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Policy AL/CA 2: Land to east of Tonbridge/west of site for Tudeley Village


This response report contains comments received on Section 5: Place Shaping Policies – Capel section.

Contents

Policy AL/CA 2: Land to east of Tonbridge/west of site for Tudeley Village

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_325

Mark Daters

Object

I object to the development of Sites 447 and 454 referred to in the following.

The Sites 447 and 454 are Green Belt Sites which may only be developed on passing an “exceptional circumstances” test.  In 2017 TWBC stated that the potential level of harm of utilising Green Belt land at these Sites would be categorised as “very high”, the highest category.  Therefore, TWBC have made their own assessment and case not to develop land on Sites 454 and 447 and remove Greenbelt.  Not satisfying the “exceptional circumstances” test and the highest level of potential harm make potential development of these Sites unsuitable.

The Sites are located on the edge of Tonbridge at the boundary of TWBC and not near Tunbridge Wells.  We await responses from TMBC as TWBC must consult with neighbouring local authorities.

Allocating the Sites 447 and 454 to development of a secondary school is unsuitable.  It is in a different location to the proposed Tudeley Village development and separated from Tonbridge by the A26.  There is no provision for walking to or cycling to the Sites so would increase car traffic significantly.  The Sites are located between the A26 and B2017 which are already congested on weekday mornings from about 7.45am to 9.00am.  TMBC conducted a Transport assessment in 2018 which evidenced that the A26 and the B2017 will not be able to handle an increase in traffic before considering the subsequent proposed development at these Sites. They indicated that some junctions at this location were already at near full capacity with projections to 2031 increasing the traffic flow.

A school on these Sites would not be serving a local settlement and its catchment is in Tonbridge (TMBC) which is already sufficiently served by secondary schools.  Therefore, this does not pass the “exceptional circumstances” test of Green Belt development.

TWBC need to demonstrate there is no realistic alternative to developing a school at these Sites to serve a new housing development.  This cannot be demonstrated as these Sites are is a different location to the new housing development they are supposed to be serving and nearer an existing settlement in a different local authority.

Tonbridge (TMBC) will bear the brunt of the development of these Sites and development of Tudeley Village to the extent proposed from increased population, traffic and commuting from Tonbridge station.  The areas around Tonbridge High Street, Tonbridge Station and Cannon Lane at the new Retail Park are already regularly gridlocked.

Any development would impact nine listed buildings in Postern Lane to the East of the Sites: Grade II* - The Postern and Upper Postern Farmhouse and Grade II – Postern Heath, Postern Forge, Postern Park, Pond Oast, The Stables, Old Barn and Upper Postern Oast.

There is no access to a public highway currently to either of the Sites. Postern Lane is single private road with limited passing places and there is no legal right of way for changed use of the land.  The TMBC Transport assessment in 2018 referred to above evidenced that the A26 or B2017 at the perimeter of the Site could not cope with increased traffic.  These roads are regularly gridlocked at peak driving times.

The Sites are split by a railway line is unsuitable for a school.

The busy A26 on the perimeter of Tonbridge at the border of TMBC and TWBC serves as a boundary to protect urban sprawl from Tonbridge which serves some of the purposes of Green Belt land, specifically, “to check the unrestricted sprawl of large built-up areas” (Tonbridge), “to prevent neighbouring towns from merging into one another (Tonbridge to Paddock Wood based on the proposed development).

Therefore, based on the numerous reasons outlines above the proposed Sites for the new school are completely unsuitable.

DLP_59

Thomas Weinberg

 

Comments on Policy AL/CA 2 (Land east of Tonbridge, west of Tudeley) p.164

This policy refers to a site that is wholly unsuitable to the development of a secondary school due to the:

* Railway line

* Busy roads

* Flood risk

* High pressure gas pipeline risks

* Unsustainable transport links to Tonbridge and Tunbridge Wells Town Centre

* Reliance on private car use for staff and students’ families.

There is no evidence that the development at Tudeley, with 1,900 homes built in the next 15 years, will have enough children of Secondary School age to fill an eight form entry secondary school.

Most of the students will come from Tonbridge and Southborough/Bidborough resulting in a high increase in levels of traffic and significant reduction in air quality.

DLP_141

Gregg Newman

 

Comments on Policy AL/CA 2 (Land east of Tonbridge, west of Tudeley) p.164 

Again here I quote from a previous submission since it precisely sums up my own views:

QUOTE

This policy refers to a site that is wholly unsuitable to the development of a secondary school due to the:

  • Railway line
  • Busy roads
  • Flood risk
  • High pressure gas pipeline risks
  • Unsustainable transport links to Tonbridge and Tunbridge Wells Town Centre
  • Reliance on private car use for staff and students’ families.

There is no evidence that the development at Tudeley, with 1,900 homes built in the next 15 years, will have enough children of Secondary School age to fill an eight form entry secondary school.

Most of the students will come from Tonbridge and Southborough/Bidborough resulting in a high increase in levels of traffic and significant reduction in air quality.

Is a students’ ability to get between lessons without being hit by a train going to be part of the admissions process? The risk to students is extremely high and the school should not be built on this site.

UNQUOTE

Children will die or at best be injured. Think about it!

DLP_8330

Andrew Richards

Object

INTRODUCTION

I am not a resident of Tunbridge Wells Borough, but I live near to the Borough boundary just outside Tonbridge.

I visit the Borough regularly and enjoy the benefits of its countryside, notably the Green Belt and the Areas of Outstanding Natural Beauty, which need to be preserved in line with National Planning Policy.  I also drive around Tonbridge regularly and am shocked at the impact the proposals in your draft Local Plan (LP) would have on Tonbridge and its environs.

The LP is vast and complex and has clearly consumed a significant amount of effort; I congratulate the officers for their diligence in seeking to balance the various competing demands of policy, legislation and local constraints. As a private individual I do not have similar resources or expertise; I have therefore confined my comments to a small number of topics.  This is not to say I endorse the remainder of the LP and its associated material; I am aware of some of the concerns raised by others and support many of them.

Notwithstanding the level of effort that has gone into the LP, I’m afraid my overall assessment is that the Borough has fallen short of the diligence needed.  Sadly, it seems to have taken the easy way out of its obligations in a number of areas.  It has:

  • Failed to challenge the standard method for determining the housing need;
  • Failed to widen its search for housing sites beyond those yielded in the voluntary Call for Sites;
  • Analysed poorly those comments raised against the Issues and Options paper;
  • Failed in its Duty to Co-operate with Tonbridge and Malling Borough Council (TMBC);
  • Been selective in its application of the ‘exceptional’ burden of proof;
  • Opted for the easy route of selecting sites for large scale development owned by a single or small number of landowners;
  • Failed to take account of commuting habits and the pressures resulting from its proposals on rail services, notably but not exclusively in Tonbridge;
  • Failed in its duty of care to students by proposing the establishment of a new school spanning a busy railway line;
  • Failed to provide housing suitable for an increasingly aging population

I conclude that the Borough has failed to meet the required standard for a Regulation 18 consultation and should repeat the exercise, having first addressed some of the fundamental concerns raised.  I believe this plan requires too substantial a series of amendments to proceed directly to a Regulation 19 consultation.

My comments are in relation to a number of documents identified below.

Policy AL/CA 2 – School

29. I object to the policy for the new secondary school. Specifically:

a. The location spans a railway line and therefore conflicts with The School Premises (England) Regulations 2012, para 6, which state “School premises and the accommodation and facilities provided therein must be maintained to a standard such that, so far as is reasonably practicable, the health, safety and welfare of pupils are ensured”.

Conclusion

39. In conclusion, to reiterate the point made in opening, I conclude that the Borough has failed to meet the required standard for a Regulation 18 consultation. It should therefore repeat the exercise, having first addressed some of the fundamental concerns raised.

40. I believe this plan requires too substantial a series of amendments to proceed directly to a Regulation 19 consultation.

[TWBC: See full representation]

DLP_279

Peter Hills

Object

Additionally, I wish to object to the allocation of “Land to east of Tonbridge/west of site for Tudeley Village” (Policy AL/CA 2)

Many of the points above also apply to this objection.  Particularly the impact on local traffic, and the additional problems caused because a railway line divides the site.

The use of this site for a school is completely impractical.  I do not believe it will be possible to minimise trips to and from it by private vehicle given its location and the distance from any public transport provision.

The link between the two sites is a private road, and public footpath, across a narrow railway bridge. It is unsuitable as a link between the two sites and I do not believe it would be feasible to create a practical link.

DLP_284

Paula Hills

Object

Additionally, I wish to object to the allocation of “Land to east of Tonbridge/west of site for Tudeley Village” (Policy AL/CA 2)

Many of the points above also apply to this objection.  Particularly the impact on local traffic, and the additional problems caused because a railway line divides the site.

The use of this site for a school is completely impractical.  I do not believe it will be possible to minimise trips to and from it by private vehicle given its location and the distance from any public transport provision.

The link between the two sites is a private road, and public footpath, across a narrow railway bridge. It is unsuitable as a link between the two sites and I do not believe it would be feasible to create a practical link.

DLP_494

Tonbridge Civic Society

Object

Tonbridge Civic Society – the largest amenity society in Tonbridge with almost 500 members – objects to the above proposals, which would have a big impact on Tonbridge and the countryside near it.

We oppose very strongly on environmental, amenity and infrastructure grounds the proposal to build up to 2800 dwellings at Tudeley, which is less than 2 miles from Tonbridge (indeed, it is much closer to Tonbridge than to Tunbridge Wells):

  1. it is environmentally irresponsible to build what is in effect a new small town in an area with no existing public transport, a town whose 5000 or so inhabitants will be dependent on cars to go anywhere;
  2. a development of this size in the Green Belt and immediately adjacent to the High Weald Area of Outstanding Natural Beauty is unacceptable and will destroy the fine, pastoral landscape at Tudeley: it would be contrary to national planning policy;
  3. All Saints, Tudeley has become one of the most visited small churches in England because of its Chagall glass: it attracts visitors from all over western Europe. They see now a church amidst fields. If the plan goes ahead, they will see a church in a housing estate. It is extraordinary that Tunbridge Wells Borough Council is prepared so to compromise one of Kent’s most important buildings;
  4. the impact on Tonbridge of this development would be severe. The town has significant traffic problems at peak times because of the concentration of schools and the presence of one of the busiest commuter railway stations in south east England. It would be inevitable that a large development at Tudeley, combined with yet another secondary school on the edge of Tonbridge proposed in this plan, would make those problems worse;
  5. existing overcrowding at Tonbridge railway station would be exacerbated.

The impact on Tonbridge would be in addition to that of the extensive new development which has recently taken place in the town and which is proposed in Tonbridge and Malling Borough Council’s own plan.

The fact that one landowner has accumulated a great deal of land round Tudeley with the aim of developing it is not a reason for allowing this proposal to go ahead. The proposal needs to be looked at objectively, not regarded as a matter of convenience for the Council and the landowner. Looked at objectively, the case against it is overwhelming.

It would make much more sense to develop the large tract of unbuilt land on the north-eastern edge of Tunbridge Wells between Pembury Road and the A21 which would offer easy access to the centre of Tunbridge Wells, including its railway station and to the railway station at High Brooms, both of which are much less busy than that at Tonbridge.

The Civic Society also objects to the building of a new secondary school on the eastern edge of Tonbridge. Tonbridge already has one of the highest concentrations of secondary schools of any town of its size in England. It will be a major traffic-generator, drawing yet more people from the east and south-east of the town towards Tonbridge.

Moreover, urban sprawl east of Tonbridge is undesirable and will impinge visually on Somerhill and its park. If Kent County Council and Tunbridge Wells Borough Council judge that a new secondary school is needed in west Kent, it should be built at Paddock Wood or Pembury.

DLP_8011

David Hugh Tennent

Object

I have been fortunate enough to benefit from the beautiful Kent countryside afforded by the green belt, which we very much hope will be protected and enhanced, as required by the National Planning policy.

The Postern is a grade II* listed building, dating from 1753, and the garden is classified as a ‘formal garden monument’.

I have been a schoolmaster at Tonbridge School, teaching biology and geography, for 37 years (with a keen interest in ecology) and we have lived at The Postern for 26 years. We know the locality well and feel very privileged to live here.

I would be grateful if you would add my details to your database, so that I can be kept informed of future consultations on Planning Policy. I understand that my comments will be published by the Borough Council.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

I plan to do this in two sections: Firstly, the objection to the proposed school on the land to the South of Postern Lane (Sites 454 and 447) and secondly a more general objection to the proposed ‘Garden settlement’ at Tudeley [TWBC: See comment DLP_8010].

The objection to the proposed school on the land to the South of Postern Lane (Sites 454 and 447)

Green Belt

Allowing development of sites 454 and 447 is of concern, because it would breach the barrier, formed by the A 26, which separates Tonbridge from the green belt. This would allow Tonbridge to sprawl into the open countryside to the East of the town. One of the stated reasons for the green belt is ‘to check unrestricted sprawl of large built up areas’ (such as Tonbridge).

Traffic

Traffic on the local roads is already at overcapacity, even before allowing for the impact of a large new secondary school. Cars on the B2017 are ‘nose to tail’ at peak times in the morning and afternoon, resulting in drivers trying to take a shortcut through Postern Lane. The local plan seems to assume it will be possible to achieve additional infrastructure to get staff and pupils, as well as parents to and from the school, without providing any detail of what form this might take or where it might be. Surely this should be thought through first, before any proposal is submitted or considered.

Flood risk

Part of both sites are included in ‘flood zone 3’, which suggests a high probability of flooding. There have been several occasions over the last 25 years when the stream has broken its banks to the South of the lane. The new school would, of course, significantly increase the rate of run-off from buildings and tarmac, adding to the flood risk.

Loss of agricultural land

Both sites are designated grade 2, which indicates high quality agricultural land and I gather several rare species are to be found on these sites and in the woodland.

Heritage assets

There are nine listed buildings close to site 447 and the area has strong historic connections to the iron industry of the 15th and 16th centuries. (May I recommend a small book, sponsored by Tunbridge Wells Borough Council, called ‘Capel Explored’. It provides a valuable insight into what makes this such a special and unique area, worthy of preservation)

Pevsner refers to Postern Lane as ‘A charming and remote seeming hamlet, though only a mile from Tonbridge’. If this school proposal goes ahead, Postern Lane, far from being charming and remote, will form the new eastern boundary of Tonbridge.

Access to the school

Postern Lane is a private road and the lane is single track and winding, with few places to pass. Quite apart from the fact it is private, this is a completely unsuitable route for access to the proposed school. Cars travel along Postern Lane at speed and it contains several blind corners. Under no circumstances would I let any of my grandchildren walk along it unsupervised. Just as much of a problem is the fact that the site is split through the middle by the railway line and it is not clear how one side of the site could safely be joined to the other. Having taught boys between the age of 13 and 18 for over 3 decades, I am conscious of several reasons why a bridge across a railway line for the use of pupils could be a serious problem.

Tonbridge is well known for its schools. There are already 5 secondary schools and 2 primary schools close by.

Another school, located a significant distance from the area it serves, will only add to the congestion and delay to traffic. And most of the journeys will be by car. The school is not within easy walking distance of the proposed settlement at Tudeley and it is a long way from Tonbridge station. It is not even clear which routes cyclists might take.

For all these reasons, to conclude that this is not a sensible site for a school, is something of an understatement.

Thank you for reading this submission and I apologise for its length, but we feel very strongly that the Green Belt should be preserved for all the reasons outlined above. Finally, I do hope that the Tunbridge Wells planners will listen to these objections and take them seriously. This did not seem to be the case at the meeting I attended at the Tunbridge Wells offices on 15th August 2019, but I am very hopeful that this was not typical of the way these meeting are normally conducted.

DLP_8046

Postern Lane Residents Association

Object

Address Sites 454 (“Land at the east of A26, Postern, Tudeley, Tonbridge, Kent”) and (“Land at the east of A26, Alders Wood, Tudeley, Tonbridge, Kent”)

The residents of Postern Lane listed in Appendix 1 November 2019

Introduction

1 This statement is made on behalf of the residents of Postern Lane listed in Appendix 1 to set out our strong opposition to the proposed inclusion of Sites 454 and 447 (both greenfield sites adjoining Postern Lane) in the draft Local Plan as suitable for development as a secondary school.

2 Sites 454 and 447 have been included in order to provide a site for a secondary school to serve the proposed new town at Tudeley. The views of the residents of Postern Lane in relation to the New Town are being submitted individually. This collective objection relates only to Sites 454 and 447.

Summary

3 We summarise our objections to the development of Sites 454 and 447 as follows:

a. These Sites are wholly unsuited for use as a secondary school. At a macro level they are in the wrong place and would cause massive traffic disruption if developed as a school. At a micro level they are a very poor site for a school, being split by a main railway line and including flood plain, a large block of ancient woodland and a high pressure gas line.

b. The Sites are prime agricultural land and habitat and environmental destruction would be unacceptable.

C. These sites are designated Green Belt land. That designation may only be changed if the “exceptional circumstances” test can be met; it cannot. TWBC itself, as recently as July 2017, stated that the potential level of harm to the Green Belt associated with a release of this land was “very high” (its highest category of harm). The Sites are also immediately adjacent to the AONB.

d. Postern Lane abounds in heritage assets and development of Site 454 would adversely impact the setting of nine listed buildings.

e. Tonbridge and Malling BC (which was not consulted before this plan was formulated even though the land is on the edge of Tonbridge) strongly objects to this development and we agree with its reasons.

4 We now briefly expand on these points in turn.

Unsuitability of the sites: macro level

5 This is a ridiculous site to choose for a school, wherever the pupils come from. It is 1.2 miles (25 minutes’ walk) from Tudeley Church (so this is the minimum distance for students coming from the New Town) and 1.3 miles from Tonbridge station (which is likely to be where other students come from). It is cut off from Tonbridge by the fast bypass road (A26). There is no bus route and no pedestrian access. The only way to access it is by car.

6 We note the statement in the draft Local Plan that “The school shall be designed to minimise trips to and from it by private vehicle and to facilitate active transport modes, such as walking and cycling from (the new townj”.

7 This is fantasy. A school here will inevitably generate a great deal of car traffic. Even schools in the centre of Tunbridge Wells and Tonbridge generate large volumes of car traffic; a school on a site as isolated as this will generate far more. TWBC cannot magic this issue away by blandly stating that it will encourage cycling and walking. The A26 and B2017 are exceptionally busy roads at peak times and no parent will want their child cycling on them; there is no pavement on the B2017 or on the east side of the A26. There is no pedestrian access to this site at all.

8 So the addition of a large new school at Sites 454 and 447 will inevitably create a significant increase in car traffic, and the evidence is clear that the existing road network will not be able to cope with that increase. For the purposes of its own Local Plan, Tonbridge and Malling BC commissioned a Transport Assessment from Mott MacDonald dated May 2018. This included an assessment of the two junctions on the A26 nearest to Sites 454 and 447: to the north what was designated Junction 17 [1 The junction between Vale Road and Vale Rise (a three way roundabout, just outside Tunbridge Wells Borough).] and to the south what was designated Junction 18. [2 The junction between Woodgate Way (A26), Tudeley Road (B2017) and Five Oak Green Road (a four way roundabout).] See road map at Appendix 3. Both these junctions will be directly affected by traffic to and from the Sites.

9 Simply looking at existing conditions (assessed in 2017):

a. Junction 17 is already operating at almost maximum capacity, with two of its three exits having an RFC (“ratio of flow to capacity”) of 0.919 and 0.970 in the morning peak. [3 Mott MacDonald Report May 2018 table 57.] (As the report states, “An RFC of 0.85 or below is the desirable threshold; a junction would operate adequately between an RFC of 0.85 and 1.00; and any RFC values exceeding 1.00 are considered to be over theoretical capacity and therefore over maximum capacity”). [4 Mott MacDonald Report May 2018 page 22.]

b. Junction 18 has an RFC of 0.823 on the Tudeley Road in the morning peak, with a mean maximum queue of 44 Passenger Carrying Units. [5 Mott MacDonald Report May 2018 table 60. This does not accord with our experience as local residents: Junction 18 is heavily overloaded at the morning peak in school terms and traffic regularly backs up to Tudeley.]

10 The forward Projections (to 2031) show this worsening:

a. Junction 17 will have an RFC of 0.962 and 0.997 on two of its exits. [6 Mott MacDonald Report May 2018 table 58.]

b. Junction 18 will have an RFC of 0.827 on the Tudeley Road in the morning peak, with a mean maximum queue of 70 Passenger Carrying Units. [7 Mott MacDonald Report May 2018 table 61.]

11 Even accepting this evidence at face value, the critical point is that these assessments do not factor in the impact of a new school on Sites 454 and 447. It is obvious that creating a large new secondary school will generate a substantial volume of new car traffic and TMBC’s evidence clearly shows that the existing road network simply does not have the capacity to cope with this increase.

Unsuitability of the sites: micro level

12 The Sites are bisected by the main railway line to Ashford. This has three serious implications for the suitability of the Sites for a school.

13 First, they cannot be used together as one site without more bridges. We note the statement in the draft Local Plan that “There is an existing link (which forms a public right of way) between the two sites”. But this “existing link” is completely inadequate.

a. It is a single lane bridge with two blind corners. It is wholly unsuitable for regular use by school traffic and it would be unsafe for such use.

b. The public right of way referred to is only a footpath along a private road — there is no right of way for wheeled traffic. (The landowners of the Sites do not own the bridge and cannot grant a new type of right of way over it.) It would not be safe for large numbers of students to be regularly crossing the bridge on foot and heavy foot traffic would also seriously disrupt the existing use of the bridge by vehicles.

c. The bridge is in any event at the far eastern boundary of the sites and thus impractical for day to day use.

14 So a school here would require at least one new bridge over the main rail line to access its playing fields. This would require the consent of Network Rail.

15 Even if that were achieved, the result would still be only to achieve a school which consists of two small sites split in two by a main rail line; how can this seriously be regarded as sound planning?

16 Second, even if new bridges are built it is undesirable for adolescent students to have such constant and easy access to a main rail line, both because of the risk of vandalism and because of the sad but real risk of self harm (the existing bridge was used as a suicide site a few years ago). It would be highly irresponsible to place a school here.

17 Third, the constant noise from passing trains (which in addition to engine noise are obliged to sound their horns along this stretch because a footpath crosses the line at Tudeley) will negatively affect the concentration levels of students. No responsible educationalist would choose such a position.

18 It is no surprise to see that KCC, the relevant education authority, has not endorsed the selection of this site. Our understanding, from discussions with KCC staff at the road shows, is that KCC regards this as a poor site for a school. We agree.

19 In addition to the rail line issues, there are the following further micro-issues with the site:

a. As shown in Appendix 4, much of Site 454 and a part of Site 447 lies within Flood Zone 3 as defined by the Environment Agency. These parts of the land thus have a high probability of flooding. We note the statement in the draft Local Plan (p161) that “the layout of the school shall avoid built development in areas of highest risk of flooding (Flood Zone 3)”. If this statement is followed, it will remove a large proportion of the developable land.

b. A high pressure gas pipe crosses the northern Site.

Loss of agricultural land and other environmental issues

20 Both sites are Grade 2 agricultural land. [8 TWBC Development Constraints Study October 2016, Figure 5.] Grade 2 land is rare in the Borough. [9 See TWBC Agricultural Land Classification Study 2014. It is not easy to see what conclusions this study reaches, since it offers various different figures: Table 1 on page 2 states that only 4.4% of TWBC land is Grade 2, based on the Provisional ALC Map; but paragraph 3.5 on page 19 states that the Provisional Map shows that grade 2 comprises only 0.5% of the Borough’s agricultural land; and paragraph 3.17 states that there “may be” more grade 2 land than either figure.] The NPPF states as follows:

a. “Planning policies and decisions should contribute to and enhance the natural and local environment by ... recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services — including the economic and other benefits of the best and most versatile agricultural/o nd”, [10 NPPF para 170(b). “Best and most versatile agricultural land” includes Grade 2: see Glossary, p65.] and

b. that “Where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality”. [11 NPPF footnote 53.]

21 Site 447 includes Alders Wood (see aerial view at Appendix 2), which is a large block of ancient woodland and a prime wildlife habitat. We note the statement in the draft Local Plan that “The layout of t/ie school shall avoid built development in, and have regard to, the areas of Ancient Woodland and their buffers ...” \l this restriction is respected, it removes a further large proportion of developable land.

22 Further, both sites are recognised as habitats for priority species Lapwing and Turtle Dove (listed respectively as Red and Amber listed “Birds of Conservation Concern” by the RSPB). Both the Sites are also partially bordered by ancient hedgerows, also protected by the Wildlife and Countryside Act 1981.

Heritage assets

23 Developing Site 454 would adversely impact the setting of no fewer than nine listed buildings (see Appendix 5). This does not seem to have been considered in the Draft Plan at all.

a. Site 454 is directly opposite The Postern, a Grade II* Listed Building mentioned by Pevsner with gardens which are classified as a Formal Garden Monument.

b. Site 454 is also directly adjacent to Postern Forge, a Grade II Listed Building dating from the 15th century. According to KCC Heritage Records it “may have been built in 1480 by Thomas Willard, iron master, and was certainly associated with the iron trade for many generations. The forge dam adjoins the house.” The reference to the forge dam is amplified by the Kent Heritage Assets mapping service, which records the section of Postern Lane forming the northern boundary to Site 454 as a Monument, since it was the bay to the forge. [12 The Bay, length 140m, height 1.5 to 2.75m now forms Postern Lane. The water system is dry and the spillway situated at the west end. Forge bottoms and cinder, and cannon balls found by the owner of Postern Forge house which is timber-framed and probably contemporary. Liable to confusion with Rats Castle Forge (see TQ 64 NW 8) and Old Forge, Southborough (see TQ 54 SE 5). They are all probably ironworks operated by David Willard in 1553.”] Not far to the north lies the remains of Rats Castle Forge, a listed Monument thought to be the second of two medieval iron forges recorded in 1574 and constructed by David Willard. [13 KCC Heritage Records.]

c. Approximately 100m to the north west lies Postern Heath Farmhouse, a Grade II Listed Building mentioned by Pevsner.

d. Approximately 200m to the east lie:

i. Upper Postern Farmhouse, a Grade II* Listed Building mentioned by Pevsner; and

ii. Upper Postern Oast, a Grade II Listed Building.

e. Approximately 350m to the north east lie:

i. Postern Park, a Grade II Listed Building;

ii. The Old Barn, a Grade II Listed Building;

iii. Pond Oast, a Grade II Listed Building; and

iv. The Stables, a Grade II Listed Building.

