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Section 5: Place Shaping Policies Paddock Wood


This response report contains comments received on Section 5: Place Shaping Policies Paddock Wood.

Contents

Policy STR/PW 1: The Strategy for Paddock Wood

Comment No.

Name/Organisation

Response

DLP_60
DLP_867

Thomas Weinberg
Ian Pattenden

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

Comments on Policy STR/PW 1 (The Strategy for Paddock Wood) p.170


The expansion of Paddock Wood can be achieved without using land at East Capel for housing. Flood storage/attenuation/mitigation measures may be useful there but no housing is required. In fact, providing housing will contravene the NPPF as East Capel is Green Belt and the removal of East Capel from the Green Belt will cause coalescence with Five Oak Green. This is not permissible as the inclusion of East Capel in the expansion of Paddock Wood is not an “exceptional circumstance”. This is further described in comments on the Sustainability Appraisal.

DLP_70

The Access Group

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

2. THE MAJOR CONCERNS

  • Paddock Wood is already growing and will clearly continue to grow into a large town, the "intention" to provide extra schools, GP surgery etc must become a serious overall planning condition imposed by the LPA on all developments within this area to reduce the growing demand mention above, which the existing services cannot cope with.
  • As a result of these new developments as indicated, prior to the commencement of the development:

- New self contained GP & Dental Surgeries

- Primary & Secondary Schools

- Guaranteed transport links

must be included as part of each development being permitted to take place. These along with the three major legal demands set out in this letter [TWBC: see Comment Numbers DLP_66-67] must be planning conditions imposed by the LPA, if they cannot be met then planning approval must be postponed or refused.

[TWBC: this comment has also been placed against Policy STR 5 - see Comment Number DLP_71].

DLP_115
DLP_117
DLP_119
DLP_146
DLP_148
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DLP_402
DLP_428
DLP_431
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DLP_438
DLP_448
DLP_485
DLP_497
DLP_500
DLP_502
DLP_507
DLP_509
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DLP_630
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DLP_715
DLP_790
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DLP_826
DLP_829
DLP_831
DLP_845
DLP_891
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DLP_991
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DLP_1010
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DLP_1017
DLP_1019
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DLP_1410
DLP_1417
DLP_1422
DLP_1432
DLP_1440
DLP_1443
DLP_1656
DLP_1659
DLP_1661
DLP_1667
DLP_1671
DLP_1712
DLP_1731
DLP_1997
DLP_2000
DLP_2159
DLP_2266
DLP_2294
DLP_2345
DLP_2355
DLP_2362
DLP_2376
DLP_2379
DLP_2382
DLP_2518
DLP_2525
DLP_2555
DLP_2558
DLP_2560
DLP_2563
DLP_2565
DLP_2568
DLP_2571
DLP_2576
DLP_2581
DLP_2583
DLP_2586
DLP_2588
DLP_2590
DLP_2592
DLP_2618
DLP_2620
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DLP_2627
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DLP_2814
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DLP_4058
DLP_4060
DLP_4082
DLP_4087
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DLP_4099
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DLP_4426
DLP_4431
DLP_4450
DLP_4453
DLP_4525
DLP_4527
DLP_4529
DLP_4603
DLP_4609
DLP_4612
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DLP_4638
DLP_4642
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DLP_4888
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DLP_4995
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DLP_5150
DLP_5168
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DLP_5197
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DLP_5286
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DLP_5297
DLP_5300
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DLP_5462
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DLP_5489
DLP_5491
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DLP_5509
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DLP_5531
DLP_5539
DLP_5548
DLP_5568
DLP_5629
DLP_5781
DLP_8310
DLP_4523
DLP_5709
DLP_639

James Deasy
Charlotte Deasy
Emma Deasy
David Rabbett
Jacqueline Rabbett
Linda Barretto
Nigel Barretto
Norman Pickett
Tony Castleden
Lyn Castleden
Christopher Wise
Iain Thomas
Lawrence Matthews
Andy Myers
Martin Meyer
Neil Brooks-Johnson
Hangman's Hill Residents Association
Claire Songhurst
Eleanor Arscott
Julie Smithers
Sara Day
Paul Hunt
Mrs Linda Hewings
Ian Huddart
Simon Walton
Rosemary and Bernard Hayton
Alison Edwards
Petrina Lambert
Samantha Fenton
David Crouch
Mary Crouch
Paul Cullen
Nicholas Harris
Graham Roy Edwards
Graham Edwards
Anne Etherington Rich
Mr Nigel Lambert
Mary Lambert
Alexander Fenton
Amanda Parkes
Sarah Branch
Kit Hawes-Webb
James Arscott
Simla Patel
K and L Entacott
Elise Patel
JG and BA Burchett
Megan Forster
Gwendoline Lamb
Nicola Kearns
Tessa Allen
Fiona Pengelley
Susan Whitfield
Daniel Bird
Heidi Wiltshire
Summar Larter
Irene and Tony Thomas
David Perry
Anand Ganguli
Neil Nisbet
Valerie Walker
Nick Hebditch
Roger Maxted
Rachel Cattanach
Paul and Kate Chalklin
Peter Bowden
Marilyn Bacon
Geoffrey Newby
Charlotte Kearns
Andrew Hallifax-Lyons
Katie Lewis
Alexandra Standen
Rosemarie Hicken
Vivien Concannon
Hany Hakim
Rebecca Richmond
Sharon James
S Parrett and family
Dermott Young
Stephen Thompson
Sarah Thompson
John England
Janet Connor
Jim Madar
Linda Jorden
Ann Crosby
Janet and Tony Griffiths
Nick Gandon
Jamie Gandon
Thomas Gandon
Sadie Gandon
Andy Bowerman
Anna Trafford
Hubertus van Hensbergen
Jennifer Rohan
Jon Elliott
Stefan Knight
Lucy Skinner
Christopher Dennis
Sean Lloyd
Joanna Baldock
Patrick Fretwell
Paul Andrews
Lynn Hams
Catherine Willan
Rhea Patel
Alistair Cook
Mrs Jenny Vincent
Sajjad ur Rehman
Sarah Hughes
Jane Anscombe
Juliette Negri
Daniel Maxted
Anthony Baldock
Victoria Maxted
Alex Baldock
Luke Baldock
Nicola Maxted
Hugh Fairbairn
Richard Songhurst
Dr David Parrish
Helen Homard
A Price
John & Linda Chapman
Richard & Tracy Paddington
Jan Bedden
Lara Shatto-Sweeney
Alexander Clelland
Matthew Edwards
Maria Gonzalez
Paul Latham
Philippe Negri
Barry Watson
E Vans
P Simmons
Ellen Worrow
Terry and Christine Vidler
R J Allen
Pauline Till
Resident of Bourne Park
Rod Belsey
Marion & Richard Marcroft
Beverley P Callaghan
Patrick O'Malley
P Sierts
Jessie Moon
Mr S Munday & Mrs J Munday
Pamela Summers
Lynne & John Fuller
Mr & Mrs C Cadell
Mary Norris
Sally Goldstone
Sallyanne Clark
Andrew Bowen
Joanna Osborne
Tara Stanley
Thomas Pack
Will and Tara Biddle
Suzy McAllister
Catherine Gunton
P Scally
Deborah Wilcock
Richard Kaupert
James Wade
Lesley Stanley
Sarah Faes
Ian Tilley
Mark Bourne
Mr Andrew Rankine
Cassandra Cook
Matthew Vickers
Colin Hurley
Steve Parrish
Ruth Rankine
Nicola Van Hensbergen
Catie Walklin
Michael McKee
Neil & Jill Goldsworthy
Caroline Brooks-Johnson
Carol Stanton
Claire Light
Mr Steve Morecroft
Mr Collin Godsave
Claudia Johannes
Mr and Mrs Kauper
Janis Lee
Rufus Beard
Clare Thorpe
Maureen Dennis
Kirstie Hart
Colin Burgess
Ann Stammers
Anthony Bagwell
Sean Waddingham
Fiona Claire
Kim Botten
Kerry Allen
Lorraine Ballard
Jean Thompson
Simon Hewitt
Olivia Rose-Wilson
Shane Priestman
Tom Barber
Michael Dale
Hannah Grogan
Noelle Quinn
Christine Bowden
Drs CR and EJ Buchanan
Debra Brindle
James Carpenter
Kim Stanley
Gordon Hodge
S George
Zara Marsh
Caroline Lovell
Joanna McEachern
Michelle Sanna
Paul Alderman
Cristiana Dias-Dafforn
Patricia Mathieson
Judith Deckers
Michael Perretta
Mandy Pereira
Mike & Ginny Stennulat
Jackie Smith
Abigail Grundon
Residents of Golden Green Association
Andrew Deckers
Johnny Boult
Caroline White
Lesley Probert
Sarah Marchant
Kimberley Miller
Chris and Jessica Lowe
Stuart Hodgson
Jillan Haydock
Rebecca Waugh
Mr Raymond Steward
Natarajan Kannan
Natasha Hiddingh
Ellis Parsons
Hugh and Lindsey Rayner
Ian and Dawn Davis
Diana Clark
Paula Fry
Louisa Curchod
Louise Knight
Ruth Mullan
Geoff Pearson
Mr B Lambert
Angela Pattenden
Mr and Mrs J Hancock
Barry Holsman
Ari Philips
Ismini Philips
Hadlow Estate Resident
Lisa Landreau
Derek Fouche
Graham Whibley
Nicholas Lang
Tracey Jones
Eddie Haydock
Anita Peach
Elizabeth Andrews
Katherine Weinberg
Maria McNamara-Westlake
Steve Waugh
Tim Farazmand
Alison Williams-Walker
Hayden Parsons
Stefan Jansen
Jonathan Sayers
Stephanie Sagar
Eliza Chilvers
Edward Howison
Peter Gurr
A Richardson
Richard, Hollie, Harry & Jack Sadler
Emma Hicks
Bruce Preston
Natalie Sadler
Amalia Floyd
Melissa Funnell
Joanne Warnett
Emma Vickers
Julie Tilley
S Thompsett
Duncan Beagley
Sarah Johnson
Kate Shorten
Robert Davis
Helen Pratt
Arnold Hugh Foster
Tony Ansell
David Dunlop

TWBC: the standard response was submitted by the list of responders on the left:
object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1). 

This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel. The comment above about coalescence and the creation of a conurbation from Paddock Wood right across to Tonbridge is very relevant here, as is the land’s use as a flood plain. Building here, even with flood risk mitigation and “betterment” could have disastrous consequences for all, as the measures being looked at are based on old data that does not fully consider the impact of climate change.

TWBC: The standard response (as above) with the following additional comments were submitted:

DLP_405

Charlee Harman

Standard comment as above, plus the following additional comment:

As a council perhaps you should be listening to the needs of your current residents rather than creating an issue which could be avoided by presenting ideas that will be economically viable to our communities and local businesses.

DLP_407

Colin Leake

Standard comment as above, plus the following additional comment:

The dictionary definition of a village is a small group of houses in a rural area. This was never a Garden Village it is plainly a New Town

The fact that after two years of supposed planning this plan has been published with a total lack of detail would suggest very little proper planning has been undertaken. The mad ill-considered proposal for a new school on a totally unsuitable site is but one example of this

DLP_423

Adrian Dawn

Standard comment as above, plus the following additional comment:

I do not live in these areas but know them well. All of the above I agree. This is madness to build such a large settlement in these areas.

DLP_425

Susan Marchant

Standard comment as above, plus the following additional comment:

There is no advantage to anybody in pursuing development in this area. 

I am hopeful that my objections will be considered carefully and fairly and that TWBC will be mindful of local opinion on this issue. There is no need to blight Capel Parish in this way and the Tudeley site should be removed from the Draft Local plan.

DLP_433

Coralie Tringham

Standard comment as above, plus the following additional comment:

I have no issue we nearby housing, increased lighting needs etc etc as nothing stands still and areas must continue to grow. However the motives here do not seem practical or well rounded but rather driven by planning convenience over long term and thorough practicality. Schooling and infrastructure especially are hugely important here and if the recent Tonbridge high street redevelopment is anything to go by you are determined to make things worse.

Green, sustainable, bikeable and health friendly planning must be front and centre of a national, cohesive strategy and this plan is the absolute antithesis of this. Start with rail, bike way or bus route development, then cite and develop school/amenities and finally an area fit for human habitation can emerge. The climate will not tolerate any further poor decision making.

DLP_504

Lucy Bradley

Standard comment as above, plus the following additional comment:

Tonbridge town has expanded in size over the last few years due to the amount of flats that have been built. Local amenities such as doctors practices and schools are already feeling the strain of the increased population this has brought. Traffic is has worsened due to recent changes to the high street and additional shops in the industrial estate. The town does not have the infrastructure to take the inevitable surges in congestion and population that will result from this plan.

DLP_530

Emily Mercer

Standard comment as above, plus the following additional comment:

As a personal experience, along Whetsted Road, traffic is already a nightmare, even out of school term time. The idea of building that many houses opposite will incur a massive knock on effect that will likely make traffic, noise and pollution even worse along this road. Furthermore, the fields opposite (the site of some of the houses planning to be built) are just some of the areas of classic countryside in the community that make Kent the 'Garden of England', and building on areas like these destroys that representation of Kent, as well as the local community for residents (and wildlife!) who reside in Kent due to the rural and peaceful nature of the area. I have had such a wonderful childhood in this area, my friends who came from council estates were always jealous of the space and beautiful scenery we have here, and it would be such a shame to destroy this for our community and future generations, especially as climate change is currently a massive issue that we should working together to fight - this can only be done by preserving our green spaces.

Addressing Greg Clark - In my opinion, you did such a wonderful and respectful job standing up for our community against Boris Johnson when you publically opposed the Brexit deal. We need this same attitude towards this Local Plan, to prevent a terrible decision to permanently destroy the area!

DLP_685

Helen Connell

Standard comment as above, plus the following additional comment:

I lived in East Peckham about 17 years ago when we had the floods at Old Road, East Peckham and it was devastating for those properties, please reconsider this for the sake of local people and local wildlife.

DLP_2165

Bryan, Jane and Rosalind More

Standard comment as above, plus the following additional comment:

Further comments

1. At present the traffic from Paddock Wood is increasing and will continue to do so when the houses at present being constructed at Green Lane and near Mascalls Corner are completed.  Developments of the site at East Capel will add to the congestion at the Dampiers roundabout and up Colts Hill and cause even more delay at Pembury cross roads and along the notorious Pembury Road.  If traffic goes from Paddock Wood through Matfield to Kippings Cross and the A21 - already a trouble spot - there will be more congestions. At present there is a traffic incident/accident at Dampier roundabout approximately every nine days causing delays and closure on this vital through route for ambulances travelling with blue lights between Maidstone Hospital and the Tunbridge Wells Hospital at Pembury.  Traffic through Five Oak Green village consists of many heavy lorries passing the Primary School at Capel, often ignoring the 30mph and 20mph speed restrictions.

Flooding 

At Christmas 1999, the first Christmas we moved here near to Dampiers Corner on Badsell road, we witnessed the serious flooding of Five Oak Green Village. This has continued to be a source of anxiety and frustration for the village.  At Tudeley Brook Farm, further down the Maidstone Road and adjacent to the proposed Capel East Development, there has been serious flooding requiring construction of a flood barrier to protect the house and stables.  This problem will be exacerbated in the area covered by the proposed development.  Also, on both the Capel East and "village settlement" the cost of house insurance policies, even if available, would surely be inordinately high because of the flooding risk.

Sewerage

The question of sewage treatment for both areas is vitally important.  The present arrangements are, we believe, inadequate.  Sewage from Five Oak Green already goes to the Paddock Wood plant so the proposed development at Green Lane and Mascalls Corner will inevitably lead to capacity problems at Paddock Wood.  Is there to be a treatment site at the village settlement?

We await the outcome of the Borough Council's decision with great interest.

DLP_793

Gill Keenan

Standard comment as above, plus the following additional comment:

I believe that once Green Belt land is allowed to be built on, then this will open the floodgates to developers, and our precious green England will be no more.

DLP_2573

C A Hogg

Standard comment as above, plus the following additional comment:

Build on Brown Field Sites. You only want to build on green field sites as it is less cheaper and hassle. I agree with Brown Field Sites.

DLP_4056

Jill Giles

Standard comment as above, plus the following additional comment:

I truly hope TWBC consider the views and objections of the residents who will be most adversely affected by this proposal even though they don’t live in the borough of Tunbridge Wells!

DLP_2367

Martin Rohan

Standard comment as above, plus the following additional comment:

I trust you will take these comments into account as we as a community feel VERY strongly about the proposed plans to ruin our countryside,

DLP_4097

A Scally

Standard comment as above, plus the following additional comment:

Please do not spoil this wonderful countryside. There is a reason it is designated as green belt and should be preserved for future generations. 

DLP_4320

Sue Fairbairn

Standard comment as above, plus the following additional comment:

In conclusion I would like to add that I am not a nimbyist – I just don’t feel that the type of development proposed is suitable for these sites due to the many concerns listed above, summarised again here:

1. The Flood risk cannot be mitigated

2. The green belt should not be sacrificed until all other options have been exhausted.

3. There is a complete failure to provide suitable infrastructure to improve the lives of those already living in the area.

4. It would be placing an unfair burden on a neighbouring council, rather than its own, whose facilities and services would be used with no financial gain from the development.

5. The area of outstanding natural beauty is home to many species of wildlife which will disappear if their habitat does.

6. Need has not been proved, and if need exists it is for affordable homes for local people not expensive homes for the extended stockbroker belt.

DLP_4639

Rosie Bleet

Standard comment as above, plus the following additional comment:

As stated above, flood mitigation is not the answer; we should be reducing the need for mitigation by not building on areas that are vulnerable to flooding to start with.

DLP_4756

Amy Constant

Standard comment as above, plus the following additional comment:

We, as a Nation and the World as a whole have a duty to take climate change seriously or there will be no planet left to build houses on. Once great swathes of Green Belt land, like the sites identified in the Local Plan, are destroyed, they can never be replaced. It is this Green Belt land which is allows for greater biodiversity, food production and flood protection by supporting the absorbtion of rain water. For the sake of my children and future generations, I sincerely hope that the Local Plan team take this proposal and process forward with the gravity it deserves.

DLP_4846

Joanna Nightingale

Standard comment as above, plus the following additional comment:

In addition to this the quarry in Whetsted Road is being re-opened anyway with plans (which I have objected to also) to expand massively. Whetsted Road can't cope with the amount of HGV's going in and out of Scripps as it is. This traffic has increased hugely sine we moved in 2007. It is damaging the road and our houses with these HGVs rumbling along 7 days a week. It can't cope with any more traffic.

Stop the plans please. They are insane.

DLP_4905

Emma Hewage

Standard comment as above, plus the following additional comment:

Finally, greenbelt is for everyone and not just the few that live in or near it.  A strategic local plan for the next 15 years, particularly these next 15 years, should outline the vision for the greenbelt in TWBC and how the council is ensuring everyone has opportunity to benefit from this natural resource.

DLP_4955

R. G. Cazalet

Standard comment as above, plus the following additional comment:

As the current flooding elsewhere shows there is a lot to be learnt about the causes and the prevention of flooding and about how actions in one area can have serious effects elsewhere. This surely should, at present, be a very strong argument against building on any area of flood plain.

DLP_4968

Rachael Foster

Standard comment as above, plus the following additional comment:

The plan also states that there will be an inclusion of “a three pitch one mobile home and (one touring caravan per pitch) gypsy/traveller site on this land and in Paddock Wood Town Centre (AL/PW 2)". This is again an irresponsible move and one to which I severely object. These sites are a blight on the landscape and severely and negatively impact the price of neighbouring homes as no-one wants to live near or next to such a site. They often mean crime and anti-social behaviour significantly increases in the area and given that Somerhill Green has been subjected to two burglaries in one week recently along with a recent assault from a gang who’ve recently inhabited Tonbridge I don’t want to subject my children and family to more crime.

DLP_5005

Andy & Katey Halford

Standard comment as above, plus the following additional comment:

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.

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. I 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_5013

Mrs Sophie Cashman

Standard comment as above, plus the following additional comment:

Over the years Paddock Wood has seen huge development in regard to new housing but unfortunately the infrastructure and facilities have not been improved in spite of promises that have been made with every new development. My friend's constantly experience problems with water supply and sewage issues. The High Street offers limited shopping options so residents head in privately owned cars to Tonbridge or Tunbridge Wells. This scale of housing in this area without complete regeneration of Paddock Wood town centre, services, facilities and infrastructure is simply not sustainable. Residents are already voicing concerns over increasing crime levels and non existent police presence.

DLP_5014

Sara Davis

Standard comment as above, plus the following additional comment:

Finally I must say how sad I am that we may lose the “green lungs” which make this part of Kent a lovely place to live with its balance of small towns and villages with ancient woodland, farms and the river valley.

DLP_5020

Pauline Bevan

Standard comment as above, plus the following additional comment:

I ask myself, why oh why in these times of global warming, why fill these beautiful fields with concrete blocks!!?? We need all the green fields and woodlands to sustain us. It will be a tragedy if this all goes ahead.

DLP_5023

Bernadette Cawley

Standard comment as above, plus the following additional comment:

Finally I also object to inaccurate information being included in the Plan regarding land ownership in Tudeley.

DLP_5033

David Sagar

Standard comment as above, plus the following additional comment:

In summary this plan is going to be hugely damaging to the surrounding areas and I believe it would drive long standing residents into finding more suitable places to live. This is going to have a huge long term economic impact on the area as well as the short term direct impacts outlined above. I don’t want this to happen to the place we call home.

DLP_5038

Hayley & Simon Hobbs

Standard comment as above, plus the following additional comment:

We feel angry as residents that Tunbridge Wells is building the housing and making this decision, when the negative impact will be felt in Tonbridge and Malling.

DLP_5039

Colin Nye

Standard comment as above, plus the following additional comment:

In addition to my personal comments made at the beginning of this letter of objection I have included information provided by the Save Capel Group which I have read and thoroughly agree with.

DLP_5042

Jenny Nye

Standard comment as above, plus the following additional comment:

Not only will these proposals have a serious detrimental effect on Tonbridge residents but will seriously affect those who would be living in the “new” houses”. They would be as badly effected as exisiting residents and no doubt wonder why they moved to the location in first place.

In addition to my personal comments made at the beginning of this letter of objection I have included information provided by the Save Capel Group which I have read and agree with all the points made.

DLP_5069

Stephanie Tizzard

Standard comment as above, plus the following additional comment:

I would also like to add that as my husband is an on call firefighter, he must live no more than within a 5 minute “turn out” area of the Paddock Wood Fire Station. We live on Badsell Road in Five Oak Green. If this plan goes ahead, my husband (and a lot of other local trained firefighters) will no longer be able to remain on call at Paddock wood fire station. The shear increase in traffic (even during construction) would render our location unviable.

I used to work in London. I’m glad I don’t anymore. The trains when I did commute were FULL with no seats available. Would you be able to increase trains in regularity in relation to the increase in local population (x5?).

Would these properties be affordable? And by affordable I don’t mean £400k+. The houses in the local area aren’t selling in the current climate and haven’t been selling for at least 2 years. I should know, I’ve been looking to move within five oak green but even with our two incomes, a £400k house is too expensive. I can assure you I would not buy one of your new builds.

Five oak green and the surrounding areas FLOOD….REGULARLY. Green belt and farming land is a huge flood defence from GROUND WATER FLOODING. Ignoring the local river ways, if you cover fields in concrete there is nowhere for ground water to go.

I appreciate you need to build more houses…. But building with ONE land owner and placing so many houses in two areas is: 1. Lazy planning, 2. Greedy and 3. Irresponsible to wildlife.

What is the point in Green Belt land when to someone with enough money and influence it means nothing? Are you against the law or morality? I wouldn’t be allowed to build on green belt land so why are you?

DLP_5199

Stephen Constant

Standard comment as above, plus the following additional comment:

In summary as a resident of Tonbridge I believe TWBC have created a plan which benefits only them and creates huge issues for neighbouring boroughs. I suspect those who are pushing this forward will not be effected, the areas they represent are well away from this development and building here will ensure there is little or no disruption to their electorate and local area. Given the anticipated strain on food supplies in the future why are we building on farmland that is productive, once it is built on you cannot get this land back.

DLP_5123

Linda Garratt

Standard comment as above, plus the following additional comment:

As a Tonbridge resident, the whole plan smacks of Tunbridge Wells trying to offload its housing problem onto another borough with no thought or care about the consequences upon the communities affected on the fringes of your own borough... even when they pay their council tax to you.... and with little thought to the impact on the environment and wildlife. I do not feel enough thought has been into mitigating the impact of these proposals and those suggested are deeply flawed. Whilst buying up a job lot of land from one landowner "makes life simple" for the council the potential consequences are far-reaching and devastating.

DLP_5292

Lee Cashman

Standard comment as above, plus the following additional comment:

Over the years Paddock Wood has seen huge development in regard to new housing but unfortunately the infrastructure and facilities have not been improved in spite of promises that have been made with every new development. My friend's constantly experience problems with water supply and sewage issues. The High Street offers limited shopping options so residents head in privately owned cars to Tonbridge or Tunbridge Wells. This scale of housing in this area without complete regeneration of Paddock Wood town centre, services, facilities and infrastructure is simply not sustainable. Residents are already voicing concerns over increasing crime levels and non-existent police presence.

DLP_5312

Jason Foster

Standard comment as above, plus the following additional comment:

The plan also states that there will be an inclusion of “a three pitch one mobile home and (one touring caravan per pitch) gypsy/traveller site on this land and in Paddock Wood Town Centre (AL/PW 2)". This is again an irresponsible move and one to which I severely object. These sites are a blight on the landscape and severely and negatively impact the price of neighbouring homes as no-one wants to live near or next to such a site. They often mean crime and anti-social behaviour significantly increases in the area and given that Somerhill Green has been subjected to two burglaries in one week recently along with a recent assault from a gang who’ve recently inhabited Tonbridge I don’t want to subject my children and family to more crime.

DLP_5320

Sue Goldfinch

Standard comment as above, plus the following additional comment:

I remember the last bad flood in Tonbridge and cannot believe that you would intend to inflict this on a community willingly!

DLP_5358

Neil MacAskill

Standard comment as above, plus the following additional comment:

Please don’t spoil Kent and our precious green land, and the quality of Tonbridge district residents to suit TWBC targets – for the sake of future generations

DLP_5785

Mrs Jacqueline Hayward-Gant

Standard comment as above, plus the following additional comment:

I live in Paddock Wood and this directly affects our environment and car journeys.

This and the Paddock wood housing policy and flooding we already have will impact us all.

Now a letter dated the 8th November for land at Mascalls Farm( phase 2) Badsell road, Paddock wood by Berkeley homes wants an additional proposal for an increase of 117 homes. This is an existing disaster for the area from Paddock Wood to Capel to Tonbridge.

My garden floods badly after heavy rain but has a field at the back of my house.

The water takes weeks to drain away.

How on earth what would all these additional properties do to the existing flooding we already have before these homes, etc, would cause, a huge amount of flooding to the area.

The flooding that caused huge floods in this area and Yalding out to Tonbridge made all the roads impassable and killed livestock at Paddock Wood Hop farm as they died a pony in a stable in distress then drowning plus other animals.

The flooding went above the lanes crossing to both sides of the fields so I could not even see the lane with rivers both sides and got severely psychologically damaged as I had to continue as the lane was too small to turn round, having to get to my horse in Willow lane and check all the other horses and add multiple bales of straw on top of the water which had entered all the horses and ponies as it was too high and unsafe to let them out as there was no where to take them as here to past Yalding to Tonbridge including 5 oak Green and Capel were flooded too.

Two shires had to be moved out of the Hop farm as they were in 5 feet of water.

The water poured into my car through over the wheels and into my car and was extremely frightening.

Additional homes would make the flooding more prevalent.

The water and sewage pipes already can not cope and this is pre any additional housing.

What will thousands of more houses do to flood risk and environmental risks.

Our homes will be difficult to gain house insurance and buildings insurance for damages so will Tunbridge Wells be covering any potential damage ?we will receive from the additional housing I believe being placed by greed by the owners of these large estates.

[TWBC: See image 1 and image 2]

DLP_6119

Tim Page

Standard comment as above, plus the following additional comment:

In my employment I drive a lot around the area. I can see that the roads at present can not take the size and volume of traffic now. Road edges and verges are being demolished and this is with out the increase additional housing brings. Not just resident commuting but the vehicles required to service and support. I strongly feel the there is not the infustructure for this development.

DLP_6532

Robin & Gillian Dunn

Standard comment as above, plus the following additional comment:

It seems obvious to us, as to many other Tonbridge residents we have spoken to, that TWBC is seeking to take advantage of our local area in a reckless manner, with total disregard to the needs of local Tonbridge & Malling residents and tax payers.

DLP_6636

Eugene & Nicky Androsov

Standard comment as above, plus the following additional comment:

I hope you can see that there are more than ample reasons why these developments should not go ahead and indeed would create far more problems than it is intended they solve. Please review and overturn the current strategy.

DLP_7121

Mr Jeff Fenton

Standard comment as above, plus the following additional comment:

TWBC Transport Strategy 2015-2026 – States - By 2026, Tunbridge Wells will have a transport network which is less reliant on the private car, with a greater mode share towards walking, cycling and public transport, especially for shorter journeys. However, it is recognised that some journeys will continue to necessitate use of the private car, especially in rural areas.

Capel is a rural area, Tudeley new village within Capel will be a rural area, Paddock Wood is a rural area. Where in this TWBC 2015-2026 Transport Strategy does their claim fit that their precious housing need is sustainable?

Build on Brownfield and NOT on Green Belt land!

The TWBC Draft Local Plan is unsound and unsustainable.

DLP_1004

Linda & Hugh Bingham

Standard comment as above, plus the following additional comment:

We think building on green belt land is totally wrong. This country should be trying to become more self sufficient with food, and not turning it into concrete. Once this is done the land for growing food is lost forever.

This whole impact on Tonbridge will be unbelievable. The road, parking and surgery use is difficult enough now, but if this goes ahead it will absolutely ruin Tonbridge, and it's completely wrong that a neighbouring council could do this

DLP_5475

Jack Marr

Standard comment as above, plus the following additional comment:

I live in Hadlow, and frequently drive along the roads along which the development in question will be sited. I grew up in the area and am deeply dismayed by the proposal as it will irrevocably alter the character of the area, overload the roads and existing infrastructure, present a flood risk and have a terrible impact on the ecology of the area. We have a collective responsibility to preserve Green Belt land and to use brownfield sites instead wherever possible. I expand on my objections below.

I urge you to bring this plan to an immediate halt.

DLP_5658

Angie Liddell

Standard comment as above, plus the following additional comment:

Please reconsider and look alternatives - we cannot continue in this way with no forethought for future generations.

DLP_5669

Paul Nightingale

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel. The comment above about coalescence and the creation of a conurbation from Paddock Wood right across to Tonbridge is very relevant here, as is the land’s use as a flood plain. Building here, even with flood risk mitigation and “betterment” could have disastrous consequences for all, as the measures being looked at are based on old data that does not fully consider the impact of climate change.

Building in Paddock wood on the site Badsell Road / Mascalls is underway and it is already a nightmare.  It is a single lane road in and out and there is constantly temporary lights on the road which the road can’t cope with.  I dread to think how long we will have to live like this already!  The building at Mascalls Grange has come to a halt, due to the following reasons, 1) they can’t sell the houses they have built already in the first small phase and so they can’t build more and 2) they are having problems with drainage eg septic tanks etc.  There are approx. 10 houses that are currently for sale in Five Oak Green alone (that have been on the market for a long time) that are NOT selling.  We do not need more homes here.

In addition to this the quarry in Whetsted Road is being re-opened anyway with plans (which I have objected to also) to expand massively.  Whetsted Road can't cope with the amount of HGV's going in and out of Scripps as it is.  This traffic has increased hugely sine we moved in 2007. It is damaging the road and our houses with these HGVs rumbling along 7 days a week.  It can't cope with any more traffic.

Stop the plans please.  They are insane.

TWBC: end of standard comment with additional comments added

DLP_5050

Stephney Dallmann

I live at xxx, Colts Hill, Five Oak Green [TWBC: part of postal address redacted]. My daughter attends school at Derwent Lodge, Somerhill and I drive on the roads from Colts Hill to Tonbridge, passing through Tudeley in the morning and evening every day. The journey in the morning, around 8am, is always significantly congested with a queue from Tudeley Church all the way to Somerhill School and then on to Tonbridge railway station. I then commute to London. My main concern is that with an additional 2,800 houses at Tudeley, 1500 houses at East Capel and a Senior School opposite Somerhill, I would literally not be able to get anywhere. The roads would be gridlocked. Then the additional pressure on Tonbridge Railway Station would be very significant - with not enough parking available at the station and overcrowded trains meaning we would need to stand all the way to London.

As well as these practical concerns which will have a very significant impact on my day to day life, I am dismayed that the most beautiful landscape will be scarred forever for future generations. It is one of the most beautiful views of our countryside from the top of the hill looking out over Tudeley. To think that will be gone is just awful. It can never be rectified. And it will be a most terrible legacy for future generations.

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel. The comment above about coalescence and the creation of a conurbation from Paddock Wood right across to Tonbridge is very relevant here, as is the land’s use as a flood plain. Building here, even with flood risk mitigation and “betterment” could have disastrous consequences for all, as the measures being looked at are based on old data that does not fully consider the impact of climate change.

My additional concern for the land at East Capel, is that living on Colts Hill, where the traffic is already very heavy, it is going to make my road even more dangerous and congested to the point of not being able to get anywhere. I can't understand how the road will cope with this amount of additional traffic.

I object to these proposals in the strongest terms,

DLP_5415

Iain Mills

I live in Woodfield Road in Tonbridge and regularly commute into London. I also regularly visit Tudeley, meeting up with friends and enjoying the Church and other amenities that the current village provides.

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

I believe it is important to consider other options for housing within the existing town centres of Paddock Wood, Tunbridge Wells and Tonbridge, using brownfield / industrial land that is currently underdeveloped. Infill developments are closer to existing transport infrastructure and can allow residents to walk / cycle to the stations, without adding additional car journeys on the already busy roads.

DLP_5418

Valerie Coleshill

Dear local plan team, My husband and I have lived at XXX Crockhurst street cottages Tudeley for 46 years [TWBC: House number redacted]! I have lived in Tudeley all my life!  Our residence is directly on the B2017, we overlook an area of outstanding natural beauty! My children and my grandchildren have benefited from this very rural setting! We are now very concerned as to what the future holds for Tudeley and certainly do not approve of this local plan for its future!

We object to the inclusion of land in East Capel in "The strategy for Paddock Wood"(policySTR/PW1) This is Greenbelt land and should only be built on if exceptional circumstances exist!

TWBCs own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plans aims without using the Greenbelt land at East Capel. The coalescence and the creation of conurbation from Paddock Wood right across to Tonbridge is very relevant here, as is the lands use as a flood plain. Building here could have disastrous consequences for everyone, as the measures being looked at are based on old data that doesn't fully consider the impact of climate change!

DLP_5420

Peter Borrett

We bought our house in Five Oak Green because it is in a very nice Green Belt area, we strongly object to your plan for 2,800 houses which will ruin the peaceful and beautiful place we live in. please add my contact details to your consultation database so that I can be kept informed. I understand that my comments will be published by the Borough Council, including on its website.

I OBJECT TO THE INCLUSION OF LAND IN EAST CAPEL IN “THE STRATEGY FOR PADDOCK WOOD” (POLICY STR/PW1).

This land is Green Belt land and should only be built  upon if an “exceptional circumstance” exists, TWBC’s own assessment in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using Green Belt land at East Capel. This land is used as a Flood Plain.

Last point, if this building of houses goes ahead, TWBC will have to remove the sign at the beginning of the A2017 “Love where you live”, as we most certainly will not.

DLP_5426

Robert Botten

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. I don't believe that there are exceptional circumstances and as mentioned above it is important to keep substantial buffer zones between places to preserve those things that make this area such a nice place to live.

DLP_5435

Susan Bottomley

I am writing to strongly object to”The  Strategy for Capel Parish”(PolicySTR/PW1).

My name is Sue Bottomley ,I-Live at XXX, Five Oak Green ,XXX I have lived here since June 1998 [TWBC: House number and post code redacted] . Our Home is positioned on the main road , Exactly opposite the Alders brook, To the side of my home is a drive way that is in active use by southern water at the bottom of the drive is their Pumping station. Which gets regular attendance.

Xmas eve 2000 it was late that evening as we watched in horror at the water from the brook come over the top onto the road , then down to the green , & surrounding roads , Off of the main road ,it was horrendous, this was 19 years ago , there has been other flooding issues on quite a number of occasions since. As I have explained exactly where I live .

Let me mention last December 2018 .There was a knock on our front door by southern Water man, saying there was a burst sewerage pipe in the field down the road& that they have called in the Tankers to remove the sewerage , so for approximately 10 days& nights we had  noisy engines 24/7  active on the drive way next to our house, flashing orange lights ,as one left the other reversed in we had trouble getting in & out of our drive way due to the  big pipes they use ,  I didn’t complain coz I knew it was stopping @. Some point , also , it was explained to me that the sewerage  pipes were struggling to cope ,with the extra sewage due to building of new homes in the area . we must  seriously consider that our climate is changing at a very vast rate. Why do you need to build thousands of homes  in such a high flood risk area  & on green belt , There is enough brown belt  land  in the Borough of Tunbridge Wells . We are all so aware that the present infrastructure can’t & wont cope.  you really  need to listen to the people to understand why this building must not go ahead , you will be creating  more problems ,with flooding& a lot of other main issues, people will struggle to get buildings & contents insurance in the Parish in the future ,more cars more pollution , just a couple of examples I’ve mentioned & there are a lot more very important issues why you must Not go ahead with this Garden village . It will also have a tremendous impact on wildlife they have to live somewhere too ,please ,please ,ABOLISH  !

this plan for this parish & surrounding areas .

DLP_5511

Catherine Sherwin-White

I live with my young family off the Hadlow Road outside Tonbridge.  My husband and I both commute to London daily and we chose this area amongst other things due to the green belt setting and the rural upbringing it will offer our children.

I am writing to object to 'The Strategy for Capel Parish' (Policy STR/CA1) and the inclusion of the land of East Capel in 'The Strategy for Paddock Wood' Policy STR/ PW1).

The proposed development will cripple an already crowded and dysfunctional infrastructure. The impact of these sites will be significant on residents, businesses and is totally unsuitable for the area - both in the development phase and when complete.  There are already major traffic issues round the Cannon Lane area which need to be resolved as it is. The narrow lanes and a railway going through the middle are the most absurd settings for such a development and a school, presenting immense safety implications.

We know from recent years that Tonbridge is vulnerable to flooding, and meddling with the flood plain further is irresponsible, foolhardy and shows a distinct disregard for the current and future population (including the proposed new residents).

With 5 secondary schools in the area already, it is a very impractical move to add another in such close proximity.  Surely there are other areas in TWBC who are far more deserving of a secondary school nearer to them that would benefit the existing and newly planned population.

These plans are alarmingly un-thought-through and will have significant repercussions on the infrastructure the community and the environment.  They are shortsighted and will have short term benefits on paper and significant long-term implications - as your councilors have publicly stated in meetings, well after they are gone from this earth.

I trust you will take my comments in to consideration.

DLP_5524

Alan and Claire Cattermole

We are writing to you as concerned citizens and residents of Golden Green.  WE are wondering why, when there is so much space in Tunbridge Wells you have found it necessary to try and impose the erection of 4,000 homes on the borders of Tonbridge.  You state that you are interested in helping to maintain green belt land and ancient woodland but have chosen a site in Tonbridge borders where both of these are going to be destroyed.

How can you justify putting large expensive, unaffordable houses on land bordering Tonbridge and then using the revenue to support Tunbridge Wells facilities?  Not really fair is it.

Not only is Tonbridge green belt but also in a flood plain as well as an ANOB.  Are you suggesting that you erect all 4,000 home in Tonbridge borders without providing a decent system to deal with the flooding?  What happens when the Medway overflows as often happens in the winter, especially around the swimming pool area and Sainsburys.  Don’t you think the concrete involved in erecting these houses will exacerbate the flooding situation?

I wonder how you think you are going to solve the traffic problem with the addition of a further 4,000 homes.  Tonbridge is already suffering from tailbacks in both directions onto the high street much of the day.  Rush hours are practically impossible to move around in.  I suppose the plan is to use even more green belt land to increase the road area.

Where are those commuters in the expensive houses going to park their cars when they travel to London?  Are they even going to be able to board the trains? These are often packed by the time they arrive at Tonbridge.  There aren’t going to be parking places at other stations are there.  There has been mention of new businesses in Tonbridge but where are they? And where are they going to go if more are mooted?  There was mention of a new station being built at Capel.  I wonder what the situation is regarding this?  Capel and Tudeley are small and charming little villages where there is the renowned church – a major tourist attraction with the Chagall Windows.

WE have heard too that there is talk of a Capel bypass.  How much greenbelt land will disappear under tarmac and how many animals and natural habitats will be destroyed to achieve this aim?

Rumour has it that Tonbridge Cottage Hospital could be commandeered by the local council who will then use the land to build houses.  That is a very important facility for the people of Tonbridge with many facilities, the disappearance of which would lead to more disruption.

There is talk about a new school being built opposite Somerhill Schools. How is this even possible?  How is it proposed that the children get to school? This will only add to the already hugely overcrowded roads in Tonbridge.  ON top of that how many children will be bussed in from other areas.  Imagine the destruction to the roads!

How will the small town of Tonbridge sustain such a huge influx of people?  Are there plans to knock down the High Street and rebuild?

What a shame that Tonbridge is being used to achieve the aims of Tunbridge Wells fulfilling their housing quota just because the boundary seeps over the edge – BUILDING A NEW TOWN.

DLP_5554

Lauren Stanley

I object to the land in East Capel being included in “The Strategy for Paddock Wood” (Policy STR/PW1 and Policy AL/CA3)

The comments above relating to Policy STR/CA1 apply here [TWBC: See comment DLP_5552].

The Council seems to treat Capel as part of Paddock Wood despite boundaries and the separate identity of Capel.

The land highlighted for development is a flood plain. Any attempt to deal with this issue by mitigation and betterment do not take account of global warming/climate change or its use as a flood plain.

All of the land is greenbelt and is grade 2 or 3 agricultural land. At present we only produce 50% of the nation's food; more houses and less agricultural land can only make that worse.

There will be a conurbation from Paddock Wood to Tonbridge and the character of Capel will be lost forever. TWBC talks about “love where we live” and then destroys one small part of the borough.

Is there a back-up plan? There should be and I hope the Councillors look at this current plan and imagine their own parish being destroyed in the same way. There should be a much greater sharing of new housing and there are far better places to put major development where roads already exist!

I’m also aware that brownfield sites have not all been included in this plan and the Council should have done more to identify and use them. 25% of the borough is non-greenbelt of brownfield so destroying one parish is fundamentally unfair and just plain wrong!

Finally, I wonder how the medical services will cope with this? There are significant issues with finding GPs for Woodlands Health Service (used by Five Oak Green and Paddock Wood residents) and at Tonbridge GPs. The doctors and Pembury hospital are already stretched to breaking point.  With around 7,000 new houses in this area together with around another 1,000 in Paddock Wood that already have planning permission the whole area will be ruined and it’s infrastructures will buckle under the strain. In addition, there is significant new development planned in Tonbridge and Sevenoaks which can only result in a crisis.

