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Policy AL/CA 1: Tudeley Village


Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_69

The Access Group

General Observation

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

2. THE MAJOR CONCERNS

  • The Tudely Garden Village must have its own railway station irrespective of the cost, to reduce the inevitable congestion on the roads leading to Tonbridge & Paddock Wood stations which are not designed to cope with such a flow of traffic. Also to reduce the impact of car parking, as the bus services between both the aforementioned centres are poor in the area and would not be able to cope with large numbers of commuters on a daily basis providing a 15 minute service. These issues were raised by me at a previous Local Transport Forum, as a then academic question, as I considered Tudely the obvious site for such a Garden Village. Schools and GP & Dental surgery must also be imposed as conditions of such a development and they must be in place as part of the overall build, not as an afterthought. The existing facilities in Paddock Wood cannot cope with such a growing demand, I have been told by my members that currently patients often wait three weeks for an appointment with a GP.

DLP_326

Mark Daters

Object

I object to the development of Tudeley Village.

The Site is nearer Tonbridge than Tunbridge Wells, particularly to the west of the Site which is a different local authority.  We await responses from TMBC as TWBC must consult with neighbouring local authorities.

Purposes of Green Belt land include “to prevent neighbouring towns from merging into one another (Tonbridge to Paddock Wood based on the proposed development) and “to assist in safeguarding the countryside from encroachment” (surrounding Tudeley and Capel).  The proposed development does not consider these purposes.

Such a large scale and concentrated Green Belt development does not consider a further Green Belt purpose to “assist in urban regeneration, by encouraging the recycling of derelict and other urban land.  TWBCs original Plan identified multiple Sites spread across the Borough including urban Sites which are far more likely to not impact Green Belt land or impact on a marginal basis spread over multiple Sites.

Whilst the proposed development is within TWBC authority, it is the infrastructure and services including the station and supermarkets in Tonbridge which will be used by the new residents as this will be the local town.  Tonbridge High Street is already congested seven days a week demonstrating it is already at maximum traffic capacity.  It cannot manage any more.  The existing Tonbridge roads cannot be widened or developed to improve traffic flow which is why congestion has increased annually over many years.  There appears to be no plan in the Consultation Draft for a new station in Tudeley so residents who commute will use Tonbridge station which also allows a more frequent train service from the other train line serving Tunbridge Wells. Tonbridge will be the favoured commuter station over Paddock Wood or Tunbridge Wells each serviced by one train line compared with two at Tonbridge and a longer train journey costing more.

The closest Grammar Schools are in Tonbridge; Weald of Kent, Tonbridge Girls Grammar and The Judd.

The costs of infrastructure on the Tonbridge & Malling side of the local authority boundary will fall to Tonbridge & Malling residents whilst Tunbridge Wells will receive council tax from the residents in the new dwellings. If the B2017 from Tudeley to Woodgate Way at the border of Tonbridge were to be improved as part of the proposed development it would not solve and traffic issue but simply move traffic faster to Woodgate Way but result in the same congestion into Tonbridge. 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. There should be land separating Tonbridge and Tudeley. I understand the Medway floodplain covers parts of the proposed development.  Concreting over fields will increase the potential flood risk and widen the floodplain.  The increased potential for flooding will affect part of the proposed development or move the flooding further down the River Medway to areas such as Yalding. Climate change will increase the risks further in the future. I believe TWBC can challenge the Government housing targets locally since development of Green Belt land can only be made in “exceptional circumstances” which do not appear to have been met for many sites, particularly for the proposed secondary school on Sites 447 and 454.exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan. I cannot see any benefits fits of this proposed development.  It appears TWBC are opting for convenience in response to one landowner rather than seeking numerous smaller developments spread across TWBC requiring less significant infrastructure changes.  Tonbridge and TMBC rather than Tunbridge Wells and TWBC will bore the brunt of the resulting insufficient infrastructure, pollution from one concentrated and significant development in one location and permanently remove pleasant and healthy countryside and agricultural land. Therefore, based on the numerous reasons outlines above the plan is unsustainable..

DLP_636

Capel United Church

General Observation

Policy AL/CA1 and related, concerning Tudeley Village.

Comments follow on behalf of the Vicar and Churchwardens of All Saints' Church, Tudeley.  These comments deal only with specific issues relating directly to the church building and its surroundings: location, parking, access and security.

All Saints’ Church, Tudeley 

All Saints’ Church is a mediaeval parish church, lying within the ecclesiastical parish of Tudeley, Capel and Five Oak Green and in the civil parish of Capel.  It is in regular use for public worship.  What makes it extraordinary is that it houses stained glass windows designed by Marc Chagall, of great beauty and artistic significance, which attract visitors from around the world.

The Vicar and Churchwardens of Tudeley, Capel and Five Oak Green are responsible for the church and its churchyard. They are supported in this by Capel United Church (being a Local Ecumenical Partnership between the Church of England and the United Reformed Church) and by the Diocese of Rochester.

Matters of concern

  1. Location: The location of the church in any development would need to be carefully planned, so that the church setting relates well to its environs, rather than being cut off from a new centre of population.  Ideally, All Saints’ would be approached by an open precinct, providing a clear focus for the community.
  2. Parking: Effective ministry to our congregation and community, as well as the benefit to tourism and the local economy of welcoming visitors to view the Chagall windows or to attend concerts and other events, depends on the availability of sufficient parking for cars and coaches.  Two parking areas which are leased by the church from the Hadlow Estate appear to be included within the footprint of the garden village. There is also a risk of the church parking areas being pre-empted by others, should insufficient (or inconvenient) parking be provided within the development.  There should be careful consideration as to how suitable parking for the church will be maintained and protected.
  3. Access: At present, access to All Saints’ is along a shared private road, which is in an indifferent state of repair.  Should development take place, this may have to change.  Certainly, the existing access road cannot easily sustain even the present strain upon it.  It may well be that access to All Saints’ should be from a different direction, depending on whatever roads were developed for the future.  This should not adversely affect access.
  4. Security: The church is normally open (and unattended) during daylight hours. Its celebrated stained glass windows have no physical protection, which would diminish their visual impact.  It would be unfortunate if concerns over nuisance, noise, damage or insurance were to inhibit either of these circumstances. Moreover, the church would need to cover the cost of any security arrangements which would need to be put in place.

Rev Dr Jeremy Ive, Vicar
Mr Philip French, Churchwarden
Ms Celia Curling, Churchwarden 
24 October 2019

DLP_22

Darren white

Object

whyt here and not along the A21 corridor???

DLP_2922

Chris Gow

Object

Green Belt land should not be developed.

DLP_57

Thomas Weinberg

 

Comments on Section 5 Paragraph 5.60 (Allocation Policies) p.159

This site is unsuitable for a garden settlement because it has a main railway line running through the middle of it. No amount of crossings can join the garden settlement in to one settlement. It is two settlements divided by a railway line, neither of which satisfy garden settlement principles.

You state that this site is under single ownership. This appears to be the overriding factor in its selection as a site for a large (grotesque) development. The landowner has a very poor track record re maintaining leased properties and leasing land out for quarrying, abandoning it to become derelict, contaminated land. They are not suitable partners for masterplanning (regardless of the number and nature of agents they employ) and the subsequent development of the site. Nobody in this community trusts them. No-one has had any positive form of engagement with them since the development was disclosed. They appear to be evicting tenants to sell houses to pay their masterplanners and/or make way for link roads.

Development on the site will adversely affect flood risks in Tudeley and neighbouring Golden Green, East Peckham, Hadlow and Tonbridge. The River Medway is rising. The rapid increase in sea levels and other Climate Change factors have not been fully considered. The Five Oak Green flood risk will be reduced by damming the Alders Stream, not by building thousands of houses. This can be delivered and funded independently of the garden settlement.

The Biodiversity on this site is extraordinary. As you rightly note, it is also adjacent to a Biodiversity Opportunity Area and directly adjacent to AONB.

DLP_58

Thomas Weinberg

 

Comments on Policy AL/CA 1 (Tudeley Village) p.160

This policy refers to too many new dwellings. They are entirely unsustainable.

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 justification”. (Paragraph 194, NPPF)

In domestic planning applications, TWBC requires an assessment of the impact of the proposed development on all heritage assets within a kilometre. Applying its own metric to its own development proposals the following approximate numbers of heritage assets in, or within a kilometre of CA1 are; 2 Grade 1, 1 Grade 2* and 70 Grade 2 listed heritage assets. This is a high number of assets that should be protected.

Tudeley is particularly sensitive in terms of heritage around Tudeley Church, which is a Grade I listed building and the only church in the world with all its windows designed by Marc Chagall. Significant consideration needs to be given to the heritage and conservation impact of the development proposed in this area on the setting of this unique global heritage asset.

In addition, TWBC’s own Historic Environment Review (2018) states that “The historic character of the Low Weald is particularly vulnerable to poorly managed development at the urban fringe, especially around Paddock Wood and Five Oak Green”. This is of particular concern in relation to the development proposed in the Parish of Capel. I believe that the harm imposed by the Local Plan has not been adequately considered.

The new secondary school is in a dangerous place, with a railway line running through the site and it will add an unacceptably high level of traffic to/from Tonbridge.

The whole Tudeley Village site should be scrapped on the grounds of not being able to develop the secondary school due to safety and pollution issues.

The flood risk is bound to go up, regardless of mitigation/attenuation measures. It cannot be proven to be controlled or to go down, so the site should not be developed.

DLP_353

Charlotte Raleigh

Object

Strongly Object

Genuine long term quality low-cost housing cannot be provided via the short-term profiteering of developers or 'planning gain'. Where there is a housing need amongst local people, please think about providing secure low-cost tenancies in housing with proper infrastructure and real place-making that should either upgrade existing property or be built on sites that are NOT farmland or woodland. Please.

Please protect the UNIQUE KENT LANDSCAPE from over development. Do not destroy productive farmland or build on the flood plain. It is not necessary. Do not turn Kent into one big suburb.

You should resist any government policies that do not seek to rebalance the economy between the South East and the other regions. And do not be persuaded by those whose only motive is to gain from high property prices. The Borough Council should be seeking to do what is best for the inhabitants of the Borough. And I would hazard a guess that most people in the area feel the same way and many help the Council stand up to Government if you asked us.

I very much hope that you will not adopt this policy and prove that the Council is responsive to the opinion of the people whose lives will be directly affected by your choices.

I should also like to add my hope that this consultation is a meaningful exercise to canvass opinion which you will take into account. Past experience makes us worry that once a proposal reaches the "Consultation" stage it is often already too late to stop unwise and unwanted development. I hope my cynicism in the matter proves to be unwarranted because my concern for the future of this area is heartfelt and genuine.

DLP_95

Clive and Margaret Andrews

Object

SAVECAPEL

1) Enormity of ‘Masterplan’ Too large to put into operation on all levels:-

i) Flooding  prevention and Sewerage.

ii) The very building of thousands of properties set against biodiversity and ecology for the area.

iii)  Adding to Climate Change in totally the wrong way.

2) Building in an area of green belt and outstanding natural beauty on such a massive scale should not be allowed, ever.

3)  A complete u-turn by the Government and TWBC on building in the areas mentioned above.

4)  The plan is too enormous and unbelievable, without  taking very, very seriously dealing and putting into practice, flooding, construction of intended new roads, all amenities including schools, Community and  Health Centres, pharmacies and, professional people to operate these facilities.

5)  The proposed  ‘Tudeley Village’ is a myth and may as well be built in the sky!

6)  Not respecting the very valuable and sacred Tudeley Church which will eventually be surrounded by properties and roads.

7)  Who are the ‘people’ that need the housing?  Are they local or outsiders?

8)  How are the thousands more people to be accommodated on the already congested roads, local transport (which is minimal in Five Oak Green) trains, already via Paddock Wood, Tonbridge and Sevenoaks at full capacity?

When are the leaders of the Government who are proposing all these building plans (not only in Kent, but over the whole country) going to visit some, or all, of these areas to see what catastrophe is being planned in the name of ‘progress’? This should not be about money regenerated and made.  It is peoples’ lives being greatly undermined.

The proposed costs suggested by TWBC amount to approximately £110m.  Where is this money to come from?

We have lived in Five Oak Green for over thirty years and have walked many of the paths through the areas of land proposed for this monstrous scheme.  Walking through a built up area is not going to be good for peoples health and well-being.

DLP_139

Gregg Newman

 

Comments on Section 5 Paragraph 5.60 (Allocation Policies) p.159

Again I quote because I can add nothing to this except the following in addition. Please see my comments above about Hadlow Estate actively removing SaveCapel.com posters from the outside of our property which neighbours our own!!

QUOTE

This site is unsuitable for a garden settlement because it has a main railway line running through the middle of it. No amount of crossings can join the garden settlement in to one settlement. It is two settlements divided by a railway line, neither of which satisfy garden settlement principles.

You state that this site is under single ownership. This appears to be the overriding factor in its selection as a site for a large (grotesque) development. The landowner has a very poor track record re maintaining leased properties and leasing land out for quarrying, abandoning it to become derelict, contaminated land. They are not suitable partners for masterplanning (regardless of the number and nature of agents they employ) and the subsequent development of the site. Nobody in this community trusts them. No-one has had any positive form of engagement with them since the development was disclosed. They appear to be evicting tenants to sell houses to pay their masterplanners and/or make way for link roads.

Development on the site will adversely affect flood risks in Tudeley and neighbouring Golden Green, East Peckham, Hadlow and Tonbridge. The River Medway is rising. The rapid increase in sea levels and other Climate Change factors have not been fully considered. The Five Oak Green flood risk will be reduced by damming the Alders Stream, not by building thousands of houses. This can be delivered and funded independently of the garden settlement, as well you know.

The Biodiversity on this site is extraordinary. As you rightly note, it is also adjacent to a Biodiversity Opportunity Area and directly adjacent to AONB.

UNQUOTE

DLP_140

Gregg Newman

 

Comments on Policy AL/CA 1 (Tudeley Village) p.160 

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 justification”. (Paragraph 194, NPPF)

For reasons set out above and without rehearsing these again, there is simply no clear and convincing justification. Full stop!

DLP_8199

Mrs Suzi Rich

Object

I strongly object to the entirety of Policy AL/CA 1 because creating a garden settlement at Tudeley of 2,800 dwellings will cause immense harm to existing residents of the Parish of Capel, which currently contains just 950 dwellings. The harm that this Policy will cause is set out under sub-headings below for ease of reference

Lack of sustainable public transport

Network Rail has confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. People living in the new settlement at Tudeley will have no choice but to use their cars to drive to either Paddock Wood Station or Tonbridge Station to commute to work. Neither stations has capacity for the additional cars to park and the increased numbers of passengers on already packed commuter trains travelling through both stations will be unsustainable. Due to its poor location, most people living in the new settlement at Tudeley will drive privately owned cars, despite initiatives to encourage bus and bicycle use.

Impact on traffic / highways

The result of the lack of sustainable public transport for a new settlement of this size will be a significant increase in traffic. The proposals for Capel will result in approximately 10,000 additional cars using local roads which are totally unsuitable, including the B2017, Hartlake Road and Alders Road.

Alders Road is already used as a ‘rat run’ for motorists trying to avoid traffic congestion on the A21 and the absurd proposed ‘mitigation measure’ for a link road (or Five Oak Green Bypass) from the new settlement to the new Colts Hill Bypass will do nothing to ease the issue. The ‘mitigation measure’ proposals for the Colts Hill Bypass are also ill thought out and based on evidence which is almost 40 years old. The transport evidence base even suggests that a roundabout should be located to allow traffic to leave and join the Colts Hill Bypass at Alders Road, a single track road with weight limits at both ends and unsuitable for HGVs.

Air Quality

The new settlement will severely impact upon air quality and the policies in the local plan are incongruent with TWBC’s own Air Quality Action Plan for the period from 2018 – 2023 , which was adopted following TWBC Cabinet Meeting on Thursday 7 March 2019.

That document states “We also recognise the impact of particulate matter PM2.5 on health. Whilst the levels in the borough do not exceed those set for this pollutant, the measures proposed in this plan will also help deliver improvements with regards to this issue.”

Increased flood risk

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 throughout Kent. Plan for alleviation will simply move the location of flooding from one group of dwellings to another, namely, the dwellings along Alders Road

Landscape / environmental impact

There will be an increase in air, light and noise pollution that will create a visual scar across the landscape. 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.

Heritage impact

The setting of historic assets like All Saint’s Church in Tudeley, with its world famous Chagall windows, and the ancient Church of St Thomas a Becket in Capel, with its 12th century wall paintings, will be permanently impaired.

Unsuitability of site as a garden settlement

The garden settlement at Tudeley will be divided by a railway line that has very narrow, weak Draft Local Plan (Regulation 18) Response Form 20 September to 01 November 2019 12 crossings. Even if larger crossings can be added, the settlement will still be two distinct halves and as a result it will never satisfy garden settlement principles.

Housing need

I believe that housing need calculated using the government’s standard methodology can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. TWBC should use this argument to remove the garden settlement at Tudeley from this plan.

Lack of proper assessment

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.

This Policy and this strategic site should be removed from the DLP as it is in direct conflict with multiple objectives, policies and strategies outlined in the DLP

Please see my comments under COMMENT BOX 2 in relation to the Development Strategy and Strategic Policies; STR 1, STR 2, STR 3, STR 4, STR 5, STR 6; STR/CA 1 The Strategy for Capel Parish and AL/CA 1, AL/CA 2 AL/CA 3; STR/PW 1 The Strategy for Paddock Wood and AL/PW 1;

Policies EN 2, EN 23, EN 28, TP 1 and TP 6; COMMENT BOX 3 in relation to the Vision; COMMENT BOX 4 in relation to the Key Diagram and in COMMENT BOX 8 in relation to the Distribution of Development Topic Paper, Green Belt Study, Infrastructure Delivery Plan and SWECO Local Plan Transport Evidence Base.

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

DLP_8325

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 1 – Tudeley Village

27. I object to the policy for Tudeley Village. Specifically:

a. The site reference is incorrectly stated as 438, whereas it should read 448.

b. At point 3 it is logically impossible for the “Council and the landowner/developer jointly to lead the masterplan approach” – just who is in charge?

c. Point 10 calls for “improvements to pedestrian/cycle links across the railway”, without testing the deliverability of what is a critical criterion to the success of a unified settlement. Further work is required to achieve a mature and credible Reg 18 consultation

d. Point 10 also calls for the “provision of longer distance cycle links to land at Capel and Paddock, Tonbridge, and villages surrounding Paddock Wood (leisure and utility)”, despite the fact that efforts to establish the routing of such links in the past has proven very problematic. Further work is required to achieve a mature and credible Reg 18 consultation

e. Point 14 requires any development to “not exacerbate flooding elsewhere in the vicinity” yet any development (notwithstanding the requirement for SuDS) will have a direct runoff effect downstream – as shown on the following map showing the historic flood map of the area, demonstrating that this proposed policy is unsound (as indeed does the fact that a proportion of site 448 appears to lie within the flood risk area itself)

f. The site runs adjacent to the AONB and yet the SHELAA Site Assessment Sheet for site 448 fails to identify this as a constraint on development, despite recognition in STR/CA 1 that “Sites outside the AONB but . . . close to the boundary of the designated AONB landscape, will have similar characteristics and are likely to contribute to the setting of the designated landscape” (point 13). The map below demonstrates the proximity of the AONB to the proposed site 448, and therefore the omission of this significant constraint on development, which renders a significant proportion of site 448 unsuitable for development purposes.

28. I support the specific provisions made to respect the setting of heritage assets, especially All Saints Church and the view of Hadlow Tower. I note with disappointment that the exceptional nature of the church was not mentioned in the Historic Environment Review (Jan 2018), notably it being unique in having a complete set of stained glass windows designed by the world famous artist Marc Chagall, and having more Chagall windows than Winchester cathedral.

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_8070

RSPB

General Observation

The Tunbridge Wells Borough Council Draft Local Plan includes the provision for 2,500 to 2,800 dwellings (Tudeley Village) located 250m from Tudeley Woods reserve which the RSPB manage. As an adjacent land manager and conservation body, we are seriously concerned with the potential impacts to Tudeley Woods from this proposed settlement.

From the southern section of the proposed Tudeley Village settlement which borders Crockhurst Street there are three Public Rights of Way footpaths affording easy access to Tudeley Woods from the proposed settlement. There is a growing evidence base of recreational disturbance impacts on sensitive species and habitats. The likely increased recreational use of these footpaths and therefore Tudeley Woods by new residents from the proposed settlement could have a significant impact upon a wide variety of species sensitive to disturbance within Tudeley Woods. This includes, but is not limited to; ground nesting birds such as woodlark (Lullula arborea) and nightjar (Caprimulgus europaeus), and species with an amber or red UK conservation status such as lesser spotted woodpecker (Dendrocopos minor), marsh tit (Poecile palustris), spotted flycatcher (Muscicapa striata), and willow warbler (Phylloscopus trochilus).

Records held by the RSPB can be obtained via our data request service through the RSPB website here: https://www.rspb.org.uk/our-work/conservation/conservation-and-sustainability/mapping-and-gis/

Impact pathways potentially leading to effects on the above nature conservation interests include, but are not limited to:

  • Recreational disturbance
  • Increased pressure from wild predators such as foxes
  • Domestic cat predation
  • Artificial lighting
  • Anti-social behaviours such as littering and dog fouling

Further to our concerns regarding Tudeley Woods reserve, the RSPB would like to take the opportunity to highlight the importance of planning policies and decisions including local plans contributing to and enhancing the natural and local environment, as advised within the National Planning Policy Framework (NPPF, 2019). Such large-scale developments should seek to identify and pursue opportunities for securing measurable net gains for biodiversity.

DLP_8163

Myriam Ruelle

Object

Policy AL/CA 1 – p 160:  Strongly object.

The project at Tudeley village is completely unsustainable.  It must be abandoned.  This project has grave implication for the environment and biodiversity.

DLP_8283

Laurie Dunkin Wedd

Object

[TWBC: for images, maps and charts, see full representation].

The Right Homes

In The Right Places?

A response to TWBC’s Draft Local Plan

February 2017:

The government calls for ‘the right homes in the right places’.

[Fixing our broken housing market. A housing white paper]

July 2019:

TWBC responds with the wrong homes in the wrong places.

[Tunbridge Wells Borough Draft Local Plan Regulation 18 Consultation Draft]

The Right Homes In The Right Places?

Contents:

1. Personal Statement

2. The Right Homes?

National guidance not observed by TWBC. Why building new homes willy-nilly will not help solve the housing crisis. Why building the right type of homes is crucial. How affordable and social housing are desperately needed. Why the draft Local Plan fails to deliver.

i) What TWBC is required to do

ii) There’s no housing shortage - there’s a crisis

iii) So where have all the homes gone?

a) Some have several while others have none

b) Buy to let reduces the market

c) The top of the market sequestered

iv) How should Tunbridge Wells respond?

v) Affordability - what is it?

3. In the right places?

Why building on Green Belt is counter-productive. How building on watershed above the flood- prone Medway endangers downstream communities. The danger to heritage assets. Why the draft Plan’s transport strategy is unachievable.

i) Green Belt

ii) Flooding

iii) Heritage assets

iv) Transport

4. Climate change and the environment

Even UK Parliament accepts climate crisis. New research supersedes TWBC plans.

5. Can TWBC deliver?

Recent and not-so-recent projects suggest a lack of competence. Neighbouring councils not apprised. TWBC claims a firm evidence base not possible in the time.

i) A history of failure

ii) A failure to consult

iii) Evidence base impossible in the time

iv) Non-compliance with NPPF

6. Appendices

1. Personal statement

My beloved mum died just over a year ago: we buried her at All Saints’ Tudeley.

She loved All Saints’ Tudeley, and served for some years as secretary of the PCC. She was passionate about the countryside, and was a lifelong member of CPRE. We thought it was so appropriate that from her grave one could see the wonderful view across the Medway valley:

It had given us great comfort to know that she was to be buried in sight of this beautiful rural view, one of our favourites in Kent. My wife wishes to be buried at Tudeley, and as a local, born and bred in Kent, it was my hope to be buried there too.

So you can imagine our distress when we saw the plans for the proposed Tudeley Village. It was devastating to think that there might be a new housing estate within a few yards of our graves. It is hard to see how this will ‘respect the setting of... All Saints Church’.

I love to hear the skylarks singing from the field to the south of the church; how sad if they must go.

[TWBC: for image see full representation].


The ground has now settled enough for a headstone, and we had chosen the inscription from Psalm 121: ‘I will lift up mine eyes unto the hills’. That inscription is looking bitterly ironic now - if it is to look like this:

[TWBC: for image see full representation].

That’s my personal sadness.

But there are also innumerable reasoned arguments against this project. Here are some of them.


2. The Right Homes?

i) What TWBC is required to do

“The Plan is required to meet the full assessed need within the borough for market and affordable housing of 678 per annum” [Draft Local Plan 2.31 page 27]

This sounds incontrovertible, doesn’t it?

But it simply isn’t true.

Here is the latest government advice on the subject:

“The National Planning Policy Framework is clear that, to enable effective planning of new homes, local planning authorities should start the plan-making process with a clear understanding of the number of new homes that they need in their area.

While this is an essential first step, it is not the only stage in the process. Local planning authorities then need to determine whether there are any environmental designations or other physical or policy constraints which prevent them from meeting this housing need.

These include, but are not limited to, Ancient Woodland, the Green Belt, Areas of Outstanding Natural Beauty and Sites of Special Scientific Interest.

They also need to engage with other authorities – through the duty to co-operate – to determine how any need that cannot be accommodated will be redistributed over a wider area. This means that the level of housing set out in a plan may be lower or higher than the local housing need.”

