictive and should allow for additional future development on suitable sites.

[TWBC: see full representation and site plan attached].

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

DLP_6669

Gladman

Support

5 SUPPORTING HOUSING GROWTH

5.1 Policy STR 1: The Development Strategy

Spatial Strategy

5.1.1 Policy STR1 sets the overarching strategy to meet development needs over the plan period for the Local Plan. Supporting text to the policy confirms that a strategy of distribution (Option 3) has formed the basis for the Council’s approach in Policy STR1. Gladman supported this strategy in its submitted representations to the Issues and Options consultation, and as such welcomes the Council’s decision. This approach promotes delivery across a broad area, and best supports the development needs of each settlement in the District including its rural areas.

5.1.2 The concentration of growth at Paddock Wood and new settlement at Tudeley represents a sound approach at which to deliver a large part of the future development needs of the District. Both sit outside the High Weald AONB and as such are unlikely to result in harmful effects on special and valued landscapes in line with the NPPF. The concentrated of development in these locations also ensures that other areas of Green Belt considered to fulfil an important function is safeguarded from development, promotes higher rates of housing delivery, and provides the opportunity to secure the delivery of new infrastructure necessary to secure this growth in accordance with the Plan’s vision and objectives.

5.1.3 Notwithstanding this, there is a need for the Council to ensure that identified housing needs are met consistently through the plan period and as such smaller sites distributed across the wider Borough are necessary. The Local Plan demonstrably secures this with sites identified at sustainable and suitable settlements for growth such as Horsmorden and Pembury. This approach will help secure delivery in the earlier part of the plan period before strategic sites with longer lead-in times commence delivery and ensures that the Local Plan is better equipped to deal with locally arising housing need.

5.1.4 As part of this, Gladman welcomes the Council’s decision to release land from within the Green Belt within the Borough and the allocation of major sites within the AONB. Gladman agree that the extensive development needs of the District and associated economic, social and environment impacts of failing to accommodate this in full, combined with the extent and constraining nature of the Green Belt and AONB to some of the Borough’s most sustainable locations, provide the exceptional circumstances and public interest case required to develop the Green Belt and AONB in accordance with the tests of national planning policy.

5.1.5 Gladman therefore support the Council’s spatial strategy as drafted.

Housing Need

5.1.6 Supporting text to Policy STR1 confirms the Local Housing Needs of Tunbridge Wells for the period 2016 to 2036 is 13,560 dwellings. The basis for this need is set out in the Housing Needs Assessment Topic Paper.

5.1.7 The Housing Needs Assessment Topic Paper confirms that the housing needs of Tunbridge Wells have been derived applying the Standard Method as advocated in national planning policy [2 PPG Paragraph 002 Reference ID: 2a-002-20190220 ]. In common with PPG, to determine the level of demographic housing need, the 2014-based household projections have been used [3 PPG Paragraph 004 Reference ID: 2a-004-20190220 ]. This has been assessed over the period 2020 to 2030 to respond to PPG that a housing needs figure can be fixed for a 2-year period following submission [4 PPG Paragraph 008 Reference ID: 2a-008-20190220 ]. The overall effect on housing need of rebasing this 10-year period from 2019-2029 to 2020-2030 is marginal given the limited change in demographic need and the fact that the adjustment made in response to affordability in the authority is capped.

5.1.8 Noting the above and based on current evidence, Gladman consider that the Council’s approach in establishing the minimum level of local housing needs is sound. However, as set out in Paragraph 4.1.3 of this representation (and as recognised by the Council in the associated Topic Paper), both the approach to defining housing needs and data informing this calculation is subject to change within the next 12 months and as such should be subject to review ahead of consulting on the Submission version of the Local Plan.

5.1.9 The NPPF and PPG both confirm that the standard method represents the minimum housing needs of an area and confirms the circumstances where housing needs may be higher than the standard method indicates. [5 PPG Paragraph 010 Reference ID: 2a-010-20190220] This includes, but is not limited to:

* Growth Strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);

* Strategic infrastructure improvements that are likely to drive an increase in the homes needed locally;

* An authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground; and

* On occasion, situations where previous levels of housing delivery in an area, or previous assessments of need are significantly greater than the outcome from the standard method.