24 So Postern Lane holds two out of only 133 Grade II* Listed Buildings in the entire Borough.[14 TWBC Historic Environment Review 2018, p28. It also has 7 of 2,089 Grade II Listed Buildings.] It also has strong historic associations with the medieval Wealden iron industry, which is singled out by TWBC’s own Historic Environment Review as being of special importance for conservation in the Low Weald. [15 TWBC Historic Environment Review 2018, para 4.2.12.]

25 Development of Site 454 will harm the setting of all these heritage assets through visual encroachment (as well as adversely impacting residential amenity).

a. The NPPF states “Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting , should require clear and convincing just///cat/on”. [16 NPPF paragraph 194, emphasis added.] The Glossary defines the setting of a heritage asset as: “The surroundings fn which a heritage asset is experienced. Its extent is not fixed and may change as the asset and its surroundings evolve”.

b. English Heritage has published Good Advice Practice on The Setting of Heritage Assets in Practice Note 3 (Second Edition) 2017. This points out that “Setting is the surroundings in which an asset is experienced, and may therefore be more extensive than its curtilage”(p2).

C. Although experience of a heritage asset is not dependent on public access, in fact a popular public footpath runs along Postern Lane and it is thus clear that the public’s experience of those heritage assets which front onto Postern Lane (which are The Postern, Postern Forge House and Postern Heath Farmhouse) will be materially adversely affected by development of these two Sites.

d. In TWBC’s own words, “The historic character of the Low Weald is particularly vulnerable to poorly managed development at the urban frinae, especially around Paddock Wood and Five Oak Green”. [17 TWBC Historic Environment Review 2018, para 4.2.11.] This is an excellent summary of the proposed development of Site 454 (and indeed Site 447) on the urban fringe of Tonbridge.

26 Postern Lane is a little corner of the Low Weald which is extraordinarily rich in heritage; Pevsner calls it “A charming and remote-seeming hamlet, though only a mile from Tonbridge. The handsome brick houses of the early C18 make it memorpb/e ”. [18 “Pevsner Architectural Guides - The Buildings of England: West Kent and the Weald” (John Newman) (1980) p576.] This description is as accurate today as it has been for three centuries. But if this proposal proceeds, the effect will be to bring the urban edge of Tonbridge right up to the west edge of the lane and to destroy its historic character forever. Postern Lane will in effect become the new eastern boundary of Tonbridge.

27 We note the statement in the draft Local Plan that the proposal “shall have regard to” the setting of the Somerhill Park and Garden, but whatever this vague statement means it seems to have wholly overlooked the other important heritage assets (listed above) which would be more immediately affected.

Green Belt & AONB

28 The National Planning Policy Framework (“NPPF”) (February 2019) deals with “Protecting Green Belt Land” in Section 13. Para 134 states as follows:

Green Belt serves five purposes: a) to check the unrestricted sprawl of large built-up areas; b) to prevent neighbouring towns merging into one another; c) to assist in safeguarding the countryside from encroachment;

d) to preserve the setting and special character of historic towns; and e) to

assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

29 TWBC engaged Land Use Consultants Ltd in 2016 and 2017 to carry out an assessment of the extent to which various parcels of the Green Belt land within the Borough served the first four of these five purposes. [19 Tunbridge Wells Green Belt Study, Stage Two Final Report prepared by LUC July 2017. See paragraph 5.2, "Assessment Principles", for an explanation of why the fifth purpose (urban regeneration) was not assessed.] Since "Broad Areas" BA3 and BA4 (as defined by Land Use Consultants Ltd) are respectively defined as land south and north of the main railway, Site 454 lies in Broad Area BA3 and Site 447 lies in Broad Area BA4.

30 The conclusions of the assessment were summarised in Table 6.1 of the Stage 2 report as follows:

Area

Purpose (a)

Purpose (b)

Purpose (c)

Purpose (d)

Overall Harm Rating

BA3

Strong

Strong

Strong

Weak or no

contribution

Very high

BA4

Relatively

weak [20]

Strong

Strong

Relatively

weak

Very high

[20 Although BA4 (Site 447) was assessed as "relatively weak" for Purpose (a) (which is “to check the unrestricted sprawl of large built-up areas“), this assessment covers the area as a whole. Different considerations apply to Site 447 when considering its micro-location as a buffer to Tonbridge.]

31 It follows that TWBC’s own assessment of the "broad areas" in which Sites 454 and 447 lie is that there is a very strong case against allowing any land within them to be withdrawn from the Green Belt.

32 This becomes even more clear when examining not merely the "broad areas" as a whole but the specific position of Sites 454 and 447. They lie just outside Tonbridge, immediately to the east of the A26 ring road (see aerial view, Appendix 2). At present the A26 represents a strong and important physical barrier to the urban sprawl of Tonbridge. Allowing development of Sites 454 and 447 would breach that barrier and allow Tonbridge to sprawl into the open countryside to the east, closing the gap between Tonbridge and Tudeley/Five Oak Green. This would be the clearest possible breach of national policy.

33 TWBC could only lawfully remove Sites 454 and 447 from the Green Belt if it could positively show that "exceptional circumstances" exist justifying their removal: NPPF para 137. It cannot begin to do so. A school on these sites would not serve any existing settlement in the Borough and would in practice be more likely to draw students from a different borough (Tonbridge and Malling). They could therefore only be required as a school at all if the New Town proceeds. If the New Town proceeds, then TWBC needs to show that there is no realistic alternative to Sites 454 and 447 for a school serving the needs of the New Town. This is obviously not so, as TMBC has already pointed out, and TWBC does not appear even to have considered alternative sites.

34 As to AONB, although the Sites are not within the designated AONB they are literally on the other side of the B2017 from it. They are attractive countryside and the quality of their landscape is equal to that of the adjacent AONB. These sites are highly visible in the wider landscape and there will be a serious loss of amenity if they are developed. No assessment of landscape impact appears to have been made.

TMBC and the dutv to consult

35 Under s110 of the Localism Act 2011, TWBC has a duty to consult with (among others) Tonbridge and Mailing BC. This is not optional, it is obligatory.

36 This was not done before the draft Local Plan was produced. This was an extraordinary omission given the proximity of these sites to Tonbridge.

37 A letter to TWBC dated 16 October 2019 from Mr Ian Bailey, TMBC’s Planning Policy Manager, makes the following comments, which we endorse:

a. This is “a constrained site with poor access, adjacent to a town which already has

a large number of existing secondary schools and the associated transport issues.” We agree.

b. TMBC has a “concern that the proposed developments close to the built confines of Tonbridge would result in the coalescence of the settlements of Tonbridge, Capel, Tudeley, Five Oak Green and Paddock Wood”. We agree.

C. In relation to transport issues, TMBC says that new bus routes would be welcomed BUT that “there are significant delivery challenges in ensuring that route is feasible, particularly within the two town centre environments”. We agree, although we think that this significantly understates the problems.

38 These concerns lead TMBC to suggest that an entirely new location should be found for the new secondary school, if there is to be one. It suggests “a location at or preferably between the new settlement at Tudeley and the allocations at Paddock Wood”, since this “would represent a more sustainable solution, being closer to the need generated and the potential for reducing the need to travel to a site on the periphery of Tonbridge”. We agree.

39 The views of TMBC are of particular significance given that this proposal is to create a large school in what is, effectively, Tonbridge. Tonbridge already has a high number of secondary schools relative to its population and attracts students from a wide catchment area; it does not need another one attracting even more. This is a poor and unsound plan.

Conclusion

40 Developing Sites 454 and 447 would not be a sensible piece of strategic planning. It would be contrary to national and local policy; it would destroy Green Belt and prime agricultural land; it would have a negative impact on significant heritage assets; it would create traffic chaos on what the evidence clearly shows is an already overloaded road network; and it would create a school split in two by a main railway line. The New Town at Tudeley should not be created at all; but even if it is, a different site needs to be found for any associated school. These sites should not be included in the draft Local Plan and the draft is unsound.

Appendices

1 List of Postern Lane Residents on whose behalf this objection is being lodged.

2 Aerial view marking the Sites.

3 Road map showing affected junctions.

4 Environment Agency Flood Map showing the Sites.

5 Aerial view showing heritage sites in relation to Site 447.

[TWBC: signed by 26 Postern Lane residents - for appendices and signatories see full representation].

DLP_571

Lee Prebble

Object

Introduction

I am not a resident of Tunbridge Wells Borough but live near to the Borough boundary with Tonbridge. I do visit the Borough on a regular basis and enjoy the significant benefits of the countryside and Green Belt that should both be protected and enhanced as required by National Planning Policy.

The Draft Local Plan documents produced are vast and complex. As an individual I do not have the time and resources to examine each and every part and policy in detail. I have, therefore, concentrated on consideration of two particular aspects of the Draft Plan that concern me most (the proposed development at Tudeley and the proposed secondary school on land in west Capel). That is not to say that I support other policies in any way. Indeed, I am aware of some of the concerns of others and agree with many of them.

I may also add that I am a retired member of the Royal Town Planning Institute and have some considerable experience of the production of local plans. I have to say that I would not be at all happy to put documents like these to the public. In essence, I consider the approach has been shoddy and the output both dubious and faulty in many respects. I would go so far as to say I would be ashamed to have these as part of my legacy.

My comments are in relation to three documents: the Distribution of Development Topic Paper; the Sustainability Appraisal and the Draft Local Plan.

Draft Local Plan

  1. As indicated in my introduction I am primarily concerned with two developments proposed in this Draft Plan (DP) at sites AL/CA1 and AL/CA2. As an individual with limited resources I have not been able to assess other policies and proposals in the DP. It should not be taken that I support any of those policies in any way shape or form.
  2. The Overview of Capel Parish commencing on page 154 is incomplete. It identifies Landscape Character Areas but provides no actual assessment of the quality of the landscape; there is no recognition of the quality of the land in relation to agriculture and actually confirms that, in relation to buses it has yet to be updated. This is very poor practice and demonstrates an extremely sloppy and unprofessional approach to the production of this document.
  3. I object to Policy STR/CA1 and in particular the developments proposed at points 1, 2 and 3 of the Strategy; and the release of Green Belt land.
  4. It is significant to note that at point 13 land outside the AONB is recognised as having similar characteristics (to the AONB) and is likely to contribute to the setting of the AONB. This is the first time this has been given any recognition in the production of the Draft Plan. It was not mentioned in the Distribution of Development Topic Paper or the Sustainability Assessment. This is preposterous! If that recognition had been given to the land earlier in the process it would have weighed heavily against the designation of such land for development. In this respect the policy is self-contradictory and without merit. For this reason the policy is unsound and should be deleted.
  5. The section on Masterplanning and Delivery leaves crucial elements of the process to a later date. It assumes that it will be possible to achieve necessary infrastructure but makes no provision for any contingency if infrastructure is not possible or delayed. To leave these key aspects to be resolved till later is unsound.
  6. Similarly it assumes that equalisation agreements are highly likely yet provides no indication what these will entail and how they will be achieved. It leaves key factors in the development process to chance and provides no guarantee that acceptable sustainable development will result. The Local Plan should provide deliverable development and not leave key elements to chance. This Draft Plan fails to provide the proper assurance that the development in an acceptable and sustainable fashion is possible and for this reason the Plan is unsound.
  7. The Strategy relies on achieving a number of strategic transport links but provides no proper detail of these links and no assessment of the impact of the links on the AONB, Green Belt or the local environment. The Plan is deficient and unsound in these respects.
  8. In relation to secondary education the Draft Plan relies on a new secondary school on a site which is not only unsuitable but is understood to not currently have the agreement and backing of the Education Authority. This is simply unsound planning.
  9. This Strategy is ill-thought and lacking in the necessary clarity as to detail and how it will be achieved. It leaves much to chance and speculation and lacks the necessary assessment of the impact on key factors including the local environment and transport. The Strategy is unsound and should be deleted from the Plan.
  10. Map 37, that identifies the allocated site CA1, is flawed. It has an out of date base and fails to identify significant areas of tree cover, for example. It has unexplained holes within the area of the site allocated. The Key to the map refers to 3 elements that do not appear on the map at all; Community UsesOpen Space and Landscape Buffer and Safeguarded Land. Again this demonstrates a lackadaisical and poor approach to the preparation of the Draft Plan. It is entirely unclear how the boundaries were identified but it is easy to speculate that they were dictated by the landowner. That is not a properly considered approach to the determination of a key development site; it is unsound.
  11. Once again this demonstrates that the production of the Draft Plan has been simply a desk exercise with no proper assessment of the site that has been allocated and no understanding of how the development will relate to the area and the land on which it is allocated.
  12. This completely inadequate approach to the allocation of a key site demonstrates that the Council’s preparation of this Draft Plan has been completely unsatisfactory and the Draft Plan is unsound.
  13. The description of the site (para 5.60) confirms that it includes Ancient Woodland, archaeological potential, listed buildings and is adjacent to a Biodiversity Opportunity Area yet none of these are identified on the Map and there is no apparent provision to modify or adapt the development in any way shape or form to ensure that there is no harm to these important designations. As discussed earlier it has been acknowledged that development immediately adjacent to a designation can have a serious and harmful impact on that designation. To ignore this is a serious omission and makes the Draft Plan unsound.
  14. The description does say that the land is likely to provide the routes of transport links yet gives no indication as to how this can or will be achieved. Again this makes the Draft Plan unsound.
  15. This land is not suitable for the proposed development for a number of reasons:

    * It is attractive countryside that is highly visible in the wider landscape and will suffer serious loss of amenity if developed;

    *The quality of the landscape is equal to that of the adjacent AONB as confirmed in Strategy STR/CA1; that landscape quality will be destroyed for ever;

    *It is also good quality agricultural land (a factor unrecognised in the description of the site) and is part of the local ecosystem with a complex biodiversity that the Council has failed to properly assess.

    *The roads are inadequate to accommodate the necessary transport links in an acceptable and sustainable manor;

    *there is no current infrastructure;

    *The area cannot absorb a development of the scale proposed without significant and irreparable damage;

    *The development of a settlement of the scale proposed is completely disproportionate to the scale of development in the locality. It will destroy the existing rural character; and

    * existing residents, their rights and amenities will be completely overcome and lost by the size and scale of the new development.

  16. There are not very special circumstances that justify the removal of this land from the Green Belt. This land was designated part of the Green Belt many years ago for sound reasons that remain. The intention was that the land should remain free from inappropriate development for the long term. There has been no proper assessment of the impact of the proposed development on the openness, landscape or visual amenities of the Green Belt. As such there has been no considered approach to weighing all relevant factors in the decision to allocate this land in the Draft Plan.
  17. The allocation of this land will result in urban sprawl and significantly diminish the gap between Tonbridge and Five Oak Green contrary to the fundamental aim of including this land in the Green Belt in the first place.
  18. No amount of Masterplanning will overcome the basic issues and harm that will result from developing this land.
  19. The Policy AL/CA1 sets out a number of requirements without any demonstration as to how those might be achieved. It is ‘motherhood and apple pie’ without any justification or proper analysis of how the requirements will realistically be achieved. The Policy is unsound.
  20. The Policy requires the development to be on a sustainable scale that supports the necessary infrastructure but fails to provide any detail as to what is meant by this. Without proper assessment of what that infrastructure might be it cannot possibly be assessed whether the land can satisfactorily accommodate the development.
  21. The Policy requires a number of elements in relation to transport yet the reality is that the site is a significant distance from a train station and it is highly likely that the new residents will wish to commute. To avoid large numbers of private cars will require a fleet of buses over a long period of the morning and evening commuting times. This is unrealistic. Even if that issue were resolved there is a further issue with the capacity of the train stations and trains to accommodate the additional people likely to use them. There has been no assessment of what the numbers might be let alone how they might be accommodated. The whole thing has simply not been thought through. It is unsound.
  22. The Policy makes it clear that studies relating to land use, landscape character, visual amenity, biodiversity and heritage have yet to take place. These are important matters that should have been part of the consideration and assessment as to whether the land is suitable for the development proposed. The cart has been well and truly put before the horse leading to an ill-considered allocation and an unsound Plan.
  23. Point 11 of the policy AL/CA1 states that the development is subject to the provision of a new secondary school. The proposal for the secondary school is unacceptable as explained below. It is also understood that the school has yet to have the backing of the Education Authority. This aspect of the policy should mean that if the school does not go ahead then the whole ‘Tudeley Garden Village’ should not go ahead.
  24. I am no expert in ground water or flooding matters but these should not be left to chance and a later stage as seems to be the approach in this instance.
  25. I object to policy AL/CA1 and consider it should be deleted from the Draft Local Plan.
  26. Map 38, that identifies the allocated sites CA2, is flawed. It has an out of date base and is incorrect in relation to areas of tree cover, for example. The Key to the map refers to 2 elements that do not appear on the map at all; Community Uses, and Safeguarded Land. Again this demonstrates a lackadaisical and poor approach to the preparation of the Draft Plan. It is entirely unclear how the boundaries were identified but it is easy to speculate that they were dictated by the landowner. That is not a properly considered approach to the determination of a key development site; it is unsound.
  27. Once again this demonstrates that the production of the Draft Plan has been simply a desk exercise with no proper assessment of the site that has been allocated and no understanding of how the development will relate to the area and the land on which it is allocated.
  28. This completely inadequate approach to the allocation of a key site demonstrates that the Council’s preparation of this Draft Plan has been completely unsatisfactory and the Draft Plan is unsound.
  29. The description of the site confirms that it is split by a main railway line but suggests that there is an existing link via a public right of way. There is no recognition of the constraints that actually arise from developing a school on a split site either side of or immediately adjacent to a railway or the fact that the public right of way is actually a private drive. The practicalities of the proposal have simply not been properly thought through.
  30. There is no mention that the proposal is in any way endorsed by the Education Authority and the views of that key authority are conspicuous by their absence.
  31. Other constraints are also noted but there is no consideration of landscape impact, impact on biodiversity or visual amenity. There is no proper balancing exercise in the allocation of this land.
  32. This land is not suitable for the proposed development for a number of reasons:

    * It is attractive countryside that is highly visible in the wider landscape and will suffer serious loss of amenity if developed.;

    *The quality of the landscape is equal to that of the adjacent AONB as confirmed in Strategy STR/CA1; that landscape quality will be destroyed for ever.

    *It is also good quality agricultural land (a factor unrecognised in the description of the site) and is part of the local ecosystem with a complex biodiversity that the Council has failed to properly assess.

    *The roads are inadequate to accommodate the necessary transport links in an acceptable and sustainable manor;

    *there is no current infrastructure.

    *The area cannot absorb a development of the scale proposed without significant and irreparable damage; and

    *It is unrealistic to suggest that trips to and from the site by private vehicles can be minimised. All secondary schools in this area attract pupils and staff from a wide area; they will not all come from the proposed Tudeley development site. There is already significant pressure on roads in southern Tonbridge at school delivery and collection times given that there are five existing secondary and two primary schools nearby. This proposal will only add to the congestion, delays and potential for road accidents in the vicinity.

  33. There are not very special circumstances that justify the removal of this land from the Green Belt. This land was designated part of the Green Belt many years ago for sound reasons that remain. The intention was that the land should remain free from inappropriate development for the long term. There has been no proper assessment of the impact of the proposed development on the openness, landscape or visual amenities of the Green Belt. As such there has been no considered approach to weighing all relevant factors in the decision to allocate this land in the Draft Plan.
  34. The allocation of this land will result in urban sprawl and significantly diminish the gap between Tonbridge and Five Oak Green contrary to the fundamental aim of including this land in the Green Belt in the first place.
  35. The Policy AL/CA2 sets out a number of requirements without any demonstration as to how those might be achieved. It is ‘motherhood and apple pie’ without any justification or proper analysis of how the requirements will realistically be achieved. The Policy is unsound.
  36. It is clear that studies relating to land use, landscape character, visual amenity, biodiversity and heritage have yet to take place. These are important matters that should have been part of the consideration and assessment as to whether the land is suitable for the development proposed. The cart has been well and truly put before the horse leading to an ill-considered allocation and an unsound Plan.
  37. I object to policy AL/CA2 and consider it should be deleted from the Draft Local Plan.

DLP_8116

Ashley Saunders

Object

This policy refers to a site that is wholly unsuitable to the development of a secondary school due to the:

  • Railway line
  • Busy roads
  • Flood risk
  • High pressure gas pipeline risks
  • Unsustainable transport links to Tonbridge and Tunbridge Wells Town Centre
  • Reliance on private car use for staff and students’ families.

The proposed secondary school site is in a dangerous place, with a railway line running through the site.  It will add an unacceptably high level of traffic to/from Tonbridge with a negative effect on the town’s infrastructure as well as the setting of the Grade 1 listed Somerhill. The development at Tudeley, with 1,900 homes built in the next 15 years, will be unlikely to have enough children of Secondary School age to fill an eight form entry secondary school. Most of the students will come from Tonbridge, Tunbridge Wells, Southborough, Bidborough and Paddock Wood. The road infrastructure is not capable of sustaining this pressure and it will provide for an over reliance on the car given its distance from central Tonbridge and Tunbridge Wells and its otherwise rural catchment.

DLP_653

Jane White

Object

I wish to object to your Local Plan developments in the Parish of Capel and for Tudeley.

This is Green belt Land which is so vital to our countryside and originally designated to stop the fingers of encroaching building engulfing good farm land, small hamlets and villages into urban sprawl.

The infrastructure of the proposed developments, with access roads joining the already over full country lanes leading to Paddock Wood, Tonbridge, Tunbridge Wells, the A21, railway stations and schools, will be a nightmare.

There is also the problem of water, drainage and sewage on the low lying land near the river Medway which is already suffering from pollution, and possible flooding.

I cannot think of a more unsuitable area to consider building houses. STOP THIS PLAN NOW.

DLP_8261

Alan Chilvers

Object

Objection to Policy STR/CA1, AL/CA2, AL/CA3, AL/ PW1

The reason for this objection is summarised below:

1) Duty to Cooperate

2) Lack of detail and Clarity within the Infrastructure Plan

3) Transport

4) Housing Policy

5) Economic

6) Risk Management & Development Strategy Masterplanning

7) Heritage

8) Climate Change - Have not considered Climate Change Polices

9) Green Belt

10) Landscape & Amenity

11) Water & Aquifers

12) Air Pollution & Air Quality

13) Dark Skies

14) Biodiversity

15) Ancient Woodland

16) River Medway

17) Quarries

18) Flooding

19) Loss of Agricultural Land

20) Noise

21) Railways

22) School

Duty to Coperate:

OJEU- Is a legislative process that all local authorities must go through regarding public procurement; due to the most unusual partnership the council has adopted with the landowner to jointly promote the masterplan.

Lack of engagement between KCC and TWBC- No signed Statement of Common Ground Letter (SoCG) to KCC regarding KCC Minerals & Waste Draft Plan and no commentary regarding KCC Policies DM7 and DM8.

Part of CA 1 development was until recently included within the KCC Minerals and Waste Draft Plan.

TWBC have previously made robust objections and commentary to KCC regarding previous and current quarry proposals within the Kent Minerals and Waste Draft Plan including -

Development of the site should only take place where there is no unacceptable adverse impacts on health and amenity and appropriate mitigation which is reasonably practical should be implemented to protect residents. Further technical assessments should be robust, thorough and have particular regard to the following both in terms of impact of individual sites and in terms of cumulative impact.

Transport links, including highway safety, operation of the highway network and access. Residential amenity, including in terms of impact via noise, dust, vehicle movements, air quality, vibration etc;

Flooding, both in terms of surface water and groundwater; Pollution, including in terms of the aquifer protection zone; impact on Green Belt,

Landscape impacts, including setting of the AONB;

Heritage: there are areas of potential archeological importance within the vicinity of allocations, as well as a number of listed Buildings (some of which form part of historic farmsteads),the settings to which are important;

Impact on high pressure gas pipeline; Trees, including areas of ancient woodland; Ecology, including local wildlife sites;

Considering CA 1 is closely situated to M:13 Stonecastle Farm Quarry and M:10 Moat Farm it is very confusing that TWBC does not consider all the above commentary it has made relevant for its CA 1 development proposals.

Planning Application reference : 18/01767/FULL - Erection of building 6 B&B rooms associated with the Poacher, Hartlake Road Tudeley Tonbridge TN110PH

31st July 2018- The Council REFUSES Planning Permission for the above for the following reasons:

(1) The proposal would constitute inappropriate development within the Metropolitan Green Belt, which by definition is harmful to its openness. There is insufficient evidence of the necessary ‘ very special circumstances’ to overcome this harm.

(2) It would not conserve and enhance the rural landscape character of the locality, nor would it protect the countryside for its own sake, nor preserve the interrelationship between the natural and built features of the landscape. The overall Impact is harmful to the rural character of the area.