[www.gov.uk/government/publications/fixing-our-broken-housing-market]

So it is clear that:

  • TWBC must balance housing need with environmental considerations
  • TWBC cannot determine local housing need until they have consulted other authorities

Neither of these conditions has been met. TWBC’s draft Local Plan has not followed NPPF guidelines and is therefore unsound in general and in detail.

The following pages demonstrate how far TWBC’s plan is from meeting these - and other - conditions.

* There is NO housing shortage! (But there IS a crisis.)

The UK has 28.1 million residences (ONS 2014) and 27.6m households (ONS 2018)

* The crisis is a shortage of AFFORDABLE HOUSING

Average UK home costs eight times average earnings (Conservative Party Conference 2017)

* Tunbridge Wells has a very poor record of provision of AFFORDABLE HOUSING

1,705 needed, just 580 provided in 2012-2017 (W Kent Housing & Homelessness Strategy)

* There IS a problem of distribution

1.5m people own multiple homes (ONS) while others have none at all

* There IS a problem of inequality

UK inequality is second worst in Europe (OECD Social and Welfare Statistics 2017)

* There IS a problem of money laundering and tax evasion

UK property market is particularly attractive (draft Registration of Overseas Entities Bill 2018)

* The Tunbridge Wells Borough Draft Local Plan will address NONE of these problems

Green Belt provides executive housing, not affordable homes (CPRE Oct2019)

* Instead the Tunbridge Wells Borough draft Local Plan will create a ghetto for the wealthy

Average house prices: SE England = £383,422, Tudeley = £715,000 [Zoopla]

i) There’s no housing shortage - there’s a crisis

We have all heard that we are short of millions of homes, and that we must build hundreds of thousands of new ones a year to address the situation.

TWBC’s draft Local Plan appears to agree:

“The rising household numbers, coupled with an ageing population, mean that the Council will continue to need to provide a mix of housing types and sizes, including specialist forms of housing. This presents a challenge for the new Local Plan, as it will need to facilitate the delivery of affordable housing... [Draft Local Plan, section, 2.30 p27]

Whilst it is well-known to almost everyone, it’s worth asking if this housing shortage does, in fact, exist?

It does not.

So says Ann Pettifor, Director of Policy Research in Macroeconomics, Fellow of the New Economics Foundation, and author of The Case for the Green New Deal.


And the statistics back up this view:

“In 2014, there were 28 million dwellings in the UK, but only a predicted 27.7 million households in 2016. As the director of consulting at Oxford Economics, Ian Mulheirn, highlights, London’s number of dwellings grew faster than the number of households between 2001 and 2015.” [www.theguardian.com/commentisfree/2018/jan/27/building-homes-britain-housing-crisis]

The Office of National Statistics confirms it:

[TWBC: for image see full representation].

[https://www.ons.gov.uk/peoplepopulationandcommunity/birthsdeathsandmarriages/families/b ulletins/familiesandhouseholds/2018

https://www.ons.gov.uk/peoplepopulationandcommunity/housing/articles/ukperspectives2016h ousingandhomeownershipintheuk/2016-05-25]

ii) So where have all the homes gone?

And yet, there is certainly a housing crisis, characterised by increasing homelessness and a shortage of homes for first-time buyers, making it impossible for our young people to get onto the housing ladder.

According to Theresa May addressing the Conservative Party Conference in 2017, the average UK home cost eight times average earnings; mortages are limited to 4.5 times salary.

Where does the problem lie? How can be it that we have more homes than families, and yet still not enough homes for everyone?

a) Some have several while others have none

First of all, some people have several houses, while others have none.

“At the time of the 2011 Census, 1,570,228 usual residents in England and Wales (2.8 per cent of the usual resident population) reported having a second address in another local authority in England and Wales, that they used for 30 days or more each year”. [www.ons.gov.uk/peoplepopulationandcommunity/housing/bulletins/2011censusnumberofpeopl ewithsecondaddressesinlocalauthoritiesinenglandandwales/2012-10-22]

b) Buy to let reduces the market

Second, an increasing number of property owners own homes that they do not live in.

In recent years, buy-to-let has grown exponentially, removing homes from the sale market. Between 1999 and 2015, lenders advanced 1.7 million loans for buy-to-let houses, according to the Council of Mortgage Lenders. This trend was especially marked in the south east, as the chart shows.

[TWBC: for image see full representation].

[Council of Mortgage Lenders cml.org.uk]

That’s 1.7 million homes removed from the market - fully 6% of the total. Their owners are wealthy enough to own two or more houses, and they rent the spare ones out, at a profit, to people who cannot afford to buy a house.

So those who can afford to own more than one property make an income from the rent paid by people who can’t afford to buy even one.

c) The top of the market sequestered

Thirdly, property at the top of the market is made unavailable through tax avoidance and money laundering.

The National Crime Agency suggests that “the scale of money laundering impacting the UK annually is in the hundreds of billions of pounds”.

[www.nationalcrimeagency.gov.uk/what-we-do/crime-threats/money-laundering-and-terrorist- financing]

“£180 million worth of property in the UK has been brought under criminal investigation as the suspected proceeds of corruption since 2004”, said our local MP and then Business Secretary Greg Clark, introducing the government’s plan for a Register of Overseas Entities. [www.gov.uk/government/news/world-first-register-to-crack-down-on-criminals-laundering- dirty-money-through-uk-property-market-to-go-live-by-early-2021]

In 2015 the London Mayor’s office reported that 36,342 London properties were held by offshore haven companies. Not even the Land Registry knows who owns these homes. [www.london.gov.uk/questions/2015/1366]

According to the Standard, “Land Registry figures also show that in just one deal signed off by Boris Johnson in 2011, at Riverlight Quay in the Nine Elms regeneration area, 15 per cent of the homes sold so far have been bought by foreign firms.” [www.standard.co.uk/news/london/revealed-how-foreign-buyers-have-bought-100bn-of-london- property-in-six-years-a3095936.html]

Almost one in ten (9.3 per cent) properties in the borough of Westminster were owned in 2016 by offshore companies, say Transparency International. [www.independent.co.uk/news/uk/crime/the-uk-is-a-global-corruption-centre-campaigners- claim-a7058126.html]

Is this a London thing, entirely irrelevant to Tunbridge Wells?

Not at all. The UK total is certainly much more. In 2015, Private Eye’s research linked more than 100,000 land title register entries to specific addresses around the country.

And it’s not just someone else’s problem: two-thirds of the purchases were made by companies registered in just four British tax havens - Jersey, Guernsey, the Isle of Man and the British Virgin Islands.

[www.private-eye.co.uk/registry]

OECD figures show that UK incomes are already the most unequal in Europe, save only for Lithuania. The people at the bottom of the housing ladder have no hope whatever of buying a home, however many we build.

[TWBC: for image see full representation].

Some people own many homes, whilst other people have none. It’s a problem not of housing shortage but of inequality, and as Pettifor says, you can't build your way out of that.

We will not address the gap between rich and poor by allowing already wealthy landowners and property developers to submerge Tudeley under concrete.

iii) How should Tunbridge Wells respond?

It is obvious that these are structural inadequacies, quite out of the power of TWBC to affect, and more suitably addressed at national and international level.

But TWBC cannot just carry on building executive homes on Green Belt as if these issues did not exist.

It is crucial that TWBC plays its part. It must keep up to date with recent analysis, it must deal with the problems as best it can, and if necessary it must respond to government that the portrayed housing demand is inaccurate, and the imposed solution (just build more houses) unworkable. Sevenoaks’ response to government has been imaginative, though controversial.

Have TWBC taken any account of any of these meta-problems? Apparently not: it seems they have swallowed whole and unquestioningly the view that any new houses, built anywhere, are a good thing. TWBC’s response has been merely supine.

And yet the only people who will benefit from Tudeley New Town will be the property developers and the land-owner - whose own assets may already be offshored to Ireland for tax.

What kind of property will actually help to counter all these threats? An estate of Persimmon Homes, Dandara and Berkeley homes is not the solution. Nor is a luxury Poundbury development, commanding prices one third higher than those around it.

What is the local situation in Tunbridge Wells, and how should TWBC respond?

Answering a 2017 Freedom of Information Request by Chris Gerry, TWBC stated that there were in 2017 just 20 rough sleepers in Tunbridge Wells. [www.whatdotheyknow.com/request/information_on_rough_sleepers_in FOI F06396]

And on March 31 2016, there were 994 households on the borough council's housing register, of whom 430 needed one-bedroom accommodation, and 363 needed two-bedroom. [West Kent Housing and Homelessness Strategy]

TWBC bases its plan on national and local housing need, using Central Government’s 2014 household projections data [TWBC Housing Supply and Trajectory Topic Paper, p1]. This data is five years out of date, and has been superseded by more recent - and much lower - projections.

Only on 12 September 2019, Housing Minister Esther McVey MP announced a crackdown on developments on the nation’s Green Belt, saying:

“Once the Green Belt is built on it’s often gone for good: that’s why we are determined to protect it. The public have told us loud and clear they want it kept for future generations to enjoy”.

[Ministry of Housing, Communities & Local Government, 12 September 2019]

Perhaps TWBC’s aim is to provide homes for social rent?

These would certainly be the only type of homes that would be immune to the inflationary effect of oligarchs, investment funds and offshore trusts. They would not contribute to house inflation. And they would actually begin to tackle TWBC’s local housing need. And there is good evidence that council houses are increasingly being seen as the local solution.

After all there have been famous recent successes such as Norwich, winner of the 2019 RIBA Stirling Prize for its Goldsmith Street development, or the Bourne Estate in Holborn.

[TWBC: for image see full representation].

[Council housing: it's back, it's booming and this time it's beautiful - Oliver Wainwright, Guardian, 20 June 2019]

And mayor of London Sadiq Khan has negotiated a £1bn fund from central government to build 11,000 new council homes over the next four years, set explicitly at social rent levels. [https://governmentbusiness.co.uk/news/24102018/%C2%A31bn-plan-build-11000-new-london- council-homes]

Perhaps TWBC has something similar in mind?

But the phrases ‘council house’ and ‘council housing’ are entirely absent from the draft local plan. Nor does the term ‘housing association’ appear. The words ‘social housing’ appear only as a definition on page 529. In fact, TWBC seems to have entirely overlooked a number of modern trends in housebuilding.

Whatever the reason, Tunbridge Wells BC is clearly not about to embark on on a major programme of council house building.

So the focus is firmly on affordability: in its West Kent Housing and Homelessness Strategy, TWBC speaks almost exclusively about affordable housing.

v) Affordability - what is it?

[TWBC: for image see full representation].

[www.tunbridgewells.gov.uk/residents/housing/affordable-housing/west-kent-joint-housing- and-homelessness-strategy]

The draft plan is similarly ambitious for affordable homes. This may be a panic reaction to such unfavourable headlines as ‘The borough is falling woefully behind… in 2013-14 just 36 affordable homes were delivered…’

[www.kentlive.news/news/kent-news/affordable-housing-hard-come-tunbridge-492345]

But no numbers are given. And what is meant by ‘affordable’? The national planning policy definition is homes that cost 20% below the market rate or less.

[NPPF Revised July 2018, Annex 2]

The average house price in Tudeley is £715,000. [www.zoopla.co.uk/house-prices/tudeley]

By the NPPF definition, then, an ‘affordable’ home would cost up to £572,000.

Who will buy an ‘affordable’ home in Tudeley?

The average house price in Tudeley is £715,000. [www.zoopla.co.uk/house-prices/tudeley/]

By the NPPF definition, an ‘affordable’ home would cost £572,000.

According to Halifax, the average deposit put down by those buying their first home in the first half of 2018 was 16%.

[http://static.halifax.co.uk/assets/pdf/mortgages/pdf/halifax-first-time%20buyer%20review-13- january-2017-housing-release.pdf]

16% of £572,000 is £91,500, leaving a balance of £481,000; using the standard loan-to-income ratio of four-and-a-half times income, we can see that this ‘affordable’ home will only be available to those with an income in excess of £107,000 pa.

With a £91,500 deposit, a Halifax tracker mortgage over 35 years for the balance of £481,000 [www.moneysavingexpert.com], will have monthly repayments of £1,928 for 26 months, and then £2,539 for 22 years and 10 months - or £30,468 per year.

The average salary for a registered nurse in the UK is £24,664 [www.payscale.com]. The national average salary for teachers is £30,097. [www.glassdoor.co.uk]

Perhaps the new homes will be priced lower than average house prices in Tudeley? That’s not what has happened in Poundbury, on which the new development is being modelled.

Poundbury homes are now 27% more expensive than those in Dorchester, just walking distance away. [www.rightmove.co.uk/house-prices/Dorchester.html]

[TWBC: for image see full representation].

If that happened in Tudeley, the new homes would not cost £715,000, but a whopping £908,000.

In fairness, however, maybe we should compare the new housing not with Tudeley’s luxurious homes, but with those in less-eligible Five Oak Green nearby. The average house price paid there is a mere £512,500 [www.zoopla.co.uk] - though applying the Poundbury/Dorchester factor would take that to £650,000.

These prices are still not affordable for our teachers and nurses.

And there won’t be many of such houses, either. Building on Green Belt land turns out not to produce many affordable homes: located in beautiful rural settings, the houses tend to be overwhelmingly 'executive' (ie expensive) houses.

In fact, ‘affordable’ homes make up just 13% of those built on land that was previously Green Belt. [CPRE Report 'Space to Breathe' October 2019]

So of our 2,800 Tudeley homes, 2,436 (87%) will be at full price - something close to a million pounds. Of the whole estate of 2,800, just 364 will be at <80% of full price - probably not less than £650,000.

So 364 ‘affordable’ homes at £650,000? This is still a long way from the 1,200+ needed as identified by TWBC’s West Kent Housing & Homelessness Strategy.

If the objective is to generate affordable housing in our area, this seems an oddly inefficient way to go about it.

3. In The Right Places?

i) Green Belt:

TWBC Development Strategy:

“Prevent urban sprawl by keeping land permanently open”

“The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open to maintain the character of the Green Belt. Once established, Green Belt boundaries should only be altered in exceptional circumstances and should be fully evidenced and justified, through the preparation or updating of a Local Plan.”

[TWBC draft Local Plan 4.48]

TWBC’s own analysis of Green Belt of July 2017 identified five purposes:

  • Purpose 1: Check the unrestricted sprawl of large built-up areas;
  • Purpose 2: Prevent neighbouring towns from merging;
  • Purpose 3: Assist in safeguarding the countryside from encroachment;
  • Purpose 4: Preserve the setting and special character of historic towns; and
  • Purpose 5: Assist in urban regeneration by encouraging the recycling of derelict and other urban land

    [Tunbridge Wells Green Belt Study, July 2017, Stage Two, section 1.2]

The development proposed would appear to fail at least on the first four of these counts.

TWBC also admits that the Local Plan “does not designate other land as 'replacement' Green Belt to replace that to be removed”. In other words, there will be a net loss of Green Belt; the plan offers to mitigate this, but does not specify how.

The Green Belt Study (July 2017) determined a Very High Level of Harm to the Green Belt Associated with Release of Broad Areas in an area covering Tudeley; but Tudeley is not examined individually. Presumably the Tudeley plan came in too late for inclusion - has proper consideration been given to these issues - or is this another sign that the plan has been rushed?

[TWBC: for image see full representation].

[Tunbridge Wells Green Belt Study, July 2017]

Comparison is made with other nearby boroughs. TWBC notes that “Sevenoaks District Council is not proposing to wholly meet [sic] its housing need”, and that “the constraints applying to Sevenoaks apply similarly to this borough”. [TW Draft Local Plan 4.8, page 34]

Government analysis of Green Belt, Areas of Outstanding Natural Beauty and Sites of Special Scientific Interest shows that Sevenoaks has 94% of such areas, leaving only 6% of other kinds, while TWBC has only 75%. In other words, 25% of TWBC’s area is NOT Green Belt, AONB or SSSI. [www.gov.uk/government/uploads/system/uploads/attachment_data/file/644783/Housing_Need_Consultation_Data_Table.xlsx]

Clearly Sevenoaks can build very little if at all without infringing protected areas. But despite making the comparison, TWBC is entirely different, with 8,000 of its 33,000 hectares available for development.

But TWBC’s draft Local Plan takes no account of this. Instead it plans to build a large portion of its new homes entirely on the 22% of its land which is Green Belt. It’s hard to see this as anything but perverse.

[TWBC: for image see full representation].

[Map from Draft Local Plan Summary leaflet, pp4-5, my annotation]

TWBC’s strategic objective number 9 is “To establish garden settlements as a model for the future delivery of development in the borough.”

TWBC’s argument is that Tudeley is the only place they can put such a settlement.

But it is to be the model for others. If Tudeley is the only possible location, then where are these other future settlements to be?

And if there are other possible sites, why are these not being considered now?

TWBC admits that the convenience of dealing with just one landowner is a factor in its decision. The inspector may consider that mere convenience should not drive decision-making in the planning arena.

ii) Flooding:

The European Commission’s guidance on Flooding Best Practice - though long - is well worth reading. It’s pretty clear that no one at TWBC has done so. Here’s a flavour:

“human interference into the processes of nature should be reversed” “restore rivers' natural flood zones”

“strategy should cover the entire river basin area”

“one should not pass on water management problems in one region to another”

“shift from defensive action against hazards to management… [to] include rare events” “flood protection is never absolute, and may generate a false sense of security”

[European Commission Environment Directorate: Best Practices on Flood Prevention, Protection and Mitigation: https://ec.europa.eu/environment/water/flood_risk/pdf/flooding_bestpractice.pdf]

A cursory look at the Environment Agency’s long term flood risk maps shows how seriously we must take this problem. It is not sufficient to kick it into the long grass to be dealt with at the masterplanning stage.

[https://flood-warning-information.service.gov.uk/long-term-flood-risk/map]

[TWBC: for image see full representation].

The topographical map shows how adding impermeable surfaces in the suggested area will create rainwater flows downhill directly into the Medway:

[TWBC: for image see full representation].

Further maps appended.

There must be huge concern for communities downstream, such as Maidstone or Yalding, so heavily hit in 2000 and again at Christmas 2013.

[TWBC: for image see full representation].

Recent plans to protect this part of the Medway basin have been dropped, leaving the area especially vulnerable. The cost of the 2013 flood to local business alone was estimated at £100m.

[www.bbc.co.uk/news/uk-england-kent-36973257]

Acknowledging the huge risks, TWBC’s plan offers: ‘flood storage/attenuation/mitigation areas to reduce the flood risk to particular existing residential areas in Five Oak Green and Paddock Wood’. [Policy STR/CA 1, page 156]

The details of such mitigations are left to the masterplanning stage - when it will be too late to pull back if such mitigations turn out to be impractical or uncertain.

TWBC’s mitigations are unspecified - dreamt up on the spur of the moment, perhaps? There are few strategies that will mitigate covering 600 acres of farmland in tarmac. As the EU says, the best mitigation is not to do anything so unsustainable in the first place.

iii) Heritage assets:

[Draft Local Plan, p158: “particularly respect the setting of heritage assets, especially All Saints Church… (see Policy EN 7: Heritage Assets)]

I’m not the only one who loves Tudeley Church: it is visited by many thousands of international tourists every year.

In just one six-week period between 20 August and 10 October, All Saints’ visitors book reveals visitors from Denmark, Germany, France, Switzerland, Ireland, Australia, Georgia, Ecuador, South Africa, Belgium, Spain, Belarus, Netherlands, Canada, Japan, Gibraltar, Israel, Greece, Czech Republic, Italy, Norway, Egypt. [Analysis of All Saints’ Tudeley Visitors’ Book - appended]

The car park is routinely occupied by coaches of 30-50 seats or more. In the six months to 1 October 2019, the church calendar shows 84 visiting groups (defined as being 8 or more people). If the average group consisted of just 40 people, that is 2,000 visitors a year. [www.tudeley.org/dailycalendar.htm]

Of course, the vast majority of visitors come independently. Between April and October, 66 pages of the visitors’ book were filled. Each page has 21 lines, giving at least another 1,000 visitors.

[Visitors Book, All Saints’ Tudeley]

How many did not bother to sign? Twenty minutes spent in the church reveal that only a tiny minority do so. The total number of visitors per year is certainly in excess of 10,000.

Many stay in the area, and even more use local restaurants and pubs: they generate significant income for the area.

[ITN News, interview with Aline Koehler-Price, Poacher & Partridge, Tudeley, July 9, 2019]

All Saints’ location is part of the attraction. A world-famous artwork in the middle of fields and woods is a significant draw. A world-famous artwork in the middle of a housing estate? Not so much.

According to Visit Kent, tourism’s total value to the local economy has risen to £278 million a year. Is it really wise for Tunbridge Wells to jeopardise All Saints’ contribution to that? [www.timeslocalnews.co.uk, 17th January 2019]

So far we have looked only at numbers. Artistically speaking, how important is it really?

According to Simon Jenkins’ ‘England’s Thousand Best Churches’ it’s “a superb work of 20th century church art”; Jenkins’ book waxes lyrical, and devotes a whole page colour illustration to the east window.

[TWBC: for image see full representation].The overall objective of the Local Plan is “to ensure the quality of life for all residents whether in the home, at school, at work, or at leisure in 2033 is better than today”.

[TWBC Consultation Statement Sep 2019]

And in section 4.24 the plan notes that ‘the cultural offer of an area can benefit wellbeing… the borough has a cultural need”. [Draft Local Plan, section 4.24, p36]

How can we calculate well-being? With mental health very much on today’s agenda, what recourse do people find in Tudeley?

If the comments are anything to go by, visiting this country church in its quiet location has a transformative effect on many who come. Here are just a few comments from the visitors’ book:

‘A magical and spiritual place’ ‘There is so much peace here’

‘Beautiful windows in a peaceful setting’ ‘Meditative and beautiful’

‘Silence is golden’ ‘So tranquil’

How much of this peace will visitors find if there is a housing estate all around the plot?

Meantime, the church provides inspiration for further artistic endeavour. Poetry and music have been generated by its presence and value:

[TWBC: for image see full representation].

From Oxford University, one commentator speaks of the experience of sitting in “that still, small church, immersed in the colour and pain and hope of those windows shining through”. [www.universitychurch.ox.ac.uk/sermons/chagall-tudeley]

Note the mention of stillness. Surround this gem with houses, and that is what will be lost.

The best way to ‘respect the setting of… All Saints’ Church’ is NOT to build 2,800 houses around it.

iv) Transport:

Perhaps the most compelling argument against the Local Plan for Tudeley is in the matter of transport. It has been pointed out that the traffic from the new development would inevitably devolve on Tonbridge and its railway station. As neighbouring MP Tom Tugendhat points out, this station is already the busiest in Kent - and - other than London - one of the busiest in the south-east of England.

[TWBC: for image see full representation].

There is little or no prospect of a new railway station to serve the new community. Simply put, the transport links do not exist.

TWBC realise this - but they have a plan:

“Technology in transport is moving rapidly, including in relation to autonomous vehicles… scope for new and innovative technology.”

[Draft Local Plan para 4.61]

Early drafts of the plan recommended autonomous vehicles connecting Paddock Wood, Tudeley and Tonbridge; these futuristic recommendations have been tactfully dropped in the published version.

But TWBC has a record for embracing this innovative thinking, though so far only in theory. An imaginative and visionary proposal was put forward as far back as 2016 - though its proponent had been working on it for some four years prior to that.

[TWBC: for image see full representation].

‘Self-driving cars could be introduced in Tunbridge Wells’

[www.kentonline.co.uk/tunbridge-wells/news/kent-town-set-for-30m-92396]

Self-driving Vehicles for Tunbridge Wells.

Joint Transportation Board Agenda and minutes, Monday, 15th February, 2016 [https://democracy.tunbridgewells.gov.uk/meetings/documents/s26066/15b%20Self- driving%20Vehicles%20for%20Tunbridge%20Wells%20-%20Appendix%20B%20-

%20Background%20Papers.pdf]

As of 2019, this attractive and compelling £30million project still exists only on paper. It seems highly probable that the same fate would befall the Tudeley version.

TWBC has a standard response to all insoluble problems: future technology will provide. These tech solutions are as-yet uninvented, and/or impractical.
---

In parenthesis, I don’t expect many people in Tunbridge Wells have ever seen a podcar, or even a picture, so here is one. We look forward to seeing them in Tudeley. [www.podcars.com]

Alternatively, the ‘Mister’ model seems particularly well-suited to rural Kent:

[TWBC: for image see full representation].

There may also be scope for a development of this kind - perhaps sited mid-Medway? *

[TWBC: for image see full representation].

* After flooding, obviously.

5. Climate change and the environment

TWBC Objective: 'to tackle climate change'

[Draft Local Plan, p32, Vision and Objectives 2, Strategic Objectives #7: “tackle climate change and minimise the impact of development on communities…”

On 1st May Parliament passed a motion declaring a climate emergency. Just when we need to treasure our green spaces more than ever, it’s short-sighted indeed to be considering submerging Green Belt, AONB, and ancient woodland under yet more development.

However environmentally friendly a development may be, its carbon footprint will be huge: every cubic yard of concrete is responsible for emitting around 400 lbs of CO2.

[World Business Council for Sustainable Development]

And the more we pave the Medway valley, the more flooding there will be - TWBC’s ‘mitigations’ notwithstanding. The water has to go somewhere.

We now know that climate change is happening far faster than was previously thought [Scientific American August 19, 2019]; the UK Met Office now confirms that after 11,000 years of stable global temperatures, there has been a rapid heating in the last twenty years.

[TWBC: for image see full representation].

The UK has a responsibility be at the forefront of change: as the first to industrialise, it has cumulatively contributed more carbon dioxide emissions than most other countries. [Myles Allen, Professor of Geosystem Science, University of Oxford]

The latest reports came in August 2019; the draft Local Plan does not - and could not - take account of them. In the light of new research this development is clearly far from sustainable.