Can’t the Council have a serious rethink about the unfairness of this? We don’t need this many houses in the borough and current requirements are lower than the ones being used which are based on outdated figures from 2014.

We are providing houses for London overflow and that will never end. How can we give such power to developers?

Former Prime Minister David Cameron and Chancellor of the Exchequer George Osborne wrote: “We will always protect the green belt and make sure planning decisions are made by local people.”  Public faith in politicians!!!!

DLP_5606

Sean Chapman

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

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

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

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

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

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

DLP_5623

Philip Clarkson Webb

The Government has assessed the need for extra housing in Tunbridge Wells Borough at 13,560 units, which TWBC has upscaled to 14,776. Why?

Of these 14,776 new dwellings, the draft Local Plan requires 2,800 to be built in Tudeley parish and a further 1,500 to be built in Capel parish, leaving the remaining 9,476 to be built in the whole of the rest of the borough. This places an inequitable burden on just these two parishes.

TWBC's own Sustainability Appraisal shows that Paddock Wood can be expanded to meet most of the housing needs without using Green Belt land at East Capel.

Furthermore, recent floods in Yorkshire and the Midlands have shown the folly of building new housing on flood plains such as those at Capel.

New housing in Capel and Tudeley would inevitably draw extra commuter and other traffic to Tonbridge station and Tonbridge businesses which are already heavily congested. The costs of any new infrastructure needed to cope with the extra traffic would inevitably fall on Tonbridge residents while any benefits in the form of extra council tax would accrue to TWBC.

Finally, as a Tunbridge Wells resident, I would ask TWBC to do a thorough survey of brownfield sites suitable for development, or, if this has been done, to update the figures and to publish them, since this would a major impact on the alleged need to build housing in the Green Belt.

DLP_5630

Colin Broad

After hear your plans to build thousands of houses in and around Paddock Wood I want to know how the Schools , Doctors , Hospitals , Ambulance service and other emergency services ,the road infrastructure going to cope. To get a doctors appointment we have to wait up to 3 weeks, hospital appointments up to 9 months if you are lucky how bad do you think it will get with thousands more people in the community .

I want you to know I strongly oppose your plans and think you should take into account the affect it will have on local people and those in the Tonbridge and Malling Borough.

DLP_5632

Mr Tom Davis

I am responding as an individual, I am retired and live locally

My objections to Policy STR/PW1

- The use of Green Belt and agricultural land for housing  is short-sighted and I oppose it in principle - national self sufficiency in food should be the aim and land that is in use for food production should not be in the allocations.

- This development will exacerbate flood risk in the Medway Flood plain .

- The commuter demand arising from the proposed new development of 2800 properties in Tudely/Capel, 4000 in Paddock Wood, 2000 in Hawkhurst/Horsmonden/Cranbrook will overload the stations at Paddock Wood and Tonbridge – the peak time trains are running at capacity now - and car parking at the stations will be unsustainable.

- Traffic congestion on roads into and out of Tunbridge Wells and Tonbridge is terrible now, the development plan will not make this improve.

- The creation of new housing of this scale on greenfield sites  will cause the destruction of hedgerows , meadows, woodland and farmland causing the loss of varied wildlife habitats essential to the local survival of a wide range of species of animals, birds and insects.

- Tunbridge Wells Borough’s housing needs  must not be dumped on to high grade productive agricultural land, green fields and meadows.

DLP_5634

Ann Davis

I am responding as an individual, I am retired and live locally

My objections to Policy STR/PW1

- The use of Green Belt and agricultural land for housing  is short-sighted and I oppose it in principle - national self sufficiency in food should be the aim and land that is in use for food production should not be in the allocations.

- This development will exacerbate flood risk in the Medway Flood plain.

- The commuter demand arising from the proposed new development of 2800 properties in Tudely/Capel, 4000 in Paddock Wood, 2000 in Hawkhurst/Horsmonden/Cranbrook will overload the stations at Paddock Wood and Tonbridge – the peak time trains are running at capacity now - and car parking at the stations will be unsustainable.

- Traffic congestion on roads into and out of Tunbridge Wells and Tonbridge is terrible now, the development plan will not make this improve.

- The creation of new housing of this scale on greenfield sites will cause the destruction of hedgerows , meadows, woodland and farmland causing the loss of varied wildlife habitats essential to the local survival of a wide range of species of animals, birds and insects.

- Tunbridge Wells Borough’s housing needs  must not be dumped on to high grade  productive agricultural land, green fields and meadows.

- Schools and Medical Centres are currently overstretched, capacity for the future is still in planning rather than already underway.

DLP_5641

Pam and Kim Tattam

It has recently been brought to our attention the full extent and implications of the development in neighbouring Paddock Wood and Tudeley.

Although outside the development area it will have an impact on residents of villages such as ours at East Peckham.

As a pair of 83 year old pensioners our prime concern will be the provision of adequate and promptly available Medical Services.

For many years we were provided with an excellent service within the village. This was removed with the flimsiest of excuses to Paddock Wood.

Although all the staff are doing their best they are already feeling the strain of increasing numbers.

The parking facilities are already inadequate and the proposal will add several thousand families to the register.

Public transport is patchy and the walk from stops to health-centre is beyond the capability of many elderly patients.

May we ask if TWBC and TMBC are considering the feasability of replacing services in villages such  as ours to alleviate future problems.

DLP_5642

Eryl Davies

Even though I am not a resident of Tunbridge Wells Borough I have worked in and around Paddock Wood for 37 years.

It is bad enough having to put up with new developments in the area around Paddock Wood, but having seen the proposed plans for reducing the Green Belt area between Paddock Wood and Tonbridge I am appalled by the idea of unnecessarily building new homes in this beautiful area of the Weald.

The build up of morning traffic during school term is appalling on the road between Five Oak Green (note the colour in the placename)  and Tonbridge already.

Also the peace and serenity of Tudeley Church(with its beautiful Mark Chagall windows) would be lost for ever if a housing estate were to appear in the field behind it.

Please reconsider your plans for the future

DLP_5643

Walter Stubbington

I have lived in PW since 1973 and when we first arrived it was a great place to live. There were a variety of shops to cater for all needs.

Wit h all of the new development over the years the now TOWN has become overcrowded and is impinging on local residents.

Many of the shops are closed and have been replaced with charity shop and coffee shops, which is driving resident to Tonbridge, Tunbridge Wells, and Maidstone  We are becoming overrun by commuters , I live at number 86 in Allington Road and cars are now regularly parked outside. With any new development, Doctors Schools and all other amenities will be overrun

I would urge the council to reconsider this development, or better still experience living in Paddock Wood, and then reassess the situation

DLP_5649

Charles and Fiona Rosenmeyer

We have read the draft plan, particularly as to its possible effect on Tonbridge, where we live. We have also read the submission to your council by Tom Tugendhat MP. We wish to support his comments and those of Tonbridge and Malling District Council about the proposals in the plan in so far as they affect Tonbridge. We also wish to make the following additional comments about the proposals for Tudeley/Capel, Paddock Wood, Woodgate Way and Mabledon, all of which are on Tonbridge’s doorstep.

Generally

There is a considerable lack of information in the draft or in reports appended to it showing the likely effect on Tonbridge of the proposals, why Tonbridge should be expected to accept that effect and who, other than the council tax payers of Tonbridge, will pay for the costs of ameliorating it.

Green belt

Whilst the draft mentions the green belt, in relation to Mabledon and Tudeley/Capel it must be remembered that what is proposed is not building in the green belt protecting Tunbridge Wells but in the green belt protecting Tonbridge. So the case needs to be made for invading that green space which will have little effect on Tunbridge Wells (other to help it hit its targets) but will have a major effect on Tonbridge, which is not even asking for the development.

Roads and road transport

  1. Tonbridge has only one major rail crossing and one major river crossing in the town. That leads to regular congestion, particularly at the start and end of the working day and in the afternoons when the schools break up. Any new development in the neighbourhood of Tonbridge will have an effect on bus services, parking and the emission of CO2 and other harmful substances. It is not sufficient to state, as does the draft, that these issues should be considered as part of a detailed planning application; Tonbridge, which has not asked for these proposals but will be affected far more by them than Tunbridge Wells, should have access to data and reports now while the plan is still a draft and not later when it will be claimed as a fait accompli.
  2. In the same way, Tonbridge should be told now what alterations to local roads are proposed. The roads around Tudeley are local, narrow, winding, prone to flooding, dangerous in places and already overused. The principal road from Paddock Wood to Tunbridge Wells already needs considerable improvement, not least a by-pass to Colts Hill; no such improvements are proposed by the relevant highway authority. If Paddock Wood is doubled in size as is proposed, major improvements will also be required to the principal route between the town and Tonbridge.
  3. New housing will generate additional private car journeys and delivery journeys. It would be facile to suggest that most food shoppers from any development at Tudeley/Capel would carry out their major food shop anywhere other than Tonbridge. It is also facile to suggest as the draft implies that commuters from Tudeley/Capel would drive to Paddock Wood to board a train for London. To do so would increase their overall travel times and increase the cost of their train tickets.
  4. A new school at Woodgate Way would also increase car traffic not least as there is no obvious way other than the private car by which teachers and pupils can reach the site. There is no principal bus route, no cycle lane and it is too far to walk (and dangerous to do so) either from Tudeley or Tonbridge.
  5. As people shop increasingly on-line, there should be a study on the additional road miles in the vicinity of Tonbridge, which will be generated by these proposals. For instance, it is likely that many food deliveries ordered on-line will be delivered from Tonbridge. Also Royal Mail post for the area, initially delivered to Strood, is driven by articulated lorries into Tonbridge via the A26 for local sorting in the Royal Mail facility in Tonbridge. Deliveries from there to Paddock Wood and Tudeley and collections in reverse are bound to add materially to the use of the surrounding roads.

Train travel

The plan does not say whether the rail transport authorities would support or fund a new station at Tudeley. The line between Tonbridge and Paddock Wood is already congested at peak times. Those commuting from Tonbridge should be informed now what effect the draft proposals would be likely to have on frequency of services, availability of seats, choice of destinations and what rail improvements are required, who will fund them and when they will be carried out.

Flood defences

A material part of the proposed Tudeley/Capel development area lies on the Medway flood plain at a height above sea level of only 50 feet or less. Even though the remainder of the site rises gently above that level, much of it has flooded in the past and the proposals for further defences at Leigh have yet to be carried out. Even if they are, an assessment should be made now of the likelihood/risk of future flooding on the site given climate change, the slow sinking of the landmass and the rising of sea levels.

Schools and healthcare

The draft makes a proposal for a new secondary school but says little about the need for additional infant and junior schools and additional doctor’s surgeries and supporting medical services the need for which will be generated by the additional housing proposed. As the likely effect will be disproportionally laid at Tonbridge’s door, there should be studies now in support of the draft realistically to measure that effect rather than later when a new local plan has been adopted.

Services

It is not good enough to say, as does the draft, that these are issues to be considered in the future when the plan has been adopted. As the supply of services may affect Tonbridge, Tonbridge residents should be told now what that effect will be. For instance;

Gas; will the supply come from Tonbridge, what route will it take, and what impact will it have on local supplies?

Sewage; where will the sewage be treated, by what route will the sewer pipes take it there, will it be pumped, will it have to cross the railway and the Medway and what effect will it have on the already stretched treatment plant in Tonbridge?

Electricity; what additional generating capacity will be required, where will it be sourced, what renewable capacity will be generated on site and what if any additional high tension supplies will need to be brought in?

Internet and mobile ‘phones; what if any disruption to internet availability in Tonbridge will be needed to supply services to the proposed new development? Mobile coverage is already patchy in the area. What binding proposals will there be to ensure adequate coverage?

The draft should deal with all these issues before it goes for consideration by the planning inspector or the minister so that the residents and taxpayers of Tonbridge may have a full understanding of the proposals, which are likely to affect them far more than the inhabitants of Tunbridge Wells.

As Tonbridge residents we feel that the draft reveals that the Tunbridge Wells Council, concerned about development in its own back yard, has cynically decided to place that development in Tonbridge’s back yard, with Tonbridge being expected to pick up many of the ancillary costs, financial, social and environmental.

DLP_5651

Emma Scott

As a resident of East Peckham I am vehemently opposed to the proposed development of Tudeley, Capel and Paddock Wood.

The sheer number of properties contained within the plans will result in a devastating impact on the existing community and infrastructure.

Although the build is to take place within the Tunbridge Wells Borough Council area, the effects on surrounding areas, infrastructure and local services will be far-reaching and detrimental in every way imaginable.

Just from my own personal perspective, I can foresee tremendous difficulty for myself and my family should the build go ahead.

Our family has chosen to live in East Peckham due to the rural location, local facilities, lack of overcrowding, surrounding countryside and our enjoyment of village life.

In recent years we have already seen a reduction in our quality of life due to increased numbers of people moving into the area. We recently lost our GP surgery in the village and now have to travel to Paddock Wood to see a doctor. I am recovering from cancer and have a few ongoing health issues. It is incredibly difficult to get an appointment due to sheer numbers of service users and it is not always convenient to travel to another village whilst ill. It is utterly unacceptable to me that the elderly, disabled, mothers of young children etc should have no access to a doctor in the place where they live.

Bringing yet more people into the area will compound this problem immensely.

Traffic on the roads in this area is already heavy. I work at Tunbridge Wells hospital and have recently had to change my working hours to ensure that I can avoid the worst of it and arrive at work on time. I currently leave my home at 6.30am, by which time the traffic is already considerable.

The vast rise in local population would also have a ‘ripple’ effect in many other ways; school places, travel to school, amount of people using shops and leisure facilities and parking.

As well as the housing to be built, new roads and associated infrastructure will destroy the countryside that we currently enjoy. It cannot be known what the effect on wildlife may be, not to mention levels of pollution and other environmental concerns such as flooding.

The strain placed upon the hospital and other local services by thousands of additional households will undoubtedly be the worst effect of all. Hospital staff are struggling to cope as it is. I personally have had an operation cancelled 4 times due to a lack of capacity. This will clearly only get worse in future, even if no development were to take place.

It seems so unfair that Tunbridge Wells Borough Council can plan what amounts to a mass invasion of the local area. Life as we residents know it will be gone for ever. I personally will seriously have to consider moving away if this goes ahead as the life and home I have created for myself and my family will be ruined.

DLP_5667

William Forsythe

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. Please do what is right for those your represent and work closely with Tonbridge council who will suffer most of the burden of these works.

DLP_5670

Andrea Ray

I write to formally raise my objections and concerns regarding the planned addition of 4k+ new homes in Paddock Wood under strategy STR/PW 1 and AL/PW 1. I was born in Paddock Wood 47 years ago and though spent a few years as resident in TW and the USA i have found myself back in Paddock Wood the last 6 years. Paddock Wood has a lively high st and some wonderful rural walks which I use daily as I have a dog. My garden has a back gate out to the public footpath which connects us to the Capel boundary and a lovely walk currently through farm fields and into ancient woodland. This is one of the proposed sights STR/PW1 for new homes. The negative impact of this on myself as far as enjoyment of my current living lifestyle and home will be immeasurable.

The proposed sights for the homes in Paddock Wood are category 2 and 3a flood risk areas. This will mean that huge amounts of developers money will have to be used for flood mitigation diverting funds from other essential infrastructure.

Paddock Wood TC has been consistently liaising with Southern Water due to sewage problems in the town with the sewage station already full to capacity. Additional homes will cause a major problem with sewage.

The trains in commuter times are already full with additional homes all along the train line to London and no ability to add carriages due to platform length this already existing problem will be exacerbated. Theres insufficient parking for commuters also leading to dangerous parking along residential roads.

With additional homes the volume of traffic on our roads which are already congested will only get worse as will pollution from additional vehicles.

The figures being used from central government for numbers of additional new homes required to address a  housing need are out of date (2014) there is suggestion that latest calculations indicate the figure could be halved. Why are TWBC not insisting that central government have a current day review. Additionally the sort of homes being built currently are large homes with starting prices way out of reach of the first time buyer so not necessarily going to assist the housing crisis. The new homes also offer no consideration towards the UK working towards zero carbon emissions, there are no solar panels, grey water systems or thermal heating systems.

The areas hospitals and GP surgeries are full to capacity with wait times rapidly increasing. Committing to the volume of new homes in the area will only add to existing frustrations.

DLP_5674

Jose Hyatt-Twynam

I object to the inclusion of land in East Capel in ‘The Strategy for Paddock Wood’ (Policy STR/PW1)

The land is Green Belt and should only be built upon if an ‘exceptional circumstance’ exists. It is also good agricultural land vital for food production. This area is on the flood plain and even with flood risk mitigation and ‘betterment’, development at East Capel could have disastrous consequences for all, particularly as we cannot under estimate the impact of climate change.

I think the plan should be re-drafted to distribute the housing need throughout the borough prioritising brown field sites. Capel should not be expected to suffer more than its fair share of the negative consequences of development when other parts of the borough have greater housing needs. Capel has low unemployment. The business and commercial premises to be created within the Garden Village should be located in more deprived areas within the borough that have been identified as having high unemployment.

In my opinion a more measured approach to development from our government with more incentives for businesses, employment and houses in the north of the country would help stop over urbanisation of the South East while readdressing the housing shortage.

DLP_5679

Simone Harrington

I am writing to express my concerns about the proposed development across the above mentioned areas.

Whilst I agree that more affordable homes should be built I don't believe this is the way forward.

My concerns are as follows.

Flood risk increased due to large areas not having sufficient drainage, fast run off of rain water due to hard materials.

Traffic congestion & associated pollution.

Insufficient infrastructure to support the new population.

I also remain unconvinced that the homes being built will have a high percentage of affordable homes.

I urge you to reconsider these plans.

DLP_5683

Chris Sutton

I attended the Draft Local Plan exhibition at Mascalls School on Thursday 3 October, and learned that it was possible to submit my land under the Call for Land so long as I do so before 1 November.

My land is my 4 bedroom house and large garden at 2 Eastlands Cottages, TN12 6BU. This is a former oast house and local heritage asset which is a distinctive feature in the fields to the north of the railway line and the west of Maidstone Road.

To borrow TWBC’s slogan, I and my family love where we live and object to the proposed development of PW1.3 and PW1.4 which will totally change the character of our home which we purchased in 1993. I have set out my concerns about the development directly on the Local Plan Consultation website.

However, should the development of PW1.3 and / or PW1.4 go ahead, then it makes sense to submit my land under the Call for Land, so that the development can proceed in an integrated manner, rather than leaving Eastlands Cottages marooned in the midst of new buildings.

You will be aware that the oast building comprising Eastlands Cottages is split between 1 and 2 Eastlands Cottages. Naturally I cannot speak for my neighbour who owns and lives at 1 Eastlands Cottages, but you are probably aware that he is the owner of the surrounding fields (Eastlands Farm) which have already been submitted by him under your Call for Land.

The land is marked in GREEN on the map below. [TWBC: see map].

Title deeds of K582564 and site plan attached.

DLP_5686

Ruth Davies

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1) and to the inclusion of land in East Capel in “The Strategy for Paddock Wood” ,Policy STR/PW1.

I am a resident of Tonbridge and  I object for the following reasons:

  1. The whole development is close to the Tonbridge boundary and is likely to have a negative impact on traffic, station use and Tonbridge amenities. There is already limited parking and traffic levels are high, particularly during school times and the working day.  TMBC will incur costs for roads and services infrastructure whilst gaining no revenue from the residents.
  2. There is insufficient community infrastructure, for example community spaces and halls, local shops, medical centres etc. within the plan.  The school will result in even more station traffic with pupils who then face a walk along busy and congested roads, with potentially poor air quality.
  3. No development should be undertaken on green belt or agricultural land. There is plenty of brown site land available within TWBC to meet the new housing demand.  Equally, the impact on the flood plain is likely to be negative through loss of absorbent land.

DLP_5693

Mark Preston

Hi my name's mark and I seriously think this is disgusting what you are doing there is no infrastructure to take all this...you barely get a drs appt in paddock wood as it is also the drainage in paddock wood us already outdated and can't cope ...traffic will be worse more cars more pollution...not enough school places ...seriously you lot need to think about what you are doing ....it's wrong very wrong

DLP_142

Gregg Newman

Comments on Policy STR/PW 1 (The Strategy for Paddock Wood) p.170

Again, the following are quotes which are totally supported:

QUOTE

The expansion of Paddock Wood can be achieved without using land at East Capel for housing. Flood storage attenuation/mitigation measures may be useful there but no housing is required. In fact, providing housing will contravene the NPPF as East Capel is Green Belt and the removal of East Capel from the Green Belt will cause coalescence with Five Oak Green. This is not permissible as the inclusion of East Capel in the expansion of Paddock Wood is not an “exceptional circumstance”. This is further described in comments on the Sustainability Appraisal.

UNQUOTE

DLP_268

Cheryl Randeria

Dowding House provides a fantastic day centre facility for the older generation of Paddock Wood and the surrounding area. You cannot take that out of circulation even if you intend to rebuild a facility on the dame site surrounded by houses. The old people rely on that facility daily for the company it provides and the fact that there is someone to check in on how they are doing and help them if needed. Your proposal will completely isolate those individuals and severely affect their quality of life.

DLP_361

David Marriott

According to the EA most of the sites that you are proposing to allocate north of the railway line are flood zone 3. This is the worst designation and with global warming having an increased impact in years to come any mitigating measures proposed will be well and truly surpassed by deteriorating weather and flood patterns. There should be NO development in any flood zone 3.

DLP_371

Hadlow Parish Council

  • The land proposed for development is all Green Belt land. We do not believe that the very special circumstances required in the NPPF for residential development within the Green Belt have been credibly argued in the draft plan. This is particularly the case bearing in mind the extent of the area covered by Tunbridge Wells Borough.
  • The general impact of the developments along the B2017 will fall on Tonbridge. For day to day services present residents of that area look overwhelmingly to Tonbridge. We believe that will continue. Council Tax in the area will be paid to TWBC but the cost of the required improvements to infrastructure and services in Tonbridge will be borne by residents of TMBC. That must not be overlooked.
  • The improvements to the road system proposed in support of the developments in and around Tudeley, Capel, Five Oak Green and Paddock Wood appear to focus on the A228 and the North and South traffic. Traffic heading West out of the area or East into the area does not seem to be very well provided for. The roads in the South of Hadlow parish and on the B2017 are busy and often congested now. Rush hours and school runs are a problem.
  • On its own the draft plan poses a very serious challenge to the wildlife and ecology over a wide area. Taken together with the proposals to resume and extend quarrying very close by we are looking at wholesale destruction on quite an impressive scale. The character of the area will be transformed from countryside to suburban with post industrial zones in just a few years.
  • The northern part of the development area in Tudeley is close to the westward extension of Stonecastle Farm Quarry proposed in the revision of KCC’s Mineral Plan. The same issue applies to the western side of the Paddock Wood West parcel regarding Moat Farm. Any hydrographic studies or other checks on possible flooding risks arising in connection with any of these proposed developments should take full account of the risks both with and without the proposed neighbouring development. Has this been done?
  • With concerns mounting over the failure to achieve effective control of COemissions around the world the proposal to build so extensively on green field sites is of concern. The threatened land is presently playing a very valuable role sequestering CO2. This plan will bring that firmly to an end.

The proposal for a large new school between Vale Road and Postern Lane can only aggravate transport and road safety issues around Tonbridge further. Tonbridge is already served by several significant secondary schools drawing from large catchment areas. Traffic generated by this additional school will be most unwelcome.

DLP_7889
DLP_7891

P Parsons
Coline Parsons

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

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

​This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel. Building here, even with flood risk mitigation could have disastrous consequences for all, as the measures being looked at are based on old data that does not fully consider the impact of climate change.

I hope you listen to the comments of your residents & reconsider this plan. We have not had enough time to consider all the implications of this plan & did not know anything about it until other residents started informing us.

DLP_4945

Lesley Ribbens

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel.  Land around here often floods, something which will happen with greater frequency as climate change progresses.

To sum up, I believe that the proposed development around Tudeley and East Capel is wholly inappropriate and should not be allowed to go ahead.​

DLP_4909

Alison Froggatt

I strongly object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel. This is not an exceptional circumstance.

Building at East Capel, even with flood risk mitigation and “betterment”, could have disastrous consequences for all. The measures being looked at are based on old data that does not fully consider the impact of climate change, species loss and environmental degradation.

DLP_3206

Graeme & Tina Anderson

We object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

This is the part of the Plan with which we have first-hand knowledge and experience, as residents of long-standing. This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel. The comment above about coalescence and the creation of a conurbation from Paddock Wood right across to Tonbridge is very relevant here, as is the land’s use as a flood plain.

Creating a settlement at East Capel of 1500 new houses will cause immense harm to residents of the Parish of Capel and to residents of Paddock Wood. There will be a significant increase in traffic in to both Paddock Wood and Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road every morning. Which schools will the children of this development be expected to attend? Whether it is Mascalls in Paddock Wood, or the new school in Tonbridge they will need to be bussed there or driven in private cars as there is no safe footway on the B2017 in either direction, and not enough land at the side of the road to create one, for the majority of the distance.

People living in East Capel will use either Paddock Wood Station or Tonbridge Station for commuting and either Paddock Wood or Tonbridge for services that will need more parking. The increase in traffic will be more than Paddock Wood and Tonbridge can cope with. Their 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 Paddock Wood and Tonbridge Station will be unsustainable. Parking in and around Paddock Wood and Tonbridge Stations will be even more difficult.

Has any thought been given to the impact on traffic using the A228 between Pembury and the Hop Farm, in particular the Colts Hill section? It takes very little already for the traffic to become backed-up on this stretch of single carriageway.

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. Our personal observations are that in the twenty-four years in which we have lived here, the water table has got significantly higher. Now, even in high summer, after weeks or months of dry weather, the soil remains sodden just below the surface. Flood mitigation measures may help, but we believe that flood risks will increase. Covering farmed fields and woodland with houses and roads will make the Medway flood more often and cause increased flood risk not only in East Capel but in Five Oak Green and Paddock Wood.

As with Tudeley, creating so much housing in East Capel 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.

DLP_374

Mr David Smith

2. Whilst there is mention of the provision of two further secondary schools in the area, there is no explicit mention of the possibility or desirability of expanding Mascall's School in the plan. Although I understand that this possibility is being entertained it should surely be declared in the plan as it does not seem socially economically or environmentally desirable to expect overspill from Paddock Wood to travel to more distant schools given the considerable growth planned in Paddock Wood.

3. The basis on which the plan is predicted is flawed. There is widespread distrust of, lack of confidence in and in some cases anger with TWBC amongst many Paddock Wood residents in my experience about the way that the TWBC appear to take no notice of their views. Indeed, when the Town Council act in the local interest in rejecting undesirable planning applications, the TWBC invariably over-rule this. In the case of this local plan,  it is regarded as wildly overambitious, to the point of recklessness. The infrastructure in Paddock Wood and the surrounding area is already too thinly stretched and in some cases failing.

DLP_392

Keith Sinclair

Having looked at specific elements of the draft plan and attended the presentation of the plan at Mascalls school, I have the following comments.

  • The plan suggests a further 4000 house in the Paddock Wood area and a further 2800 creating a "garden village" in the Five Oak Green / Tudeley area. This represents a significant increase in the urbanisation of this area of the borough which is contrary to the widely accepted view that green areas and specifically wooded areas need to be increased in order to absorb carbon dioxide.
  • Much of the Paddock Wood area and specifically areas to the west of the Madistone road from the railway to the Hop Farm roundabout are at high risk of flooding, creating new roads and housing in the area must significantly increase the risk of flooding. Your last 5 - year plan confirmed that the area to the west of the Maidstone road was not suitable for development specifically because of the flooding risk (zone 3).
  • Past 5 - year plans also confirmed that Nursery Road was not suitable for more vehicular traffic and access to a projected "light industrial" development to the west of the Maidstone Road suggested access through the unadopted road, Eastlands.
  • The general infrastructure of Paddock Wood is under severe pressure now -
  1. Foul and surface water drainage is inadequate when rainfall is high, and the Maidstone Road suggested end of Nursery Road and Eldon Way is frequently flooded. Flooding at the north end of Nursery Road has been alleviated by the significant wooded growth to the west of Nursery Road but remains a risk due to a lack of a drainage pipe from the road drains.
  2. The doctor's surgery is under capacity now and a lack of the number of G.P. doctors makes appointments difficult to obtain. The plan talks about a new medical centre, but timing and funding are not mentioned.
  3. Recently a new church primary school was rejected by K.C.C. when demand would appear to justify it, especially in the light of the three recent planning approvals for 800 houses.
  4. Traffic in Paddock Wood and surrounds is ever increasing, making walking (as I try to do) and cycling increasingly hazardous. Lack of control of parking in the High Street and Maidstone Road, stretched parking at the railway station and local roads in the vicinity of the station are already problems for residents. Further expansion of the town can only make the situation worse.
  5. Noise associated with the traffic is a factor for all residents who live adjacent to these busy roads.
  6. Wild - life, i.e. birds and small animals have increased in the area's wooded and open areas and will be threatened or destroyed by the proposed developments.

In summary, I would question the need for further significant housing development in this area. Although the plan talks of the need for infrastructure development, past experience indicates that his does not happen in a timely manner if at all and the borough has little ability to influence this provision.

I believe that no more decisions to expand housing in Paddock Wood be taken until the currently approved 800 houses are built and sold and the subsequent effects on our community are carefully assessed.

DLP_478

Paul Dixon

I am also writing to strongly object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

1. The additional housing will lead to the destruction of land that is designated Green Belt. There is a reason why this land is designated Green Belt, the point of which is to maintain an area where agriculture, forestry and outdoor leisure can be expected to prevail and to prevent urban sprawl. The plans for the Capel Parish run completely contrary to that. It will involve the destruction of woodland, hedgerows, meadows and farmland. It will also have a negative impact on the landscape. The Green Belt should only be built upon in ‘Exceptional Circumstance’ – no such exceptional circumstance exists in relation to this proposal.

In addition to the destruction of the land, it will also lead to the destruction of wildlife, including ‘at risk’ species.

2. Impact on local residents, both in Tudeley and Capel and also Tonbridge. Traffic congestion is already a significant issue in this area and the plans put forward will exacerbate this even further. The B2017 is already a busy road and the plans will lead to more traffic pouring into Tonbridge from this direction (whether it’s commuters driving to Tonbridge station or parents taking children to school). This will particularly impact Woodgate Way and Vale Road.

Furthermore, other country roads / lanes (including Three Elm Lane) can be expected to see an upsurge in traffic as the new residents will try and use this as a ‘cut through’. These country roads / lanes already suffer from inappropriate traffic levels.

3. The proposed school on the edge of Tonbridge is ill considered, both due to the traffic congestion already referred to and particularly given that it will cross the railway line. Traffic is already busy on the B2017. Adding a school on the proposed site will worsen this. In addition, it is beyond belief how anyone can consider a school split over a railway line to be a sensible idea.

4. Tonbridge does not have the capacity for additional people. Tonbridge itself is already running at peak capacity in terms of its roads, parking spaces and trains. Residents in the new settlements can be expected to use cars rather than bus and bicycles and will undoubtedly drive to Tonbridge rather than Tunbridge Wells.

5. Tonbridge residents will end up with the cost of infrastructure whilst Tunbridge Wells gets the benefits of the additional council tax. The cost of infrastructure such as new health services, amenities and car parking will be borne by Tonbridge residents which is inappropriate. It seems that this may be the reason that Tunbridge Wells council have decided to put the majority of their proposed additional housing in the north western corner of their borough because it offloads any costs and problems to another borough.

6. Risk of flooding from the River Medway. It seems that the council have a short memory on the flooding risk from the Medway. Any building on the Medway floodplain will increase the risk of future flooding, even more so as the impacts of climate change take place. The current landscape should be left to act as a natural flood buffer, not have houses and roads built upon it. Residents could also have difficulty obtaining insurance coverage.

7. Increased pollution. This is both in respect of air pollution from additional traffic, light pollution from additional housing, street lights, etc and noise pollution.

8. Tunbridge Wells Council does not appear to have properly considered alternative sites. I believe there are plenty of other sites, including brownfield sites across the borough of Tunbridge Wells which could absorb the additional housing need. The Council should undertake a more comprehensive study on this first. It seems to me that the Council is taking the lazy option of imposing large groups of housing in areas where they only have to deal with one eager landowner, regardless of whether the area is appropriate for such housing levels.

9. The plan for Tudeley has not gone through the proper planning process, with no detailed Green Belt Study performed, no Landscape Assessment, no Biodiversity Assessment. Tunbridge Wells council should not just add these new plans without having gone through the proper studies and procedures beforehand.

Again, for similar reasons to the above, this land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. Again, the impact of traffic, pollution, flooding risk, cost of infrastructure is all very relevant. Please can the nine points above be applied to my objection with respect to The Strategy for Paddock Wood?

I trust that the above comments are given the appropriate consideration. Do not underestimate the strength of local feeling regarding this, not just in the directly affected areas but in the wider region too. These plans should not succeed.

DLP_487

Michael Perry

I live in Badsell Manor (wrongly described in the draft local plan as Badsell Manor Farmhouse) a grade II listed building surrounded by a working moat and located in the centre of green-belt land, protecting the nature of this ancient building.

I am writing to strongly object to the proposed strategy for developing Capel Parish and Paddock Wood.  I particularly feel that the development of East Capel would highly detrimental.

A large proportion of residents that live in East Capel do so because of the semi-rural nature of the area, in the knowledge that it is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel. Currently the land in East Capel is a flood plain and building there, even with flood risk mitigation and “betterment” could have disastrous consequences for all, as the measures being looked at are based on old data that does not fully consider the impact of climate change.

The proposals to allocate such a large proportion of the Borough’s requirements for housing and other development in one area will have a huge negative impact on local residents. There will be a significant increase in traffic going into Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road every morning. There would also be unacceptable levels of traffic on the A228, which would not be helped by the building of the proposed Pembury bypass, which would simply increase road noise and move the bottleneck going into Tunbridge Wells.​

People living and working in the proposed developments will use Tonbridge and Paddock Wood Stations for commuting. The increase in traffic will be more than Paddock Wood and 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 Paddock Wood and Tonbridge stations, will be unsustainable. Most people living in the new settlements will inevitably drive privately owned cars, despite initiatives to encourage bus and bicycle use.  Proposals to deal with the traffic problems by bus, cycle and pedestrian solutions are conveniently naïve.  Elsewhere this has been shown not to work.

Intensive development, on the lines proposed, will require massive infrastructure improvements.  The proposal is that this infrastructure will not be put in place until after development has taken place.  Whilst this may be a viable option for a series of small developments, it is impractical for such a huge series of proposed developments in one area.  The result would be chaotic with a collapse in the provision of health, education and transport facilities for an extended period of time, causing misery for local people.

The proposed development at East Capel 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 increase flooding with the increased flood risk impacting not only Paddock Wood and Five Oak Green but also other local areas.  There will be an increase in air, light and noise pollution that will spread across the developed area, creating an urban environment.

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, and act as a flood plain. There is little point in the concept of Green Belt if it then developed at the whim of a Borough Council.​

I believe that the housing need calculated by the government can be reduced if it requires development of Green Belt land. 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 in the borough. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant. ​​

I am concerned that if this plan is adopted it will eventually create a ribbon development running all the way from Tonbridge to Paddock Wood, permanently destroying the rural environment. 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. The developments in East Capel and Tudeley are unsustainable and place huge pressure on Paddock Wood and Tonbridge.

Please add my contact details to your consultation database so that I can be kept informed of all future consultations on Planning Policy documents. I understand that my comments will be published by the Borough Council, including on its website.

DLP_491

Heather Corrie

OBJECTIONS TO TWBC DRAFT LOCAL PLAN

I write as a resident to raise my strong objections to the proposals by TWBC to build over 4000 new homes in Tudeley and East Capel with a large school near Somerhill, namely “The Strategy for Capel Parish” (Policy STR/CA1) and the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

My objections are grouped as follows:

1. This is over 600 acres of greenbelt (GB) which is mostly prime agricultural land, with diverse woodland, wildlife and hedgerows which would be destroyed. TWBC has brownfield and non GB and non-AONB land available across the borough with better access to infrastructure and under consideration until this year. There are no “exceptional circumstances” to merit Green Belt being used. There is no Green Belt Study, Landscape Assessment or Biodiversity Assessment for these sites as this proposal was rushed through after the Issues and Options process in 2017.

2. The combined developments will create a conurbation running from Paddock Wood to Tonbridge not a garden settlement which will dwarf Tunbridge Wells town centre and swamp Tonbridge. The TWBC assertion that Tudeley is a garden settlement is misleading as it does not qualify under the Government proposals for garden villages and settlements. There is nothing discrete about the development and it has no local support.

3. The visual impairment of this AONB will be very significant. The Weald of Kent is an historic landscape, in particular around All Saints Church Tudeley with its complete set of Chagall windows, one of our most prized local assets.

4. Commuter trains are already full to capacity via Paddock Wood and Tonbridge and Network Rail has already indicated it is not possible to build a new halt at Tudeley. There is not room to push thousands more commuters onto the trains at Paddock Wood and Tonbridge and no capacity to run enough additional services at peak times. Traffic congestion will be massive with the additional cars particularly around Tonbridge where there already is inadequate parking.

5. How can TWBC councillors justify that the future cost incurred as a result of the proposed developments in providing public services and infrastructure will be offset by the future council tax revenues? Ie that they have not been negligent and will be able to balance the books without huge borrowing increasing the costs for all residents and worst case the council becoming insolvent. The council aim to balance their books via Community Infrastructure Levy and S106 payments from developers. Each dwelling will require a £50,000 contribution based on current estimates for good infrastructure around the” new town” at Tudeley, let alone the East Capel developments. Spreading development across the borough as previously proposed would be the cheaper option building on existing infrastructure and services. Issues not properly analysed and costed include:

* Adequate flood protection measures

* New sewage infrastructure as existing network already near capacity

* Need to renew and upgrade most electricity substations to cope with increased demand and, in particular, charging of electric cars as in theory the majority of people will then be needing fast charging points

* Ability to deliver and pay for road development required on a timely basis

6. How do TWBC councillors justify dumping the cost and problem of providing additional support services, schools pressure and traffic problems on the residents of Tonbridge Borough?

B. ADDITIONAL OBJECTION RE EAST CAPEL

1. This is a high risk flood plain and subject to regular flooding. TWBC has used old climate statistics to roughly calculate flood defence measures which would need to be implemented. The cost of flood defence measures are likely to be woefully inadequate and cost significantly more than assumed in this proposal. The impact of climate change has not properly been considered. There will be a knock on flood risk to places such as Yalding.

2. This is flat PRIME agricultural land in full production. There are no “exceptional circumstances” to justify building 1500 houses.

3. The roads will need significant development and some parts eg along Badsell Road are not capable of widening. There is already significant congestion which is already being increased by the new Mascalls housing development on Badsell Road.

C. ADDITIONAL OBJECTION RE TUDELEY DEVELOPMENT

1. Residents of the new development which is on the edge of Tonbridge will seek to use services of Tonbridge – the neighbouring borough for schools, health and other services and for commuting. Tonbridge town has not got the capacity to deal with the influx of people from outside their council tax area who are not paying for services. There will be a huge negative impact on Tonbridge based businesses due to traffic congestion.

DLP_516

Sarah Hughes

I write as a local resident to raise my strong objections to the proposals by TWBC to build over 4000 new homes in Tudeley and East Capel and a large school near  Somerhill. Namely “The Strategy for Capel Parish” (Policy STR/CA1) and the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1). I understand you may publish my objection but not my contact details. My objections are:

The residents of the 2800 homes proposed for Tudeley (possibly 6000+ people) will come to Tonbridge for their services eg health service, schools and other amenities as its closer than Tunbridge Wells. As a council tax payer in Tonbridge I strongly object to carrying the cost of increased demand for our local services which will be stretched beyond capacity and TWBC walk off with the council tax payment.

This is over 600 acres of greenbelt (GB) and prime agricultural land, including major floodplains, which would be destroyed. TWBC has brownfield and non GB and non-AONB (Area of Outstanding Natural Beauty) land available across the borough and previously under consideration in 2018. There are no “exceptional circumstances” to merit greenbelt being used on this scale.

In particular, for me as a commuter,  it will push thousands more people onto the Paddock Wood and Tonbridge commuter trains. In Tonbridge, the roads at peak times are already very heavily congested and not able to be widened. Parking is a nightmare.  Where will all these cars and people to go? TWBC are simply viewing the additional commuters at Tonbridge as somebody else’s problem. This is not acceptable and has not been thought through.

DLP_545

Jane Jackson

I write as a Sevenoaks resident to raise my strong objections to the proposals by TWBC to build over 4000 new homes in Tudeley and East Capel, namely “The Strategy for Capel Parish” (Policy STR/CA1) and the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1). I understand this email may be published but not my contact details.

My objections are as follows:

  • The area in question is over 600 acres of greenbelt (GB) and prime agricultural land, including major floodplains, which would be destroyed. TWBC has brownfield and non GB and non-AONB land available across the borough and previously under consideration in 2018. There are no “exceptional circumstances” to merit Green Belt being used. 
  • It will be a visual scar on the Weald of Kent landscape, particularly around All Saints Church Tudeley with its Chagall windows, one of our most prized local assets. We must consider our cultural treasures with more seriousness.
  • Thousands more commuters will be pushed onto the Paddock Wood and Tonbridge commuter trains. These trains are already full to capacity and as a resident of Sevenoaks I already experience the problem of serious overcrowding by the time these trains reach my station. TWBC are simply viewing this as somebody else’s problem. This is not acceptable.

DLP_548

Mr Don Foreman

I am Don (Donald) Foreman and I have lived in the Parish of Capel for 35 years. During that time I have become closely involved of the life of the parish as member and currently Chairman of the Capel History Society, which has published 3 books to date, member of the Friends of Capel Church, working as a volunteer maintaining the churchyard, member of Capel Cricket Club, where I am Publicity Officer, and throughout my time here have supported a range of other parish activities on a less formal basis.

As a dog owner I walked virtually every parish path north of the A21 and thus gained a knowledge of the land, its use for agriculture and recreation, and the wildlife which inhabits it.

My late mother lies at rest in the beautiful and tranquil graveyard of St. Thomas a Becket, Capel, and I will in due time also be buried there.

I also object to the inclusion of land in East Capel in 'The Strategy for Paddock Wood' (Policy STR/PW1).

This huge parcel of land between the A228 and the current built area of Paddock Wood is also Green Belt, and like the site of Tudeley New Town should only be built on in exceptional circumstances, and I do not believe that any such circumstances have been proven. Within Paddock Wood itself there are brownfield sites which have lain derelict for years, and TWBC has failed in its duty to ensure these are used before agricultural land is lost. In short, it has 'taken the easy way out' by lazily proposing the destruction of East Capel.

The extension of Paddock Wood towards Five Oak Green, Tudeley New Town, and the school site east of Tonbridge, would effectively urbanise the whole central corridor of the Parish of Capel, altering the landscape beyond recognition. Wasn't the purpose of the Green Belt Act to protect the landscape and prevent urban sprawl? Once this policy has been breached further violations are predictable, probably inevitable. It is time to call a halt now.