(3) It has not been demonstrated that the occupiers of the development would not be at risk from flooding or that the development would not increase flood risk elsewhere. Therefore the development is likely to result in a risk to human life from flooding.

Again this refusal of planning permission is closely situated to CA 1, but all the reasons for TWBC to reject this application now appear to be void and irrelevant for 2,800 new houses..

Lack of Detail / Clarity within the Infrastructure Plan

The Plan preparation process did not initially include CA1 & CA2 (Tudeley Sites) until the Issues and Options Process Stage, therefore many of the processes and procedures that were undertaken with other sites have not been completed due to timing constraints, for example NO detailed Green Belt study has been undertaken, which given this is the largest identified site within Green Belt it should have been paramount and a requirement that such important analysis should have been concluded before any submission to the plan.

No Biodiversity Assessment, again fundamentally given that this whole area is heavily populated with many species of wildlife and plant life that such ecological studies and analysis should have been undertaken prior to any submission to the plan.

NO Flood Risk Assessment CA1 as large parts of the development are proposed to occur on The Medway Floodplain, with 2,800 homes this will have many effects on the Floodplain and could have serious flooding implications to the area, without consultation with the Environment Agency and Southern Water. The partial removal of the floodplain without expert consultation analysing the area and the effects this could have, does not demonstrate good compliance and governance, the Medway Floodplain is historically well know flood vulnerable area, Climate Change within CA1 is a major consideration and has not even been considered within the preliminary inclusion of this site. Very vague and lack of detail flood mitigation proposals within the plan are just not good enough, further Upriver storage at the Leigh Flood Barrier will not provide any flood mitigation to CA1.

NPPF paragraph 173 also states that that in order to ensure both viability and the deliverability of development, careful attention to viability and costs in plan-making and decision-taking is required.

Policy EN:1

1) Ensure there is adequate drainage provision. This will ensure that surface water is appropriately controlled within the development site, flood risk is managed on-site and off site, and any existing flood risk, in the locality is not exacerbated: and

2) Avoid inappropriate new development within such areas at risk from flooding, or mitigate any potential impacts of new development within such areas whereby mitigation areas measures are integral to the design of buildings.

How has surface water runoff been considered in the scheme?

Have areas at risk of flooding been avoided before mitigation measures have been considered?

Policy EN: 28

Proposals for new development should contribute to an overall flood risk reduction, and development will only be permitted where it would not be unacceptable risk of flooding on the site itself, and there would be no increase to flood elsewhere.

There is no evidence within the plan that demonstrates that the above policies have been addressed therefore the plan is not sound.

The infrastructure Delivery Plan demonstrates a wish list of objectives and fails to determine how such essential infrastructure will be implemented. This plan makes numerous references to further details available within the Masterplan which has yet to be shared with Members of the Public.

From the information available the essential infrastructure requirement prior to any development at CA1 has NOT secured future funding and is heavily reliant on Public Funding.

Potential Funding Sources;

2.27 New Development is generally expected to meet the needs for infrastructure that are generated from the development itself. This can be in the form of connections to utility services or the building of new roads, junctions, schools, and open space areas. Provision can be delivered directly by the developer or by way of financial contributions to a service provider/ third party.

2.28 The Council will use a combination of Section 106 and Section 278 agreements, alongside Community Infrastructure Levy if the Council decides to pursue this option. Whatever the process is, developers will continue to be expected to meet the needs of the development.

It is understood the Council has entered into a Joint Masterplan Agreement with the landowner of CA1 and CA2, this highly unusual strategy for a LA to partner with the landowner, who has no development experience or track record, it is most concerning that the Council will be reliant on deliverability of one of the most ambitious development projects within the history of the borough, with many questions remaining unanswered regarding funding, delivery and execution.

This strategy does not demonstrate prudent Risk Management has been adopted by the Council, before any development can proceed substantial infrastructure costs will have to be incurred.

These infrastructure costs are reliant on Public Funding as well as third party funding, considering the A228 bypass has been an outstanding project by Highways England for over 30 years, and we understand Southern Water have recently withdrawn its proposals to construct a much needed sewer system upgrade in Paddock Wood due to lack of funding demonstrates that funding such ambitious infrastructure projects within the current economic climate are just not deliverable.

4.56 The Council recognises that in certain instances the provision of infrastructure, including that related to flood storage ( both to mitigate the impact of new development and to provide ‘betterment’), and new transport routes will negatively impact on land, residences, and businesses which otherwise would not directly affected by the Development Strategy of this Plan. This has been considered in the formation of the Development Strategy.

All of the roads, roundabouts, bus lanes and cycle lanes are in the Infrastructure Delivery Plans as post 2025 items.

New roundabout at the Junction of Hartlake and Tudeley Road cost of £100-£500k

Upgraded Somerhill roundabout

B2017 additional capacity improvements Five Oak Green bypass - £100-£500k

-£5- £10m

- £tbc

Colts Hill bypass -£40-£45m

Railway crossings -£tbc

Cycle lanes -£1-£5m

Bus lanes -£5-10m

Some costs may be shared between KCC and developer Senior School - £32m

Primary Schools -£11.5-£15.5m

GP Surgery -£5m

Community Hall -£2.9m

Open Spaces - £tbc

Other costs will be negotiated with developers at planning application stage, water supply, sewage, energy, broad band and flood mitigation.

These estimated infrastructure costs of between £102.5-£125.9m.

If you take into consideration of the last major infrastructure project completed in the area, the A21 dualing project between Tonbridge and Pembury the original budget of £23m -£25m with the completed cost in excess of £70m.

These substantial infrastructure costs do not have any extraordinary cost provisions included and highlights the reliance of the majority of costs will be born by the developer / landowner, should there be further costs incurred to the scale of the A21 project ,highlights the lack of risk management the council has adopted as any substantial cost increase will threaten the economic viability of the development proposals.

Transport

Policy STR 6

This policy states that future development will be delivered within close proximity to accessible locations of existing settlements across the borough to help reduce the need to travel. Where travel is necessary, active travel (walking and cycling) will be prioritised, particularly in the urban areas, and then public transport (rail, bus, car club car share and taxi) as alternative means of transport to the private car.

Ministry of Housing Communities & Local Government Garden Communities Guidance Document August 2018 page 7 (f)

Transport - integrated, forward looking and accessible transport options that support economic prosperity and wellbeing for residents. This should include promotion of public transport, walking and cycling so that settlements are easy to navigate, and facilitate simple and sustainable access to jobs, education and services.

Capel and Tudeley

The current road infrastructure is already at capacity and during peak travelling hours is barely coping with existing daily traffic volumes with long delays, these proposals will further increase the traffic congestion situation within Tonbridge and Paddock Wood.

The sheer scale and size of these proposals will have an immense impact to the current transport infrastructure system with 1000’s of new vehicles accessing Tonbridge and Paddock Wood on a daily basis, this will also increase air quality and motor vehicle emission issues that are already a serious concern within the borough.

TWB is the 8th worst district in Kent for Poor Air Quality, poor air quality is shortening peoples lives. Significant unacceptable detrimental effects on health and amenity of the existing settlements.

The SWECO Local Plan Transport Evidence Base indicates that most households within the area have access to 2 or more cars.

The proposals indicate at least 4,000 new homes will be constructed which would mean additional 8,000 plus vehicles .

The LP Plan promotes prosperity and wellbeing for residents and highlights that it will encourage greater use of public transport, walking and cycling and will provide the necessary infrastructure to achieve this.

The ability to provide dedicated express commuter bus lanes from the Tudeley Village Settlement directly into Tonbridge or Paddock Wood is almost impossible unless many houses within Tonbridge are demolished as the current roads are not wide enough. A bus lane and cycle path could be provided from Tudeley alongside the existing B2017 and the A26 Woodgate Way, but how can a suitable bus lane be incorporated along the A26 Pembury Road and Vale Road especially as these areas are already grid locked at peak travel times.

To achieve a partial bus lane and suitable cycle paths would require further removal of Green Belt/ AONB land and would create access problem for Sommerhil School.

With 1000’s of acres of Green Belt land proposed to be removed and developed, the plan has not considered the horse riding community which will loose many acres they currently enjoy to exercise their horses all of these proposed cycle paths should include the abilty for horse riders to use as routes to access a wider future network of bridleways providing further green spaces for all users to enjoy.

Housing Policy

National Practice Guidance (Housing and economic development needs assessments) defines need for housing as “the scale and mix of housing and the range of tenures that is likely to be needed in the housing market area over the Plan Period – and should cater for the housing demand of the area and identify the scale of housing supply necessary to meet that demand.

If you combine Housing Targets for TMBC and TWBC Draft Local Plans nearly 20,000 dwellings are proposed, with 80% of these houses within a 5.82 mile radius of Capel/ Tudeley.

Capel Parish has a total population of approximatley 2,400 people with plans to develop 2,800 dwellings, this will turn a small village and hamlet communities into a town with a population greater than Paddock Wood ( 8,253 ).

The Tudeley and Capel sites will have extremely high development costs due to the substantial infrastructure costs which will make the deliverability of Social and Subsidised Housing very limited, similar to the Kings Hill Development at West Malling that should have delivered a 35% allocation for Social Housing but actually delivered 17%.

These proposals are aimed at attracting the significant migration growth the borough has experienced from people moving out of London into the borough, and not the local community. TWBC Questionnaire Re Option 5 - New Free Standing Settlement - Only 18% of the 34 respondents ranked option 5 as there preferred choice, 60% of 118 respondents ( Growth corridor) as their most preferred option, and 67% of the 13 Parish Councils disagreed with TWBC proposals within the Draft Local Plan.

Economic

Kent Economic Indicators Report 2019 KCC

Tunbridge Wells ranks well above the national median in five indicators, most notably resident earnings, knowledge economy employs and NVQ4+ which are within 20% of all English authorities. It does however, rank below the national median for 3 year business survival rates, 5 year employee change and employment rate.

Tunbridge Wells ranks higher in 2015 in three Indicators: GVA per head, job density and NVQ4+. Its position has fallen notably in workplace earnings, unemployment, 5 year change and 3 year business survival rates.

The Council (KEAs) Key employment areas in the borough, as defined in the Core Strategy are.

Royal Tunbridge wells Town Centre

Royal Tunbridge Wells - North Farm/ Longfield Road Industrial area Southborough- High Brooms Industrial Park

Paddock Wood- Eldon Way and West of Maidstone Road Paddock Wood- Tranfesa Road East and West

Gills Green - Former Hawkhurst Railway Station and sidings Capel - Brook Farm

All of the above sites already have existing infrastructure and good transport hub connectivity with the exception of Capel/Tudeley, which currently has no infrastructure and very poor transport hub connectivity.

The local Plan very much demonstrates the Councils desire to capture neighbouring Borough Councils economic growth plans and revenues by focusing a majority of its future development plans on TMBC’S ward borders/ boundaries, therefore capturing the high value revenues and relying on TMBC with the ongoing costs of the infrastructure network the Capel developments will be totally reliant on.

“ The borough-wide development requirements for housing, employment, retail leisure and other town centre uses, as well as other supporting users:”

This plan is hardly borough wide as 60% of the TWBC total housing allocation within the Local Plan are within a 3 mile radius with 30% bordering TMBC.

There will be significant cost implications to TMBC, public services such as local health and welfare, emergency services, road infrastructure, schools and public leisure and parking facilities will have to be upgraded to accommodate the Tudeley and Capel Villages residents who will access Tonbridge facilities and infrastructure on a daily basis.

There has not been any consideration of potential loss and effect on existing businesses within the area.

The potential closure or substantial reduction of several thriving businesses within the area such as Moat Farm, Adrian Scripps has been successfully farming this area since 1960, today farming 750 Ha, with 320 Ha of Apples, Pears and Blackcurrants, it is now recognised as one of the Uk’s largest fruit growers, supplying many of the national supermarket chains.

Moat Farm is a key contributor to the local economy providing local employment, a key supporter of innovation and biodiversity preservation.

Bank Farm Equestrian facilities which provides livery for 50 plus horse owners as well as indoor and outdoor riding facilities for many people.

Local shops and businesses in Five Oak Green could suffer substantial income losses or closure.

In recent years Golden Green, Tudeley and Hadlow have enjoyed a positive economic environment as it has firmly established itself as a popular tourist destination in Kent, with people visiting the area from many UK and world destinations, including Australia, USA, South America, India, Hong kong, Singapore, South Africa (Trip Advisor)

It has become evident that such iconic buildings as Hadlow Tower, Tudeley Church, Hadlow Church, Hartlake Bridge, Hadlow Agricultural College, The River Medway, Tonbridge Castle are extremely popular visitor attractions which has led to a noticeable economic uplift to local businesses in the area in recent years.

Local pubs, restaurants, hotels and bed and breakfasts, local shops and businesses have seen a positive economic impact from increased visitors to the area.

Green Belt

Policy STR 4

The release of Green Belt land has been undertaken through this Local Plan, and is detailed where relevant in the place shaping policies in Section 5

In order to protect the remaining Green Belt, as defined on the draft Policies Map, the Council will consider the proposal against the relevant policy in the National Planning Policy Framework, or national planning policy at the time a planning application is being determined.

Substantial Green Belt boundary alterations are proposed in the Local Plan to enable land to come forward for development. National policy is clear that Green Belt boundaries should only be altered in ‘exceptional circumstances’. Even where such exceptional circumstances are demonstrated to exist, consideration must also be given to the nature and extent of the harm to the Green Belt (or those parts that would be lost), and the effect on Green Belt objectives.

The extent of Green Belt in the Parish of Capel is 96% within the whole parish surrounded by Green Belt and ANOB.

These development proposals are alongside further plans with KCC to extend an existing quarry facility at nearby Stonecastle Farm Quarry and a new quarry at Moat Farm which adjoins CA1, these proposals would see the permanent removal of 1000 plus acres of Metropolitan Green Belt Land.

This area has been subject to 40 years of quarry excavation and landfill, the construction of a 100 acre Solar Farm in 2015 , these proposals clearly demonstrate Urban Sprawl.

There is very little evidence within the local plan supporting Green Belt Alterations, the parcels of land are very extensive and further development would be intrusive and would have severe settings implications to existing properties located within the area.

Tunbridge Wells Borough Council Constraints Study Page:16

Section 4: Green Belt 4.1 The Metropolitan Green Belt covers 22% of Tunbridge Wells borough. It should be noted, however, that the Green Belt is not an environmental constraint but a policy consideration.

With this in mind, the extent of the Green Belt is shown within this document for contextual purposes. Figure 6 shows where Green Belt is present. 4.2 Section 9 of the NPPF articulates the five purposes of the Green Belt:

*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 preserve the setting and special character of historic towns

*to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. The plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough.

The Council has not demonstrated any reason why the permanent removal of this Green Belt which also serves a fully functional flood plain ( one of the largest natural flood storage areas within the UK) and is in fact dismissing the substantial environmental value of Green Belt Land which it brings to the area, including significant biodiversity and heritage assets, providing space for water storage to prevent flooding, Carbon capture from acres of mature trees, hedges and historic woodlands.

Furthermore most of this Green Belt area is currently in agricultural use, this can not be considered low environmental value, when global population growth and climate change are putting increasing pressure on land, and when we grow less than two-thirds of our own food. Now more than ever, we need to avoid unnecessary losing our countryside.

Policy STR/CAI The Strategy for Capel Parish.

13.Sites outside AONB but within the High Weald National Character Area, or close to the boundary of the designated ANOB landscape, will have similar characteristics and are likely to contribute to the setting of the designated landscape. The AONB Management Plan and any supporting guidance will be a material consideration for these sites.

[TWBC: for image see full representation].

The AONB boundary is currently defined by the B2017 road, this boundary should be reassessed

as this is a boundary that has been defined for convenience rather than actual functionality, and does not adhere to the

above policy.

The Current Far Reaching Views from the B2017. Any development would have severe scarring within the Medway Valley and the Downs.

The provisional allocation of CA1 and CA2 will result in significant urban sprawl, diminishing a majority of the Green Belt countryside borders between Tonbridge and Paddock Wood.

The evidence within the Draft Local Plan does not provide any special circumstances that justify the permanent removal of this land from the Green Belt. The land was designated as part of Metropolitan Green Belt for sound reasons and particularly to protect and safeguard the many surrounding villages from inappropriate development and urban sprawl and to protect against the proposals that we are strongly opposing today.

Without the appropriate Green Belt assessment analysis that is required to properly evaluate these sites, and the Councils clear reliance on third party and desk top studies do not warrant any claim for the removal of these Green Belt allocations or very special circumstances.

Risk Management & Development Strategy Masterplanning

The Local Plan does not demonstrate the adoption of a robust risk management strategy, allocating 60% of its total housing allocation within a 3 mile radius, bordering another borough of which will result in TWBC receiving all the income from the new developments and TMBC left with all liabilities and ongoing cost of the all the relevant infrastructure and public services that will be required.

The Plan preparation process did not initially include CA1 & CA2 ( Tudeley Sites) until the Issues and Options Process Stage, therefore many of the processes and procedures that were undertaken with other sites have not been completed.

Despite CA1 being located within a designated flood zone area, and locally well know as a flood vulnerable area, within a designated fully functional flood plain ( one of the Uk’s largest natural flood storage areas)

No Green Belt Assessment
No Flood Risk Assessment Report
No Ecological Biodiversity Assessment No Landscape Sensitivity Assessment No Environmental Assessment
No Transport Assessment No Heritage Assessment

The Local Plan mentions a comprehensive masterplan approach, but does not provide any detail of implementation or costings, however the Council state that they have agreed a highly unusual strategy of jointly promoting the masterplan with the landowner.

The landowner does not have any development experience. Considering these proposals are the largest development plans in the history of Capel / Tudeley and many surrounding villages that will be effected, the deliverability and financial resources of the landowner should be closely scrutinised.

The high risk strategy the Council seems to have adopted for CA1, despite many highly

regarded ,experienced developers/ promoters advising that CA1 & CA2 are development projects full of extreme risk and substantial cost overruns and delays, as major parts of the infrastructure plan are dependant on public funding and the financial resources of a single landowner.

Already there are many questions and issues, including Southern Water announcing recently that the proposed sewer upgrades at Paddock Wood have been abandoned due to lack of funding and commercial viability, this has led to the suspension of the construction of further developments within the Paddock Wood area as the current sewer infrastructure can not provide any further capacity.

The proposed extension of Stonecastle Farm Quarry and additional Quarry at adjoining Moat Farm, within Kent County Councils Minerals and Waste Local Plan 2013-2030 has not been fully considered within the CA1 development plans.

Who will want to buy a house looking into a quarry?

Potential individual site viability influences relating to likely highly variable abnormal development costs and also to matters that will only impact in certain instances (such as Flood Risk (FR) mitigation and/or Air Quality Management (AQM) related requirements have not been specifically accounted for at this stage.

The evidence that has currently been presented within the local plan highlights the financial instability and potential cost volatility, as any CIL / Section 106 payments still leave a substantial funding gap to fund all the necessary infrastructure costs.

Heritage

There are some heritage assets of strong community importance within close proximity to the proposed CA1 & CA2 sites including Somerhill, All Saints Church, Tudeley, Hadlow Tower, Hadlow Agricultural College, The River Medway, Mereworth Castle, Roydon Hall and Roydon Church.

The area is surrounded by abundance of listed buildings and distinctive oasts kilns and historic farmsteads, at least 2 Second World War Pill Boxes which will have their settings and residential amenity severely compromised.

The National planning Policy Framework defines the setting of a heritage asset as the surroundings in which it is experienced. The extent is not fixed and may change as the asset and its surroundings evolve. Elements of a setting may make a positive or negative contribution to the significance of an asset; may effect the ability to appreciate that significance;

Historic England Guidance on the setting of Heritage Assets ( Good Practice Advice) advises that the setting may be more extensive than the curtilage and views of or from an asset are an important consideration. It also advises that local planning authorities must consider the implications of development which will materially detract from the assets significance and economic viability.

Several of these heritage properties will have direct views of the CA1 and CA2 sites which will directly effect their setting, residential amenity of these listed buildings permanently.

The proposed development area lies in an area of archaeological importance associated with the Medieval and Post- Medieval period connected to the historic iron industry. Records show there is a recognised Monument named Rats Castle Forge which dates back to the Medieval period, potentially the site of the Tudeley ironworks of the mid- 14th century.

Parts of CA1 are named in the Doomsday book . The remains of the agricultural field system dating from this period are of considerable value to the surrounding rural landscape.

Other heritage assets of archaeological interest include Postern Iron Forge Monument, adjacent to Postern Forge House. Research by the Wealden Iron Research Group suggest that it dates from between 1553 and 1622.

Hartlake Bridge was known to exist in 1460 as in 1451 John Tatlyngbery who lived in Barnes place left money in his will for the repair of the road and bridge at Hartlake, as did Henry Fane in 1533.

As set out in the NPPF, heritage assets are an irreplaceable resource that should be conserved or enhanced in a manner appropriate to their significance. Any harm or loss will require a clear and convincing justification.

The setting, significance, and importance of historic buildings can be seriously harmed by inappropriate neighbouring developments and /or uses. Therefore, for any proposals that would have an impact on the setting of a listed building, applicants will be required to submit technical and illustrative information about the proposed development and its relationship to its setting as part of a heritage statement and/ or design and access statement.

The Council refers within the plan that many conservation appraisals within the borough are no longer fit for purpose as they were conducted over a decade ago, one would hope such appraisal for CA1 and CA2 will prioritised due to the sheer size of the development proposals as well as TMBC recognising the River Medway Valley as a conservation area within its Local Plan.

Climate Change -

Climate change is a serious problem with far reaching consequences. The Local Plan polices, Policy EN 5 lack any detail or clarity and should be far more robust.

NPPF 14 Meeting the challenge of climate change, flooding and coastal change.

148. The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. it should help to:shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings, and support renewable and low carbon energy and associated infrastructure.

Planning for climate change

149. Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long- term implications for flood risk and coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures. Polices should support appropriate measures to ensure the future resilience of communities and infrastructure to climate change impacts, such as providing space for physical protection measures, or making provision for the possible future relocation of vulnerable development and infrastructure.

So far the local plan demonstrates the complete reverse of the NPPF Climate Change Policies,

1) Greenhouse gas emissions and Carbon reduction will increase substantially over the development period, with the large number of HGV’s, and various construction machinery accessing the site as well as the local road network, and the proposed quarry extension at Stonecastle Farm and additional quarries at the adjoining Moat Farm will all have a detrimental effect with local air quality and carbon emissions.

2) Long term flood risk implications- This is currently unknown as the Council has not conducted a flood risk assessment of CA1 and CA2, despite NPPFs guidance in section 155, Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk (whether existing or future). Where development is necessary in such areas, the development should be made safe for its lifetime, without increasing flood risk elsewhere.

Local authorities are also advised to adopt a precautionary approach to the issue of flood risk, avoiding such risk and managing it elsewhere. The Local Plan is acutely aware of flooding issues across the Borough and the potential implications at the CA1 site, despite this well published information the Council has still chosen not to seek a flood risk assessment unlike other sites that are included within the plan that are within areas at risk of flooding.

As set out in the NPPF Policy Framework, local planning authorities should only consider development in flood risk areas appropriate where informed by a site-specific flood risk assessment. This should identify and assess the risks of all forms of flooding to and from the development and demonstrate how these flood risks will be managed so that the development remains safe throughout its lifetime, taking Climate Change into account. These requirements have not been demonstrated in the Local Plan so far.

3) Policy EN 5 (2) Reduction in flood risk and provision of infrastructure to protect vulnerable communities and habitats, and minimisation of water consumption, so far the plan makes vague references to ‘ensure there is adequate drainage provision’ but does not provide any detail on how this would work in practice. ‘This will ensure surface water is appropriately controlled within the development site, flood risk is managed on-site and off-site and any flood risk in the locality is not exacerbated’. Climate Change is predicted to increase rainfall intensity in the future by up to 40%, this will increase the likelihood and frequency of surface water flooding.

How can the Council even consider these sites suitability as they have not provided any evidence or produced sufficient polices to demonstrate the effects of Climate Change, especially as CA1 borders one of the countries largest natural flood plain storage areas, lack of detail and evidence regarding man-made storage facilities to compensate the loss of flood plain and the reliance of the increased capacity at the Leigh Barrier does not result in sufficient flood and Climate Change mitigation. Avoid inappropriate new development within areas at risk of flooding.

Further evidence should be produced including SFRA and EA data providing assurances to local residents that their homes are not at risk, and the proposals will not cause significant harm to their surrounding amenities.

Landscape and Amenity

Capel Parish has not been included in any of the Landscape sensitivity analysis produced by the Council and its consul-tees, and as per other important issues that have not been addressed in any detail. This analysis is fundamentally important to determine the identified sites are suitable for development, without such information how can such sites be included within the Local Plan?

However with the limited information available publicly, the Landscape Sensitivity Assessment of the Countryside of Tunbridge Wells assess the borough and addresses the Landscape Sensitivity Issues within a traffic light scoring system. Following this principal with Capel one can assume that all the scorings for Capel demonstrate an extremely high sensitivity scoring (RED).

Landscape Sensitivity Assessment of Countryside around Tunbridge Wells Report - LUC Feb 2017

Physical Character

The landscape makes a strong contribution to local landscape character – e.g. it has a distinctive landform, an intact, natural landscape with strong hedgerows, mature trees and other features of interest, such as ponds or watercourses. Strong landform features such as ghyll valleys are likely to be more sensitive.

E.g. Development would have a poor relationship with existing settlement form, crossing a boundary feature and/or extending into an area with a distinctly different landscape – e.g. the extension of settlement beyond a ridge crest, onto steep slopes or into a valley.