The Tudeley project represents the thinking of the past, when we thought we could just take from the planet and give nothing back. We know better now.

5. Can TWBC deliver?

i) A history of failure

It’s cruel to mock the afflicted, but it must be admitted that TWBC’s history on delivering on its projects is not an encouraging one. The election of councillors from outside the old TWBC clique seems to augur well for the future, but there is a long way to go.

Here is what locals call ‘the cinema site’. It faces directly onto TWBC’s council offices.

[TWBC: for image see full representation].

To the frustration of residents, it has presented this appearance for eighteen (yes - 18!) years.

Residents were incredulous that in eighteen years, TWBC was unable to manage this prime site in such a way that it was anything other than an eyesore.

The previous structures were demolished in 2001. According to the local newspaper, diggers were finally spotted just last month.

[TWBC: for image see full representation].

[www.timeslocalnews.co.uk/tunbridge-wells-news/work-finally-gets-underway-on-the-derelict- cinema-site]

But note that the plan includes a mix of units, to include retail outlets.

Once upon a time, retail could be depended upon to provide an income from any town development; those days are gone. In Tunbridge Wells’ main retail centre, Royal Victoria Place, a third of the shops stand empty.

[www.kentlive.news/news/kent-news/nearly-third-royal-victoria-places-1032472]

There is no plan to convert any retail premises to dwellings. (Why not?) Instead, TWBC plans for yet more unsustainable retail outlets. Yet again, TWBC is living in the past.

Next, it turned out that their flagship project for new council offices and theatre was deeply unpopular with residents. Voters turfed out long-established councillors in favour of a single- issue party, the Tunbridge Wells Alliance. After years of planning and expenditure in excess of £10million, the project - known around the borough as ‘The Vanity Project’ - was finally quashed on October 8 2019.

[TWBC: for image see full representation].

At once, TWBC created more problems with its grandiosely-named and similarly costly Public Realm plan, costing £1.3million and driving Monson Road retailers close to bankruptcy. The works started on July 7 2019 and were supposed to finish on September 1, but had not been completed by October 30.

[www.timeslocalnews.co.uk/tunbridge-wells-news/ten-sets-of-roadworks-on-same-day-bring- the-town-to-a-standstill]

As late as 1 October, local journalist Mary Harris began a social media campaign to save local shops: “What Monson News has on the shelves is all they can afford now to put on there…”

[TWBC: for image see full representation].

The draft local plan has already cost over £574,000 and is on track to be 2 years and 2 months behind schedule. And yet it has been rushed through.

[@twellsense analysis, via Twitter]

TWBC’s plan offers ‘a vibrant and viable town centre’. [4. 5.9]

The Council has “ambitious plans to improve the offer of the town centre with both public and private sector investment, including the Calverley Square project providing a new modern theatre…”.

Vibrant and viable? The Calverley Square project is cancelled. The local retail centre is on its last legs. The council’s grandiose plans are bringing retailers to their knees.

Do these experiences encourage us to believe that TWBC is competent to manage the Tudeley project, in partnership with a landowner who gives his job title as ‘farmer’?

Or do they indicate another expensive omnishambles?

ii) A failure to consult

TWBC’s draft Local Plan looks to the future - and it’s rosy:

“A new garden settlement will have been established at Tudeley Village, including homes, employment, and community facilities: this will continue to develop into the following years. It will be well connected to other settlements…”

[Vision and Objectives,3.2, 1, page 21]

Which ‘other settlements’ are these, and how will they be connected?

The only meaningful one is nearby Tonbridge which has its own housing need. The Tudeley development is located absolutely on TWBC’s border with Tonbridge and Malling. It is 1.5 miles from Tonbridge Railway Station, and the best part of 6 miles from Tunbridge Wells Station.

It is clear that all the infrastructure demand will be placed on Tonbridge.

The Local Plan developed for nearby Sevenoaks was recently rejected by inspector Karen Baker for not properly consulting neighbouring authorities, saying:

"My main concern relates to the lack of constructive engagement with neighbouring authorities to resolve the issue of unmet housing need and the absence of strategic cross boundary planning to examine how the identified needs could be accommodated. Indeed, the council did not formally ask neighbouring authorities if they were in a position to address its unmet housing need until just before the Local Plan was submitted for examination.

Any failure of the duty to co-operate cannot be rectified during the examination and therefore the only option is for a report recommending non-adoption to be issued or for the plan to be withdrawn."

So how have nearby TWBC handled their duty to co-operate? The headlines are not encouraging.

[TWBC: for image see full representation].

[www.kentonline.co.uk/tonbridge/news/council-blasts-plans-for-thousands-of-new-homes- 214496]

Neighbouring Tonbridge and Malling Borough Council knew nothing of the Tudeley plan. When it was revealed in full, T&MBC went so far as to hold a special meeting to discuss it (2 Oct 2019), at which Tonbridge and Malling’s mayor said: “I am so angry I can hardly speak”.

In his response letter on behalf of T&MBC, Planning Policy Manager Ian Bailey wrote: “TMBC needs to be assured that it will be a key partner”.

[Response on behalf of Tonbridge and Malling Borough Council (T&MBC) 16.10.2019]

TWBC replied blandly that “The policies specifically state that we will work closely with neighbouring authorities on the infrastructure requirements of the Plan.” The inspector may consider this to be a little late in the day, and wonder why it is limited only to infrastructure requirements?

As for residents, the full proposal for Tudeley was only publicly revealed in May 2019: [TWBC: for image see full representation].

[Excerpt from letter from Castle Planning of Berkhamsted, Herts, dated 31st July 2019, on behalf of The Save Capel Campaign Group and Capel Parish Council]

Other aspects of the plan were developed years earlier, and indeed, the plan itself was due for publication in January 2019. Was it delayed until May to work up some justification for the so- recently-included plan for Tudeley? Or were the plans kept quiet for as long as possible because TWBC knew they were flawed?

For consistency of approach, the Inspectorate must surely return the plan to TWBC for ‘lack of constructive engagement’.

iii) Evidence base impossible in the time

Section 1.30 of the plan states that TWBC has “commissioned and completed a substantial and varied evidence base” [Draft Local Plan, 1.30, p19]

Yet the Tunbridge Wells Green Belt Study, Stage Two, prepared by LUC in July 2017, makes no mention of the Tudeley project - though other parcels are examined in detail. Was Tudeley not included in TWBC’s plans at that time?

How can ‘a substantial and varied’ evidence base have been constructed between publication of the Green Belt Study in July 2017 and the first mention of the scheme in April 2018?

Certainly very little time has been allowed to build up “a substantial and varied evidence base”. How could such an evidence base be comprehensive without the views of residents? How could those views have been incorporated when the plan became public only in May 2019?

One might conclude that the various arguments in favour of the Tudeley project have been hastily put together to justify, ex post facto, its inclusion in the Draft Local Plan. This view is supported by the failure to consult with neighbouring boroughs: presumably TWBC simply didn’t have time to comply with this aspect of the Local Plan system.

iv) Non-compliance with NPPF

Does the plan comply with the Local Plan system in other respects? According to the NPPF Consultation Draft p18, it is required to be:

“Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.”

  • There has been no objective assessment of the area’s housing need
  • Plan was not agreed with neighbouring councils eg Tonbridge and Malling
  • Does not balance needs, so is not consistent with sustainable development*

* The term ‘sustainable development’ is long defined as “development that looks to balance different, and often competing, needs against an awareness of the environmental, social and economic limitations we face as a society” Sustainable Development Commission, 2011

“Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence”

  • Reasonable alternatives (eg brownfield) have not been considered
  • The attraction of dealing with just one-landowner has overridden other concerns
  • No proportionate evidence of alternatives: they have simply been ignored

“Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground”

  • Not based on cross-boundary working with T&MBC - and others?

“Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.”

  • Not consistent with recent ministerial pronouncements on Green Belt

    (See also notes on sustainable development above)

In conclusion, it is clear that TWBC’s Strategy for Capel Parish fails on many counts. It has failed to follow proper NPPF procedures in consulting with neighbouring boroughs, with calculating its housing need, or taking account of environmental factors.

It dismisses the causes of the national housing crisis without consideration. It proposes a ghetto for the wealthy. It fails to address its own housing need - 1,000 families waiting for housing.

It proudly boasts its plans for affordable homes, conveniently overlooking the fact that they will be affordable only to those with incomes over £100,000.

It is out of date with respect to environmental challenges. It pays insufficient attention to the risks of flooding, promising unspecified mitigations. Without justification, it places a huge percentage of its planned housing entirely on the one fifth of its area which is designated Green Belt. It fails to focus on the 25% of its area which is NOT Green Belt, AONB or SSSI.

TWBC’s plan would utterly ruin its biggest heritage asset - the quiet peace of a country churchyard, and a mecca for visitors from far and near, thereby jeopardising its own tourism income.

It offers futuristic but unspecified solutions to its transport problems, dumping them unannounced on its neighbouring borough, whose railway station is already the busiest in south-east England.

It claims to be concerned about climate change, but offers more unspecified and probably non- existent mitigations.

It exaggerates the value of its evidence base, and seeks to divert attention from the rushed manner in which its plan for Tudeley has been developed.

It has a record of proposing unworkable plans, spending millions of pounds of ratepayers’ money on them, and having them collapse. Residents opine that it is not competent to manage its own parking policy, let alone a major housebuilding project.

It is, in short, a failure.

TWBC’s response to the government’s call for ‘the right homes in the right places’ is to come up with the wrong homes in the wrong places.

Appendices

Appendix A : additional Environment Agency Flood Risk Maps

[TWBC: see maps in [full representation].


Appendix B: Visitors to All Saints’ Church Tudeley

PRIVACY NOTE: This book is in the church and available for anyone to view: it is therefore, by my estimation, in the public domain.

[TWBC: see images in full representation].

DLP_493

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;
  1. 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;
  • 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;
  1. 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;
  2. 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_570

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_8115

Ashley Saunders

Object

This policy envisages too many new dwellings, completely out of proportion to its environment. They are entirely unsustainable in this rural area with a limited infrastructure. Capel Parish Council believes this proposal is unsustainable and therefore unsound – clearly not of a sustainable scale as claimed here. CPC is also troubled by the call for a ‘clear identity’ by which we take something similar to Poundbury, which would be an unwelcome urban intrusion into this rural Low Weald Medway Valley landscape. We believe this is what the landowner intends, and we believe he should not be allowed a free hand.

If this development were to materialise, we believe TWBC should insist that all infrastructure (transport services, new roads and road improvements) must be delivered before construction of housing begins. We believe the added flood risk cannot be fully mitigated against and the site contributes negatively to climate change.

DLP_633

Jonathan Kellett

Object

My comments relate to Policy AL/CA1 (Tudely) but also to Capel.

I have lived in the area of North Tonbridg for over 30 years and I am familiar with the problems of overcrowding, inadequate transport facilities, flooding and drought, provision of school places, traffic jams and constant pressure to extract the poor quality mineral reserves in the area. My comments are as follows:

Green Belt/AONB.  This area is a wonderful resource for residents in what has become a heavily developed area stretching from Sevenoaks through Tonbridge to Tunbridge Wells. Its permanent loss and the effect on wildlife and prime farmland is incalculable.  The construction of housing and infrastructure in this area cannot be justified.  The overall impact on the area and the communities will be horrendous.  There are simply no persuasive arguments in its favour.

Transport.  The area around Tonbridge is overwhelmed and frequently grid-locked during busy periods. There are already too many cars and the effect of additional housing would add hugely to journey times and parking problems.  The bus services in the area are a bad joke - infrequent and unreliable, partly due to getting caught up in the traffic jams. In term time they are full of screaming school children and are a very unpleasant way of moving around so, not surpisingly, anyone with a car uses it so increasing the traffic and parking problems.  If anyone thinks the residents of new housing will act any differently they are totally wrong. Many will have to work in London and inevitabley drive to Tonbridge.  The overcrowded trains already cannot cope and with the pension age creaping upwards, many commuters will be elderly and it is inhumane to expect them to stand for 40 minutes or more all the way to London. Commuters joining at Sevenoaks  already have problems forcing their way onto trains arriving from Tonbridge.

Cycle path.  Cycling is not an option for anyone who is not from the lycra brigade.  The gradients from Tudely/Capel to Tonbridge and even worse from Tonbridge to Tudley/Capel make any suggestion of this being an alternative means of transport absolutely absurd.

Infrastructure.  The Roads, schools, hospitals, police and transport systems are all at full capacity and these grand statements of putting in place new infrastruture are not believable. The A21 link from Tonbridge Tunbridge Wells, even though a massive priority for the region,  was under discussion when we moved to the area in 1987 - and opened this year.  With funding and planning constraints this whole scheme is a ridiculous pipe dream.

TW and Construction plans.  It is blindingly obviouse that (not for the first time) Tunbridge Wells is seeking to push any unpleasant development on to its borders so that Tonbridge & Malling suffer the adverse consequences of this monstrous scheme.  The construction of the infrastructure and housing would devastate the area for a generation.

Flood Risk.  This has not been adequately considered and is a hugely complex issue with climate change making any predicitions even more likely to be wrong.

DLP_652

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_1537

Tonbridge & Malling Borough Council

Object

The potential significant impacts of the proposed developments at Tudeley and Capel on the local highway network and on infrastructure and services in nearby Tonbridge are a major concern for TMBC, particularly in the light of the existing infrastructure challenges in Tonbridge and surrounding villages and communities which have been identified by TMBC. TMBC believes that some of these will present delivery challenges for the allocation due to appropriate mitigation measures not being feasible. However, we wish to work collaboratively with TWBC to explore all possibilities and particularly welcome the early identification of a number of junctions requiring mitigation within TMBC.

It is acknowledged that Policies STR/CA1 and AL/CA1 recognise these issues and require comprehensive master planning and ongoing liaison between Tonbridge and Malling, Tunbridge Wells, Kent County Council and all other relevant stakeholders. This will include land owners, promoters, and infrastructure providers to ensure that the infrastructure accompanying these proposals is properly planned for and delivered at the appropriate time. TMBC requests that they are specifically mentioned in all relevant policies with the emerging Local Plan to ensure that this collaborative approach is enshrined in policy.

Both this site and the Paddock Wood sites discussed below require appropriate onsite health service provision to be provided at a primary care level. Given the proximity of these sites to Tonbridge and the proposals for Local Care Hubs that are being progressed by the West Kent CCG, TMBC request that the potential for facilitating Local Care delivery through this strategic site allocation providing land or contribution (our preference is Tonbridge Cottage Hospital) should be explored in detail as part of the next stage of plan development, should this site be taken forward.

DLP_2021

Dr David Parrish

Object

Policy AL/CA 1 (Tudeley Village) p.160

TWBC should change the Local Plan, by cancelling the intention of a Tudeley Garden Village, to adhere to the NPPF an this point

To consider a Garden Village split in two by a Railway is ludicrous

TWBC must protect the Heritage that exists in which their voting public live

This policy refers to too many new dwellings. They are entirely unsustainable.

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 justification”. (Paragraph 194, NPPF). In domestic planning applications, TWBC requires an assessment of the impact of the proposed development on all heritage assets within a kilometre. Applying its own metric to its own development proposals the following approximate numbers of heritage assets in, or within a kilometre of CA1 are; 2 Grade 1, 1 Grade 2* and 70 Grade 2 listed heritage assets. This is a high number of assets that should be protected.

Tudeley is particularly sensitive in terms of heritage around Tudeley Church, which is a Grade I listed building and the only church in the world with all its windows designed by Marc Chagall. Significant consideration needs to be given to the heritage and conservation impact of the development proposed in this area on the setting of this unique global heritage asset.

In addition, TWBC’s own Historic Environment Review (2018) states that “The historic character of the Low Weald is particularly vulnerable to poorly managed development at the urban fringe, especially around Paddock Wood and Five Oak Green”.

Another Contradiction

This is of particular concern in relation to the development proposed in the Parish of Capel. I believe that the harm imposed by the Local Plan has not been adequately considered.

TWBC may not be in complete control the Local Plan

The Council should not allow the landowner to jointly master plan this site. The landowner has a poor reputation with regard to sustainability, quality and delivery. Their involvement poses a high risk of harm to the area.

Transport services, new roads and road improvements must all be delivered before construction of housing begins.

The new secondary school is in a dangerous place, with a railway line running through the site and it will add an unacceptably high level of traffic to/from Tonbridge. The whole Tudeley Village site should be scrapped on the grounds of not being able to develop the secondary school due to safety and pollution issues.

The flood risk is bound to go up, regardless of mitigation/attenuation measures. It cannot be proven to be controlled or to go down, so the site should not be developed.

DLP_1623

Maggie Fenton

Object

Section 5 Paragraph 5.60 (Allocation Policies) p.159

This CA1 site is unsuitable for a garden settlement because it has a main railway line running through the middle of it. It is two settlements divided by a railway line, neither of which satisfy garden settlement principles. At present there are 2 crossings at Hartlake Road (a minor country road) and Sherenden which is single width by the railway embankment. There is a “woolly” plan for ingress and egress to the site at the southern point but to date I have yet to find anything in the DLP which shows how traffic will move from the northern half of the site?

An overriding factor in the selection of this site appears to be the fact it is in single ownership (no where else in the DLP does it cite ownership numbers). This appears to make the allocation to be sheer laziness on the part of TWBC. There has been no engagement with the community from this landowner apart from one letter suggesting the community should be grateful for him offering his land in the national interest to help the housing crisis!

Development on the site will adversely affect flood risks in Tudeley and neighbouring Golden Green, East Peckham, Hadlow and Tonbridge. The River Medway is rising. The rapid increase in sea levels and other Climate Change factors have not been fully considered. The Five Oak Green flood risk will be reduced by damming the Alders Stream, not by building thousands of houses. This can be delivered and funded independently of either of the garden settlements.

The development in East Capel is totally unsuitable, it is MGB that truly provides its function, namely it stops the coalesence of Paddock Wood and Five Oak Green. The site is prone to flooding & the complete disregard for those Five Oak Green residents who live here and their absorption into a completely different parish and town is breath takingly appalling.

The Biodiversity at CA1 site is extraordinary. As you rightly note, it is also adjacent to a Biodiversity Opportunity Area and directly adjacent to AONB.  It is unlikely to be any the less important at CA3 and in East Capel.

Policy AL/CA 1 (Tudeley Village) p.160

The number of new dwellings are entirely unsustainable and totally disproportionate to the local existing environment.

Transport services, new roads and road improvements and any other infrastructure must all be delivered before construction of housing begins.

The landowner intends to “masterplan” this project, this is concerning. A Poundbury is not acceptable to this Low Weald Valley landscape.

The new secondary school is in a dangerous place, with a railway line running through the site and it will add an unacceptably high level of traffic to/from Tonbridge. The whole Tudeley Village site should be scrapped on the grounds of not being able to develop the secondary school due to safety and pollution issues.

The flood risk is bound to go up with Climate Change, regardless of mitigation/attenuation measures. It cannot be proven to be controlled or to go down, so the site should not be developed.

WHERE IS THE NEW SETTLEMENT (Garden Village) FEASIBILITY STUDY? The evidence base is lacking and therefore the plan is unsound.

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.

It is unlikely 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. However it is likely that students from Five Oak Green and Paddock Wood will travel to this school, as Mascalls reaches capacity & parents choose a smaller school – thus making PolicyAL/PW1 unsustainable.

Many more students will come from Tonbridge and Southborough/Bidborough, ensuring more traffic chaos. Without the expansion of Mascalls, which is not possible beyond a certain level, Paddock Wood residents will no doubt select (& drive!) to this school.

DLP_959

Mrs Karen Stevenson

Object

As already stated, the development of up to 2,800 new homes, creating a new town in the countryside, will cause immense harm to the local community. The signficant imapct of increased traffic on the rural road network is not sustainable. Also 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. Covering farmed fields with houses and roads is likely to increase the 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 which create a visual scar across the landscape. Views across 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).

​Creating so much housing in Capel Parish will mean 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. ​ The garden settlement can never be one settlement as it is divided by a railway line. Putting in additional crossings at frequent points across the railway may be possible but it won’t integrate the two halves of the settlement together enough to make it one settlement, so is unlikely to satisfy garden settlement principles.

In summary, land that is Green Belt should, like the AONB, only be built upon if an “exceptional circumstance” exists. I do not believe TWBC has done enough to demonstrate why these developments should be promoted, against the over-riding principles of protecting our countryside.

DLP_2067

Terry Everest

Object

Strongest Possible Objection

Refer to comments for policy STR/CA1

This is totally wrong and should not go ahead. It is Green Belt, AONB and a historic village which should all be conserved!

DLP_865

Ian Pattenden

Object

Comments on Section 5 Paragraph 5.60 (Allocation Policies) p.159

This site is unsuitable for a so-called garden settlement. It is divided by a main line railway and no amount of crossings can join it into one settlement; therefore it does not satisfy necessary principles for this style of development.

You state that this land is under single ownership very willing to participate in a development scheme, no surprise since he does not have an interest in farming or preserving the countryside he has been privileged to have inherited.  This appears to be the overriding factor in your selection as a site for a large development. None of us as current residents have had any positive form of engagement with the landowner since the development was disclosed (or indeed before), only a patronising and hypocritical letter addressed to “The Resident”. We have lived within the Hadlow Estate for over 33 years, so that indicates how engaging the current land owners are with the community.

Development on the site will adversely affect flood risks in Tudeley and neighbouring Golden Green, East Peckham, Yalding, Hadlow and Tonbridge. The River Medway is rising. The rapid increase in sea levels and other Climate Change factors have not been fully considered. The Five Oak Green flood risk will be reduced by damming the Alders Stream, not by building thousands of houses. This can be delivered and funded independently of the garden settlement, as well you know.

The Biodiversity on this site is extraordinary. As you rightly note, it is also adjacent to a Biodiversity Opportunity Area and directly adjacent to AONB.

Comments on Policy AL/CA 1 (Tudeley Village) p.160 to 162

Para 2 – Clearly Identify –There cannot be a “heart” when the settlement is split into two by the railway.

Well Designed Places – There is no conclusive proof that there is a shortage of local employment.

Great Homes – I question that 2,800 homes are for local people and they will certainly not be affordable. This development would draw in people from the London area and become a dormitory commuter town where many residents would need to commute back to London to work on trains which are currently overcrowded and full to capacity. Additionally, station car parking availability is up to capacity with no room to expand.

Strong Local Vision & Engagement – The current natural environment is a rural farming landscape, this cannot be transformed into something equal to or better by building 2,800 houses, civic amenities, business premises, schools, health centre, roadways etc.

Transport – The settlement will be very difficult to navigate around when the railway runs through the middle.

Healthy Places – The current rural healthy area will be difficult to sustain or improve by transforming it with the building of 2,800 houses, civic amenities, business premises, schools, health centre, roadways etc.

Green Space – Details are lacking on how it is envisaged to accomplish this promise when replacing a rural environment with a new town and all that this requires.

Legacy of Stewardship Arrangements – No details are available of what is being suggested or proposed so it is difficult to comment.

Para 3 – The land owner has no experience in Masterplanning yet he is being proposed as a partner to TWBC.

Para 5i – The current area of designated farmland is fertile grade 2 or 3 producing approximately 1,000 tonnes of cereal crops, 400 tonnes of apples, 240 tonnes of pears and 200 tonnes of black currents. This food production will be lost with the proposed level of housing and associated infrastructure necessary to support such a scheme. This will have a negative impact on the rural economy and level of employment, at a time when food production is commonly recognised as at a premium.

Para 5ii –There are approximately 70 listed grade I & II properties currently identified within the Parish. One outstanding world-renowned heritage asset is All Saints Church in Tudeley. It is the only church in the world to feature stained glass windows designed by the famous artist Marc Chagall, this must be protected along with the medieval Church of Thomas A Beckett also located within the parish of Capel. In addition, TWBC’s own Historic Environment Review (2018) states that “The historic character of the Low Weald is particularly vulnerable to poorly managed development at the urban fringe, especially around Paddock Wood and Five Oak Green”. This is of particular concern in relation to the development proposed in the Parish of Capel. I believe that the harm imposed by the Local Plan has not been adequately considered.

Para 5iii – The current and irreplaceable natural rural habitats of native wildlife species and birds, flora & fauna will be destroyed by this massive housing estate and all accompanying additional amenities and infra structure.

Para 6 – Low level of car use is an impractical and ideological dream, you cannot un-invent the car. Independent transport is a fact of life and an essential commodity in the 21st Century and a democratic choice.

Para 7 – There cannot be a settlement centre as the railway splits this into two distinct areas. Furthermore, the open rural landscape, which can be viewed from many miles around due to the topography of the area, will be destroyed beyond recognition.

Para 8 – The visual impact of building 2,800 houses, amenities and infrastructure necessary to make a functioning town on an open landscape will be catastrophic and irreversible and unnecessary.

Para 9 – The 4,000 or so additional residents located in the north of the proposed Tudeley New Town will have extreme difficulty getting into Tonbridge or Tunbridge Wells. Currently there are only two crossings, a single-track lane with a bridge under the railway (Sherenden Road) or a small country road (Hartlake Road) which has a bridge over the railway and is a pinch point, and has a weight limit restriction.

Para 10 – More ideological mumbo jumbo, people will not be prepared to walk or cycle to Tonbridge or Paddock Wood towns or stations or totally rely on public transport to other areas of the Borough or beyond as part of their working day. Movement to and from this settlement will rely, in the main, on private motorcars which will cause air pollution and congestion.

Para 14 – In the 33 years we have lived in our house we have witnessed on many occasions flooding as a result of rainwater runoff from the arable farmland, this will be exasperated by the increased amount of rainwater runoff from hard surfaced roofs and concreted surfaces of the proposed development structure.