Our Conservative Borough Councillor's election manifesto made these commitments:-

I passionately support maintaining the quality of our rural environment and heritage and will work to prevent inappropriate development of the Green Belt, and preserve the Area of Outstanding Natural Beauty.

I will work with the Borough Council to limit any proposed residential building to small appropriate developments . . .

That manifesto was endorsed by the Leader of the Conservative Group, but now it is that very Group and the officers it instructs which is proposing destruction of Capel's rural environment, our heritage, and large swathes of the Green Belt, and is promoting residential building which is most certainly neither “small” nor “appropriate.”

I urge the Council to think again, withdraw this threat to our precious environment, and tell Her Majesty's Government that the Green Belt in general and the Parish of Capel in particular is not to be sacrificed to provide houses for wealthy commuters.

DLP_560

Carole Noakes

I also object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1). This is a totally unnecessary desecration of Green Belt Land.

DLP_596

Sport England

Policy STR/PW 1

Sport England support point 3 which is in line with the adopted Playing Pitch Strategy.

Sport England would encourage any masterplan to incorporate Active Design Principles  http://www.sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/active-design/ in order to create healthy and active environments for the new residents and visitors.

Sport England supports point d under Infrastructure which is supported in the adopted playing pitch strategy.

DLP_611

Don Kent

You state that monies from development should pay for infrastructure, but how can that be when there is so much that needs doing. From not just Doctors surgery, ( where are you going to get the doctors, as it has taken nearly 3 years to get me a regular doctor and not a temp) schools 1 primary and an extension to Mascalls, again where are you going to get good quality teachers, Road improvements in Paddock Wood need to be addressed not just junctions, Mascalls court road need widening and straightening and so does Church road, then the Maidstone road needs improvement especially over the bridge going towards East Peckham. Colts Hill bypass needs to be addressed before any development is started and this is without addressing the flooding issues and sewage system. So where is all this money coming from to accommodate and address all these issues. The land the developers will be building on is not good quality building land so developers will be going to you asking for reduced infrastructure costs imposed on them due to high development cost as has happened in the passed and been given. Paddock Wood has never had the infrastructure it needs,take for example the 1100 houses we have starting at this moment, we were promise this before but nothing has happened except more flooding poor sewage systems and poor roads.We cannot comment on the master plan as it is not ready yet, but you expect us to comment on the local plan???

DLP_642

Andrea Childs

I wish to register my objections to the proposals by Tunbridge Wells Borough Council to build over 4000 new homes in Tudeley and East Capel (the Strategy for Capel Parish - Policy STR/CA1) and the inclusion of land in East Capel (the Strategy for Paddock Wood - Policy STR/PW1). I understand my contact details will not be published. My concerns are:

Firstly, this is greenbelt and agricultural land, including floodplains. I understand there is brownfield land available within the borough which was previously under consideration in 2018. There are therefore no ‘exceptional circumstances’ to merit greenbelt being used.

Secondly, this will result in many more commuters on the Paddock Wood and Tonbridge commuter trains. These trains are already overcrowded at peak times.

Thirdly, this area is well known for its walks. Visitors are particularly attracted by All Saints Church, Tudeley, well known for its Chagall windows.  It is entirely inappropriate to develop this area for housing, particularly when there are brownfield sites available elsewhere.

Finally, local schools, doctors and hospitals are already full to capacity.  Any increase in housing in this area of Kent will add to this problem.

DLP_698

Debbie Hughes

I write as a local resident to raise my strong objections to the proposals by TWBC to build over 4000 new homes in Tudeley and East  Capel and a large school near Somerhill. Namely “The Strategy for Capel Parish” (Policy STR/CA1) and the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1). I understand you may publish my objection but not my contact details. My objections are:

The residents of the 2800 homes proposed for Tudeley (possibly 6000+ people) will come  to Tonbridge for their services eg health service, schools and other amenities as its closer than Tunbridge Wells. As a council tax payer in Tonbridge I strongly object to carrying the cost of increased demand for our local services which will be stretched beyond capacity and TWBC walk off with the council tax payment.

This is over 600 acres of greenbelt (GB) and prime agricultural land, including major floodplains, which would be destroyed. TWBC has brownfield and non GB and non-AONB land available across the borough and considered up to 2018. There are no “exceptional circumstances” to merit greenbelt being used on this scale.

In particular, for me as a commuter,  it will push thousands more people onto the Paddock Wood and Tonbridge commuter trains. In Tonbridge, the roads at peak times are already very heavily congested and not able to be widened. Parking is a nightmare.  Where will all these cars and people to go? TWBC are simply viewing the additional commuters at Tonbridge as somebody else’s problem. This is not acceptable and has not been thought through.

DLP_710

Ruth Dixon

I am writing to register my objections to the recent Tunbridge Wells Council Local Plan.

I have lived in Tonbridge with my family for nine years, having previously lived in Hildenborough for twelve years. We live on the northern edge of Tonbridge and I work at a local secondary school.  My family and I enjoy living in Tonbridge and appreciate all that it has to offer in terms of facilities and services and also the open countryside.

I am also writing to strongly object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

All of the points above for the Strategy for Capel Parish are to be repeated for the Strategy for Paddock Wood.  There is no justification for building on Green Belt land, and the points regarding the impact of traffic, pollution, flooding risk, cost of infrastructure remain relevant.  Please can the nine points above be applied to my objection with respect to The Strategy for Paddock Wood?

I trust that the above objections are taken into consideration.

DLP_795

Peter Ashlee

I have lived in Kent all of my life and have cycled with the West Kent CTC (Cyclists Touring Club / Cycle UK) since 1972. We cycle for pleasure along the roads, lanes and bridleways but during this time my cycling colleagues and myself have seen ever increasing traffic and the subjugation of the countryside that we live and need for our mental & physical health.

These proposals are yet more examples of the misguided desires of the planners and developers to ignore the needs of those living and working in the area. There is nothing in this scheme that will promote our cycling pleasure and the quality of the area everything to decrease it

Please add my contact details to your consultation database so that I can be kept updated. I understand that my comments will be published by the Borough Council. Including on its web sites.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1 and the inclusion of land in East Capel  in “The strategy for Paddock Wood” (Policy STR/PW1).

The fundamental point is that this is Green Belt land. When The Town & Country Planning Act was 1st published in the 1940’s it was in response to the effects of the effective unregulated pre WW2 planning and the detrimental effect that this was having on the countryside and the people. As the famous Polish author Marina Lewycka has written, a country needs its cities and towns at its heart but it needs its countryside as its lungs. Both need to be kept in good condition and both are needed for a healthy life.

One of the purposes of the Green Belt was to literally draw a line where no urban development would be allowed so that developers and planners were clear that this land was sacrosanct and could not be touched. The only consideration would be in “Exceptional Circumstances”. Are not examples of exceptional circumstances  war, famine, flood and other extreme isolated incidents? Surely simple market forces for housing cannot be considered in the same category?

Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. If this proposal goes ahead it will lead to ever increasing motor traffic from the B2017 from Tonbridge as well as all of the lanes from Golden Green , through Tudely, Capel, Paddock Wood, and the surrounding area. It will lead to the destruction of woodland, hedgerows, meadows and farmland, spoiling the landscape, killing wildlife and creating noise and pollution in an area of priceless beauty. These are not mere words, they go to the nub of the issue about the quality of the overall environment.

As an Occupational Therapist I am fully aware of the need to maintain a healthy mind and healthy body. It is accepted that that the peace and tranquilly of the countryside can assist with the former and being able to exercise by walking and cycling the latter. This scheme will have a detrimental effect on both for the reasons mentioned above and while difficult to coldly cost must be considered.

With regard to climate change, sustainability and biodiversity, the Garden Settlement proposal goes against all.  The Council’s sustainability assessment shows that it’s housing objectives are compatible with only 5 of the 19 sustainability objectives they have set themselves and incompatible with 9 of them. Covering the fields with houses and roads will make the river Medway flood more often not only in the area affected by this development but also East Peckham, Tonbridge & Yalding, areas already at extreme risk where significant flooding has frequently occurred in recent years.

The inevitable increase in motor vehicles and the houses themselves will all increase noise air and light pollution at a time when it is supposed to be Government policy to reduce them. The infrastructure in the surrounding area is barely able to cope with the demands of the movement of people at the moment in relation to motor vehicles and train capacity. How will the people living in the new settlements get to work , to the shops, to meet their friends and family? Will it be walking or by bicycle? Of course not. They will be driving. 2,800 dwellings will create an unsustainable demand on the existing infrastructure and the mitigation measures are counterproductive.

The reason for the housing being proposed in this area needs to be questioned. Who offered it for sale and why? Is it not convenient for TWBC to have been offered a huge parcel of land from one landowner instead of them having to apply for compulsory purchase orders? Is this proposal a lazy way to achieve the numbers they feel they need to achieve in the draft local plan?

With regard to the Draft Plan the whole basis of the proposals are flawed because the figures are likely to be wrong. The most current national statistics on population growth and household formation have been ignored by national government. Instead of the arbitrary target of 300,000, Mulheirn’s report published by the UK Collaborative Centre for Housing Evidence concludes that no more than 160,000 homes per year need to be built to cater for housing need. TWBC is using housing need numbers and the NPPF to justify building on this Green Belt Land by saying that if they do not do it central Government will do it for them. However, in 2018 Rt Hon Sajid Javid said , Planning inspectors cannot enforce Green Belt releases onto authorities. The NPPF states that before changes to Green Belt boundaries are proposed, councils should examine fully all other reasonable options and make as much use of brownfield as possible. Has there been a complete and thorough search for Brownfield land in the Borough of Tunbridge Wells?

In addition to this, national planning policy does allow Tunbridge Wells to provide for less than the assessed housing need, in view of the high proportion of Green Belt  and AONB land.

Finally, we are in a nationally recognised climate emergency. Under the Government’s climate change guidance, planning authorities are advised that the distribution and design of new settlements and sustainable transport solutions are particularly important considerations that effect transport emissions. Tudeley garden village represents a housing model highlights the unsustainability of this draft plan. It represents unsustainable, environmentally harmful destruction of the countryside, replacing a beautiful, unspoilt and protected site with a dormitory for city commuters, heavily reliant on private cars for transport. It will destroy local communities, ruin local residents’ lives and ruin for ever the Kent that we know and love.

DLP_797

Peter Lakhani

I also object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

It is clear and obvious to anyone that gives it a moment's thought that these 'strategies' will cause immense harm to residents in the local area. The entire area is already near to 'gridlock' on a regular basis and this will make it a whole lot worse.

What on earth are those that put this strategy together thinking of?

Where will all the additional people park when they come into Tonbridge? (please don't say they will cycle or get the bus - we all know that isn't realistic!)

What calculations have been done to assess the effect on car journey times?

What is the increased safety risk to cyclists and pedestrians?

Where will the additional train commuters sit (the trains are already bursting at the seams)?

What has been done to assess the effect on air pollution?

Where will all the additional people go to see a GP? Or to hospital?

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.

I would appreciate a full response to the questions above please as soon as possible?

DLP_800

Amy Dixon

I am also writing to strongly object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

These are for the same reasons as above - there should be no building on the Green Belt land, the area will be damaged by the buildings, we will lose farmland and the general countryside, there is a flood risk, there will be more traffic and pollution and congestion.

Therefore, the plans are not appropriate for the area and they should be rejected.

DLP_815

David Hughes

I write as a resident to raise my strong objections to the proposals by TWBC to build over 4000 new homes in Tudeley and East Capel with a large school near Somerhill, namely “The Strategy for Capel Parish” (Policy STR/CA1) and the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1). Please add my details to your consultation database so I can be kept informed of future consultations on Planning Policy documents. I understand my comments can be published but not my address and contact details. My two key objections are set out below.

Economics for TWBC: the true cost has been under estimated  – the arithmetic does not work

As a finance professional, I have done a brief cost benefit analysis and concluded that council tax raised from the developments would not cover the cash investment and borrowing required to provide the required additional new and upgraded Council services needed for some 15/20,000 people. The numbers presented in the plan hugely underestimate costs in a number of areas. This project would appear to have a significant negative net present value from the Council’s viewpoint and would be ruled out as uneconomic if proposed in the private sector. The councillors have not justified their arithmetic sufficiently, using limited and flawed assumptions, assuming that utilities will foot the many of the costs and deliver required infrastructure on time and that implicitly Tonbridge Borough Council will carry the burden and costs of additional services for Tudeley. Councillors have a duty of care which also should extend to the medium to longer term when they are no longer in office so that someone else is not landed with a major debt problem. Councils have become insolvent in the past due to poor decisions which may then carry personal liability for the councillors.

Local Infrastructure issues

I have spent the past 15 years investing in various forms of UK infrastructure and renewable energy and am particularly aware of local area difficulties re utilities, including:

  1. Fresh water supply. The whole of Kent is already distressed for water and the supply infrastructure aged and need of substantial upgrade. Bewl Water’s recent falls in reservoir levels and  the significant upgrade of the Sevenoaks water supply currently in process illustrate this point. The TWBC historic statistics used do not take account of the negative effects of climate change. The water companies are already under supply and financial pressure and concentration of 6000 new homes (including East Paddock Wood) in one area will create significant problems in supply, financing and timing of delivery, which could take many years and be highly disruptive.
  2. Sewage/waste water infrastructure. We know from sewage flooding in recent years in the local area that this is a problem and new sewage plants and pipework will be required. Again major disruption, cost and delivery issues over many years.  This problem is exacerbated by the fact the water table is very near the surface in the local area.
  3. Electricity. I know from experience that the local grid is inadequate and insufficient for 6,000 new homes – this completely ignores the forecast usage of electric cars over the next 5-10 years which will require double the capacity again. Upgrades to large, intermediate and local substations are incredibly slow due to the significant pressure on demand across the UK given most of the electricity infrastructure was built in the 1950/60’s. Currently it can take up to 2 years to get even a small local upgrade in this part of the South East. The utilities again are under considerable demand and cost pressure here and nationwide with competing demands, disruption, cost and delivery issues.

Major upgrades will take perhaps 10 to 15 years to complete. Economically the previous draft proposals for smaller developments across the borough made sense as bolt on services and utility upgrades can be added at lower cost and more quickly.

There are no “exceptional circumstances” to justify using 600 acres of Green Belt which was established to prevent exactly this form of development.

This massive set of developments threatens the character of the Kentish Weald, an ANOB. Most of this is prime agricultural land when other brownfield and infill sites are available. It potentially creates a conurbation between Tonbridge and Paddock Wood, the very thing the Green Belt was meant to protect against.

DLP_827

C G Rickard

I am also writing to strongly object to the inclusion of land in East Capel in "The Strategy for Paddock Wood" (Policy STR/PW1).

All points above also apply to the Paddock Wood proposal [TWBC: see also comment number DLP_824]. Small developments and brown field sites elsewhere in Tunbridge Wells Borough must be explored further as there is no excuse for wholesale, wanton and unnecessary destruction of Green Belt Land.

DLP_832

Mrs Margaret Swaite

As a resident of Paddock Wood I strongly object to the huge volume of housing which is envisaged for Paddock Wood and Tudeley which will have a detrimental affect on the  lives of residents.

Since coming to Paddock Wood in 1966 I have witnessed a huge increase in the housing with little thought seemingly going into the infrastructure. At present the local medical services are struggling to provide adequate care. Few new shops have been built in spite of an increase in the population, the roads are unable to cope with the volume of traffic at certain times of day and the schools are already at capacity.

Added to these problems, the new housing development will cause flooding in an area which is in a flood zone. The attenuation ponds built since I have been living in Paddock Wood have not solved the problem of flooding: this is likely to get worse with climate change and extra development. Southern Water have said that there is insufficient capacity for sewage after 60 homes have been built on the Green Lane site - and yet they have agreed that 60 more homes can be built on the Mascalls Farm site. Residents in Paddock Wood already have raw sewage on their property following heavy rains.

I also object to the number of homes envisaged in Paddock Wood because they will be detrimental to our environment, with more pollution and noise from increased traffic and a loss of trees which are needed to ameliorate our carbon emissions. We need our green spaces, not only for leisure and sport (for a healthy lifestyle) but also to promote our good mental health in an age where there is so much pressure.

I urge you to reduce greatly the number of houses planned for this area and to ensure that adequate infrastructure is planned for any extra housing development, especially with regard to the foul waste drainage and risk of flooding.

DLP_842

E D Rickard

I am also writing to strongly object to the inclusion of land in East Capel in "The Strategy for Paddock Wood" (Policy STR/PW1).

I also object strongly to the positioning of the development of land near Paddock Wood. This land is also part of the Green Belt and should be preserved for the future. It is also a flood risk area with overstretched infrastructure.

I feel small developments and "Brown Field" sites elsewhere in the borough need to be explored further before wholesale destruction of Green Belt Land is sanctioned.

DLP_877

Lisa Leslie

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1). I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

I have attended meetings, read the literature, taken part in one of your Facebook Q&A sessions and listened to your Head of Planning but I still have a number of unanswered questions. Your inability to provide any answers or answers that are 'lose', flim flam in nature, lack detail or are not specific enough form the backbone of my objection. I want to also make it crystal clear that in top addition to my points below, I do NOT support building on Green Belt land, on a flood plain, on any SSNI, on AONB or anywhere that jeopardises our natural wildlife habitats and precious ecosystems.

Who will buy these homes? - I do not think you will sell all the properties proposed in the Draft Local Plan. When asked, your Head of Planning said 'Londoners' would buy them. This is an admission, right there, that the homes will be priced in a way local Kent people will be unable to afford, alluding to the fact that Londoners will be able to cash in on their higher property values to move to Capel Parish. This is not in the spirit of building local homes for local people.

If Londoners are so desperate to live here, why are so many homes for sale and to rent still on the market? Rightmove will show you just how many and tell you the 'length of time' they have been for sale or up for rent. Add in thousands of new homes - many being built in neighbouring TMBC - and tell me where these people will come from.

Figures - TWBC is adamant it has been given housebuilding targets by Government. These are outdated figures that do not reflect: a.) current migration trends, with more people choosing to leave our country b.) a trend for people to have fewer children c.) Brexit and the scrapping of Freedom of Movement, that is likely to see our population decrease very soon d.) an ageing population who need assisted living homes and not 'executive' detached houses e.) economic fluctuation, that may see us tip into recession f.) the distinct prospect that interest rates will rise from their historic low and make home buying and moving prohibitive for millions g.) the prospect of so many 'garden villages' coming to fruition over the next 20 years, saturating the market and tipping many people into negative equity.

Why have you not got the professional foresight and gumption to challenge your TWBC house building quota? Or even a backbone to refuse it!

A profit exercise - house builders build for profit, not for charity or good causes. This is merely a commercial exercise. As soon as this plan moves into the hands of developers, all control will be lost. Developers can go back in for new planning applications to amend plans and extend the size of the development or alter the density of the site. They can tinker will asking prices too. Therefore what you present to us as existing residents now will most likely not be what we end up with.

Landbanking - are you aware of this? No one at TWBC has been able to tell me if the developer at the helm of the garden villages will be prohibited to landbank. If they do landbank in the hope that land values will rise, they may sit on the land for decades. This, in turn, will cast a black cloud over the parish that will detrimentally affect existing residents' house values and ability to sell - your Local Plan will be cropping up in conveyancing searches and deterring people from moving here. What's to say the parcels of land won't be sold on it the future and become part of a bidding war? May I remind you of your very own TWBC ABC 'cinema site' debacle for perfect illustration.

Fake 'affordable homes' - not one person at TWBC has been able to give me a break down of your affordable homes plan. To Mr Joe Bloggs on the street, they think your promise of 'affordable homes' means cheap property well below market value or even council houses of the old variety. Help to Buy and part buy, part rent are not affordable homes, and evidence suggests that it's actually more expensive to own a home this way!

Real affordable homes - I have been unable to establish who will be offered any true affordable homes. It is a nationwide trend to redistribute people and families in need, with influxes of people from outside of the county - let alone the parish or borough - being moved into the affordable homes. I have not been reassured that your affordable plans are for Kentish people, which they should be. Birmingham families being moved to Marden is not how the process should work as there are deserving families within TWBC that should benefit.

Non exploration of vacant properties and brownfield sites - I have not been given assurance by TWBC that it has fully explored brownfield sites and vacant properties (of both residential and commercial nature) in its borough to create new homes.

Lack of skills an even bricks - have you ever spoken to a house builder? Did you know that building in Kent has recently been suspended on some residential sites because of a lack of bricks? But, of course, this may not be a concern of yours if the huge quarry plan off Whetsted Road is given the green light - another huge blot on our wonderful Capel Parish landscape. Brexit will also cause a skills shortage - it's already being felt by housebuilders - so this may stunt any plans unless there is a huge training and recruitment plan.

I am more than happy to sit down and speak with you in detail.

In addition, please add my contact details to your consultation database so that I can be kept informed of all future consultations on Planning Policy documents. I understand that my comments will be published by the Borough Council, including on its website.

DLP_897

Tonbridge Line Commuters

As a rail user group, our comments are strictly limited to the impact of this development on the transport infrastructure in the area. Tonbridge Line Commuters (TLC) is a recognised rail user group, representing the interests of rail passengers from Tonbridge, Paddock Wood and Hildenborough. We have three main areas of concern around the draft plan.

In proposing the volume of housing and the concentration of residential development in the Paddock Wood and Capel areas Tunbridge Wells Borough Council does not address adequately the impacts of an inevitably large increase in rail commuting that would result.

Access to Stations. TWBC proposes prioritising development in the Paddock Wood and Capel areas of the borough, partly because these areas have convenient access to local railway stations (Paddock Wood and Tonbridge).   However, none of the allocated sites are within reasonable walking distance of those stations, and realistically, cycling is going to remain a minority choice. Without a very significant provision of high frequency (minimum 15 minute intervals) shuttle bus services running from 06.00 to at least 21.00 on weekdays, the majority of trips to and from stations are going to be by car, either as drop-off/pick-up journeys, or with associated parking around the stations.

We note that bus provision is outside the remit of TWBC, and is Kent County Council’s responsibility.  We therefore have very low confidence that TWBC would be able to adequately ensure that suitable bus services will be introduced as developments take place.

Existing road access to both Paddock Wood and Tonbridge stations is via congested and relatively narrow town centre roads.  Especially in Tonbridge, traffic at peak times is already heavy and slow moving and there is limited opportunity for improvement (and in the case of Tonbridge, not in the remit of TWBC).   TLC is of the opinion that any local development that is likely to increase car traffic to and from these stations is unsustainable.

Station Parking. On the assumption that the proposed developments go ahead without mitigation of the station access issues noted above, once passengers reach the station there is very limited capacity for additional parking at existing facilities in either Tonbridge or Paddock Wood.  In theory, it would be possible to provide more parking by converting the existing surface car parks in both locations to multi-deck parking, as has already been partially implemented at Tonbridge.   This, however is a very expensive option and it is not clear where any funding would come from, especially as the existing parking infrastructure is not under the control of TWBC (being owned by Network Rail or Tonbridge and Malling Borough Council). Our analysis, supported by Tonbridge and Malling Borough Council, suggests that the majority of people would drive to Tonbridge station (not going back on yourself and much greater choice of services). TLC believes that the significant increase in parking that would be required would not be achievable.

Passenger Capacity.  The existing train services from Paddock Wood and Tonbridge into London are already nearly full at peak times, and there are housing developments underway further down the line from Ashford to Tonbridge. The vast majority of rush hour trains in this area are already 11 or 12 cars and so extending the remaining services would add very few seats and not nearly enough to cope with the influx of commuters this development will bring.  The trend towards part-time commuting may provide some respite but is not, in TLC’s opinion, sufficient to offset the likely extra demand that some 9,000 homes in the Paddock Wood and Capel area would generate.

Looking to the medium term, Network Rail’s Kent Area Route Study states (paragraphs 6.9.4 and 6.9.5) that routes via Tonbridge are most in need of extra capacity but providing any extra capacity between 2024-2044 is “challenging” and there are no practical or fundable schemes for doing so. Such capacity improvements would require expensive and innovative solutions such doubling 2 track section between Tonbridge and Orpington to 4 tracks. Other issues include power supply limitations and lack of capacity at the Charing Cross terminus, which could not be addressed without a major rebuild of the station. The Kent Area Route Study makes clear that the rail industry simply has no plans to solve these issues. To do would require huge investment from Central Government and is certainly beyond the 15 year horizon covered by the draft TWBC Local Plan.

All of the likely train overcrowding mitigation measures are outside TWBC’s capability to directly influence.  Realistically, should these proposals go ahead in their current form then commuting from this area into London will become an intolerable experience.

As a result of the concerns above, we cannot support these proposals.

DLP_960

Mrs Karen Stevenson

The proposal to add up to another 4,000 homes at Paddock Wood is unrealistic and will have immense adverse impact on the existing residents of both Paddock Wood and neighbouring areas. There appears to be little consideration given to the pressure this will put on the already busy local and rural road network. Considerable traffic from Paddock Wood already passes through Matfield to reach the A21, and this will only get far worse as more homes are built. There seems to be no consideration to how the rail services will cope with the extra commuters, as clearly most of the new residents will be London commuters. The trains which used to “fill up” at Tonbridge will now do so at Paddock Wood, if they haven’t already done so at Marden where yet another raft of housing is being proposed. The Paddock Wood station car park is already full every day. The station parking would need to be significantly increased in capacity to deal with the additional commuters.

Further, I would challenge the suitability of Paddock Wood to increase in size to the extent that is proposed, when it has such poor highways connectivity to the national trunk road network. Even with the proposals to create a new by-pass on the A228 at Colts Hill, the damage to other neighbouring settlements will be considerable and unwarranted in an AONB environment. Its train station is the only real reason station why the town has grown to the size it has already, but as already stated above, this South Eastern train route is going to struggle to cope, with the additional developments proposed not only here, but further down the line.

DLP_989

Janet Harman

PROPOSED DEVELOPMENTS IN PADDOCK WOOD

The developments are excessive to a small town with very little infrastructure. It will cause more traffic chaos on top of the congestion at times in the Town. The Medical Centre is struggling now with volume of patients let alone with a few thousand more! Also, lack of GPs they are having to manage with Locums now.

To me the whole Local Plan is seriously flawed. It has been ill thought out and totally unsustainable for this rural area. Perhaps just to tick boxes for the Government. Other Councils have refused any more developments. TWBC have put in an extensive recycling scheme to 'save the planet' and then come up with all these building developments which will pollute the air, use more electricity and water.

DLP_1002

Esmond White

Your plan will cause heavy over-load on already congested roads in and around Tonbridge.

TWBC will take the new residents' council tax while T&MBC will have its health and support services inundated with thousands of extra people (your own estimate is about 6000!)

It is wrong to plan to build on productive farmland and the floodplains of the River Medway. Your plans will increase surface water run-off and increase the flood risk to us who live close to the river downstream.

There will be a horrible increase in noise, light and air pollution.

Now is NOT the time to be building on 600 acres of Green Belt and destroying the scarce natural habitat. In the 21st Century you should be planning low-rise development on brown field sites where the necessary infrastructure can be expanded.

Do not even think of building a new senior school so far from existing railway and bus stations.

DLP_1021

Mr & Mrs R B Coles

We have lived in the Parish of Capel since 1973 at Colts Hill in a property bordering the B2015 road , now renumbered as the A228.

We object to the inclusion of land in East Capel in “The Strategy for Paddock Wood”(Policy STR/PW1)

The proposed development of 1500 new houses on a Green Belt site adjacent to a flood plain and dissected by a main railway line seems inappropriate, and should only be carried out if there are exceptional circumstances. The rail , road, parking and other facilities at Paddock Wood are already congested and will deteriorate still further if the approved and proposed developments there are completed.

There appear to be several alternative sites to those in Capel in and adjoining Tunbridge Wells which should be considered for development if there really is a need for the thousands of dwellings being planned-viz:

Land between Sandown Park and the A21 Pembury bypass.

Land bordering Dunorland Park,Bayhall Road,and Halls Hole Road.

Land adjoining North Farm Industrial Estate, Robin Gate Woods and Colebrook The site of the former Rawsons garage and Ritz cinema bordering Mount Pleasant

Please add our contact details to your consultation database so that we can be kept informed of all consultations on Planning Policy documents.We understand that our comments will be published by Tunbridge Wells Borough Council, including on its website.

DLP_1218

Ursula Solomon

I see that there are plans to build 4000 new houses in Paddock Wood. Before you give planning permission please think, there are problems here at the moment - the sewage system cant cope, if we get floods and being on a flood plain it does happen from time to time, excrement comes out of the drainage system which is not healthy or pleasant as I'm sure you will agree.

The Healthcentre has a job to care for us all. I'm very lucky, I'm 88 and therefore am a priority case and when I'm ill which lucky is not often, a doctor is sent out to me. However my younger neighbours have to wait to get an appointment.

I taught at P.W. Primary School and there was a promise of a second Primary School on the Woodlands Estate - we are still waiting.

The lanes get busier every day, Lucky Lane was put aside as a place for horses and dog walking years ago. Now one has to be very brave to walk up the lane and its not very safe to cycle on either.

Wildlife has already been decimated. When I was a girl there were always hedgehogs in the garden and weasels used to scamper through, its years since I've seen a weasel (altho' in fairness they are shy!)

Please think carefully before you give permission. Once built the houses are here for life and rural life has gone for good.

DLP_1380

William Forster

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1) and to the inclusion of land in East Capel in “The Strategy for Paddock Wood”

(Policy STR/PW1).

I have lived in this area for 30 years and in Capel for c27years. As a family we have explored the countryside and made great use of available footpaths and landowner generosity.

When the call for land went out, we specifically didn't put our 7 acres up, as we felt the area wouldn't benefit from building on acres of green fields in the parish.

I object to the plan, both where it is sited and the volume it proposes. It is based on a disproven target, developer wishfulness, and very limited insight on the scope of impact and what would need to be funded by TWBC and residents. It brings with it a huge political risk as well as commercial risk of failure, puts vast swathes of the garden of England under yet more concrete and fails to address the flooding which such a site alongside, and in, a known flood risk area will bring.

Locations.

The Borough has nearly 50 Borough Councillors, only 1 of which lives in Capel Parish. The Borough has 18 parishes and Capel Parish (1 out of all) is getting 60%+ of the whole Borough's target. The imbalance is both stark and cavalier. Furthermore the plan refers to Capel as 'deprived' as if that gives the borough the right to ride roughshod across the constituents here.

And the Borough says that Southborough's air quality management problems will be alleviated by the new town at Tudeley. That is plainly nonsense. Traffic on the A26 through Southborough would more likely increase not have it reduced by Tudeley new town. And anyway if it were true would merely relocate the AQMA causes into Tudeley.

Plan

Over the summer there were 3000 properties available either for sale or rent within a few miles of Paddock Wood. Existing development in the area is not finding buyers. The ONS has advised that the targets for building are too high and based on discredited calculations.

The plan should not be taken further until Government addresses the target numbers.

The new town

There is no plan to alleviate traffic problems going into Tonbridge where the road to be used is already a choke point.

There is no planned new link between the north and south Tudeley new town developments across the railway. Existing bridges and the under pass are narrow and have traffic constraints. At least 2 new bridges would be required on the planned site if the blot of development is to have any chance of being a community.

Siting a new school to straddle a railway is asking for trouble, especially as no link road or footbridge is proposed. Children and railways are a dangerous mixture.

The link road to the A228 only addresses traffic going through between Tudeley and Colts Hill. It doesn't address Paddock Wood traffic up to the A21 via Matfield, nor Badsell Road traffic and Paddock wood traffic along past Transfesa.

The new development will increase traffic along the Pembury Road into Tunbridge Wells where traffic is already at a standstill during busy periods. There is no plan element which considers the already creaking access to Tunbridge Wells.

No consideration has been given to Tonbridge and that side of the boroughs' boundary. Tonbridge also has traffic problems and their station is already at capacity.

Pembury hospital, new just a few years ago, doesn't have planned capacity for the new household population.

The Borough planners talk about developer levies as being the answer to many problems but not to the above and are anyway unreliable. As cost escalate, the levy would run short. As new things are identified, the planned budget would not cover it and local taxes would get raised or services cut.

A developer elsewhere dropped a few houses from a plan so they didn't have to build the surgery and other community facilities which were contingent on the full permitted build being achieved.

Bus funding by Developers is promised to help manage traffic, but it is not clear how that will work and whether it will work. Nor is it clear how it is funded when development stops. And the plan appears to rely on Autonomous buses, a technology that is not yet available and for which there are many hurdles, both technical and legal.

Over 40 years ago a planned development in Paddock Wood was stopped for a while when it was found there was no sewage capacity. History repeated itself with the present Paddock Wood estates being built.

When Transfesa was developed it was on the basis that Colts Hill would be bypassed. We still wait for that, despite reclassifying a small capacity B road to an A road to help the process.

While a green field development is attractive to developers, it isn't to the community and no use of brownfield development is in the plan and has not been properly investigated by TWBC for delivery of any significant part of the target.

Bearing these points in mind we can have little faith in the integrity, necessity and adequacy of the proposed plan. It should be dropped and the target addressed with Government.

Please add my contact details to your consultation database so that I can be kept informed of all future consultations on Planning Policy documents. I understand that my comments will be published by the Borough Council, including on its website.

DLP_1539

Tonbridge & Malling Borough Council

Although Paddock Wood is further from the borough boundary than the sites at Tudeley and Capel, the size of the allocation here means that the same comments made above are also applicable, particularly for communities in East Peckham. [TWBC: see Comment Nos. DLP_1536-1538 within the Capel section].

The aspiration to improve the A228 at Colts Hill is a long held West Kent priority and is supported by TMBC. However, TMBC has significant concerns about the impact of works on the A228 and the potential wider implications need to be thoroughly considered in a holistic fashion, working with KCC Highways, TMBC and Maidstone Borough Council. Following officer discussions, TMBC are requesting that this approach to the A228 corridor is enshrined in the relevant policies.

The implications of this allocation (and the new settlement at Tudeley, which is unlikely to justify the introduction of an additional railway station between Tonbridge and Paddock Wood) on future rail capacity to London will need to be the subject of on-going discussions with Network Rail and the rail service providers and be included in the Infrastructure Delivery Plan. This extends not only to train services but to commuter parking and likely travel habits. The frequency of services at Tonbridge station make this the more likely destination for commuters when compared to Paddock Wood. There is also the need to consider planned development at Marden, Staplehurst and Headcorn that will put additional pressure on the line.

DLP_1576

Mr John Hurst

Do not develop any Green Belt land around Paddock Wood - if it is available, enhance it with more trees to address Climate Emergency.

DLP_1580

David Rowlands

I also object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

Your plan to create a garden settlement of at 2,800+ at Tudeley and 4,000 at Paddock Wood will cause nothing but harm to the local community, environment and wellbeing of the residents of the Parishes of Capel, Paddock Wood and the residents of Tonbridge. The only benefits are to TWBC through receiving the council tax of these new dwellings and that it solves 60% of their incorrect housing targets with one Vendor without them having to investigate their local brown field sites and other smaller sites within Tunbridge Wells and that they would happily use 600 acres of our green belt.

1. My objections are as follows: - (Please note you have already rejected planned building in this area for building only 6 B&B rooms)

1. GREEN BELT: - Losing 600 acres of Green belt and 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, clean air, and biodiversity. This area should remain rural with agricultural land that can be used to provide food. And to quote from Rejected building application 31st July 2018 REFERENCE18/01767/FULL. “The proposal would constitute inappropriate development within the Metropolitan Green Belt, which by definition is harmful to its openness. There is insufficient evidence of the necessary 'very special circumstances' to overcome this harm. The proposal is thus contrary to Policy MGB1 of the Tunbridge Wells Borough Local Plan 2006, Core Policy 2 of the Tunbridge Wells Borough Core Strategy 2010, and the National Planning Policy Framework 2018. The proposal, by virtue of creating new buildings with associated domestic paraphernalia, works to alter the land levels and potential additional impacts from further parking and works in close proximity to the trees at the rear would have more than a minimal impact on the landscape character of the locality. It would not conserve and enhance the rural landscape, nor would it protect the countryside for its own sake, nor preserve the interrelationship between the natural and built features of the landscape. The overall impact is harmful to the rural character of the area. It would thus be contrary to saved Policies LBD1, EN1 and EN25 of the Tunbridge Wells Borough Local Plan 2006, Core Policies 4, 5, and 14 of the Tunbridge Wells Borough Core Strategy Development Plan Document 2010, the National Planning Policy Framework 2018 and the Planning Practice Guidance.”

2. FLOODING: - Note the danger of Flooding and threat to life as highlighted in rejected planning (quote from Rejected building application 31st July 2018 REFERENCE: 18/01767/FULL). “It has not been demonstrated that the occupiers of the development would not be at risk from flooding or that the development would not increase flood risk elsewhere. Therefore, the development is likely to result in a risk to human life from flooding and is contrary to policies EN18 of the Tunbridge Wells Borough Local Plan 2006 and Core Policy 5 of the Tunbridge Wells Borough Core Strategy 2010, guidance in the National Planning Policy Framework 2018 and the Planning Practice Guidance”

3. TRAFFIC: - Increase in traffic in the region of 4000 vehicles on already congested roads in particular B2017 that will cause extreme high levels of Carbon dioxide (CO2) near at least 6 local schools queuing at current road junctions and roundabouts. The Office for National Statistics: - Household Labour Force Survey shows that: Percentage of households by combined economic status, April to June 2019 that 60% of households have both residents working which means at least one will use a car and 26% have one family member working which again no doubt will be using a car. I will be interested to see how you as stated achieve “ Zero and low carbon energy production to be considered during early design stages”

4. INFRASTURE: - Unacceptable increase of pressure and stress on local Tonbridge Doctors, Schools, Buses, Roads, and Parking, Tonbridge will become this garden settlement’s town of choice as its much closer than Tunbridge Wells.

5. TRAINS: - Unacceptable increase of commuters on already overcrowded trains at Tonbridge with no room for any increase in carriages due to length of platforms.

6. PARKING: - Insufficient parking in and around Tonbridge now.

7. SCHOOL: - The proposed new senior school will draw children in from all of West Kent. It is a 40-minute walk from the over busy station of Tonbridge. And the plan has a railway line at the back of the school grounds.

8. HERITAGE: - Damage to environment around a very important prized heritage site – All Saints Church at Tudeley, with its world renowned stained unique stained-glass windows.

9. Community: - This plan will divide the communities of Capel, Tudeley, Paddock Wood, and Tonbridge who will pay the price for this disastrous planning application that threatens the wellbeing of all of these communities.

DLP_1586

Tricia Bewsey

I can’t help wondering if there’s any point in objecting to the vast scale of planned development for the Paddock Wood and Capel /Tudeley area of the borough.

Many extensive objections were raised to the current developments in Paddock Wood and went on for some years. In spite of good and valid grounds to object the only benefit is alterations to schemes. The fact that the schemes will inevitably happen is a fait accompli.

We now have the first of such developments underway, discussions with sales staff has told us of the extremely limited interest in purchasing these properties. To the point where local rumour has it that Berkeley homes has put two tranches of that site back up for sale. The proposed new school and other benefits to the community are simply not happening.

Yet at the same time ancient green belt land in Badsell road is also being hacked about an enormous development planned yet again. Orchards destroyed.

No sign of the necessary infrastructure promised is happening. No village hall is being built. No swimming pool promised many years ago, no larger car park at the station to cope with new residents commuting needs. No new health centre to cope with one that is already at full stretch. That’s before we begin on the hospitals capacity, and the country lanes that abound around this area. Infrastructure needs to begin in tandem. We all know developers offer a token amount for something but if that something, such as a village hall or school isn’t on the table quickly enough they walk away from that commitment.

At what point do local councils stand their ground with government policies and say enough. Infill by all means, small localised developments definitely. But planning to concrete over vast areas of one of the most expensive property areas in the country seems little short of ludicrous. A minute one bed flat here would buy a reasonable house in the midlands.

If we need developments then let them be in areas where homes are affordable and create jobs and infrastructure to help these areas prosper.

DLP_1590

Maggie Fenton

I strongly object to the Policies STR/CA1, STR/CA2 and STR/PW1

  1. Lack of public Consultation

    It is not appropriate for consultation with the Community to first take place at Reg. 18. This is a 500% increase in housing in the parish of Capel. Growth Strategy 5 (Garden village)throughout the evidence base documents is just referred to as a possible option SOMEWHERE it is therefore evident that Tudeley (CA1) and East Capel (PW1) (to be delivered on the garden village principle) have never been formerly consulted on

  2. Lack of Process regarding consultation

    Neither the Parish Council nor existing residents have had the opportunity to be formally consulted on either site. The supposed consultation between the PC and TWBC has not allowed for the formulation and provision of a formal response until Reg 18. The whole community has merely been presented with what appears to be a done deal.

  3. Constraints

Almost all of PW1 lies within Flood Zone 3 – only 7% of the Borough has this designation. It would therefore seem that a different site with a lower flood risk (which would accord with NPPF 149) would be to be more appropriate and sustainable. There is a reason the current boundary of Paddock Wood stops where it does – its on the edge of a flood plain! All 3 sites are within the MGB. 2 would impact hugely on the AONB. Planned road infrastructure will cut straight through the AONB.

DLP_1624

Maggie Fenton

Policy STR/PW 1 (The Strategy for Paddock Wood) p.170

The expansion of Paddock Wood can be achieved without using land at East Capel for housing. Flood storage.attenuation/mitigation measures may be useful there but no housing is required. In fact, providing housing will contravene the NPPF as East Capel is Green Belt and the removal of East Capel from the Green Belt will cause coalescence with Five Oak Green. This is not permissible as the inclusion of East Capel in the expansion of Paddock Wood is not an “exceptional circumstance”.

DLP_1635

Amanda Parrett

As a resident of Tonbridge, I am devastated at the plans to alter the landscape and innate character of the town and local area in which I’ve lived my whole life. The very essence of what makes Tonbridge Tonbridge is its position within the countryside; with greenbelt land all around, yet with access to larger towns such as Sevenoaks and Tunbridge Wells nearby and quiet country villages in between. This is the reason for the town’s popularity and why people pay large sums of money/take out massive mortgages to live here. 

The plans for thousands of new homes and communitites to be built on our doorstep in our surrounding countryside will negate a signficant element of Tonbridge’s appeal and its inhabitants’ quality of life. 

I understand the need for additional housing, but – as with other elements of the TWBC plan – it needs to be distributed more equally throughout the Tunbridge Wells borough, rather than sandwiching our historic town next to a new ‘super town’. 

My 4-year old son started his school life in September this year (at the new Bishop Chavasse school right on the border with Tudely) and already the journey and parking is becoming an issue. The school is set within a new housing estate (a small version of what TWBC plans for Tudely/Capel/Paddock Wood) and it is already obvious that planners have not accounted for what will happen as the school grows. Traffic at the Somerhill roundabout on the approach is very busy at peak times. The new Tudely town will put additional pressure on this busy area, compounding the problem. Will there be new roads/ road layouts / parking areas to facilitate all the traffic from thousands more inhabitants? 

I object very strongly to the scale of the plan on the border of Tonbridge and feel sad at the prospect of losing the character of my home town.

DLP_1637

Peter Crawford

Regarding the plans for additional housing in the Tudely and Paddock Wood area I would ask you to consider the effect of these proposals on the residents of East Peckham. Many people in East Peckham are dependent on the services provided by Paddock Wood.