5.1.10 The Housing Needs Assessment Topic Paper only considers the latter two factors set out in the above list and as such, there is no evidence that economic or infrastructure needs have been accounted for by the Council in its assessment of housing need. Taking this in account Gladman cannot conclude that 678 dwellings represents a sound level of housing need for Tunbridge Wells and further work is needed.

Housing Requirement

5.1.11 To aid the transparency and clarity of the Local Plan, Gladman consider that the housing requirement should be set out within Policy STR1. The adoption of this approach will improve the accessibility and legibility of the document and allow for more effective plan monitoring (see Section 7 of this representation).

Housing Supply

5.1.12 Table 1 of the Local Plan provides a breakdown of housing land supply as of 1st April 2019. Table 1 confirms:

* There have been 1,552 dwellings completed in the District between April 2016 and March 2019;

* There is a residual requirement of 12,008 dwellings at 1st April 2019 to meet the current identified local housing need;

* At 1st April 2019 there were commitments for 3,127 dwellings;

* This excludes a further 580 dwellings at existing allocated sites;

* A windfall allowance of 700 dwellings is made for the remaining plan period; and

* There is a need to identify allocations sufficient to deliver 7,593 dwellings to meet needs not already committed, allocated or accounted for.

5.1.13 The position set out in Table 1 is supported by evidence provided within the Housing Supply and Trajectory Topic Paper. This Paper provides the Council’s rationale for the sources of supply referenced above including existing site allocations and windfall.

5.1.14 For site allocations, the Paper sets out that these have been subject to review by the Council, with sites considered deliverable retained in the supply as part of the new Local Plan. Sites found undeliverable have been removed. Whilst Gladman welcome and endorse the Council’s approach, it is unclear where this assessment is, and as such the Council’s conclusions cannot be examined. Gladman request that this is made available before the Local Plan is submitted to the Secretary of State for examination.

5.1.15 To demonstrate the windfall allowance applied through the emerging Local Plan the Council provide completions data for sites of 1-9 dwellings which have taken place in the authority since 2006. The data shows that on average around 144 dwellings were delivered at windfall sites over this period. Whilst this would appear to justify the 50 dwelling per year allowance made, it is unclear whether the Council’s sample includes garden land development or not, and if it does, what effect this would have on identified rates were it to be excluded. Further information is needed from the Council in this regard before the Local Plan is submitted to the Secretary of State.

5.1.16 The overall level of supply provided by allocations identified within the local plan combined with commitments, completions and other sources of supply is outlined in Paragraph 4.16 of the Local Plan to amount to 14,776 dwellings (a 9% buffer).

5.1.17 The decision made by the Council to identify a surplus of land in comparison to the housing requirement is welcomed. This is necessary to ensure that the Local Plan is resilient to change and continues to be effective over the plan period should sites not deliver as expected.

5.1.18 Gladman is however concerned that a 9% buffer in housing land supply is insufficient and should be increased to around 20% (an equivalent uplift of 1,496 dwellings against that currently planned by the Council). This is of increased importance in the case of Tunbridge Wells noting:

* The designation of 22% of land in the authority as Green Belt including surrounding the main settlements of Royal Tunbridge Wells and Southborough, severely restricting development in this part of the District;

* The absence of any carried forward safeguarded land within the District, and need set out within national planning policy to ensure that Green Belt boundaries set out in a Local Plan endure beyond the end of the plan period [6 See Paragraph 136 of the 2019 NPPF.];

* The proportion of the District located within the High Weald Area of Outstanding Natural Beauty amounts to 70% (overlapping with Green Belt in some areas). This designation significantly restricts the delivery of major development in a large part of the District with a requirement to meet the tests of Paragraph 172 of the NPPF for any major development proposal brought forward in the area; and

* The Plan contains several large-scale strategic sites which are identified to contribute significantly in response to residual housing needs in this plan period (circa 5,000 dwellings). If assumed timescales and delivery rates are not achieved at these sites, the Local Plan will quickly fail based on the current supply position.

[TWBC: see full representation].

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

DLP_6788

G M Whitehead

Object

Policy Number:  STR1

‘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.’