Para 15 – It is difficult to see how green spaces, green infrastructure and biodiversity as well as 2,800 houses, civic amenities, schools, medical centres, roads etc. can all be accommodated within the same rural setting.

Para 16 – It is difficult to see how the ground water sources and supply can be protected from this proposed huge development.

DLP_1785

CPRE Kent

Object

Policy STR2 sets out the Council’s commitment to deliver sustainable development. However, it is not clear from policy AL/CA1 how the new Tudeley village of 2,500-2,800 dwellings will be delivered sustainably.

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

Sustainable development

While it is noted that “integrated, forward looking and accessible transport options” with links between Paddock Wood, Tudeley Village, Tonbridge and Royal Tunbridge Wells will be at the heart of the development, it is not clear what this actually entails. In order to constitute sustainable development there will need to be frequent day and night time public transport links to Paddock Wood/Tonbridge to enable onward commuting by train, and enable access to services/facilities in the higher order settlements.

While reference is made to a new bus only link from Paddock Wood to Tonbridge via Tudeley and demand responsive urban bus services in the Paddock Wood area in the Council’s  Infrastructure Delivery Plan (August 2019), it is not sufficiently clear what the Council’s aspirations are in this regard and what the actual mechanics for provision will be.

The need for public transport is flagged up under section 2 and section 10 of the policy. There is currently an hourly service (approximately) running between Tunbridge Wells and Paddock Wood, via Tudeley and Five Oak Green - the 205 - although this doesn’t run in the evenings or on Sundays.  The nearest railway stations are at Tonbridge and Paddock Wood.  Census 2011 data for Capel ward shows that 20.4% of the working population worked nearby (less than 5km) and that 7.1% walked or cycled to work, 1% went by bus, 10.2% by train and 72.1% by car (either as driver or passenger).  Given the absence of a frequent bus service and lack of evidence to show that a regular walk-on service could be provided early it is more than likely that new residents would travel by car for the whole or part of their journey to work and/or school.

In terms of train services the IDP sets out usage details for the four mainline stations within the borough. Bearing in mind the proximity of the proposed Tudeley village to the train station at Tonbridge (within Tonbridge & Malling Borough Council) – and the fact that rail travellers may prefer to travel forward to Tonbridge, rather than back to Paddock Wood – consideration should be given to the impact on capacity at Tonbridge to ensure that Tudeley Village can actually attain its goal of being a low car, exemplar development.

The Maidstone Borough Council Local Plan Review Scoping Themes & Issues Consultation July 2019 at page 52 states: “Research has shown that travel habits develop very quickly in new developments and once people have chosen their travel mode, they tend to stick to it.” It will be important for rapid bus links/transport links to be provided early to prevent/reduce additional vehicular traffic on existing roads.

The Key Diagram shows two proposed road link routes serving Tudeley Village.  The northern one links with Paddock Wood and the southern one along the edge of the High Weald AONB to the A228. It is noted that policy STR/CA1(6) states: “Strategic transport links shall be provided between Tonbridge, Tudeley Village, the A228, Five Oak Green, Royal Tunbridge Wells/Southborough, and land at Capel and Paddock Wood and Paddock Wood Town Centre. To include the provision of an offline A228 strategic link. Links from Tudeley Village to the east should minimise the impact on the road network in the settlement of Five Oak Green and have regard to Kent County Council minerals allocations in the vicinity. The exact location of such a link has not been determined.” The absence of a costed link route brings into question whether development at Tudeley and Paddock Wood can cover the costs, as well as all the other community and infrastructure required to support these developments.

This allocation straddles the railway line which is crossed by Sherenden Road (bridge under/height restriction) and Hartlake Road (bridge over).  These are both narrow country roads. If Network Rail does not allow additional crossing(s) the settlement will be forever divided by a railway line which has pinch point crossings. There is no mention of this in table 3 (scale and distribution of development), or in the Infrastructure Delivery Plan. If no crossings are proposed as part of the development for reasons of cost/viability, it calls into question whether development of this site will be acceptable in terms of free-flowing movement and community cohesion.

AONB

CPRE Kent object to the provision of a new settlement at Tudeley and the impact that this would have on the setting of the High Weald AONB.  The proposed new village would be highly visible on the slopes leading down to the flat lands of the River Medway flood plain, when viewed from 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

Policy AL/CA1 does not set out the site area for the proposed Tudeley Village and how much is designated green belt. Figures provided in the appendix to the Distribution of Development topic paper should be included in the policy for clarity – and with an explanation of why more land is to be released from the green belt (167.79ha) than is allocated (157.47ha).  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.

Tudeley falls with Broad Areas 3 and 4 in the Green Belt Study Stage 2.  Stage 2 figure 1.1 indicates that there would be a very high level of harm caused by the release of these broad areas.  The study considers smaller parcels around Five Oak Green and Paddock Wood but not at Tudeley.  Given the findings of the study and the absence of an assessment of the Tudeley allocation site there is no evidence to suggest that it is appropriate to release the site from the Green Belt and allocate it for development.

The Council’s SHELAA sets out that this site has a gross area of 157.47ha, of which the developable area is 148.62ha.  With an anticipated final yield of between 2,500-2,800 units density would be less than 20dpa.  This is lower than the density usually associated with suburban development of 40dpa.  On this basis it is not clear how this demonstrates the optimised density required to comply with paragraph 123 of the NPPF.

With 5.35% of green belt in the borough being released for development, CPRE Kent is concerned that the Council does not intend to designate additional land as replacement green belt – and seeks clarification as to why this is. Assurances are also sought as to how compensatory improvements to environmental quality and accessibility of the remaining green belt will actually be delivered (policy STR4).

Flooding

Paragraph 149 on the NPPF places an onus on the Council to ensure that it takes “a proactive approach to mitigating and adapting to climate change, taking into account the long term implications for flood risk”.

Land allocated for Tudeley Village adjoins land in flood zone 3b – the functional flood plan for the River Medway, and is therefore a very high risk flood area. While it is noted that policy requires that development will not exacerbate flooding elsewhere (particularly from the Alder Stream at Five Oak Green) and should deliver flood storage/attenuation/mitigation measures, it is considered that development in such close proximity to an area at risk of flooding, and which would exacerbate flooding further afield, should not be permitted in this location.

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).

There is no evidence that the Council has sought to identify areas of poorer quality agricultural land for development.

Light pollution

CPRE Kent is concerned that development of the site 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 and its associated roads will introduce light pollution into the area of dark skies contrary to the NPPF.

Dark skies should be referred to under section 5 of this policy.

Heritage assets

As well as considering the impacts of development on All Saints Church and (views from) Hadlow Tower regard should be had to the impact on the heritage assessments at Lilley Farm and Bank Farm within the proposed allocation and the numerous listed buildings at the edges of the allocation.

Section 5(iv) refers to need for the layout to investigate how Hadlow Tower will be viewed from within the development.  It should also consider the impact on views of Hadlow Tower from the High Weald AONB.

Delivery assumptions

The Council’s OAN is 13,560 of which 1,552 have been completed, leaving the need for 12,008 to be provided.  Some of this will be in the form of existing permissions, outstanding site allocations and windfall allowance.  The remaining 7,593 will be from new allocations of which 1,900 will be at Tudeley and 4,000 at Paddock Wood.  These two sites will provide 49% of outstanding new housing.

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

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

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

CPRE Kent questions these trajectories for the following reasons:

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

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

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_1649

Tom Tugendhat MP

 

STR/CA 1 - The Strategy for Capel Parish and AL/CA1 - Tudeley Village

Finally, I wanted to comment on the allocation for the strategic site at Tudeley which has probably attracted the most publicity in the run up to this consultation. It has certainly galvanised the interest of residents in Tonbridge and Golden Green since the proposals were published a few short weeks ago and from the allocation it is obvious to see why.

The boundaries of both Tonbridge and Golden Green are very clear and self-defined. On the south east of Tonbridge, Woodgate Way forms a natural buffer between the town and the countryside, and in the most part acts as the borough boundary as well. In Golden Green, the River Medway acts as a natural boundary between it and Tudeley. The result is that development here cannot be considered to be congruous with either settlement. The lack of acceptance that development at Tudeley would provide north-south traffic movements between it, Golden Green, Hadlow and East Peckham is striking of the need for additional work.

As I mentioned in my response to STR/PW 1 and AL/PW 1, the impact on the rail network is one of significant concern for any development on or near the Southeastern mainline. In the most likely event that a railway station is not built at Tudeley, residents will use Tonbridge station as their closest and I have significant concerns about the travel connections between Tudeley and Tonbridge.

First, considering the most sustainable form of transport, there are no cycle paths between the development and even if one was constructed along the B2017, there are many questions about the route it should take in Tonbridge. For a number of years I have been campaigning alongside Kent County Councillors, Richard Long and Michael Payne, as well as Tonbridge Bicycle Users Group to connect Tonbridge Station with the A21 Non-Motorised User Route and we have found agreeing an acceptable route with all parties extremely difficult. There are no indications that this would be any easier from Tudeley. Consequently, we cannot rely on the bicycle as being a primary and suitable mode of transport for residents in Tudeley.

Furthermore, parking capacity at Tonbridge station is already both limited, and expensive. Access to the car parks can be tricky, especially on the way in from the B2017, with cars having to go through Sovereign Way and Avenue du Puy to get there. This area is also frequently congested at peak times with existing business access, and possible improvements to the road network are limited. Consequently, development of this scale at Tudeley would have an unacceptably high impact on the centre of Tonbridge, and one which I highly doubt can be appropriately mitigated.

It is essential that TWBC looks at the impact of development on key junctions in Tonbridge if its proposals are to be progressed any further. If this does happen, it is down to TWBC to suggest ways that these will be improved which will not have an adverse impact on the quality of life of residents in Tonbridge, will come with the agreement of KCC and TMBC and, crucially, will not be funded by them either.

Turning to Golden Green, it is not possible to adequately assess the impact of development near the village without referencing the terrible flood events which have caused so much trouble for people here in recent decades. Like Tonbridge, in 2013/14 the flooding event hit Golden Green hard and the suitability of the land in the immediate area for further development is questionable. At the time of writing, the River Medway Flood Relief Act 1976 has yet to be amended and consequently we must assess these proposals on the basis that improvements to flood defences at the Leigh Flood Storage Area don't happen as quickly as we would like, although I am confident that they will be delivered. In light of any additional flood defences in the Golden Green area, I have my concerns that the increase in development will increase the flood risk and would request that TWBC engages closely with the Environment Agency to produce accurate models for the Regulation 19 consultation under all eventualities. Of course, these models should extend to Tonbridge as well.

Finally, I wish to cover the health provision needed to make this development acceptable. I am hugely concerned that these have not been identified and cannot find any reference in the Local Plan to the number of GPs needed to serve this development, and where they will be located. My concern is based on my experience representing Leybourne Chase. While TWBC may not be aware, this development of 733 dwellings came with provision for a GP surgery. However, now 5 years on from the first occupation, there isn't a GP on site, with discussions now taking place about changing the use of the building through the planning process.

Like in Leybourne Chase, neighbouring practices are full and in Tonbridge WKCCG has to allocate surgeries to new residents because of their closed lists. Therefore GP facilities are needed on site, but only if agreement can be found with a GP provider to take on ownership of the building. If this doesn't happen, development should not be permitted here as it would put an additional burden on the three Tonbridge GP practices.

In addition, shortly following the conclusion of this consultation we eagerly await the result of WKCCG's study into the need for hubs across West Kent. In Tonbridge Cottage Hospital we have the ideal site for one of these to serve residents across Tonbridge and the borough of Tunbridge Wells and I am concerned that the vague nature of the policy in the current Draft Local Plan leaves open the possibility for a hub to be located at Tudeley. This would no doubt be used as a reason to make any development acceptable, but would also undermine the viability of Tonbridge Cottage Hospital. Therefore, I urge TWBC to do much more work on the health impacts of these proposals on a strategic level ahead of the next consultation.

In summary, based off the available evidence it is clear that the development proposals at Tudeley would fundamentally change the character and nature of Tonbridge and Golden Green. I am hugely concerned that many of the key issues have not been adequately assessed so far and urge TWBC to complete this work so we know what the impact is on communities across the borough boundary. Without this being done, the Draft Local Plan cannot be considered sound, and I would not be surprised at all if it demonstrated that there was an unacceptable impact on towns and villages in Tonbridge and Malling as a result of these proposals.

[see also full response - Comment Number DLP_1577].

DLP_1691

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_7004

Turnberry for Hadlow Estate

Support with conditions

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

Policy AL/CA 1 Tudeley Village

This site, as defined on the Capel draft Policies Map, is allocated for:

i. Approximately 2,500-2,800 new dwellings, with approximately 1,900 to be delivered in the plan period. The level and tenure mix of affordable housing is to be determined through the Local Plan and CIL Stage 2 Viability Assessment. This figure will be confirmed in the Regulation 19 Pre-submission version of the Local Plan;

ii. The provision of appropriate employment within the settlement;

iii. A range of local services and facilities appropriate to the scale and function of the settlement;

iv. The provision of appropriate open space, leisure, and recreational areas, including informal and formal space, children’s and youth play space, sports pitches and allotments/food growing areas (see Policy OSSR 2: The provision of publicly accessible open space and recreation).

Proposals shall accord with the following requirements:

1. AllThe development toshall be delivered through a comprehensive masterplan approach led by the landowner in consultation with the community, stakeholders, statutory consultees and the Council. The consultation process shall be clearly communicated and documented. Proposals for the piecemeal development of individual sites will not be supported;

2. AllThe development must demonstrate how it meets and embeds the key qualities below:

i. Clear identity – a distinctive local identity as a new garden community, including at its heart an attractive and functioning centre and public realm.

ii. Sustainable scale – built at a scale which supports the necessary infrastructure to allow the community to function self-sufficiently on a day to day basis, with the capacity for future growth to meet the evolving housing and economic needs of the local area.

iii. Well-designed places – with vibrant mixed use communities that support a range of local employment types and premises, retail opportunities, recreational and community facilities.

iv. Great homes – offer a wide range of high quality, distinctive homes. This includes affordable housing and a mix of tenures for all stages of life.

v. Strong local vision and engagement – designed and executed with the engagement and involvement of the existing local community, and future residents and businesses. This should include consideration of how the natural and historic environment of the local area is reflected and respected.

vi. 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.

vii. Healthy places – designed to provide the choices and chances for all to live a healthy life, through taking a whole systems approach to key local health & wellbeing priorities and strategies.

viii. Green space – generous, accessible, and good quality green and blue infrastructure that promotes health, wellbeing, and quality of life, and considers opportunities to deliver environmental gains such as biodiversity net gain and enhancements to natural capital.

ix. Legacy and stewardship arrangements – should be in place for the care of community assets, infrastructure and public realm, for the benefit of the whole community.

x. Future proofed – designed to be resilient places that allow for changing demographics, future growth, and the impacts of climate change including flood risk and water availability, with durable landscape and building design planned for generations to come. This should include anticipation of the opportunities presented by technological change such as driverless cars and renewable energy measures.

3. The Council and the landowner/developer jointly to lead the masterplanning approach;

4. The masterplanned approach is to include determining appropriate phasing of development, to be linked to the relevant and strategic delivery of infrastructure, including in terms of surface water; in particular the provision of high quality, multiple benefit Sustainable Urban Drainage systems, foul water, refuse collection, etc., utilising industry best practices and where feasible, new and emerging technologies (see Water Policies EN 26 to EN 29, criteria 2 and 10 of Policy EN 1: Design and other development management criteria, and Policy ED 3: Digital Communications and Fibre to the premises);

5. The masterplan shall be informed by detailed studies within and surrounding the allocation that shall include land use, landscape character, visual amenity, biodiversity and heritage. Particular attention will be given to:

i. The grade of agricultural land and agricultural activities to minimise the effects on the rural economy and agricultural functionality (see Policy EN 22: Agricultural Land);

ii. Key landscape characteristics, views and the setting of heritage assets and the setting of the High Weald AONB (see Policies EN 1: Design and other development management criteria, EN 20: Rural Landscape and EN 7: Heritage Assets);

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 Policies EN 11: Net Gains for Nature: biodiversity and EN 12: Protection of designated sites and habitats);

iv. The layout to particularly respect the setting of heritage assets, especially All Saints’ Church, and to investigate how Hadlow Tower will be viewed from within the development (see Policy EN 7: Heritage Assets);

6. The layout and design is to be of the highest exceptional quality which raises the standard of design within Tunbridge Wells Borough. , with exceptional The development shall be permeable ility and with low levels of private car use within the settlement. The design quality, as an exemplar, to be one of the justifications for the release of Green Belt land (see Policies EN 1: Design and other development management criteria and EN 20: Rural Landscape);

7. Opportunities to provide a higher density of development around the settlement centre and other key points within the development should be maximised, and structural landscaping and buffers around perimeters of the site shall be provided (see Policy H 4: Housing Density, criterion 3 of Policy EN 1: Design and other development management criteria, and Policy EN 20: Rural Landscape). In particular, the masterplanning must have regard to the need to ensure the visual separation between Tudeley Village and Five Oak Green, and the potential to feasibility of ‘undergrounding’ overhead power cables;

8. Provision of defensible boundaries at the site edges as part of a strategic landscape strategy to protect and enhance the surrounding compensatory improvements to the environmental quality and accessibility of remaining Green Belt within the locality shall be made, to be agreed and secured through the masterplanning approach ;

9. Transport provision shall be delivered on a strategic basis, taking The transport strategy for the site shall take account of the impact of proposed development at land at Capel and Paddock Wood, withhaving regard to transport infrastructure links between Paddock Wood, Tudeley Village, Tonbridge, and Royal Tunbridge Wells. A key element will be determining the most appropriate route to link to the road network to the east access strategy, which shall minimise the impact on the existing highway network through Five Oak Green, and should seek to reduce traffic levels through this settlement, and have regard to Kent County Council minerals allocations in the vicinity and sensitive receptors such as Capel Primary School. Contributions will be required towards local transport improvements the provision of the potential offline A228 and eastward link to the A228 or land at Capel and Paddock Wood ;

10. A strategic approach to increase walking and cycling permeability will be included in the masterplanning (see Policy TP 2: Transport Design and Accessibility): development to be structured around direct walking and cycling routes, linking new development with existing community facilities (e.g. primary school), public transport, employment, and commercial centres. Improvements to pedestrian/cycle links across the railway to be sought, subject to viability issues; the provision of longer distance cycle links to land at Capel and Paddock, Tonbridge, and villages surrounding Paddock Wood (leisure and utility); embracing new and emerging technologies and maximising public transport provision (frequency, linkages, etc.) using new technology. New development to be designed appropriately to

facilitate provision of bus routes within allocated sites, linking into wider bus network;

11. Provision shall be made for appropriate education facilities, or contributions towards such facilities. Development at this site is subject to the provision of land for a new secondary school to the west of Tudeley Village (and to the east of Tonbridge) to be allocated under Policy AL/CA 2, a new primary school within Tudeley Village, and provision for the expansion of Capel Primary School, with delivery linked to an overall delivery timetable (to be determined through the masterplanning process) ;

12. Provision shall be made for sports and recreation facilities (see Policy OSSR 2: Provision of publicly accessible open space and recreation);

13. Provision shall be made for appropriate health facilities, or contributions towards such facilities;

14. 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 ;

15. The settlement will be expected to include the provision of a scheme of management and funding for green spaces and green infrastructure for both amenity and biodiversity for the lifetime of the development.

16. 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.

[TWBC: see full representation].

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

DLP_6996

Turnberry for Hadlow Estate

Support with conditions

1. Introduction

1.1. This representation is submitted on behalf of the Hadlow Estate concerning Tunbridge Wells Borough Council’s spatial strategy and specifically, the allocation of a new village at Tudeley under Policy AL/CA 1.

1.2. The Estate recognises the acute housing shortage facing the Borough, indeed the country, and has supported the principle of a new community at Tudeley on the basis that it will be seen in the same context of the approach adopted by the Prince’s Foundation at Poundbury, Tregunnel Hill and Truro, as well as other landowners in Scotland at Tornagrain and Chapelton.

1.3. To rank alongside these projects, Tudeley Village requires a long-term commitment and involvement throughout the planning and construction process. At the conclusion of the project, the new village will be regarded as nationally significant in terms of UK town planning: that is the standard that will be delivered. This is consistent with the values and tradition of the Hadlow Estate which has a 170 year connection to the history and stewardship of the land and will live alongside Tudeley Village once the project completes.

1.4. Freed from the burden of purchasing land or retuning dividends to shareholders, the Hadlow Estate can invest in placemaking and create an exceptional and vibrant community with high quality housing. Tudeley Village is therefore distinct from any other strategic proposition in the Draft Plan.

1.5. Therefore, whilst we naturally support the general aspirations and content of the Plan which has been positively prepared, it is important for the emerging policies to align completely with the aspiration of the Estate and our intended delivery process so that the Council’s spatial vision and aspiration for Tudeley Village are fully realised. On that basis we make a series of corrections and adjustments to the Draft Plan.

1.6. The following comments should therefore be registered as Conditional Support for the overall Draft Plan, whereby our client would likely raise no objections, provided our suggested modifications are incorporated in order to put the Draft Local Plan on a Sound footing. However, there are some Development Management Policies where we raise specific and targeted objections. Notwithstanding this, the changes suggested in this representation are easily remedied and we clearly set out how the Plan can be improved to enhance the clarity of the Spatial Vision and its delivery.

1.7. Our representation is structured as follows: In Section 2 we set out the case for Tudeley Garden Village with particular emphasis on ensuring the supporting evidence base is clearly expressed i.e. justified and effective in accordance with the tests of Soundness. In support of this analysis, we explain why Tudeley goes beyond the general garden settlement principles set out in the draft Plan.

1.8. We then discuss the additional evidence Hadlow Estate is collecting in support of the proposal within Section 3 which will move us towards a delivery plan for the proposed development.

1.9. Sections 2 and 3 have informed specific changes we would like to make to the wording of the Draft Plan to ensure its Soundness and these are set out in Section 4.

2. The case for Tudeley

2.1. We have reviewed the Draft Plan and its supporting material to assist the Council in ensuring the evidential basis for the Plan is both robust and justified, particularly in its identification of Tudeley as a new village for 2,500 – 2,800 homes. We begin with the macro issues which drive the need for the new Local Plan i.e. Housing Need, before moving to the response to that need, the Spatial Strategy and the clear justification for selecting the site. We conclude with some commentary on how the principles of a new garden community at Tudeley are expressed and what it actually means in terms of Tudelely becoming an exemplar development in the tradition of notable UK Garden Villages.

Housing Need

2.2. Appendix A, Stantec have undertaken an audit of the Council’s approach to assessing housing need to ensure that it accords with National Planning Guidance. Although the approach has been found to be positively prepared, there are areas which the Council need to address to ensure the Plan is as robust as possible before Submission.

2.3. These matters include:

a. More headroom in terms of overall housing numbers is required to manage potential risks such as for example, addressing unmet need arising from neighbouring authorities or future revisions to the Standard Method;

b. The Plan period may need to be extended to address potential delays so it is compliant with paragraph 22 of the NPPF which requires a 15 year plan period from adoption;

c. An extension of 5 years to the plan period would give the Council additional ‘headroom’ to manage these risks before the shortfall requires to be plugged;

d. The Council should not include its housing backlog in the Standard Method: its housing need should be re-set from submission;

e. Finally, the Council needs to update its economic evidence which is not in step with its housing evidence and may point towards

additional housing need. This should be resolved now in advance of Submission.

2.4. The Draft Plan is therefore positively prepared, but further work is needed to ensure it is consistent with national policy and justified.

Spatial Strategy

2.5. The Council has undertaken a rigorous process to construct an evidence base that justifies its proposed Development Strategy:

a. The Borough constraints have been mapped:

b. Development Constraints Study; The potential for expansion of existing settlements has been assessed: Limits to Built Development Topic Paper;

c. In particular, the capacity of the landscape around the principal urban centres at Tunbridge Wells and Southborough has been reviewed: Landscape Sensitivity Assessment;

d. Consultation on growth options has taken place: Distribution of Development Topic Paper;

e. The relative sustainability of the Growth Options has been assessed: Interim Sustainability Report;

f. An understanding of the quantum and location of land that could come forward for development has been established: Call-forsites and SHELAA.

2.6. The Distribution of Development Topic Paper helpfully brings these matters together to explain the steps that led to the proposed Development Strategy within the Draft Plan. It should be noted however, that the Issues and Options consultation, whilst highlighting the constraints associated with the different growth options, did not directly and spatially relate the Growth Options to the Development Constraints. The responses to the Growth Options are therefore potentially abstract, particularly when contrasted with the detail of the responses in the Issues and Options Consultation Statement which prioritise the preservation of the AONB and therefore directly aligns with paragraph 172 of the NPPF demanding ‘great weight’ is attached to conserving their landscape and scenic beauty.

[TWBC: for Figure 1 see full representation].

2.7. Limiting the extent of development within the AONB should therefore be a key finding of the Issues and Options consultation and should be highlighted as such to ensure the Development Strategy is situated on a firm, evidential and justified basis. This is not the case at present, although the assessment of allocated sites inside the AONB within the Distribution of Development Topic Paper appears robust.

2.8. The other key factor to consider in locating development is proximity to the key employment hub of Tunbridge Wells, Paddock Wood and Tonbridge, as evidenced in the Economics Needs Study (August 2016) and in particular, Figure 5.4 (see Figure 1, above).

2.9. Although economic factors are assessed within the individual options for new communities in Table 3 of the Distribution of Development Paper, as a key principle influencing development strategy, this point is not expressed sufficiently. Locating development distant from these strategic employment and service centres, irrespective of the degree of containment sought for new communities, would not be sustainable as it would give rise to higher out-commuting and would not be sustainable.