The following will have a major impact on East Peckham residents:

TRANSPORT- road, rail and bus services are already under stress and the new housing will substantially   increase this

FLOODING - flood control within the Medway valley is the responsibility of various bodies with no overall control or central planning and funding

EDUCATION - students from East Peckham, where there is no provision within the village for secondary education, have to travel to school; many going to Mascall's in Paddock Wood

HEALTH SERVICES - following the closure of the surgery in East Peckham residents are dependent on the services provided by Woodlands Health Centre which already is very busy and parking difficult

The overall environmental impact of these proposals on East Peckham will be extremely adverse.

The call for housing proposals to 2031 has produced a raft of ideas which are likely to be damaging and need to be drastically revised. The concept that each council should produce a plan without reference to the wider impact is basically unsound and there is a pressing need to consider the impact of major housing developments within the Medway valley area from Tudeley to Marden etc

DLP_1646

Tom Tugendhat MP

STR/PW 1 and AL/PW 1 - The Strategy for Paddock Wood

The Draft Local Plan proposes approximately 4,000 additional homes on land at Capel and Paddock Wood. This gives me huge concerns, specifically for the impact on those neighbouring communities.

Over the past few years I, along with East Peckham Parish Council and many patients and local residents, fought hard to save the East Peckham Doctors Surgery. We managed to in the short term, before it shut last year and residents were forced to travel to Paddock Wood to access Woodlands Health Centre as their local GP instead. This was a shame but it was felt that £250,000 was needed to bring the existing surgery up to scratch, a figure which Woodlands did not dispute when I quoted this to them in a letter dated 31 January 2018 about the closure.

On Page 170 of the Draft Local Plan, I note that it is referenced that Paddock Wood has its own doctors surgery. This is seen as one of the justifications for such large scale development here. However, in order for the existing surgery to cope with the demand from 4,000 additional homes in the town alone it will need to expand, and repurchasing a branch in East Peckham would be the best way to achieve this. It would enable the village to keep its facilities for the local population and ensure that Woodlands Health Centre can adequately deal with the greater number of patients visiting it from Paddock Wood. Meanwhile, East Peckham gets its branch surgery back and reduces the need to travel into Paddock Wood. I hope this is an issue which TWBC will pursue alongside West Kent Clinical Commissioning Group (WKCCG) to ensure that a significant increase in the population of Paddock Wood will not impact on the ability of East Peckham residents to see a doctor.

Furthermore, an additional impact of the Paddock Wood development which gives me great concern is capacity on the Southeastern mainline. We are already seeing significant development in the adopted Maidstone Borough Council (MBC) Local Plan in Marden, Staplehurst and Headcorn, the next stations down the line. The justification used by MBC to designate each of these areas as Rural Service Centres was that they had a railway station. Indeed, as some of these developments have been brought forward and built out they have already gone above the indicative figures in the MBC Local Plan. For example at Marden, Land South of The Parsonage on Goudhurst Road has an allocation for 50 dwellings, yet planning permission was granted for 65 dwellings in 2017. This represents an uplift of almost an additional third of the site allocation.

Consequently, we must accept that there will be significant additional demand on the rail network from Maidstone borough, and I am hugely concerned that, coupled with the volume of development proposed at Paddock Wood, it will result in overcrowding from these stations on the Southeastern mainline. At present, Tonbridge is the last realistic stop where passengers heading to London can expect a seat, and on the way back commuters are almost always standing from London Bridge. With further stops at Orpington and Chelsfield planned by the Department for Transport in the Invitation to Tender for a future Southeastern franchise, this line will only get busier.

I am hugely concerned that the only perceived impact on the rail network identified in the Draft Local Plan is the need for improved vehicle and cycle parking at Paddock Wood station. While this may be needed, it will do absolutely nothing to mitigate the impact of the development on commuters from Tonbridge and only seek to encourage more people to use the Southeastern mainline. I am extremely disappointed that there is no assessment of this and would urge TWBC to include this as part of their Regulation 19 consultation.

[see also full response - Comment Number DLP_1577 within the general comments on the whole Plan section].

DLP_1679

Ian & Julia Henderson

I am writing to object to "The Strategy for Capel Parish" (Policy STR/CA1) and the inclusion of land in East Capel in "The Strategy for Paddock Wood" (Policy STR/PW1) in the Tunbridge Wells Local Plan.

I understand my comments will be published by the Borough Council, including on its website.

My family and I have lived on Old Hadlow Road in Tonbridge for many years and regularly use the roads in and around the Tonbridge and Tudeley area. Specifically our son used to attend the Schools at Somerhill, so we are well aware of the traffic issues that are caused by the amount of traffic using the roundabout at the end of Woodgate Way coming from the Tudeley direction, as well as the tendency to use the road from Tudeley to Golden Green and then up to the A26 Tonbridge to Hadlow Road as a back route. We also use and have used the footpaths and rural area around Tudeley for dog walking etc.

The proposed creation of the garden settlement at Tudeley and a new senior school on the border of Tonbridge will create a huge increase in traffic which the current narrow rural roads are not equipped to cope with. There is already a substantial amount of traffic congestion on the B2017, particularly during rush hour in the mornings and any further development of the area would raise this congestion to unacceptable levels, leading to gridlock in and around Tonbridge, including the narrow, twisting road to Golden Green with a blind bend on a bridge over the river. Public transport is insufficient and too inefficient and people living in a rural area will always use cars in preference, despite schemes to encourage them to use other forms of transport. Commuter traffic will cause further problems with parking and train overcrowding at Tonbridge. Whilst the burden of the increased traffic and related costs to the Tonbridge council, individuals and businesses which will suffer as a result will be borne by Tonbridge the income from the new settlement from council tax will go to Tunbridge Wells. In addition residents from the new settlement would tend to use Tonbridge amenities which are closer than Tunbridge Wells which will cause further burdens to already overstretched health and other services.

The area proposed for a new senior school is completely unsuitable, being on farmland which is cut off from Tonbridge and public transport links in the town by a busy main road (A26) and a railway line. Tonbridge is well served by current secondary schools and the creation of yet another one would pull more children into the area from outlying settlements, so creating further traffic along already congested roads. Schools for the Tunbridge Wells Borough Council area should be built closer to other centres of population in the Tunbridge Wells borough, not on the border of Tonbridge borough.

The development of such a large area of housing on the flood plain is of substantial concern, particularly with the unknowns associated with climate change and rising water levels. It is known that development of housing increases water run off and potential flooding problems and any increase in this area close to the Medway could cause further problems with the already flood prone areas of Tonbridge, Golden Green, East Peckham and Yalding. The road from Tudeley to Golden Green already floods on occasion which would cut off one of the main exit routes from the proposed garden village. The flood risk assessments should be updated before any development plans for such areas are included in the Local Plan.

Sites CA1 and CA2 were not included in the plan preparation process until after the Issues and Options Process in 2017, meaning a large area of housing did not go through all the processes, with no detailed Green Belt Study, no Landscape Assessment, and no Biodiversity Assessment, meaning this part of the Plan is not ready for public consultation. The protection of Green Belt land was a high priority for those who participated in the Issues and Options process, and the building of the garden village at Tudeley and the Capel development would both be on Green Belt land. A growth corridor led approach should be implemented to protect Green Belt land within the borough.

The new housing in Capel parish would destroy current green belt land, including hedges, meadows and productive farmland as well as the wildlife associated with these. It would also destroy an area of countryside and turn Tudeley into a major settlement instead of a country village, disrupting local views and historic assets such as Tudeley church. Whilst there may be local housing need in the Tunbridge Wells area this is more than covered by other provisions in the Local Plan and the destruction of green belt land to provide housing would be unacceptable. The use of Tudeley to provide housing needs now will mean that in the future the Council would view it as an area which could be further developed to provide additional housing - the gap between the proposed garden village and Tonbridge would then gradually be filled until there was a complete corridor of housing along the road from Tonbridge to Capel and on to Paddock Wood (see the reference in 440 of the Local Plan to Tudeley Village securing a long term option for the borough to deliver the needs of future generations). Such a large extension of Tonbridge would destroy the character of the area and cost Tonbridge council and its residents an enormous amount in terms of burdens on services, transport and roads, whilst having little impact on neighbouring Tunbridge Wells. Development should be spread across Tunbridge Wells borough through development of brownfield sites where possible and, should a large development be necessary, it should be placed in an area with better transport links and more central to the borough, rather than placing all the burden on Tonbridge

DLP_1686

Trevor & Lesley Hill

We are writing to object to “The Strategy for Capel Parish” (Policy STR/CA1) and the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

Creating a garden settlement at Tudeley (“New Tudeley”) of 2,800 dwellings will cause immense harm to residents of the Parish of Capel and to residents of Tonbridge. There will be a significant increase in traffic 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 sixth 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. We believe this would be an unsafe site for a school given that it would be surrounded by heavy traffic and would require pupils and staff to have a safe crossing facility across the railway to access both sides of the site. As the railway line has a high voltage electrified third rail system there will always be a risk that someone could not keep to the official crossing installed leading to injury and potential fatality.

People living in the “New Tudeley” will use Tonbridge Station for commuting and will want access to Tonbridge town services, a consequence of which will be a need to increase the parking capacity for the station and the town, and the higher volume of traffic will be more than Tonbridge can cope with. The town’s 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 unless there are longer or additional trains. Addressing these issues will need to involve Southern and South Eastern Railways as well as Network Rail, who have already confirmed that a station at the “New Tudeley” is not viable at present and so will not be built in this plan period. Most people living in “New Tudeley” will probably drive privately owned cars, despite initiatives to encourage bus and bicycle use. The costs of updating the infrastructure on the Tonbridge & Malling side of the boundary could cause an increase in the council tax for Tonbridge & Malling residents, whilst Tunbridge Wells will receive the 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 also be an increase in pressure on local health services and amenities, including those that serve Capel Parish.

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 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 and East Capel but also 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 into Tonbridge & Malling and create an environmental scar across the landscape.

Creating so much housing in Capel Parish will require the destruction and loss of 600 acres of farmland, orchards, natural habitat for birds, fauna and flora, and area of natural beauty. This loss will probably have a negative impact on species numbers and the natural food chain.

Historic assets like All Saint’s Church in Tudeley, world renown for the complete set of Marc Chagall windows, may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout, which would no doubt have a negative impact on its value as a heritage asset.

Recent ONS figures show that population growth in the borough is slowing, yet TWBC has taken the housing need figure of 13,560 identified by the government and upscaled it to 14,776. We believe that the housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist and would like to see TWBC use this argument to remove the proposed development of “New Tudeley” and other similar proposed developments from this plan. Supplementing this argument we would like to draw your attention to the fact that the plan preparation process did not 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 the plan preparation process as recommended/required by the Government White Paper “Garden Communities”, August 2018. As there is no published Green Belt Study, Landscape Assessment or Biodiversity Assessment for these sites, we think that this version of the draft Local Plan isn’t complete enough to be ready for public consultation given that a significant proportion of the housing sites haven’t had the same level of assessment as the rest of the plan.

The plan strongly indicates that TWBC want to build housing in and around Tudeley and East Capel until they coalesce with Tonbridge to the West and Paddock Wood to the East, ultimately creating a conurbation that will dwarf Tunbridge Wells town centre when alternative sites are available throughout the borough.

We also note that TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel. The comment above about coalescence and the creation of a conurbation from Paddock Wood right across to Tonbridge is very relevant here, as is the land’s use as a flood plain. Building here, even with flood risk mitigation and “betterment” could have disastrous consequences for all, as the measures being looked at are based on old data that does not fully consider the impact of climate change.

Notwithstanding the above we would question whether the plan meets all the principles detailed in the above referenced white paper.

DLP_1694

Brenchley and Matfield Parish Council

3. Mitigating the Impact of Development

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

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

c. The Council supports policy STR/PW1 Transport 5, which requires provision of improved vehicle and cycle parking at Paddock Wood railway station. However, we note that it only refers to retaining the Commercial Road East and West public car parks, not increasing public parking provision in the town centre.  Unless public parking in the town centre is increased substantially, the existing public car parks will be entirely taken up by residents from the outlying new developments, which will mean that residents of surrounding parishes, who rely on Paddock Wood as their local centre for much of their shopping and services and who have limited access to public transport, will be unable to park. This will also impact adversely on retailers in Paddock Wood, who depend on a turnover of parking places for shoppers, rather than having most spaces taken up from early morning to evening by London commuters. The Council will therefore wish to see a substantial increase in public parking in Paddock Wood town centre.

[TWBC: part of whole comment number DLP_1683].

DLP_1719

Oliver Worsfold

I also object to the strategy for Paddock Wood (Policy STR/PW1). 

In line with my comments above I object to the use of green Belt for the same reasons outlined above and furthermore the Sustainability Appraisal conducted by TWBC themselves concludes that Paddock Wood can expand to meet the majority of the plans aims without the need to release the green belt in East Capel and there are certainly no ‘exceptional circumstances’.

My comments set out in (11) above also apply to the Paddock Wood development. The local area has historically suffered flooding, and climate change will make the situation worse in a way that no-one fully understands. Therefore despite best calculations on what will be required, the only thing that is certain is that the area is prone to flooding and additional development will enhance the risk and I totally object to the arrogance of TWBC when then believe they can gamble with the local community leaving residents at risk of a flood event that would be disastrous for the area.

DLP_1727

Emma Game

I also object to the strategy for Paddock Wood (Policy STR/PW1).

12. Release of Green Belt – in line with my comments above I object to the use of green Belt for the same reasons outlined above and furthermore the Sustainability Appraisal conducted by TWBC themselves concludes that Paddock Wood can expand to meet the majority of the plans aims without the need to release the green belt in East Capel and there are certainly no ‘exceptional circumstances’.

13. Compromising the Flood Plain – my comments outlined in (11) above equally apply to the Paddock Wood development. The local area has suffered serious flooding in the past and despite flood mitigation and ‘betterment’ TWBC are playing Russian Roulette with the local community as a flood event would be disastrous for the area.

This is a totally misguided plan that has only been developed as it is an easy option for TWBC to push 60% of their housing plans onto the furthest border of the borough so they only need to deal with a single developer and TWBC have paid no regard to the financial damage for TMBC residents who pay their council tax to fund local needs not those of TWBC.

DLP_1952

Ms Madeleine Bohringer

1. Building 4000 houses is a bad idea. Don't do it.

2. Regeneration of PW town centre is to be welcomed as long as it is done sensitively.

4. Schemes to reduce flood risk is required in Paddock Wood now, even before any more land is paved over.

7. Release of green belt land is not an option. We need our green belt, don't build on it. We need it's water holding abilities, we need the wildlife it contains and we need it for our own wellbeing.

DLP_1953

Angela King

I am commenting on the plans for the areas surrounding Paddock Wood.

Our town (Paddock Wood) is already at full capactity in many respects. To propose a further additional 4,000+ houses is outrageous.

My first concern is flooding. It is well known that we are prone to flooding so I cannot understand how you can consider allowing further building on a flood plain? I have not experienced it but I know that there are problems with sewerage too.

We have one health centre that is almost useless. The doctors are always leaving, leaving locums or temporary doctors. Our current new doctor (who took over a year to materialise) only works there for 2 days per week! It is common to wait 2 weeks for an appointment. This health centre cannot possibly accomodate any more patients and also does not have the parking spaces.

Commercial Road is where most of us shop/visit for errands. There is limited parking in a bay outside the chemist plus two car parks, one either side. These are usually busy and cannot possibly accomodate the additional vehicles that will be needing to park.

Paddock Wood is situated in a lovely position and enjoys plenty of beautiful countryside. It would be a terrible shame for this to be spoilt.

DLP_1989

Mr DA and Mrs SM Maclennan

Proposed Developments by the Council

We are very concerned to learn that your Council is proposing to build 2,800 new houses in Tudeley, a large senior school opposite nearby Somerhill and 1,500 new houses in East Capel. A particular concern for us is the impact that these proposed developments will have on us as long-standing residents of Golden Green.

We regularly use the route from Three Elm Lane in Golden Green (our nearest main road), via Hartlake Road and Tudeley Road to gain access to Tonbridge, Tunbridge Wells and other areas. From all that we hear, if these developments proceed, there will be resultant chaos on already congested roads in the Hartlake Road, Tudeley Road and Tonbridge areas, whilst associated hard surface work will increase flooding risk in Tonbridge, Golden Green, Hadlow and East Peckham. There is also an unquantifiable, but highly probable, negative effect on the marketability of and prices obtainable on domestic and other property in these areas.

We would like the Council to reconsider its proposals in view of the potentially significant adverse effects that they are likely to have.

DLP_2071

Terry Everest

Strongly object

Around 10% of that proposed can reasonably be absorbed by areas north and east of Paddock Wood rather than areas west of Paddock Wood .

Refer to comments for STR/CA1

DLP_2164

Mr Robert Assirati

I also object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

This land is also Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel.

Together with the proposals for CA1 and CA2 the result will be an almost unbroken built up are running for ten miles from the north end of Tonbridge to the east side of Paddock Wood, exactly what the Green Belt is meant to prevent.

As a professional project planner I find that the process for developing this plan has been faulty both in the completeness of the analysis and the lack of community involvement. There are so many shortfalls in the plan, especially with regard to the viability of CA1 that the Council should abandon this aspect of the plan and seek realistic alternatives such as the use of brownfield sites and should consider apartment blocks as a way of providing true low cost housing to meet local needs. To continue with unrealistic proposals will both waste taxpayers’ money and risk the plan being overturned by the Planning Inspectorate at a later stage, resulting in even more work.

DLP_2370

David Lovell

GENERAL COMMENTS: with specific reference to Capel sites (CA1 & PW1)

I live in Capel and walk extensively in the area, enjoying the beautiful countryside and its diverse landscape. I relish the wildlife, clean air, birdsong and dark skies, but fear all of this will be lost under TWBC’s plans to build thousands of unneeded houses in protected Green Belt land.

I therefore want to object to the intention to build extensively in the area, but the public consultation process is overly complicated, made all the more difficult by a Local Plan of over 500 pages of repetitive and thickly worded planning jargon. It must have been obvious the lay person would find it extremely hard to navigate, yet the process is further complicated by a convoluted on-line mechanism. By its complex nature people will be dissuaded from raising objections, and it is difficult to escape the conclusion this is by design.

Many Capel residents are concerned that, if we fail to comment in the right way, our objections may be misfiled or dismissed. This suspicion is down to a lack of trust in the planning process, compounded by misinformation and the avoidance of questions. Examples of include:

* Head of Planning’s claims of regular consultation opportunities for residents before the shock revelation in May 2019 of the intention to build extensively across Capel. This may refer to the Local Plan process before sites CA1 and PW1 were included, but that would be disingenuous at best.

* At a public planning meeting on 05/08/2019, TW Head of Planning said officers had consulted other boroughs throughout, but on 24/07/2019 Tonbridge & Malling had advised; “On TWBC – we have had Duty to Cooperate meetings with colleagues there, but these were before they proposed the sites in their reg 18 plan – the principle of new settlements was mentioned but there were no sites identified at that time.” Again, if TW planners are referring to consultation prior to the inclusion of the proposals for Capel, this would be deliberately misleading. No response has been received to my repeated requests for clarification.

* At that meeting, in response to a posed question from a councillor, TWBC’s Environment Officer claimed agricultural land in CA1 and PW1 was ‘poor quality’. TWBC’s own assessment in the Development Constraints Study, shows the land as Grades 2 and 3; defined by Natural England as ‘Very Good’ and ‘Good to Moderate’. Grade 4 is ‘poor’ and none exists in the area. However, in an email of 15/10/2019, TW Head of Planning again insisted the land quality was ‘poor’, a misrepresentation potentially explained in the same response: ‘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...’ If the land is ‘poor’, TWBC can claim the loss has little negative agricultural impact, but the loss of highly productive land is hard to justify.

* At a public meeting on 18/09/2019, in response to a question on the site for a secondary school (CA2), Head of Planning suggested Kent County Council had approved the site. KCC has denied this.

* By 24/10/2019 land at Pembury, included in the Local Plan, was cleared by developers even before the public consultation period ended. The clearance was not only disdainful of public concerns but must have been presumptive of planning permission. TW Planning Enforcement officers took no action.

Such misleading comments, avoidance of difficult issues, alongside a lack of detail and assumptive statements throughout the documents, and ignoring sharp developer practice, suggests TWBC have a policy to disguise or disregard inconvenient truths. The public consultation looks suspiciously like a cosmetic exercise, with principal conclusions pre-decided and likely to be disguised by minor changes.

Plans for Capel appear rushed, despite being the main thrust of the Local Plan, and with a flow of misinformation, lack of detail and biased assertions, planning strategy appears to be centred on finding ways to justify the unjustifiable, rather than a subjective exercise on the merits of the Capel proposals. This leads to my concluding the Local Plan is unsound, riddled with inaccurate and self-serving explanation, and cannot therefore be trusted. I therefore strongly object to the proposals for sites CA1 and PW1.

Comments on STR/PW1

Most of my concerns and objections relating to PW1 (East Capel) are expressed in my comments on site CA1 (Tudeley). To those I would add the following:

GREEN BELT

Paragraph 79 of the NPPF states: the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and permanence. By building on site PW1 the Local Plan ignores this policy and removes the separation between Five Oak Green and Paddock Wood, which will merge into one urban sprawl. I therefore strongly object to this proposed development.

Moreover, the separation between site CA1 and Five Oak Green will be minimal, and the separation between CA1 and CA2, which abuts Tonbridge will also be slim. When the KCC proposals to excavate gravel pits between PW1 and CA1 are also taken into account, alongside the infrastructure needed to link the developments and the A228, the Green Belt in Capel will all but have been removed and the AONB scarred. There appears to be no consultation between the various agencies about the cumulative effect of this combination of development and projects across the same area, which is a serious omission and needs resolving. An assessment of this combined works needs urgent attention, because as it stands the Local Plan will systematically decimate the Green Belt. The proposals for PW1 and CA1 fly in the face of the NPPF and HMG policy, and public opinion, for the sanctity of the Green Belt and must be reconsidered.

WATER

The proposals for PW1 mean building homes on a flood plain and in an area that already cannot cope with the ongoing developments around Paddock Wood. Current thought is that the water companies cannot, and will not be able to cope, and that sewage for further development will have to be contained within cess-pits. This is not a modern or environmentally friendly solution, and the extra HGVs needed to collect the sewage will only add to damaging pollution. Adding to this burden by building in an already inappropriate area, where sewage regularly breaches drains, is further evidence of the rash, irresponsible and unsound nature of the Local Plan’s proposals for PW1 and those neighbouring areas that are sure to be negatively affected.

I therefore object to the developments circling Paddock Wood, including PW1, which should be removed or, at the very least, halted and scaled back until a solution to drainage, sewage and water supply is established.

DLP_2386

Peter & Veronica Bryant

We agree to setting my comments against both the strategic place shaping policy in the Capel and Paddock Wood sections: these would be Policies STR/CA 1 and STR/PW 1.

In connection to the Proposed Draft Local Plan (Reg 18) please find our comments to this proposal.

As residents of South Tonbridge, we will be directly affected by the Proposed Draft Plan as it’s boarders run alongside Tonbridge & Malling Borough and the road infrastructure will impact our area considerably.

a. The road infrastructure from Paddock Wood to Tonbridge is at breaking point at this present time. With narrow streets in Five Oak Green and bending slow roads throughout the 6 miles, travelling along this route is certainly demanding during peak times of the day. (Early morning rush hour, school leaving times and evening rush hours). With the proposed additional housing along the route, the increase of traffic flow in both directions would be dramatic.

b. With the Ambulance Service stationed in Eldon Way, Paddock Wood, Emergency Services requiring to travel to Tonbridge already have a difficult enough time negotiating the traffic to get to an emergency. With the dramatic increase of traffic this would put lives in danger.

c. At present, bus services use the route from Paddock Wood to Tonbridge and Tunbridge Wells. Again with the dramatic increase of traffic flow created by new housing, services would be greatly affected, especially buses being used for the school runs in rush hour times.

d. Tonbridge town already has a dis-proportionate amount of Secondary Schools in the county which require children to be transported into the town from other boroughs mainly by bus. Adding an additional Secondary School into our area, which is on the boarder of the town will only increase the traffic congestion.

e. We find it totally unacceptable that any Green Belt land is used for building, especially in an area of outstanding beauty. This land is protected for a reason. Once this land is destroyed, it will never be re-instated.

f. By destroying Green Belt land you are going against all Government objectives on Climate Change Controls to obtain zero rated omissions.

DLP_2659

Anthony Clark

The plight of our fellow countryfolk in Derbyshire and South Yorkshire is a timely reminder, should one even be required, of the need to protect our homes and businesses from the increasing risk of flooding

Much time has been spent assessing and mapping those areas which as a simple consequence of their position are considered to be at the greatest risk. The fact that we know where they are is amply evidenced by the home insurance premiums they attract and it is a constant source of concern for all those who, like me, reside in low-lying areas

Setting aside the obvious but highly questionable funding presumption for the above - which sees TWBC draw rateable income to its benefit while requiring consequent costs and inconvenience to be largely borne elsewhere, in this case by Tonbridge (a town already creaking under the weight of its own recent and particularly extensive residential building programme) and parking (every pun intended) a number of very sound objections these being well documented elsewhere, it is quite clear that on the issue of flood prevention alone, the scheme lacks credence. In fact it beggars belief that the proposal could even have got this far

A plan that would incidentally require the wholesale destruction of Greenbelt in the case if the proposed 'garden' village at Tudeley is a monstrously reckless betrayal of custodial responsibility.  It might tick a box, it might well suit Hadlow Estates (who, may I say, deserve no credit for their obvious complicity in the matter), but it is completely unacceptable for the broader rate-paying community going forward

I appreciate there exists a national need for additional housing and that targets, however arbitrary, have been set. I also understand the challenges of meeting such targets locally and completely where there are substantial areas of precious Greenbelt, areas of Outstanding Natural Beauty and Ancient Woodland etc to be considered. But considered they must be and, by definition, protected. In essence it shouldn't be necessary for me to point out that this is clearly your job

I expect, at the very least, the proposed development at Tudeley- sitting as it would on the very edge and therefore contributing to the problems of a clearly identified floodplain - to be consigned to history and look forward to learning of this at the earliest opportunity

DLP_2661

Margaret Maw

I am sure that your minds are made up to continue with the huge development of Paddock Wood, turning a smallish town into a huge conurbation, built on the Green Built to the detriment of wild life, hedgerows and habitat, so I am not quite sure why I am writing this letter, but felt you need to know my views.

It seems that the Borough Council are putting much of their quota oh housing in this area of Paddock Wood and around lovely Tudeley and Capel, to the detriment of a rural part of Kent. Although I realise that more homes need to be built but it is all too intense. The housing already being built on Mascalls Court Farm is very dense and close together with very little garden for each home. On each of the proposed sites encircling Paddock Wood, I expect that many of the houses will each have two cars and this huge increase of the proposed housing Paddock Wood will cause terrible congestion on the already busy roads around the whole area. Already there is not enough room at the station car park and the trains to London will be packed before teh trains arrive at Paddock Wood because of all the housing development further down the line at Staplehurst, Marden etc.

The sewage system apparently is ailing in parts and is Bewl Bridge reservoir going to have enough water to provide for all these houses especially as we seem to be experiencing dryer summers and droughts due to climate change?

The Health Centre is already extremely busy and would be overwhelmed with even more patients and the shopping centre could not cope with all the extra traffic. We do not need another big supermarket.

It seems according to your maps that you intend to build right up to the Parish boundary with Brenchley at Mile Oak. Mile Oak is a very old historic hamlet with the majority of houses being listed. I think it is very important for the proposed housing to finish two fields away so that it is left as a rural entity and not swallowed up in the conurbation of Paddock Wood.

The proposed 'Garden Town' for Tudeley and Capel will take up a huge amount of lovely farm land and green belt which will spoil these lovely little communities. Obviously one day Tonbridge to Paddock wood will become one huge Commuter belt. A great shame for this part of Kent!

DLP_2856

Lesley Wakeling

am prompted to share my comments regarding the developments proposed for Paddock Wood.

I am aware that development will take place but am concerned that until a proper plan is in place it is worrying that the infrastructure, or lack of it, in the area will not be given proper consideration.

Traffic flow – already a problem

Parking – already a problem with no control over illegal parking

Schools – a bigger need

Doctors surgeries – not enough at present

Flood control – a major worry as there is no guarantee that measures will prevent flooding to existing houses/roads. We already have areas that flood and didn’t previously

Sewage from all the new houses – Southern Water does not have capacity for any more houses despite them being built. Who will remedy any problems when the system fails and affects existing properties.

Facilities – the town has seen business closing and will lose the valuable shops which provide the backbone for Paddock Wood. We need shops which sell goods, not hairdressers, nail bars and coffee shops.

Quality of life for existing residents – we already feel neglected with the support from TWBC. The litter problem is terrible. Policing is poor. Highway maintenance is poor.

Public transport – needs to be seen to continue and grow and not allowed to disappear

Maintenance of necessary infrastructure – this is poor already for Paddock Wood and needs some thought now, not in the long term plan.

I know that this is a long term plan but until something is drafted to say what the intention is on day 1 then everyone will contest the scheme. Infrastructure is key.

DLP_2979

Robert Johnston

There are no good things to say about the extraordinary number of new homes planned for the T.C.P.W. area.

It takes no brains to realise the effect on these areas of road congestion, air and noise pollution, educational and medical demands, increased flooding, insufficient retail outlets leading to overcrowded parking and shops. Quality of life for existing residents will suffer immensely.

House prices will almost suffer due to the oversupply and for the reasons above.

9% of TWBC's population will be subject to 65% of the new housing.

Planning with no thought for people's lives.

Think again.

DLP_3140

Andrew Pinhorn

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

I am writing to object strongly to “The Strategy for Capel Parish” (Policy STR / CA 1) and “The Strategy for Paddock Wood” (STR / PW1) on the grounds that this will involve the release of Green Belt Land.

This land was designated as Green Belt many years ago to ensure that important countryside was kept open, that urban sprawl was stopped and to preserve the special character of historic areas. It follows that the Green Belt designation should only be overturned rarely and in exceptional circumstances.

In my view, the merits of this Green Belt Land are striking in terms of agricultural use, amenity /therapeutic value, ancient woodlands and hedgerows, biodiversity. These merits far outweigh the dubious benefits should of more housing. The exceptional case argument has not been made.

The proposed destruction of Green Belt land is strongly opposed by local residents.

The Local Plan needs to be stopped in its current form.

DLP_3198

Harriet Maidman

I write as a local resident to raise my strong objections to the proposals by TWBC to build over 4000 new homes in Tudeley and East Capel and a large school near Somerhill. Namely “The Strategy for Capel Parish” (Policy STR/CA1) and the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1). I understand you may publish my objection but not my contact details. My objections are:

The residents of the 2800 homes proposed for Tudeley (possibly 6000+ people) will come to Tonbridge for their services eg health service, schools and other amenities as it's closer than Tunbridge Wells. As a council tax payer in Tonbridge I strongly object to carrying the cost of increased demand for our local services which will be stretched beyond capacity and TWBC walk off with the council tax payment.

This is over 600 acres of greenbelt (GB) and prime agricultural land, including major floodplains, which would be destroyed. TWBC has brownfield and non GB and non-AONB (Area of Outstanding Natural Beauty) land available across the borough and previously under consideration in 2018. There are no “exceptional circumstances” to merit greenbelt being used on this scale.

In particular, for me as a commuter, it will push thousands more people onto the Paddock Wood and Tonbridge commuter trains. In Tonbridge, the roads at peak times are already very heavily congested and not able to be widened. Parking is a nightmare. Where will all these cars and people to go? TWBC are simply viewing the additional commuters at Tonbridge as somebody else’s problem. This is not acceptable and has not been thought through.

DLP_3272

Kent County Council (Growth, Environment and Transport)

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

Paragraph 5 of 'Strategy for Paddock Wood’ lists destinations to provide strategic transport links to. KCC recommends this should include destinations to the north (Maidstone, Kings Hill, M20). Further work is required to assess this. KCC recommends the paragraph opens with the following: 'Strategic transport links and junctions shall be provided/improved between....

Paragraph 5 – “Strategic transport links and junctions shall be provided/improved between Tonbridge, Tudeley Village, the A228, Five Oak Green, Royal Tunbridge Wells/Southborough, destinations to the north in Tonbridge & Malling and Maidstone boroughs, land at Capel and Paddock Wood and Paddock Wood Town Centre. This will include the provision of an offline A228 strategic link. The exact location of such a link has not been determined. Links from Tudeley Village to the east (into the centre of Paddock Wood) 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”

Additional paragraph - Developers to implement improvements to road junctions and links in the town centre (subject to further assessment during the masterplanning exercise).

Additional paragraph - Strategic sustainable transport infrastructure (dedicated public transport routes, segregated footways and cycleroutes) shall be provided/improved between Tonbridge, the proposed secondary school, Tudeley Village, Paddock Wood and Tunbridge Wells.

Additional paragraph- Opportunities will be explored for a train station at Tudeley Village on the Southeastern Main Line route. If deemed suitable developers will deliver through contributions. If deemed possible for construction in the future, land will be safeguarded

Education

Proposed growth within Paddock Wood and Tudeley Village is forecast to generate the combined need for an additional eight forms of entry of secondary provision. It is proposed two forms of entry are provided through the expansion of the existing Mascalls School prior to the establishment of a new 6FE secondary school within the area. The total level of growth cannot be accommodated through the expansion of Mascalls alone and therefore Policy STR/PW 1 relating to growth in Paddock Wood must reflect the need for sites relating to the policy to contribute financially to the provision of the new 6FE secondary school.

Public Rights of Way and Access Service

While the proposals within the Transport section of this Policy are supported, there is no specific reference to PRoW. KCC recommends that PRoW is referenced 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_3379

Pamela Stanley

I have lived in Five Oak Green for 60 years. I like where I live but am distressed by this unfair plan which will destroy my parish forever and ruin so many lives. I know lots of people who hate this plan but aren't writing because thy say it's a waste of time and you will build what you want, where you want.

The comments above relating to Policy STR/CA1 apply here [TWBC: See comment DLP_3377]. The Council seems to treat Capel as part of Paddock Wood despite it being a different area and place.

The land targeted for development is a flood plain. Any attempt to deal with this issue by mitigation and betterment do not take account of global warming/climate change or its uses as a flood plain.

All of the land is greenbelt and agricultural land.

There will be a built-up area from Paddock Wood to Tonbridge and the character of Capel will be lost forever. TWBC talks about "love where we live" and then destroys one small part of the borough. Destroys is the right word because I for one wouldn't want to stay but don't have a choice.

Are there other plans for Councillors to consider-I hope so. There should be and I hope the Councillors look at this and imagine their own parish being destroyed in the same way. There should be a much greater sharing of the pain and there are far better places to put major development where roads already exist!

There are brownfield sites not included in this plan or not identified as such. The Council should have done more to identify and use them.

I wonder how the medical services will cope with this? There are major issues with finding GPs for Paddock Wood's surgery. The Pembury hospital is already stretched to breaking point. With around 7,000 new houses in this area together with around another 1,000 in Paddock Wood that already have planning permission we won't be able to get appointments or referrals.

Planning people and Borough Councillors don't understand the pain and distress this will cause. They may say they do but they don't. I saw all the opposition to 900 houses proposed in Paddock Wood - it counted for nothing and they're building even more than they asked for. I have no faith in getting a fair deal.

[TWBC: Sentence containing personal comments about individuals has been redacted]

The Councillors should have a rethink about the unfairness of this?

DLP_3399

Andy Ornsby

I live in Five Oak Green and have spent a significant time living in the village.

I object to the land in East Capel included in "The Strategy for Paddock Wood" (Policy STR/PW1 and Policy AL/CA3)

The comments above relating to Policy STR/CA1 apply here [TWBC: See comment DLP_3388]. The Council treats Capel as part of Paddock Wood despite boundaries and the separate identity of Capel.

The land highlighted for development is a flood plain. Any attempt to deal with this issue by mitigation and betterment do not take account of global warming/climate change or its use as a flood plain.

All of the land is greenbelt and is grade 2 or 3 agricultural land.

There will be a built area from Paddock Wood to Tonbridge and the character of Capel will be lost forever. TWBC talks about "love where we live" and then destroys one small part of the borough. Is there a back-up plan? There should be and I hope the Councillors look at this and imagine their own parish being destroyed in the same way. There should be a much greater sharing of the pain and there are far better places to put major development where roads already exist!

Many brownfield sites have not been included in this plan and the Council should have done more to identify and use them.

I wonder how the medical services will cope with this? There are significant issues with finding GPs for Woodlands Health Service (used by FOG and Paddock Wood residents). The doctors and Pembury hospital are already stretched to breaking point. With around 7,000 new houses in this area together with around another 1,000 in Paddock Wood that already have planning permission we are going to be swamped; our lives ruined and changed forever.

This plan will cause more pain and distress than Planning Officers and Borough Councillors can imagine.

Can't the Council have a serious rethink about the unfairness of this? Can't it explain to Government about the problems this will cause? We don't need this many houses in the borough and current requirements are lower than the ones being used. We are providing houses for London overflow and this will never end. Take a stand now.

I just hope that Councillors can view this as individuals and not feel the need to fall into line.

DLP_3461

Lindy Hall

I live in Five Oak Green (FOG) and have spent the majority of my childhood and adult life in the village.

I object to the land in East Capel included in "The Strategy for Paddock Wood" (Policy STR/PW1 and Policy AL/CA3)

The comments above relating to Policy STR/CA1 apply here. The Council seems to treat Capel as part of Paddock Wood despite boundaries and the separate identity of Capel.

The land highlighted for development is a flood plain. Any attempt to deal with this issue by mitigation and betterment do not take account of global warming/climate change or its use as a flood plain.

All of the land is greenbelt and is grade 2 or 3 agricultural land.

There will be a conurbation from Paddock Wood to Tonbridge and the character of Capel will be lost forever. TWBC talks about "love where we live" and then destroys one small part of the borough. Is there a back-up plan? There should be and I hope the Councillors look at this and imagine their own parish being destroyed in the same way. There should be a much greater sharing of the pain and as I've mentioned there are far better places to put major development where roads already exist!

I'm also aware that brownfield sites have not been included in this plan and the Council should have done more to identify and use them.

Finally, I wonder how the medical services will cope with this? There are significant issues with finding GPs for Woodlands Health Service (used by FOG and Paddock Wood residents). The doctors and Pembury hospital are already stretched to breaking point. With around 7,000 new houses in this area together with around another 1,000 in Paddock Wood that already have planning permission we are going to sink. We know it but TWBC doesn't.

This plan will cause more pain and distress than Planning Officers and Borough Councillors can imagine.

Can't the Council have a serious rethink about the unfairness of this? Can't it explain to Government about the problems this will cause? We don't need this many houses in the borough and current requirements are lower than the ones being used. We are providing houses for London overflow and this will never end. Take a stand now.

DLP_3691

Capel Parish Council

The expansion of Paddock Wood can be achieved without using land at East Capel for housing. Flood storage attenuation/mitigation measures may be useful there, but no housing is required. In fact, providing housing will contravene the NPPF as East Capel is Green Belt and the removal of East Capel from the Green Belt will cause convergence with Five Oak Green, as our comments on the SA suggest. This does not amount to “exceptional circumstances”. This is further described in comments on the Sustainability Appraisal.

DLP_3765

Geoff Croker

Re: Objection to Strategy for Capel Parish (Policy STR/CA1) & (Policy STR/PW1)

I wish to raise my strongest objection and concerns to the Tunbridge Wells Borough Council Draft Plan for a Garden Village (New town) at the CA1 site, Capel East and Paddock Wood sites all of which appear to have manifest as potential white elephants, with CA1 and its inherent complex nature proposed by some twisted logic .The proposed development at CA1 is I believe misplaced in both scale and its location. The combination of these joint proposals would result in some 8000 homes within a small area of 3 miles of the borough. Residents are likely to face higher Council Tax/ rates to fund these proposals, and the council risk facing a very large number of compensation claims.I believe it would be wise to halt this Draft plan promptly to avoid a repeat of the Calverley Park outcome which has apparently wasted £10,000,000.of residents money, the Draft plan sum that could be wasted is likely to be much greater.  

The impact on the small and rural parish of Capel and the detriment to the surrounding AONB which would contradict section 15 of the NPPF with associated quarrying construction and roads will be huge, with creation at source and overspill of pollution in many forms for an unhealthy and unnecessary time period which would likely undermine the Environment Bill 2019-2020 currently being assessed in parliament. This Bill makes provision for “improving” the natural environment regarding Waste and resource efficiency, provision of Air Quality, recall of products that fail environmental standards, makes provision for Water, Nature and Biodiversity and “Conservation Covenants” and regulation of Chemicals and for connected purposes. Such proposed housing numbers will be to the detriment of the Governments carbon aims, why would a responsible council wish to do this? I am informed no Environmental Assessment has been undertaken. Please note I have covered these topics further later in this letter.

Greenbelt

The Draft plan is against section 13 of the NPPF Building on greenbelt, this is only considered under “exceptional circumstances” paragraph 133 and 137 and it does not appear TWBC have examined fully other reasonable options.On the 27.4.2018  Savid Javid stated quote " Housing numbers will not justify building on the greenbelt" and Robert Jenrich Secretary of State for Housing Commerce and Local Government  stated on 26.10.19 quote "Ruled out building on the Greenbelt" !

The proposals would virtually join Tonbridge to Tudeley Five Oak green and Paddock Wood making a none sense of basic planning principles it appears however that this may well be the intention. The Environment Bill will aim to enhance green spaces rather than build on them.

Assessment for Sites

Following the very poor notification and confused consultation process and what may be deemed a possible lack of Due Process being that the vast majority of residents in the parish were totally unaware of the Draft plan. Furthermore it appears a relatively small percentage of parishioners were able to respond despite quotes at public meeting by council heads. It is unacceptable that non internet users appeared ignored and unable to comment. It appears also the majority some 60% of respondents wanted a growth corridor approach and were unaware of the potential greenbelt destruction.

The assessment undertaken was "Not Rigorous" or Robust and really must be so .The planning preparation did not include Tudeley sites CA1 and CA2 until after the issues and options process in 2017 this means the largest housing area in the plan “did not” go through most of the plan preparation process, but was simply included in the second call for sites. It appears many brownfield sites are available within the borough with others not having been identified. The Queens speech in 2015 prioritised the selection of Brownfield sites for housing with councils able to prioritise planning permission for brownfield sites with Local Development Orders why has this not been pursued?

Other buildings and sites are also available, Blantyre House, Goudhurst Parish, Frittenden area, Horsmonden area, Kippings Cross, Land adjacent to Colliers Green Primary School,

Land at Great Bayhall, Land between Cranbrook and Sissinghurst,Langton Green, Wakehurst, land between Sandhurst and Iden Green, and Wakehurst Farm Bennenden.

Garden Village Criteria

The Draft Plan of 2017 has been abandoned, interestingly this stated there was no place for a Garden Village.

It appears that criteria for the garden village is contradicted with regard to the dissection of the CA1 site by an existing railway line which would create 2 separate villages, hinder many operations including access and egress and pose a danger to the proposed school site as well as other basic transport and appears to fail the basic principles of containment and cohesion and will not form a standalone settlement but transpires as a bolt on to Tonbridge

The Garden Village (New Town) at Poundbury would appear a real failure with crime and murder at the top of the problems and I wonder why the council think such a scheme may work in Tudeley ?