Settlement Setting

E.g. The landscape of the sub-area is important to the setting of one or more settlement areas, providing a distinctive element in many or notable views, inward or outward, that are key to the character of the settlement. The landscape of the sub-area is important in the perception of a gap between distinct settlements.

Visual Character

e.g. The sub-area is prominent in views from the wider landscape (e.g. as a result of openness or landform). The sub-area plays a key role in contributing to valued views, such as scenic views within, from or to the AONB. Distinctive or undeveloped skylines with important landmark features are likely to be more sensitive to built development.

Perceptual Qualities

E.g. A relatively tranquil landscape, lacking strong intrusive elements. Extensively dark skies and a high perceived degree of rurality/ naturalness with few modern human influences. High scenic value

Historic Character

E.g. A landscape with many/ highly valued historic features, characteristics or heritage assets that are key to local landscape character. The presence of medieval landscape types such as assarts and commons, which are valued characteristics associated with the High Weald AONB, is likely to increase sensitivity, as is the presence of many/important historic components including ancient route ways, Scheduled Monuments or Conservation Areas. Landscapes which are intact medieval landscapes are likely to be more sensitive.

CA1 is within 1 Km AONB buffer zone so is entirely unsuitable for development of this scale, the associated proposed infrastructure will have a further damaging impact.

The surrounding landscape makes a significant contribution to the North and South Downs with far reaching views over the Medway Valley. Any development upon the ridge of ANOB would be severely impacted with permanent scarring of these views which would be very detrimental to a significant area of the Kent Countryside.

CA1 borders ANOB, this border has been assumed by the division of the road B2017, this should be re-evaluated as it is a border of convenience and does not consider the prominent and valued views across the Medway Valley.

It is totally unacceptable practice to identify sites for development without providing suitable landscape assessment.

There is no assessment of the visual impact of developments, which given the setting and the contribution of natural beauty to the surrounding areas again demonstrates further fundamental flaws and unacceptable practice within the Local Plan.

The character of the local area, Capel,Tudeley, Golden Green, Whetsted, Five Oak Green villages, which are all situated within Green Belt, would be virtually destroyed by the cumulative effect of these developments, together with the quarry extensions, and the removal of more than 1,000 acres of agricultural land.

Water and Aquifers

CA1 overlies a significant Aquifer of which is SPZ3, for public water abstraction, this is an important local water supply further development of this area may impact water supply options.

As per the recent correspondence between the Environment Agency and KCC regarding the proposed quarrying extensions the EA have concerns that any further development within this area could have a negative impact upon the Aquifers and have requested a Hydrogeological Risk Assessment to be undertaken, this assessment should extend to CA1 as well, to ensure that the Aquifers are not compromised by further development on CA1.

The Aquifer and natural springs within the site will seriously hinder excavations for building, sewage, drainage as suitable mitigation schemes will have to be implemented to avoid puncturing the natural clay membrane that protects the Aquifers.

The Groundwater Protection Zone (GSPZ) situated at Hartlake Road serves public water supplies to South East Water Customers of Pembury and Tunbridge Wells.

SEW have stated they intend to use the same sources of supply Hartlake Wells for future supply but have not anticipated additional provisions for 2,800 new homes, which would result in a water supply deficit in the area by 2030.

SEW have carried out investigations into eight groundwater sources, and within its Water Industry National Environment Programme (WINEP) report it identifies concerns of raw water quality deterioration from levels of nitrate and pesticides, metaldehyde and carbendaizm.

The Hartlake catchment is at risk from nitrate and pesticides and the investigation found a significant relationship between groundwater levels in the river terrace gravels at the Hartlake site and the River Medway levels and flows.

The Draft Local Plan has not considered the potential environmental issues around the Hartlake Aquifers and with rising nitrate and pesticide levels that have already been identified, any penetration to the Aquifers would lead to further significant human health risks.

Draft Local Plan -Water

“New development can impact on water quality through the creation of diffuse pollution from urban surface water runoff. Diffuse urban pollution is a significant factor in compromising the water quality standards that are required under the EU Water Framework Directive the Government recognises that tackling diffuse pollution originating from urban runoff is a high priority.”

There is a large variability in the levels of pollutants in urban runoff. levels of contamination rise with traffic intensities and with contaminants from commercial or industrial activities . it is therefore important that consideration is given to the location of the development.

When sensitive receiving waters are in close proximity, drainage systems must be designed to protect both surface water and ground water. The potential risk posed by a site must be assessed and adequate measures put in place to reduce the risk to acceptable levels. Inclusion if sustainable drainage systems within new development is an important means of reducing urban runoff and improving the water quality of the runoff ( see policy EN 26)”

Policy EN 26 Water Quality, Supply and Treatment

“All major development must demonstrate that there is, or will be adequate water supply and wastewater treatment facilities in place to serve the whole development (including all phases where applicable). Improvements to supply and treatment facilities, the timing of their provision and funding sources will be critical to the delivery of development.”

SEW have already highlighted there could be supply issues by 2030.

SEW will be required to increase the current water infrastructure which will require a substantial developer contribution under the water Act, there are currently no details of these financial obligations required by the developer/ landowner, furthermore there is very little details regarding the improvements of supply, treatment facilities, timing of their provision which the above highlights is critical to the delivery of the development.

The Council states the protection of ground water resources is particularly important in Tunbridge Wells borough, since the majority of the public water supply is abstracted from water-bearing strata or aquifers. The quality of ground water is easily polluted, directly and indirectly and can pose a serious risk to public health.

Water: In Kent we are already using most of the capacity in the county and in some places already exceeding it. This water stress will be exacerbated by growing population and climate change. In addition, the quality of our water effects our health, our economy and our natural environment but is under increasing pressure from pollution, reduced river flows and physical modifications to water bodies.

Clearly CA1 is situated within an area where its water resources are already under serious stress, and currently there are a number of issues outstanding with the Environment Agency, KCC and local residents.

In 2002 KCC refused planning permission for quarry extensions at Stonecastle Farm (M:13) on the grounds of potential pollution and contamination to the Aquifers, as well as concerns of public health risk, as the Hartlake Aquifers are a source of public and commercial water supply.

Recently 2 former landfill sites closely situated to CA1 have been suspected of possible contamination into the surrounding land and waterbodies, which has led to the Environment Agency to announce a they will be conducting a investigation to establish if any contamination has penetrated the Aquifers and surrounding waterbodies.

The Draft Local Plan has not considered the potential environmental issues around the Hartlake Aquifers and, with rising nitrate and pesticide levels that have already been identified, any penetration to the Aquifers would lead to further significant human health risks.

Land Contamination Draft Local Plan

6.289 - “ Any land contaminated with hazardous or toxic materials is a potentially a serious cause of pollution, as well as a threat to human health; it can also migrate into watercourses, impacting not only the water quality, but biodiversity. Contamination can derive from previous uses, such as industrial processes involving chemicals, intensive agricultural , or closed waste disposal sites where landfill gas and leachate are still present.”

6.29 “ The Council holds a wide range of data on potential sources of contamination, such as historic land use, planning history, pollution incidents, details of closed landfill sites, and site - specific reports on investigation and remediation. Further information and guidance can be found on the Councils website.”

Part IIA of the Environmental Protection Act 1990 requires the Council to identify contaminated land that is posing an unacceptable risk to human health or the wider environment, and to secure remediation of that land.

The draft plan does not identify the neighbouring 2 former landfill sites of which have had millions of tonnes of household, industrial rubbish deposited there in the 1980’s and 1990’s, given the historical issues regarding previous mineral workings, and the major concerns of further pollution to the surrounding aquifers it is very concerning that the Council have not appeared to have considered the potential environmental and health risks prior to submission of CA1 to the Draft Local Plan.

Air Pollution and Air Quality

Air quality is vitally important to the quality of life. Developments, if not properly planned and designed, can contribute to the deterioration of air quality which can harm the health of residents, workers, and visitors to the area.

Poor Air Quality arising from traffic congestion is a major public health risk.

With further housing proposals submitted within close proximity to the Tudeley and Capel sites. (Tonbridge and Malling and Maidstone Borough Councils Local Plans,) there could be thousands more new homes constructed during the plan period, all using the current road infrastructure, which will clearly increase air pollution and diminish the air quality within many of the surrounding villages.

The proposed mineral extensions will also have a detrimental effect to local air quality and air pollution, as there will be 30-50 HGV’s operating on a daily basis serving the quarries, additional dump trucks and diesel powered generators and machinery will also be operating within close proximity of CA1.

Dark Skies and Outdoor Lighting

Given the topography of CA1 and CA2, which borders ANOB, which currently provides panoramic views across the Medway Valley and the Downs, with significant areas of ancient woodland, areas of archaeological interest, historic parks and gardens, (Somerhill School, The Postern), large designations of ecological and wildlife which currently remain undisturbed.

How will the addition of 2,800 homes and a secondary school fail not to effect by the removal of the current Dark Skies that are currently enjoyed. The permanent illumination of these proposed developments will have a substantial impact to a much wider area than just the local community as it will be seen from residents on the North and South Downs as well as the Medway Valley.

LCP : 6.115 “ The Impact of light pollution is particularly harmful in the open countryside, where rural character is eroded and the distinction between town and country is blurred: Likewise, light pollution can also compromise the architectural and historical character of conservation areas, and listed buildings or their settings. The full effects of artificial lighting on biodiversity are not fully understood, but nocturnal animals can be seriously affected by artificial light at even very low levels, adversely affecting their ability to feed and reproduce.”

Sky Glow and luminance should be at zero, with particular consideration given to the dark skies of the High Weald ANOB as set out in the High Weald ANOB Management Plan.

Biodiversity

NPPF -15. Conserving and enhancing the natural environment.

170. Planning polices and decisions should contribute to enhance the natural and local environment by:

a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan):

The LP does not demonstrate any enhancement to the valued landscape, combined with the proposed further mineral extractions within the area, will permenantly remove 1,000’s of acres of Metropolitan Green Belt, Prime Agricultural Land. Surrounding, current fertile soils will be removed and replaced with overburden and gravel pits.

The loss of the current valued landscape will have catastrophic consequences for the current rich ecological and biodiversity habitat that are evident in the area. No amount of mitigation, compensation will provide such a rich and fertile environment currently enjoyed by the wildlife and plant-life today.

b) “recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services-including the economic and other benefits and most versatile agricultural land, and trees and woodland:”

This proposed development area has been farmed for many generations, providing local employment, positive contributions to the local economy. The farming community has developed the intrinsic character and beauty of this area, and have supported and developed a vibrant biodiversity conservation programme.

Recent and proposed development has/ will see the removal of many mature trees, woodland and hedgerows.

It is well documented this area has highly valued versatile agricultural land, as history has demonstrated, evolving from cattle farming, hops, orchards and soft fruits and cereal crops. Hadlow Agricultural College which originated over 50 years ago, purchased Bourne Grange Estate Hadlow, as the area was locally known for its rich and fertile soils within the Medway Valley, which provided the college the ability to grow the diverse range of crops needed to service both agricultural and horticultural departments.

England’s protected landscapes are amongst its finest and most treasured landscapes. The landscapes we see today are cultural landscapes- the result of thousands of years of human influence on the countryside as people interact with nature. They continue to be living and working landscapes and the people who manage the land today safeguard their special qualities.

d) “Minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are most resilient to current and future pressures:”

The LP mentions Policy AL/CA 1 5. iii “ Existing habitats and species and opportunities for landscape scale improvements for biodiversity to ensure a net gain for biodiversity focused on key locally important habitats and species (see policy EN:11 Net Gains for Nature; biodiversity and

EN 12: Protection of designated sites and habitats):”

Policy EN 11-Net Gains for Nature: biodiversity

Development will only be permitted where it meets all of the following criteria:

1) It can demonstrate to the satisfaction of the Council through the application of an acceptable method of measurement, or impact assessments, that completion of the development will result in a measurable long term net gain for biodiversity:

It is most concerning that as to date the Council has been happy to proceed with the Inclusion of CA 1 and CA 2 within the LP based off very vague and generalist desktop study which takes a borough- wide assessment - Biodiversity Evidence Base for Draft Local Plan- Regulation 18 Consultation September 2019.

In view of the size and scale of the proposed developments (one of the largest within the plan) and the potential net loss of land, far more information should have been provided within the plan.

No biodiversity assessment has been produced to date, it is very evident that the Council have not collaborated with other local authorities who have development plans within the area as many biodiversity issues have arisen which will have a direct effect to these sites.

The LP should ensure that biodiversity cannot be offset elsewhere, and must demonstrate through a clear application metrics that net biodiversity gain is achieved now, and not some point in time, in the future.

The Government 25 year Environmental Strategy requires net gains for biodiversity this is reflected within the NPPF.

NPPF Habitats and biodiversity

174.To protect and enhance and geo-diversity, plans should

a) “Identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them; and areas identified by national and local partnerships for habitat management, enhancement, restoration or creation and”

b) ” promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity.”

The adjoining Farm, Moat Farm is bordered to the north-west by Ancient Woodland, with further Ancient Woodland situated on the site to the south-west.

Stonecastle Farm, has Ancient Woodland, there is BAP habitat Deciduous Woodland.

Both areas have been part a resurgence in Biodiversity conservation over the last 30 years with Moat Farm working in collaboration with the RSPB to protect and preserve Turtle Doves.

The Former landowner of Stonecastle Farm spent a life time supporting biodiversity conservation, Ex Chairman of Kent Wildlife Trust, he planted the Deciduous Woodland to conserve and protect the diminishing Owl community, there are a number of Owl Boxes situated over the entire site and today many species of Owls can been seen, including Barn Owls, Tawny Owls and Short eared Owls.

The most diverse habitat within the area which contains a nationally rare plant, True fox sedge, this rare species of plant is associated with wetland habitats, such as floodplain, meadows, ponds, ditches and rivers,

There are a number of species of birds which are included on the amber and red data lists in publication “ Birds of Conservation Concern:” Birds of particular concern Nightingale and Turtle Doves which are listed in the Kent Biodiversity Action Plan.

A considerable number of bird breeding territories will be lost with these development proposals. The area has already been subject to significant loss of biodiversity with the development of 100 acres of Green Belt Land in 2015 into a Solar Farm. There has been a noticeable reduction of the Bat, Hares, Field and Hazel Mice ,Wild Partridge,Deer, Water Vole population, just to mention a few. The Swan community that was always evident at Mote Farm for many years, and historically know as a pairing area for 100’s of signet swans has almost completely disappeared since the installation of the solar farm.

There are many species of butterflies and dragonfly’s within the area of which some species have been reduced substantially due to the recent removal of many shrubs and trees to make way for a new haul road for the current quarrying operations at Stonecastle Farm Quarry.

Kent has not met its Biodiversity 2010 targets and with biodiversity continuing to decline, it is likely that we will not meet its Biodiversity 2020 targets without targeted interventions. A healthy natural environment, rich biodiversity, provides more effective services; the economic impact that degraded habitats have on ecosystem services, for example through the decline in pollinators, is increasingly recognised.

The last century has seen major losses and decline of species within Kent. Amongst the most important drivers of biodiversity loss in Kent are: the direct loss of land of value to wildlife to built development which has reduced and fragmented populations; and effects of climate change.

Ancient Woodland

CA1 and CA2 have a number of ancient woodland blocks situated at Postern, Stonecastle Farm and Moat Farm. Ancient Woodland is an irreplaceable habitat and is protected by the Forestry Commission, National Planning Policy and Natural England for its contribution to wildlife and the cultural and historic landscape.

Postern Lane is bordered with ancient hedgerows which have a high potential species-rich value and nesting birds, which are afforded protection under the Wildlife and Countryside Act (1981). The Kent BAP recognises their value to wildlife, habitats for bats, dormouse and birds and aims to ensure no net loss of ancient hedgerows (Ancient & Species- Rich Hedgerows, Kent Habitat Action Plan, Number 01,2005)

Indirect impacts to ancient woodland are likely to result from the proposed allocation and further clarity on how the impacts will be avoided and fully mitigated should form part of the site allocation process if this allocation is progressed.

The River Medway

Landscape Character: Dominated by the floodplains of the River Medway and its complex network of small streams and tributaries. An undulating landscape of clay vales, fields within the floodplain are of a medium scale and more regular in form having been amalgamated through loss of field boundaries, and riparian vegetation. Small woodlands, historic hop gardens and orchards are common land uses.

Biodiversity:

1 The most significant features are the courses, tributaries and floodplains of the River Medway, Beult and Teise. The floodplains support species rich meadows or floodplain grassland and grazing is a significant landscape feature and management practice.

2 Associated habitats include ponds, and gravel pits (former quarry workings). small areas of woodland, including mature ancient woodland, and fen.

3 Key species include otter, depressed river mussel, white clawed crayfish and river lamprey.

The River Medway, the River Bourne and their tributaries pass through the Borough and have significantly influenced the history and development of the area. An extensive area of the Borough lies in the floodplain of the River Medway, the potential impact of which in Tonbridge is reduced to some extent by the Leigh Flood Storage Area immediately west of the town. Much of the floodplain is also of significance for biodiversity with extensive areas of the lower Medway Valley being designated as Sites of Special Scientific Interest.

Tonbridge and Malling Borough Council recognises within it’s Local Plan the importance of the River Medway Valley, and acknowledges the importance and many benefits this area brings to a wide community, highlighting the area within its Green Infrastructure and Ecological Report which commits to further preservation and conservation.

Targets:

1 Achieve a quantifiable improvement in ecological status of all water bodies, as judged by Water Framework Directive indicators.

2 Pursue opportunities for creation of wider river floodplains with riparian corridors around natural drainage channels.

Green Infrastructure and Ecological Networks – March 2018

3 Pursue opportunities for the delivery of catchment improvement work, including enhancing, restoring and creating fen, wet woodland, reed-bed and wet grassland and action for key species such as otter.

4 Secure the appropriate conservation management of all existing Lowland Meadows. Enhance at least 50ha of species-rich neutral grassland to bring it to UK BAP priority habitat Lowland Meadow quality.

5 Pursue opportunities to create new species-rich neutral grassland, particularly close the Marden Meadows SSSI and south of Sevenoaks, in blocks of 2ha or more, where this will contribute to meeting the county target of creating 37ha by 2020.

6 Enhance or reinstate woodland management, and extend and reconnect fragmented woodlands where this would not conflict with grassland conservation and enhancement.

7 Continue to encourage the positive management, restoration and re-creation of hedgerows, particularly where this would reconnect other habitats or enhance the landscape, in particular where these have been removed due to agricultural intensification.

8 Improve the management of invasive species in and alongside water courses.

9 Maintain, restore, recreate and buffer ponds, particularly to establish networks of sites to support great crested newt.

10 Action for naturally widely dispersed habitats (ponds, traditional orchards), wildlife associated with arable farmland, and widely dispersed species such as great crested newt will need to focus across the whole of the area and not just within the Biodiversity Opportunity Area boundary.

With the proposed development of CA1 and the new Quarry and its extensions will seriously impact the conservation, and targets that have been outlined within Tonbridge and Malling Local Plan as well as potentially reducing it is designated Green-space and Green Infrastructure allocation.

Hartlake Bridge is a key component to open Green Space, providing connectivity via riverside walks to Tonbridge, East Peckham and Yalding, enjoyed by many people who travel far and wide to enjoy this area, it is a key leisure hub, providing many activities such as angling ( Tonbridge Fishing Club) Canoeing, leisure boating,horse riding birdwatching, cycling, running, dog walking, walking, picnics and simply a wonderful countryside outing for families enjoying these very popular public footpaths with all of the current development proposals this could compromise this whole area.

Hartlake Bridge is a memorial site for families who each year visit the area to remember previous generations, who lost their lives on 20th October 1853 in a tragic accident on the bridge where 30 hop-pickers lost their lives in the river, this is know as the Hartlake disaster. There is a dedicated memorial situated on the bridge as well Hadlow Church to remember these families.

Quarries - M13 Stonecastle Farm Quarry extension and M10 Moat Farm

Stonecastle Farm Quarry-M:13

Historically Stonecastle Farm has operated as quarry, waste landfill and cement manufacturing facility since the 1970’s. In 2000 the operator Lafarge applied to Kent County Council for planning permission to extend its sand and gravel operations over a further 600 acres of prime agricultural, Metropolitan Green Belt Land. This planning application was rigorously rejected by the planning authorities for a number of reasons including noise, dust, additional flood risk, the permanent removal of agricultural land, lack of mitigation to neighbouring listed buildings. The key concern was the effect further quarrying would have on the Water Aquifers and the high probability of contamination to public water supplies.

In 2008 the operator suspended existing operations at Stonecastle Farm, under section 26 cessation act of the planning consent, KCC granted temporary suspension for 2 years, the operators reasons for the closure/ suspension was due to the current economic climate it was not financially viable to continue with its quarrying operations.

This closure/ suspension of the quarries continued until 2018, the site had been left abandoned for 10 years leaving all the rusting dysfunctional plant machinery in situ, contaminated oil and fuel bins, the site over the years suffered considerable contamination, vandalism and theft as it was left unsupervised and unsecured.

December, 2017 a small number of local residents were contacted by the KCC, requesting comments on their Kent Mineral Sites Plan which formed the basis of KCC Draft Early Partial Review of Kent Minerals and waste Local Plan 2013-2030 (KMWLP). Included within the KMWLP draft plan were proposals to extend Stonecastle Farm Quarry as per the rejected proposal of 2002, as well as additional new Quarry situated at neighbouring Moat Farm. These 2 identified sites are the only sand and gravel sites remaining within the KMWLP and if consented will provide 2.5million tonnes of sand and gravel over a 30-60 year period.

August 2018 KCC contacted a small number of local residents who lived close to the existing operations informing them that the operator had submitted a pre application with a revised scheme to resume operations at Stonecastle Farm Quarry.

On 28th October 2018, a planning application was submitted to KCC with a revised scheme of working for the already consented workings for phases 1,2,4 and 5 pursuant to condition 3 of planning permission TM/00/1599. The proposal declared there had been an improvement in the market conditions and the applicant would now like to recommence extraction at the site in 2018, further revisions included changes of the working arrangement within Phases 1 and 2, mineral working to be undertaken ‘wet’ using a long reach excavator (ie below the water table without dewatering); Relocation of the internal haul road to follow the southern boundary of phase 1 to avoid previously restored areas of the site along the northern boundary of phase 1 and: Campaign working to change from 3 months to 6 months each year- reducing the intensity of extraction operations whilst avoiding wetter periods.

KCC granted planning permission to the revised scheme and with immediate effect the operator began the removal of 1000’s of mature trees and shrubs, breaching further planning conditions to make way for the revised haul road. In March/ April 2019 the operator removed all the existing dysfunctional plant operations machinery, along with all the site buildings.

At the time of writing this submission quarry workings have not resumed and a forthcoming planning application is expected for the installation of new plant equipment.

The Kent Minerals Waste Local Plan is currently being assessed by the Inspectorate under Regulation 19 and the Inspectors report will only be available after the end of this Regulation 18 consultation on the Draft Local Plan.

A number of key issues have arisen during the KMWLP Plans examination which are very relevant to TWBC’s Local Draft Plan, including additional flood-risk, further loss of Green Belt, Green Belt Special Circumstances,Landscape and Visual Impact, Contaminated Land, Contamination of local water courses and Aquifers, Urban Sprawl , Biodiversity, Health and Amenity and Heritage.

Historic Landfill at Stonecastle Farm

The Mineral Planning Authority (MPA) permitted the importation of various waste materials at Stonecastle Farm in the early 1970’s under condition (xii) of planning permission TW/79/753 and subsequent other conditional consents continued through the 1980’s and 1990’s.

The landfill area comprises of two large parcels of land which were backfilled with these waste materials following the completion of mineral extraction. These areas are located to the north of and south-west of the previous processing area.

Condition (iii) (h) of the planning permission TW/79/753 states “ measures to minimise the accumulation of groundwater and generation of leachate within cell being backfilled, and removing such groundwater and leachate as does arise from the site for appropriate treatment and disposal”.

Monitoring information obtained from the Environment Agency has demonstrated that the landfill sites have recorded volatile and excessive leachate, methane gas and nitrate readings in recent years, as well as the possibility of the leachate escaping from the contained cells into the surrounding water courses and aquifers, especially during severe flood events.

There is extreme concern within the community, especially as the area has historically flooded. Local residents have requested a comprehensive independent investigation with detailed analysis and to seek assurances that all contamination risk and health risks have been mitigated.

This serious environmental issue is very relevant to the Draft Local Plan as the existing and future contamination risks to the surrounding aquifers and water courses will have a direct impact on any proposed housing within the area.

TWBC was not represented at the recent Inspectorate hearings for M10 Mote Farm and M13 Stonecastle Farm and No Statement of Common Ground between KCC and TWBC has been agreed or signed and was noted by the KCC and the inspector. This raises serious concerns about the fulfilment of “Duty to Co-Operate” requirements and whether either of these plans meet the test of soundness.

Considering the many implications that both the housing and quarry developments will bring, as who will want to purchase a house that looks straight into a quarry?

It is surprising and very concerning that TWBC have chosen not to consult with the KCC to date.

Flooding

Both Capel/ Tudeley and Paddock Wood have a long and documented history of many flooding events both from fluvial and pluvial flooding with some of the worst flooding in 1960,1963,1968, 2000, 2009 and 2013.

Some areas are flooded more regularly such as Hartlake Road and Crockhurst Street, Hartlake Road is regularly closed for long periods due to over topping of the Medway, and was closed last year for a period of 4 weeks due to severe flooding. Crockhurst Street suffers severe flash flooding regularly, both areas border the proposed CA1 developments.