2.10. The need to relate new development to these economic centres prevents effective consideration of areas east of Paddock Wood, which are not constrained by Green Belt. Therefore, whilst the Distribution of Development Paper sets out a clear case for the release of land from the Green Belt, identifying the Exceptional Circumstances at Paragraph 6.48, this must be amended to make clear the need to locate development sustainably, i.e. in amongst existing economic centres. This clarity will complete the evidential base on which the proposed Development Strategy is based, justifying it and therefore making the Draft Plan Sound.

2.11. We have undertaken an independent analysis of the Council’s evidence base in respect of the review of the Green Belt and this analysis is set out in Section 3. It reaffirms the findings of the Council in this respect, but we return to this report later in terms of its main focus on identifying a defensible boundary for the proposed allocation.

2.12. However, we do consider that the Exceptional Circumstances should be elevated into the Draft Plan, at the end of Section 2 so they provide a link between Challenges and Opportunities and the response, i.e. the Vision, Objectives and Development Strategy. This would clearly evidence and justify the spatial strategy in response to the survey of the Borough.

2.13. Therefore, whilst we have suggested modifications to how portions of the evidence base need corrected or enhanced to make the proposed spatial strategy Sound, we are in support of the principle that Tudeley Village, as a new community, is the least harmful, yet most sustainably located spatial response to accommodating housing need in the Borough.

Proposed Vision for the Draft Plan: Upholding the principles of a Garden Community

2.14. On the basis the overall spatial strategy is sound, subject to evidential changes and enhancements, we now examine the proposed Vision in the Draft Plan insofar as it relates to Tudeley Village.

2.15. The Vision is very specific in referring to Tudeley Village as a ‘garden settlement’ that will be subject to garden settlement principles. These principles are not defined in the draft Local Plan but in the Distribution of Development in Table 3, the selection criteria for a site is linked to paragraph 72 of the NPPF. The assessment of Tudeley Village is related to the Garden City principles in this paragraph, as articulated by the Town & Country Planning Association and reflected in the Government’s request for Garden Community proposals in their Prospectus dated 4th June 2019.

2.16. In that document they identified the following:

a. Clear identity – a distinctive local identity as a new garden community, including at its heart an attractive and functioning centre and public realm.

b. Sustainable scale – built at a scale which supports the necessary infrastructure to allow the community to function self-sufficiently on a day to day basis, with the capacity for future growth to meet the evolving housing and economic needs of the local area.

c. Well-designed places – with vibrant mixed use communities that support a range of local employment types and premises, retail opportunities, recreational and community facilities.

d. Great homes – offer a wide range of high quality, distinctive homes. This includes affordable housing and a mix of tenures for all stages of life.

e. Strong local vision and engagement – designed and executed with the engagement and involvement of the existing local community, and future residents and businesses. This should include consideration of how the natural and historic environment of the local area is reflected and respected.

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.

g. Healthy places – designed to provide the choices and chances for all to live a healthy life, through taking a whole systems approach to key local health & wellbeing priorities and strategies.

h. Green space – generous, accessible, and good quality green and blue infrastructure that promotes health, wellbeing, and quality of life, and considers opportunities to deliver environmental gains such as biodiversity net gain and enhancements to natural capital.

i. Legacy and stewardship arrangements – should be in place for the care of community assets, infrastructure and public realm, for the benefit of the whole community.

j. Future proofed – designed to be resilient places that allow for changing demographics, future growth, and the impacts of climate change including flood risk and water availability, with durable landscape and building design planned for generations to come. This should include anticipation of the opportunities presented by technological change such as driverless cars and renewable energy measures.

2.17. It is recognised that many developments around the country will state they comply with these principles and this will be the case to a greater or lesser extent. However, the Hadlow Estate are seeking to place Tudeley Village firmly within the tradition of Garden Village planning in the UK as seen in Letchworth Garden City, Welwyn Garden City, Port Sunlight and Bournville, now protected as Conservation Areas with many Listed Buildings and visited by town planners from around the world. An overview of the history and significance of these communities, and why they matter today, is provided in Appendix B.

2.18. The legacy of these communities has inspired others, including the Hadlow Estate who ally themselves with the work of other estate landowners at, for example, Poundbury, Chapelton and Tornagrain.

2.19. These developments have three characteristics which the majority of other planned garden communities cannot deliver and the principles set out above by Government do not adequately capture:

a. Landowner-led: the presence of a single, long-term landowner with a vested interest in the site and an aspiration towards leaving a legacy is in contrast to the majority of new development schemes where a developer has no long-term financial stake in the land. Their priorities lie in the immediate satisfaction of their shareholders. The difference this makes is enormous. Development by a single, long-term landowner is, arguably, the only route that allows an extended, measured view of development. The ability to adopt a patient perspective on financial returns creates considerable opportunity to innovate beyond the norm. With it, the premium that highly crafted construction, well-considered design and mixed use will reap over time can be appreciated. Ultimately, this will secure a better place in the long run. This approach is grounded in the principle of capturing uplift that informed the original Garden Cities and model villages. Both Letchworth and Welwyn were, for example, delivered by single bodies acting as the landowner, which were able to capture the land value uplift resulting from development. This uplift then financially supported the delivery of the towns’ physical and social infrastructure. The process of capturing land value gains takes time, though, and thus is often not attractive to conventional investors.

b. Mixed use: Commercial and employment uses are firmly integrated within the residential fabric of the community, including the ability to ‘live over the shop’. This level of integration is often too complex for more simplistic developments to accommodate as they inevitably rely on larger contractors delivering single-use development plots. This leads to a physical separation and disaggregation between housing and non-residential uses. The free-standing neighbourhood centre clustered around a car park is anathema to a square, high street or high road. Moreover, developments such as Poundbury would boast that it has as many jobs as it has residents, whilst Chapelton had 30 employees by the time it had only 125 occupations. Conventional housing developments cannot deliver these statistics.

c. Stewardship: Long-term landownership also facilitates long-term stewardship. It captures the original ethos of Garden City governance, which meant that stewardship was undertaken for the benefit of the community and that the community had a stake in the settlement’s future. For the original Garden Cities, model villages and contemporary exemplar planned settlements, having a collective vision was fundamental to building momentum in the creation of community identity. Stewardship bodies have historically, and continue to be, valuable means of supporting this vision.

2.20. Their roles can be summarised under two main functions:

  • Design regulation, via building codes applicable during initial development and any subsequent alterations
  • Maintaining common, unadopted areas of the community

2.21. In so doing, they act as a vehicle for sustaining and protecting in perpetuity the unique features of the settlement – its buildings, public realm, facilities and their characteristics and identity – that encourage civic pride, identity and interaction. This in turn leads to greater value being placed upon community spirit, encouraging sound investment and creating benefits for those who live, work or visit the settlement.

2.22. This long-term, guardianship role is very different from the objectives of the private management companies set up to service residential estates that are found across the country. The latter are used by developers as a means of disposing of the obligation and liability of maintaining non-adopted space without the cost of providing resources for future maintenance, such as an endowment or commuted sum.

2.23. These principles in operation are illustrated with Case Studies in Appendix B. We therefore see the new community set out in the Vision as going beyond ‘garden settlement principles’ and will seek the appropriate changes to the text to ensure it the Vision is Effective.

2.24. The Estate therefore has the means and control over the land to deliver the Vision in the Draft Plan against the benchmark of those which sit firmly within the historic tradition of garden villages, as opposed to the broader principles articulated by the Government.

3. Delivery

3.1. Notwithstanding the draft status of the Plan, the Estate has progressed with its own evidence base to support delivery, namely:

Ecological Appraisal:

3.2. A preliminary ecological appraisal has been undertaken to inform the development of the Tudeley Village proposal. This comprises a Phase 1 habitat mapping survey and a desk-based ecological assessment and builds on recent review of existing biological information for the Site and local area provided by the Kent and Medway Biological Records Centre.

3.3. No land within the Site is designated by any statutory or non-statutory wildlife site designation, and the Site is not located close to any Site of Special Scientific Interest (SSSI) or other statutory designated wildlife site.

3.4. Figure 2 shows the Site’s existing network of high ecological value habitats – namely: woodland; species rich hedgerows; scrub; traditional orchard; and tree canopies (outside of woodland) as interpreted from aerial photos.

3.5. The Appraisal has identified sites of existing high ecological value including veteran trees and four areas of ancient woodland, which will be retained and protected as part of any future development. To this end, buffers are suggested around key habitats based on best practice (Woodland Trust) guidance that suggests a minimum 50m no development stand-off buffer around ancient woodland. Further ecological work in line with seasonal timings and accepted practice for gathering survey data is underway.

[TWBC: for Figure 2 see full representation].

Heritage Appraisal:

3.6. An initial Heritage Constraints Appraisal has been undertaken, which established a ‘heritage baseline’ for the site area (plus a 1km buffer zone), identifying areas of particular value as shown on Figure 3. Such areas include:

  • The grade I listed Church of All Saints’ and nearby listed buildings
  • The listed buildings at Bank Farm and Lilley Farm in the centre of the study site
  • The listed buildings present along the southern boundary of the study site, along Five Oak Green Road
  • The listed buildings in Tudeley
  • The listed buildings at Tudeley Hale
  • Views from Somerhill house and park

3.7. The above constraints were carefully considered and it was found that, provided approrpiate spatial design responses are provide for within the proposed new settlement, it would be possible to deliver the development of Tudeley Village while preserving the significance of the Church of All Saints’, Somerhill House and registered park and the buildings in Tudeley and Tudeley Hall. Any residual harm to the listed buildings at Bank Farm, Lilley Farm and those present along the southern boundary of the site on the Five Oak Green Road would be kept to a low level of less than substantial harm, with the potential to avoid harm and/ or provide enhancements in some instances.

3.8. The remaining designated heritage assets in the surrounding area were also appraised and it is not considered that these would constrain the delivery of the proposed new settlement. However, they would still require assessment and consideration as the proposed settlement design is developed further and in any future planning application.

[TWBC: for Figure 3 see full representation].

Archaeological Appraisal:

3.9. An initial review of archaeological potential has confirmed that the study site has a moderate potential to contain prehistoric, Saxon and Medieval evidence and known heritage assets from the PostMedieval period. There is also potential for remains associated with the Saxon and Medieval occupation at Tudeley to be present in the westernmost part of the study site, primarily close to the Church of All Saints’. Post-Medieval remains would comprise buried remains associated with the occupation of the farmsteads at Bank Farm and Lilley Farm, which would be focussed on the extent of the historic farmsteads.

3.10. The assessment of archaeological potential on site concluded that any remains are likely to be of no more than local interest. Given this, it is considered that the loss of any archaeological remains within the study site could be adequately mitigated via a staged programme of archaeological works including mitigation works to adequately record any remains which would be lost as a result of the proposed development. Approrpiate recording and publication would enhance our understanding of these periods of settlement.

Landscape and Visual Appraisal:

3.11. An initial appraisal of the landscape setting for Tudeley has been prepared.

3.12. The High Weald Area of Outstanding Natural Beauty Management Plan 2019-2024 defines five components of character that make the High Weald a recognisable, distinct and homogenous area. These include the following; (1) Geology, Landform, Water Systems and Climate, (2) Settlement, (3) Routeways, (4) Woodland and (5) Field and Heath. A further category of Other Qualities is also highlighted, which include ‘People value the wonderful views and scenic beauty of the High Weald with its relative tranquillity’. It is considered that none of these components are capable of being directly or significantly affected by the Tudeley Village proposals, which lie outside the AONB.

3.13. Whilst Tudeley Village would lie outside the High Weald AONB and, at this stage, the exact nature of the development proposals is not known, it is

evident that development at the site would be seen from the AONB and seen within the setting of the AONB. However, whilst being in the foreground of views out from the AONB, the assessment has demonstrated that only a very small part of the new development would be visible and from only a very limited number of locations. The assessment considers that these visual effects would also be capable of being substantially moderated through suitable mitigation proposals (e.g. the precise location of the development, landscape planting and its early phasing) and, consequently, any adverse effects on the setting of the AONB are capable of being moderated.

Green Belt Review

3.14. The NPPF envisages that plan-making authorities may move Green Belt boundaries in order to deliver sustainable and objectively assessed development needs, where there are fully justified exceptional circumstances. Authorities must have regard to the likely permanence of any revised Green Belt boundaries which should reflect the strategy for meeting identified requirements and for safeguarding land outside the revised Green Belt that may be required for future development needs beyond the plan period.

3.15. The Council has defined in the Distribution of Development Topic Paper, September 2019, the exceptional circumstances that they consider exist for the release of Green Belt land within the borough. These include, the extent of Green Belt and AONB constraints, the acute need for development land to be brought forward through the Local Plan and the inability for neighbouring authorities to assist in meeting Council’s need. They consider that they have maximised the use of urban sites, optimised development densities and they have considered all suitable sites outside of the Green Belt (and, for major sites, outside of the AONB).

3.16. The council also consider further exceptional circumstances exist for the release of the land for Tudeley Village. These are to provide mitigation measures to reduce flood risk associated with Five Oak Green and to offer an opportunity to deliver development of exemplar design quality, with exceptional permeability and low levels of private car use. The Hadlow Estate is seeking to place Tudeley Village firmly within the tradition of Garden Village planning in the UK and they ally themselves with the work of other estate landowners at, for example, Poundbury, Chapelton and Tornagrain. These developments have characteristics which the majority of other planned garden communities cannot deliver and the principles set out above by Government do not adequately capture. These characteristics, of being long term landowner-led with long-term stewardship, will be fundamental to the delivery of the required exemplar design quality.

3.17. The suggested Green Belt boundary, revised to accommodate Tudeley Village, is considered to provide for enough land to meet with TWBC’s strategic requirement for identified need and the boundaries proposed by the Hadlow Estate are clear, using physical features that are recognisable and permanent. No land has been included which is unnecessary to keep permanently open or that is safeguarded between the urban area (as yet undefined) and the new Green Belt boundary.

3.18. Evidently, the development of the land for Tudeley Village would have a direct effect on the existing Green Belt and impact to some degree on the first three of the five purposes set out at Paragraph 134 of the NPPF. However, the retained Green Belt between Tonbridge, Tudeley Village and Paddock Wood would be clearly and robustly defined and would prevent urban sprawl, neighbouring towns from merging with one another and safeguard the countryside from encroachment, into the long term.

3.19. We will be working with the Council to precisely define the new Green Belt boundary.

Infrastructure:

3.20. The Estate has commissioned advice on the necessary infrastructure to support the implementation of Tudeley Village, such as:

  • The development of an active travel and public transport strategy to ensure sustainable connectivity with key employment centres to reduce demand for car-based travel;
  • An access strategy that responds to the requirements of Policy AL/CA 1 is being developed at an early stage. As further analysis is undertaken, the access strategy may change from that suggested in the Policy and alternative approaches may come forward. It is therefore important to allow for that flexibility in the draft policy;
  • Establishing the nature of flooding issues at Five Oak Green and the hydrological relationship between that area and land in and around the site identified for Tudeley Village;
  • Related to the above, a strategy for Sustainable Urban Drainage, as well as waste water. This will include the necessary mitigation measures to protect the Groundwater Source Protection Area.

3.21. This work is ongoing and discussions will be held with key stakeholders, including the Highway Authority and Environment Agency. The Estate wishes to move towards a specific delivery plan for Tudeley to support the Submission version of the Local Plan.

3.22. The early involvement of our engineers has been helpful in clarifying some aspects of Policy AL/CA 1 so it is clearer and therefore Effective. These minor modifications are set out in the following section.

Agricultural Classification

3.23. Prior to 1988 different versions of the ALC system existed. The original system dates from the 1970s and the grade criteria are different to those now in use. Moreover, there was no division of grade 3 into subgrades 3a and 3b. The only national coverage of ALC information is made using this earlier system. They are published at small scale (1:1,250,000) reflecting the fact they are based on very limited density of field survey observations (often as low as 1 per square km) and rely on interpolation of published soil and geological maps. For these reasons Natural England Statutory consultee advice is that: ‘these maps are not sufficiently accurate for use in assessment of individual fields or development sites’.

3.24. Provisional mapping shows most of the site as grade 3, with grade 2 in the north-west. However, as explained above, this does not give an accurate indication of the existence or otherwise of best and most versatile land.

3.25. Several detailed surveys (to the current guidelines) have taken place in the local area. Those most relevant to estimating the grade of the (unsurveyed) land at the Site are those recorded on the same geology and/or soil type.

Relevant Ministry of Agriculture, Fisheries and Food detailed Agricultural Land Classification surveys in the locality of the Site:

Survey location

Recorded BGS geology

Recorded Soil Survey of England and Wales soils

ALC land grade

Natural England Report ref.

West of Paddock Wood

Drift deposits (silt and clay)

Park Gate Association

All subgrade 3b

R200/93

North-east of Paddock Wood

Drift deposits (silt and clay)

Park Gate and Fladbury 3 Associations

All subgrade 3b

R199/93

East of Paddock Wood

Drift deposits (silt and clay) west Wealden Sandstone in east

Park Gate series Wickham series

Subgrade 3b with subgrade 3a (32%)

R0628/91

South-east of Paddock Wood

Wealden Sandstone, Head and Alluvium

Whickham series Denchworth series

Subgrade 3b with subgrade 3a (35%)

R528/91

3.26. The land at the site seems most likely to be dominated by a mixture of subgrade 3b and 3a land. This is typical quality for the local area. The exact proportions of each could only be determined by a detailed land survey, but this is the case with any proposed site. The effect on best and most versatile agricultural land is likely to be limited in the local context and most of the site is likely to have soils of no particularly high value.

3.27. The majority of the land is farmed by the land owners as part of a wider holding. The loss of this land would not compromise the sustainability of the wider farming business. There is a livery business owned by the Estate, but this is likely to be relocated ahead of development.

3.28. The land to the north of the railway, including the smaller area of fruit production in the north-west is operated by a tenant as part of a wider holding which extends beyond the site. The loss of this land would have some impacts on the operation of their business, but this area of the site will not be needed for some time. This allows sufficient time for the tenant to plan or adjust operations. Indeed, the tenancy may revert back to the Estate before development commences in this area.

Consultation:

3.29. The Estate is keen to engage with the local community and other stakeholders to begin a visioning process for Tudeley Village. This process will commence alongside the Local Plan process and will help inform the draft policies insofar as they relate to Tudeley Village.

3.30. These workstreams underline the commitment of the Estate to be an effective delivery partner in implementing the Vision of the Draft Plan.

4. Sustainability Appraisal

4.1. This initial evidence will therefore have an impact on the SA Scores in Table 16 which appraises Growth Options 1 and 2 for Tudeley Village. As we are not seeking to promote a larger site, we have recalibrated the SA scores for Growth Option 1, as shown in our revised Table 16 below.

4.2. These changes produce a more accurate SA appraisal for the site. Many of these scores would of course in many instances apply to any development, but the following are unique to Tudeley Village:

  • The proximity of the site to strategic urban and employment areas leads to higher scores in terms of Employment, Services & Facilities, and Travel;
  • The site is outwith any historic or AONB landscapes;
  • The potential to mitigate flooding at Five Oak Green is a significant benefit under climate change;
  • The wider Hadlow estate can be leveraged in support of biodiversity improvements. The Estate has experience in wildlife conservation, biodiversity and habitat improvements as evidenced by the long standing partnership with the RSPB on Hadlow Estate land at Tudeley Woods, amongst other initiatives. In short, the impact of Tudeley Village is far less, if not more beneficial, than other spatial options available to the Council, with the majority of metrics scoring above neutral and only two minor negatives.

4.3. Indeed, we would question the SA scores given to isolated, rural and more distant sites, many scoring neutral on matters which relate directly to their scale and connectivity to urban centres, or in their case, a lack of it. This is a potential flaw in the SA which could make the plan unsound and we would ask that the negative locational implications of distant centres are reflected in the SA and there is greater moderating based on the themes discussed under Spatial Strategy in Section 2 above.

Revised SA Appraisal for Garden Settlement Growth Option 9 - Table 16, SA of the Spatial Strategy

Sustainability Objective

Garden Settlement Growth Option 1

Commentary

Air

?

No change

Biodiversity

+

The ecological constraints are identified and will be mitigated through sensitive masterplanning. As the site is intensively farmed and on the basis the Hadlow Estate extends beyond the allocation, there is opportunity to create net improvements in biodiversity.

Business Growth

+

No change

Climate Change

++

Potential to mitigate the impact of climate change on Five Oak Green

Deprivation

++

We note that some rural locations are scoring neutral under deprivation despite the increasing issues around fuel poverty. We have made an adjustment in response to reflect the fact there is less need to travel and that there are more non-car based solutions available.

Education

+/++

No change

Employment

+++

We note that isolated rural locations such as Frittenden were scoring a positive for employment despite its distance and lack of infrastructure, so we have adjusted the scoring to reflect that.

Equality

++/+++

No change

Health

++

No change

Heritage

0

Enhancement and public benefit will off-set any harm

Housing

+++

No change

Land Use

-

The farmland is not the most productive and therefore its loss cannot attract the most significant impact

Landscape

-

As the site is outside the AONB and historic landscapes, it cannot attract the most significant impact. The negative rating relates to its Green Belt status.

Noise

0

The sources of noise are typical of urban environments and can be mitigated

Resources

0/+

No change

Services & Facilities

+++

No change

Travel

++

No change

Waste

0

No change

Water

++

The benefits accruing to Five Oak Green arising from the development means this is a decisive enhancement.

[TWBC: for table showing colour coding see full representation].

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

DLP_2020

Dr David Parrish

Object

Tudeley Map 37 AL/CA1 (Tudeley Village) Page 157

The call-for-sites land details supplied to TWBC by Hadlow Estate is incorrect

It needs to be corrected

There are at least 4 Freehold dwellings annotated incorrectly as Hadlow Estate property. Mine is one of them.

There are probably many more unknown, incorrect, details supplied to TWBC

All tied properties belonging to Hadlow Estate have been included in the Red Zoned Area – other freehold properties have been excluded from the Red Zoned area of Hadlow Estate. 1, 2, 3, 4 Bank Farm Cottages, Sherenden Road HAVE NOT. This is wrong.

Hadlow Estate have made errors (with intention or with laziness to check – raising false assumptions) – which means the TWBC have also not bothered to check the details either

DLP_3687

Capel Parish Council

 

This policy envisages too many new dwellings, completely out of proportion to its environment. They are entirely unsustainable in this rural area with a limited infrastructure. Capel Parish Council believes this proposal is unsustainable and therefore unsound – clearly not of a sustainable scale as claimed here. CPC is also troubled by the call for a ‘clear identity’ by which we take something similar to Poundbury, which would be an unwelcome urban intrusion into this rural Low Weald Medway Valley landscape. We believe this is what the landowner intends, and we believe he should not be allowed a free hand.

If this development were to materialise, we believe TWBC should insist that all infrastructure (transport services, new roads and road improvements) must be delivered before construction of housing begins. We believe the added flood risk cannot be fully mitigated against and the site contributes negatively to climate change.

DLP_3604

Southern Water Services Plc

Support with conditions

Southern Water is the wastewater undertaker for Capel Parish, and has a statutory duty to serve new development. Proposals for 2500-2800 dwellings within this catchment will significantly increase its size, requiring detailed analysis of the various engineering solutions available to accommodate increased demand on the existing network. Our preliminary assessment of the capacity of our existing infrastructure and its ability to meet the forecast demand for this proposal demonstrates that existing local sewerage infrastructure has limited capacity to accommodate the proposed development. Limited capacity is not a constraint to development provided that planning policy and subsequent conditions ensure that occupation of the development is phased to align with the delivery of new wastewater infrastructure.

For development of this scale, a strategic masterplanning approach on infrastructure delivery is required, and Southern Water supports criteria 4 of Policy AL/CA1 which links appropriate phasing of development to the strategic delivery of infrastructure. Connection of new development at this site ahead of new infrastructure delivery could lead to an increased risk of flooding unless the requisite works are implemented in advance of occupation. Southern Water has limited powers to prevent connections to the sewerage network, even when capacity is limited. Planning policies and conditions, therefore, play an important role in ensuring that development is coordinated with the provision of necessary infrastructure, and does not contribute to pollution of the environment, in line with paragraph 170(e) of the revised National Planning Policy Framework (NPPF) (2019).

In consideration of the above, we recommend the following text is added to criterion 4 of Policy AL/CA 1

4. The masterplanned approach is to include determining appropriate phasing of the occupation of development, to be linked to the relevant and strategic delivery of infrastructure, …

DLP_4550

Historic England

 

Policy AL/CA 1: Tudeley Village - Tudeley and Tudeley Hale form a dispersed settlement consisting largely of isolated farmsteads and cottages, many of which are listed at Grade II, set within an open, gently undulating agricultural landscape. Despite its proximity to Tonbridge, its rural and remote character is noteworthy. Tudeley is renowned for its Grade I church which is internationally famous for having all of its stained glass windows designed by Marc Chagall. The Somerhill estate, and its Grade II Registered Park and Garden and Grade I main house,  lie adjacent to the west and Tudeley has historic connections to it which remain understandable in the landscape today. It historically formed part of its wider estate and the fields proposed for allocation can be seen from the eastern end of the Registered Park and Garden and vice versa. The connection can also be seen in the listed estate cottages that abut the proposed site (Crockhurst Farm and Crockhurst Street Cottages), which clearly follow an estate pattern with repeated detailing. The connection is reinforced in the church where the Chagall windows were added to the church as a memorial to Sarah d'Avigdor-Goldsmid, whose parents owned the Somerhill estate at the time of her death.

The church is situated directly abutting the western side of the proposed allocation site, and although internationally significant artistically for its stained glass, it is also significant as a good example of an isolated medieval and post medieval Kentish church set within an unspoiled agricultural setting.