Air Quality

The NPPF states guidance for air quality within proposed development sites under paragraph 181 and paragraph 124 should be considered.  Quality of the air would be lowered considerably likely to an unacceptable level in the immediate area this going against government legislation "The Clean Air Act 1993" and the Environmental Bill and policy and EU Regulation, permits being required under the directives.

The proposed Draft plan assumes electric car usage together with electric bicycles which would appear to be a somewhat naive expectation particularly with the vast majority of such a large development likely to be occupied by commuters with thousands of visitors to such a development using traditional petrol and diesel vehicles.

Such a large scale proposed development would also appear to contravene government thinking with regard to greenhouse gases which have to be proven to be within acceptable limits. A recent Appeal Court ruling creating a president in 2019. Statutory Environmental Impact Assessments would also be likely to fail under the circumstances. It would be very sad and improper if financial contributions were to be put forward to mitigate pollution.

Flooding

The Draft plan proposals for CA1 Tudeley village (New town) goes against The NPPF section 14 which is a grave concern indeed. Tudeley, Capel East, and Paddock Wood are all subject to regular flooding De Facto, historic flooding is documented from the 1700s to the present day with major incidents in 1960, 1963, 1968, 1999, 2000 ,2009, 2013-14 ,2018. In fact the valley proposed for these housing developments has the highest risk of flooding in the UK.

The CAI Tudeley village (New Town) site is dissected by a railway line which hinders water flow from south to the north. Much of the site is a functional floodplain level 3 with any further building on the land increasing flood risks both locally and to communities further east down river of the River Medway.

Other sites are available within the borough of Tunbridge Wells which are not within a floodplain.

The NPPF stipulates the Sequential test and the Exception test with regard to flooding, the proposed Draft plan does not satisfy either of these tests. It was with dismay that I was informed by the head of planning at Tunbridge Wells Borough Council that a flood risk assessment had not been undertaken for the CA1 site Tudeley Garden Village (New town) a site which could be up to 50% flooded with predicted climate change from the Environment Agency. The land sites proposed at Capel East and Paddock Wood also at high risk. It would appear development on the site particularly CA1 would be negligent and could result in loss of life. Any raising of land parcels or bunding cannot be accurately modelled and could have catastrophic consequences In fact in 2000 The United Nations Economic Commission for Europe stated “human interference with natural processes has increased the threat of flooding and should where possible be reversed and in future prevented”. Similar sites at risk from flooding have been rejected at Yatton, Kings Lynn, and South Stanley.

It is important to remember quote Kent County Council select committee in 2007 stated (that significant floods can happen at any time with enough severity to overrun flood defences major incidents such as the 1953 flood devastation, or worse can happen in any season). The simple logic is if you build on or near to flood plains you will be flooded at some time and risk loss of life.

Local Housing Need

Housing numbers and local housing need has not been adequately or rigorously assessed which is a basic and logical requirement. I agree there is a need for some local housing however this should be evenly and fairly distributed throughout the borough.

The local requirement for Capel may actually be some 25 new homes, these being added to those already for sale at the current time, those under construction, and those pending planning permission.

The Draft proposed plan would likely create a large dormitory town highly inappropriate for the area. Investigation has revealed previous housing developments in neighbouring boroughs have been advertised by London Estate agents with incentives for commuters to purchase, interestingly many of these homes remain unsold.

The Draft plan bases its housing numbers requirements on 2014 data rather than 2016 data, this is appears illogical furthermore it has come to light that it was not necessary for TWBC to adopt the 2014 numbers. Housing requirement numbers have in fact dropped according to ONS figures which would mean 4000 less homes are required within Tunbridge Wells therefore I would ask that TWBC please use the argument of exceptional circumstances to prevent the proposed development at Tudeley Garden Village.

This allows other land parcels within the TWBC options document to qualify as being suitable for development, some with adequate existing infrastructure and others with existing buildings, and some sites very close to the newly duelled A21.

The Impact Upon Tonbridge

The location of the proposed Draft plan would undoubtedly place both unwanted and unnecessary strain upon Tonbridge infrastructure. Tonbridge already being it is quoted as at capacity with roads full to capacity, car parks over spilling and no spaces for existing commuters at Tonbridge station, the air quality levels at Tonbridge are currently likely to be unfavourable ,this without the thousands of extra cars and added buses that would be associated with the proposed Draft Plan.

It appears the Draft plan has not been assessed rigorously, Tom Tugendhat MP for Tonbridge has indicated the Soundness of the Draft Plan may be in question!

Water Supply

The impact upon the local water supply is I believe of great concern with strains already on drinking water and shortages, added to this is the real danger of the proposed quarries, and the draft plan development interfering and polluting the natural aquifers and bore holes and wells in Hartlake Road existing in the site at CA1 Tudeley Garden Village (New Town).

Very careful consideration is necessary here, some of the water here being distributed I believe to other parishes within the borough, and it seems a risk too far to jeopardise contaminating public drinking water.

I am critically concerned following reports that leachate from landfill at Stone Castle Farm Quarry may have contaminated lakes and possibly the River Medway due to inept thought planning and management, how can residents and the council safely trust and adequately monitor further quarry excavation. If water consumption increases due to these proposed developments water will be dragged up from the wells which are likely to allow contaminated water to enter into the system.

Loss of Valuable Arable Land

To the south of the draft plan for CA1 the land is grade 1 arable, just north over Tudeley Lane and Crockhurst Street fields surrounding the all Saints Church there are crops growing the same crops. Further north on the proposed CA1 site Tudeley Garden Village (New Town) high-quality blackberries are grown this land being rated grade 2 and 3 arable, productive orchards are also present which are I believe protected.

Such high quality land is surely critical to our food supply, and particularly in view of our possibly leaving the EU, this together with environmental pressures and future legislation on flight volumes to import food provides and obvious case for this land to be kept desirable. To cover such land with houses driveways and roads would in fact mean the loss of this food production forever.  CA1 site alone will deprive the nation of 6,174 tonnes of produce over 5 years.

Biodiversity

The Draft plan appears to go against the NPPF paragraphs 174, 175, and 177 and will likely go against the Environment Bill 2019-2020. No Biodiversity assessment has been undertaken.

The loss of wildlife habitat including endangered and protected species (there are 3 EU protected species in the area, Bats, Great Crested Newts and Dormice note Dormice were noted as in danger on the BBC South East News 13.11.2019 due to loss of habitat and climate change)  shows the Draft plan to be inappropriate in both scale and location

Residents of and visitors to the parish currently enjoy open green spaces with numerous footpaths and bridleways across the areas of the proposed site at CA1 Tudeley Garden Village (New Town) and throughout Capel East. An area of concern is the huge increase in domestic animals with such an inappropriate scale of development particularly cats and dogs, (25% of the population own a cat and 25% of the population own a dog source PDSA) dogs and cats would likely have a devastating impact upon wildlife and flora an aspect not considered within the Draft plan.

The light, noise, chemical, and traffic pollution that would emanate from such an incongruous conurbation would change the whole area of Capel forever.

This area is rare in so much as it has a very healthy population of Ash trees which the government have spent £6M on Ash dieback research for the UK. Many Veteran Oak trees also exist on or adjacent to the proposed sites including Ancient Woodlands

Development on such an inappropriate scale in such a naturally long standing ancient landscape can only have a damaging effect. One example is the litter problem that sadly now exists along Tudeley lane and the B2017 since the advent of fast food and drinks outlets at the Tonbridge industrial site.

Albert Einstein stated

"The Natural Balance of Nature is Harmony !

Infrastructure

The drainage facilities at the CA1 Tudeley Garden Village (new town) development are non-existent with very limited drainage infrastructure at Capel and Paddock Wood, the latter suffering from a long history of sewage problems. Our own very efficient and competent MP Greg Clarke has made a speech in the House of Commons in the last few weeks requesting that no further housing developments be undertaken in this regard “without infrastructure in place first”.

The building of new road infrastructure requires agreement with Kent county council and the timing of this is unlikely to dovetail with any of the proposed house building.

Economic theory points to New Roads attracting traffic and usually higher volumes than existed. The parish of Capel is inherently a quiet parish any new road infrastructure should aim to remove traffic from Hartlake Road, Tudeley Lane and Crockhurst Street the B2017 Road that runs through Five Oak Green to Paddock Wood and to Tonbridge, to ensure this area is pollution free.  EU Regulation is strict on this matter and coupled with the Environment Bill will prove a significantly difficult hurdle. No Transport Assessment has been undertaken.

The hospital at Pembury (Tunbridge Wells Hospital) is already at capacity with bed shortages, and doctors surgeries are closing unable to cope with current demand. The situation of shortage of doctors and nurses is not predicted to improve, the proposed Draft Plan will put a potentially crippling burden on our local health infrastructure.   

Geology

The geology of the site would appear to make it an illogical choice with a heavy clay susceptible to expansion when wet and shrinkage when dry increasing risk of subsidence in turn leading to a high build cost. Any deep foundations for retaining structures could damage the sensitive mud and sandstones which lie over and control the natural aquifer. Puncturing of these mudstones and sandstones could have a very serious consequences to groundwater equilibrium. Building to allow water to pass under foundations would only lead to movement of the structure.

Heritage.

The proposed site at CA1 includes two Grade 1 Listed Churches All Saints at Tudeley and the medieval church at Capel and Hadlow Tower will all be screened from view together with other listed buildings. To construct homes and roads around these heritage sites would appear to be legalised vandalism if allowed. Visitors from many countries come to see these famous sites. I understand no Heritage Assessment has been undertaken.

Impact Upon Residents and Health Issues.

The strategy is to master plan this proposal over a 30 year period this would create the use of lorries passing to and from these proposed sites all adding to traffic danger, noise, and air pollution. This all within a small area with existing schools. The EU Commission Science for Environment policy confirmed the loss of healthy life due to UK noise exposure alone to be1.34 billion euros.

The use of concrete incorporates heat generation into the atmosphere by the chemical process of hydration. Chemicals are then released into the soil from the concrete over years such as alkaline, other chemicals would have to be added to the concrete to prevent sulphate attack as the area is and has been for ever farmland this then seeps into the waterways tributaries, many of which are under ground, contaminating tree roots,( note the Building Research Establishment prepared a document on this subject), and potentially polluting the aquifer before passing into the River Medway.

The current natural open space the residents enjoy together with the footpaths Bridleways and wildlife will disappear and the area slowly degenerate. An example is Poundbury where it is evident garden village new towns do not work in a modern society it seems they work only for utopian theoreticians.

Sustainability & Viability.

The following points would appear to seriously call into question the sustainability of this proposed Draft Plan:

Pollution from the proposed Draft plan including Tudeley Garden Village (New Town) and Capel East is unlikely to satisfy current regulation and The Environment Bill.

Flooding in the site at CA1 and Paddock Wood is De facto and is predicted to significantly increase with the Environment Agency prediction of climate change.

The Geology of the site with clay cap and mudstone and sandstone below will lead to high building costs and very probable foundation movement due to the clay type which is prone to changes in volume with changes in moisture content. Potential purchasers may well find these proposed homes difficult or very expensive to insure. The financial Viability of the scheme would have to be scrutinized and be open to “public view” and assessment. Build costs in difficult sites with heavy clay soils on sloping ground with underground streams and watercourses are notorious for crippling overspend.

Infrastructure is not in place and timing and phasing is unlikely to dovetail with housing development. Our Hospital, Doctors Surgeries, Drainage and Roads are already at capacity. There is no guarantee such infrastructure will have funding and less likely to be built or be sanctioned at the appropriate time.

The impact upon Tonbridge town is very significant and the consequences extreme causing an unnecessary over burden and raises questions as to sustainability of the Draft plan and its Robustness under paragraph 35a of the NPPF.

The placing of 60% of the unnecessary housing numbers in one small Parish is wrong.

Surely the most important endeavour to consider here is to strive for morality in our actions our inner balance and our very existence and values depend on it, only morality in our actions can give beauty sense and dignity to peoples’ lives. I sincerely hope TWBC will think again in view of the very real and irreversible harm and destruction they  may endorse leaving a wound in this gift of countryside that is Capel and at best a scar for future generations .

DLP_3767

Martin Robeson Planning Practice for Tesco Stores Ltd

Policy STR/PW1 – Strategy for Paddock Wood (support with conditions)

Tesco broadly supports the strategic approach to Paddock Wood, noting the intention to regenerate the town centre and the suggestion that ‘one medium sized’ food store shall be delivered by the end of the Plan period. It is agreed that this would be appropriate given the substantial planned growth in population here, secure more stainable behaviour and provide qualitative benefits (ie, choice and competition).

DLP_3780

Sharon Hunt

Re: Objection to Strategy for Capel Parish (Policy STR/CA1) & (Policy STR/PW1)

Please add my contact details to your consultation database so that I can be kept informed of all future consultations on planning policy documents.  I understand that my comments will be published by the Borough Council, including on its website

I am writing to you to raise my strong objections to Tunbridge Wells Borough Council’s recently published Local Plan proposal to build over 4000 homes in the Parish of Capel in both the areas of Tudeley and East Capel.  I live in the village of Tudeley and work at Tunbridge Wells Hospital.

I would like to make clear that the complicated convoluted way that you have requested objections from the general public leads me to believe this is a deliberate ploy to make it as difficult and confounding as possible for the general public to object.  The arrogance of a council to assume that everyone uses the internet astounds me.  This process should be easy for internet and non-internet users and for the Chief Planner to say to a room of 300 people during a SaveCapel meeting to ‘please go online to register your objections or we will have to read the letters and that your objections may not be put in the right place’, is appalling if you are in any way unsure where an objection should go then put it in more than one place.

Healthcare

Tunbridge Wells Hospital is already too small for the area that it serves.  Since opening in 2011/2012 the hospital has already had to add three new wards.  The hospital is struggling now to see people who have been referred on time so that they do not breach government set targets patients are waiting months for appointments, this is risk to life.  The hospital does not have enough staff let alone enough beds and even if they did have enough beds there would be no staff to look after the patients.  Already during the winter many elective surgeries are cancelled this will only become a bigger problem with 4,000 more homes.  GP surgeries are closing throughout the borough and some are combining and my own surgery is struggling to employ GPs and exists on a trail of locums, a garden village is supposed to have everything it needs within its boundaries if we can’t get GPs for already existing surgeries in this area how can a whole new surgery be fully staffed – again ill thought out plans.

Agriculture

Capel is a rural Parish that sits within the green belt and the High Weald AONB, there are currently approx 900 homes in the Parish. CA1 and East Capel are mainly agricultural land, including orchards which I believe are protected, mostly grade 2 and 3 agricultural fields (which are in short supply in Tunbridge Wells borough as a whole) and not poor agricultural land as has been claimed by Tunbridge Wells Borough Council, many of these orchards and fields growing much food for this country for multi-national companies such as Ribena who buy substantial amounts of blackcurrants from Sherenden Farm.  CA1 if built on will deprive the nation of some 6,175 tonnes of produce over 5 years.  We should be aiming to be a self-sufficient borough and country not cover good agricultural land with concrete.

Geology

The geology of the site (CA1) would appear to make it an illogical choice it comprises heavy clay susceptible to expansion when wet and shrinkage when dry increasing the risk of subsidence, in turn this would lead to high build costs. Any deep foundations for retaining structures could damage the sensitive mud and sandstones which lie over and control the natural aquafer. Puncturing of these mudstones and sandstones may have very serious consequences to groundwater equilibrium. Building to allow water to pass under foundations would only lead to movement of the structure.

Biodiversity

An agreement was signed and reached with 190 countries including the UK to halt the loss of biodiversity by 2020 (DEFRA) and to ultimately increase biodiversity, this development clearly goes against DEFRAs agreement as there can only be a loss of biodiversity if this huge development is built, despite claims that there will be a net biodiversity gain, I fail to see how this is possible when woodlands, fields, agricultural land and streams will clearly be greatly affected by this development not to mention birdlife, mammals, reptiles, insects, fish and other organisms all important to the protection of our village, town, borough, country and world as a whole.

Diverse wildlife including many red list species, yellowhammers, skylarks, lapwings, house sparrows, swifts and EU protected species such as Great Crested Newts, Dormice and bats (many species of bats). A news item on BBC Southeast News on 13 November stated that dormice are now in danger because of loss of habitat and climate change in the south east, we should be striving to protect our species not deprive them of valuable habitat.

The government has spent some £6 million on research into Ash dieback, there are many ancient, veteran and mature healthy Ash trees in both CA1 and East Capel.  There are also some 30 veteran Oaks and a huge number of mature and newly growing Oaks and Ash trees along with ancient woodland which will suffer if this development goes ahead as the ecosystem will not remain as it should as mammals, bird, reptiles, insects etc etc will leave these ancient woodlands and the woodland will suffer from this loss. The balance of nature is fine and we constantly distress and destroy it

Domestic Animals and their Impact on Wildlife / Wildflowers / Ancient footpaths

A development of this size 4,000 homes (both CA1 and East Capel) would also introduce a significant number of household pets, particularly dogs and cats.  25% of the UK population own a cat and equally 25% own a dog.  This will introduce at least 1,000 cats and 1,000 dogs (best case scenario as many people own more than one dog or cat) - (PDSA.org).  This will have a significant effect on wildlife, cats enjoy hunting even when well fed, they will travel several miles from their home to hunt, they will also just maim and not kill leaving prey in agony and potentially young without adults to care for young birds, mammals, reptiles etc.  Dogs will also affect ground nesting birds if off lead, this will lead to ground nesting birds leaving their broods and chicks being lost.  If dog faeces are not cleared up this will have a detrimental effect on wildflowers and will increase the growth of nettles and thistles to the detriment of rare flowers such as the orchid and true fox sedges etc. (SWT.org)  1000 dogs being walked twice a day on ancient footpaths will have a severe effect on these old walkways.  These footpaths are part of the openness of the greenbelt and the open views will be lost to concrete.

Heritage

Capel has a unique culture and heritage.  There are two Grade 1 listed churches All Saints and St Thomas a Becket, All Saints being famous worldwide for being the only church in the world with windows all created by Marc Chagall who so loved the location and light of this church that he chose to design all of these windows after being asked to do one memorial window for the Goldsmid family, how sad he would be at this legalised vandalism of our greenbelt. The proposal to build such a huge number of homes would have a significant impact on the churches, the rural landscape, environment, community and wildlife, changing the Parish beyond all recognition and in effect wiping out two small and happy communities.  Tudeley which currently has around 96 homes would effectively no longer exist as a historical village, by building 2,800 homes, this would also cause the loss of the all important green belt buffer from Tonbridge, which would result in urban sprawl development from Tonbridge to Paddock Wood.

Flooding and Water Supply

The suggestion of so many homes in this location is not sustainable as there is no infrastructure and will lead to a greater risk of flooding both locally and further along the River Medway floodplain, putting at risk other built up towns and villages and villages that already have a flood problem such as Yalding and East Peckham to name just two, this is clearly a danger to life. There is already a problem with supplying water for homes in this area with 4000 new homes this will be an impossibility.  In 2013 CA1, East Capel, Tonbridge and surrounding villages flooded badly, again please think about the danger to life.

Transport

The trains from Tonbridge and Paddock Wood are already at capacity, you are lucky to get on the train let alone get a seat, the service would not be able to cope with the additional commuters, and they will be commuting as there are not enough jobs in this area to sustain the huge number of people expected to live in these developments and the council would be naïve to think this is not the case. Already the homes in Paddock Wood are being marketed in London with season tickets paid for by developers as the incentive for moving to Paddock Wood from London.  Homes for local people well clearly not.  The train company have already advised that they are not able to put on any more services or extra tracks and no further station will be built.  This train line is a two track rail line to London and the coast and this cannot be changed as there is at least one two track tunnel to London. Most commuters will drive to Tonbridge or Paddock Wood stations to get to London the car parks are already full, of course some people will cycle but not everyone and anyway with everyone cycles where will they park their bikes the station is already full of push bikes.

Housing Needs

Increased housing should be developed in proportion to existing population numbers across the borough.  There are brownfield sites and other sites which already have infrastructure in place, there are over 100 brownfield sites that are known to the council, there must be many many more. There were 450 sites offered in the call for sites, 20 homes on each site would fulfil the government’s 2014 methodology requirements for housing in Tunbridge Wells, some of this number having already been built.  However, Tunbridge Wells Borough Council should be working with the 2016 methodology as the 2014 methodology was found to be incorrect due to NOS as advised by the government, if the council worked with the 2016 methodology as required and instructed by the government it would need to build 4,000 less homes than this local plan has decreed need to be built, thereby negating the need for these two new towns in Tudeley and East Capel. Much of the land proposed in Capel for development has a single landowner and the simplicity in developing that land should not come before the significant detrimental impact it would have both on greenbelt and also the impact the development would have on the High Weald AONB which borders the proposed site.

Impact on Neighbouring Borough – Tonbridge and Malling

Part of the site of the proposed development sits at the very edge of the Borough next to the border with Tonbridge and Malling. Any increase in population within Capel would result in a significant demand upon the neighbouring Borough without the plan or infrastructure to cope and without the benefit of the added council tax. This development would have little or no impact on Tunbridge Wells town itself but all the monetary gain. Tonbridge and Mallng Council have questioned the Soundness of Tunbridge Wells Borough Council’s local plan.

Government’s Garden Village Criteria

Under the Government proposals for garden Villages and settlements they recommend that they are not built where there are existing settlements but should be new and discrete, the government also advise that brownfield sites should be built on before greenbelt. There is nothing discrete about the proposed plans which would be situated in the existing settlements and as previously stated effectively wiping out the village of Tudeley. The Government also advise that garden villages and settlements should have local support, I would suggest that this is clearly not the case in the Capel proposal. In addition, it is likely that the existing railway line would dissect the proposed site at Tudeley which does not support garden settlement principles but actually creates two villages (towns). The proposal for the new school site is also not part of the garden village ethos as it will sit about a mile away along a busy road, this would also lead to more traffic on an already congested road and a railway line dissecting the school site, surely this is not a safe option, I would suggest it is a health and safety nightmare and again a danger to life.

Road Network, Pollution and Climate Change

The roads are already severely congested so presumably another road would have to be built which would cross greenbelt and AONB, this is just unacceptable and may move transport though the development area more quickly but will just end up polluting and congesting Five Oak Green, Capel, Tudeley, Tonbridge and surrounding towns and villages to an even greater extent than they are congested now.  The pollution caused by all this additional traffic in a greenbelt area will just add to the problems of climate change and building on greenbelt where many trees, ancient and veteran (the lungs of the world) exist will be devastating for our clean air.  There would be significant light pollution from these two developments CA1 would have a considerable impact on the AONB as currently this area enjoys dark skies and clearly this would be lost as 2,800 homes on CA1 will produce considerable light pollution and likewise in East Capel.

Costs

The Council have already wasted £10 million of Tunbridge Wells’ taxpayers hard earned money on a vanity project in Calverley Park which has now been voted out and abandoned.  How much has been wasted thus far on this ill thought out local plan for a new town, another vanity project using the wrong methodology in assessing numbers required, use the right methodology (2016 not 2014), this would be the professional and correct way forward.  The council and employees, planners, etc are paid by local taxpayers and as such should be representing the needs of the constituents of this borough, clearly they are not representing us at all just trying to make a ‘name’ for themselves with another badly thought out ‘vanity project’.

General Comments

This proposal it is ill thought out and unsustainable and is detrimental to both local residents’ health, physical and mental. I believe this is a lazy plan and has only been proposed so that the council do not have to deal with multiple landowners and just have to deal with one in Tudeley, (this site was not on the first call for sites and as such not planned for as rigorously as should be) and two in East Capel, this should not be a reason for this development. This is not a special circumstance !  The council have also not advised what their ‘very special circumstance’ is for building on greenbelt, as there should be a special circumstance as required by the NPPF, and I have to ask why not !

The plan preparation process did not include Tudeley (CA1 and CA2) until after the issues and options process in 2017.  This means that the largest housing area in the plan did not go through most of the plan preparation process.  There is no greenbelt study, no landscape assessment, no biodiversity assessment, the Local Plan isn’t complete enough to be ready for public consultation when these two areas (the biggest development in the borough) have not had the same level of assessment as the rest of the plan. The issues and options process led to most people – some 60% - wanting growth corridor led approach, less than half wanted a garden settlement and that was when they did not know a garden settlement would involve the destruction of many acres of precious greenbelt and have a significant impact on the AONB.  Protection of greenbelt was a key priority for people who participated in the issue and options consultation the plan should be re-written to implement a growth corridor led approach to protect green belt and I stress again that the correct methodology should be used 2016 as instructed by the government!

DO THE RIGHT THING – PROTECT OUR GREENBELT – PROTECT OUR CLEAN AIR – PROTECT OUR DARK SKIES – PROTECT OUR WILDLIFE – PROTECT OUR WILD FLOWERS - PROTECT OUR ANCIENT TREES – PROTECT OUR FOOD PRODUCTION - PROTECT OUR HISTORIC VILLAGES - PROTECT OUR FUTURE

DLP_3930

Ide Planning for Paddock Wood Town Council

OBJECT

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Detailed comment on the SFRA is supplied under separate cover.

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

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

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

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

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

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

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

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

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

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

In addition –

Policy STR/PW1: 1 – this explains a proportion of the 4000 dwelling allocation is to be provided within Paddock Wood. Reference is also made to Mascalls Court Farm, Mascalls Farm and Church Farm; it would be helpful in an appendix to set out expected housing numbers by site so clarifying how the overall figure is derived.

3 – this should state outdoor sports hub.

4 – TWBC is planning to put the bulk of housing in the next plan period in the areas of highest/most complex flood risk, as outlined in its 2017 document, Flood Risk to Communities in Tunbridge Wells. This will make building the houses expensive and reduce the likelihood of money being available for other infrastructure requirements in Paddock Wood.

6 – what are the sites and windfall developments?

Policy STR/PW1, Master planning & delivery 2 – there is one brief mention of the need to deliver infrastructure related to foul and surface water – this needs to be stronger in the Plan

Policy STR/PW1, Flooding – it is essential that consideration is given to the impact of one new development on existing town and all other proposed developments

Policy STR/PW1, Transport 3 – essential to have a road from east PW to the north, and a westwards link via Eastlands.

Policy STR/PW1, Landscape 2 – the additional houses proposed on Mascalls Farm may be on the slope – needs to be avoided to avoid affecting view and to prevent surface water flooding to houses on flat area

Policy STR/PW1, Infrastructure d – should read outdoor sports hub

DLP_4023

Caroline Steadman

I never know what to write, so please note that I am very concerned about the current waste water situation in Paddock Wood, which will only get worse with every new house or redevelopment.  Southern Water need to get involved and actually DO something about preparing for ANY and ALL building work, including the current ones taking place.

Flooding is also a major concern; there is already a huge pond on the Mascalls Grange site (where the school is due to go), so what the Church Farm site will be like is the stuff of nightmares for those living closest.

Roads also a concern. When will councils realise that just because they want people to walk and cycle doesn't mean the people either want to or will?  And not building enough garages or allowing parking facilities will again exacerbate the problem.

DLP_4038

Mr I and Mrs E Turvey

We feel that we must join with everyone that has already written regarding the proposed developments for Tudeley, Capel and Paddock Wood.

The planners need to take heed from what is being said by the local residents. The area around Tudeley that is proposed to become a garden village is on a floodplain, as is Capel and Paddock Wood. The environment agency seem to make light of the situation however the impact to the area with the amount of houses that are proposed will put an even greater pressure on the local infrastructure. Parts of Tonbridge flood on a fairly regular basis and Paddock Wood is already having sewerage problems with the new houses being built. Given the problems that are now happening up North with flooding, and the local amber warning that's in place here for Thursday 14th November, there is a real need to consider the implications putting so many houses in an already at risk area.

The whole infrastructure needs to be readdressed before new houses are even decided upon. The Leigh barrier needs to be upgraded and there is an awful lot of groundwork to be considered. You do not build houses and then decide how to deal with flooding issues.

This leads onto the next point, the existing roads cannot cope and we basically here at Five Oak Green live in a triangle that is supplied by B-roads. There is already a vast amount of traffic that uses Colts Hill and the B2017. There have already been several serious accidents on the new Pembury Bypass. Heavy lorries are using substandard roads. The Transfesa site was only allowed back in the 70's by the Secretary of State on the understanding that, most of the haulage would be transported by the rail link at Paddock Wood. It appears however that most is transported by road. The road at Colts Hill can just about allow the passing of two heavy goods vehicles and as for reintroducing the idea to put in a Bypass, that was on the agenda over 40 years ago and the money that has been spent to date would have helped to achieve that at the time. There is a lot of short sightedness by those in charge and the bureaucracy deciding the fate of the 'little person'.

The whole idea of these planning proposals are going to completely spoil this area of our green and pleasant land, the Garden of England. With all the different proposals around the country, Ebbsfleet, Lenham and Ashford etc. We are now drowning under the strain and are just becoming one large expanse of concrete / car park (for the Eurotunnel transport). Once done, this land can never be brought back to agricultural or green belt. Please think very hard.

With these arguments, we hope there will be consideration on the part of the Council to at least address the current problems i.e. flooding and roads before you embark on further houses which at best will still not be available to the younger generation as on average new houses on the market in this area have a starting price of £300-345,000, still beyond the reach of first time buyers.

We will close now and look forward to hearing the decisions that will be made. Also apologies for actually having written this letter because as stated at the meeting in Somerhill School, someone will have to sit and read this!

DLP_4085

Julian Morgan

I also object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

Same reasons as above [TWBC: See comment DLP_4084 within the Capel Section]

DLP_4101

Jackie Edwards

I am a resident of Golden Green, and use the surrounding countryside for dog walking and cycling.  I am very concerned about the proposed Capel development plans.  I would be grateful if you could add my contact details to your consultation database as I would like to keep up to date with all future consultations on planning policy.  I am happy for you to publish my comments.

I moved to Golden Green  8 years ago and one of the main reasons we chose this location was because it is so beautiful and rural, and the characteristics of the countryside are such that you can live near to a large town (i.e. Tonbridge) but be in the middle of the Green Belt, and also be part of a small rural community.  The creation of a new Garden Town at Tudeley by building 2,800 new houses will absolutely devastate the countryside that we have moved here to enjoy.  It will also cause harm to the residents of the Parish of Capel and to the residents of Tonbridge as a whole.  The increase in traffic on the small B roads and country lanes in the area will only make the existing traffic congestion worse.  Every morning the roads into Tonbridge are blocked by traffic.  The scale of the new town will lead to gridlock on the local roads, which are not able to cope already.

There is also a proposed new school, the site of which does not seem to have been  considered very carefully.  The railway line runs through the middle of the school, and it is surrounded by busy roads, meaning that schoolchildren are having to cross a railway line or major traffic routes in order to get to, and move around, the new school.  Inhabitants  of the new town will most likely use Tonbridge station as it is the nearest station for commuting to London.  The commuter trains to London are already heavily congested and traffic and parking at the station will also be an issue.  Apparently Network Rail have confirmed that there will not be a new station at Tudeley which means that any commuters will use Tonbridge, which is already at capacity.  The increased traffic will cause more accidents, more pollution, and kill more wildlife than ever before.  The lack of infrastructure will cause problems throughout Tonbridge, and the costs of the new residents will have to be borne by Tonbridge and Malling, whilst Tunbridge Wells receives the Council Tax.  The new residents will want local doctors, dentists, schools, shops, leisure facilities…and these will be supplied by Tonbridge without receiving the benefits.

Aside from the financial problems, the site is located next to an area of outstanding natural beauty.  It is Green Belt land, which should not be allocated for building projects.  The site is on the Medway flood plain and does not really take into account the impact of climate change and how the new development will cause increased flood risk in Tudeley, Golden Green, East Peckham, Tonbridge and Yalding.  These areas have all suffered flooding in the past.

The development will ruin habitats, create light and noise pollution, and create a huge visual scar on our beautiful landscape.  Other brownfield sites are available for development and I would suggest these are looked at before we destroy our countryside.

I wholeheartedly object to the inclusion of land in Capel in the “Strategy for Paddock Wood” also.  This is Green Belt land and needs exceptional circumstances to be built on.

I know many of my friends and neighbours are also very concerned about this plan and the potential development.  It should be abandoned.

DLP_4118

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

Please see the response to AL/CA3/PW1 submitted by CPRE Kent’s Head Office [see DLP_1778].

CPRE does, however, recognise that unlike Tudeley, Paddock Wood has the benefit of a railway station and a number of existing facilities and services, which makes it a somewhat more sustainable location.

If the Strategy for Paddock Wood goes ahead, it will be important to ensure that sufficient additional public parking in the Town Centre and/or sufficient new and frequent public transport from surrounding villages is provided so as to ensure that the residents of the surrounding villages and rural area, who have traditionally used Paddock Wood as their local service centre, are still able to access the town centre and are not forced out by cars from the outlying parts of the new developments.  Contributions should also be secured from the development at Paddock Wood for traffic calming in Brenchley and Matfield, to mitigate the damaging effect on quality of life in those villages that the additional traffic generated by the additional 4,000 dwellings at Paddock Wood will have.  The effect of the additional traffic on the surrounding historic rural lanes needs also to be considered and measures to prevent damage to these lanes put in place.

DLP_4369

British Horse Society

Support with conditions

The new sporting hub  and the formal and informal open spaces should include facilities for horseriding.  So should the proposal to increase walking and cycling routes.  This is particularly important as a large number of horses are stabled in the area around Paddock Wood and the lack of public bridleways in the area means that they are mostly ridden on the increasingly busy rural lanes around the town.  The opportunity should be taken to link up the few, short, existing public bridleways in the area and to provide some safe local off-road circuits for horseriding. 

The Council should use its compulsory powers under Section 26 of the Highways Act 1980 to create a public bridleway along the old Hop Pickers railway line to link Paddock Wood to the public bridleways at Bedgebury Forest, so that people can ride to Bedgebury forest instead of having to drive there with a horsebox.

DLP_4479

Paddock Wood Neighbourhood Plan Steering Group

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

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

The absence of detail concerning flood storage, alleviation and mitigation measures raises fundamental doubts about the viability and deliverability of the strategy proposed for Paddock Wood/east Capel

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

In addition –

Policy STR/PW1:

this should state outdoor sports hub, as the NP proposes development of Putlands to include indoor sports and a swimming pool. IN 4.41 Table it identifies a swimming pool in the Paddock Wood/Capel area, but this is not reflected in the policies specific to Paddock Wood.  Under Paddock Wood Overview it explicitly states there is no swimming pool – this has been the number one facility requested by PW residents for many years past, which we have included in the Neighbourhood Plan and we would like to see it identified explicitly in the Local Plan.

A 2-4-6 athletics training track is also located on the Putlands Field.  The Neighbourhood Plan group supports the development of this to 6 lanes all round to enable athletic competitions to be held.

TWBC is planning to put the bulk of housing in the next plan period in the areas of highest/most complex flood risk, as outlined in its 2017 document, Flood Risk to Communities in Tunbridge Wells.  This will make building the houses expensive and reduce the likelihood of money being available for other infrastructure requirements in Paddock Wood.

Policy STR/PW1, Master planning & delivery

there is only one brief mention of the need to deliver infrastructure related to foul and surface water – this needs to be stronger in the plan

Policy STR/PW1, Flooding – it is essential that consideration is given to the impact of one new development on existing town and all other proposed developments

Policy STR/PW1, Transport - The roads are already congested in the mornings particularly the main Maidstone Road through Paddock Wood, adding an additional 4000 homes would significantly increase traffic through the town, even if some developments are accessed from the A228.  The additional houses to the east would be served by narrow country roads, encouraging traffic through the town and over the single bridge over the railway to go north.

There are plans to bypass Five Oak Green/Colts Hill, whilst there is no mention of a road to relieve the centre of Paddock Wood.  It cannot be expected to add 4000 houses to a B road through the town.

This volume of housing would need a new road from the east of the town to the north to prevent congestion in the centre of town.  Maidstone Road which is the spine and through road of the current town is a B road, rendered in places single way by parked cars.

There should also be a road from the East of the town south of the railway to the North of the railway line emerging close to or through Transvesa to connect with the northern portion of the Maidstone Road.  The bridle way leading from Maidstone Road at Eastlands should be upgraded and extended to connect with the A228 North of the Badsell roundabout

The railway is already at capacity & with additional houses being built downline at Headcorn, Staplehurst & Marden, there will be further overcrowding and travel difficulties – doubling the size of the town will make it impossible to get on to a train during traditional commuting hours.

With the planned expansion of Paddock Wood the provision of additional public car parking is essential.  The NP group supports the idea of double storey car park at the Station and that  the railway station area should be made into a transport hub. The Group supports the idea of an additional large car park north of  the railway bridge to prevent people coming to the town centre just to park.

Policy STR/PW1, Infrastructure

  • d – should read outdoor sports hub as the NP proposes development of Putlands to include indoor sports and a swimming pool.  IN 4.41 Table it identifies a swimming pool in the Paddock Wood/Capel area, but this is not reflected in the policies specific to Paddock Wood.  Under Paddock Wood Overview it explicitly states there is no swimming pool – this has been the number one facility requested by PW residents for many years past, which we have included in the Neighbourhood Plan and we would like to see it identified explicitly in the Local Plan.

A 2-4-6 athletics training track is also located on the Putlands Field.  The Neighbourhood Plan group supports the development of this to 6 lanes all round to enable athletic competitions to be held.

DLP_4492

George Andrews

I object to the proposed Plan as it will be detrimental to Tonbridge in that it will increase vehicular traffic in and through the Town and that it will have an adverse effect upon the rail and other facilities . The proposals have not been thought through and the effects of them should not be foisted upon Tonbridge .

DLP_4518

Mr D, Mrs M and Mr S Allen

We would like to express our views over the proposed building plans for the area of Capel, Tudeley & Paddock wood.

We feel, that the sheer scale of the negative impact on everyone's quality of life will be catastrophic, is incomprehensible, and has not been considered carefully enough to take the full impact of the various developments into account

Surely, if there are changes to be made that are to impact so many lives, they should be in a forward direction, so that everyone concerned can benefit from them in a positive manner, so as to enhance quality of life, not to make things more difficult and miserable, isn't that a backwards step?

We are all residents of East Peckham for over 50 years, so it is fairly safe to say that this is our home and we do know what life is like here.

The proposed Two Thousand homes in Capel plus thousands more in & around Paddock Wood in reality is potentially around Twenty Thousand more people on our doorstep, maybe more & as some families start and others grow, that could easily double inside Five years pushing the realistic figures towards Fifty thousand or more people!!!

We find this incomprehensible that the current infrastructure is expected to accept the demands this will undoubtedly bring.

In reality, the current Hospital situation clearly cannot cope with demand as it is, when you are told it is around 9 months just to see the Consultant, without getting any treatment, it is quite sole destroying.

When we are taken ill, we would all like to be treated as quickly as possible and most illnesses, diseases and injuries have a greater chance of being treated successfully and even more likely to be cured completely if treated quickly, if they are not treated quickly, the problem actually becomes harder to treat and in some cases, incurable and may also make it difficult to manage too, then quality of life deteriorates and it is almost certain that regular treatments to try and improve or just maintain quality of life will then be needed putting additional strain on an already overstretched hospital, this is the reality of the current situation here and now.

Even bringing Maidstone hospital into the equation doesn't really solve anything, as there are surgeons retiring that they seem unable to replace, so there are patients being diverted to London, because we cant cope, coupled with all the new developments in the Maidstone area, without any additional infrastructure being put in place to accommodate them, like parking for example, and all the additional congestion!

Both Hospitals are massively overstretched, seriously understaffed, with woefully inadequate parking.

GP surgeries are also at breaking point, at the height of the summer, it was a Nine week wait to see my doctor!?

It is therefore no surprise that Accident & Emergency departments are constantly full.

The roads are already far too heavily congested & too few parking spaces, especially when there could easily be another Ten Thousand vehicles in the area, that is without mentioning the endless roadworks and the massive inconvenience it will cause all of us while its being built.

The problems will start when building work begins with Construction vehicles and Roadworks, it will be the beginning of years of inconvenience and misery, which will only deteriorate.

With the increased demand for water, which will start when the building works start, does this mean that there will be even more inconvenience while the infrastructure is put in place to accommodate the new demand, or that instead the hose pipe ban will be extended into December?

Families will inevitably grow requiring the need for schools, shopping, activities.

Have you seen the rush hour queues, or worse still, had to sit in them for either Tunbridge wells Maidstone or Tonbridge or tried to go shopping at the weekend, then tried to find a parking space?

There will be a huge Negative effect on every aspect of normal daily life to all of us in the Local and not so local surrounding areas.

These proposals and the effects of the negativity will only grow as we try to play catch-up to resolve all of the issues that these developments will bring, then there will be limitations to the resources needed to put it right, but it will be too late, the damage will already be irreparably done.

Also, if it really is so necessary to build here and the demand is so high, why are so many homes in Paddock Wood empty?

I would like to add some positive reasons for the proposed developments going ahead, but none have been suggested and I am unable to find any.

If you are able to provide me with reasons why this is a good idea and any benefits that will come from it, I will be delighted to hear them.

DLP_4552

Historic England

Policy STR/PW 1: The Strategy for Paddock Wood et seq. – we note that a number of designated heritage assets fall within and adjacent to the sites identified in this policy; we are concerned that there has not been appropriately detailed assessment of the potential for impacts on the historic environment and heritage assets that may be affected in advance of adoption of the draft local plan.

DLP_4601

Save Capel

I am writing to you on behalf of the Save Capel campaign.

We have the names and addresses of 3,750 people who signed the following petition:

“We, the undersigned, petition Tunbridge Wells Borough Council to remove the proposal to build 4,000+ new homes in Tudeley and East Capel from the TWBC Local Plan.”

Consequently, Save Capel would like to register 3,750 objections to the Strategy for Capel Parish (Policy STR/CA1) and 3,750 objections to the inclusion of land in East Capel in the Strategy for Paddock Wood (Policy STR/PW1).

Please let us know if you would like the list of names and addresses. Save Capel has worked closely with Capel Parish Council and we fully endorse their comments on both the Local Plan and Sustainability Appraisal.

Members of Save Capel teams have submitted comments and objections as individuals, detailing evidence gathered across a range of topics, including landscape, environment, biodiversity, heritage, flooding, sewerage, housing need, transport and highways. We will not duplicate their comments, as we understand that their comments will be studiously considered as individual submissions.

As a campaign, we understand the national policy constraints applied to the development of the Local Plan and will watch its progression post-consultation and the evolution of national planning policy with great interest.

[TWBC: see list of petitioners (signatures and addresses redacted)

DLP_4610

Mrs Suzanne Callander

I strongly object to the intention to build so extensively in the parish of Capel.

I live in Tudeley and my home will end up on the periphery of the intended Tudeley new town.

I made a conscious choice to live in a semi-rural location, for the views, the environment, and to be in the countryside and to enjoy the stunning low-weald landscape. I am uplifted every day by the sight and sounds of the diverse wildlife around my house and I have the joy of dark skies at night. The Local Plan in its current form will wreck my chosen way of life, with thousands of unnecessary dwellings being built on the Grade 2 and Grade 3 productive agricultural land on what we assumed would be protected as it is Green Belt land.

Throughout the creation of the Draft Local Plan there has been very little constructive consultation. Indeed, the Capel sites were only made public in May 2019. Before this TWBC’s intentions were restricted by non-disclosure agreements.