NPPF-Section 149:

“Plans should take a proactive approach mitigating and adapting to climate change, taking into account the long-term implications for flood risk”.

NPPF-Section 155:

“Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at the highest risk ( whether existing or future). Where development is necessary in such areas the development should be made safe for its lifetime without increasing flood risk elsewhere”.

NPPF- Section 157:

“ All plans should apply a sequential, risk based approach to the location of development- taking into account the current and future impacts of climate change- so as to avoid, where possible, flood risk to people and property...seeking opportunities to relocate development, including housing, to more sustainable locations.

NPPF- 158:

“ Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower risk of flooding”.

PW1- Capel East - Increased Flood Risk - The Provision of approximatley 4,000 new dwellings.

* The SFRA understates the impact of climate change over the > 100 year horizon for residential development. appropriate cautionary allowances have not been made.

* The dwellings would need to be protected from a potential breach of new water storage or reservoir facilities

* Polices STR/PW1 and AL/PW1 Capel East - The proposed development will increase the flood risk both within the development and to the existing communities in Paddock Wood, Five Oak Green and the surrounding areas.

* The SFRA prepared in support of these polices is not fit for purpose because it does not adequately quantify the flooding risk, does not include comprehensive flood mitigation measures and does not provide detailed specifications of those measures that have been included.

* These development proposals are very reliant on additional storage capacity at Leigh and do not provide any contingency plans should the barrier be breached again as in 2013.

* There have been several developments recently in Capel where the EA has insisted on raised floors and containment (tanks,swales etc) with restricted discharge. In at least one case, the EA have specified the inclusion of a void below the raised ground floor level to allow flood water to run and sit below the ground floor accommodation, at least one of these developments have become unsaleable due to the flood risk.

* The identified parcels are not currently protected by formal flood defences and the SFRA admits that the development will cause increased flood risk. Given that the proposals remove so much floodplain storage by building on it, and the SFRA identifies that some of the parcels of land are extremely vulnerable to flooding, following NPPF guidance these sites should not be considered for any development at all.

* Loss of floodplain connectivity within the rural and upper reaches of tributaries which flow through and around the development site will increase flooding to the area.

* The SFRA does not conclude that the limited mitigation will eliminate future flood risk or provide any evidence of ‘betterment to existing properties within the area.

* Development / removal of one of the UK’s largest floodplains is not appropriate, especially when considering recent events happening across the UK. Fishlake village in Yorkshire where over 400 homes have been flooded as the River Don overtopped, 1,200 properties have been evacuated. The Whaley Bridge Dam in Derbyshire where more than 1,000 homes were evacuated in August 2019..Somerset Levels spent much of the winter of 2103-2104 underwater, villages were isolated, many homes evacuated.

* Flood warnings in the area have increased substantially over the last 10 years

* The Level 2 SFRA states “ it has been stressed that the purpose of this part of the study is to demonstrate that the principle of development can be supported at the parcel.” The analysis performed was not to identify preferred options or optimum solutions.” The report again highlights that even with flood mitigation the parcels will still be vulnerable to flooding. The data assumptions for the modelling is guess work as there is no data available and recommends that understanding of the flood risk within Paddock Wood would be supported by data which helps analyse how the watercourses respond to rainfall. NO calibration or verification of the modelling has been possible, and the flood flows resulting from the design input cannot be sense checked against historic event rarity.

* The current Paddock Wood sewer infrastructure is already operating over capacity, expected upgrades to provide further capacity have recently been abandoned by Southern Water due to its economic viability. Residents have experienced many incidents of sewer flooding, as the current infrastructure cannot cope with the existing housing demands. The issue has now been take up with Local MP Greg Clark who has requested the intervention of the Housing Minister and further discussions with Southern Water.

* In conclusion the proposals are to increase flood flows from the Leigh barrier with further storage facilities, and decrease flood flows at Tudeley and Paddock Wood with partial removal of the natural floodplain, potentially installing dams and water-storage facilities. Importantly, any flood risk management measures will require substantial upfront capital costs and then ongoing costs to support maintenance and perhaps reconstruction once its design life is passed. The issue here is who is going to be responsible for these costs? How is this going to be funded? and who will be responsible for the ongoing management and maintenance.?

* It is very concerning to local residents that despite the evidence produced and all the mitigation proposals there is still a strong possibility that flooding may still occur within the area. and the Council are appearing to put their own housing requirements before human lives.

CA1 Tudeley Development

Flood Policy Statement AL/CA1

* Tudeley: the provision of flood storage/attenuation/mitigation areas to reduce the flood risk to particular existing residential areas in Five Oak Green and Paddock Wood; There is no mention of other surrounding villages such as Golden Green East Peckham, Yalding all of which are reliant on the floodplain which currently provides some flood protection, any removal will have implications for these villages.

*Contributions will be required for flood storage/attenuation/mitigation; Importantly, any flood risk management measures will require substantial upfront capital costs and then ongoing costs to support maintenance and perhaps reconstruction once its design life is passed. The issue here is who is going to be responsible for these costs? How is this going to be funded? and who will be responsible for the ongoing management and maintenance.?

* The masterplanning for this site be linked with the strategic delivery of infrastructure, including in relation to surface water, multiple benefit Sustainable Urban Drainage Systems, foul water, etc.;

*The development on the site should demonstrate that it will not exacerbate flooding elsewhere in the vicinity, particularly from the Alder Stream at Five Oak Green, and that as part of the wider delivery the development delivers storage/attenuation/mitigation, to reduce the flood risk to particular existing residential areas in Five Oak Green. This is also one of the justifications for the release of Green Belt land;

*Regard should be given to the Groundwater Source Protection Zone which falls within the north of the site and the Environment Agency should be consulted on any planning applications coming forward .

* There is NO SFRA assessment for CA1 although parts of the site reside within a floodplain. This is despite the Policy Overview stating “Flood Zones 2 and 3 in northern part of Tudeley”. It is well known that many parts of the site are regularly subjected to flooding.

Given the absence of information regarding the development parcels within the allocation, unlike PW1 Capel East, the consideration of Policies EN26-EN29 covering Water Resources, Drainage and Flood Risk cannot be adequately made. A full SFRA, with parcel analysis, for the proposed site CA1 is required for several reasons, including:

* The northern section of the proposed development CA1 includes areas within the floodplain as shown in the EA current flood risk map even before any adjustment for climate change.

* There is no assessment of the effects of this proposed development on the surrounding communities located along this flood plain.

* The increased risk of flash flooding from surface water given the vast amount of lost agricultural land.

* Run-off from developments, including roofed and paved surfaces.

* The specification of adequate SuDS to mitigate the flows and filter contaminated run-offs.

* The site is already at risk from extensive surface water flooding.

* The assessment of the impact of climate change on local and wider areas.

The CA1 Tudeley site consists of approximately 400 acres of substantially undeveloped agricultural land which already sends vast amounts of water northwards to the fully functional floodplain and aquifers. the proposed development will effect the flood risk without extensive mitigation measures.

With the floodplain already under stress from the existing surface water issues, combined with the increasing river levels of the River Medway a majority of this area becomes an extension of the river and can remain under water for lengthy periods during a flood. Adding further run-offs from the construction of buildings, roads, driveways and other impermeable areas and potentially further gravel pits from mineral workings will substantially increase the flood risk to the immediate and surrounding areas.

The loss of floodplain connectivity within rural upper reaches of tributaries which flow through and surround the site will again significantly increase flood risk.

A large proportion of existing vegetation will be removed / destroyed, trees, wooded areas, hedges, surface vegetation and crops . This vegetation absorbs large quantities of water during active growing periods significantly reducing the ground water levels.

Water volume and flood height will increase, a single mature Oak tree can absorb 100,000 gallons of water from the ground each year. (Building Research Establishment).

A further key risk and defined within the Minerals Plan is contamination from pollutants in run-off flows to the GSPZ aquifers at Hartlake and other watercourses. There are also 2 water extraction licences within the area, with further anticipated capacity requirements of water resources this could have further consequences in dry periods for the aquifers.

The Policies STR/CA1 & AL/CA1 TUDELEY do not provide any detail on how the proposed development will provide mitigation and merely state that this will be determined in masterplanning. This means that this plan cannot demonstrate that it is sound or deliverable. The flood policy statement is also unsound as it only includes Five Oak Green and Paddock Wood and does not consider the more immediate impacts on Tudeley residents nor the effects on Golden Green,East Peckham, Yalding and further downstream from the barrier.

Strategic Storage: Many of the development proposals throughout the Draft Local Plan are very reliant on additional storage capacity at Leigh to provide flood mitigation and do not provide any contingency plans should there be a repeated breach. The planned further storage capacity upriver at Leigh will increase river flows down river when under stress causing significant risk to human life.

Flood defences: There are no formal strategic flood defences at these sites and it is important to understand the consequences if the design standard of any new defences is exceeded or if they fail.

It will need to be demonstrated that the defences will not have a resulting negative impact on flood risk elsewhere and that there is no net loss in floodplain storage that could cause flood water levels on adjacent land to be elevated.

Policies STR/CA1 & AL/CA1 have not identified the measures necessary to mitigate the flood risk within the development and the stated ‘betterment’ of flood risk to the existing residential areas would need to be evidenced with a suitable guarantee that would satisfy insurance underwriters. This report has highlighted the many inconsistencies within the Draft Local Plan and, considering the evidence, it seems incomprehensible that the Council has not conducted a SFRA for CA1, unlike other identified flood vulnerable sites. The presented Plan is neither sound nor deliverable and does not provide the necessary justifications for the release of Green Belt land.

Agricultural Land

Policy EN 22

“ The Local Planning Authority seeks to protect best and most versatile agricultural land from significant, inappropriate or unsustainable development. Where development of agricultural is required, applicants should seek to use areas of poorer quality agricultural land in preference to that of higher quality except where this would be inconsistent with other sustainability objectives.

Planning applications that would result in the loss of best and most versatile agricultural land will need to justify why the loss of agricultural land is acceptable and also assess the impact of loss of the agricultural land on the wider farming resource and ecosystem services. Where site specific ALC studies are not available The Local Planning Authority will assume that the site is classified as best and most versatile”.

CA1 and surrounding land is considered to be Agricultural Land Classification Grade 3a and Grade 2, therefore considered to be part of the best and most versatile agricultural land (BMVAL) and extremely worthy of preservation. All the current development proposals will permanently remove in excess of 1,000 acres of Prime Agricultural Land which currently provides a number of cereal crops, soft fruits and orchards. This is extremely important food supply source and should not warrant the ability to make way for housing development outweighing the need to preserve good quality farming land.

Noise

Policy EN 30

“ Residential and other noise sensitive development will only be permitted where it can be demonstrated that users and occupiers of the development will not be exposed to unacceptable noise disturbance from existing or proposed uses, as set out in the Councils adopted Noise and Vibration Supplementary Planning Document”.

Noise and Vibration Supplementary Planning Document:

Section 1: “This supplementary document (SPD) seeks to ensure that there is sufficient mitigation for noise to prevent substantial loss of amenity at development stage. There are statutory provisions for noise beyond planning legislation, including the Control of Pollution Act 1974 that deals with construction site noise and legislation such as Environmental Protection Act 1990 that deals with statutory nuisance”.

1.6 NPPF Planning Polices and decisions aim to:

* avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development

* mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from new development, including through the use of conditions:

* recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes of the land in nearby land uses since they were

established , and

* Identify and protect areas of tranquility which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason

2.3 In addition to requirements under EIA, the Borough Council will require an assessment in situations where;

* there is a proposal for a development generating noise/and or vibration in a noise sensitive area (premises where noise is likely to cause or contribute to some harmful or otherwise unwanted effect, such as annoyance or sleep disturbance) These premises will include residential development, offices, hospitals, car homes and schools and other premises regularly occupied by people.

3.26 Railway noise emanates from a variety of sources. For noise from operational railway lines, the noise levels found in tables 1 and 2 will be appropriate. Local noise from station activities, freight distribution, depots and marshalling yards should be treated in the same way as noise from industrial and commercial sources.

3.27 The likelihood of significant ground-borne vibration will depend on the nature of the ground and the types of train. Ground-borne vibration can occur close to railways and sometimes next to some types of industry. The possibility of vibration and re-ratiated noise caused by trains running in tunnels should not be overlooked. Advice on acceptable levels of vibration can be found in BS 6472 1-2: 2008 Evaluation of human exposure to vibration in buildings.

Noise from aircraft

3.28 Noise from aircraft has not been a significant planning issue to date within the Borough although with recent changes to flight paths approaching Gatwick airport in particular this situation could change and this situation will continue to be monitored.

Local residents that live within the Medway Valley are concerned that the CA1 development proposals would substantially increase constant noise levels as the surrounding land is flat being at the base of the floodplain valley, and any noise travels from the high ridges across the valley. This would give rise to significant adverse impacts on health and quality of life as a result of new development.

This valley is recognised as a area of tranquility and natural beauty, the LP does not recognise this and further consideration of this policy should be implemented “identify and protect areas of tranquility which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason’”.

There has been a significant increase in aircraft traffic over the last 2 years and is set to further increase directly over CA1 if Gatwick Airport is successful in increasing flight path traffic.

No consideration for the increase in noise pollution from the proposed mineral workings and machinery, along with the proposed development machinery residents will experience a significant increase in noise pollution- Significant adverse impacts on health and quality of life.

Railway

Development proposals for CA1 and CA2 are completely unsuitable for a garden settlement as both sites have a mainline railway line running through the middle of them ,with very limited access. Only 2 access crossings which are not fit for purpose to service such developments as they are via Hartlake Road/ Sherenden Road (CA1)which are weight restricted country lanes, the railway access is so narrow that only one car can pass at a time under the railway embankment.

Access to CA2 Railway Bridge is limited via a single track private road, the bridge has significant vertical cracking to its structure showing that existing traffic reverberations from trains is damaging its structure. It is anticipated that Network Rail would have serious objections to additional volumes of traffic crossing the railway bridge as it would represent a massive increase in the structural load being placed on an already fragile structure.

It is understood there are no further proposals by Network Rail to provide any further access to CA 1 or CA 2 due to the high capital costs and the long term delays that would be have to be implemented on the mainline connectivity between London and Kents Coast.

CA 1 will be 2 settlements divided by a railway line with extremely limited access neither which satisfy garden settlement principles.

Network Rail South East Route Kent Route Study ( May 2018)

* Highlights capacity issues

* Significant increase in passengers using the railway network further growth forecast

* Tonbridge Railway Station is fraught with capacity issues, difficult to introduce additional services

* Little or no capacity for extra services

School allocated for six form entry secondary school

Policy AL/ CA 2

This site allocation is wholly unsuitable for a secondary school due to the location, mainline railway running through the centre of the site, ancient woodland, road network already at capacity and often at peak travel times grid locked, poor air quality and car emissions will be a severe health risk to children, flood risk as the area often floods, unsuitable transport links to Tonbridge and Tunbridge Wells town centres.

Detrimental Impact to the amenity and setting of heritage grade 1 listed building of Somerhill.

Conclusion

The proposed plans for Tudeley and Capel highlight the challenges, dangers, risks and extraordinary costs that any development would have to overcome to proceed to become a successful sustainable development.

It is understood the pressure TWBC is under to deliver its housing targets but it should not be at any cost, especially when it involves so many people / communities and the effects will be irreversible.

It is very apparent the offer of cheap Green Belt Land by a complying,opportunistic landowner has blinded the Council with its initial Suitability Analysis for these sites, ignoring the fact these sites flood and are widely known as flood vulnerable areas on a floodplain.

We would urge the Council to reconsider and remove these sites from the plan now before committing to further costs and taxpayers money.

Finally to take note to the horrendous flood events that have recently taken place in other parts of the country, this is the chance for the Council to say No to the developers and work with their communities to proactively provide long term flooding solutions that will protect the current community, preserve the wonderful Green Belt Countryside for future generations to enjoy as previous generations have done for all of us.

Otherwise it will be not if, but when, will TWBC be on National News organising huge evacution programmes for local residents and being held responsible for causing millions of pounds of damage to many 1000’s of homes.

DLP_1538

Tonbridge & Malling Borough Council

Object

The response is similar to that in respect of the new settlement at Tudeley above.

As this is the first opportunity to comment on the detailed development strategy set out in the draft Local Plan, TMBC would like to take this opportunity to suggest an alternative location for the proposed new secondary school at Capel. In the opinion of Tonbridge and Malling, a location at or preferably between the new settlement at Tudeley and the allocations at Paddock Wood would represent a more sustainable solution, being closer to the need generated and the potential for reducing the need to travel to a site on the periphery of Tonbridge, on a constrained site with poor access, adjacent to a town which already has a large number of existing secondary schools and the associated transport issues.

An alternative location for the secondary school would also address a related concern that the proposed developments close to the built confines of Tonbridge would result in the coalescence of the settlements of Tonbridge, Capel, Tudeley, Five Oak Green and Paddock Wood.

The proximity of the proposed school site to the borough boundary and the distance from Tonbridge Station emphasises the importance of implementing sustainable transport improvements in this area to ensure any impacts on the local highway network are minimised. Whilst TMBC welcomes proposals for new bus routes that link Tonbridge/the school/the proposed new settlements/Paddock Wood, it must be recognised that there are significant delivery challenges in ensuring that route is feasible, particularly within the two town centre environments.

Ensuring there is an appropriate access across the railway will be an important consideration for master planning and viability.

TMBC’s Local Plan has an employment allocation (LP36 site h), which is an extension of an existing site, immediately adjacent to this proposed allocation. It is essential that existing modelling work carried out to inform this and other local designations with the TMBC Local Plan are considered as part of the infrastructure master planning work that TWBC are proposing to undertake.

DLP_2022

Dr David Parrish

Object

Policy AL/CA 2 (Land east of Tonbridge, west of Tudeley) p.164

TWBC should really (not just say that they do) cooperate with Tonbridge and Malling Borough Council and cancel the Tudeley Garden Village and AL/CA2 if T&MBC object to the TWBC Local Plan

This policy refers to a site that is wholly unsuitable to the development of a secondary school due to the:

* Railway line
* Busy roads
* Flood risk
* High pressure gas pipeline risks
* Unsustainable transport links to Tonbridge and Tunbridge Wells Town Centre
* Reliance on private car use for staff and students’ families.

There is no evidence that the development at Tudeley, with 1,900 homes built in the next 15 years, will have enough children of Secondary School age to fill an eight form entry secondary school.

Most of the students will come from Tonbridge and Southborough/Bidborough resulting in a high increase in levels of traffic and significant reduction in air quality.

DLP_2068

Terry Everest

Object

Strongest Possible Objection

See comments for STR/CA1

This site is Green Belt, AONB and has Ancient Woodland - it should and  must be protected!

DLP_866

Ian Pattenden

Object

Comments on Policy AL/CA 2 (Land east of Tonbridge, west of Tudeley) p.164

This policy refers to a site that is wholly unsuitable to the development of a secondary school due to the:

  • Railway line
  • Busy roads
  • Flood risk
  • High pressure gas pipeline risks
  • Unsustainable transport links to Tonbridge and Tunbridge Wells Town Centre
  • Reliance on private car use for staff and students’ families.

There is no evidence that the development at Tudeley, with 1,900 homes built in the next 15 years, will have enough children of Secondary School age to fill an eight form entry secondary school.

Most of the students will come from Tonbridge and Southborough/Bidborough and further afield resulting in a high increase in levels of traffic and significant reduction in air quality. Additionally, in the interest of safety, street lighting will need to be provided causing severe light pollution

DLP_953

Geoff Turner

General Observation

OBSERVATION 1 OF 2

Note that there is an underground obstruction on the southerly border of the site

This observation should be forwarded to any architects commissioned for the school construction on site 447.

There is a network of underground irrigation pipes under the southerly border of the field.

The pipework extends downhill from the roadside boundary for over 100 metres into the field.

Any construction workers and architects need to be made aware of the pipes.

The pipework provides fertilisation from a sewage processing facility uphill of the field.

The sewage is flushed through with clean rainwater from the rooftops of the buildings uphill of the field, fertilising the field for over 140 years.

The system has been in place since the construction of White Lodge, a late Victorian house dating from 1874.

The underground irrigation pipework is located on the southerly border of the site, opposite the road entrance to the Schools at Somerhill and White Lodge.

Please provide provision for connecting the pipe which emerges under the B2017 into the sewage system of the new school.   The pipe goes downhill, crossing under Tudeley Road.

OBSERVATION 2 OF 2

School site, 447, – a new foot bridge is required

The initial notes on the local plan seem to imply that the existing bridge is intended to connect each campus of the two school sites.  However, it will not be sufficient.   The bridge is very narrow.  It carries a single-track road and a public right of way.  The existing sides of the bridge are only waist height.

For the safety of children and the trains on the track beneath it is obvious that an additional covered foot bridge over the railway would be needed between the two school sites.  Any attempt to add a sufficiently high roof or caged sides to the existing road bridge would need to have a custom design and foundations at the track level.   Therefore a brand new pre-fabricated foot bridge in the middle of the site would be a lot cheaper and much more fit for purpose.

DLP_1644

Tom Tugendhat MP

 

AL/CA 2 - Land to east of Tonbridge/west of site for Tudeley Village

Following the allocation at Mabledon, this is the next proposal that is closest to the borough boundary, and would have the biggest impact on residents in Tonbridge - by sheer virtue of the fact that the allocation is on the very outskirts of Tonbridge.

South Tonbridge has one of the highest concentrations of secondary schools for a town of its size in the whole country. This, along with the nature of our education system, puts immense pressure on the local road, bus, and rail network as travel to school plans are increasingly difficult to manage. Pupils often have to travel long distances to schools and it is right that Kent County Council (KCC) have strategic oversight of this. However, as we have seen recently with school expansion in Maidstone, even the slightest increase in a school's yearly roll, or a small change to its catchment area can disrupt bus services and bring gridlock to the area.

My concern is that a secondary school off Woodgate Way in Tonbridge would make peak time traffic movements in Tonbridge unsustainable. The site is not within easy walking distance of Tonbridge Station nor on the busiest bus routes in the town. Indeed, as things stand it is only services such as the 205 from Kings Hill which pass this location and this has only started this year. There is no doubt that this allocation would bring chaos to the already finely balanced public transport network in Tonbridge.

It is noticeable from the extremely detailed 544 page Draft Local Plan that there is absolutely no mention of the impact of this secondary school on Tonbridge. This gives me significant cause for concern and is a glaring omission from the Draft Local Plan. Ahead of Regulation 19 consultation it is urgent that the impact on Tonbridge is fully understood.

However, at Pages 163-164 we have the smallest of details available about the characteristics of the site itself. As I said at the start of this letter I am focusing this response on the impact on Tonbridge and Malling so won't comment on specific details within allocated sites. However, it is concerning that a high pressure gas pipe, presumably to serve residents in Tonbridge, runs from south to north through this allocated site and I would appreciate further details on where this gas pipe services, and the impact that development of a secondary school above it would have on residents should it be deemed acceptable here, of which I have my doubts.

Finally, I wish to add my support to the comments of TMBC on this allocation, which they strongly object to. They are right to say that a development of the size of which is proposed at Tudeley, as I will comment on shortly, is of a suitable size to encompass on site provision of a secondary school. The large employment site allocation on the neighbouring land in the TMBC Draft Local Plan, which is currently awaiting examination from the Planning Inspectorate, also needs to be considered. This site sits on the edge of Tonbridge's industrial heartland and, as a town steeped in history with close ties to the printing industry, any threat to this should be fully demonstrated.

In summary, a new secondary school on this site would have such adverse impacts on the town of Tonbridge that I strongly doubt whether it would be feasible to deliver.

[see also full response - Comment Number DLP_1577].

DLP_1692

Jamie Newman

Object

It has been brought to my attention that you plan to build in excess of 4000 new homes in and around Capel. To myself and many others in the already existing community, this is simply unacceptable.

No regard has been yet given for the impact not only to the pre-existing residents of the surrounding area, but to the wildlife, fauna and flora that inhabit it.

The Kent countryside is called the garden of England for a reason. Let us preserve this way of life.

Whilst one can ascribe the popular term of 'NIMBY' to this, it goes far deeper and cuts more malevolently than to be simply dismissed as per the aforementioned. It is abundantly clear these plans have not been thought out, nor researched in anyway.

It is a fault of humanity that we are far too short sighted in our approaches to our continued stewardship of the land. I urge you to take this opportunity to not only consider the short term damages this will cause, but the precedent you regrettably set should these plans be followed through.

Sadly developments such as this do not end once the building is done but continue to expand, destroy and maim both our way of life and those of the species which live there. I ask how you would feel if your garden was paved over to make space for another flat, or your beloved wildlife were forced to relocate because you have tarmac'd over their home.

The world is in increasingly dire straights at the moment, please don't let it get any worse.

I trust you will have the clarity of mind to reconsider these proposals and to further protect this wonderful countryside which we inhabit.

DLP_7023

Hadlow Estate

Support with conditions

Policy Number: AL/CA 2 Land to east of Tonbridge/west of site for Tudeley Village

Our client wishes to remove the specific reference to a 6FE secondary school in order to best meet the level of need at the time of provision. Additional text is highlighted in blue: [TWBC: additional text has been marked here as underlined]

This site, as defined on the Capel draft Policies Map, is allocated for a six form of entry secondary school. The capacity of the school shall be designed to meet identified need. Development on the site shall accord with the following requirements:

1. The layout of the school shall avoid built development in, and have regard to, the areas of Ancient Woodland and their buffers, and the impact of development on mature (non-Ancient Woodland) trees and hedgerows, including those to the boundaries of the site, shall be minimised;

2. The layout of the school shall avoid built development in areas of the highest risk of flooding (Flood Zone 3), and shall have regard to the location of the high pressure gas pipeline and associated zones;

3. Suitable provision shall be made for access into the site, and between the different parts of the site (i.e. on either side of the railway line);

4. The proposal shall have regard to the setting of the High Weald AONB (the AONB Management Plan and any supporting guidance will be a material consideration for such a proposal) and Historic Park and Garden;

5. Any development shall accord with relevant policy in relation to its impact on the adjacent Tudeley Wood Local Wildlife Site, and in terms of the archaeological environment: the land to the south of the site is identified as an area of potential archaeological importance;

6. The school shall be designed to minimise trips to and from it by private vehicle and to facilitate active transport modes, such as walking and cycling from Tudeley Village.