It not clear to us whether this site has been fully assessed for its potential impact on the historic environment. We have serious concerns about the site allocation in this location in view of the significances of the heritage assets potentially affected by development in their proximity, and the historic landcsape charater that relates to them and links them together. Large scale development as proposed potentailly would remove much of the rural and isolated character of the landscape and compromise the setting of numerous listed buildings, including the Grade I church, and therefore impact upon their significance in harmful way. A detailed evidence gathering programme should be carried out to inform a robust heritage impact assessment in advance of the adoption of the draft local plan.

DLP_3927

IDE Planning for Paddock Wood Town Council

Object

OBJECT as per STR/PW1 below

[see DLP_3930 in Section 5: Paddock Wood]

DLP_2491

Mr John Wotton

 

Policies STR/CA 1 and AL/CA 1

object to these policies, which provide for a new settlement of 2,500-2,800 new homes on greenfield sites in the Green Belt, misleadingly named "Tudeley Village", for the reasons given by CPRE Kent in their response to this consultation. I have visited the sites, had detailed discussions with the Save Capel campaign group and spoken at a public meeting which they convened. I support their objections to this proposed development.

DLP_2640

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_3425

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_4477

Paddock Wood Neighbourhood Plan Steering Group

 

No comment

DLP_2789

Mrs Karen Langston

Object

Policy Number: STR/CA 1 and AL/CA 1

I strongly object to the proposal to create a standalone garden settlement in Tudeley of 2,500-2,800 dwellings.

Whilst the public consultation on the Issues and Options document resulted in some support for growth strategy 5 – growth within a new, free-standing settlement, the strong view within that feedback was that this settlement should not be in the Green Belt or AONB. However, the site proposed lies entirely in the Green Belt, and partially in the AONB.

The NPPF attaches great importance to Green Belts, stating that their essential characteristics are “their openness and their permanence.” (NPPF paragraph 133) It sets out five purposes for the Green Belt designation and protection, which includes, “b) to prevent neighbouring towns merging into one another;” and “c) to assist in safeguarding the countryside from encroachment.”

The NPPF allows for changes to Green Belt boundaries where, “exceptional circumstances are fully evidenced and justified.” (NPPF paragraph 136). The draft Local Plan appears to suggest the “exceptional circumstance” in this case is the need to meet an untested housing target. As I argue elsewhere in my feedback, this target is based on out-of-date data, resulting in a much higher figure for new homes than the borough actually needs. In addition, the total number of new dwellings proposed in the draft Plan, through strategic site allocation, excluding windfall, exceeds this target by 1,240 dwellings.

If you consider the extremely high cost of destroying Green Belt land, the strain on inadequate infrastructure to ensure timely sustainability, the destruction of an existing community, including displacement of tenants, the impact on the environment and the failure to safeguard the countryside from encroachment, I argue that this is far from “exceptional circumstance” to justify the proposed development. Had the swathe of land not been offered by a single land owner through the Call for Sites process, I argue that this location would never have been considered suitable, sustainable or desirable for the creation of a free-standing settlement. The site allocation and subsequent policy AL/CA 1 is, I argue, not strategic, but opportunistic on the part of the Council.

I urge the Council to reconsider this policy in the context of the irreversible damage it will cause to the protected landscape of the borough and the severe challenges it will present to achieve the balance of sustainable development (NPPF paragraph 8).

DLP_4463

Mr Andrew Rankine

Object

Flooding:

I am not an expert in flooding or water management. However, I do know that the lack of detail provided in the Draft Local Plan on specific flooding mitigation strategies and the “betterment” of the existing water management in the area gives me little confidence that the extent of these issues is really understood. This policy continually insists that building on or close to a floodplain can be mitigated against, and even present opportunities to improve the situation, but there is no detail of how this is to be achieved. The increased ‘run-off’ of water from these thousands of homes, the associated new road, drives and pavement not only threatens the new developments themselves (not to mention the existing residents) but also poses a major threat to communities downstream in neighbouring boroughs. Yet again the Local Plan is worryingly short on mitigation detail and appears more hopeful than realistic. The floods on Christmas Day 2013 are a recent and stark reminder of the when an area is going to flood, no amount of planned mitigation or good-will can stop this. Proposing a vast new settlement abutting a natural flood plain just seems to be an environmental, and human, catastrophe waiting to happen.

DLP_2506

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_2773

Andrea Cox

Object

This development in Tudeley, apart from desecrating an area of Green Belt land, is also inappropriate due to the area being so close to the Tunbridge Wells Borough Council Boundary. Residents who move into these new dwellings will want their children to go to local primary and secondary schools and the nearest ones will be in Tonbridge, not Tunbridge Wells. And other facilities such as doctors surgeries, adequate public transport, libraries will all be needed. Has there been any consultation with Tonbridge and Malling Council? Are they prepared for the extra population that will be requiring their services? This development may provide housing but it has not been fully thought through. Housing brings in families and families need local and convenient facilities.

DLP_2841

Helen Parrish

Object

The call-for-sites land details supplied to TWBC by Hadlow Estate is incorrect

It needs to be corrected

There are at least 4 Freehold dwellings annotated incorrectly as Hadlow Estate property. Mine is one of them.

There are probably many more unknown, incorrect, details supplied to TWBC.

All tied properties belonging to Hadlow Estate have been included in the Red Zoned Area – other freehold properties have been excluded from the Red Zoned area of Hadlow Estate. 1, 2, 3, 4 Bank Farm Cottages, Sherenden Road HAVE NOT. This is wrong.

Hadlow Estate have made errors (with intention or with laziness to check – raising false assumptions) – which means the TWBC have also not bothered to check the details either

Policy AL/CA 1 (Tudeley Village) p.160

TWBC should change the Local Plan, by cancelling the intention of a Tudeley Garden Village, to adhere to the NPPF an this point

To consider a Garden Village split in two by a Railway is ludicrous

TWBC must protect the Heritage that exists in which their voting public live

TWBC may not be in complete control the Local Plan

DLP_3108

Andy Bashford

Object

All the land is on prime AONB with many public footpaths used regularly by numerous Walkers who cherish the scenery and landscape. Therefore it must be left as it is. The TWBC plan indicates all the land is owned by a single landowner (possible Hadlow Estate), who is obviously looking to make an absolute fortune. How much has the landowner donated to key Borough Councillors?

DLP_3126

Teresa Stevens

Object

All the land is on prime AONB with many public footpaths used regularly by numerous Walkers who cherish the scenery and landscape. Therefore it must be left as it is. The TWBC plan indicates all the land is owned by a single landowner (possible Hadlow Estate), who is obviously looking to make an absolute fortune. How much has the landowner donated to key Borough Councillors?

DLP_3261

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 2 (Transport bulletpoint) – “Integrated, forward looking, and accessible transport options that support economic prosperity, wellbeing for residents, and aim to minimise use of the private car. This should include the early integration and promotion of public transport, walking, and cycling (following PTOD principles) so that settlements are easy to navigate, and facilitate simple and sustainable access to jobs, education, and services”

PTOD is Public Transport Orientated Design i.e. putting PT at the fore of the masterplanning process to ensure buses, trains (if applicable) and cycling/walking are well planned for and do not need to be retro fitted which is an impossible task

Paragraph 5 - reference to be included to PTOD principles to ensure early planning of key transport corridors within the sites and vicinity, and further assessment of possible highway network improvements

Paragraph 9 – “Transport provision shall be delivered on a strategic basis, taking account of the impact of proposed development at land at Capel and Paddock Wood, with transport infrastructure links between Paddock Wood, Tudeley Village, Tonbridge, and Royal Tunbridge Wells. A key element will be determining the most appropriate route to link to the road network to the east, which shall minimise the impact on the existing highway network through Five Oak Green, and should seek to reduce traffic levels through this settlement, and have regard to Kent County Council minerals allocations in the vicinity and sensitive receptors such as Capel Primary School. Developers will be required to provide (or contribute towards - depending on the success of additional funding bids) the potential offline A228 strategic link, the eastward link to the A228; and all other associated highway and sustainable transport infrastructure required to mitigate the impact of development resulting from this allocation

Public Rights of Way and Access Service

Paragraphs 2 and 10 are supported, but there is no reference to PRoW within the policy text. KCC considers reference should be made considering the scale of the proposed development and the existence of the PRoW that pass through the identified sites. It should be expected that the PRoW network will be positively accommodated within the development and enhanced. The creation of new path links should also be considered, to provide ample opportunities for active travel and outdoor recreation. Additional text should be inserted into the policy text to stipulate this requirement.

DLP_4503

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_4897

Rufus Beard

Object

I’ve moved out from Tonbridge to live in the countryside and enjoy the green belt. I categorically object to the removal of the green belt at the proposed site of CA1. This will have a massive visual impact both locally within Capel but also from afar. I walk my dog across the foot paths crossing CA1 at the bottom near the Poacher and Partridge then coming back towards the George and Dragon pub along the paths by the railway and paddock. The buzzards you see in the day time and owls you hear at dusk must not be over looked with such a dramatic loss of habitat.

DLP_6048

Mr C Mackonochie

Object

See comments on STR/CA 1 [TWBC: See comment DLP_6045]

DLP_5144

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_6821

Mrs Carol Richards

Object

Policy AL/CA 1 starting p160

Comments on the numbered paras as follows:

i Too many homes

ii There will be loss of employment and people who buy these proposed homes will work in London.

Iii The inhabitants of this village will shop in Tonbridge

Iv There is plenty of space in the valley below for enjoyment. It is idyllic which is why this area should remain unspoilt.

Comments on the requirements for development on the site as follows:

1. This Masterplan again sounds like something from Star Wars but is in essence is a very poorly thought out idea. So bad someone called it shoddy

2.All points invalid as it will be a dormitory town for London and the legacy will be to have destroyed a landscape forever. This site cannot be developed without significant and irreparable damage

3. As above opening paragraph - the landowner and co-masterplanner is inexperienced and ill-equipped to deliver such a complex project.

4. There is no vast infrastructure at this site. It is a HAMLET about to be overrun in both size and scale so disproportionate to its locality

5. All these points are TBC. Not enough assessment has been given to this site and if it had -you would know it is a totally unsuitable site and unsound.

6. Of course cars will be used and it is naïve to think otherwise

7. Pack the houses in tight and high – stated as ‘an opportunity to provide higher density of development’- so innocently phrased’-what happened to point 6 –‘layout and design to the highest quality’.

8. You cannot compensate for land destroyed and of course this ‘so called compensation provision’ is TBC through the ‘Masterplan approach’.

9 and 10. The roads in this area are totally inadequate to accommodate the necessary roads and cycle routes in a sustainable manner and will take years to come to fruition. The Infrastructure Development Plan, Appendix.1 has timing ‘Medium/Long’ and costing up to £10M for additional capacity between A26 and Capel on B2017, probably more and is KCC and developer funded. Totally unachievable and totally unsound as there will be houses and no new road infruatructure. It took 40 years to dual the A21 from Tonbridge to Tunbridge Wells Industrial Estate. I’ll be dead before the Colt’s Hill bypass is built….and I have lived here for over 20 years and it hasn’t been achieved yet . The Quote Cost £40M on another document £46M. Please explain (CIL/S106) There should be a key at the bottom of this appx to explain this and others.

All vehicular transport is Timed at moderate to long, yet priority critical and relying a lot depends on Private developers. Transport costs for this AL/CA1 on the upper side (always best with building costs) £82.5M and that is without the new link to the Colt’s hill bypass which surprise, surprise is TBC!

11.The secondary school- not approved by the Education Authority and I would hate to be the one that approves this. A school site bisected by a very busy railway line, and therefore unsafe. One dead child on the railway line-is one too many. On position and safety grounds alone- this proposal should be thrown out of court. It is so unsound to be ridiculous. An inspector worth their salt would take one look at a site plan and throw it out with a reprimand. It also has an ancient woodland on the site.

13. Health. GP practice- again Timing -Moderate to Long in the IDP. As the first houses could be occupied by 2025 do the occupants use Tonbridge practices before one is built and staffed for them? Not practical and totally unacceptable to Tonbridge residents who have enough trouble getting Doctor’s Appts now. Cost £5 Million. Funding TBC.

14 The belief that by solving the Flood Risk at Five Oak Green- you can justify this as a reason- to release Green Belt Land is so preposterous -its disgraceful. This is the ‘special circumstance’ that allows TWBC to destroy the landscape at Tudeley, destroy the rural character of a small hamlet, destroy the setting of an internationally renowned church and totally overwhelm existing residents? The Five Oak Green flood risk will perhaps be reduced by damming the Alders Stream, not by building thousands of houses. This can be delivered and funded independently of the garden settlement and may work , but building more homes will exacerbate the flooding.

It seems TWBC seem to disregard how the development on this site will adversely affect flood risks on the neighbouring villages of Golden Green, East Peckham and Laddingford. These villages do not lie within the Tunbridge Wells Borough but to disregard them is just another example of how poorly thought out this Draft Plan is. It also shows how TWBC are prepared to run shod over anything that will get in the way of their ‘Masterplan’. Tonbridge can grind to a halt, villages and towns can flood but their plan creating urban sprawl between Tonbridge/Five Green/ and Paddock Wood must follow the ‘Masterplan’. The River Medway is rising. The rapid increase in sea levels and other Climate Change factors have not been fully considered.

15 This is an odd statement, having successfully destroyed this idyllic landscape and biodiversity.

16. There don’t seem to be detailed reports from the Environment Agency on this huge issue, which is relevant to the Flood plain below Tudeley, Five Oak Green and Paddock Wood. Without detailed assessment you cannot possibly be assessing this site for consideration with due diligence.

Flood Risk – applies to policies STR/CA 1, STR/PW 1, AL/CA 1, and AL/CA 3

The LP is planning 52% of its additional housing allocation in AL/CA 3 and STR/PW 1 and 36% in STR/CA 1 and AL/CA 1- (Draft Plan Table 1 p 35) but both have elements in Flood Zones 2 and 3.

TWBC should consider:-

1. The River Medway is the largest river catchment within the Environment Agency’s Southern Region.

2. The floodplain (defined by the Environment Agency’s Flood Zone 3) of the River Medway lies to the north of Tudeley, Five Oak Green, Paddock Wood. With the tributaries Alder Stream, Tudeley Brook and River Teise.

3. The Leigh Flood Storage Barrier is located approximately 3 km west of the Tudeley. It was designed to protect Tonbridge from flooding and is the largest on-line flood storage reservoir in Europe, retaining a volume of 5,580,000 m3.( This is just an indicator to the level of water that this area has to cope with.) There are plans to increase this capacity by 2023, following the floods of 2013/4

4. The area around Five Oak Green and Paddock Wood is situated on the Low Weald, which is relatively flat underlain by impermeable WEALD CLAY. This means that water cannot soak into the ground AND the FLAT LAND MEANS it cannot flow away-it just lies on top.

5. Tudeley lies on a ridge above the Medway Flood Plain and this means the precipitation on hard -standing areas, of 2,800 homes- will cause faster run-off during a large event- into the flood plain below.

www.Gov.uk shows the Flood Map for Planning of this area:- Exhibit 4 (see full representation)

This is a very powerful visual reminder of the area where TWBC have chosen to put the large number of homes 2016 -2036- up to 6,800 in total. Flooding will continue to increase with Climate Change-forecasting wetter winters. Why chose here?

TWBC have obviously not taken water related issues into account from an early stage in the process of identifying land for development and redevelopment, to encourage the use of sites where past problems can be solved and seek to avoid sites where water supply and/or drainage provision is likely to be unsustainable;

Some extracts from the NPPF:

The NPPF 149 states:

“Plans should take a proactive approach to mitigating and adopting to climate change, taking into account the long-term implications for flood risk... Policies 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” [My emphasis]

So why plan to put homes in a vulnerable area in a flood plain zone in the first place?

The NPPF 150 states:

“New development should be planned in a way that avoid increased vulnerability to the range of impacts arising from climate change and should avoid ‘inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk(whether existing or future) ………….and without increasing flood risk elsewhere”

i.e. in this case Golden Green, East Peckham and Laddingford.

The NPPF 155 states:

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.” [my emphasis]

And finally NPPF 163 states:

“When determining any planning applications, local planning authorities should ensure that flood risk is not increased elsewhere.. . Development should only be allowed in areas at risk of flooding where . . . it can be demonstrated that:

b) the development is appropriately flood resistant and resilient”

TWBC cannot assert, with all honesty, that these developments are appropriately flood resistant and resilient.

The TWBC and the environment agency can apply all the sequential risk-based approach to location development they wan, but essentially TWBC is building on a functional flood plain for the River Medway and will put not only these new homes at risk but other homes at risk in other boroughs.

Prospective buyers will look at these homes and will not buy them. They will be difficult to insure, and they will only have to flood once and people who do buy will not be able to sell them. There are other sites that do not have the River Medway hinterland so close to villages and towns.

Exhibit 5 (TWBC Comment - seefull representation) shows that Capel and Paddock Wood already have the greatest number of homes at risk in the whole of the borough as circled and TWBC propose more homes in these same boroughs. On these figures I wouldn’t look at Lamberhurst either. There is no logic to these Plans. Totally unsound and immoral.

The OS Map at Exhibit 6 (TWBC Comment - seefull representation) shows the cross sections taken from The B2017 Five Oak Green Road on the ridge- to show the topographc affects of surface water flow down the slopes - running into the valley below and into the Medway. Hardstanding on this ridge will cause increased rate of flow causing flash flooding in times of wet weather.

Exhibit 7 (TWBC Comment - seefull representation) shows the profile of the ridge (sections A and C) from Five Oak Green Road (B2017) to the Flood Plain of the River Medway.

Climate change is predicted to increase rainfall intensity in the future by up to 40% (for the Upper End estimate to the 2080s epoch (2070 to 2115) under the new range of allowances published by the Environment Agency. This will increase the likelihood and frequency of surface water flooding, particularly in impermeable urban areas, and areas that are already susceptible. Changes to predicted rainfall should be incorporated into flood risk assessments and drainage and surface water attenuation schemes associated with developments. Is there a specific assessment for Tudeley to assess surface runoff?

Historical flooding

The events of 1960, 1963, 1968, 1985, 2000 and 2009 caused widespread flooding within the north of the borough e.g. at Paddock Wood and Five Oak Green, and areas along the River Teise, due to heavy rainfall over a prolonged period of time. Since this time, significant flooding occurred within the borough during the Winter 2013/14, which included notable flooding from the River Medway, as well as August 2015. Climate change predicts more rainfall and more frequency of flooding. We can all still remember 2013/14in this area.

Assessing Flood Risk and Developments

157 d) of the NPPF states, ‘where climate change is expected to increase flood risk so that some existing development may not be sustainable in the long term, seeking opportunities to relocate development, including housing, to more sustainable locations’

A site-specific FRA is required for all developments which are located in the Environment Agency’s Flood Zones 2 and 3, or developments. As TWBC are putting the bulk of homes in area of potential flood risk has this been achieved? I have not been able to find a specific assessment for Tudeley/ Five Oak Green / Paddock Wood. It could be I have not been able to find the correct document (as there are so many) The appendices A - didn’t have detailed information for these 3 locations

Table 13-1 in the Level 1 Strategic Flood Risk Assessment (SFRA) is quite illuminating. It lists all the call for sites assessed against flood risk. To note:

* In the column ’Site intersected by Risk of Flooding from Reservoirs extent’, nearly 80% of the sites covered Tudeley, Five Oak Green or Paddock Wood (30 out of 38).

* In the column ‘Proportion of site within Flood 3a as of now’, 72% covered Tudeley, Five Oak Green or Paddock Wood (43 out of 60).

* In the column ‘Proportion of site within future flood zones 3a’ 57% covered Tudeley, Five Oak Green or Paddock Wood (45 out of 79).

* None of this analysis has used 2019 information, which bearing in mind TWBC are looking to PLAN to 2036 is not up to date enough.

Table 13-1 shows the sites most at risk and TWBC have chosen nearly every one of them for their ‘Masterplanning’ approach. The cost of attempting to use these sites will require SuDS and other methods to attempt to reduce the impact of future flooding at these sites to the tune of £12M (Appendix 1: Infrastructure Delivery Plan Table 16 p98 and 99). Why would anyone in their right minds chose the worst sites to build on i.e. the ones most likely to flood now and in the future?

The provision to mitigate flood risk and surface water management should be used to protect the current homes at risk- not planning more homes to be at risk and then, to try to protect them!

One important fact to remember

If you fail to Plan- you Plan to fail. TWBC should be looking at the report by JBA having paid for the advice . LOOK at what the report is telling TWBC.

TWBC have not shown they have site specific evidence for these sites and provided evidence they have adequately considered other reasonably available sites that won’t flood!.

TWBC believe they can build on these sites and provide ‘betterment ’at these sites-like the homes will only flood to 100mm not 500mm? TWBC are willing to spend £12M of public and developer funding to do so.

The TWBC Development Constraints Study states on p 9- 2.19 “Flood zone 3 should be a significant constraint” and all the sites at Tudley /Five Oak Green/ Paddock Wood have a % of Zone 3 areas. (Table 3-1 of Site summary assessment) p91-108.

There is a policy emphasis in the NPPF to steer development away from areas with high flood risk. Planning Practice Guidance states that:-

“The National Planning Policy Framework set strict tests to protect people and property from flooding which all local authorities are expected to follow. Where these tests are not met, National policy is clear that new development should not be allowed.

2.2.2. p7 of the TWells Level l /2 combined SFRA states

“A further review of preliminary flood risk assessments was completed by KCC in 2017 and no Flood risk areas were identified for the borough and indeed the county as a whole”.

Can you please explain why this statement can be made when we have the Leigh Barrier- the biggest in Europe- AND it is being developed to hold more volume of water by 2023? I think there is something wrong with the analysis.

2.4.2 page 10 of the SFRA (Paddock Wood Stage 1 SWMP (2011) and Stage 2 SWMP (2015)) states

“Paddock Wood is an area that has experienced a number of incidents of surface water flooding associated with small watercourses, sewerage and private drainage systems. It was recommended within the Tunbridge Wells Borough Council Level 2 SFRA (2009) that Paddock Wood be designated as an ‘area of critical drainage’. However, formal adoption of Paddock Wood as a Critical Drainage Area did not occur. To better assess the local flooding issue, the Paddock Wood Stage 1 SWMP8 (2011) was conducted to provide a more detailed understanding of local flood risk in the study area. This was extended to a Stage 2 SWMP assessment (2015).

As part of the Stage 1 SWMP, an options assessment was undertaken to identify, shortlist and assess a series of structural and non-structural measures for mitigating surface water flooding across Paddock Wood. Based on the outcomes of the assessment, a range of recommended actions were identified, and an Action Plan was established. It is noted that actions are not specific to individual development sites, but the prioritisation of actions would be affected by any future potential housing allocations.”

So, I gather from the above TWBC that Mitigating measures will be used for this area of Critical drainage.

In section 3 p17 (The sequential risk based approach) the SFRA states:

“It is often the case that it is not possible for all new development to be allocated on land that is not at risk from flooding”

That sentence just makes no sensible-why would anyone chose to build on a site that is at risk of flooding. You are asking for trouble?

Out of 513 call for sites, there are 74 which are at risk of flooding- TWBC chose nearly every site at risk from flooding some the most likely -high- for development and TWBC think mitigating measures will solve the problem? This is development planning at its worst and to think they PLAN this for the next 27 years!!!!!!!!!!!

The following diagrams show one mitigation method won’t work

Exhibit 8 (TWBC Comment see full representation) - water, water everywhere…..and the sewage.

In the SHELAA report AL/CA3 and AL/PW1at the very bottom it states,’

‘A mixed water scores is applied as the proposals would represent a substantial demand for water and wastewater treatment, and all would provide significant benefits to Paddock Wood in the form of reductions in existing flood risk’ . TWBC know there is a huge problem here and yet they are prepared to ignore all the issues raised in ‘Issues to consider’ ANOB ( I Part), land contamination, railway, Flood zones etc because it suits them. They use these ‘issues’ in other sites to discount them and many are 100% in Flood Zone1 (No risk) so why change their standards here- especially when the flood risk is High !

Exhibit 9 (TWBC Comment - seefull representation) - water, water everywhere……….. along with the sewage.

I am intrigued as to why TWBC are so determined to build at Paddock Wood. I just wonder if this is one way, they can get developers to pay for flood improvements to this area-but let’s remember this is to alleviate the problems that are recognized now. More homes will mean more problems. It is also worth noting that TWBC are relying very heavily on Development contributions -which are incorporated into the house price. This is not going to provide affordable housing, where large amounts of money will be needed to be spend by the developer trying to mitigate the huge flood issues at Paddock wood and Five Oak Green. If they do get build and sold- one bad flood, which is inevitable, and homeowners will be left with homes they cannot sell or insure.

2.4.2 of SFRA states:

“The two highest contributing factors to flooding are reported to be the overland flows that affect residential properties in the north west and north east and the ability of the surface water network to discharge into the watercourses”

and this is because the land is so flat and impermeable. This is not going to change. I have also read in reports that the ground water system is acknowledged not to be fully understood especially when linked to climate change scenarios and I know Five Oak Green has this issue-as milder wetter winters may increase the frequency of groundwater flooding incidents in areas that are already susceptible. “Current understanding of the risks posed by groundwater flooding is limited and mapping of flood risk from groundwater sources is in its infancy” SFRA 6.6 p37

Still it is believed that these are Areas Susceptible to Ground Water Flooding for example, more than 75% of the area within the 1km grid squares surrounding the Whetsted and Tudeley Hale as well as the area north of Five Oak Green are susceptible to groundwater flooding’

Paragraph 162 of the NPPF, sets out a method to demonstrate and help ensure that flood risk to people and property will be managed satisfactorily, while allowing necessary development to go ahead in situations where suitable sites at lower risk of flooding are not available. Again, why chose so many sites fraught with major difficulties that will only exacerbate over the decades and cause misery to families and TWBC are planning this? There are other sites.