Throughout the process, since the Capel sites were made public TWBC planners have continually issued misleading comments, have avoided difficult issues, and have refused to produce any detail about the plans, in relation to Capel.

The Plans for Capel appear rushed and unfinished, despite the fact that they relate to such a large percentage of Local Plan!

I believe that the Local Plan, in relation to Capel is currently unsound, unfinished, and inaccurate. It fails to offer evidence that planners have exhausted all other site opportunities, before making the decision (helped no doubt by a keen and willing single landowner) to utilise vast expanses of protected Green Belt land with the CA1 and PW1 sites. The Local Plan currently lacks any hard evidence that these sites constitute ‘exceptional circumstances’.

TWBC planners have also been publicly admonished by TMBC for a lack of consultation relating to the plans for Capel, which TMBC have acknowledged will have a devastating effect on the town of Tonbridge.

DLP_4634

Jean Jordan

I am writing to express as strongly as possible my objections to the local plan for Paddock Wood. My main and overriding concern is drainage and the flooding that will result from so large an area being concreted over in a town that already suffers from a very high water table. Being in the flood plain of the Medway and built under the shadow of the High Weald makes our town extremely vulnerable to Flooding.

No promises have been made to bring this problem to a satisfactory conclusion.

DLP_4635

CBRE Ltd for Dandara Ltd

3.6 Dandara is concerned that the delivery of new homes at Paddock Wood should not be directly linked to and reliant on the potential new settlement at Tudeley Village. Given the complexity and timescales associated with the delivery of garden settlements, it is strongly suggested that the site allocations are separated, with an overarching Strategic Framework or ‘Town Wide Framework’ to be adopted for Paddock Wood and for new infrastructure requirements to be assessed as part of an Infrastructure Delivery Plan (either incorporated into the framework or separate) which enables both allocations to be brought forward independently. Reasons for this are provided throughout these written representations.

[TWBC: see page 6 of full representation].

DLP_4683

CBRE Ltd for Dandara Ltd

Draft Local Plan Policy STR/PW1 ‘The Strategy for Paddock Wood’ - Dandara notes the following:

4.50 The views expressed in parts 4.39 – 4.47 above apply here. Again, it is worth highlighting that it is confusing to have multiple policies (strategic and site allocation policies) that apply to one allocation. It would be more straightforward and appropriate to have one policy per allocation that includes a strategic vision and detailed policy requirements where necessary.

4.51 In respect of Draft Policy STR/PW1, Dandara asks that TWBC clarifies the concept identified in the Masterplanning and Delivery section of the above policy, paragraph 1. This concept states that there will be an overall or strategic masterplan covering the parishes of Capel and Paddock Wood as well as subordinate masterplans, including in relation to Capel and Paddock Wood (Policy AL/PW1).

4.52 As stated previously, Dandara supports TWBC’s plans for an overarching masterplan but considers this should be a Strategic Framework or Town Wide Framework, to include principles and infrastructure for the broad strategic area. It is noted that there should be a requirement for an infrastructure plan that covers Paddock Wood and Tudeley Village (in combination and separate) and a masterplan that shows how all the Paddock Wood individual expansion sites (land parcels) would work i.e. for example connections, links with Tunbridge Wells, flood mitigation, open space, community infrastructure etc.

4.53 Importantly, this approach should not however include the detailed masterplanning of each site (land parcel) as this would add further complexity and conformity issues with the overarching Town Wide Framework.

4.54 In respect to Policy STR/PW1 and the role of the potential supporting Supplementary Planning Documents (SPDs), Dandara understands that any Strategic or Town Wide Framework would constitute an SPD and therefore form key guidance document.

4.55 Dandara is committed to working with TWBC and other stakeholders and the Developer Forum to prepare an overarching Framework and to bring forward an application for Badsell Farm as part of the Council’s planned expansion of Paddock Wood. This will include discussions on the phasing of infrastructure and land parcels.

4.56 As previously stated, the delivery of new homes at Paddock Wood should not be directly linked to and reliant on the potential new settlement at Tudeley Village. Given the complexity associated with the delivery of garden settlements, it is strongly suggested that it is dealt with through a separate site allocation. The delivery of infrastructure at these locations should also not be linked, and instead, separate infrastructure plans should be prepared.

[TWBC: see full representation].

DLP_4726

Catherine Scales

I am an East Malling resident whose child attended Mascalls school in Paddock Wood and as a family we have many friends in Golden Green, Tudeley and Capel. I travel regularly through these areas.

STR/pw1

This is green belt land and must be left alone, it is also important as a flood plain.

DLP_4767
DLP_4774

Heather Campbell
Alexander Christofis

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

We are writing to object to “The Strategy for Capel Parish” (Policy STR/PW1).

We are residents of Paddock Wood, backing onto the proposed East Capel site. We brought our property earlier this. We loved the small town friendly feel of Paddock Wood and the beautiful surrounding countryside. Which will all be lost with the proposed plan.

Please add our contact details to your consultation database so that we can be kept informed of all future consultations on Planning Policy documents. We understand that our comments will be published by the Borough Council, including on its website.

Creating a 4000+ new houses in paddock wood, almost 40% of all the new housing in the whole of Tunbridge Wells (1,500 new houses in East Capel) and a garden settlement at Tudeley of 2,800 dwellings will cause immense harm to residents of the Parish of Capel and Paddock Wood as well as to residents of Tonbridge. So 65% of the new houses will be in the Capel and Paddock Wood parishes. There are other more suitable sites such as the A21 corridor

Here we outline some of our main concerns:

Flooding

The plan is to build of flood plan. This will require extensive flood defences – which will divert funding from other areas and increase the flood risk to Paddock Wood, Tonbridge, Golden Green, Hadlow and East Packham.

Biodiversity

Pipistrelle bats (various species) are nesting in the local area, including our neighbour’s trees, which will back onto the new development. These bat species have a conservation order protecting them, so any planned development needs to abide by the standards set out by British law. We also have a huge range of animal and bird species, listed below, which visit our garden regularly:

Hedgehogs (Listed on Britain’s most endangered animals, population has declined by a third since the millennium)
Badgers
Foxes
Rabbits
Robins
Blackbirds
Wood pigeons
Blue tits (nesting in the woods by Tudeley brook behind house)
Goldfinches
Thrushes
Magpies
Sparrow Hawk – in field behind
Heron – Tudeley brook
Butterflies – cabbage white, red admiral and Kentish blue
Dragonflies
Frogs.

The current plan does not appear to be taking the wildlife into account. The table listed on the plan for this area simply said ‘limited biodiversity constrains’, which we feel is not taking into account the range of animals present in the area, particularly the endangered ones, which will be severely affected.

Roads and Transport

We both commute to work and the trains are already crowded, the new development will make trying to catch peak time trains impossible. Other public transport will need to be increased tenfold to cope with the additional people wanting to get to Tonbridge and Tunbridge Wells, currently bus services are inadequate at best. Road congestion will become normal in paddock wood with the 4000+ proposed houses.

Green belt

1000’s of acres of Green belt land will be lost. Why are the brown belt sites not being considered first?

The current plan will destroying existing old woodland, which is vitally important for countering global warming. The companies building may well plan to plant new trees to offset new carbon emissions, however trees take many years to mature and so this will not befit the environment for many years to come. Global warming is a huge problem which we have to tackle now before its too late and this will exasperate it.

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.

Wellbeing

We have lived in many places (Cambridge, Portsmouth and Gravesend) but chose to by our first house in Paddock Wood as we wanted to live the a beautiful green belt area. With all the health and wellbeing advantages of being in the countryside.

Pollution

Air quality will decrease – this is very worrying to us as I suffer from asthma. One of the reasons we chose to buy a house in Paddock Wood this year was the lovely fresh air to help me, which will be lost with this new construction. Additionally light and noise pollution will increase.

Sewage and water

Sewage systems already can’t cope, already approved developments now being delayed because of this and additional work having to be done to make them viable, for example the development along Badsell Road.

Housing need

Currently, the area of Paddock Wood has seen a massive slowdown in the property market. People are preferring to look at places such as Tunbridge Wells, Sevenoaks and for convenience to London places such as Ebbsfleet Garden Village. When we were buying our house there were many properties which had been on the market for a very long time and having to make multiple price reductions to try to sell as this is not a popular area at present. The rate of sales have slowed down so much that local estate agents have started closing down. We struggle to see who will be buying these thousands of new homes when the houses already in Paddock Wood aren’t selling.

Health services

Paddock Wood already requires a new Health centre for the current population, Woodlands Health Centre is already stretched to capacity, and wait times for doctors’ appointments are excessive. Plus there is a lack of dental and social care which is not addressed in the local plan.

Emergency services

Currently, Paddock Wood only has a part time fire service and doubling the number of properties will require a full time permanently operational fire station which there appear no plans for. Also, the local hospital in Pembury will have to expand to cope with the mass increase in the local population.

Utilities

Will the existing electrical substations be able to cope with the increased demand? Would additional pylons be required or will the main power supplies be sunk in the ground resulting in either additional eye sore and environmental impact.

We have heard there is a lack of a gas pipe across the Capel Parish and worry about the implications of this for the new development.

I object to the inclusion of land in Tudeley Now Town site (Policy STR/CA1).

This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. Most of our objects outlined above apply to the Tudeley settlement as well.

Overall, we are deeply trouble about the new plans which will destroy the beautiful green belt land, kill the wildlife and will also apply pressure onto the neighbouring borrow of Tonbridge and Malling owing to Paddock Wood location next to Tonbridge.

DLP_4815

Adrian Pitts

I live in Allington Road in Paddock Wood. Following the approval of numerous new homes including the Badsell Road I am concerned about planning priorities going forward. You gave these the go ahead despite local concerns.

In recent days an adjournment debate has been held by Greg Clark https://t.co/4BcxKuPUvr and Rebecca Pow also supported this about the specific problems in Paddock Wood. The 4000 homes recommended by the new plan was unmentioned in Parliament.

Flooding - The plan to build again on category 2 and 3a flood risk areas. I questioned developers about this in the last consultation for the three sites already approved. Huge amounts of developers' money will inevitably be spent on flood mitigation, diverting funds from other essential infrastructure. This doesn’t take account of the interim risks to homes like mine in the construction phase. The water company needs to be included at the very least to improve drainage for the area replacing outdated and poorly functioning pipes and culverts. The plan should not seek to keep the risk as neutral but to improve the situation.

Biodiversity - we live in the country where wildlife and plants abound. Countless creatures will lose their habitats in the draft plan and the continuing urbanisation of PW together with potential political boundary changes seeks to make PW the urban hub without infrastructure improvements or the safeguarding of natural elements and habitats.

I hope the plan can amended to be grown up enough to lift its head up to see the other massive developments proposed in geographical neighbouring areas which further erodes the environment and lacks infrastructure. Massive development along Five Oak Green Capel etc will further impact the area. Plan needs to address this in a joined up way.

Roads - in Allington Road already and around the town there is heavy congestion. In the previously approved developments I asked developers about the roads and they’d assessed this when the schools were on holiday and not at peak times. The queuing lane approved by KCC Highways will have been put in place on the Badsell Road! It already takes 10 minutes or more from the A228 into PW- covering a main route fro

Tonbridge and Maidstone. The Maidstone Road gets busy now whenever traffic is congested as the other route to the A228 by the Hop Farm. The plan needs to address this and the noise, cost, location and upkeep.

Green Belt land - an exceptional reason is needed to build upon it. Sevenoaks has already had its local plan rejected by the government due to this. TWBC?

Wellbeing - The accessible natural green space standard (ANGSt) recommends that everyone should have accessible natural green space of at least 2ha in size, no more than 5 minutes' walk from home... The candidate local nature reserves, to the SW and E of PW will not meet this standard for those living in the NW of PW.

TWBC already recognise that air and noise pollution is a downside to these developments. Light pollution will be a factor too (not just from street lamps, which will be low-pollution LED ones)

Heritage - building proposals near historic buildings/features, e.g. some listed buildings will be surrounded by development areas. Changing tbd character forever.

Transport - increased number of commuters, non-existent parking spaces, more dangerous parking in residential roads, not enough seats on trains (issue with length of platform so not able to just add more carriages). People already come to PW to access the railways from villages where services have been cut.

Sewerage - Southern Water are already over capacity; antiquated and mixed type infrastructure causing back-ups and flooding when it rains; all waste water coming through from Capel parish to PW's water treatment works in North-East Paddock Wood.

Education - Schools and transport to them (especially Tonbridge - e.g. Trains, Tudeley Lane) adds to congestion by non-residents to highly popular schools. New education infrastructure should be addressed.

Agriculture - With the draft plan, a large amount of grade 2/3 land will be lost, including some of Ribena's blackcurrants. Apple orchards have already gone in existing developments given approval.

Housing need and type - the latest calculations show that much less housing is actually needed (some sources have said it's almost half!) 'Affordable' housing is rated at 80% of market value - how many local people will actually be able to afford these homes? These homes should not marketed to those in Greater London. Affordable should mean just that and some genuine starter homes in permitted development.

Health provision - Another GP surgery has been allowed for, but they do not take into account the lack of GPs in the NHS. East Peckham closed so PW Woodlands has long waiting times for GPs already.

Police - Increase in population will lead to an increase in crime. TWBC want to double the population of PW so we should at least have a part time police presence. With the proposed demolition of the police station, we will have nothing. Again needs a joined up approach

Sports provision - A sports hub is planned for the NW side of PW, which floods. If TWBC/PWTC's plan for the Community Centre goes ahead, the PW Memorial Playing Fields will lose its cricket pitch. The tennis courts have already been closed 'for the Winter' as they are in bad repair and dangerous.

The plan needs to look at and support local people. Ambitious climate change measures are missing and ignoring flood information already in the public domain. Infrastructure and amenity improvement first! Then sustainable development not just to tick off targets but improve the area holistically.

Not in support of the current proposals.

DLP_4926

Anna and Nicholas Watson

We are responding to the TWBC Local Plan regulation consultation as residents of Golden Green, Tonbridge. We feel that the developments will negatively impact upon us in many ways, in fact in far more ways than those who live in the Tunbridge Wells borough.  Please add our contact details to your consultation database so that we can be kept informed of all future consultations on Planning Policy documents.

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel.

We hope that you will take into account the strength and depth of feeling from the community about these proposals and remove them.

DLP_4943

J Borrett

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1)

This land is Green Belt land and should only be built upon if an "exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using Green Belt land and/or land with a high flood risk.

DLP_4951

Keith Hardwick

I object to the inclusion of land in East Capel in ???The Strategy for Paddock Wood??? (Policy STR/PW1).

This land is Green Belt land and should only be built upon if an ???exceptional circumstance??? exists. TWBC???s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan???s aims without using the Green Belt land at East Capel. The comment above about coalescence and the creation of a conurbation from Paddock Wood right across to Tonbridge is very relevant here, as is the land???s use as a flood plain. Building here, even with flood risk mitigation and ???betterment??? could have disastrous consequences for all, as the measures being looked at are based on old data that does not fully consider the impact of climate change.

DLP_5063

Joan Bryant

I object to green belt land being used for development and I object to houses being built on a known flood plain. It is stated that green belt land is being used in order to help alleviate flooding.  It would make far more sense not to build on a flood plain, particularly as climate change is becoming an ever closer reality.

Large parts of the proposed 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. I do not think flood mitigation measures will provide a long term solution.

Our MP Greg Clark proposed an adjournment debate on Monday (28th October) regarding Southern Water.  Paddock Wood and the struggles the Town Council have had with Southern Water is given as his specific example.  Please read the full Hansard report here ( https://hansard.parliament.uk/commons/2019-10-28/debates/19102919000001/SouthernWater ).

I quote: “The town of Paddock Wood is situated in a low-lying area quite close to the River Medway that frequently floods. When it does so, the overload of the current network has unacceptable, unhealthy and frankly disgusting consequences for residents.

One of my constituents, who lives on an estate near the centre of the town, described how for 10 years her front garden has been regularly flooded with water containing sewage, toilet paper and other waste, coming up from a manhole cover in the middle of the road outside her property. A resident in a different part of town described how he and his neighbours have submitted complaints time and again about sewage and toilet paper being washed out into their road.”

He also stated what he recognised as being the obvious:  “..if new development is to take place, it must always be accompanied by the new infrastructure necessary to make the development work”.  Mr Clark only mentioned the initial 1,000 houses that already have planning permission in Paddock Wood.  He did not mention the extra proposed 8,800 extra homes planned for Paddock Wood and Capel, so you can see the scale of the problem.

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 excessive housing allocation to Paddock Wood. 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. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant

Rather than take the easy option of building on farmland, I would like to see the council think of innovative ideas such as building homes over existing car parks.

DLP_5119

Fiona Lee

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

I live in Golden Green and have done so for over 20 years. It is a wonderful community, in a spectator rural location, giving all that choose to live there, the best of all worlds - town and country living within good proximity to transportation links. My daily car route, in and out of the village is via Hartlake Road and am all too aware how this development will impact my life and ultimately, the reason for our choose to live in the area in the first place.

Whilst my responsibility of good citizenship is to be acknowledged, I do feel there are far better solutions to achieve housing quota targets than this one proposed. Such examples are the great development around Tonbridge’s old industrial estate, combining business and living together with adequate transportation links to and from the area. Encouraging more of this combined approach, with incentives to businesses to provide more opportunity, must surely be a better solution. And how about utilising the retail high street units, providing landlords incentives to release unused retail space for living, work and educational spaces?

Please add my contact details to your consultation database so that I can be kept informed of all future consultations on Planning Policy documents. I understand that my comments will be published by the Borough Council, including on its website.

DLP_5140

Peter & Veronica Bryant

We refer to our email sent on the 23rd September 2019 and wish to add additional comments.

In connection to the Proposed Draft Local Plan (Reg 18) please find our comments to this proposal.

As residents of South Tonbridge, we will be directly affected by the Proposed Draft Plan as it’s boarders run alongside Tonbridge & Malling Borough and the road infrastructure will impact our area considerably.

a. The road infrastructure from Paddock Wood to Tonbridge is at breaking point at this present time. With narrow streets in Five Oak Green and bending slow roads throughout the 6 miles, travelling along this route is certainly demanding during peak times of the day. (Early morning rush hour, school leaving times and evening rush hours). With the proposed additional housing along the route, the increase of traffic flow in both directions would be dramatic.

b. With the Ambulance Service stationed in Eldon Way, Paddock Wood, Emergency Services requiring to travel to Tonbridge already have a difficult enough time negotiating the traffic to get to an emergency. With the dramatic increase of traffic this would put lives in danger.

c. At present, bus services use the route from Paddock Wood to Tonbridge and Tunbridge Wells. Again with the dramatic increase of traffic flow created by new housing, services would be greatly affected, especially buses being used for the school runs in rush hour times.

d. Tonbridge town already has a dis-proportionate amount of Secondary Schools in the county which require children to be transported into the town from other boroughs mainly by bus. Adding an additional Secondary School into our area, which is on the boarder of the town will only increase the traffic congestion.

e. We find it totally unacceptable that any Green Belt land is used for building, especially in an area of outstanding beauty. This land is protected for a reason. Once this land is destroyed, it will never be re-instated.

f. By destroying Green Belt land you are going against all Government objectives on Climate Change Controls to obtain zero rated omissions.

g. Tonbridge is valued as an important commuter town and as such has high demand on it’s rail network and car parking. Car parking is limited for commuters and with an additional increase of population around the Tonbridge boarders would not be sustainable.

h. We know that our doctors surgery in Tonbridge has closed their books as they are working to capacity. Surgeries would not be able to cope with the increase in population, NEW surgeries would need to be built.

i. We also have great concern over the increase of land being covered with concrete and therefore restricting the amount of land for drainage. With many homes and villages in the area already under threat of flooding, this would only increase the probability of future flooding in the Tonbridge & Malling area.

DLP_5166

Michaela Blewett

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

Many of the extreme concerns I have stated above are also appropriate for the paddock Wood Policy STR/PW1 as this land is ALSO GREEN BELT and should only be built upon if an “exceptional circumstance” exists. . Building here, even with flood risk mitigation and “betterment” could have disastrous consequences for all, as the measures being looked at are based on old data that does not fully consider the impact of climate change.

DLP_5194

Lynton Wright

My wife and I moved to E.Peckham in 2001.At this time traffic was manageable on the village roads and the speeds of vehicles acceptable.  Now however the traffic has increased at least three fold and speeding is a regular occurrence For example traffic along Hale streed is heavier than on the A228 EP bypass and Church road / Hale Street is a rat run from Tonbridge to the motorways.

Our proposed development of about  70 houses along Church road ( which is not mentioned in your letter) will cause an increase  in traffic through the village.  Thousands of houses in Paddock wood and Tudely will just  make matters worse, each house  owning on average 2 vehicles.

In my humble opinion the road infrastructure will have to be reassessed  otherwise the three towns/villages will seize up   New schools, parking facilities, shopping centres are all inadequate now so thousands of new people in the area is going to cause major problems and will cost millions .

I would like to see the latest proposals for how this massive influx is going to me managed.

DLP_5274

Rachel Smith

I am a resident of Paddock Wood and have lived in 3 homes within the town over a period of around 30 years.

I am writing to OBJECT to the strategies for both Paddock Wood (Policy STR/PW1) and Capel Parish (Policy STR/CA1).

OBJECTIONS TO THE STRATEGY FOR PADDOCK WOOD (POLICY STR/PW1)

I challenge the need for so many houses to be built over the plan period of 2016-2036. The Office for National Statistics estimates borough population growth of 13,952 people, and with an average house occupancy rate of 2.35 people (117,140 people living in 49,880 houses), the need is for 5,937 houses (of varying sizes). TWBC must challenge the government on the number genuinely needed in the borough.

Flooding: Land already built on lies within Flood Zones 2 & 3 (http://www.tunbridgewells.gov.uk/__data/assets/pdf_file/0003/26499/Surface-Water-Management-Plan-Apprendix-A-Maps-2012.pdf)

We do not yet know the impact of the additional 900+ homes already planned so to propose a vast expansion of Paddock Wood seems very short sighted. Should further land be made available for development no doubt huge amounts of developers' money would have to be spent on flood mitigation, diverting funds from other essential infrastructure.

Inadequate Arrangements for Sewerage: My understanding is that the current arrangements do not have the capacity for the new housing already proposed for Paddock Wood so vast improvements would be required to accommodate more developments.

Roads: I fail to see how roads in Paddock Wood can accommodate increased traffic from the current proposed developments without major congestion. In addition there will be an increased number of commuters and more dangerous parking in residential roads

DLP_5277

Susan Lovell

Policy STR/PW1

First and foremost, I feel I cannot adequately comment on this policy, as the masterplan has not been detailed. I have made certain generalisations and assumptions in my comments.

Number of Houses

TWBC’s numbers were calculated on old figures and there is already evidence that the housing numbers are hugely inaccurate. As at September, only 34 houses of the Mascalls Court Farm development had been sold and the new primary school has been put on hold, because it has been decided that it is not needed because potential numbers are too small. TWBC has the right to challenge the government on the number of houses - and it should do so!

I am unhappy that Paddock Wood and Capel are jointly getting the lion’s share of the housing - a figure of 68% has been mooted, or 33% for Paddock Wood alone!

I am not happy that numbers of houses on each potential development site have been estimated. This has made it almost impossible to make any reasoned judgements on the matter.

Housing need and type - the latest calculations show that much less housing is actually needed (some sources have said it's almost half!) 'Affordable' housing is rated at 80% of market value - how many local people will actually be able to afford these homes? The garden village principles state that there should be housing types that are genuinely affordable.

There are people in Paddock Wood who dream of owning their own home but there is no way that they will be able to afford an average £378,000 family house in the borough, let alone in their own town.  Residents should be encouraged to live within a close proximity to their family.

I believe the homes that are currently in development are being marketed to those in Greater London.

Paddock Wood should remain of a largely Rural nature - This statement is part of PWTC’s draft neighbourhood plan. Effectively doubling the size of Paddock Wood does not match this statement in any way. Development proposals should not have an adverse impact on the landscape setting of Paddock Wood and should maintain the distinctive views of the surrounding countryside from public vantage points within and adjacent to the built-up area. From Castle Hill view point in Brenchley the views will be irrevocably changed.

TWBC should be seeking and reassessing out other sites such as the A21 corridor and Blantyre House.

Flooding - TWBC want to build on category 2 and 3a flood risk areas. This hugely contradicts the NPPF Climate change flood risk assessment.Huge amounts of developers' money will inevitably be spent on flood mitigation, diverting funds from other essential infrastructure. Southern Water employees have also told me that as soon as it rains the storm tanks are full, so there will have to be other valid sites for more of these tanks. There is a huge amount of standing water on both the Mascalls Farm (AL/PW3) and Mascalls Court Farm sites as at today, 15/11/19. The infrastructure needs to be put in place before the houses and roads are built.

Biodiversity - wildlife and plants. Countless creatures will lose their habitat. I have major concerns over the habitat of tawny owls, kestrels, sparrowhawks, buzzards and other wildlife (Including their prey) if PW1_7 and other large areas of agricultural land are heavily built upon.   Families of these creatures are a common sight/sound over that area. If you remove or alter the habitats of the local wildlife The proximity of more people and their pets to historically natural areas will invariably be detrimental.

The draft local plan states that there will be a ‘net gain’ i.e. more trees will be planted than lost. However, these will be saplings. A mature tree will take up between 50 and 100 gallons of water per day.  The removal of mature trees and hedgerows will decimate the habitat of thousands of animals and birds in Tunbridge Wells Borough Council’s draft local plan.  Planting additional trees and hedgerows will not adequately help these creatures, as they will not be able to make their homes in young trees.  We need to ensure that developers calculate the impact of any developments using the government’s agreed biodiversity impact accounting metric. (Gov.uk/government/news/spring-statement-2019-what-you-need-to-know/) Biodiversity net gain is of course a government requirement.

Church Road’s important hedgerows are well over 30 years old, as defined by the Hedgerows Regulations 1997 and there are laws against these being destroyed.

Roads - There will inevitably be a new road built East of Paddock Wood, possibly within PW1_7. This will cause more light and noise pollution. I hope that Church Road will get the footpath it so desperately needs as soon as possible.  The infrastructure will need to be present before the developments.  Current residents cannot continue to risk their lives while walking to the town centre or station. Church Road needs improving in that cars, travelling in both directions, pass our row of houses over the white line in the road. There should be an extension to the 30mph limit.

The country lanes within our area will not withstand the increased traffic, including the industrial traffic such as Scrapco and Osmonds at Old Hay.

Green Belt land - policies AL/PW1 & AL/CA3 - an exceptional reason is needed to build upon green belt land. Sevenoaks has already had its local plan rejected by the government due to this.

Green Spaces - I am concerned about the green space/rest area behind the Wesley Centre as it has been labelled as a potential development area and giving us a local green status may frustrate the potential. This should be labelled as a local green space and kept that way. Otherwise, there is potential for building on that site which is not what local residents want.

I am concerned about the Mascalls school playing field being given as insufficiently evident as a local green space. I would hope that this would not be built upon.

I’m also concerned about the natural woodland behind Warrington Road/Heather Bank 1.27 ha of natural woodland - this is important wildlife habitat and should be protected.

There is ancient woodland, ponds, and meadows to the south-east of Mascalls school, bounded by Mascalls Court road and Chantler’s Hill (including a public footpath.) It should be treated as a local green space.  This area is not marked on your local green spaces assessment.

Paddock Wood Primary School’s playing fields, AS_54, should be marked as a green space and protected.

Wellbeing - The accessible natural green space standard (ANGSt) recommends that everyone should have accessible natural green space of at least 2ha in size, no more than 5 minutes' walk from home...

In the Tunbridge Wells green infrastructure framework for draft local plan item 40, gap analysis recognises this. In the table, the key access issues states that paddock wood has got very poor access. Following on from that, there should be one accessible 100 ha site within 5 km of “home“ there is not one in Paddock Wood. Item 41 states that there is significant opportunity to provide for and address any shortfalls in natural green space provision, as part of the master planning process, according to green garden settlement principles. I would like to flag this to make sure that this actually happens.

The candidate local nature reserves, to the SW and E of PW will not meet this standard for those living in the NW of PW, so these conditions have not been met.  The green wedges have not been adequately detailed to enable me to comment. However the one strip of land at the very east of Paddock Wood (PW1_8) seems unsuitable as it is right between a solar farm and Queen Street.

TWBC already recognise that air and noise pollution is a downside to these developments. My house in Paddock Wood is on the main road but semi-rural. I chose this house for peace and quiet. I have already been affected by the noise of Mascalls Court at the back of my property. Now I have the threat of more roads and houses being built, causing a huge amount of noise. This is not what I moved to Paddock Wood for! Light pollution will be a factor too - not just from street lamps, which will no doubt be low-pollution LED ones, but from vehicles on the road and the new houses and other buildings.

Rural feel to Paddock Wood - the green and Rural feel to the approaches to paddock wood, in particular from the south (from Brenchley) and West (from Five Oak Green) should be safeguarded and enhanced, as per PW’s draft Neighbourhood plan. Policy G3 also states that ‘development proposals that would lead to the join up of the built up areas of Paddock Wood and Five Oak Green will be resisted.’ Tunbridge Wells Borough Council’s local plan is based upon development to the west of Paddock Wood, which belongs to the east of Capel. This totally goes against our Green infrastructure policy, therefore I am totally against the development to the East of PW.

Heritage - There is a huge development planned to the East of PW - possibly a ’neighbourhood centre.' There are listed buildings that will be surrounded by development areas on 3 sides, namely 1 and 2 Rose Cottages will be surrounded by PW1_7, PW1_8 and the Mascalls Court development. The row of 4 houses on this stretch of Church Road (of which mine is one) have been completely surrounded with development sites. The beautiful views of the countryside and historic farmsteads over the fields, which add to the financial value of the properties, will be ruined. Will homeowners be adequately compensated for this intrusion? Is it even legal for houses to be built in the area within the curtilage of these listed buildings?

Policy AL/PW4 states that the community centre will be placed on the Paddock Wood Memorial Playing Fields.  This was purchased using donations by the people of Paddock Wood and then more recently, I am told that the deeds were transferred into PWTC’s name.  Also the town had a poll, which stated that the residents were not in favour of the community centre at the PWMPF.  This is not democracy and it is wrong. There are more suitable sites for the community centre.

The linear route of the historic railway line should be afforded protection against future development.

Transport - there will be an increased number of commuters, non-existent parking spaces, (AL/PW2,) more dangerous parking in residential roads, not enough seats on trains (issue with length of platform so rail companies will not be able to just add more carriages.)

Sewerage - Southern Water is already over capacity; antiquated and mixed type infrastructure cause back-ups and flooding when it rains; all waste water is coming through from Capel parish to PW's water treatment works in North-East Paddock Wood.

Education - Schools and transport to them (especially Tonbridge - e.g. Trains, Tudeley Lane) Also TWBC state that further education is covered in Royal Tunbridge Wells - it really isn't!

Agriculture - With TWBC's plan, a large amount of grade 2/3 land will be lost, including some of Ribena's blackcurrants (PW1_9.)

Health provision - Another GP surgery has been allowed for, but they do not take into account the lack of GPs in the NHS. NHS England have admitted to me that they cannot recruit GPs.

Police - Increase in population = increase in crime. TWBC want to double the population of PW so we should at least have a part time police presence. With the proposed demolition of the police station, we will have nothing.

Sports provision - A sports hub is planned for the NW side of PW, which floods. A cricket pitch would sink there - the lime would wash away. If TWBC/PWTC's plan for the Community Centre goes ahead, the PW Memorial Playing Fields will lose its cricket pitch. The tennis courts have already been closed 'for the Winter' as they are in bad repair and dangerous. Will they ever come back in to use?

Utilities - There is currently no gas pipe serving East Paddock Wood - this, I assume would have to be installed at great cost, or other alternatives provided

This probably does not cover all of my feelings on these developments but I have spent hours poring over these documents.

DLP_5301

Frank and Sue Rossiter

Proposed allocations for Paddock Wood:

  1. North of the Railway line – this land is in flood zone 3
  • Floods happen to a greater or lesser extent every year; these are expected to get worse.
    • Homeowners have already had to have pumps installed in their gardens to help avoid a badly flooded house; again, there is the issue of covering precious green field sites with concrete.
    • The fire service will have records of the latest floods and the cost of dealing with them
    • Insurance for new homes?
  • Brown field site/s should be built on first – eg: LandSeaAir site on Hop Pocket Lane which has had planning permission for building 24 homes for over a decade.
  • Primary school already urgently needed (planning permission turned down)
  • Medical support – despite the best attempts of our Woodlands Surgery, they cannot give the service that is currently needed.
  • Transport
    • Road traffic- the local road system is not fit for purpose; roads are too narrow, vehicles too heavy, (railway bridge cannot take vehicles of over 7.5 ton) and we have very restricted pavements/safe pathways for pedestrians and cyclists.
    • Commercial road/Station Road cannot take the current demand for traffic.
    • Rail commuters add to the road traffic and the trains are already packed.
    • Eldon Way traffic emerging on to Maidstone Road, especially from Paddock Wood Autos, blocks the junction causing long tailbacks; there is also an Ambulance station on Eldon Way.

DLP_5304

Kay Groves

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1) and the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1) for the following reasons:

There is a distinct omission in your proposals with regard to understanding the waste infrastructure within the Borough of Tunbridge Wells, but also with regard to the impact on neighbouring authorities.

North Farm Transfer Station is at capacity and cannot receive any more tonnage than the current intake of household waste. Kent County Council Waste Management will be able to confirm that waste infrastructure in Kent is already of a grave concern to the Waste Disposal Authority with regard to the number of housing developments being planned/built in the County and the lack of full consideration with regard to waste management being a key public service.

The significant development within the TWBC area will undoubtably put pressure on the waste services provided by KCC in this area.  KCC as the Waste Disposal Authority provides a Waste Transfer Station (WTS) at North Farm for the receipt of kerbside waste collected by WCAs (both TWBC and some of T&M BC).  There is also a co-located Household Waste Recycling Centre for residents to dispose of household waste.  Both of these facilities are strategic, serving not only the whole of TWBC area but also serves residents from adjoining Districts.

The tonnage of kerbside waste these new developments will produce has not been fully considered, both with regard to collections, but more importantly disposal infrastructure. Waste Collection Vehicles cannot travel large distances if they are to complete their rounds within a reasonable daily timeframe and therefore, consideration of how to receive, bulk and onward haul significant additional tonnage at a local tipping facility and the placement of more local HWRC facilities must be part of the plan.

Without increasing waste infrastructure, KCC would not be able to take in any more tonnage collected by Tunbridge Wells Borough Council, and therefore be unable to fulfil its statutory duty as Waste Disposal Authority which means the waste would have to be refused. Strict permitting and Planning restrictions govern waste facilities with regard to capacity and waste levels. Subsequently, the consequences may mean waste is not collected from the kerbside, breaching the Environmental Protection Act and damaging human health.

Local Plan Document

  • Section 6.22 only refers to the waste from the construction process and not output from households.
  • Sections 2.10 and 2.11 refer to a Development Constraints Study of October 2016.  There is no consideration of Waste Infrastructure.
  • Waste consideration needs including in ‘Policy STR5 Essential Infrastructure and Connectivity’.
  • North Farm WTS and HWRC is missing in the Overview Table on p64 for Royal Tunbridge Wells as it is a key piece of Infrastructure that serves the whole of the District.

Infrastructure Delivery Plan Document

  • Theme 9 in the IDP, Section 3.247 notes the unprecedented demand for KCC Waste facilities however it needs to explain that whilst KCC operates ‘a network of 18 Household Recycling Centres (HWRCs) and 6 co-located Waste Transfer Stations (WTSs)’ this is across the whole County and that TWBC is served by one combined WTS and HWRC at North Farm.
  • The paragraph on Current Planned Provision, section 3.248 only mentions TWBC’s collection service and does not account for the disposal service and associated infrastructure - the new collection contract has already put North Farm Transfer Station under immense strain despite infrastructure alterations being made.
  • Section 3.251 ‘There are unlikely to be any major short term (five years) infrastructure requirements, but potentially some over the lifetime of the Plan, such as expansion to the depot’ - this underplays the extent of the problem which is only a reflection of TWBC’s view on WCA infrastructure requirements. KCC’s infrastructure requirements as the WDA are different and noted in Section 3.253 which requires updating.
  • Table 15, p81 should be reworded to include WTS expansion/improvement/new site needed.

Furthermore, on another but very relevant point is that on the 5th August 2019, Tunbridge Wells Borough Council declared a “climate emergency” where it was accepted that the Council needed to do more to protect the environment through environmental and sustainability impacts in Council services, with the Local Plan being one area which will contribute to reducing carbon emissions.

The Council is acting inconsistently by declaring a Climate Emergency but failing to prevent development on Green Belt countryside and open spaces which provide vital mitigation for climate change and putting forward large swathes of Green Belt/open space land for housebuilding despite professed commitment to environmental protection.

By protecting green spaces, the Council could be making a hugely important contribution to people’s health and well-being as well as maintaining essential eco-systems and providing wildlife corridors.

London Green Belt Council has stated the following in relation to London and the Home Counties:

“Green spaces help to mitigate climate change because carbon is absorbed by vegetation and held long-term in soils emissions. They also help us adapt to climate change by absorbing rainwater and cooling our towns and cities. The more green space we lose, the more we are at risk from flooding and rising temperatures, two of the predicted effects of climate change.

“District and borough councils are absolutely right to recognise the seriousness of climate change and to acknowledge the role that local government can play in tackling the climate crisis, but if they do not also pledge to defend the Green Belt and countryside from development then they are failing in their duty to protect our communities and environment.”

The LGBC is calling on all local authorities to state categorically that climate change mitigation requires the protection of Green Belt countryside and open spaces, and to agree to block developers’ proposals for building on Green Belt land”

Central government has tree planting targets, air quality targets and climate change targets that will be passed to Local councils to help deliver their pledge to the people - the Local Plan cannot be put in place in isolation without recognising this conflict, as well as the crisis we are facing globally.

I object to my Council producing plans that are in direct conflict with their own and Central Government’s commitment to mitigating climate change, as well as failing to consider fully how waste will be managed for thousands of new homes.

You have an opportunity to be seen as the leading Authority in proposing intelligent and sensitive developments that don’t wreck our environment, our health and our well-being; please listen to your residents.

DLP_5309

Alison Martin

I am writing to object to “The Strategy for Paddock Wood” (Policy STR/PW1) including AL/PW1

This land is Green Belt land and should only be built upon if an ‘exceptional circumstance” exists.  TWBCs own assessments in the Sustainability Appraisal show that Paddock Wood could be designed to tolerate some of the plans aims along with an updated Brownfield land map for the Borough to absorb the rest.  Green Belt land should not be re-boundaried (LBDs) to excuse the gross incompetence of a Borough Council.

Building here, even with flood risk mitigation and ‘betterment’ could have disastrous consequences for all, as the measures being looked at are based on old data that does not fully consider the impact of climate change.

I can not believe so many dwellings are planned without first waiting to see the impact of the construction occurring at Mascalls Court Farm, and Church Farm. The traffic generated from these developments will have a huge impact, as well as the increased population figures impact on local services, health and social.

Why are Borough Councils still adopting the out of date inflated figures for housing numbers?  Why do Borough Councils not have up to date maps of Brownfield sites.  Why is is not law to develop Brownfield sites first before any Greenfield land can be developed?  (Let alone Greenbelt or AONB)

The arrogance of TWBC astounds me, what has to happen to make you listen?

DLP_5318

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

Policy STR/PW1

Support with conditions

In supporting policy STR/PW1 we note that criterion 5 of the section on ‘The Strategy for Paddock Wood’ indicates that the exact location of the offline A228 strategic link has yet to be determined. Yet policy TP6 looks to safeguard a route. In order to avoid confusion policy STR/PW1 needs to be clear about what is proposed and to cross refer to policy TP6 in this regard. If the exact location of the offline link has yet to be determined then the area identified on the proposals map pursuant to policy TP6 needs to provide flexibility – albeit as this is referred to as a critical piece of infrastructure, it needs to be identified and safeguarded as soon as possible so that it can be costed and the costs included in the stage 2 VA, if it is not to prejudice the housing trajectory.

Criterion 1 of the section on Masterplanning and Delivery appears to contradict policy H2 when it suggests that proposals for the piecemeal development of individual sites will not be supported. Clarity is needed upon this as, as indicated above, we believe multi developer delivery /piecemeal development can occur without prejudice to the overall Framework Plan and Strategic Infrastructure Plan, and that this is needed to facilitate the proposed housing trajectory. Turning to the first bullet point of criterion 1 on Masterplanning and Delivery we do not believe the requirement to be for a strategic masterplan for the provision of infrastructure, but for a Framework Plan and Strategic Infrastructure Plan which is we believe more aligned to that required to address the issues raised in policy STR/PW1. We also note the reference to said document requiring input from Tonbridge & Malling and Maidstone Borough Councils where it impacts on Tonbridge town centre and land to the north of Tunbridge Wells borough. This clearly interrelates with the need for TWBC to agree a strategy with the neighbouring authorities through the DtC – which we note has not occurred to date and which, as set out above, we consider to be required in order to fulfil the requirements of the DtC.

We also note that the third bullet point of criterion 1 on Masterplanning and Delivery refers to the ‘creation and adoption of one or more Supplementary Planning Documents’. The Local Plan needs to be clear what these are, and when they are to be delivered, and consider how they will affect the housing trajectory. Requiring the adoption of SPD post adoption of this plan could have sever implications on housing delivery.

Turning to criterion 2, 3 and 4 of that section of policy STR/PW1 that relates to Masterplanning and Delivery, we would, as far as criterion 2 is concerned, reiterate our view that what TWBC are actually looking for is a Framework Plan and Strategic Infrastructure Plan not a masterplan, and refer the reader back to our comments about the implications of references to CPO powers. We would also reiterate the point above re viability – to establish a robust viability for the allocation at Paddock Wood as part of the Reg 19 plan, TWBC and KCC need to identify whether LEP or central government funding will be available to contribute towards the funding of the road and infrastructure improvements envisaged by the local plan and IDP, and the scale of said funding. The development industry will need to know what’s happening by the time the Stage 2 Viability is prepared so that sensible decisions can be taken about what pieces of infrastructure are needed and when and to try and tie infrastructure delivery to particular areas of growth so that house builders know what they need to provide by way of works or by way of contributions.

In addition to the above, as suggested elsewhere in this letter, we see no reason why a Framework Plan cannot provide for the separate masterplanning and delivery of the areas to the east and west of Paddock Wood. The Framework Plan can demonstrate how these interrelate in terms of the requirements of policies STR/PW and AL/PW1 for housing, employment, schools, medical facilities and open space etc and associated connections in a general land use planning way, whilst the Strategic Infrastructure Plan can show who is providing what, and when, and how projects such as highway improvements / drainage works are to be funded jointly who is paying for what and when it has to be provided. It can in addition look at how the plans for Tudeley are incorporated into the overall Strategic Infrastructure Plan for Paddock Wood

Criterion 1 of the section of policy STR/PW1 that relates to Transport reiterates the need for development to provide for an offline A228 strategic link. As set out above the exact route of said link has yet to be determined and needs to be to ensure the timely delivery of the strategic allocations.