Just how appropriate is the development soon to be foisted on Cranbrook?

5. New Healthcare Centre – When? Where? What other local services for 761 new houses in Cranbrook and 108 in Sissinghurst?

DLP_6797

Kember Loudon Williams for Wedgewood (New Homes) Ltd

General Observation

This submission is made in response to the Tunbridge Wells Borough Council’s (TWBC) Consultation Draft Local Plan (Regulation 18). It is made by Kember Loudon Williams on behalf of Wedgewood (New Homes) Limited.

A separate, fully detailed Supporting Statement has been prepared to accompany these representations (See Chapter 3 of the Statement), which supports Horsmonden as a suitable and sustainable location for a modest amount of additional housing to that which is currently proposed to be allocated, particularly given the stated importance elsewhere in the draft Plan (including at paras. 4.38 and 4.40) of only considering development within AONB areas ‘having first maximised potential outside the AONB’.

Horsmonden is one of the larger villages in the Borough and unlike the great majority of villages in the Borough sits outside the AONB, and is unencumbered by Green Belt designation. Submissions in the KLW report demonstrate that the settlement is perfectly capable of accommodating a further 35 homes, which is a modest 11 per cent uplift in the number currently proposed to be allocated to the Settlement in the first Draft Local Plan.

We propose to increase the current housing allocation given to Horsmonden Parish by 35 residential units. This can be accommodated on land South of Goudhurst Road, Horsmonden.

This will not require amendment to STR1 itself, but will require amendment to Table 3 which is referred to in STR1 – see comment box 6 below.

[TWBC: see Supporting Statement and Comment Numbers DLP_6793, 6797-6799, 6801, 6803-6804]

DLP_6875

Rosemary Cory

Object

Policy Number: STR 1

The Plan does not seem to follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages.

The quick and easy option pursued by the Council involves identifying land which owners are prepared to offer for development regardless of the impact on the landscape, sustainability or local communities. This is despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB.

If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents.

I believe that the Council’s conclusion (for example, at Paragraph 4.34) that the sites identified for mass housing estates are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper.

The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions.

Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted.

The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments.

Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed.

For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place.

It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them.

The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:

1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan;

2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point.

Hawkhurst

The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course.

The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village.

The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan.

There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development. Note, also, that Natural England have stated that they will ask the Secretary of State to “call in” any such application which is approved by the Council.

Non-compliance with Hawkhurst Neighbourhood Development Plan

The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment.

Lack of adequate infrastructure

Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament.

The proposed development would impact unacceptably on an AONB

The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019.

The proposed development would not constitute sustainable development

The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment.

Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents.

There are very limited local employment opportunities and no secondary schools within walking distance.

The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution.

The village is already a congestion black spot and subject to unacceptable levels of pollution – results of formal pollution monitoring in the village will be available shortly. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it.

TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103).

The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate.

The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF.

There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF.

The “relief road” will not work

The so-called “relief road” (which has been conceived by the putative developers of the Golf Course site) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny.

As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes.

DLP_6947

Hallam Land Management Ltd

 

Table Number: STR 1

Development being identified to other settlements, consistent to the dispersed strategy is welcomed, in particular the level of development identified to Cranbrook. It is recognised the constraint of the AONB has limited growth in Cranbrook and the draft housing numbers of 718 – 803 needs to be kept under review and where sites in the AONB can meet the tests set out in the NPPF, these should be maximized to take advantage of the sustainability of Cranbrook.

DLP_7090

Brown & Co Planning Ltd for The Hendy Group

General Observation

COMMENTS ON THE STRATEGIC OBJECTIVES (SECTION 4)

Policy STR 1 - The Development Strategy; General Observation

1.125 Policy STR 1 states that ‘Where major development is provided for at specific identified sites in the AONB, this is only where the tests set out in the NPPF are met’.

1.126 Our Client would like to highlight that through the allocation of a site in the AONB, the Council is recognising that the site is suitable for development.

1.127 In order to ensure that allocations are brought forward in line with the Local Plan, allocated sites should not have to go through the process of demonstrating that the proposal will make a positive contribution toward achieving the AONB Mana