DLP_4116

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

It is noted that a new six form entry secondary school to west of Tudeley Village is allocated on land beyond AL/CA1, in the resultant gap between the proposed new settlement and the borough boundary at Tonbridge.  This site lies in the green belt, adjoins the High Weald AONB and includes a large area of Ancient Woodland. The site also straddles the railway line – making access between both parcels of land difficult. Postern Lane (which crosses the railway line) lies beyond the site allocation.  This is a narrow private road (which serves as the vehicular access to several properties), and a designated public footpath. Has the Council been in discussion with Network Rail with regard to improved connectivity either side of the railway line?

In terms of securing sustainable development it is not clear why a school of this size needs to be sited in this particular location. If the school is intended to serve a need generated by the proposed strategic allocations at Tudeley Village and Paddock Wood then in terms of getting children and staff to school, it would be better sited with the aforementioned allocations.

On this point the IDP refers to the need for an up to eight form entry school “to be provided on land at the garden settlement at Tudeley Village and further expansion of Mascalls Academy at Paddock Wood”.  With the site being so close to the borough boundary it raises the question of whether this allocation’s primary purpose it to service the new village, or whether it is being sited on the edge of Tonbridge to address a need arising from there instead - the SHELAA appears to indicate that the site is intended for use by Tonbridge Girls Grammar School and that the girls would need to be bussed between the existing school and this site. Located as it is, every single child on the school roll will need to be taken to and from school each day. Policy AL/CA2 loosely refers to the need for the school to “be designed to minimise trips to and from it by private vehicle and to facilitate active transport modes such as walking and cycling from Tudeley Village” – this doesn’t go nearly far enough.

More information will be required as to the commitment of the site promoter/developer to work with local bus service providers. While a frequent bus service may go some way to addressing the sustainability for this location, this leaves the matter of “active transport modes”.

CPRE has strong concerns about the safety of school children and others using the B2017.  Walking and cycling routes would need to be separated from vehicular traffic and, moreover, will need to be perceived as being safe and well lit – otherwise these routes won’t get used and the default position will be reliance on private vehicles-.  Moreover, if children will be coming from Tonbridge, they will need to negotiate the A26 Tonbridge bypass and/or the roads through Tonbridge’s industrial estates.

This development, together with the strategic allocations at the proposed Tudeley Village and at Paddock Wood, will result in development stretching from Tonbridge in the west right through to the east of Paddock Wood – some seven miles long.

Ancient Woodland

The southern part of the allocation contains Alders Wood, an ancient woodland.  It is not clear how this woodland will be protected – and general access dissuaded-.  Moreover, in order not to isolate and sterilise it, the ancient woodland needs to be connected with adjacent woodland, not built around on all sides.  The much greater use of Postern Lane that would result from the school proposal would also contribute to the isolation of Alders Wood from nearby woodland and if the school proposal does eventually go ahead on this site, measures to prevent this should be made a condition of the planning permission.

AONB

CPRE object to the provision of a new six form entry secondary school and the impact that this would have on the setting of the High Weald AONB.  The proposed new school would be right up against the boundary of the AONB and would detract seriously from its setting.  It would also be visible when viewed from within the AONB.

Paragraph 172 of the NPPF:

“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 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”. This principle equally applies to AONBs through paragraph 11(b)(ii) of the NPPF to ensure that the scale and extent of development proposed does not harm the purposes for which these areas were nationally designated.

Green Belt

CPRE questions the need for this allocation when on grounds of sustainability provision should be made at the pupil source – the proposed new Tudeley Village or Paddock Wood-. Bearing in mind that a large part of the borough is not green belt it is felt that the disproportionate loss of green belt in this location (which forms a larger swathe of green belt east of the A26 running from Wateringbury to Tunbridge Wells) would undermine the five purposes for green belt designation as set out in paragraph 134 of the NPPF.

This site falls within Broad Areas 3 and 4 in the Green Belt Study Stage 2. Stage 2 figure 1.1 indicates that there would be very high level of harm caused by the release of these broad areas.  Given the

findings of the study and the absence of an assessment for this site there is no evidence to suggest that it is appropriate to  allocate it for development.

We note that TWBC do not propose to release this site from the Green Belt.  The rationale for this must be questionable, given that such a large school will inevitably involve building over a considerable area of the site.  It also means that the 5.35% quoted for Green Belt release under the draft Plan is a misleading figure as regards the amount of Green Belt land to be allocated for building.

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 be assessed as to their adequacy to meet the “Exceptional Circumstances” test, and delivered (policy STR4).

Agricultural Land

Paragraph 170(b) of the NPPF requires planning decisions to contribute to and enhance the natural and local environment by recognising the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land.  With paragraph 170b, footnote 53 stating that “where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality.”

The Agricultural Land Classification (England) [ALC] shows land in vicinity of the allocation as Grade 3 – which is land of good/moderate quality – above land at grade 4 and grade 5 (poor and very poor quality).

Best and most versatile land needs to be protected wherever possible and there appears to be no evidence that the Council has sought to identify areas of poorer quality agricultural land for development.

CPRE Kent is concerned that development of the site and any road and any cycle track development associated with it will increase and intensify the extent of light intrusion in this and the surrounding areas.

NPPF 180 c) requires planning policies to limit the impact of light pollution on intrinsically dark landscapes.  The CPRE Dark Skies map https://www.nightblight.cpre.org.uk/maps/ shows that Tudeley is in the darker skies category (one up from brighter) and the AONB to the south and the river plain north to Hadlow are both in the next to darkest category.  The scale of the development will expand the light pollution from Tonbridge further into the area of dark skies contrary to the NPPF.

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

DLP_3688

Capel Parish Council

 

This policy refers to a site that is wholly unsuitable to the development of a secondary school due to the:

  • Railway line
  • Busy roads
  • Flood risk
  • High pressure gas pipeline risks
  • Unsustainable transport links to Tonbridge and Tunbridge Wells Town Centre
  • Reliance on private car use for staff and students’ families.

The proposed secondary school site is in a dangerous place, with a railway line running through the site.  It will add an unacceptably high level of traffic to/from Tonbridge with a negative effect on the town’s infrastructure as well as the setting of the Grade 1 listed Somerhill. The development at Tudeley, with 1,900 homes built in the next 15 years, will be unlikely to have enough children of Secondary School age to fill an eight form entry secondary school. Most of the students will come from Tonbridge, Tunbridge Wells, Southborough, Bidborough and Paddock Wood. The road infrastructure is not capable of sustaining this pressure and it will provide for an over reliance on the car given its distance from central Tonbridge and Tunbridge Wells and its otherwise rural catchment.

DLP_2641

Mr Nigel Exall

Object

I write in respect of the above consultation, and to express my deepest concerns about the proposed land use planning strategy for Capel/Tudeley.

The policies referenced above promote a comprehensive mixed-use development for Capel/Tudeley, in the form of a ‘garden settlement’, and encompassing approximately 2,500 — 2,800 dwellings; employment provision, a range of local services and facilities to serve such a settlement; and open space, leisure and recreation uses.

Also proposed is a new six form entry secondary school — which is remote from the proposed ‘garden village’.

There are a number of very obvious, and very serious, problems with this proposed Strategy, including (but not limited to):

  • Green Belt,
  • Infrastructure/deliverability,
  • Area of Outstanding Natural Beauty/Heritage Assets/visual impact, e Flooding,
  • Ecology, and
  • The location of the proposed new secondary school.

These shall be briefly addressed in turn as follows:

Green Belt — The site for the new garden settlement falls within the Green Belt, wherein the primary aim of planning policy is to keep land permanently open. In terms of Local Plan preparation this means not releasing land from the Green Belt except in exceptional circumstances. I understand that exceptional circumstances cannot exist if there are alternative, non-Green Belt sites that might be available to accommodate the proposed development. In this case only a small proportion of Tunbridge Wells Borough is washed over by the Green Belt. There is a significant swathe of land to the east of the Borough that is not within the Green Belt, and is therefore free of such constraint. Has it genuinely and robustly been demonstrated that there are no alternative sites available that are outside of the Green Belt? If the answer to this is no, then exceptional circumstances simply cannot exist.

Infrastructure/Deliverability — Clearly the delivery of a new garden settlement will be entirely dependent upon the provision, up front, of the infrastructure to serve such. The provision of such infrastructure is likely to be complicated by the fact that the proposed site is dissected by a railway line. In this context, timescales become important. For instance, by the time a (very large scale) planning application has been determined, conditions have been discharged, and sufficient infrastructure works been undertaken to enable housing and other development to be delivered, it seems incredibly likely that it will be a number of years down the line. As such the strategy does nothing to alleviate housing and employment needs in the short to medium term; and does nothing to meet the stated objectives of producing a Local Plan.

Area of Outstanding Natural Beauty/Heritage Assets — The site of the proposed garden village lies outside of, but adjacent to, the Area of Outstanding Natural Beauty. The National Planning Policy Framework (paragraph 172) states 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. Similarly, there are a number of Listed Buildings located around the perimeter of the proposed allocation, including my own home. The current (and historic) setting of those Listed Buildings is one of a distinctly rural environment, characterised by open fields, interspersed with historic field boundaries and other historic buildings. There is simply no way that the introduction of 2,500 — 2,800 new homes, employment, and associated facilities, on a large swathe of attractive, undeveloped, rural land cannot have a significant and detrimental visual impact upon the adjacent Area of Outstanding Natural Beauty, and upon the setting of the surrounding Listed Buildings.

Flooding — The site itself might not be subject to significant areas of flood risk, but adjoining areas certainly are. Surface water flooding has proven repeatedly to be an issue of serious local concern. Providing a new garden settlement on currently undeveloped, free draining, greenfield land — with the inevitable (considerable) increase in areas of hard surfacing and built form, will simply increase the prevalence of surface water flood risk on the areas of land that adjoin the proposed allocation.

Ecology — Given the extensive scale, and rural/undeveloped nature of the site of the proposed garden settlement, it seems inconceivable that it will not be home to protected species. With such a large-scale development it is impossible to fully mitigate against such wholesale destruction of habitat.

The Location of The New School — As indicated above, the new secondary school to serve the proposed garden settlement is actually located remote from the resulting settlement — approximately 1 mile away at the closest point, and accessed via country roads without the benefit of pedestrian footways. The school would only realistically be accessible by motorised vehicle — pupils, parents and staff are most unlikely to walk or cycle given the nature of the road network between the garden settlement and the school site. Additionally, and linking back to the above referred issue of infrastructure/deliverability, the school site is also dissected by a railway line running east-west through the centre of it. Delivery of the northern half of the proposed school allocation is therefore subject to provision of access across the railway line. The southern half of the proposed school allocation contains a sizeable area of Ancient Woodland, which must be protected as such. Given these constraints, it seems incredibly unlikely that a school could be delivered on site in the early, medium or even long term parts of the Local Plan period.

In light of the foregoing matters, the proposed allocation of land at Capel/Tudeley must be removed from the emerging Local Plan, and an alternative, and more sustainable means of meeting housing and employment needs must be identified.

I hope that the foregoing clarifies my position, but should you require any additional information then please do not hesitate to contact me.

DLP_3427

High Weald AONB Unit

Object

STR/CA 1, AL/CA1,2, 3 and PW1 and 3

These policies propose 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_2808

Graeme Veale

Object

2. There is a proposed secondary school to be situated east of Tonbridge (AL/CA2 – site 447 & 454). This utterly preposterous for a number of reasons:

a. It is situated either side of a railway track, the only bridge being a private single lane road.

b. It is situated adjacent to Tonbridge borough, which already has numerous (6) secondary schools within a few mile radius.

c. It is situated some distance from the proposed Tudeley Garden Town, with no obvious access routes by foot or bicycle.

d. It is situated some distance from both Tonbridge and Tunbridge Wells railway stations, making it even more inaccessible for secondary school pupils.

e. It is situated adjacent to a roundabout and roads which are already very heavily congested during rush hour periods. I often sit in traffic queues at both ends of the day.

f. It is situated in Green Belt land.

DLP_2507

Roger Golland

Object

Your on-line response form seems to be deliberately restrictive and convoluted. On a draft borough plan, where the overall impact on West Kent residents is at issue, it is not feasible to assign specific comments to particular paragraphs of a 554pp document.

I live just over the western border of TWBC. Our neighbourhood will be adversely and permanently damaged by the impact of the proposed so-called garden village at Tudeley and its associated secondary school on the edge of Tonbridge. The Vision speaks of a ‘vibrant’ master-planned village. The reality is that it would be a stagnant dormitory housing estate clogged with vehicles trying to get to the already over-stretched facilities of Tonbridge.

Traffic is already choking the access roads into town, for schools, shops and the railway station – for instance at Vauxhall Roundabout and along Pembury Road. The proposals guarantee thousands more commuting vehicles and log-jams for hours every day. The existing winding road network is inadequate as matters stand. There is nowhere near enough road and parking capacity in Tonbridge, let alone Tunbridge Wells [STR6]. Your sustainability policy claims about clean air, public health, road safety and protection for wildlife in the blast of this development are not credible - assertions without supporting evidence.

Green Belt [STR 4] serves a statutory purpose and exceptional grounds must be given to justify its sacrifice. Expediency and the convenience of dealing with one profiteering landowner does not amount to exceptional grounds. The same landowner has already moved to develop Green Belt land on Tonbridge’s fringes in the TMBC Plan, where the same arguments apply. It is laughable to defend the plan on spurious bio-diversity grounds when ancient woodland and so much green space is to be chewed up unnecessarily.

The plan speaks of increased ‘walking and cycling permeability’, not to mention ‘active travel provision’, whatever that means. There is very little evidence from Tonbridge of a significant move to cycling and walking for children going to school, or people going to work. There are hardly any bus routes available to serve the planned ‘village’ and little reason to believe they will materialise. The notion of ‘low levels of private car use within the settlement’ is pious hope, especially when it is rainy and dark. There are no clues as to what employment will spontaneously appear in the new community to replace horticulture and farming. Many, if not most, residents will be commuters trying to reach Tonbridge station.

The plan suggests that the Tudeley plans are contingent on approval for a new secondary school on the edge of Tonbridge. The selected site, alongside the ring-road, next to industrial units, split by a busy railway line, over a gas-pipe, with limited pedestrian access from any direction, is utterly hopeless, for reasons countless objectors have already spelled out. Absent a suitable school site, can we assume the plans will be dropped?

Tonbridge cannot absorb the numbers proposed. The plan is a monster. It is bound to spoil vast areas of precious landscape. TWBC should challenge the basis of the excessive housing targets imposed by Whitehall (as it is free to do) and adopt genuinely sustainable settlement policies which will protect the environment, not continue to destroy it. An authority pursuing such old-fashioned development sprawl, based on the car and miles away from employment centres, does not deserve to stay in power for long.

DLP_2842

Helen Parrish

Object

TWBC should really (not just say that they do) cooperate with Tonbridge and Malling Borough Council and cancel the Tudeley Garden Village and AL/CA2 if T&MBC object to the TWBC Local Plan

This policy refers to a site that is wholly unsuitable to the development of a secondary school due to the:

* Railway line
* Busy roads
* Flood risk
* High pressure gas pipeline risks
* Unsustainable transport links to Tonbridge and Tunbridge Wells Town Centre
* Reliance on private car use for staff and students’ families.

There is no evidence that the development at Tudeley, with 1,900 homes built in the next 15 years, will have enough children of Secondary School age to fill an eight form entry secondary school.

Most of the students will come from Tonbridge and Southborough/Bidborough resulting in a high increase in levels of traffic and significant reduction in air quality.

DLP_3143

Andrew Pinhorn

Object

I am not a resident of Tunbridge Wells Borough but live near the Borough boundary with Tonbridge. I have lived at my current address for 22 years and prior to that for 5 years in Golden Green. I know the area around Paddock Wood, Capel and Tudeley well. This is an attractive rural landscape and an important reason why I choose to live here.

I am writing to object strongly to part of The Local Plan, reference AL / CA2, concerning the proposal to build a secondary school. I know this site well and consider it wholly inappropriate for a school.

My reasons are as follows:

The site in question is adjacent to and split by a main railway line

Access between the sites is via a narrow, single-lane, private drive, over an even narrower bridge, with blind spots at both ends of the bridge. There is no separate pedestrian walkway.

The main road to the south of the school is very busy already at certain times of the day and in my opinion it would be dangerous to have further significant traffic movements caused by a secondary school.

The countryside where the proposed school is to be built is attractive, comprises good quality agricultural land and attractive woods,

The countryside in question has public rights of way which are frequently used and have considerable amenity value.

I think this site should be deleted from the Local Plan.

DLP_3266

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

Paragraph 3 - “Suitable provision shall be made for vehicular, pedestrian and cycle access into and through the site, and between the northern and southern parcels of land.”

Additional paragraph - Vehicular access to be informed by a Transport Assessment

Additional paragraph - Development shall provide improvements to local road junctions and pedestrian footway crossings, and to other traffic or sustainable transport measures

The standard paragraph regarding contributions should feature in this policy - It is expected that mitigation measures will be implemented by the developer. A contribution may be taken if appropriate

Education

This policy relates to land proposed for the establishment of a new 6FE secondary school. The establishment of a new school is wholly required to support the proposed level of growth. It would be advantageous for the school to be located closer to the proposed development towards the East; this would increase the likelihood of more sustainable modes of travel being used by students. However, the geographic location of the school is acceptable in order to meet the additional need for school places.

The identified site is significantly constrained consisting of two sites separated by a railway line with deep embankments, the southerly part of the site contains a sizeable area of Ancient Woodland, a high pressure gas pipeline runs from south to north through the western side of the site and the south of the site is identified as an area of potential archaeological importance.

It is not preferable to establish a new school on split sites and the site’s additional constraints are likely to make design and construction of a new secondary school far more challenging. The maintenance and management of the ancient woodland could not be the responsibility of the school. Nor could the maintenance of the bridge that crosses the railway line; however the school would require security that the bridge will be maintained in perpetuity and there is potential that a second bridge over the railway would be required within the school site to overcome some of the site’s constraints; this would enable students to cross the two sites without leaving the safeguarding line of the school during the school day.

Delivery of a secondary school at this location is therefore highly likely to cost significantly more than that of a regularly shaped and unconstrained single site; the school will need to be wholly funded by development and therefore the financial contributions from contributing developments would need to be increased to cover the additional costs derived from both the site’s abnormals and the likely need to deviate from the DfE’s baseline design. In order for the County Council to confirm that the necessary secondary provision could be provided within the proposed site it is suggested that prior to Regulation 19, the Borough Council undertakes a detailed design and costing exercise relating to the site or that an alternative site with fewer physical constraints is identified within the area.

Public Rights of Way and Access Service

Attention is drawn to the existence of Public Footpath WT163, which connects the two sites. Whilst this right of way is highlighted within paragraph 5.6.1, Policy AL/CA 2 makes no reference to this path, which would increasingly serve as a sustainable transport link. Additional text should therefore be inserted into this policy, requesting that enhancements are made to this right of way, in preparation for the expected increase in use. Consideration should also be given to upgrading the status of this route, to enable access for cyclists and equestrians.

Heritage Conservation

Scale 2 - Pre-determination assessment should be carried out to clarify whether development of any part of the site is possible.

Potential for significant archaeology including industrial landscape features and buried archaeology. The site lies in an area of complex geology with gravels and head deposits along a river valley, which is favourable for prehistoric and later industrial and settlement activity. There is Postern Forge within the northern part of the north site and there are designated historic farm complexes adjacent with associated historic farmland and field boundaries.

DLP_4504

K Jones

Object

I have been a resident of Tonbridge for 38 years latterly enjoying the open landscape of Higham Wood. I have worked locally in both Tonbridge and Hildenborough for 36 years and on occasion travel to London. During this period I have experienced longer travel times to my place of work latterly 45 minutes for what takes 15 mins out of rush hour.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1, AL/CA1 Tudeley Village, AL/CA2 Land to East of Tonbridge/West of site for Tudeley Village)

Creating an enlarged settlement at Tudeley of 2800 dwellings will cause immense harm to residents of the Parish of Capel, but also to the residents of Tonbridge. Creating so much housing in Capel Parish will require the destruction of woodland, hedgerows, meadows, and farmland that is Green Belt land and should be protected. It will spoil the landscape and kill wildlife that is very special to the area, including rare species and increase air and light pollution. This area should remain rural with agricultural land that can be used to provide food.

The levels of traffic are already unacceptable during rush hour and beyond. The proposed school is on the border of Tonbridge, split by a main line railway alongside a heavily used road. Undoubtedly the school will attract students from outside the area of Tudeley and Tonbridge and I have concerns about the travel connections to the new school and road congestion as a result. The site would seem totally unsuitable for a school when considering the safety of students accessing both sites across a busy railway and pedestrian access to the school alongside an already heavily used road. Traffic will undoubtedly back up along the A26 inconveniencing those travelling from the North and South through Tonbridge.

The proposed housing consists of family homes and as we all know most households have 2 cars as a minimum. The increased traffic will exacerbate the already congested main routes and cause further rat runs of the surrounding small lanes. The possible relief roads which may or may not come to fruition will not stop this.

As it is likely that a railway station is not built at Tudeley the extra footfall at Tonbridge station could be significant on an already oversubscribed service. The lack of parking and bus routes will impact parking in surrounding roads which do not have parking restrictions and greatly inconvenience these residents. There are no cycle paths between the development and Tonbridge and indeed none along the A26 from Three Elm Lane heading to Tonbridge. Cycling is not a safe viable alternative mode of transport.

It is of concern to me that the area of development is subject to flooding relief and I worry any redirection might only exacerbate other areas, as we have seen in the recent case of Fishlake, Yorkshire.

Medical practices within the Tonbridge area are already swamped. One Tonbridge medical practice is moving to larger premises, but the advantage of the services they hope to provide and long overdue for their patients will only be absorbed by the residents of the new development, causing increased pressure on Tonbridge health services and have a detrimental effect on the health and wellbeing of Tonbridge residents.

The costs of infrastructure on the Tonbridge side of the boundary will be carried by Tonbridge & Malling residents whilst TWBC will receive council tax from the residents in the new dwellings. The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area, resulting in higher unemployment and further pressure on social services available with detriment to the High Street.

TWBC is using Capel to meet their housing needs on green fields and meadows, polluting a rural area rather than 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. They should reconsider and look to these brownfield sites and housing that is derelict before imposing this development on Green Belt land. The developments in Tudeley are unsustainable and place huge pressure on Tonbridge with no benefit to the residents of Tudeley or Tonbridge, only misery.

DLP_7051

Sigma Planning Services for Rydon Homes Ltd

Object

6. The basic concept of creating a new "garden settlement" at Tudeley is not considered to be sound and therefore will not survive examination in terms of Paragraph 35 of the NPPF. In particular the proposed policy is not:-

justified because there are reasonable alternatives that would avoid the serious adverse environmental impacts that would arise from this development.

  • effective because the infrastructure that is necessary to support the scheme will not be in place in time to deliver the development, even in significant part, within the plan period.
  • consistent with national policy - which seeks to balance competing objectives of the need for more housing against the protection of the environment. In this case the balance should fall in favour of avoiding the extensive harm to the environment that will result from this development.

7. The main reason why this development proposal should not be taken forward into the Reg 19 submission draft plan is that it puts at risk the soundness of the Plan as a whole and this will potentially prejudice the adoption of the Plan and at least delay its' progress whilst Main Modifications to remove the proposal from the Plan are considered and processed. The policy makes the whole Plan highly controversial and this will have consequences for the timing, complexity and cost of the plan process. These are not justified when alternative strategies are available.

8. The proposal will involve the loss of an extensive tract of open countryside which, although not within the AONB designation, is attractive and unspoilt including many areas of special ecological and environmental importance, notably Ancient Woodland, Listed Buildings (including the Grade 1 Listed Church of All Saintes), areas of Archaeological Potential, Habitat of European Protected Species and adjacent to the AONB and a Biodiversity Opportunity Area. The side does not lie adjacent to any substantive settlement and will manifestly change the character of the site and a wide surrounding area from undeveloped rurality to an urban area of Tonbridge and then another short gap to the east to Five Oak Green which itself is close to an expanded Paddock Wood, the Plan will introduce what is effectively an urban corridor between Tonbridge and Paddock Wood.

9. The selection of a site that is split by the main railway line and bordered by a higly trafficked main road is counter-intuitive in terms of objectives of connectivity and cohesion of the various parts of the proposed settlement. This simply presents problems for the creation of a unified settlement, increases infrastructure costs and sterilises development opportunities due to noise along both transport corridors.

10. The list of new infrastructure that will have to be provided, and mainly front-loaded, is daunting. The concept is unprecedented in Tunbridge Wells Borough and Members will have to be assured that the Council has the skill set and resources to manage this type of proposal properly at the same time as managing the expansion of Paddock Wood. One such project is a challenge, two is an impossibility.