In addition to the above, Whilst supporting improvements to the local road network, and new roads in association with new development, to provide for improved permeability, we would question the extent to which any development can provide for improved links north of the railway – other than through financial contributions, as structural works themselves could take years given the need to involve Network Rail, and are, as set out above, questionable as little traffic will travel north from the strategic expansion proposed to the east of Paddock Wood.

Finally, we note that when commenting upon infrastructure, policy STR/PW1 refers to the expansion of Mascalls Secondary school and the provision of additional primary schools. The number of schools and their distribution is not qualified. The same occurs within policy AL/PW1 (criterion (iii) and criterion 11 refer), albeit criterion 11 does refer to ‘new and potentially expanded primary schools with delivery linked to an overall delivery timetable (to be determined through the masterplanning process). The IDP refers to the provision of 4x2FE primary schools, with the first being available from Sept 2025. Given the lack of clarity on this matter we would recommend further consultation with KCC on the educational requirements within Paddock Wood as a matter of urgency as this needs to be resolved and factored into the next iteration of the VA and future framework plans.

[TWBC: see full representation].

DLP_5332

Nick and Hilary Andrews

We are writing to object to “The Strategy for Capel Parish” (Policy STR/CA1) and to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1-1 & PW1-2).

Our property is an old house, set within an acre of land surrounded by PW1-2 fields. Our children were born and brought up in this house and attended primary and secondary schools locally. Whetsted is a small hamlet, on the outskirts of Five Oak Green; a vibrant village with a hugely strong community, a true neighbourly structure with a village fete and procession (since Victorian times), Gardeners shows, youth organisations, sports and social clubs and a widely used village hall for various functions and clubs.

One of us works full time in London so uses Paddock Wood station 5 days a week mostly getting to the station by bicycle. The other works in Kent and the South East, travelling by car and train to London.

Please add our contact details to your consultation database so that we can be kept informed of all future consultations on Planning Policy documents. We understand that our comments will be published by the Borough Council, including on its website.

The Local Plan

It is worth noting that the whole plan has been produced by TWBC over many months, at significant cost to the tax payer, produced in secret with Non Disclosure Agreements applied and yet its contents include many factual inaccuracies and certain reports and details upon which it has been based and with assumptions missing. It is amateur in its execution. The TWBC method of delivery to the tax paying public does not conform to their statutory duty as detailed in the seven principles (and elsewhere) in the TWBC Code of Conduct http://democracy.tunbridgewells.gov.uk/meetings/documents/s42969/Part%205%20-%20Codes%20and%20Protocols%20-%20April%202019.pdf. That can be deemed to be because TWBC do not want dissent, challenge or proper discussion. It is odd that the combined plan of CA 1 and PW1 were not the original preferred options but suddenly became so and the plan was therefore rushed by TWBC. It is also odd that the construction companies were granted options to acquire the land in both sites before the Plan was made known to the public (TWBC should also be aware of the insider trading rules for any listed company granted an option and implemented its suitable measures to ensure this could not have happened).

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.

Transport

It is apparent that the proposed garden village and the East Capel site for circa 4500 houses (approximately 13,500 new residents with likely 2 cars per household making circa 9,000 additional vehicles in the two proposed sites) is ill thought through. The majority of the proposed housing will be to create dormitory towns for people to work elsewhere, be it London by train or in neighbouring towns by car. The type of house proposed is not being built for the local workforce who could bicycle, walk, bus to work and so two cars per family is likely to be the norm. Two cars per family unit is at the low end of the number of car movements being created.

The sheer volume of additional traffic that will need to move through the sites to their places of work and leisure will simply destroy the existing Parish of Capel making one major conurbation of Paddock Wood, Five Oak Green and almost joining Tonbridge. Its impact on the irreplaceable Green Belt will be wholly destructive both from the local point of view but for miles around as it is visible from the North Downs and the surrounding countryside that overlooks it.

The input of new roads will not alleviate the traffic that will need to either drive to Tonbridge or Paddock Wood station (carparks at capacity already) or to Tunbridge Wells or Tonbridge for shopping. Road links into both are at capacity and both towns suffer from standstill traffic jams at all times. Dumping the traffic onto neighbouring towns is causing additional problems.

Proposed schools and other infrastructure being added will also increase traffic problems. The impact on the neighbouring Borough councils is equally horrendous with the main thoroughfare to Tonbridge being overloaded and blocked for most of the time at peak times (Five Oak Green Road, Woodgate Way, Vale Road and Cannon Lane). There is no capacity for further vehicles through Tonbridge or to Tunbridge Wells.

People living in the Tudeley garden settlement will use Tonbridge Station for commuting and Tonbridge town services and 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. Parking in and around Tonbridge Station and further afield in Tonbridge residential streets will be even more difficult. Network Rail have confirmed that a station at Tudeley is not viable and so will not be built in this plan. Most people living in the proposed sites will drive privately owned cars, despite initiatives to encourage bus and bicycle use. Other sites with bus and cycles initiatives have found they simply do not work for volumes of people and they fail. The costs of infrastructure on the Tonbridge & Malling side of the boundary will be a burden  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.

Tonbridge is already experiencing the problem of commuters driving to the railway but having to park elsewhere (either for cost or space issues). Yardley Park is a prime example with some of the residential streets being used for commuter parking despite it being circa a mile from the station. Yardley Park itself is now used for parking for commuters who drive there and park to catch coaches to London. Using this as an example of the unintended consequence of such an enormous influx of housing, Paddock Wood will be turned into one large carpark with all residential streets used for commuter parking. The problem in Tonbridge will exacerbate from what it is now and similar issues for areas around Tunbridge Wells stations.

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.

The proposed sites are either bordered by a train line or the line cuts through it. This is a two line track, one up/one down to London and Dover. This train line is at capacity for the number of trains that run upon it. Paddock Wood has two trains an hour to London outside of peak times and during peak times there are three. Peak trains are full already and out of peak are often full too. Any large influx of commuters from Paddock Wood will increase the volume to ensure that peak trains are standing only from this station (which happens already). Bear in mind that large new sites further down the line are being built and each of those are proposing that commuters use the self same trains to get to London. That influx of “down the line” potential commuters from the new sites has not been factored in the Plan. Other sites, not necessarily in station stop villages (eg Horsmonden), are also proposed where the nearest stations are on this railway line. Paddock Wood station is one of them. An influx of hundreds, if not more cars into Paddock Wood, will have to park on the residential streets (generally narrow) to the detriment of the existing residents and any potential visitors to Paddock Wood.

Floodrisk

We have lived on the very edge of site PW1-2 for nearly 30 years and know the area very well. Our house is old and built on the only slight rise in elevation of land in East Capel and has not flooded during these years. However, the risk of flooding of our property has noticeably  increased during this time; our garden and lower lying land nearest PW1-2 floods on a  regular basis every time there is heavy rainfall. The farmland in PW 1-2 is surrounded by large and significant ditches that have been there for years to drain the land for agricultural purposes. They have generally worked assuming the ditches towards the Medway are kept clear. Flood water soaks or drains towards the Medway.

PW1 is a floodplain (the whole site is). The fields in PW 1-2 are waterlogged in the winter with three fields in particular being perma-flooded during a typical wet winter. There is very recent evidence (that has been ignored in the plan) that this area floods and insurance for local properties has risen significantly. We also note that a mortgage application for a property in Maidstone Road, Paddock Wood (near Baxalls) was declined due to it being a flood risk. Therefore simply building and hoping that mortgages are attainable is nonsensical – each mortgage application will need to advise the lender they are in flood plains/areas of flood risk and floods have occurred regularly, (to not advise the mortgage lender is of course fraudulent and renders any insurance payout as nil). Insurance premiums and cover for residents currently in the area who have experienced flooding, is substantial if available. Some properties currently very near the proposed plan area have been required to build dykes, reservoirs and pumping stations simply to obtain insurance cover.

Large parts of the proposed developments will be on the Medway floodplain with flood risk assessments based on old data that do 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 increase flooding not only in Capel but in Golden Green, East Peckham, Tonbridge and Yalding.

The concept of flood run off water has not been satisfactorily evidenced. Water has to go somewhere and quickly; covering the land to stop it absorbing water speeds the run off towards the Medway, the natural drain for the whole area. Whatever plans there are for flood prevention will not be sufficient without sacrificing either the houses proposed on PW1/CA1 or those downstream at Yalding and ultimately Maidstone. Again, a problem that has been dumped on a neighbouring council.  Flooding is a problem that does not just disappear and will get progressively worse with rising water levels/climate change. We are of course pleased that the TWBC Head of Planning verbally “guaranteed” on behalf of TWBC at the May 2019 meeting of residents of Capel that no residence in the proposed sites will flood; this is a contingent liability that TWBC will have to manage through their balance sheet in terms of provisioning for future flood risk.

In the PW1 Area, the current water table is approximately 18inches below the ground level, this is typical for the time of year and it rises rapidly in time of heavy rain. That water table is closer to the surface in some of the fields. Certainly this accounts for the waterlogged fields that have water lying in them now (at time of writing) despite the winter not yet starting. The B2017 Badsell Road to the East of the A228 is regularly flooded (as was the case on the 11th November 2019 at 6.30am).

A neighbouring council (Nettlestead) recently declined a new property building application on the basis that it was likely to flood and would need to be built with the ground floor at least 2 meters above current ground level – that proposed property is in the run off area near the Medway which would drain the flood waters from the Tudeley/West Paddock Wood sites. That council knows the implication of future flood risk.

Agricultural Land and the Environment

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.

Land PW1-2 is a good site for stargazers and astronomers as there is currently little light pollution. This will undoubtedly lost if the proposed development goes ahead. Light pollution will also have a negative effect on the nocturnal wildlife (some of which are protected by law).

The Plan has incorrect data as the quality of the agricultural land in PW1 and is not the lowest grade of land. This is simply wrong on behalf of the planning department of TWBC and must therefore call into question other factual errors upon which decisions could be made in this plan.

Heritage and Ecology

Both sites, together, form part of the best preserved medieval farm land which is visible from the higher surrounds both to the south and north of the proposed sites and in area of Green Belt.

Running across PW1-2 are the well preserved remains of an ancient drovers road that used to criss cross the old woodlands of the weald. It is potentially the best preserved such road in the area. It is also a wild life haven. It is lined at the western end by 30 oak trees and at the eastern end where the road itself is not well delineated (towards Baxalls) by a similar number of oaks. Furthermore, there is part of the last remaining oak woodland from the ancient forests in PW1-2; these have been undisturbed for hundreds of years and should remain as a precious and rare ecological habitat.

We are aware that TWBC attitude to old oak trees is that they are capable (at significant cost) of moving them and their attempts to do this in other areas of development has ended in woeful failure as the trees died. If the oak trees die, are moved, cut down, we lose one of the richest habitats for wildlife where each oak tree can support many hundreds of different species that are important to our ecology.

These lines of old trees provide the natural space for a variety of birds and mammals to thrive. The local Bat Conservation group have recorded five or six species of bats in the two parts of this line of trees. These trees are therefore protected in law by being bat roosts and the pathways where the bats have been recorded feeding are also protected in law. This has not been taken into account with the proposed carpet development devastation of PW1.

Furthermore the wildlife that have been recorded in the fields and trees in PW1 include

Buzzard
Sparrowhawk
Kestrel
Red Kite
Tawny Owl
Barn Owl
Little Owl
Carrion Crow
Jackdaw
Magpie
Jay
Lapwings
Sky Larks
Blue tits
Great Tits
Long tailed tits
Sparrows
Gold finches
Song thrush
Mistle thrush
Starling
Wood Pigeon
Ring necked doves
Great spotted woodpecker
Green woodpecker
Nuthatch
Blackbird
Starling
Heron
Wren
Ducks
Pied wagtail
Cabbage white butterfly
Orange tip butterfly
Blue moth
Red/black moth
Deaths head moth
Red admiral
Peacock butterfly
Painted Lady butterfly
Grass snake
Adder
Brown newt
Toad
Frog
Weasel
Badger
Fox
Various types of bat (difficult to identify, but potentially 6 type according to local bat group)
Rabbits

For which it is noted, a good number are protected species. The exact nesting sites of some of the birds are well known and the oak trees alongside the above mentioned drovers road, are primary amongst them. Tudeley Woods is also an area of untouched wildlife with ancient oaks supporting many indigenous species.

Consequently, building on PW1 and on CA1, on green belt, will destroy a significant habitat for such indigenous species of wildlife. The previous methods of TWBC in respect of wildlife is that wildlife will “transfer” to a different habitat if a development goes ahead. This is simply nonsensical as habitats are unique to the wildlife residents and they do not move, they die out and very quickly. TWBC allude to the fact that wildlife will simply seek similar specific habitats (such as old oaks, indigenous woods and hedges etc) and survive. Tragically, this ineptitude has been seen in their past record causing the destruction of the wildlife they were “protecting” – it cannot be allowed to happen again.

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. Recent research shows the importance of hedgerows rather than fences for wildlife; this has not been included within the plan and should be made mandatory.

Putting housing alongside Tudeley church in CA1 will require the windows to be screened from the outside to protect them from the higher risk of accident, vandalism, and theft (refer to recent press reports of stained glass stolen to order).

As mentioned in the first paragraph of this objection, the community of Capel Parish is vibrant, inclusive, and cohesive. The proposed developments included for Capel Parish in this local plan will simply destroy this community.

Employment

The Plan envisages creating employment opportunities by building the facilities. This has not been defined as to what is proposed to be built but whether it is warehousing or office blocks, neither create local jobs meaning they will not be accessible by bicycles, walking, scooters or even buses. Workers drive to work rather than live locally/travel to work by bus/bicycle. This will create yet more incoming traffic from surrounding areas whilst residents will also be leaving the area to their jobs, schools leisure facilities.

The volume of car, van and lorry journeys will increase exponentially the pollution, air quality, noise levels, and so on.

Housing

The numbers of proposed houses has been calculated incorrectly using old data and with incorrect projections based on wrong assumptions. The housing needs 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 does provide, particularly in PW1 with housing that could be built within any housing estate in the country and takes no account of the local and traditional style of houses. Estates of this nature are monotonous and as have been seen in the large construction company builds, usually of poor quality with cheap materials (noting that new houses are not subject to the Sale of Goods Act so post sale problems are covered by NBC warranties). The requirements to build as much living space in each property means that additional storage of household items will require secure storage sites to be built (as can be seen by the increasing rise of this industry providing prefabricated sheds of significant size to provide storage). These will need to be placed somewhere creating yet more traffic journeys, ugly eyesores and more pollution etc.

The affordability nature of the houses has not been defined as to what will be built. They are certainly not proposed to be properties for first time buyers of social housing so the majority will be standard housing. This reinforces the fact that they will be built as dormitory’s rather than creating any sort of village or social aspects to them.

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 and Maidstone .

Brownfield Sites

The plan has not considered existing brownfield sites in the borough, the potential for alternative types of build (ie zpods), empty properties in and around the towns etc. The figures by TWBC as “needs” does not make sense with government guidance and have not been satisfactorily justified by TWBC.

Infrastructure

The plan has not shown where and how fresh water will come from to be used in either site (a new reservoir will be needed), where the sewage farm will be located (Tonbridge is at capacity) power supplies originate from (can the existing National Grid infrastructure in the surrounding areas support the influx), telephony including mobile masts need to be provided, police station and so on.

To locate a school on the boundary of Tonbridge where the access road is the primary bypass for vehicles from the west of Tonbridge to the east of Tonbridge will create gridlock beyond the current traffic jams. Having children crossing there will be a tragedy waiting to happen, let alone the increase in accidents.

Greenbelt​

This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel. The comment above about coalescence and the creation of a conurbation from Paddock Wood right across to Tonbridge is very relevant here, as is the land’s use as a flood plain. Building here, even with flood risk mitigation and “betterment” could have disastrous consequences for all, as the measures being looked at are based on old data that does not fully consider the impact of climate change.

Bribery and Corruption Act 2010

It is also worth reminding the TWBC and its CEO of their obligations under the 2010 Bribery & Corruption Act and to ensure that any suspicion of such criminal activities are reported to the authorities appropriately and whistleblowers suitably protected. The property and construction business is generally considered high risk under this legislation. The CEO and Cabinet Members must be able to justify to us, the taxpayers, that they have very strong and robust systems and controls to ensure that there is a zero tolerance to bribery and corruption. Any such issues of impropriety in this area within TWBC should be brought to the attention of any Inspector in the future review of this plan.

DLP_5341

Colin Hussey

My name is Colin Robert Tarver HUSSEY,and I am aged 62, and the owner/occupier of XXX, Hadlow Road, Tonbridge, Kent XXX in Medway ward [TWBC: House number and postcode redacted].  I was raised and schooled in Tonbridge and have been resident here on a continual basis since 1962.

I wish to draw your attention to my comments upon the Tunbridge Wells Local Plan, but more especially to the proposed developments in respect to a new Secondary School at Tudeley Lane (B2017) and Woodgate Way (Tonbridge) and 2800 homes on 600 acres of agricultural land commonly known as 'Tudeley New Town' subject to STR/CA1 and also to East Capel subject to STR/PW1.

My primary objections to these proposed developments are because the said developments are planned to be built on designated Green Belt land, on prime Agricultural land, on designated Flood Plain, lack of road infrastructure and Housing Need.

First and foremost these proposed developments are supposed to be part of the Tunbridge Wells Local Plan, and whilst I accept that the villages of Tudeley, Capel, Five Oak Green, and the town of Paddock all fall within the boundary of Tunbridge Wells Borough Council, the main settlement which will adversely be affected by these developments is Tonbridge itself.  Whilst I accept that there is indeed a national housing shortage which needs to be addressed, and that each council area has to build a specific number of new homes in their area, including within the Tunbridge Wells Borough Council, that need should be evenly built across the Borough, and not concentrated in one specific area, and one that is nowhere to the town of Tunbrdge Wells itself.  Personally I am not convinced by central government inspired housing targets, this should be driven by local need, and is there a need to build this amount of housing.  However we are where we are, but some common sense surely has to be applied to these plans which seems to be severely lacking in this particular case.

As I understand it, the creation of the Green Belt policy in the late 1940's was designed amongst things to prevent unrestricted urban sprawl of large built up areas, and to prevent neighbouring towns from merging into one another.  If these plans are allowed to proceed it will result in a continuous ribbon development between Tonbridge and Paddock Wood, which rather defeats the object of the Green Belt.  Surely the quality of life of the existing residents of these villages and the small town of Paddock Wood and Tonbridge itself has to be taken into consideration.  The building of 2800 homes will surely equate to a population growth of anything between 5,600 and 11,200 persons assuming that between to two and four people live in each house.  When one considers that the average household now owns two motor vehicles each, potentially there could a further 5,600 extra car movements per day on the present road infrastructure, and lets face it as it currently stands the road that traverses the development area is of 'B' road classification.  When one considers the fact that Tonbridge has been a dormitory commuter town for some considerable years now, where a considerable number of residents travel daily up to London to work, I think it is a reasonable assumption that the residents of  these proposed developments at Tudeley and Capel will do likewise.  The lack of parking is already an issue and likely to exacerbated by these proposed developments which are in close proximity to Tonbridge, not to mention the already trains which are already running to full capacity.

I assume that the land on which these proposed developments are to be built is just confined to residential development and not for employment use. if that is the case the majority of these residents will be driving into Tonbridge on already unsuitable roads into a town which is already at saturation point in terms of road use. I also assume that they will also be doing their daily or weekly shopping within Tonbridge town centre where there are presently 4 plus supermarkets.  I live on Hadlow Road (A26) which already experiences heavy traffic throughout the day from about 06.00 am to 9.00 pm.  Rush hour traffic queues already extend from the HadlowRoad/Cannon Lane junction to way beyond the roundabout junction with Woodgate Way and sometimes as far as Sovereign Way. This will only worsen if these developments get the green light.  Tonbridge High Street is already clogged with traffic throughout the day during the week but worse at weekends, even though some pressure is alleviated by the presence of the Cannon Lane mini bypass. Everything including the lack of parking places will be made that much worse if these developments get the go ahead.

Also the proposed development of a Secondary School in Tudeley Lane junction with Woodgate Way is the most inappropriate location in my opinion.  One assumes that the majority of the pupils attending the school if built, will travel by train as do quite a number who attend schools in Tonbridge. The distance however between Tonbridge Railway Station and the proposed new school is quite considerable and getting there by foot will entail a fair amount of danger to those attempting it, due to the nature of the very busy roads.  If the pupils were to travel by car again we are talking about extra congestion on an already over burdened road network.

The other objection that I have to these specific developments is that they are to be built on prime agricultural land.  Whilst I appreciate the land is not Grade 1 they are nevertheless a mixture of Grade 2 and Grade, and it is important that the land is retained for agricultural purposes.  We simply cannot go on building on agricultural land no matter grade it might be, especially in a country like ours which has a rapidly expanding population largely due to our continuing membership of the European Union with free movement of peoples etc.  If we do then we will surely come to a point in the not too distant future where we wont be able to feed our own population.  Apart from this, Tudeley, Five Oak Green Green and Capel is part of an area which is of outstanding natural beauty which needs to be conserved for future generations.  Once it is gone, it is gone forever.  Where possible these type of developments need to be concentrated on brownfield sites not on the Green Belt.

One last point, I have read somewhere recently that Kent County Council might be willing to share costs with the developer insofar as infrastructure costs are concerned.  Most definitely not. the local taxpayer should not have to accept this burden in part or otherwise.  Section 106 of the Town and Country Planning Act needs to be rigidly enforced here, whereby the developer(s) should burden the whole cost of infrastructure works.

DLP_5368

Joseph White

Paddock Wood Expansion – 2019

There should be no more house building around paddock Wood for the foreseeable future for the following reasons:

1) These houses will not be for local people, we do not need them.  They will be for outsiders, most probably Londoners.

2) There are not enough jobs in the area, they will most probably work in London.

3)  let London solve its own problems.

4) There is not enough perking in the area to support commuters.

5)  Car use will increase pollution to the detriment of the environment and the health of residents.

6)  The country needs the fertile Kent area to grow food.  Housing takes away the agricultural land forever.

7) Building houses should not be allowed to enrich a company who have been acquiring farm land around the area.  Questions should be asked about the reasons they have been som much land here.

8) There are questions over the availability of suitable sewage and drainage facilities throughout the area.

9)  The influx of so many additional people will destroy our community and rural way of life.  Nobody has the right to destroy our way of life to meet their political objectives.

10) Many houses are proposed to ease the shortfall in Sevenoaks.  Let Sevenoaks solve its own problems.  We should not be made to suffer because they cannot or do not want to solve their problems.

11) There is an old saying, not in my back yard.  What the Council is doing is dump their problem on somebody else’s back yard.

12) The Government has caused the shortage of houses by allowing millions of people to come into the country over the last seventy years.  The country does not need them oir their future offspring.  Working efficiently, effectively, training the existing population and paying descent wages would resolve most labour difficulties. Government is just overpopulating our small island and creating an even greater problem for the future.  What is needed is less people in this country and in the world.  It is the number of people on this plant that is the cause of all the environmental problems in the world.  The Government has its priorities wrong.  The Government should be required to solve the problem they have caused, not put a sticking plaster on it by building more houses.  The Government should answer on simple question, what are they going to do when every square meter of our country is built on?

13) The Council did not listen to the people when they were told residents did not want the last batch of houses approved.  If the Council will not listen, they should remember who voted them into power.  The Council and the Government can easily be voted out.

14) Now encroachment on the Green Belt is acceptable.  The Council take a little bit, then another, then another.  Soon there will be none left.  Green Belt building is unacceptable under any circumstances.

DLP_5385

Mark French

I live in Tunbridge Wells north near High Brooms station and my children attend local schools in the borough. My son is at The Skinners' School and my daughter is due to transfer to secondary school in September.

My address is xxx TN4 [TWBC: full address redacted].

My comments refer to Tudeley and Capel draft local plans. STR/CA1 and STR/PW1.

My concern is regarding the road infrastructure locally. I used to work in Hadlow and drove the A21 and Hartlake Road each day on my commute. The roads suffer congestion by Somerhill School and i feel that a new secondary school by Woodgate Way is needed but a new relief road would be required and dual carriageway ideally. I also feel that the railway bridge on Hartlake Road needs widening and a roundabout on Tudeley Road/Hartlake junction. The A26 into the Tonbridge industrial estate would also need to be widened to include a bus/cycle lane. Tudeley Road should be expanded with a cycle way and a proper pavement/bridleway etc. the road is poorly lit and can be dangerous in bad weather.

Train services also need improving in the borough and Tudeley should get a new train station with this many new homes proposed in Capel and Tudeley. I use the trains most weeks to commute to London for business and i now tend to travel after 9.20 to get a seat at High Brooms. High Brooms is very busy but still has poor parking and poor access to the south bound platform. The station needs a car park second tier and lifts for disabled commuters. Toilets would also be good!

My final comment is that new houses and businesses should be built on the A21 bypass at Castle Hill. You have the old Balfour Beatty construction sites on each carriage way plus a new junction and are ideal locations for new homes and ideally some more businesses/offices. The old A21 Shell petrol station was never replaced and we need another service station on the A21. You have Kent College locally but we should also build another school near Knights Wood and Pembury hospital. SKA is full and that end of Tunbridge Wells does not have enough Secondary school options. All the schools are near St John's Road and causes congestion on the A26 every day. New houses should mean more jobs as well for local people and we do really need a better hospital at Pembury with more parking and more specialist services offered.

I appreciate we need new homes and more local businesses but roads and schools need to built first plus the hospital expanded in Pembury. Tunbridge Wells West station should be reopened and BML2 built to give another route into London each day.

DLP_5399

Tara Stanley

I am writing to object to parts of the Tunbridge Wells Borough plan and with particular reference to “The Strategy for Paddock Wood” I believe this to be covered by Policy STR/PW1 (& AL/PW1)

I live in Paddock Wood and enjoy the countryside and regularly walk the footpaths and fields of Paddock Wood and Capel.

This plan is as damaging and inappropriate and results in the present Paddock Wood being surrounded by a further “belt” of concrete.

The Council has not identified or allocated all brownfield sites (contrary to Government guidance).

Of its total housing requirement (a figure that isn’t accurate or required) the new housing for Paddock Wood and Capel amounts to around 65% of the total “need”. This isn’t planning at all. Just imagine if that had been proposed for other parts of the Borough!

The plan will mean virtually unrestricted development from well to the east of Paddock Wood through to the new proposed school at Somerhill (Policy AL/CA 2) on the fringes of Tonbridge. It will also require a huge upgrading in transport infrastructure (roads) including re-routing the A228 through an AONB and then a spur further bisecting Capel to join to Tudeley New Town. It also appears to be turning farm tracks in Paddock Wood (north of the rail line) into roads, further destroying any illusion of countryside. The cost of the roads and their future maintenance will be enormous.

With roads being the greatest expense in infrastructure terms it is clear that the A21 corridor and Knights Park/Longfield Road or Mabledon offer far better alternatives with immediate and easy access to the A21.

Offers by landowners along and adjacent to the A21 and elsewhere were not taken forward. Why?

Paddock Wood rail station Tonbridge rail station will be inundated as the effects of developments from Ashford to Tonbridge take effect with no new stations possible and little additional capacity available with London stations already at or near capacity.

Much of the land in Paddock Wood (Policy AL/PW1) is in a flood plain and no amount of mitigation measures and “betterment” will resolve that. I consider that little or no account has been taken of the severe weather implications of global warming/climate change.

The Planning Officer and Councillors will probably not be around to see the consequences of this folly. The large parts of Paddock Wood in this plan are in known flooding areas and is a major reason why no development has taken place in parts of the town before. It is difficult to understand how covering the land in concrete is going to help this floodplain.

Throughout this plan there are repeated references to masterplanning. In my view there is nothing that such planning (whatever that means in practice) can do with a plan that is ill conceived.

It is also important to note that the large area of planned development will result in Paddock Wood being entirely joined to Five Oak Green (Capel) as a built-up area.

The massive housebuilding proposed in Paddock Wood and East Capel will create considerable traffic and parking problems in Paddock Wood and will cause unresolvable problems at Paddock Wood rail station where peak time trains are already at capacity. This plan doesn’t even include over 700 of the houses with planning permission already given in Paddock Wood. The plan refers to improving parking at PW rail station. With around 5,000 new houses within a mile of the station and little space available that will be interesting to observe. The retention of 2 car parks in Commercial Road doesn’t help much as they are already there and regularly full!

I wonder how the medical services will cope with this onslaught? The population will more than double. There are significant issues with finding GPs in Paddock Wood and Capel and the local hospital is already over-stretched. The Planning Officer advised that this isn’t within the planning remit – so that’s alright then.

TWBC's Issues & Options Consultation report in 2017 recommended spreading new housing across the borough with alternative garden village sites outside of the green belt identified augmented by areas along the A21. More suitable alternatives appear to have been discarded.

DLP_5409

Mr & Mrs N Starritt

OBJECT TO THE INCLUSION OF LAND IN EAST CAPEL IN "THE STRATEGY FOR PADDOCK WOOD" (Policy STR/PW1).

This land is Green Belt land and should only be built upon if "exceptional circumstance" exist.  TWBC's own assessments in their Sustainability Appraisal showed that Paddock Wood can expand and meet most of the plans aims without using the Green Belt land at East Capel.  The comment above about coalesce and the creation of a conurbation from Paddock Wood right across to Tonbridge is very relevant here, as is the land's use as a flood plain.  Building here, even with the flood risk mitigation and "betterment" could have disastrous consequences for all, as the measures being looked at are based on old data and does not fully consider the impact of climate change.

DLP_5701

Mrs Jacqueline Cobell

They call our beautiful countryside Royal Tunbridge Wells.

Because Queen Victoria loved visiting our Town, and the beauty that is The Garden of England.

She would be turning in her grave, if she knew the bulldozers were running riot on our green beautiful fields, ripping up ancient woodlands, our little creatures running for their lives, their habitat gone forever. And once the concrete is laid, the fertile land is gone forever.

We Love Where We Live. We Love Our Friendly Community.

This plan will devastate so many passionate villagers.

We love where we live, we marvel at our Area of Outstanding Natural Beauty.

We are blessed that we live here.

But it all changed in May 2019. Imagine our shock and utter dismay when we learnt of a New Town envisaged to swamp our little hamlets. Tudeley a quaint picture book of Oast houses and historical timbered houses, a world renowned ancient church bearing every window painted by the Russian artist Marc Chagall. Folk come from all over the world to love and appreciate these great works of art, commissioned by Lady Goldsmith in memory of her beloved daughter who died tragically.

The peace, serenity and magical light surrounding our little church will be lost within a mass of ticky  tacky homes thrown together in great haste to earn the greedy developers more money. Talking of greed  TWBC will be earning millions in Poll tax.

Perhaps other sweeteners as well . ......

So the call went out for landowners, better and cheaper for the planners and council to make deals on Greenbelt. There are 109 Brownfield sites in Tunbridge Wells, so we were told by Steve Baughen  Indeed a big brown site is dead opposite TW town hall ! 18 years a brown field site . Homes could be built there !!!!!!

Looking at the draft plan, it is a dire project glued together by planners that haven't got a clue. They say that's it's a government initiative / necessity that we need 4,500 houses. That's just poppycock. Yes homes are needed, but planners want to put them in our village because they have one big landowner offering it all on a plate for an exorbitant amount in one foul move. This is lazy planning, and bad planning !!!

The above is why I sincerely  and deeply object to the proposals for sites CA1 and PW1.

Comments on the introduction Plan preparation process para. 1.4  p.13

The issues and options process 2017 mentioned a garden village but with no location.

All of a sudden in mid 2019 its much more than a village set in Tudeley smack bang in the middle of the green belt which is contrary to the issues surrounding the protection of the green belt.

ACTUALLY I OBJECT TO YOU THREATENING TO IGNORE MY COMMENTS IF I DON’T RELATE EACH COMMENT TO A SPECIFIC SECTION AND PARAGRAPH. BEARING IN MIND THAT YOU SHOULD KNOW YOUR DRAFT LOCAL PLAN LIKE THE BACK OF YOUR HAND YOU SHOULD BE ABLE TO RELATE ALL MY COMMENTS TO YOUR SECTIONS AND PARAGRAPHS.

THIS OBJECTION LETTER THAT WE ARE SUPPOSED TO WRITE ON YOUR TERMS IS INTIMIDATING, CONDESCENDING, AGEIST AND DONE ON PURPOSE TO CONFUSE THE ORDINARY FOLK. HUMANITY IS THE GREATEST QUALITY THAT MAN CAN HAVE, ARROGANCE IS UNDOUBTEDLY THE WORST !!

I’M SURE MY FRIEND AT THE BBC WILL BE VERY INTERESTED TO KNOW HOW THE NUMBER OF OBJECTORS HAS BEEN KEPT LOW DUE TO THE HOOPS AND HURDLES THAT THEY HAVE HAD TO MEET TO AVOID BEING IGNORED 

1. A Garden Village is defined as a place where local people can live and work.

This New Town will become a  hub for commuters working in London, not for our local folk.

2. There is not a need for all these houses for local people. The birth rate in the Tunbridge Wells area is declining.

3 . Why vandalise our Greenbelt and Areas of Outstanding Natural Beauty, bulldozing fertile productive land, when brownfield sites are available ( according to Steve Baughen at the first meeting in May )

4 . The proposed building site of 600 acres is on a flood plane .

Recent houses built in our Village had to have tanks built under their foundations to take up flood water. This means all new houses will have to have the same measures built in. But as developers are self regulating, they won't go to this expense!

5 . Our village has flooded badly at least three times. Councils oppose concrete drives that are non-porous. So what is 600 acres of concrete going to flood. Capel !!!

6 . 4.500 homes will each own 1 or 2 cars. Our country roads are not fit for purpose now, let alone another 6000  or more vehicles in and around the Tonbridge area. This will create massive traffic Jams. It takes half an hour now in the rush hour to reach the roundabout at Woodgate way . Mainly because of Sommerhill School .

7 . The new secondary school opposite Sommerhill will create even more traffic chaos. The school will be divided by the Railway line. This will not be safe !!!!

8 . The New Town will be divided by the Railway Line !!!

9 . Tonbridge Station , the carparks will not handle the extra volume .

The Trains are overcrowded to bursting point already .

10 . The proposed new roads will destroy great swaths of Greenbelt , perhaps even homes compulsory purchased . The Medieval Church of Thomas - a - Becket

And the surrounding countryside will be ruined forever .

Do we not have any pride left in our heritage historic buildings left ???

11 . Global Warming . Chopping down hundreds of trees has a negative impact on purifying Carbon Emissions .

12 . The River Medway will be even more polluted . Mussels that once were along all the River banks have all but died because of pollution .

The River Medway runs into the oceans . More pollution and plastics in the Sea . I was given the opportunity to swim for a short while with Lewis Pugh, the United Nations Patron of the Oceans, as he swum the length of the English Channel last year to highlight the pollution in our rivers and oceans

13 . There will be even greater burdens on Pembury Hospital . doctors surgery , dentists etc etc . Tonbridge has not the Infrastructure  to cope with all the extra folk the commute on its roads and services !!!

14 . Why build on Greenbelt and Areas of Outstanding Nature Beauty , when a Site in Horsmonden or in fact the A21 corridor has none of these ???

Perhaps councillors or planners live near there ?

15 .  . Where is the democracy??? How dare you run roughshod over 2,000 folk whom have made their lives here . We love where we live . We  choose to live in a village to bring our kids up in away from Towns and the inner city's !!!

16 . While the Landowner may make a billion pounds ..... we are losing millions , our homes blighted by this awful Town as big as Kings Hill swamping our 900 homes

Remember Kings Hill was built on a Brownfield Site . And it appeared to be getting bigger and bigger ! In fact , any green spaces have been built on . Just like at Holborough lakes , whereby the divers and swimmers car park has been built on .

Many people enjoyed diving and swimming . They have been denied a healthy pastime , because of greedy developers .

I sincerely hope that you and the planners see sense and decide to stop this folly of a new town in one of Kents most beautiful low wealds that has hundreds of years of history and has truly  majestic buildings.

DLP_5703

RW & SE Weale

Please find attached the map of land which we would like to put forward for consideration, you will see that there is a section in red which encompasses our house, garage & garden of approximately 3/4 acre which we are not putting forward.

The approximate amount of land available is 11 acres with road frontage to Mile Oak Road & Knowle Road.

The land marked in red is owned by us RW & SE Weale, with no mortgages or debts on the land.

DLP_5713

Jacky Burrell

I live in East Peckham and drive to Sevenoaks each day.  I am most concerned about the expected increase in traffic on the road through Golden Green and Tudeley and the impact on the existing traffic queues from the end of Hartlake Road, along the Tudeley Road and all the way along the A26 to the Vauxhall Inn roundabout especially during the morning rush hour.

I believe the flood risks will increase.   Covering farmed fields with houses and roads will cause increased flood risks  across Tudeley,  Golden Green, East Peckham, Tonbridge and Yalding.   There will also be an increase in air, light and noise pollution and create a visual scar across our beautiful landscape.

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

DLP_5715

SJM Planning for Mr and Mrs Smith

We would like to submit an additional site for consideration. Mile Oak Stables, Mile Oak Road, Paddock Wood, Kent. The parcel of land in question would be south of, and East of, existing and proposed housing allocations. Whilst being outside the MGB, AONB and Flood Zones, it could provide further ribbon development in keeping with the vision for this part of Paddock Wood. Site access could be safely achieved from the Northern end of the site, where there is already an existing access. A second access has also been permitted further south on the same parcel of land. We have appended an approximate plan for the allocation of 12 dwellings, though consideration should be made regarding the location of accesses toward the southern end of the site. An alternative proposal would be to allocate the land for residential park homes, much in the same vein as Five Furlongs Caravan park. This development could extend further rearwards and incorporate landscaping and ecological enhancements. We envisage approximately 22-25 park homes on the site.

We are currently undertaking a pre-application enquiry for the above site and my client has approached me regarding a submission for the call for sites for housing

The existing site has 1 No. G&T site but the remainder of the land is owned by the same applicant on a freehold basis.

We have seen that land is being put forward to the North and West of the site for housing allocation. Site numbers 344, 48 and 26 are all adjacent to the site.

The site lies outside the LBD, but is not within the Green Belt or High Weald AONB. Furthermore, there is no flood risk on or adjacent to the site.

My client would like this site put forward for consideration during the site allocation process. Our suggestion is for either a linear form residential development, or more extensive Park Home development, much akin to Five Furlongs in Queen Street or Newbridge Park in Maidstone Road, providing more affordable accommodation for those wishing to downsize and remain in the area.

There are a number of existing planning applications for G&T sites across the borough so the site could either be relocated within the site (Envisaging a linear form of housing development in the same vein as the existing Catts Place Cottages) or elsewhere within the Borough.

DLP_5725

Julie Sanders

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel.

In conclusion, I feel that the building of nearly 4000 houses in this area of Green Belt Land will destroy an area of outstanding natural beauty in an idyllic area of Kent. The very special landscape, ancient woodland and fertile farmland will be lost to future generations. The increase in traffic, pollution and heightened risk of flooding in the wider area will completely outweigh any short term financial or social gain from increased housing, and there are better , more sustainable areas within TWBC that can be used for this purpose

DLP_5731

Roger Worraker

Dear Local Plan team

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

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

I live in Five Oak Green and for the last 50 years have travelled through Tudeley on my way to Hadlow and surrounding fruit farms in the area.

I am therefore fully conversant to the area surrounding Tudeley and the proposed areas of development. I object to the plans for many reasons:

1) It will destroy a large area of farming ground.

2) It will destroy an area of outstanding natural beauty.

3) It has always been a pleasure to travel to Tonbridge from Paddock Wood and Five Oak Green as well as Golden Green and Hadlow. This will no longer be the case.

4) I have experienced the occurrence of flooding in Five Oak Green and am concerned that the proposed development will increase the risk of future damage to property.

5) The dramatic increase in property will mean the traffic flow through Five Oak Green and Tudeley and the consequent road traffic risk.

DLP_5760

Bruce Burdett

I strongly object to this proposal.

My key concerns are;

1. The A264 road between Paddock Wood and Tunbridge Wells is already is already at saturation point. HGVs between Paddock Wood and Pembury make this narrow road dangerous. The plan will only encourage even more traffic onto the the A264/

2. The land is Green Belt and open countryside and must be preserved as such. The new Prime Minister recently spoke of his plans for '' a massive house building programme on BROWN FIELD sites'', The plan clearly contradicts government policy.

DLP_5771

Samantha McClements

I just wanted to send feedback/thoughts on the plan.

I’ve lived around paddock wood for 36yrs.

I think the plan is a positive step, we are ideally situated in the borough to take the extra housing, and rather than peace-meal development this is clearly going to be well thought through. I’d rather this than have the development in a less controlled way.

I’m also grateful for the clear way this has been presented and for you answering all my questions at the event at mascalls school.

DLP_5775

Anne Bambridge

As a resident of Paddock Wood for almost 40 years, I must express my concern for the proposed building works in the area. The recent prolonged heavy rainfall has highlighted the serious threat of flooding on the Medway flood plain as the ground is currently so waterlogged that the present drainage system is unable to cope. I applaud the movement to build homes- they are badly needed, but as a scientist, I know that this is not the place to do this.

DLP_5788

Susan Brock

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel. The creation of a conurbation from Paddock Wood right across to Tonbridge is very relevant here, as is the land’s use as a flood plain. Building here, even with flood risk mitigation could have disastrous consequences for all, as the measures being looked at are based on old data that does not fully consider the impact of climate change.

DLP_5819

Irene Walkland

I do not live in the TWBC area, but as a resident of East Peckham, if plans to build thousands of new homes in the Paddock Wood area are carried out, I shall undoubtedly be one of many who would be adversely affected.

One major concern is the extra pressure on the health centre in Paddock Wood, which already seems to be stretched.  It is often extremely difficult to find parking spaces when attending appointments and residents of this village no longer have the alternative of a branch surgery.  The increased population would inevitably make it harder to get appointments when needed and add to the parking problems.

Another consideration is that the road network in the area would not be able to cope adequately with the increased traffic such a development would involve and this would have an impact on those of us in the surrounding villages as well as Paddock Wood residents.

DLP_5872

Helen Reynolds

It is with extreme concern that I view the potential development in and around Paddock Wood. Although it is deemed that we increase our housing and listening to Radio Kent they had a guest speaker who is Professor in planning and he quite clearly stated that instead of doing piecemeal developments without proper infrastructure we should be directing these developments around such areas as Ebbsfleet.

The reasons I feel so strongly are:

  1. The road from the Hop Farm to the roundabout is going to widened it is already at capacity and with new A21 bypass the traffic is now stagnating from Pembury to Kippings Cross.
  2. You cannot get an appointment at my local health centre and I understand there is particular difficulty in recruiting doctors in West Kent. Is there capacity for further patients at the Tunbridge Wells Hospital I think not.
  3. As a dog walker there are now no go areas which are flooded around Paddock Wood. Church Farm Field is for the first time in 17 years not safe to walk in.  The water is rushing through the culverts and has increased with the building by Charles Church. The culverts have been cleared and the water is flowing freely but this needs monitoring. I do not think the TWBC Planning Committee take on board that this is a flood plain and with the ripping out of trees which absorb the water and increased building this problem will be exacerbated.

I would therefore suggest you review the Local Plan for this area until sufficient infrastructure and surface water treatment has been put in place.