The Sequential and Exception Tests will be used to show it is safe to build at Paddock Wood and Capel Parish, but the Sequential test is supposed to be used to steer new development to areas with the lowest probability of flooding i.e. Flood Zone 1 and the Exception test is to be used as set out in paragraph 162 of the NPPF, to demonstrate and help ensure that flood risk to people and property will be managed satisfactorily, while allowing necessary development to go ahead in situations where suitable sites at lower risk of flooding are not available. Well there are 513-74 = 439 other sites and NONE of these are considered a more suitable location?. There are other safer sites than Paddock Wood. Five Oak Green and Tudeley.

The real TEST- will be- will there be people to BUY these houses…. I have heard buyers are very wary about buying homes in Paddock Wood and Capel Parish, as they know there is a flood risk. There are already sewage problems at Paddock Wood and buyers are not stupid.

I would never buy a house in Paddock Wood or Five Oak Green-there is a huge flooding issue and no amount of :Strategic Storage, flood defences, Increased channel conveyance , new channels, raising level of occupied floors of buildings above ground level- would induce me to buy a home in either of these places. I think it is wrong to expect others to do so. Hopefully builders will realize this too and market forces will prevail-they will have the sense not to build homes they cannot sell- even if there is no common sense at TWBC.

The SFRA at 14.6.2 Future Developments states:

“Development must seek opportunities to reduce overall levels of flood risk at the site, for example by:

* Reducing volume and rate of surface water runoff based on Local Plan policy and LLFA Guidance

* Locating development to areas with lower flood risk

* Creating space for flooding.

* Integrating green infrastructure into mitigation measures for surface water runoff from potential development and consider using Flood Zones 2 and 3 as public open space”

Maybe TWBC should listen to the advice they paid for?

Finally, I note the suggestion in the Summary of Level 2 SFRA (p161), section 5.1.3:

* Floodplain restoration or augmentation represents the most sustainable form of strategic flood risk solution by allowing watercourses to return to a more naturalised state. This may involve measures such as . . . return existing and future brownfield sites that are adjacent to watercourses back to floodplain, rather than allowing new development

Hear hear!

DLP_6164

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_4947

Nigel Tansley

Object

I am writing to express my objection to the proposal to build several thousand houses at Capel at the site known as CA1.

The reasons for this are as follows:

We should be increasing the amount of forested areas, not housing, to attempt to balance the negative effects of the amount of land covered by human developments;

We should be increasing the amount of agricultural land to feed the expanding population;

And increasing the amount of agricultural land in anticipation that alternatives to fossil fuels will be plant based;

Also:

We should be reducing the mileage driven by vehicles to reduce energy consumption whether it is oil or electricity based;

so, we should be encouraging people to travel to work and leisure pursuits by active methods (ie cycling and walking);

and we should be minimising effects on the environment by making the most of existing infrastructure rather than the environmental costs of creating new roads when the need for these can be reduced by an effective transport infrastructure, which is most effective within settlements and least effective in rural locations.

The proposed development at CA1 is contrary to all of these because:

It would be building on productive agricultural land, which also happens to be green belt;

In doing so, even more forested areas elsewhere would need to be destroyed to create new agricultural areas, already being executed at an alarming rate;

The mileage driven by vehicles in this rural location would likely be far greater than in an urban location, as acknowledged in the SHELAA documents where potential rural sites are rejected because of this contributory factor;

In this rural location remote from larger settlements, there would be few amenities compared to larger towns, to which it would not be convenient to walk or cycle due to the greater distance than an urban area, where the distances are much lower and thus more likely to encourage cycling and walking;

This location in the middle of greenfield land is not designed for an urban situation so would need its own infrastructure built, despite there being suitable infrastructure in nearby towns, if suitably planned and adapted, for example with comprehensive low cost or free bus services which in the long run by reducing traffic would cost the borough council less than building new roads.

The much better alternative to building a new settlement in the middle of the countryside, together with the infrastructure and associated negative results on the environment it would require, would be to build on the outskirts of existing settlements and transport routes, utilising existing infrastructure, improving where necessary with contributions from the developers; a normal arrangement.

I hope that these proposals in CA1 will be abandoned and that while the discussions are being held there will be refreshments in the form of blackcurrant drinks, while they are still available from Capel’s local fields, at the moment still producing our vegetables and fruit in the Garden of England.

DLP_5046

Hawkenbury Village Association

Support

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

DLP_5094

Dr John Nimmo

Object

Summary

I OBJECT TO the proposal to build a new town of almost 3,000 homes at Tudeley in the parish of Capel. Additionally, I OBJECT TO the proposals for downgrading the local Green Belt land in order to enable it to be used for the construction of housing.

The land to be used is Green Belt that lies adjacent to Kent's Area of Outstanding Natural beauty (AONB) and in close proximity to at least one Area of Ancient Woodland. To use Green Belt land, there needs to be “exceptional circumstances” and housing need is NOT sufficient to overrule currently protected Green Belt.

These proposals will result in a massive burden on the local community. The impact on the environment will be profound. Hectares of agricultural land on the Green Belt and in close proximity to the Area of Outstanding Natural Beauty in The Weald will be damaged forever. The location of the proposed development at Capel would be located closer to the town of Tonbridge than to Tunbridge Wells. It is far from clear that the local infrastructure could ever cope adequately with the magnitude of this development. This housing will have more adverse impact on Tonbridge, rather than being of significant benefit to Tunbridge Wells. There is insufficient evidence that the local housing needs exist to such an extent that a new town at Tudeley, on Green Belt land, is justified.

FULL COMMENTS

Personal Background - I first came to live with my family in Capel in 1995 on taking up employment with a company in outer London as an industrial chemist. My two children were brought up in Capel and attended local schools. We revelled in the local community with its outstanding quality of life. Although travelling often, and working abroad for a few years, we kept our house in order to return to the beautiful village of Capel, to retire and to enjoy the way of life.

OBJECT TO the proposal to build a new town of almost 3,000 homes at Tudeley in the parish of Capel. Additionally, I OBJECT TO the proposals for downgrading the status of local Green Belt land in order to enable it to be used for the construction of housing.

The land to be used is Green Belt that lies adjacent to Kent's Area of Outstanding Natural beauty (AONB) and in close proximity to at least one Area of Ancient Woodland. To use Green Belt land, there must be “exceptional circumstances”, and housing need is NOT sufficient to overrule currently protected Green Belt.

Despite the assertion that no other brownfield sites exist or are suitable, it remains that insufficient attention has been paid to investigating less damaging options. It appears that the expedient option rather than the logical option has been speedily and thoughtlessly selected, making it much easier for TWBC to deal with a single individual selling the land, rather than negotiate sales with several different landowners.

It is understood that the housing need figure is not a mandatory target (Ref. : Jake Berry (Minister DHCLG, April 2019). He went on to say that “Local Authorities should make a realistic assessment of the number of homes their communities need, using the standard method as the starting point in the process. Once this has been established planning to meet that need will require consideration of land availability, relevant constraints and whether the need is more appropriately met in neighbouring areas... The NPPF is clear that only in exceptional circumstances may a Green Belt boundary be altered, through the Local Plan process. Last year we strengthened Green Belt policy in the revised NPPF”.

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

* 39% of the parish of Capel is designated as an Area of Outstanding Natural Beauty (AONB)

* There are 10 Sites of Special Scientific Interest (SSSI)

* 22% of the borough's land is designated as Green Belt (Source: TWBC website, Key Borough Statistics)

Consequently, Government-imposed housing targets are disproportionate for a borough and parish with such a high proportion of Green Belt and/or AONB land. Just as Sevenoaks Council have done, TWBC should push back on this external imposition of housing targets from central government. Government targets are based off 2014 ONS data, not the updated 2016 numbers which are at a lower level.

Roger Gough, leader of the Conservative Party at Kent County Council and likely new leader of Kent County Council, has said about housing plans in Kent: “the consensus is housing has moved ahead of infrastructure. We are talking about roads, we are talking about schools……we do need to work together to present to government what is required in terms of a balanced approach. People must not feel that housing is coming on such a scale in places that it is not balanced with the infrastructure that comes with it.” (Courier, October 11, 2019, page 14).

Local needs - it is not clear whether the local needs have been properly assessed in relation to the targets set by central government, both in the number of houses, but also in the type of housing. The risk is that the new town at Tudeley is more likely to generate executive, London commuter homes which are far more profitable for the developer, rather than social or affordable housing which is the local need.

It is an open question as to whether TWBC has worked strenuously enough to identify all of the available brownfield sites to the same extent as they have targeted greenfield sites for development. Para 137 NPPF requires local planning authorities to “examine fully all other options for meeting its identified need for development” before concluding whether exceptional circumstances exist to justify changes to Green Belt boundaries. If TWBC used greater efforts in seeking out landowners for greenfield land than brownfield, the draft plan fails that test.

Local resident groups under similar pressure from local housing strategies have identified non-green sites and visited each site to assess its suitability as brownfield, with significant increases found on brownfield rather than greenfield sites.

Housing density - Clarification is needed by TWBC on housing density in the new town at Tudeley. The destruction of Green Belt land should certainly justify a high level of housing density to reduce the irreversible loss of the valuable natural landscape. Insufficient housing density is one of the grounds for refusal of a Local Plan.

Local roads and transport - It is very well known that the existing village of Tudeley is poorly served by existing public transport. Para 138 NPPF states that: “Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. Extra cars will use the local roads, with further congestion on roads that are already badly congested at peak times.

Whilst a new road is proposed between Five Oak Green and Capel, this would also be in Green Belt land, resulting in yet more destruction of the natural environment. The roundabout at the Colt’s Hill end of Alders Road will encourage ease of access onto the proposed Colt’s Hill bypass, thus driving traffic down Alders Road and potentially along Sychem Lane at peak times, rather than along the proposed new road south of Five Oak Green. Additionally, the proposed Colts Hill bypass is in both Greenbelt and AONB land.

Hospital capacity / Medical care- A new town with the proposed number of new homes in Capel will put much more pressure on the services at the Kent & Sussex hospital at Pembury. Adequate medical centres, fully and professionally staffed, will be necessary to support the greatly increased size of the local community. Clarification is needed to assure the local residents that enough has been done to assess and plan for the extra demand. It is critical that the capacity of the hospital and medical centres are well enabled to cope. Extra funding will be necessary for this, in order to cope with the increased local population, and it is not clear where the funding would come from.

Flooding / Water supply - parts of Capel parish have long suffered from flooding. The proposed new town is in close proximity to the natural flood plain of the Medway. There is a risk that flooding could well impact Yalding, which already suffers regularly in times of heavy rain.

The whole of the South East is prone to lack of water; the reservoir at Bewl Water frequently suffers low levels in summer. Clarification is needed that proper professional research has been done to secure an adequate supply for the region once the extra demand from the new town and 4,000 extra homes comes on stream.

Natural environment - the destruction of the greenfield land will adversely impact the natural environment and wildlife in the area. Care must be taken to protect the RSPB nature reserve at Tudeley Woods on Half Moon Lane, which is within one mile from the proposed new town in Tudeley. Loss of habitat and a reduction in the number of species would be unacceptable. The agricultural heritage of the parish will be lost for ever.

Air quality, light and noise pollution / Wellbeing - the extra housing, cars, street lighting and all that goes with a new town will lead to increased levels of pollutants in the air, resulting in poorer air quality. The carbon footprint will unquestionably increase, and this will be a contributor to climate change. In addition, noise and light pollution will increase in what is now a rural, Greenbelt area. Due to the increase in light pollution, our vision of the night sky in the village will deteriorate. The quality of the environment in Capel will be irreparably damaged and changed for the worse - and forever. It is hard to imagine that this is consistent with a desire for betterment of the parish, and it is certainly a total destruction of the existing local way of life. Personal wellbeing is greatly enhanced by green, open space to be enjoyed for posterity by everyone. With the current and growing awareness of mental health issues, protection of the Green Belt is essential to the health and wellbeing of every member of the local community.

Architectural heritage - the historic church at Tudeley is located beside where the proposed new housing development will be sited. Tudeley Church has windows designed under a commission to Marc Chagall, the world-renowned artist. Tudeley is internationally famous as the only church in the world with stained glass windows designed by Chagall, within its setting in the green fields of Kent. This will be lost when the surrounding fields are destroyed and the church is surrounded on three sides by the new town at Tudeley. What assessment has there been on this historic site and the other listed buildings in the parish and its surroundings?

Sustainability assessment - according to the TWBC Sustainability Assessment, the housing objective is compatible with only 5 out of the 19 sustainability objectives. Further, it is incompatible with 9 of those objectives.

CONCLUSION

In conclusion, I contend that this draft Local Plan and the concept of the new town to be built on Green Belt land in Capel has been poorly thought through. It is an expedient solution towards meeting government-imposed targets, rather than addressing true local needs. Further, there can be no justification for the destruction of Green Belt land and for ignoring the long-established precedents to protect the Green Belt.

DLP_5270

Tunbridge Wells Friends of the Earth

Object

Policy Number:  AL/CA 1 Tudeley Village 

We object to the suggestion in point 6 that “design quality [is] one of the justifications for the release of Green Belt land” as this does not constitute an ‘exceptional circumstance.’

General objection to all new development in Green Belt.

DLP_5298

Graeme and Sue Connell

Object

I have to assume that whoever came up with the idea of suggesting the site shown on the Local Plan for a new secondary school, has never travelled on the B2017 in the rush hour which in the morning and for part of the afternoon would  coincide with school arrival and departures.

The exit on to the B2017 from Postern lane is already very dangerous.  The exit from Postern lane is on an incline which adds to the excitement of making a fast take off .  In the morning and afternoon rush hours the flow of traffic in both directions is almost continuous.  Constant   quick neck movements are vital to try and gauge a break in traffic but this is all the more difficult because the exit is slap bang in the middle of two blind corners in either direction – corners that are further obscured by high hedgerows.

To add to this already hazardous situation by adding the prospect of scores , possibly hundreds, of cars of parents transporting their children to and from school ( there being no other viable means of transport) at peak congestion time is simply a recipe for disaster.

The references to access improvements by road widening Postern lane and creating a roundabout before the railway bridge, suggests that no real risk management exercise has been carried out on site, since that simply deals with the final hundred yards or so, and does nothing to address the real and dangerous problem of entering and exiting the B2017.  The only possible solution to avoid the almost inevitable serious accident, and one that probably would involve children, is the installation of traffic lights.  That would result in quite unacceptable traffic congestion at peak travel times and would be  highly unpopular with commuters and school parents alike.  The  gridlock that resulted from the recent temporary traffic lights in nearby Vale Road illustrates this point, one of the unfortunate spin offs of which was the use of Postern lane as a rat run.

To contemplate a school-site that has a main line railway running through the middle of it would almost seem humorous were it not importing an unacceptable risk factor with the large number of children involved.  Presumably the existing narrow rail bridge would see considerable numbers of children walking across it to reach the playing fields and back on a daily basis notwithstanding the fact that Postern Lane itself will continue to be used by vehicular traffic and has no sidewalks.  The width is only sufficient for one vehicle.  The potential for train spotting ‘ accidents’ cannot be dismissed and there have already been two suicides from that bridge in recent times.

There are many more reasons for objecting to such an unsuitable choice of site for a school which others can articulate/describe better than us but we have chosen to highlight the link to the B2017 as a real and present danger which will become much worse if this development proceeds.  There are also many other reasons for challenging the proposed siting of the entire Local Plan, which again we will leave to others, but perhaps the most obvious conclusion that might be drawn is that it must be a matter of supreme convenience/relief to TWBC to have such a willing vendor offering up such a large parcel of land, thus potentially shortening the effort that might otherwise be entailed. Convenience however is not a substitute for due diligence as I am sure you will agree.

DLP_5347

June Winton

Object

I live in Marden and I pass through Capel on a regular basis on the way to Pembury Hospital.  It is such a beautiful area and I love the peace and quiet on my way to treatment at the Pembury.  To think of this little piece of heaven being decimated and ripped up by bulldozers, destroying the habitat of millions of birds, insects and wildlife, saddens me greatly.  I do not think even one house is worth this destruction, let alone the proposals which will destroy this piece of countryside for ever.

What price can be put on peace and quiet?  What price can be put on beauty?  These are things which are priceless. 

We do not need more people in the area, we do not want more people in the area.  Who wants this?  Does our MP agree with protecting our countryside and all that it means or does he support more development? He needs to make his thoughts known so that we, the people who live here, are fully warned and aware. 

I also do not wish to see 5G in the neighbourhood which is proven to decimate wildlife.  The fact that we cannot get insurance from Lloyds against the risks of ill-health from the effects of 5G radiation should be enough for our MP to stand up and be counted and say NO, NO TO 5G!  Again, we need to know his thoughts on this issue, which affects the health and well-being of his electorate.

Stand up and be counted, Greg Clark!  Or forever hold your peace and step down now!

DLP_5351

Barry Smith

Object

We are writing to object to the draft local plan as it relates to Tudeley “New Town” and East Capel.

In the preparation of the current draft local plan TWBC has chosen to assess the government’s housing need for Tunbridge Wells Borough based on the standard method of calculation which resolves as a ‘housing need’ figure of 13560.  This figure is based upon a 2014 assessment of housing need, whereas you are aware the Office of National Statistics (ONS) 2016 figures show a smaller housing need and that policy will reflect this in due course.

Contrary to the approach of neighbouring Councils TWBC has upscaled its assessed figure of 13560  to 14776 and promotes (despite valued arguments to the contrary)  development of Green Belt lands to selectively satisfy a self-imposed numerical ‘need’.

From the Government position, the Ministry of Housing, Communities and Local Government has repeatedly made clear via. Ministers and the Secretary of State for Housing that the ‘housing need’ figure is not a mandatory target and that local authorities should make a realistic assessment of the number of houses their communities need, using the standard method as the starting point in the process. TWBC has made no realistic assessment.

The initial draft plan prepared by TWBC made no reference to Tudeley ‘new town’ and East Capel, these ‘sites’ resulting from a second later request for volunteered lands.  The local plan is supposed to address the housing needs Borough wide, whereas over 60% of the ‘upscaled’ future housing need figure is grouped in the extreme northern part of the Borough , much in conflict with the fundamentals of Green Belt policy (see below) and part (Tudeley ‘new town’) having a severe and adverse impact on Tonbridge .

TWBC sets out to argue against Green Belt Policy whereas the NPPF provides that the government attaches great importance to Green Belt.  The fundamental aim of the Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts being their openness and their permanence.  Among stated purposes ‘to prevent neighbouring towns merging into one another’ (see below) and ‘encouraging the recycling of derelict and other urban land’: TWBC has no strategy to identify brownfield sites.

The current TWBC proposals for Tudeley ‘new town’ and East Capel reduce the Green Belt/ urban ‘separations’ to a few fields verging on a built- up coalescence from Paddock Wood to Tonbridge.  This is contrary to the fundamentals of Green Belt policy. Regarding the Tudeley ‘new town’ there is no evidence garden settlements lead to any positive outcome and I would suggest even less when the ‘town’ is divided by a rail line.  The proposal for Tudeley ‘new town’ is an ill placed planning ego trip conveniently facilitated by opportunist land owners.  The proposal involves the loss of several hundred acres of prime agricultural Green Belt land, the loss of numerous incumbent ‘at risk’ bird species, creates insurmountable traffic problems for Tonbridge and is clearly in conflict with the fundamentals of Green Belt policy.

To support their current draft plan (being in conflict with Green Belt policy) TWBC must set out a plausible strategic policy and argue a case for exceptional circumstances.  There are no exceptional circumstances.  Other sites are available which do not involve the loss of Green Belt land. Other sites are available that are better placed and suited to the needs of the Borough as a whole.

The ‘new town’ site is effectively located on the boundary with Tonbridge and Malling which by its siting would benefit TWBC by way of community charge and leave all the adverse consequences to Tonbridge in terms of access and parking, already a major problem at key times

In summary, we object to the current draft plan for the following reasons:-

With regard to the Tudeley ‘new town’ :- 

  1. We object to the unnecessary loss of prime arable Green Belt land and the destruction of habitat involving multiple ‘at risk’ species.
  2. We object to the loss of prime Green Belt land as there are alternative sites available, not involving Green Belt land and better placed to meet the Boroughs needs as a whole.
  3. We object to the location for which there is no local need, and which will inestimably aggravate the existing traffic problems accessing and/or parking in Tonbridge at key times, leaving Tonbridge with a multitude of issues and potential cost with no beneficial (community charge) income. (Traffic already stacks back from Tonbridge along the A26 to Hadlow past the junction with Three Elm Lane and similarly down the B2017 and about the Tonbridge Industrial Estate at key times).
  4. We object to the proposal which will have an adverse impact on the setting of All Saints Church at Tudeley , listed and of world renown.

With regards to East Capel, Tudeley ‘new town’ and the new school :- 

  1. We object as the proposal is directly contrary to Green Belt policy and will effectively result in an urban coalescence from Paddock Wood to Tonbridge.
  2. We object to the cavalier inclusion of Tudeley ‘new town’ and East Capel in the draft plan as they have not been subject to a detailed Green Belt study, no Landscape Assessment and no Biodiversity Assessment. With regard to the proposed ‘new town’ the present owner’s father and grandfather were known to have an active interest in the wild life of the area.

On general matters we object :- 

  1. To the draft plan because it has been developed without an aggressive strategy to identify brown field sites.
  2. To TWBC upscaling their housing need figure when the current ONS information supports a downward trend.
  3. To TWBC promoting the loss of Green Belt lands (Tudeley ‘new town’ and land at East Capel) for no other reason than convenience and compliant land owners.
  4. To promoting the loss of Green Belt land in the knowledge the NPPF makes it perfectly possible to argue TWBC objectives are not achievable reflecting Green Belt and AONB guidance (the option exercised by Sevenoaks District Council).
  5. To promoting the loss of Green Belt lands in the knowledge the adjoining districts (SDC, TMBC and Maidstone) and the Government do not share this view.
  6. To the new senior school proposal, which is remote from the ‘new town’, divided by a rail line and will further compound the existing traffic difficulties in that area.
  7. To an ill thought out draft plan of convenience, that lumps over 60% of the upscaled ‘housing need’ figure in one TWBC boundary area and leaves Tonbridge (already subject to inordinate traffic and parking difficulties at key times) to cope with the multiple added influx of ‘new town’ traffic and a legacy of inordinate cost issues for TMBC residents.

DLP_5352

Patricia Smith

Object

We are writing to object to the draft local plan as it relates to Tudeley “New Town” and East Capel.

In the preparation of the current draft local plan TWBC has chosen to assess the government’s housing need for Tunbridge Wells Borough based on the standard method of calculation which resolves as a ‘housing need’ figure of 13560.  This figure is based upon a 2014 assessment of housing need, whereas you are aware the Office of National Statistics (ONS) 2016 figures show a smaller housing need and that policy will reflect this in due course.

Contrary to the approach of neighbouring Councils TWBC has upscaled its assessed figure of 13560  to 14776 and promotes (despite valued arguments to the contrary)  development of Green Belt lands to selectively satisfy a self-imposed numerical ‘need’.

From the Government position, the Ministry of Housing, Communities and Local Government has repeatedly made clear via. Ministers and the Secretary of State for Housing that the ‘housing need’ figure is not a mandatory target and that local authorities should make a realistic assessment of the number of houses their communities need, using the standard method as the starting point in the process. TWBC has made no realistic assessment.

The initial draft plan prepared by TWBC made no reference to Tudeley ‘new town’ and East Capel, these ‘sites’ resulting from a second later request for volunteered lands.  The local plan is supposed to address the housing needs Borough wide, whereas over 60% of the ‘upscaled’ future housing need figure is grouped in the extreme northern part of the Borough , much in conflict with the fundamentals of Green Belt policy (see below) and part (Tudeley ‘new town’) having a severe and adverse impact on Tonbridge .

TWBC sets out to argue against Green Belt Policy whereas the NPPF provides that the government attaches great importance to Green Belt.  The fundamental aim of the Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts being their openness and their permanence.  Among stated purposes ‘to prevent neighbouring towns merging into one another’ (see below) and ‘encouraging the recycling of derelict and other urban land’: TWBC has no strategy to identify brownfield sites.

The current TWBC proposals for Tudeley ‘new town’ and East Capel reduce the Green Belt/ urban ‘separations’ to a few fields verging on a built- up coalescence from Paddock Wood to Tonbridge.  This is contrary to the fundamentals of Green Belt policy. Regarding the Tudeley ‘new town’ there is no evidence garden settlements lead to any positive outcome and I would suggest even less when the ‘town’ is divided by a rail line.  The proposal for Tudeley ‘new town’ is an ill placed planning ego trip conveniently facilitated by opportunist land owners.  The proposal involves the loss of several hundred acres of prime agricultural Green Belt land, the loss of numerous incumbent ‘at risk’ bird species, creates insurmountable traffic problems for Tonbridge and is clearly in conflict with the fundamentals of Green Belt policy.

To support their current draft plan (being in conflict with Green Belt policy) TWBC must set out a plausible strategic policy and argue a case for exceptional circumstances.  There are no exceptional circumstances.  Other sites are available which do not involve the loss of Green Belt land. Other sites are available that are better placed and suited to the needs of the Borough as a whole.