11. The transport infrastructure that is required cannot be guaranteed in terms of practicality, cost/viability or timing. The route, costings, land assembly and planning consent for the connection to the proposed Colts Hill by-pass (in order to by-pass Five Oak Green) are all, as yet, undetermined. The timing is therefore uncertain but must await the completion of the Colts Hill by-pass which itself has been decades in plan but without any reality. Also, the project requires the introduction of a bus service simply to serve the Garden Settlement. Existing bus services run primarily from Paddock Wood to Maidstone and Tunbridge Wells, picking up Five Oak Green on the way. There is a variable timed but roughly hourly Autocar bus service from Paddock Wood to Tonbridge through Tudeley but this is focussed on a school-day service. It is more convenient to take a train between Paddock Wood and Tonbridge. The viability of a new bus service and the ability of this development to subsidise it are questionable.

12. There is an obligation to assist in the mitigation of flood risk in Five Oak Green but there appears to be no firm flood mitigation scheme proposed or details of costs, funding, practicality or timing. The requirement for the garden settlement to alleviate existing flood risk at Five Oak Green is unlawful in the light of the tests set out in the CIL regulations 2010.

13. The evidence base to the Plan does not include any meaningful viability assessment of this major development proposal. There being no existing infrastructure to assist provision in the early years of development, the new education, health, retail, drainage, utilities, transport, highways, social and leisure infrastructure will have to be fully front loaded. Without a detailed analysis and careful viability assessment this proposal can only, at best, be considered to be aspirational and there is insufficient evidence to give the necessary assurance that provision of infrastructure will be in place to deliver the suggested 1900 dwellings within the Plan period.

14. The SHELAA for the site assumes a 5% gross to net ratio, which is wholly unrealistic. It would be more realistic, given the level of necessary infrastructure to be delivered at this site, to apply a 60-40% gross to net. Based on 30 dph the land could deliver 2,834 units, 15 dph 1,417 units. The policy assumes 2,500-2800 new dwellings and it is questionable whether the site could deliver this, unless densities are increased which would likely have a detrimental impact on the landscape, heritage and flood risk etc.

15. The resilience of the Local Plan upon the success of this proposal is too great. It places the Plan as a whole at risk of being unsound because it is not justified, effective or sufficiently consistent with natioanl policy to protect open countryside and other important environmental considerations. This highly controversial policy should be withdrawn from the Plan - event if that is only to allow a longer period for the essential details and practicalities to be fully costed and investigated allowing a properly considered proposal to come forward in a future plan. 78% of the entire housing target is either allocated to Paddock Wood or Tudeley and this unbalanced strategy is too risky.

[TWBC: See full representation]

DLP_6049

Mr C Mackonochie

Object

Policy Number: AL/CA 2

This site is split by the railway line so it is unclear as to whether there are two schools or school on one side of the railway line and playing fields on the other. It seems a very unsuitable site for a school complex. It has other problems ranging from transport, flooding, high pressure gas pipeline. It is also a distance from the proposed garden village; a school should be within a community that is its major catchment area. It will be very attractive to the recently built development in Tonbridge

DLP_5145

Residents of Golden Green Association

Object

This is Objection submitted on behalf of the Residents of Golden Green Association,

Golden Green, is a small rural village with a population of 400, situated within the Medway Valley, 1 mile from Hadlow and 4 miles from Tonbridge, within the Borough of Tonbridge and Malling .

The surrounding area is predominantly agricultural with fruit orchards and cereals as the principal crops. The village is located on a ridge over looking the River Medway and The Medway Valley to the south and the River Bourne to the north. Goldhill Mill is the only watermill on the Bourne that retains its original machinery.  The Bell Inn public house is located in the village centre along with  Golden Green Mission Church hall a Grade II- listed tabernacle  opened in 1914.

These development proposals will have life changing consequences, the removal of 1000’s acres of Metropolitan Green Belt Agricultural Land which is situated upon one of the Uk’s largest natural floodplains, this floodplain has protected parts of the village from flooding since the villages existence, partial removal of this natural flood protection could seriously increase flooding to the area.

The village enjoys panoramic views across the open farmland and the Medway Valley across to the High Weald ANOB, a development of 2,800 houses would have a substantial adverse impact on the setting of Golden Green Village.

The provisional allocation of CA1 and CA2 will result in significant urban sprawl, diminishing a majority of the Green Belt countryside borders between Tonbridge and Paddock Wood.

The evidence within the Draft Local Plan does not provide any special circumstances that justify the permanent removal of this land from the Green Belt. The land was designated as part of Metropolitan Green Belt for sound reasons and particularly to protect and safeguard the many surrounding villages from inappropriate development and urban sprawl and to protect against the proposals that we are strongly opposing today.

The current road infrastructure is already at capacity and during peak travelling hours is barely coping with existing daily traffic volumes with long delays, these proposals will further increase the traffic congestion situation, especially through the centre of the village, Three Elm Lane and Hartlake Road. The current road infrastructure quite simply will not be able to accommodate the sheer quantity of motor vehicles from such a sizeable development, parts of the village don’t even have pedestrian footpaths.

There has been a significant amount of quarrying activity in the area over the years, notably at Stonecastle Farm Quarry to the East, which has led to amenity impact from noise, dust, vibration, light pollution and increases in HGV traffic. Active quarrying ceased 12 years ago and the area has been left undisturbed and has enjoyed a resurgence of many species of wildlife and plant-life returning to the area.

Villagers discovered in 2018 that the quarry operator intended to recommence operations after years of absence this has led to strong opposition  against such proposals, which are currently being reviewed by the inspectorate.

The character of the local area, Capel,Tudeley, Golden Green, Whetsted, Five Oak Green  villages, which are all situated within Green Belt, would be virtually destroyed by the cumulative effect of these developments, together with the quarry extensions, and the removal of more than 1,000 acres of agricultural land.

We would like to endorse all the comments  and objections that have been made by saveCapel

​Creating a garden settlement at Tudeley of 2,800 dwellings will cause immense harm to residents of the Parish of Capel and to residents of Golden Green and Tonbridge. There will be a significant increase in traffic in to Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road every morning. The already unacceptable levels of traffic between 7.45am to 9am on Woodgate Way, Vale Road and Pembury Road coincide with the site of a proposed new 6 form entry senior school. This proposed school will be on the border with Tonbridge, split by a main line railway and alongside a heavily used road. This appears to be a terrible site for a school, surrounded by heavy traffic and requiring children to cross a busy train line to access both sides of the site.

People living in Tudeley will use Tonbridge Station for commuting and Tonbridge town services that will need more parking. The increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times and can’t be made wider in most places. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable. I previously commuted and frequently had to stand the entirety of my journey up to London, how can the existing transport links cope with the extra commuters. Parking in and around Tonbridge Station will be even more difficult. Network Rail have confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. Most people living in the new garden settlements will drive privately owned cars, despite initiatives to encourage bus and bicycle use. The costs of infrastructure on the Tonbridge & Malling side of the boundary will have to be carried by Tonbridge & Malling residents whilst Tunbridge Wells will receive council tax from the residents in the new dwellings. The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area. There will be an increase in pressure on Tonbridge health services, amenities and car parking as residents from the new garden settlement at Tudeley will use Tonbridge as their local town, not Tunbridge Wells, because Tonbridge is much closer.

Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but I believe that flood risks will increase. Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding. There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape. Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saint’s Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. That will cause great harm to its value as a heritage asset of world renown (due to the complete set of Marc Chagall windows)

The garden settlement at Tudeley can never be one settlement as it is divided by a railway line that has very narrow, weak crossings. Putting in larger crossings at frequent points across the railway may be possible but it won’t tie the two halves of the settlement together enough to make it one settlement, so it will never satisfy garden settlement principles.

​Creating so much housing in Capel Parish will require the destruction of woodland, hedgerows, meadows, and farmland that is Green Belt land and should be protected. It will spoil the landscape and kill wildlife that is very special to the area, including rare species. This area should remain rural with agricultural land that can be used to provide food.

We believe that housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. we would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan. TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government 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. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant.

The plan preparation process didn’t include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan didn’t go through most of the plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment, no Biodiversity Assessment. We think that this version of the draft Local Plan isn’t complete enough to be ready for public consultation when the land for such a big proportion of the housing hasn’t had the same level of assessment as the rest of the plan. The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they didn’t know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. We think that the plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough.

​Earlier in the plan (in 4.40) 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. We think that TWBC want to fill Tudeley and East Capel with housing until they coalesce with Tonbridge to the West and Paddock Wood to the East, ultimately creating a massive conurbation that will dwarf Tunbridge Wells town centre. TWBC is using Capel to dump their housing needs on green fields and meadows, polluting a rural area rather than 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 and place huge pressure on Tonbridge.

DLP_7276

Mrs Katie Lee-Amies

Object

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_6165

Susan Bevan

Object

As a resident of Tonbridge, I strongly object to the proposals to fulfil the bulk of Tunbridge Wells’ projected housing requirements on the borough’s border with our borough, Tonbridge and Malling. In particular, I am aghast by the proposal to swamp the small village of Capel, on Tonbridge’s doorstep, with a development of 4,000 houses.

As the main urban centre of Tonbridge and Malling, Tonbridge has seen rapid expansion in recent years and further expansion is proposed in our borough’s own local plan. Our infrastructure is already creaking under the strain. The proposals for Capel would make intolerable demands with the new residents inevitably using our facilities and not those of Tunbridge Wells which would nevertheless be in receipt of their Council Tax payments.

In particular, our road system, which is inadequate already, due in part to insoluble problems presented by the town’s location straddling the River Medway, could not sustain the additional pressure generated by the proposed development. Capel has no existing public transport. The new residents would be dependent on their cars whose initial destination is likely to be Tonbridge. Commuters would inevitably add to the congestion at Tonbridge railway station already the busiest in the south-east.

The proposal to build a new secondary school straddling the railway line on the outskirts of Tonbridge is absurd. Tonbridge already has an exceptionally high concentration of secondary schools attracting pupils from far and wide whose transport contributes significantly to our traffic problems. The proposed school would not be in walking distance of the station or on a bus route.

Apart from its ramifications for Tonbridge, this very large development on the green belt adjacent to the High Weald Area of Outstanding Natural Beauty, is completely unacceptable and contrary to national planning policy. A particular scandal would be the impact on Tudely church, which attracts visitors from around the world to view its beautiful Chagall windows. This little building in the countryside would, under these proposals, be surrounded by a housing estate.

It is quite clear that Tunbridge Wells Borough has seen an easy route to fulfilling its housing needs by entering into agreement with a single substantial landowner quite regardless of any other priorities or considerations.

DLP_5067

Nigel Tansley

Object

I am writing to object to the proposed development at fields neighbouring the railway at the eastern boundary of Tonbridge, known in the TWBC Local Plan as site CA2.

At the moment they form a clear boundary between Tonbridge and the neighbouring countryside, which is one of the main reasons for that location being in the green belt.

If the fields were in Tonbridge and Malling district they might possibly make a logical extension to their town, but these fields are not attributed to them, being in a different borough across the boundary which runs approximately along the A26 road at the western, Tonbridge end of the site.

If they were in T&MBC’s area, that borough council would be prepared to undertake the effects that a development there would have on their town, but being in a different borough they would only suffer the negative effects and not the positives.

In addition, the fields are of a productive size and not only are Grade 3 but also Grade 2 soil as confirmed in the SHELAA documents for the two fields involved, which is relevant in the growing need for more food to be grown.

In attempting to solve its own housing problems, Tunbridge Wells Borough Council seem to have potentially done so at the expense of its neighbouring town at Tonbridge.

I understand that the proposals in place for the green fields at site CA2 are for a secondary school, which seems a strange choice when Tonbridge already has so many secondary schools which cause problems when those thousands of pupils are all travelling to and from school at the same time. This additional number of pupils would only compound Tonbridge’s transport problems.

I have not made a study of secondary schools but I would have thought it should be better to offer a greater choice elsewhere, in a location that offers fewer schools.

Paddock Wood has Mascalls School which I understand is an excellent school and perhaps would benefit from expansion, or maybe the competition from an alternative school. Pupils from the proposed Capel CA1 site would have to travel a little further to Mascalls than they would to the school at CA2, but it is not clear at this point how they would travel to the new schools at CA2, separate as it is from CA1.

If a new school was to be built, if it was to serve the pupils at CA1, perhaps it would be more logical to build it close to Paddock Wood in that way perhaps making an annexe of Mascalls if it was felt there was not adequate room for that site to expand.

However, I object also to the planned expansion of Paddock Wood, and the site in Tudeley at CA1, also building on extensive productive agricultural land when alternatives area available closer to existing settlements, notably rejected SHELAA sites at Tunbridge Wells and Pembury plus other sites in the borough, which I hope TWBC will review instead of this and the other nearby unsuitable and inappropriate locations immediately neighbouring Tonbridge.

DLP_5439

Cheryl Acaster

Object

I’m writing to express my deep concern about the proposed housing development in Tudeley coupled with the secondary school on Woodgate Way. Not only would this have a detrimental effect on the villages of Tudeley, Capel and Five Oak Green because their services could not cope with 2000 additional homes but it would have a severe impact on the roads and services in Tonbridge. For example during the morning and evening rush hours the traffic at the Somerhill Roundabout is often at a standstill. Any additional traffic approaching from Capel would cause major problems. The commuter community is already under strain and the extra houses would affect the trains from Tonbridge even though the train passengers would be living within the T Wells boundary.

Council tax would go to Tunbridge Wells yet Tonbridge and Malling Borough Council would have to be sorting out the terrible problems which would arise. Tonbridge is already under great pressure to provide adequate services such as Doctors’ surgeries.

I urge the members of Tunbridge Wells Council to te think their plans.

DLP_5442

Jackie Powell

Object

I live on the Somerhill Green residential development just off the A26 (Woodgate Way) and I am writing to strongly object to your proposed housing and school developments at Tudeley and Capel.

Creating a garden settlement of 2800 residential dwellings at Tudeley will cause immense harm not only to the existing residents of the Parish of Capel but also to the residents of Tonbridge and in particular residents of Somerhill Green. There will be a significant increase in traffic into Tonbridge from the B2017 (Tudeley Road). This road is already heavily congested, particular in the mornings and late afternoons. The roundabout connecting Somerhill Green to the A26 is the only vehicle access into and out of Somerhill Green and The Bishops Chavasse primary school. The A26/B2017 roundabout on Woodgate Way is difficult for traffic to enter due to its layout. The construction of yet another school in this area is a recipe for disaster. It is a terrible location for another school, surrounded by heavy traffic and requiring children to walk along and cross busy roads. Air and noise pollution from the road traffic would become unbearable for all residence, old and new. This would also effect the health of the children at Bishops Chavasse and the new school.

Many of the people living in the new houses will use Tonbridge Railway Station for commuting to and from work, where will they park ? The additional traffic will be more than the local roads can cope with. The towns roads are already full at peak times, the trains are already packed. With 2800 houses at Tudeley and a further 1500 at East Capel it will mean more than 8600 additional cars on the narrow lanes, each day. I don't believe this proposal is sustainable. There will also be a big impact on health services and other amenities in the Tonbridge area, which are already stretched to breaking point.

Covering our farm fields, woods and meadows with hard surface of tarmac, concrete and paving will have a large impact on flood risk. Much of the Medway floodplain will be lost. The local stream already takes additional surface water from the A21 duelling and the construction of Jaguar Landover’s new showroom and service centre.  I believe that flood risks will increase should this proposed land development proceeds. The developments will also make the Medway more likely to flood more often and  cause increased flood risks in the whole area of Tonbridge to Yalding.

Creating such a large development and destroying so much Green Belt land will kill off wildlife and ruin the habitat for many others, with increased noise and light pollution. We should be protecting our woodland, hedgerows and the environment. Future generations will not thank you for vandalising the countryside.

I would therefore ask that you  please rethink before adopting this environmental unfriendly plan. Destroying many acres of pristine Green Belt, teeming with wildlife and biodiversity is not in keeping with todays thoughts for helping to reduce climate change and to protect our planet for the children of the future. There must be a better way forward.

DLP_5446

Mr Timothy Holbrow

Object

As a long term resident of South Tonbridge, I am writing to express my views on those TWBC local plan proposals that will have a significant direct impact on me, even though I don't live within the TWBC area, namely:

  1. Proposals for over 2,000 homes at Tudeley; and
  2. Proposals for a new secondary school on Woodgate Way.

South Tonbridge already has 3 secondary schools, 2 primary schools and the Schools at Somerhill all within 1 mile of the proposed new school. It is already at saturation point in this respect without making matters worse.

The recent increase in retail outlets in Cannon Lane (A26) and alterations to the traffic flow around Tonbridge Station have already resulted in significantly increased peak hour and often off-peak queues in all directions. The houses proposed for Tudeley and new proposed new school will significantly worsen this. Also what is the provision for increased primary school places?

The proposed site for the new school is ludicrous. If this is designed to serve the new houses at Tudeley and Capel this can only be achieved by pupils getting to school by car or bus. The B2017 is certainly not suitable or safe for increased cycle traffic and has no pavements for pedestrians. This would therefore not be a 'green' solution. Potential pupils from Paddock Wood could travel by train but pedestrian routes to the proposed school are from ideal (e.g. Vale Road) and would require pupils to cross Woodgate Way at some point further exacerbating the traffic flow.

As a general comment, it appears that, in selecting Tudeley for major development, TWBC is trying to meet its housing target but escape any liability for providing any other additional services (such as doctors) by placing this development on the doorstep of Tonbridge.

DLP_5488

Dennis and Patricia King

Object

Comments on TWBC Local Plan Elements CA1 & CA2 Capel / Tudely & Paddock Wood (East Capel)

The enclosed missive is likely to be very similar to many other Tonbridge residents who are very concerned with and opposed to the proposed plans for the Capel / Tudely  and East Capel Garden Development. This is because myself neighbours and most sections of the communities across Tonbridge appreciate the significant detrimental and unsustainable effects of this plan on Tonbridge and its residents.

There are very many reasons why this proposal is ill conceived. Here are our principle reasons for objecting to this aspect of the TWBC Local Plan:

  • The Capel / Tudely Plan is only for the convenience of TWBC which is satisfying 57% its housing requirement by building close to the borders with TMBC and Tonbridge in particular. I.E. in Capel, Tudely and Paddock Wood / East Capel. Tonbridge will suffer the unsustainable burden of 8000 new houses without any of the tax revenues to compensate for the loss of amenity and degradation in the quality of life due to limited infrastructure, demands for public services and general capacity.
  • The proposed developments in Capel / Tudely and Paddock Wood are not addressing the demand profile for housing across the whole of the TWBC area.
  • The resultant road congestion and demand for rail and other services on Tonbridge will have unsustainable impacts on Tonbridge, even with major upgrades in local access roads.
  • The countryside around Tonbridge will be decimated and the urban sprawl around Tonbridge will largely disappear. TWBC already acknowledge that this is one of the fundamental purposes of the green belt.
  • 600 acres of prime agricultural, food producing green belt land will be removed from the national capacity to feed our people. This land has been previously been judged by TWBC to fulfil all its green belt criteria and according to recent TWBC judgements as being inappropriate for development.
  • The Capel / Tudely development would be bisected by a rail line and would effectively be 2 disconnected components.
  • This is a potential floodplain area and for the River Medway and hence inappropriate for large scale development.
  • A beautiful and world renowned part of Kent Life would disappear with the absorption of local villages and hamlets.
  • Capel / Tudely would become a suburb of Tonbridge, against the wishes of its residents!

DLP_5579

Kate Butcher

Object

My name is Katie Butcher and I live with my partner in Hazelwood Close, Tonbridge (the new build development on Somerhill Green).  I wish to express a real objection to the secondary school being developed on Woodgate Way - this will cause a real increase in traffic to the roundabout on Woodgate Way - once which already struggles to cope with the current infrastructure, let alone the increased number of houses you wish to development in the Capel area.  ​

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

DLP_5593

Max Green

Object

I live close to the proposed site for a secondary school (Policy AL/CA 2) and make regular use of the Tudeley Woods Local Wildlife site and surrounding green belt areas.

I am writing to object to the plans to build a secondary school close to the border with Tonbridge (Policy AL/CA 2).

There are already six schools within half a mile of where I live and adding another would regularly cause gridlock on surrounding roads (Woodgate Way, Vale Rd, Tudeley Rd).

The location, right on the border, appears to have been chosen specifically to ensure that negative impacts are passed onto Tonbridge rather than Tunbridge Wells.

The plan suggests that transport issues will be dealt with by facilitating “active transport modes, such as walking and cycling from Tudeley village”. This is clearly a nonsense as the reality is that - like all schools - it will be attended by children from way beyond the immediate locality and, as it some way from the station, many will travel by car. As well as road congestion, this will have a negative impact on air quality and will harm the quality of life for people living and working in the area.

In fact it is hard to think of a less suitable site for a new school in the area. As mentioned above, it is an area where roads are already overburdened at school pickup times, split by a railway line, a high pressure gas pipe and close to ancient woodland and areas of potential archaeological significance. In fact, the only motivation for Tunbridge Wells appears to be that many of the negative impacts will be passed onto a neighbouring borough.

I would also like to stress that many people in my locality are still unaware of the dramatic changes planned for areas within a few hundred metres of where they live. This would suggest to me that the consultation process has not done enough to engage with people in Tonbridge, who would be among those paying the biggest price for the most ill-considered aspects of this local plan.

DLP_5603

Sean Chapman

Object

I have lived in Tonbridge my whole life, was educated in Tonbridge and have spent most of my working life in the Tonbridge/Tunbridge Wells area. I feel that makes me particularly knowledgeable of the changes Tonbridge has gone through in that time and its issues and needs for both the present and the future.

For the last six years i have lived in South Tonbridge and in that time alone the increase in numbers of residents and cars has been unimaginable. The increased number of houses and flats, together with the mainline railway station and unusually high number of schools result in the key roads in and around Tonbridge and South Tonbridge in particular being in a permanent state of grid-lock a large proportion of the time.

The idea of adding another 4,000+ homes and a senior school onto the outskirts of Tonbridge will make the town centre, mini-bypass / industrial estate and surrounding areas inhospitable and uninhabitable.

I OBJECT to the Tudeley (STR/CA1), Senior School (STR/CA2) and East Capel (STR/PW1) planning strategies in the STRONGEST possible terms and for the following reasons:

  • Tonbridge is UNABLE to support its current ever increasing population. That is WITHOUT the creation of a new garden town on its doorstep that is totally reliant on its services.
  • TMBC has indicated a strategy to discourage unnecssary car use and ease congestion in Tonbridge, via the provision of increased footways and cycle paths. Yet these plans by TWBC render this ethical and environmental strategy of TMBC totally useless, with the provision of the 4,000 totally car dependent homes and senior school on its perimeter. This is UNETHICAL and WRONG.
  • Only this week i had to queue for ten minutes just to buy a train ticket after 9am and subsequently missed my train. It dawned on me that this is likely to become the norm with the addition of these homes and that is simply not acceptable.
  • The proposed area of development is an area of natural beauty, intrinsically linked to the history of the region with its orchards and hop growing past. The opportunities to explore this area via its network of public footpaths are vast and spectacular. In today's world, with the surging mental and physical health issues it creates, there is not an expert in the world that would understate the absolute importance of encouraging people to experience and enjoy the natural environment around them. Yet TWBC proposes to remove and urbanise this very environment, that provides exercise and enjoyment to so many. This is UNETHICAL, SHORT-SIGHTED, IRRESPONSIBLE and WRONG.
  • Perhaps TWBC should concentrate on utilising the many derelict / empty buildings and sites in the existing town first, before it decides to destroy a natural environment.
  • I would add that in the current Brexit related times, with a possible need to become self-sufficient and a growing conscience in respect of food air miles, the Garden of England should perhaps be that once again, NOT an urban jungle.
  • Building on Greennbelt is IMMORAL and WRONG.
  • The proposed area of development is a FLOODPLAIN. This area has already suffered from severe flooding through the years, with the Leigh flood barrier also being at full capacity several times in recent years. Building to this scale on floodplains SHOULD NOT BE ALLOWED. It is quite simple, these developments will increase the flood risk for this area and downstream (Maidstone) exponentially and that should not be allowed to happen.
  • Building on floodplains is IRRESPONSIBLE and WRONG.
  • The proposal of a senior school, on greenbelt land, with a railway line running through the site, on the edge of town with road travel the only option, in an already congested area in terms of road traffic is DANGEROUS and NOT SUITABLE.
  • Finally, the fact that TWBC can propose a development and strategy that will have more of an impact on its neighbouring borough council is both IMMORAL and WRONG. The already hugely over-subscribed services of Tonbridge will not be able to cope, Tonbridge will become clogged and struggle to breath, yet TWBC will tick 4,000 homes off its target and collect its council tax, whilst suffering minimal fall-out. How can that be right? How can that be acceptable?

These strategies are wrong and must not be allowed to happen. The damage will be irreversible. TMBC will suffer unbearably under the weight and cost of the increased burden from these homes and the residents of TONBRIDGE will bare the scars of TWBC's irresponsibility every single day.

DLP_5739

Mark Bone

Object

I am contacting you to highlight why I believe your local plan is defective in relation to the proposed development of Tudeley, Capel and Paddock Wood - re AL/CA1, AL/CA2 and AL/CA3 and to make it clear that I object to the proposed development.

I am a resident of East Peckham and I use the B2017 and the Hartlake Road everyday. In addition, I regularly travel to and from Tonbridge, Paddock and Tunbridge Wells for recreational purposes and have previously spent 20+ years commuting form East Peckham to Tunbridge Wells. I also often walk in the area of the Medway Valley between East Peckham, Five Oak Green and Tudeley.

I observe that you propose a massively disproportionate development of the B2017 corridor and the segment of the A228 that intersects with it. Your own strategic plan talks about a Borough wide development yet an overview of your local plan makes it clear that the development on the Tudeley-Capel- Paddock Wood axis is vast in comparison with even the next biggest development for the town of Tunbridge Wells. In comparison the towns and villages to the south east of Tunbridge Wells such a Hawkhurst, Sissinghurst, Cranbrook and Goudhurst have a fraction of the development proposed for Tudeley, Paddock Wood and Capel.

Your strategic plan calls for a sustainable development with each large development having its own distinct identity. Yet you local plan envisages creating one continuous suburban sprawl from Tonbridge to Paddock Wood along a route that is already has, by your own admission, an inadequate transport infrastructure. The addition of thousands of more houses in this area will draw a huge increase in traffic towards the existing bottleneck at the Somerhill roundabout on the edge of Tonbridge being the most direct route to the A21 and Tonbridge Railway station. The proposed secondary school opposite the existing Somerhill school will exacerbate this volume of traffic and create a further rise in congestion and air pollution. The mitigations in your plan lack detail and frankly ignores the reality that most residents of any new development will need and want to use a car, and that each household will probably average two cars. Even if people wanted to use bicycles rather than cars the nature of the roads in this area makes cycling dangerous and counterproductive as the roads are too narrow and the volume of traffic already excessive.

Furthermore, in the opposite direction heading away from Tonbridge, the Colts Hill section of the A228 is already unsuitable for the current volume of traffic and a proposed by-pass will simple move the problem to another place whilst creating further environmental damage, not to mention expense. Your plan also appears to overlook the lack of capacity at both Tonbridge and Paddock Wood stations, plus the fact that Southeastern trains are already at full capacity on this route. Your plan also seems to overlook the effect of additional congestion on the main route between Maidstone and Tunbridge Wells and how this will be detrimental to the town of Tunbridge Wells.

In addition to the travel issues mentioned, I also note that the proposed developments will inevitably add to the flood risks in the adjacent section of the Medway Valley. Replacing fields with housing estates on the higher ground along this stretch of the valley will certainly add to run off and accentuate the already high flood risk. The local plan acknowledges this but provides no clarity as to how this will be mitigated.

Finally, the removal of a natural habitat of flelds,hedges and copses will cause irreversible harm to widlife species listed under section 41 of the Natural Environment and Rural Communities Act 2006, in particular farmland birds such as the Yellowhammer, Linnet and Lapwing, all of which I have seen along the Hartlake Road in the last year. Similarly, the Tudeley Wood RSPB reserve (which incorporates a rare heathland habitat) will be affected by the scale of the proposed developments, especially if a by-pass for the A228 is constructed. Consequently, there seems no realistic prospect of a net gain for the environment and biodiversity.

In summary, I believe the scale and design of the proposed local plan strategy for Tudelely, Capel and Paddock Wood is both unfair, unjustified and misguided. Therefore, I reiterate that I strongly object to AL/CA1, AL/CA2 and AL/CA3 of the draft local plan strategy document regulation 18 and I would appreciate an acknowledgement of this e-mail.

DLP_5744

Clare Robins

Object

I have tonight learnt of plans to build s school off Woodgate Way.

I live in St Mary’s Road and work in Five Oak Green Road opposite the Porsche Garage.

Out of peak hours my journey takes me 4 minutes, in the morning it can take me 20 minutes.

There is a huge amount of congestion around Pembury Road and Woodgate Way and also in Five Oak Green Road where the new Bishops Chevaise School has been built.

The Woodgate Way is now dangerous as you have vehicles turning in and out if the new Jaguar Garage.

This location is not suitable for another school and will mean another load of inconsiderate parents having to drive as it is so far away from anywhere and not on a Bus Route.

Please register my objection.

DLP_5927

Sarah Chilvers

Object

I have lived along with my family in the area for my entire life and have seen at first hand the dramatic changes and the effects this has had on our local community.

This very unique network of small rural hamlets and villages have evolved and developed around the farming community. From my childhood of growing up being surrounded by hop fields and orchards over the last decade have seen the removal of the hop fields an orchards to be replaced with Quarries, Solar Farms and now potentially 4,000 new homes. The creeping ‘Urban Sprawl’ is becoming more and more evident by the day, destroying the unique character and community spirit many of the surrounding villages have always enjoyed.

To surrender 1000’s of acres of productive agricultural land in the centre of Kent’s Green Belt, bordering High Weald AONB does not make any sense at all, especially as we depend on crops produced both locally and nationally. We have a number of extremely successful fruit farmers within the area, with Moat Farm being one of the largest fruit farms in Kent.

To replace these vital parcels of Green Belt with further quarries and houses would severely compromise this very important industry which supports our local economy as well as contributing to the conservation of the vibrant biodiversity within the area.

Upon reading the evidence or lack of it ...within the Draft Local Plan and reading the NPPF polices and guidance on Green Belt I can not see any justification that supports the “ Special Circumstances” that the Council justifies .

Creating a garden settlement at Tudeley of 2,800 dwellings will cause immense harm to residents of the Parish of Capel and to residents of Golden Green and Tonbridge. There will be a significant increase in traffic in to Tonbridge from the B2017,Hartlake Road, Three Elm Lane and the A26 exacerbating the extreme traffic congestion that exists on this road every morning. The already unacceptable levels of traffic between 7.45am to 9am on Woodgate Way, Vale Road and Pembury Road coincide with the site of a proposed new 6 form entry senior school. This proposed school will be on the border with Tonbridge, split by a main line railway and alongside a heavily used road. This appears to be a terrible site for a school, surrounded by heavy traffic and requiring children to cross a busy train line to access both sides of the site.

The decision by TWBC to build over 60% of its total housing allocation between Paddock Wood and Tonbridge will effectively be the commencement of the disappearance of the villages of Tudeley, Capel, Five Oak Green and the surrounding hamlets as once one development happens more will follow e.g Kings Hill West Malling.

30% of total housing allocation is on the borders of TMBC, which will provide TWBC with all the associated revenues and TMBC with all the costs and liabilities. People living in Tudeley will use Tonbridge Station for commuting and Tonbridge town services will need more parking and public services facilities and budgets will have to be increased substantially, who will maintain and pay for the substantial infrastructure requirement now and the ongoing liabilities, as well as the recruitment of all the additional public services that will be required TWBC ratepayers or TMBC ratepayers?

Large parts of the developments will occur on the Medway floodplain, which is a key natural flood defence for many of the surrounding villages, any removal or partial removal  could create further flooding issues in the future , it appears although parts of the proposed  CA1

development are situated with EA Flood Zone 3 the Council have not undertaken any flood risk assessment as outlined within the NPPF.

The garden settlement at Tudeley can never be one settlement as it is divided by a railway line that has very narrow, weak crossings. Putting in larger crossings at frequent points across the railway may be possible but it won’t tie the two halves of the settlement together enough to make it one settlement, so it will never satisfy garden settlement principles.

CA1 overlies a significant Aquifer of which is SPZ3, for public water abstraction, this is an important local water supply further development of this area may impact water supply options.

As per the recent correspondence between the Environment Agency and KCC regarding the proposed quarrying extensions the EA have concerns that any further development within this area could have a negative impact upon the Aquifers and have requested a Hydrogeological Risk Assessment to be undertaken, this assessment should extend to CA1 as well, to ensure that the Aquifers are not compromised by further development on CA1.

The Aquifer and natural springs within the site  will seriously hinder excavations for building, sewage, drainage as suitable mitigation schemes will have to be implemented to avoid puncturing the natural clay membrane that protects the Aquifer

CA1 is situated within an area where its water resources are already under serious stress,

and currently there are a number of issues outstanding with the Environment Agency, KCC and local residents.

The Draft Local Plan has not considered the potential environmental issues around the Hartlake Aquifers and, with rising nitrate and pesticide levels that have already been identified, any penetration to the Aquifers would lead to further significant human health risks.

The draft plan does not identify the neighbouring  2 former landfill sites of which have had millions of tonnes of household, industrial rubbish deposited there in the 1980’s and 1990’s, given the historical issues regarding previous mineral workings, and the major concerns of further pollution to the surrounding aquifers it is very concerning that the Council have not appeared to have considered the potential environmental and health risks prior to submission of CA1 to the Draft Local Plan.

It is most concerning that as to date the Council has been happy to proceed with the Inclusion of CA 1 and CA 2 within the LP based off very vague and generalist desktop study which takes a borough- wide assessment - Biodiversity Evidence Base for Draft Local Plan- Regulation 18 Consultation September 2019.

In view of the size and scale of the proposed developments (one of the largest within the plan) and the potential net loss of land, far more information should have been provided within the plan.

No biodiversity assessment has been produced to date, it is very evident that the Council have not collaborated with other local authorities who have development plans within the area as many biodiversity issues have arisen which will have a direct effect to these sites.

The LP  should ensure that biodiversity cannot be offset elsewhere, and must demonstrate through a clear application metrics that net biodiversity gain is achieved now, and not some point in time, in the future.

The Government 25 year Environmental Strategy requires net gains for biodiversity this is reflected within the NPPF.

There are many other issues I have but due to time constraints of todays 5 pm deadline i will list them without providing further detail.

No Green Belt Assessment
No Flood Risk Assessment 
No Landscape Sensitivity Assessment
No Biodiversity Assessment
No Environmental Assessment
No Transport Assessment
No Heritage Assessment
Questionable Sustainabllity Scores versus other Identified sites.

The initial Draft Plan preparation process did not initially include CA1 and CA2 until the Issues and options Process Stage, therefore many of the processes and procedures that were undertaken with other sites have not been completed.

DLP_6230

Amy Togher

Object

Policy Number: AL/CA 2

Land to the east of Tonbridge / west of site for Tudeley Village

This proposal would have the biggest impact on the residents of Tonbridge by sheer virtue of the fact that the allocation is on the very outskirts of Tonbridge.

South Tonbridge already has one of the highest concentrations of senior schools for a town of its size anywhere in the country.  This puts immense pressure on the local road, bus, and rail network as travel to school plans are increasingly difficult to manage. Pupils often have to travel long distances to schools, and it is right that KCC should have oversight of this. However as we have seen recently, with school expansion in Maidstone, even the slightest increase in a schools’ yearly roll, or a small change in catchment area can disrupt local bus services and bring gridlock to the area.

My concern is that a secondary school off Woodgate way in Tonbridge would make peak traffic time movements in Tonbridge unsustainable. The site is not within easy walking distance of Tonbridge station, nor on the most convenient bus routes in the town. Indeed as things stand, it is only services such as the 205 from Kings Hill which pass this location, and this only started this year. There is no doubt that this allocation would bring chaos to the already finely balanced (i.e. strained) public transport network in Tonbridge.

It is noticeable from the extremely detailed 544 page of the Draft Local Plan that there is absolutely no mention of the impact of this secondary school on Tonbridge. This gives me significant cause for concern and is a glaring omission from the draft local plan.

In the words of Tom Tugendhat, MP for Tonbridge – “A new secondary school on this site would have such adverse impacts on the town of Tonbridge that I strongly doubt whether it would be feasible to deliver.”

DLP_6271

David Witt

Object

I am writing as a resident of Tonbridge.

Having looked at the plans for the developments in Tudely and Capel and the school at Woodgate Way, I can only say that I am absolutely appalled by the potential impact on the infrastructure and services of Tonbridge. These developments would seriously overload and threaten the viability of the town’s train and medical services and almost inevitably lead to severe congestion.

The fact that these plans were conceived and promoted by a neighbouring council (TWBC) which will not itself have to suffer the burdens caused by the developments represents one of the most cynical acts of local planning that I have ever encountered. It is difficult to believe that our planning system could be so inadequate as to allow one town to meet its own objectives by crippling the infrastructure of a neighbouring town without even bothering to make a serious assessment of the resultant damage or secure agreement on a resolution with the other town.

I would therefore urge all those who are in a position to influence the outcome of this proposal to do everything in their power to ensure its rejection.

DLP_6322

Emma Stroud

Object

Policy Number: AL/CA 2

Land to the east of Tonbridge / west of site for Tudeley Village

In the words of Tom Tugendhat, MP for Tonbridge - This proposal would have the biggest impact on the residents of Tonbridge by sheer virtue of the fact that the allocation is on the very outskirts of Tonbridge.

South Tonbridge already has one of the highest concentrations of senior schools for a town of its size anywhere in the country. This puts immense pressure on the local road, bus, and rail network as travel to school plans are increasingly difficult to manage. Pupils often have to travel long distances to schools, and it is right that KCC should have oversight of this. However as we have seen recently, with school expansion in Maidstone, even the slightest increase in a schools’ yearly roll, or a small change in catchment area can disrupt local bus services and bring gridlock to the area.

My concern is that a secondary school off Woodgate way in Tonbridge would make peak traffic time movements in Tonbridge unsustainable. The site is not within easy walking distance of Tonbridge station, nor on the most convenient bus routes in the town. Indeed as things stand, it is only services such as the 205 from Kings Hill which pass this location, and this only started this year. There is no doubt that this allocation would bring chaos to the already finely balanced (i.e. strained) public transport network in Tonbridge.

It is noticeable from the extremely detailed 544 page of the Draft Local Plan that there is absolutely no mention of the impact of this secondary school on Tonbridge. This gives me significant cause for concern and is a glaring omission from the draft local plan.

A new secondary school on this site would have such adverse impacts on the town of Tonbridge that I strongly doubt whether it would be feasible to deliver.

DLP_7148

Kaye Palmer

Object

I am writing with my formal comments on your Local Plan. I live in Tudeley with my family and passionately love where I live. Although we pay our Council Tax to Tunbridge Wells Borough Council, we have a closer affiliation to the town of Tonbridge and use their amenities, being only a short car or bus journey away. For example my child attends school in Tonbridge, I have never started a train journey from either Paddock Wood or Tunbridge Wells stations because Tonbridge station is closer and we are registered with the Hadlow medical practice, also in Tonbridge and Malling Borough, because this is closer than any Tunbridge Wells practice.

For the reasons set out below, please include my objections to policies CA1 and CA2 of the Local Plan.

“The Strategy for Capel Parish” (Policies STR/CA1 and CA2)

Traffic and Transport – To say the least, the Plan is sketchy on its highway proposals for this site – much more information would have allowed constructive comment. However, I do not believe it will be possible to mitigate the effects of the additional houses because any improvements in TWBC will merely deliver traffic to the pinch points in Tonbridge faster, where most traffic will be heading either as a destination or en route elsewhere. The B2017 is already very heavily used, and traffic frequently queues back from All Saints Church to the Woodgate roundabout, then to the A21 roundabout and beyond into Tonbridge along the Pembury Road during the morning rush hour. There are many secondary schools and a FE college in a small area of Tonbridge (and close to CA1) which contribute considerably to the daily congestion, creating a danger to school children as drivers’ patience wears thin. This will be acerbated by the proposed new secondary school which will not be served by a railway but will necessitate most children arriving and leaving by road.

Tonbridge station is one of the busiest in the South East and will not be able to cope with a large increase in passenger numbers or station car parking. It is unrealistic to suggest that residents of Tudeley will travel to Tunbridge Wells or Paddock Wood stations for their daily commute or that large numbers will choose to cycle to their destination. Trains are already at capacity with passengers having to stand as a result of developments which have already taken place further down the line. This will also affect passengers in Sevenoaks and Orpington and is unsustainable.

Pollution and air quality – The increase in traffic, congestion and idling car engines will increase the presence of harmful emissions and damage air quality at a time when TWBC should be responding constructively to the climate emergency not adding to it. Leading scientists are promoting the planting of trees to remove harmful greenhouse gases from the atmosphere and yet TWBC is promoting the removal of trees and ancient woodland.

Dark Skies – The Local Plan is promoting “dark skies” in rural areas stating, “Dark skies are places where you can look at the night sky without light pollution”. The Parish of Capel is currently such a place. It goes on to say “Light pollution can harm the character of an area and cause problems for wildlife especially nocturnal animals”. It is difficult to imagine anything more at odds with this aim than constructing a new town on a site which currently, because of its topography, has vast open night skies and is teaming with nocturnal wildlife including owls and bats. Policy CA1 conflicts with the dark skies objective.

Biodiversity and Wellbing – The site of CA1 is currently occupied by woodland (some of it ancient), hedgerows, meadows, farmland and is home to threatened species. Wildlife visitors to my garden would be under serious threat from the proposal including finches, nuthatch, thrush, tits, woodpeckers, kingfisher, newts and hedgehogs. The proposals would wipe out acres of land currently enjoyed by residents, visitors and wildlife. I see daily the very many walkers who use our footpaths and appreciate the fresh air and wildlife of this Parish. The restorative nature of our beautiful landscape is so vital to the mental and physical wellbeing of people taking a break from the stresses of daily life. At a time when the UK is redefining its place in the world, we should be supporting not destroying our high quality agricultural land which can provide sustenance and support wellbeing. CA1 is not environmentally sustainable.

Tourism and Heritage – Our parish has a rich history and attracts very many tourists. They visit All Saints Church, with its unique Chagall windows; and enjoy our distinctive, beautiful landscape, peppered with oasthouses reflecting a bygone age of hop picking by Londoners who would take up temporary residence in Capel. Tourists also appreciate the open views across the High Weald to Hadlow Tower. As the All Saints visitors’ book will testify, coach parties and individuals from around the world are frequent visitors to the church. Its setting is as important as its windows and should be protected. Having installed the one window Chagall was commissioned to create, he declared that he would replace all the windows, such was the beauty and perfection of the setting for his art. It is a great shame and an embarrassment that TWBC are blind and profligate with the beauty that was so obvious to Chagall and to the many visitors to our parish. The Plan refers to its requirement to conserve heritage sites – CA1 is contrary to this requirement.

Greenbelt – The separation between settlements that the greenbelt provides has been protected for generations. Once it has been built on, it will be gone for ever. Therefore, the Government advises that Greenbelt land should only be developed in exceptional circumstances. No such exception has been evidenced for CA1. This large swathe of prime agricultural land and woodland should continue to enjoy the protection provided by the Greenbelt policy. CA1 together with PW1 will vastly reduce the separation between settlements and eventually result in a coalescence of development creating a conurbation from Tonbridge to Paddock Wood. In addition, large parts of this land are within the Medway Floodplain and will increase the risks of flooding to the nearby villages of Golden Green, East Peckham and the town of Tonbridge, as well as further afield in Yalding which already has a history of major flooding. I understand that the housing need calculated by the Government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan.

Housing – To suggest that Tudeley new town will meet the local need for affordable homes is disingenuous. New housing estates in the area are frequently marketed in London, with offers of season tickets thrown in to attract buyers when properties are difficult to sell. It appears that Capel is being sacrificed to help deal with the wider issue of Londoners being priced out of the Capital. The railway bisecting Tudeley will provide no benefit to residents but will lead to a divided community. This is contrary to the unified new settlement being promoted and required by garden settlement principles. The number of homes the parish of Capel is expected to provide is completely disproportionate to the rest of the Borough.

I understand that TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government 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. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the Borough is slowing, making this proposed approach honest and relevant. The Plan refers to Tudeley securing a long-term option for the Borough to deliver the needs of future generations. This statement indicates an intention to add more and more housing to this “garden settlement”. TWBC is using Capel to dump their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the Borough. The developments in Tudeley and East Capel are unsustainable and place huge pressure on Tonbridge.

Brownfield Sites – The Plan does not provide adequate evidence of brownfield sites either being sought or considered during the preparation process. Bringing back into use some of the many derelict sites around the Borough would have been a far more sustainable approach to meeting the housing need, in locations where infrastructure already exists. Instead the Council has struck a financially expedient deal with one landowner by dumping the majority of its new housing in one Parish with little regard to the consequences.

Local Plan Consultation Process - The plan preparation process did not include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. Therefore, the largest housing area in the Plan did not go through most of the Plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment or Biodiversity Assessment. Therefore, the draft Local Plan is not fit for public consultation.

The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they did not know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. Therefore, the plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the Borough.

DLP_7522

Sarah Parrish

Object

Policy AL/CA 2 (Land east of Tonbridge, west of Tudeley) p.164

Will the TWBC cooperate with Tonbridge and Malling Borough Council and cancell the Tudeley Garden Village and AL/CA2 if T&MBC object to the TWBC Local Plan?

DLP_7540

Colin Clarke

Object

In the words of Tom Tugendhat, MP for Tonbridge - This proposal would have the biggest impact on the residents of Tonbridge by sheer virtue of the fact that the allocation is on the very outskirts of Tonbridge.

South Tonbridge already has one of the highest concentrations of senior schools for a town of its size anywhere in the country.  This puts immense pressure on the local road, bus, and rail network as travel to school plans are increasingly difficult to manage. Pupils often have to travel long distances to schools, and it is right that KCC should have oversight of this. However as we have seen recently, with school expansion in Maidstone, even the slightest increase in a schools’ yearly roll, or a small change in catchment area can disrupt local bus services and bring gridlock to the area.

My concern is that a secondary school off Woodgate way in Tonbridge would make peak traffic time movements in Tonbridge unsustainable. The site is not within easy walking distance of Tonbridge station, nor on the most convenient bus routes in the town. Indeed as things stand, it is only services such as the 205 from Kings Hill which pass this location, and this only started this year. There is no doubt that this allocation would bring chaos to the already finely balanced (i.e. strained) public transport network in Tonbridge.

It is noticeable from the extremely detailed 544 page of the Draft Local Plan that there is absolutely no mention of the impact of this secondary school on Tonbridge. This gives me significant cause for concern and is a glaring omission from the draft local plan.

A new secondary school on this site would have such adverse impacts on the town of Tonbridge that I strongly doubt whether it would be feasible to deliver.

DLP_7596

Mrs Pollyanna Bishop and Mr Pierre

Object

We would like to raise our concerns and objections to the Tunbridge Wells Borough Council (TWBC) Draft Local Plan, Regulation 18 Consultation proposal to create new large scale residential developments in Paddock Wood, Tudeley and Tonbridge. As lifelong residents of East Peckham, within the neighboring Borough of Tonbridge and Malling (T&MBC), we are most concerned by the impact these proposed developments will have on our immediate daily lives and the borough as a whole. While we recognize the pressure the boroughs are under to create new ‘affordable’ housing, this does not appear to be a responsible approach to sustainable and long term successful ‘town planning’.

Our three children attend schools in Tonbridge and Tunbridge Wells and we rely on the local bus services which are appallingly stretched in recent years and the traffic congestion is also a huge daily problem locally at peak times of travel. We well understand the local schooling, transport and medical provision problems our area endures. The introduction of this incredibly sizeable increase of residences will rely, in the main part, on the infrastructure of Tonbridge and its neighboring villages, which are already overloaded and stretched. The roads (especially the B2017), train services, bus services and community facilities are already overwhelmed and incapable of managing the current population demands. We have yet to be convinced that there is coherent proof these proposals are agreeable with the T&MBC local draft plans for the years ahead. There does not appear to have been any consideration given to the locality that will be directly affected the most as these proposal sit at the very border and, indeed, over the border of the two boroughs.

We are also extremely concerned that large parts of the developments occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but we believe that flood risks will increase. Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding. Having experienced flooding and the more common occurrence of ‘flood risk’ in our village over the last 30 years, it seems hugely flawed to plan to build directly on the floodplain and the consideration of the immense ‘run off’ caused by these new areas is of paramount importance. These open fields will no longer exist to absorb the water and given the flooding issues currently being endured in the north of the country right now, SURELY this demonstrates the enormity of how critical the planning for flood risk is in the very first instance, before any other considerations. These considerations should not only extend to new developments, but the potentially devastating impact on our existing settlements and communities.

The plans for a ‘New Garden Town’ at Tudeley are all on greenbelt land. Creating so much housing in Capel Parish will require the destruction of agricultural land, woodland, hedgerows and meadows that should be protected. The landscape and wildlife will be threatened irreparably. It is very disappointing to learn that TWBC have sort to preserve their greenbelt and areas of outstanding natural beauty but cynically burden their neighboring borough with a huge development that sits at the extreme edge of their northern boundary. TWBC appear to be suggesting a ‘satellite town’ in Tonbridge with scant consideration for the onerous impact on their neighbours. There’s no doubt that the costs of the infrastructure required on the Tonbridge side of the boundary will financially burden T&MBC residents whilst TWBC will receive council tax from the residents in these new dwellings.

In the plan (in 4.40) there is reference 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 the intension is to add more and more housing to this “garden settlement” in each five year review of future Local Plans. This would suggest that TWBC want to fill Tudeley and East Capel with housing until they coalesce with Tonbridge to the West and Paddock Wood to the East. Ultimately, this creates a massive conurbation that will dwarf Tunbridge Wells town centre. TWBC is using Capel to dump their current and future housing needs on green field sites and meadows, polluting a rural area rather than spreading development across the borough on brownfield sites or placing the garden settlement in the middle of their borough to make it accessible from the north and south. The developments in Tudeley and East Capel are unsustainable and place huge pressure on Tonbridge.

Nationally there is government policy that demands new houses. We have borough councils that are desperately trying to meet these demands. Housing developers are businesses that are mainly interested in profit margins. These incongruous elements create a toxic chain that results in ill-advised schemes being forced on local communities that are struggling to manage with their current infrastructures. The plans and strategies for these developments within the borough of Tunbridge Wells make very little reference to the upgrading of the current infrastructure which falls in the Borough of Tonbridge and Malling. These areas will be MOST affected by these proposals. Surely it is the duty and responsibility of all involved in this decision process to address the current and future infrastructure needs for the surrounding area FIRST, before introducing 4,000 plus new homes, approximately 10,000 new residents and approximately 8,000 new vehicles to the area.

Will Tunbridge Wells Borough Council please be responsible and considerate when assessing a proposal of this scale and the impact on the local communities involved.