The ‘new town’ site is effectively located on the boundary with Tonbridge and Malling which by its siting would benefit TWBC by way of community charge and leave all the adverse consequences to Tonbridge in terms of access and parking, already a major problem at key times

In summary, we object to the current draft plan for the following reasons:-

With regard to the Tudeley ‘new town’ :- 

  1. We object to the unnecessary loss of prime arable Green Belt land and the destruction of habitat involving multiple ‘at risk’ species.
  2. We object to the loss of prime Green Belt land as there are alternative sites available, not involving Green Belt land and better placed to meet the Boroughs needs as a whole.
  3. We object to the location for which there is no local need, and which will inestimably aggravate the existing traffic problems accessing and/or parking in Tonbridge at key times, leaving Tonbridge with a multitude of issues and potential cost with no beneficial (community charge) income. (Traffic already stacks back from Tonbridge along the A26 to Hadlow past the junction with Three Elm Lane and similarly down the B2017 and about the Tonbridge Industrial Estate at key times).
  4. We object to the proposal which will have an adverse impact on the setting of All Saints Church at Tudeley , listed and of world renown.

With regards to East Capel, Tudeley ‘new town’ and the new school :- 

  1. We object as the proposal is directly contrary to Green Belt policy and will effectively result in an urban coalescence from Paddock Wood to Tonbridge.
  2. We object to the cavalier inclusion of Tudeley ‘new town’ and East Capel in the draft plan as they have not been subject to a detailed Green Belt study, no Landscape Assessment and no Biodiversity Assessment. With regard to the proposed ‘new town’ the present owner’s father and grandfather were known to have an active interest in the wild life of the area.

On general matters we object :- 

  1. To the draft plan because it has been developed without an aggressive strategy to identify brown field sites.
  2. To TWBC upscaling their housing need figure when the current ONS information supports a downward trend.
  3. To TWBC promoting the loss of Green Belt lands (Tudeley ‘new town’ and land at East Capel) for no other reason than convenience and compliant land owners.
  4. To promoting the loss of Green Belt land in the knowledge the NPPF makes it perfectly possible to argue TWBC objectives are not achievable reflecting Green Belt and AONB guidance (the option exercised by Sevenoaks District Council).
  5. To promoting the loss of Green Belt lands in the knowledge the adjoining districts (SDC, TMBC and Maidstone) and the Government do not share this view.
  6. To the new senior school proposal, which is remote from the ‘new town’, divided by a rail line and will further compound the existing traffic difficulties in that area.
  7. To an ill thought out draft plan of convenience, that lumps over 60% of the upscaled ‘housing need’ figure in one TWBC boundary area and leaves Tonbridge (already subject to inordinate traffic and parking difficulties at key times) to cope with the multiple added influx of ‘new town’ traffic and a legacy of inordinate cost issues for TMBC residents.

DLP_5353

Karen Mackie

 

I am writing with concern regarding the proposed building of houses at Tudeley, Capel and Paddock Wood with the senior school in Tonbridge, from the perspective of a resident and a teacher.

I have lived in East Peckham all my life, as have many generations of my family.  I have experienced first hand and historically the impact of the flood defences that protect my home and the local area.  My grandparents would rely on boats to move around the village at times during the last century and would have to move furniture to rooms on the first floor to protect their property.  Places like Hartlake Road and other surrounding areas are carefully managed at present through organised flooding to protect our village and ensure the impact of heavy rain is minimum.  A quarry legacy is flooded land and a large housing development means that extra water will be left on surfaces: water does not soak into water or concrete roads and driveways.  There will also be access water from domestic use pumped into our sewage systems. Where will this water go?  All money, time and scientific innovation considered beneficial during the past few decades will be meaningless through permission given to the quarry and the proposed building developments.  The flooding impact on the future generations is frightening.

Secondly, the infrastructure around this area is at breaking point, encouraging more people to move here will only add to the chaos of traffic.  I work in Tonbridge and traffic congestion increases my journey of 13 minutes to often 45 minutes in the morning and up to 25 minutes in the evening rush hour.  Pollution and impact on wildlife is more of a concern than inconvenience though: this cannot be reversed.  I seriously doubt the Conservative commitment to these long term environmental causes.  Another transport consideration is to train travel.  At present it is often impossible to be seated during rush hour or late evenings - I regularly have to stand on return journeys from London. How will British Rail cater for the extra movement of people?  How will Tonbridge and Paddock Wood station platforms hold the extra waiting customers?  Like the water, there will be an overloading past saturation point.

Thirdly, as an English teacher in a local secondary school, I can inform you that building a school is a simple job compared to finding qualified staff to fill the roles.  The last three teachers recruited in my department at my school came from Hong Kong, Canada and New Zealand.  I recently attended an Initial Teacher Training evening to give information to people who are interested in becoming teachers in any subject, it was represented by five local schools and well-publicised. From 4.30pm to 8.30pm, THREE people came through the doors and not one of the them signed up or, to my knowledge, pursued their interest in working in this profession.  Working with newly qualified teachers, we expect the maximum of two out of every five to still consider it their chosen profession after five years, particularly in secondary schools.  My daughter and her husband are teachers in state schools in Tonbridge, they cannot afford to live near their places of employment but live in East Sussex because of the house prices.  How are teachers going to be found for this new school?

Also, I believe the problem regarding recruiting and paying staff enough money to live in this area will also be an issue for health care facilities too.  My only experience is the overworked health staff and high turnover of doctors at Woodlands Health Centre in Paddock Wood who will be inundated with more patients, increasing waiting times and availability of emergency appointments.   I am informed by friends in the profession that nursing at Pembury Hospital is already at a crisis point and waiting times in A&E have increased to unacceptable hours over the past few years as people turn to the hospital to help because they cannot see their GP.  Why increase the excess demand further and bring the local health facilities to the brink?

Finally, the green belt has ensured this part of Kent has remained beautiful.  Watching the seasons change with the different farming practices along Hartlake Road and other local farms confirms the need to enjoy and make our countryside work for us.  How will we feed the people locally and nationally without our farmland? Brown field sites are being deliberately held without proposals by building companies and speculators on the understanding that greenfield sites will be used now and brown field ones can be kept for later, giving few people wealth and security at the expense of many.  I believe with limitations on air travel and haulage because of environmental concerns in the future, Britain will have to supply more of its own food.  Kent could become a prosperous and leading county in this area: a return to “The Garden of England’.  Once the farmland is developed there is no opportunity for reversal, only regret.

As a long time Conservative voter and hardworking teacher who is passionate about the future, I thought the Conservative party echoed my values about fairness and consideration regarding family, the environment and the individual; however, this proposal is destructive, thoughtless and careless.  I worry about who will be the next party in government for many ethical and long term policy commitments which will ruin the lives of my children, the local community and country, but I am also concerned about who I will vote for in the next election because Conservative council decisions are a reflection of the ideology behind their party’s ethos and values.  If Capel and Paddock Wood development, along with the destructive quarry at Hartlake are agreed, who do I trust with both the future of Kent and this country?

DLP_5386

Gary Evans

Object

I have read through my MP's concern's regarding the extraordinary amount of housing and new school in Tudeley, Woodgate Way and Mabledon House.

I absolutely agree with my MP's concerns and would urge the Council to give consideration to those who will be detrimentally affected by this tsunami of build.

Where is the capacity on our roads, our local hospitals, GP services to meet the demand for more human expansion? We must protect our environment, reduce our carbon emissions and live sustainably. We must have green spaces for our mental and physical health, not just a few trees planted to offset the significant environmental impact.

Your proposals demonstrate disrespect, not only for the residents of Tunbridge Wells but also your neighbours in Tonbridge.

We cannot go on like this. You need to say to central government enough is enough and we as a society need to change our way of life in order to provide a sustainable future for our children. That means amongst other things that each and every one of us should not have more than 2 children, as we have chosen to do.

These proposals should not go ahead.

Thank you for your time

[TWBC: accompanying email from Tom Tugendhat MP copied here for information]:

Dear Gary,

As you may be aware Tunbridge Wells Borough Council are proposing to develop land in Tudeley for over 2,000 homes. In addition to this, they are also considering building a Secondary School off Woodgate Way, here in Tonbridge, and more housing at Mabledon House, just south of the A21.  

Though each of these areas are close to Tonbridge, they technically fall outside our council area. I am keen for Tunbridge Wells Borough Council to hear the comments of those of us who live in Tonbridge about the proposals. 

Up until 15 November 2019 they will be consulting. It is open to anyone, including people living in Tonbridge and surrounding villages, to respond. I am keen that they understand the concerns that many have raised with me. 

You can see my response here, but if you haven’t yet done so please consider responding too. You can do so by e-mail to localplan@tunbridgewells.gov.uk or by following the link here

With our own housing needs to meet, Tonbridge and Malling Borough Council are understandably hugely concerned about the proposals too. They have agreed a robust response too and I know your councillors Dennis King (dennis.king@tmbc.gov.uk) and Frixos Tombolis (frixos.tombolis@tmbc.gov.uk) would be interested to hear your thoughts as well.

If you share these concerns please do respond before 15 November, and encourage your friends and neighbours to do so as well. 

Best wishes
Tom 

Tom Tugendhat MP
Member of Parliament for Tonbridge and Malling
130 Vale Road
Tonbridge
Kent
TN9 1SP
01732 441563

DLP_5392

Fiona Jones

Object

Please accept this email as my objection to the local plan proposed by twbc

I note that the majority, if not all the land has been put forward by Hadlow Estates. I strongly object to their monopoly on these areas and that by granting planning on these sites will change our market town and surrounding villages for good. The infrastructure cannot cope as it is. This hasn't been thought through and I'm sure you have brown field sites available which have not been considered. To create more traffic at mabledon farm onto a busy main road is ridiculous. As for your proposed plans for paddock wood, Tudeley, Capel and Golden Green are equally unsustainable and Ill thought out. It appears these are all easy options for building as once again it all belongs to Hadlow Estates.

DLP_5438

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_5441

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_5445

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_5487

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_5503

Iain and Francesca Hearfield

Object

My family and I have lived on the A26 Hadlow Road in Tonbridge for over 19 years and in the area far longer. We commute to London, (waiting 4 years, 1998,  to obtain a season ticket parking space at Tonbridge station). In the last year however it has become increasingly difficult to drive to the station and despite the improper infrastructure for cycling, I am now taking my life in my hands and cycling. It has cut the drive time in half and so far I have only been knocked off my bike once by a passing car!  Transport issues in the Tonbridge area an in particular the industrial estate (Tonbridge hight street bypass) has been raised with my local MP, indeed  our family had a reply from Mr Tugendhat only last year.

The recent leaflet  I received via leaflet from the Savecapel group grabbed my attention and whilst am acutely aware of the need for more housing in the area and nationally it does appear to me from the reading of the papers published that Tonbridge will suffer if the agreement is made. We therefore have no option but to object.​

Creating a garden settlement at Tudeley of 2,800 dwellings will cause immense harm to residents of Tonbridge and the surrounding area. There will be a significant increase in traffic into 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 and 3-6.30 pm in and around Tonbridge especially Woodgate Way, Vale Road, Hadlow Road and Pembury Road will bring the town to a standstill.​

People living in Tudeley will use Tonbridge Station or Pembury 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 its infrastructure is not able to cope. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable. 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. ​

I believe that 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. 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. I 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. I think that the plan should be re-written to implement  a growth corridor led approach and to protect Green Belt land within the borough.​

In summary the developments in Tudeley and East Capel are unsustainable and place huge pressure on Tonbridge.  A joint plan and agreement between both councils is required along with the provision of the proper infrastructure before any land is developed.

I look forward to hearing the result of your deliberations.

DLP_5738

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_5773

Ru Rahman

Object

I am a Tonbridge resident and use Tonbridge train station as a commuter into the City of London during the weekdays.

My objections were in relation to the proposed development in Capel including Tudeley Village and Paddock Wood.

The points I had wished to raise are as follows:

  • As with previous green belt policy, inappropriate development is, by definition, harmful to the green belt and should not be approved except in very special circumstances (paragraph 87).
  • When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the green belt. "Very special circumstances" will not exist unless the potential harm to the green belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.

Paragraphs 79 to 92 of the National Planning Policy Framework (NPPF) set out the Green Belt policies.

The fundamental aim of the Green Belt policy is to prevent urban sprawl by keeping land permanently open (paragraph 79, NPPF). The essential characteristics of Green Belts are their openness and permanence (paragraph 79, NPPF). (Emphases added.)

The Green Belt serves five purposes including "to assist in safeguarding the countryside from encroachment" (paragraph 80, NPPF).

Local planning authorities should plan positively to enhance the beneficial use of the Green Belt such as “to provide opportunities for outdoor sport and recreation…or to improve damaged and derelict land" (paragraph 81, NPPF).

Paragraph 87 states:

"… inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances".

Paragraph 88 states:

"When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations".

Paragraph 89 states:

"A local planning authority should regard the construction of new buildings as inappropriate in Green Belt. Exceptions to this are: … Provision of appropriate facilities for outdoor sport, outdoor recreation … as long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it”.

The proposals in the Local Plan for the development in Capel and Paddock Wood are contrary to the paragraphs 79-92 of NPPF and no lawful justification has been provided for the development of Green Belt land which would constitute very special circumstances in accordance with paragraph 87 of the NPPF.

In addition no consideration has been given to the increase in traffic on the Hadlow Road, the increase in traffic with vehicles turning into the Hadlow Road from Yardley Park Road, the Ridgeway, the increase in traffic along Cannon Lane and adjoining roads leading into the town centre and Tonbridge Rail station, the increase in traffic on Tonbridge High Street, the fact that there are already no spaces to park at Tonbridge Rail station for non permit holders before 9.30am, prior to 9.30am with the rear car park already being full early morning and the increase of commuters travelling from Tonbridge Station into London.

DLP_5928

Matt Taylor

Object

I apologise for this not arriving in time for the 15th November i was away and did not know the deadline.

I would like to voice my strong opposition to the plan to build any properties on the land surrounding Tudeley. I do not for one second believe their is the infrastructure to deal with this plan, in terms of the roads, public transport, the railway and local amenities there is simply nothing in place to deal with this number of properties.

It is disgraceful that Tunbridge Wells want to use this stunning land to build the sheer number of properties they are proposing. I purposely live in this part of kent for the countryside and I do not wish for this to be marred by housing that will no doubt be tiny and crammed together as with every other recently built estate - just look at the development at Mascalls in Paddock Wood, it is horrendous, ugly, crammed together and the properties are simply not fit for a growing family so what is the point?

There has been very little investment in the local roads, they are often full of potholes and i do not see how adding 2000 extra homes to the area is going to make that any better?

Find somewhere else for your homes, Tudeley should remain green.

DLP_6196

Turley for Bellway Homes Strategic

 

The draft Local Plan proposes a standalone garden settlement (referred to as Tudeley Village) of up to 2,500 – 2,700 dwellings (1,900 of which are expected by the Council to be delivered in the Plan period). We have set out comments on the deliverability of this site elsewhere in these representations and reserve the opportunity to comment in greater detail if this site is retained in subsequent versions of the Local Plan.

This development is to be focused on the very small settlement of Tudeley. It is clear that the existing settlement comprises a small number of dwellings with very limited facilities. This view is reinforced by the overview on pages 154 - 156 of the draft Local Plan. Although the railway line runs between the site of the proposed garden settlement, Tudeley is not served by a railway station and the nearest stations are at Tonbridge (approximately 4km to the west or Paddock Wood (approximately 7.4km to the east).

The Policy does not include any requirements for the garden settlement to provide a new railway station. Policy AL/CA 1 seeks to ensure that the scheme includes:

“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.”

“Transport provision shall be delivered on a strategic basis, taking account of the impact of proposed development at land at Capel and Paddock Wood, with transport infrastructure links between Paddock Wood, Tudeley Village, Tonbridge, and Royal Tunbridge Wells. A key element will be determining the most appropriate route to link to the road network to the east, which shall minimise the impact on the existing highway network through Five Oak Green, and should seek to reduce traffic levels through this settlement, and have regard to Kent County Council minerals allocations in the vicinity and sensitive receptors such as Capel Primary School. Contributions will be required towards the provision of the potential offline A228 strategic link and eastward link to the A228 or land at Capel and Paddock Wood”

On the basis of this policy context and the description of Tudeley on pages 154 – 156, our interpretation is that the area would, in normal circumstances, be considered to be a wholly unsustainable location for the scale of growth envisaged in the emerging Local Plan. There are very little facilities or employment opportunities in the area and the existing public transport opportunities are limited. The Council’s approach appears to be that the garden settlement itself may deliver employment uses and facilities and that links to other settlements will be provided.

Bellway contend that the steps required to make Tudeley Village a sustainable location for the scale of growth envisaged are significant. The Council cannot have certainty that employment uses will be forthcoming in a manner which reflects housing delivery or that those uses will be sustained in this inaccessible area over the longer term. Whilst the Council seeks to ensure that the allocation supports the use of public transport opportunities to other settlements, it is highly likely that the garden settlement itself will continue to generate a significant level of trips by car to other locations.

It is clear that there are other, alternative options (such as the land at Mouseden Farm) which are capable of providing new homes in areas which are closer to a range of existing services and facilities which can be enhanced and can facilitate access via public transport, waling and cycling.

Bellway consider that Tudeley Village will support the delivery of a strategic scale development which is fundamentally in the wrong place.

In addition to the specific points set out above, Bellway consider that there is no clear explanation within the Council’s evidence base to explain why the Tudeley Village option has been selected and other options discounted. The area in which Tudeley Village is located in the Green Belt, as is the site promoted by Bellway at Mouseden Farm, however in the case of Tudeley Village, this does not support sustainable patterns of development and does not build upon existing facilities whereas the delivery of additional recreation at High Woods Lane would. Indeed the Council have acknowledged this as a solution by securing planning permission but cannot deliver it, so why a residential allocation to facilitate such needed recreational facilities is not being supported by the Council is a mystery.

We note that the SHELAA assessment of Tudeley Villlage (site 448) appears to be based upon assumptions about what services and facilities the development could provide. For example the SHELAA states “The Services and Facilities objective scores positively reflecting the likely well thought-out provision in the new settlement as a result of the master planning process. The settlement also benefits from the proximity of enhanced provision at the nearby North Farm retail park, Tonbridge and Royal Tunbridge Wells.”. The SHELAA also refers to “A positive score for travel is applied following a similar logic to air quality whilst also considering new bus routes and relatively easy access to train stations.

However, as we establish above, Tudeley is not served by a railway station and the nearest stations are at Tonbridge (approximately 4km to the west or Paddock Wood (approximately 7.4km to the east).

Whilst the SHELAA analysis of site 448 found the site “is considered suitable as a potential Local Plan allocation subject to further consideration”, it also found that “The site is in the Green Belt: the TWB Green Belt study (2017) identified that the harm caused by the release of land in this broad parcel is ‘high’.”

Bellway consider that the Council’s proposed allocation of a garden settlement at Tudeley Village is fundamentally unsound. The location of this site is remote and it does not benefit from a railway station. Although there are stations in the area, these are some distance away and the garden settlement appears to be predicated on the basis that a movement strategy will be implemented to access these. That primarily relies on new road links.

[TWBC: see full representation and Comment Numbers DLP_6189-6198].

DLP_6326

Persimmon Homes South East

 

Tudeley Garden Village

The new settlement is expected to accommodate 2,500 – 2,800 units in total, of which 1,900 are expected to come forward within the Plan period.

However the proposed new settlement is in an unsustainable location and is of insufficient scale to secure the necessary new infrastructure to make it sustainable.

With regard to the sustainability of the settlement, it is noted that Tudeley is too small to be assessed in the Settlement Role and Function Study and has very limited facilities and services (comprising only a pub and church). The nearest settlement to the proposed new settlement is Five Oak Green (just under 2km from the centre of the proposed new settlement) also performs poorly in the Settlement Role and Function Study with an average score of just 34 points.

Given the location is currently highly unsustainable the proposed development is required to deliver a comprehensive package of new infrastructure including:

  • Strategic highways links road to the east;
  • Secondary School
  • Primary School
  • Expansion of Caple Primary School
  • Sports and recreation facilities
  • Health facilities
  • Provision of local services and facilities appropriate to the scale and function of the settlement

Even if the settlement can bring forward this new infrastructure, this will take time to deliver, with implications for housing trajectory.

[TWBC: see full representation. Also see Comment Nos. DLP_6319, 6323-6326, 6328, 6830-6835, 6837-6839].

DLP_6815

Matfield Village Hall Management Committee

Object

Of great concern to MVH MC is the wider scope of the TWBC Local plan to create a very large settlement at Capel.

Access to & from Capel South to the A 21 highway is currently served by the wholly inadequate A 228 ‘Colts Hill’ with its notoriously dangerous bends and junctions, culminating in congested ‘traffic light’ approaches to Tunbridge Wells and Pembury.

The alternative route is the B 2160 Maidstone Road passing through Matfield past this site. Again this has dangerous bends, dangerous junctions and bottle necks at the A 21 Kippings Cross roundabout.

Clearly the transport infrastructure would require a vast improvement BEFORE such a development at Capel is commenced.

DLP_7147

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_7487

Sheila Smith

Object

Dear Mr Tugendhat,

Thank you for your letter of the 31st October.

I would firstly like to say that young families need decent housing and I don’t condone the voices of those who are happy to have houses built but not on their door step.

That said I don’t believe that enough attention has been given to the poor infrastructure around and near the site of this development.

1) we only have 2 NHS Hospitals Pembury and Maidstone they can’t cope with the number of patients they see now. Parking has been grossly underestimated by the planning departments. If you are unlucky enough to require appointments at these hospitals don’t expect to find a parking space after 8:30 in the morning. They both need multi-storey parking as bus services are quite hopeless at both sites.

2) Road and Railways Tudeley is nothing more than a sleepy hamlet serviced by a lane and Capel is not much better 2000+ houses will mean at least the same number of cars. If a number of these new families have one member working in London these people will require another car to get them to the railway station that could mean up to, or more than 1000 cars requiring parking most will not want to pay parking charges at their chosen railway station so will be looking for on street parking within walking distance of the station. Tonbridge railway station would not have enough room for this number of extra cars........better get a multi-storey parking put in there too.

The trains are heavily congested especially at rush hour. Good luck with getting to work on time.

3) I believe we also have a housing development of some 500 houses behind the fire station in Tonbridge.

4) It’s very kind of TW borough Council to fill these areas with mass housing but they should be responsible for putting in place decent roads to accommodate their plans. Also add another hospital, doctors surgery, dentists, nurseries, schools, a fire station and these families will require food stores.

Planning departments are poor on common sense you only have to look at the complete waste of money that Tonbridge and Malling council call a cycle path on the London Road between the junction of Dry Hill park and Hildenborough they narrowed the road down I believe that’s called traffic calming. The cycle path runs 500yards then you get off your bike cross the road back on your bike 500yards get off the bike cross back again all the way up to Hildenborough zig zag so the cyclist are on the narrow road Holding up cars, lorries etc. While this is going on pedestrians can fight their way through the over hanging brambles stinging nettles etc on the 18inches of path given to them. As you may gather from this last paragraph I don’t believe these people are cap or properly supervised.

I hope you find this letter for the most part constructive.

Please feel free to pass it along to anyone who might find my comments helpful.

DLP_7521

Sarah Parrish

Object

I object to the proposed plans for the local area, especially the Tudeley Garden village. This means 63% of the local plan is allocating houses on the greenbelt next to the floodplain and AONB. There has been no detailed planning or analysis for this.

Section 5 Paragraph 5.60 (Allocation Policies) p.159

How will you deal with the Main Railway Line?

How will you plan for Flooding Risk?

Tudeley Map 37 AL/CA1 (Tudeley Village) Page 157

Why is the call-for-sites land details as supplied to TWBC by Hadlow Estates incorrect?

How will it be corrected?

There are at least 4 Freehold dwellings annotated incorrectly as Hadlow Estate property. Mine is one of them.

How many more incorrect details have been supplied to TWBC?

All tied properties belonging to Hadlow Estates have been included in the Red Zoned Area – other freehold properties have been excluded from the Red Zoned area of Hadlow Estates. 1, 2, 3, 4 Bank Farm Cottages, Sherenden Road HAVE NOT. This is wrong.

Where else have Hadlow Estates made errors (with intention or with laziness to check – raising false assumptions – for which the TWBC have not bothered to check the details either?

Policy AL/CA 1 (Tudeley Village) p.160

How will TWBC change the Local Plan, by cancelling the intention of a Tudeley Garden Village, to adhere to the NPPF?

How can you consider a garden Village split in two by a Railway?

How will you protect the Heritage that exists?

How will TWBC control the Local Plan?

DLP_7524

Ray Wiffen

Object

I would like to express my deep concerns at the proposal of plans for over 2000 homes in Tudeley and Paddock Wood. The area and facilities are already over stretched and the hospitals and doctors can not cope at the moment with the development of the local area. It is such a shame to see the whole of Kent flooded with houses. The garden is England is no longer an area of green space and It is shocking that Tunbridge Wells council is happy to propose such plans so close to the borders of Tonbridge and Malling. If action is not taken Kent will sadly no longer be a desirable place to live, roads, schools, doctors, hospitals, can not cope with this influx of people.

DLP_7595

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.

DLP_8374

Nicola Gooch

Support

AL/CA1

Tunbridge Wells is highly constrained, with large parts of the borough covered by either the High Weald AONB or Metropolitan Green Belt - so there are limited opportunities for development of the scale required to meet the growing housing needs of the borough.

This new Garden Village would be well connected and the provision of a new settlement would also allow for significant improvements to local infrastructure. There is also a lot to be said for taking a holistic approach to planning for housing delivery - starting from the ground up gives a real opportunity to build a properly functioning, sustainable, community, which is a rare prospect these days.

The new village will need to be carefully masterplanned, following Garden Village principles, and accompanied by signficant infrastructure investment, but it has the opportunity to be something really special. It would also make a significant contribution to the Borough's housing land supply.