DLP_5889

Emily Cammell

My name is Emily, I am 28 and I have been a resident of Paddock Wood since I was just one year old. I have grown up here and now live with my Mum on the Ballard Way/Dimmock Close estate (near PW 1_7). I work locally in Tunbridge Wells and commute every day, either by car or train. In my free time, I enjoy running and taking walks around the fields and countryside near my home. Paddock Wood has already changed so much since I was little and I am horrified at the changes that are now being proposed to my home town and the surrounding towns. If these local plans go ahead, these towns will be unrecognisable and I think the impact will be, overall, a negative one, not just on the existing communities but also on the environment and resident wildlife.

I am writing to object to “The Strategy for Paddock Wood" Policy STR/PW1.)

A main concern of mine is flooding. When we have heavy bouts of rain, the fields behind us on Church Farm, PW 1_7 and on the corner of road B2017 by the Mascalls Farm land, is prone to gathering a large amount of surface water. I am seriously concerned that by building houses and roads on these fields, the problem will be hugely exacerbated. I believe the amount of run-off water will pose a flood risk to current Paddock Wood residents and other towns further afield, such as East Peckham, Yalding and even Tonbridge. I think current news events, regarding the issue of flooding in the midlands, particularly the town of Fishlake, should not be ignored. It should serve as a warning of what could happen to towns near streams and rivers, if the surrounding land is overdeveloped and important flood plains are built upon.

I am also concerned at the damage these proposed developments will cause to wildlife and the countryside environment. I have often walked in the field and woodlands on the Church Farm land, PW 1_7 and I have seen many different species of resident wildlife. I can also observe that the Mascalls Farm site and site PW 1_1 is incredibly close to Foal Hurst Wood. I think these developments will have a negative impact on this ancient protected woodland reserve, with increased noise, traffic and light pollution and increased human prescence.

Traffic and transport is also another issue I would like to raise. When I leave for work, around 8:30am and when I return around 5:30pm, the roads surrounding the town are usually busy with school and commuter traffic. Increased development and more residents will only add to this heavy traffic, leading to more pollution and increased wear and tear on the already badly worn roads. Whenever I have taken the train to work (7:30am), Paddock Wood station is often crowded. I believe increased commuter numbers would cause overcrowding for Paddock Wood station (including its car park) and indeed the trains.

I see there is a new ​Medical Centre proposed in this strategy. I would like to comment that our current Medical Centre is already oversubscribed (especially with the closure of the East Peckham Surgery) and I have sometimes had to wait up to a month for a non-urgent medical appointment. If the current surgery is already like this, then even adding another medical centre will not make a difference, if you take into account all the new residents it would be serving. It's running would also be subject to employing NHS Doctors and Nurses, which is currently a nationwide recruitment issue.​

I have many issues of objection to these local plans but the ones I have written above are my main ones. I hope you will be taking residents concerns and comments seriously.

DLP_5892

Tracy Chapman

I live in Taylor Close, Deakin Leas, Tonbridge

I have lived in Tonbridge for 6+ years having lived in Tunbridge Wells prior to that.

I strongly object to the proposals STR/CA1, STR/CA2 & STR/PW1.  Please see my reasons for objecting these proposals below.

In those 6 years I have noticed the remarkable increase in the number of people and cars, noise and traffic pollution, demand on infrastructure and amenities.

This has been attributed to the fact that several residential projects have been completed since 2013, including the flats adjacent to Waitrose and the large site at Somerhill Green.  The completion of the A21 bypass including longfield Road roundabout, has also meant a noticeable difference to the amount of traffic using that stretch of the A21, and the traffic entering Tonbridge along Pembury Road from the Vauxhall roundabout down into Tonbridge.

It is more sensible, astute and acceptable to build small developments in areas where there is already a derelict building or derelict land, but this proposal STR/CA1 is on a totally outrageous level and will mean that green belt land will be destroyed unneccessarily forever with very detrimental effects on the environment and the residents of Tonbridge.  How can this possibly be a good idea or an acceptable solution?

It quite simply will be disastrous for the everyday lives of people living in Tonbridge.  Whilst it is healthy to keep the High Street and the community alive, it will have an adverse affect on Tonbridge if CA1 goes ahead. To build this number of houses is basically creating another small town which will depend on Tonbridge for everything.  Tudeley village life will be swallowed up along with its history and its beauty.

The traffic will be ridiculous at this end of Tonbridge.  It already is during school times and rush hour.  The whole structure will grind to a halt.  This in turn will impact on air pollution, noise pollution, quality of life, and will have a very negative affect on the access to the High Street and shops.  The parking will be difficult and impossible at times. The train service from Tonbridge is already at "breaking point"  and this plan does not include any future plans for a new station, despite the train line running through the centre of both CA2 and CA1

The proposed senior school site AL/CA2 is just as ridiculous, but dangerous too, for obvious reasons.  It will be on an already very busy roundabout which will directly impact on traffic and the safety of both road users and school children.  The train line running through the school will surely lend itself to some undesirable and unsafe situations.  The impact of the school will also add to the issues of already overloaded public transport and road use.

I could list many other reasons that these proposals are not sustainable and are very shortsighted.  They are not a long term answer to needing more houses!

These include demand on water supply, sewage waste, the affect on nature and the environment in destroying green belt land, demand on schools, medical and dental practitioners, Pembury hospital, on the well being of the present residents who live in Tonbridge.  This is not a complete list.

The proposals are unsustainable and very shortsighted.  The Tonbridge infrastructure is already fragile and these proposals will break it irreversibly.

The irony is that these are TWBC proposals but it will be Tonbridge and the surrounding villages that will be affected.  Tunbridge Wells should look to build some houses near to it's centre on several sites so that it encourages the High Street to become a vibrant and healthy centre.  The old cinema site is one that comes to mind.... this is a shameful eye sore in the centre of the town and it is an absolute disgrace that this site has been derelict for so many years!

DLP_5893

Mr Jonathan Easteal

I object in the strongest terms to the housing development plan by TWBC to build 4000 new homes around Paddock Wood.

This plan destroys our local rural environment and encroaches substantially into our green countryside and unspoilt farm land.

The Council should focus solely on developing brownfield sites and not building more than the minimum required by law. Also any developments needed should be spread out more around the borough - not predominantly in Paddock Wood - just because there is a railway station and the rules may therefore render development more easy to achieve.

Paddock Wood already has substantial plans in place for housing which will increase the town by one third.  This is more than enough for the town which already will affect our rural spaces.

If the Council pursues this plan, they will be complicit in the gradual destruction of Kent as one of the most beautiful parts of the country and, more specifically the areas around Paddock Wood which are very attractive themselves.

So please register my complete objection of this current plan for Paddock Wood.

I have cc’d Greg Clark, our previous MP,  so that he can be aware of my and my neighbours’ strength of feeling and, if he is re-elected, can take account of it for future policy making.

DLP_5905

Robert Lawrence

The following comments refer to STR/PW1:

I moved to Paddock Wood just over 12 years ago, having previously lived in London for a number of years, wanting to return to the country side for a quieter, less stressful, and healthier life. I chose to live on the outskirts of the town, opposite hundreds of acres of open countryside side that I enjoy on a daily basis when walking my dogs. The idea that the current views of the green belt and it's diverse wildlife that myself and many residents currently benefit from will be destroyed and replaced by huge housing development is difficult to comprehend. My concerns are  that the land that is earmarked for development, particularly in the North west area of Paddock Wood is without doubt unsuitable for any large scale development and will impact greatly on the small town and environment for a number of reasons which I will detail below,  and I therefore urge you to look for other suitable sites such as brown fill etc

Flooding: There is a long history of flooding in Paddock wood, with notable recordings of these events in 1960 and 1968. Paddock wood is very low lying and sits on clay, meaning when there is heavy rain and the ditches and River Medway are full there is nowhere for excess water to flow to or be soaked up by the ground.

In 2011 Tunbridge Wells Borough councill, in conjunction with the Environment Agency and several other partners produced the Surface Water management plan, which was a response to continuing issues with flooding in Paddock wood which they recognised. In this very detailed report much of land that is included in local plan falls within an area referred to as Flood Zone 3, which in itself should be enough to tell anyone with any common sense that this land is not suitable for mass development. You only have to watch the current news with reports of flooding and climate change to realise that we will be getting more of this type of weather, not less. In short, Paddock wood will continue to experience more flooding, adding thousands of homes on to ground that already struggles with excess rainfall is not viable and will be a huge mistake. Not only will all the run off water from these extra houses add to the current issues but most of the land that is currently available to help absorb it will be gone. The conclusion from YOUR own report in 2011 is very pertinent:

"Following the study and a public engagement event, it was shown that there is no single measure which could substantially reduce flood risk across Paddock Wood. Instead, a combination of policies, local action and larger-scale measures will be required to manage and reduce the existing level of flood risk."   If larger scale measures will be required for the existing risk how can you possibly consider adding another 4000 homes to this problem?

It is worth noting that during my time living here I have had problems with a number of insurance companies as they view the area as Flood risk. I have had to pay for reports from the Environment Agency to show historic flooding in the area near my house or risk having my policy cancelled.

Tied in with the current flooding issues are the problems with existing sewer and surface water systems. On several occasions during heavy fall I am one of the many residents who experience severe problems with drains backing up into my garden. This is due to the surface water run off and sewer system merging. Again, adding 4000 more houses to this already failing infrastructure is just incredulous.

Green belt:

The land to the east of Capel is designated green belt. This land is supposed to be protected from development, and whilst I understand there is pressure from central government to provide more homes for the local community I feel that the destruction of hedgerows, prime agricultural land, and woodland is unforgivable as once gone it can't be replaced. The plan acknowledges that there is a need to provide green spaces, but we already have these!  The benefits of green space on health and wellbeing are widely acknowledged, and therefore we should all be doing as much as we can to preserve what we already have not reduce it.

Biodiversity:

There are a great number of species that live in this area, I regularly see buzzards, skylarks, bats, and dragon flies to name a few. I am concerned that no comprehensive study has been carried out to see what species and habitats will be disturbed and destroyed with the building of so many homes. Trees as we know are vital in helping to keep air we breathe healthy, but the removal of trees and hedgerows coupled with the the extra pollution that the number of proposed house will produce will be detrimental to the natural environment and health of the residents alike.

Infrastructure:

The waiting lists at the doctor's and dentist are already past acceptable, especially with the surgery in East Peckham having closed recently. If you are currently unable to solve the current issues how do expect to resolve this when the population is projected to double, if not more in size? This also applies to schools in the area which again are already oversubscribed and struggling to meet demand.

Next are the issues of transport, including roads and railway networks. Undoubtedly many of new residents will be commuting to work, as many already do from Paddock Wood. The railway network is already struggling to cope with demand during peak times, adding more homes of the number suggested will only make matters worse. Add to this the number of extra passengers that will be using the same line as a result of the Development in Tudley and it's clear the network will under severe pressure creating miserable conditions for service users which impacts directly in quality of life, an important consideration that the Plan seems to neglect.

The same issues apply to the roads, which are already noticeably busier than they were 10 years ago. The plan proposes a bypass for Colts Hill, again using an area of green belt. With the additional homes and consequently cars in Paddock Wood this may in the short term alleviate the extra demand to some extent on existing roads but ultimately will not be an improvement as the overall volume of traffic and consequently levels of pollution will increase in the area.

The Following are comments on Plan Policy reference STR/CA1.

I strongly oppose the proposed plan of Garden settlement at Tudley which will totally transform a small rural settlement located in Green belt  into a huge development. Combined with the development in Paddock wood/east Capel the plan is essentially creating one giant conurbation.

Infrastructure:

There are serious issues of transport, schooling, and health care to be considered which I have already outlined above with reference to Paddock Wood, but further to this as I understand there is no plan to build a new railway station near this proposed development. The railway service in Tonbridge is already struggling in peak times as are the roads with those who need to drive to the station, how are these travel networks  intended to cope with the added demand?

Green belt:

Tudley is currently a very small settlement in the heart of the green belt, land which is predominantly used for agricultural. It also boasts a church of architectural and cultural interest. At a time when we know we are facing a global environmental calamity due to destruction and use of natural habitats and rural spaces,  the decision to propose the use of green belt flys in the face of common sense and the prevailing view that we should be doing more to preserve these precious and important areas, for reasons regarding the health and wellbeing of all and the protection of existing and threatened eco systems. As I stated previously, once it's gone you can not create more, so please reconsider the plans for this proposed development.

Finally I would like to add an overall comment that I believe the figures for proposed population growth and housing demand in the borough are grossly exaggerated, and whilst there is a need for some  housing in the borough it is not to extent forcaste. Furthermore most of the proposed housing will no doubt be used by commuters from London, who unable to afford homes in the capital will relocate. Affordable homes in London are needed, and this shouldn't be a problem for Tunbridge Wells Borough council but seemingly it is. Much of proposed development certainly won't be affordable for residents of the borough here, despite claims to the contrary, if the house prices of recent developments in Paddock Wood are anything to go by.

DLP_5906

Mr Andrew Stanley

I am writing to object to parts of the Tunbridge Wells Borough plan and with particular reference to “The Strategy for Paddock Wood” I believe this to be covered by Policy STR/PW1 (& AL/PW1)

I live in Paddock Wood and enjoy the countryside and regularly walk the footpaths and fields of Paddock Wood and Capel.

This plan is as damaging and inappropriate and results in the present Paddock Wood being surrounded by a further “belt” of concrete.

The Council has not identified or allocated all brownfield sites (contrary to Government guidance).

Of its total housing requirement (a figure that isn’t accurate or required) the new housing for Paddock Wood and Capel amounts to around 65% of the total “need”. This isn’t planning at all. Just imagine if that had been proposed for other parts of the Borough!

The plan will mean virtually unrestricted development from well to the east of Paddock Wood through to the new proposed school at Somerhill (Policy AL/CA 2) on the fringes of Tonbridge. It will also require a huge upgrading in transport infrastructure (roads) including re-routing the A228 through an AONB and then a spur further bisecting Capel to join to Tudeley New Town. It also appears to be turning farm tracks in Paddock Wood (north of the rail line) into roads, further destroying any illusion of countryside.  The cost of the roads and their future maintenance will be enormous. It will be necessary to drive to get to the countryside.

With roads being the greatest expense in infrastructure terms it is clear that the A21 corridor and Knights Park/Longfield Road or Mabledon offer far better alternatives with immediate and easy access to the A21. I have driven and walked around this area and it is immediately clear that it is much more suitable due to existing roads and already (in parts) having been developed and where further development would be less damaging to the community and barely noticeable.

Offers by landowners along and adjacent to the A21 and elsewhere were not taken forward!? Why is that? Was it too difficult to negotiate?

Paddock Wood rail station and Tonbridge rail station will be inundated as the effects of developments from Ashford to Tonbridge take effect with no new stations possible and little additional capacity available with London stations already at or near capacity.

Much of the land in Paddock Wood (Policy AL/PW1) is in a flood plain and no amount of mitigation measures and “betterment” will resolve that. I consider that little or no account has been taken of the severe weather implications of global warming/climate change. Severe weather events are occurring much more frequently and that position will deteriorate further and is not planned for in this proposal. Perhaps the present terrible flooding in the north of England at this time was the subject of mitigation and betterment but global warming is setting the bar in a much higher position. I note the draft policy says “to ensure flood risk is not increased materially at individual properties”. No great confidence in that statement.

The Planning Officer and Councillors will probably not be around to see the consequences of this folly. The large parts of Paddock Wood in this plan are in known flooding areas and is a major reason why no development has taken place in parts of the town before. It is difficult to understand how covering the land in concrete is going to help this floodplain.

Throughout this plan there are repeated references to masterplanning. In my view there is nothing that such planning (whatever that means in practice) can do with a plan that is ill conceived.

It is also important to note that the large area of planned development will result in Paddock Wood being entirely joined to Five Oak Green (Capel) as a built-up area.

The massive housebuilding proposed in Paddock Wood and East Capel will create considerable traffic and parking problems in Paddock Wood and will cause unresolvable problems at Paddock Wood rail station where peak time trains are already at capacity. This plan doesn’t even include over 700 of the houses with planning permission already given in Paddock Wood. The plan refers to improving parking at PW rail station. With around 5,000 new houses within a mile of the station and little space available that will be interesting to observe. The retention of 2 car parks in Commercial Road doesn’t help much as they are already there and regularly full!

I wonder how the medical services will cope with this onslaught? The population will more than double. There are significant issues with finding GPs in Paddock Wood and Capel and the local hospital is already over-stretched. The Planning Officer advised that this isn’t within the planning remit – so that’s alright then.

I object to the Memorial Field being developed as a community hub (Policy AL/PW4).

I am in favour of a community centre in the town but not at the Memorial Ground. Although this may not be within the plan’s concerns or objectives, this site is the most attractive park in Paddock Wood. There is not surplus field area as indicated in the plan. It would be interesting to see the assessment; however, it is clearly not correct.

When the Paddock Wood Council was considering locations, the Memorial Ground was not identified within the top 3 available sites; so clearly something has gone on behind the scenes of which the public are unaware. I have attended meetings where I was informed that the TWBC would only approve the building if it was at the Memorial Ground and that money from developers would only be available if that site was used. I have subsequently established that the developers don’t mind which site. I wonder if the comment re TWBC was also incorrect?

For those living in the town there are (at least) two worthy alternatives. Putlands is opposite the proposed Memorial Ground and is a far less attractive field. It already houses the Putlands Leisure Centre and Athletics Club which already has floodlighting. The field is sufficient in size to house the proposed community centre and requisite parking.

The field at Green Lane has an area at the north-east of the site that is unused and unsuitable for sport or housing. It could also accommodate the community centre. There is also the option of incorporating the new centre within part of one of the developments being proposed. Why not exactly?

There was also a parish poll at which a majority were against developing the Memorial Ground. It has a familiar ring that the findings of the poll were rejected. I am involved with a football club that plays at the Memorial Ground and the club committee voted against the use of the field for development. There is a proposal that the cricket club is being re-formed. Cricket cannot be played at the ground with the community centre taking such a large amount of the free space.

I feel the above provides a starting point to raise concerns about this plan.

The Planning Officer advised at one meeting that Councillors will be able to consider options but also says there is no other plan!

TWBC's Issues & Options Consultation report in 2017 recommended spreading new housing across the borough with alternative garden village sites outside of the green belt identified augmented by areas along the A21. More suitable alternatives appear to have been discarded.

Where do we go from here!

DLP_5910

Mr Andrew Stanley

I am writing to object in the strongest terms to parts of the Tunbridge Wells Borough plan and with particular reference to “The Strategy for Capel Parish” I believe this to be covered by Policy STR/CA1 and Policy STR/PW1.

I live on the boundary of Paddock Wood and Capel and was brought up in Five Oak Green. Members of my family continue to live in Five Oak Green. I enjoy the countryside and regularly walk the footpaths and fields of Capel (both east and west).

I have seen many references by the Council regarding public consultation. The people of Capel became aware of this undemocratic and unfair plan on 20 May 2019; the rest of the borough subsequent to that date. At every meeting I have attended since, the Council or its officers have said that it is not “a done deal”. When I attended the TWBC’s Planning and Transport Cabinet Advisory Board’s meeting on 5th August 2019 the TWBC Leader (and Chair of the Planning Policy Working Group) opened by saying how much time and money had been spent on the project. Now, where have I heard that before!

By whatever means this plan was arrived at, it is as damaging and inappropriate as it could possibly be. I understood that greenbelt land was so designated to stop exactly what is being proposed in this plan and only “exceptional circumstances” might allow that restriction to be circumvented or breached. There is little or no evidence in this plan that such is the case.

In priority to considering greenbelt land there is approximately 25% of the borough that is either brownfield or non-green belt. The Council has not identified or allocated all brownfield sites (contrary to Government guidance). It has found reasons not to prioritise non greenbelt land.

Capel is a rural parish and that is why most people live there. If they wanted to live in an urban environment, they would live in one. To plan for an area with 2% of the Borough’s population to take 40% of the new housing (that rises to around 65% if you consider adjacent Paddock Wood) isn’t planning at all. Just imagine if that had been proposed for Bidborough, Goudhurst, Sandhurst et al!

The plan will mean virtually unrestricted development from well to the east of Paddock Wood through to the new proposed school at Somerhill (Policy AL/CA 2) on the fringes of Tonbridge. It will also require a huge upgrading in transport infrastructure (roads) including re-routing the A228 through an AONB and then a spur further bisecting Capel to join to Tudeley New Town. Capel will be destroyed by this plan. The cost of the roads and their future maintenance will be enormous.

With roads being the greatest expense in infrastructure terms it is clear that the A21 corridor and Knights Park/Longfield Road or Mabledon offer far better alternatives with immediate and easy access to the A21. It would also lead to householders using a range of rail stations. I am sure Capel understands that it should provide a small amount of additional housing in line with other rural parishes but that could be accommodated by infill within Five Oak Green without too much devastation.

The plan has all the hallmarks of 3 major landowners offering up their land and the Council taking the easy option (as alluded to re Hadlow Estates at the meeting in Five Oak Green Village Hall on 20 May 2019 by the Planning Officer). It should be the responsibility of TWBC to do the right thing rather than the easiest. Offers by landowners along and adjacent to the A21 and elsewhere were not taken forward!?

At the western boundary of Capel, the proposed new town (Policy AL/CA1) is on greenbelt land which separates Tonbridge and Capel. The amount of traffic movement resulting from this proposal will be unsustainable; people will not start cycling and walking despite initiatives/fanciful claims. The B2017 is already congested at peak times and that will only get worse. I don’t know whether residents of Golden Green, Hadlow and Tonbridge appreciate how this plan will impact on them but many other minor roads will become blocked with cars trying to find alternative routes. Tonbridge rail station will be inundated as the effects of developments from Ashford to Tonbridge take effect with no new stations possible or, more importantly, very little additional capacity available with London stations already at or near capacity.

Hartlake Road which is on the western boundary of the proposed development is subject to regular flooding as is land to the east of that road. Much of the land here and in East Capel (Policy AL/CA3) is in a flood plain and no amount of mitigation measures and “betterment” will resolve that. I consider that little or no account has been taken of the severe weather implications of global warming/climate change. Where severe weather events were one in a hundred years they are occurring once in ten years; that position will deteriorate further and is not planned for in this proposal. The large parts of Capel in known flooding areas is a major reason why no development has taken place before. It is difficult to understand how covering the land in concrete is going to help this floodplain.

As this plan is progressed, we know that house numbers are based on the standard method of calculation and on 2014 projections. Subsequent calculations show that this is a significant over-estimate of the number of homes required in the borough; just adding to the injustice and lack of need. I would consider that this is something TWBC would have made representations to Government long before we got to Regulation 19 and particularly with the high level of AONB and greenbelt in the borough.

Throughout this entire plan I note repeated references to masterplanning/constructive masterplanning/strategic masterplanning. In my view there is nothing that such planning (whatever that means in practice) can do with a plan that is ill conceived. I am surprised that with such masterplanning at the forefront, the Planning Officer has advised that there is no back-up plan! So, does that mean entirely starting again? That does not suggest the Council is prepared to listen to any significant extent. All organisations have back-up plans on major projects and often more than one.

The Council has declined to make representations to government regarding a lower housing number and advises of the dire outcomes of not planning for the proposed number or offering any plan at all. There is little evidence of government sanctioning local authorities where representations are made.  I can’t imagine that a government-imposed plan could be more destructive for Capel than what is proposed here.

I strongly object to the land in East Capel being included in “The Strategy for Paddock Wood” (Policy STR/PW1 and Policy AL/CA3)

Many of the comments above relating to Policy STR/CA1 apply here. I note the Council’s attempt to blend Capel into Paddock Wood despite boundaries and the separate identity of Capel.

The land designated for development is on a flood plain. It floods regularly to my knowledge as I frequently walk the area. Any attempt to deal with this issue by mitigation and “betterment” do not take account of global warming/climate change or its use as a flood plain to stop flooding elsewhere.

All of the land is designated greenbelt and is grade 2 or 3 agricultural land which will be lost at a time when the country only provides 50% of its own food requirements. A range of crops have been produced on the land over the past 50 years.

It is also important to note that the large area of planned development will result in Paddock Wood being entirely joined to Five Oak Green (Capel) as a built-up area. The Council’s own review rejects fields to the west of the A228 (ID CA16 part of CA02; local plan site ref 308) due to concerns given as “There is concern that allocation of this site would result in coalescence concerns between Capel and Paddock Wood. It is also part of a larger Green Belt parcel the release of which would cause very high harm”.

The Council can conclude that the above field of 14 acres would cause problems with “coalescence” between Paddock Wood and Five Oak Green (Capel) at the same time as planning to build on adjacent fields east of the A228 (ie over the road) (ID CA17 part of CA01; local site plan 309) and  (ID CA7 part of CA01; local site plan 142;  AL/PW1). These latter 2 sites are 22 and 112 acres respectively in size; are greenbelt; have some AONB land; are flood zone 2; have noise issues; pose a high risk to deterioration of local air quality; contains agricultural land and have cross boundary and highways issues but are deemed suitable and form a substantial part of the Local Plan for East Capel. It is an amazing piece of logic where the desired outcome has ignored the Council’s own evidence!

It is also worthy of mention that the massive housebuilding on the above 2 sites will create considerable traffic and parking problems in Paddock Wood (just yards from the development) and will cause unresolvable problems at Paddock Wood rail station where peak time trains are already at capacity. This plan doesn’t even include over 700 of the houses with planning permission already given in Paddock Wood.

Finally, I wonder how the medical services will cope with this localised onslaught? I am Chairman of the local Patients Participation Group. There are significant issues with finding GPs in Paddock Wood and Capel; appointments are harder to get and the local hospital is already over-stretched. The Planning Officer advised that this isn’t within the planning remit – it needs to be within someone’s! Another matter that could perhaps be referred upward with regard to a reasonable planning level.

Conclusion

Although there is a great deal more of concern, I feel the above at least provides a starting point to raise concerns about this plan.

The Planning Officer advised at one meeting that Councillors will be able to consider options but also says there is no other plan!

TWBC's Issues & Options Consultation report in 2017 recommended spreading new housing across the borough with alternative garden village sites outside of the green belt identified augmented by areas along the A21. More suitable alternatives appear to have been discarded.

3 acquiescent large landowners appear to be a better option.

Former Prime Minister David Cameron and Chancellor of the Exchequer George Osborne wrote: “We will always protect the green belt and make sure planning decisions are made by local people.” (David Cameron and George Osborne, The Times, here’s how to build a homeowning Britain, 4 July 2015). So, promises don’t even last 4 years!

DLP_5925

Sarah Hamilton

I have now seen submissions from the Parishes and Town in my Division and have just sent you a contribution from Lamberhurst residents.

As you are aware I am triple hatted (Paddock Wood East) and  have discussed my position with the TWBC Monitoring officer.

You will have received many detailed responses which I don’t need to add to. We have already discussed many topics. They include flood risk, roads, rural transport and distribution networks as well as future demands in terms of the nature and  location of employment and uncertainty of retail.

As you know I  have raised these issues with you and your team concerning the whole Division and would not wish to add to that in terms of repetition but would like to emphasise the following:

The scale of this development plan and associated concerns about the infrastructure are, as would be expected, a cause of serious concern to many of our residents. The tremendous work by your officer team and level of engagement has helped very much but I hope we will be able to ensure the voice of, and engagement with, communities is even more evident as an integral part of future work.

[TWBC: see Comment Nos. DLP_5913-5925].

DLP_5959

Claire Derbyshire

Finally, I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel.

I implore you to do the right thing for the residents of Capel Parish and beyond.

[TWBC: see also Comment No. DLP_5955 Policy STR/CA 1].

DLP_6099

Julia Speight

I have been encouraged to email and voice my concerns about your proposed development surrounding Tudeley, Paddock Wood and the school on Woodgate Way.

Shame on you.

I agree with SaveCapel that this will be a blight on our landscape. The air, light and noise pollution will be disruptive to the residents. I don’t want to lose 600 acres of pristine Green Belt, the wildlife and biodiversity destroyed, when Brown Belt sites sit empty and should be utilised, it is pandering to the developers that they may build cheaply and make more money, rather than doing the right thing.

I am very concerned about these developments as I think they are proposed to that area with an unscrupulous intent. They may be positioned in your council and your council will receive any and all revenue connected with the developments, yet the burden on the roads, services and general disruption will be placed firmly on the shoulders of Tonbridge and Malling council. It will significantly increase traffic in and out of Tonbridge, these people will not be using Tunbridge Wells for their daily needs, they will be travelling to Tonbridge. The GP surgeries and dental surgeries that are already stretched to limits will struggle with the influx of population. The public transport is already packed.

I recognise a new school is probably needed, I just think it is rather underhanded to build on the very border of your council knowing that the brunt of the disruption during building and then once open will be felt by Tonbridge residents. It is already busy in and around Tonbridge. It is not close to the train station and the buses are already packed. Piling on more students will not help that situation. So many come into Tonbridge from as far away as Kings Hill and Sevenoaks, the buses are already standing room only by the time they are coming into Tonbridge. And it also has the train line bisecting the site. Really? How is this a good idea?

The massive development at Tudeley seems ill conceived. With the rail line also bisecting the development, that also seems an expensive way to build, it must make it more difficult catering to a very busy and necessary line. Just seems ridiculous. It is almost like someone proposed it as a joke and it caught traction. Were they patted on the back for coming up with a way to make money without too much duress on your Royal Tunbridge Wells? There is a flood risk around that area and this can only make it worse. I remember the Christmas flood, and paving over floodplains seems the absolute worse thing to do. Losing that agricultural land seems short sighted, as well.

I recognise that homes are needed. This plan is not the answer, get back to the drawing board and look at Brown Belt sites. Then you MAY have more public support.

Shame on you

DLP_6115

Charlotte Walter

I would like my objection to be registered, it relates to the excessive building of unwanted houses in Paddock Wood.

Paddock Wood infrastructure can not cope as it is now, let alone with additional housing.

As a resident of Capel / Paddock Wood for 30 years, I have seen many changes, the saddest of all was turning a Village where there was a sense of community, into a faceless town.

The current amenities can not cope already – Waitrose, Dr Surgery, Car parks and local roads. Not to mention the problems with drainage and flooding. Building hundreds of new homes, causing existing homes to suffer from flooding and drainage issues is inconsiderate, especially when the houses proposed are not wanted or needed.

What Paddock Wood NEEDS is affordable housing and none of these houses are affordable. As a single woman in my mid 40’s who has lived here for over 30 years, I have not been able to afford to live in the town where I grew up. I have been forced to pay extortionate private rent. I couldn’t even secure social housing when I had my stroke. It is a disgrace TWBC want to build houses for greedy Landlords to purchase and people from London to have a second ‘country’ home. Start looking after the existing community.

Flooding is a problem in Paddock Wood already and is being ignored. With the introduction of having to pay for a garden waste bin, more people will opt to concrete over their gardens, increasing flooding problems as there is nowhere for water to soak away. I haven’t paid for a garden bin because I struggle to afford to live here with the costs I already pay, as someone who is reliant on benefits after suffering a stroke, every penny matters.

I suffer with post stroke fatigue and am already exhausted writing what I have written but I could go on so much longer. I am SO passionate about saving Paddock Wood and Capel from an influx of outsiders and wan the Town to be able to grow for exisiting families and people like myself who would love to own where I have lived over 30 years but can not afford to. Come on TWBC, help US who live here first, and let us keep our green spaces. Stop building on all our beautiful fields.

DLP_6118

Charlotte Walter

I hope my comments will still be taken on board. I am passionate about Paddock Wood and also Capel, where I have lived for over 30 years. I feel let down by TWBC as a resident who has never been able to afford to buy a property of my own and now I have had a stroke, am even more unlikely to.

Knowing Paddock Wood, I wouldn't want a property I know to be built in areas that have flooding problems and drainage issues, even if I could afford one, and I know the developers say there will be a proportion of affordable housing but affordable to who? TWBC already don't acknowledge the cost of private renting and only pay around £500 housing benefit when its impossible to even rent a 1 bed flat for under £750. WAKE UP TWBC......

Its about time the council starting listening to the people all these developments are affecting rather than putting money first to build houses and town halls that no one wants or needs.

DLP_6147

Turley for Taylor Wimpey UK Ltd

On the basis of the evidence base presented thus far on this and Policy STR/PW1 options, we have concerns over the scale, location and delivery expectations for these proposals. Over 67% of the Draft Local Plans new allocations are dependent on these policy options being delivered. A high degree of certainty is therefore needed to justify a strategy so heavily reliant on these. As outlined in our comments to Policy STR1 (Development Distribution and Delivery), there remains significant gaps in the evidence base underpinning the delivery assumptions for these options. We have suggested further evidence be commissioned to refine and robustly support delivery rates from this policy. The delivery uncertainties posed by such options place an added onus on delivering the smaller allocations proposed elsewhere in the district, so as to maintain a rolling five year housing land supply. We have recommended additional or alternative allocations be made in this context at Cranbrook. Specifically the allocation of our clients lands (SHELAA Site 25) for a modest development of around 70 homes in addition to, or instead of, draft Policy site CRS6 or CRS7 or CRS4. A site we believe may have been overlooked by TWBC in error through the SA and SHELAA process (see introduction to this letter and Cranbrook policies below).

[TWBC: see full representation and supporting document A, supporting document B , supporting document C, and supporting document D]. 

DLP_6195

Turley for Bellway Homes Strategic

The draft Local Plan proposes approximately 4,000 dwellings at Paddock Wood (in Paddock Wood and Capel parishes). 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.

We note that this site is acknowledged to be subject to a number of specific constraints, including land being within Flood Zone 3. This Local Plan consultation does not appear to be supported by any material which explores or demonstrates how the quantum of development (residential and other uses) and associated infrastructure can be accommodated within the site.

Policy AL/CA 3 relates to Land at Capel and Paddock Wood and the land shown on Map 39. Policy AL/PW 1 relates to the Land at Capel and Paddock Wood as shown on Map 40. In addition, we note that Policy STR/PW 1 sets out the strategy for Paddock Wood. In our opinion, this combination of policies is highly confusing. Whilst we understand that it may be useful to have a policy relating to the strategy for the wider Paddock Wood area, there does not appear to be any sense in having two policies relating to the strategic scale development envisaged around Paddock Wood.

[TWBC: see full representation and Comment Numbers DLP_6189-6198].

DLP_6249

Anne Trevillion

Policy Number: STR/PW1 The Strategy for Paddock Wood

While I appreciate the need for more housing, the placing of over 4000 dwellings in Paddock Wood will place an unacceptable strain on the local infrastructure. The increase in pollution and congestion as a result of the increased traffic associated with the extra housing will lead to poorer health outcomes and wasted time and carbon – not what we need give the climate crisis we face. Flooding and drainage are major issues in Paddock Wood that have not been addressed for decades.

There are likely to be problems with overcrowded trains, a lack of GPs, and extra strain on the existing health services. These problems need to be fully addressed, even for a smaller development. The proposed increase in population is so large, the existing community would be overwhelmed. The number of houses is too large. The inevitable loss of habitat for wildlife is too great.

The plan does not seem to provide for local shops and amenities, so people would inevitably use cars to visit the single supermarket and few convenience stores in the town centre. The plan also seems to envisage a vast dormitory with none of the facilities that a proper town should have. Where is anything of any merit that one would visit the town to see? Art gallery? Cinema? Theatre? Swimming pool? Attractive formal gardens? Sculptures? Duck pond? A town is more than a collection of houses – there needs to be some sense of history and places for people to meet and engage in conversation and cultural activities, and civic buildings of which the community can be proud. The current Town Council building is a disgrace.

Please can you re-think the numbers here, and instead plan for a much smaller, high-quality development that truly enhances Paddock Wood and protects the environment.

DLP_6478

Graham Simpkin Planning for Alan Sutton

PROPOSED ALLOCATION – SITE PROPOSAL

GREEN FIELDS FARM, OLD HAY ROAD, PADDOCK WOOD, TN12 7DG

Land at Greenfields Farm should be allocated for use as a Gypsy and traveller site, or touring caravan site. The site is 0.63ha

This site is located to the south east of Paddock Wood. It is situated in a semi commercial area with B2 light industrial uses and a scrap yard nearby. Any noise associated with these uses could be mitigated by high quality landscaping. The site has access to the local highway network via Old Hay Road. Whilst a fair walking distance of nearby settlements, it is well connected by footpaths and roads. There are no landscape or wildlife designations associated with the site.

A site plans is attached.

The land could accommodate 5 - 10 sites, depending on whether more than one pitch per site is required.  A transit or touring caravan site would accommodate more pitches.

DLP_6483

Woolf Bond Planning for Millwood Designer Homes Ltd

Site 2: Chittenden Fields, adjacent to High Street and Slip Mill Road, Hawkhurst

Policy STR/CA 1: The Strategy for Capel Parish and Policy STR/PW 1: The Strategy for Paddock Wood

Representation

The strategy for Capel Parish and Paddock Wood seeks to provide for significant growth as follows:

- The provision of a standalone garden settlement (referred to as Tudeley Village) of 2,500-2,800 dwellings, of which 1,900 are expected to be delivered in the plan period, together with appropriate employment, including retail provision, within the settlement. This is required to be developed using a comprehensive masterplanned approach;

- Together with land outside of Capel parish on the northern, eastern, and southern sides of Paddock Wood, and within the town centre, a proportion of approximately 4,000 new dwellings and associated education, leisure, and health facilities to be delivered (on the wider allocations). Again, they are required to be advanced using a comprehensive masterplanned approach.

The approach to masterplanning and delivery states as follows:

“The comprehensive masterplanning approach will require close liaison and involvement with local communities and organisations, infrastructure providers, statutory consultees, relevant landowners and developers, and county and neighbouring authorities, and will follow garden settlement principles. Proposals for the piecemeal development of individual sites will not be supported….”

The strategic site allocations include a number of separate land ownerships and there are significant infrastructure issues to address and deliver.

In setting out our concerns in response to Policy STR 1 above, we have considered the content of the Housing Supply and Trajectory Topic Paper (Sept 2019) and the analysis set out therein in relation to build rates etc.

Including for the reasons set out in that Paper, and the accompanying source documents (paragraph 4.2.2 refers), we consider the assumed build rate of 299 dwellings per annum at the strategic allocations of 2,000+ dwellings (Table 8 refers) is overly optimistic.

Reliance on overly optimistic build rates artificially inflates the assumed rate of completions set out in Table 9 of the Topic Paper.

The available evidence does not support nor justify relying upon 150 completions from Tudeley village (AL/CA1) in 2025/26 and nor does it justify 333 completions from Paddock Wood (AL/PW1) in 2024/25.

A more robust assessment, with a more realistic start date and annual rate of completions would require additional site allocations in order to demonstrate a deliverable and developable supply of housing land sufficient to meet the minimum housing target during the plan period.

Suggested Change

Revise the delivery assumptions for the sites to provide for a more realistic date for first completions as well as a more realistic annualised build rate.

[TWBC see full representation, site plan and Landscape and Visual Statement].  [TWBC: see also Comment Numbers DLP_6479-6484]

DLP_6491

Woolf Bond Planning for Millwood Designer Homes Ltd

Site 222: Land on the west side of Iden Green Road, Benenden, TN17 4ES

Policy STR/CA 1: The Strategy for Capel Parish and Policy STR/PW 1: The Strategy for Paddock Wood

Representation

The strategy for Capel Parish and Paddock Wood seeks to provide for significant growth as follows:

- The provision of a standalone garden settlement (referred to as Tudeley Village) of 2,500-2,800 dwellings, of which 1,900 are expected to be delivered in the plan period, together with appropriate employment, including retail provision, within the settlement. This is required to be developed using a comprehensive masterplanned approach;

- Together with land outside of Capel parish on the northern, eastern, and southern sides of Paddock Wood, and within the town centre, a proportion of approximately 4,000 new dwellings and associated education, leisure, and health facilities to be delivered (on the wider allocations). Again, they are required to be advanced using a comprehensive masterplanned approach.

The approach to masterplanning and delivery states as follows:

“The comprehensive masterplanning approach will require close liaison and involvement with local communities and organisations, infrastructure providers, statutory consultees, relevant landowners and developers, and county and neighbouring authorities, and will follow garden settlement principles. Proposals for the piecemeal development of individual sites will not be supported….”

The strategic site allocations include a number of separate land ownerships and there are significant infrastructure issues to address and deliver.

In setting out our concerns in response to Policy STR 1 above, we have considered the content of the Housing Supply and Trajectory Topic Paper (Sept 2019) and the analysis set out therein in relation to build rates etc.

Including for the reasons set out in that Paper, and the accompanying source documents (paragraph 4.2.2 refers), we consider the assumed build rate of 299 dwellings per annum at the strategic allocations of 2,000+ dwellings (Table 8 refers) is overly optimistic.

Reliance on overly optimistic build rates artificially inflates the assumed rate of completions set out in Table 9 of the Topic Paper.

The available evidence does not support nor justify relying upon 150 completions from Tudeley village (AL/CA1) in 2025/26 and nor does it justify 333 completions from Paddock Wood (AL/PW1) in 2024/25.

A more robust assessment, with a more realistic start date and annual rate of completions would require additional site allocations in order to demonstrate a deliverable and developable supply of housing land sufficient to meet the minimum housing target during the plan period.

Suggested Change

Revise the delivery assumptions for the sites to provide for a more realistic date for first completions as well as a more realistic annualised build rate.

[TWBC: see full representation, Figure 3 Landscape Strategy, Heritage & LGS Assessment, and site location plan].

[TWBC: see also Comment Numbers DLP_6485, 6487-6489, 6491-6494]

DLP_6557

Woolf Bond Planning for Millwood Designer Homes Ltd

Site 60: The Paddocks, Home Farm, 92 Lower Green Road, Rusthall TN4 8TT

Policy STR/CA 1: The Strategy for Capel Parish and Policy STR/PW 1: The Strategy for Paddock Wood

Representation

The strategy for Capel Parish and Paddock Wood seeks to provide for significant growth as follows:

- The provision of a standalone garden settlement (referred to as Tudeley Village) of 2,500-2,800 dwellings, of which 1,900 are expected to be delivered in the plan period, together with appropriate employment, including retail provision, within the settlement. This is required to be developed using a comprehensive masterplanned approach;

- Together with land outside of Capel parish on the northern, eastern, and southern sides of Paddock Wood, and within the town centre, a proportion of approximately 4,000 new dwellings and associated education, leisure, and health facilities to be delivered (on the wider allocations). Again, they are required to be advanced using a comprehensive masterplanned approach.

The approach to masterplanning and delivery states as follows:

“The comprehensive masterplanning approach will require close liaison and involvement with local communities and organisations, infrastructure providers, statutory consultees, relevant landowners and developers, and county and neighbouring authorities, and will follow garden settlement principles. Proposals for the piecemeal development of individual sites will not be supported….”

The strategic site allocations include a number of separate land ownerships and there are significant infrastructure issues to address and deliver.

In setting out our concerns in response to Policy STR 1 above, we have considered the content of the Housing Supply and Trajectory Topic Paper (Sept 2019) and the analysis set out therein in relation to build rates etc.

Including for the reasons set out in that Paper, and the accompanying source documents (paragraph 4.2.2 refers), we consider the assumed build rate of 299 dwellings per annum at the strategic allocations of 2,000+ dwellings (Table 8 refers) is overly optimistic.

Reliance on overly optimistic build rates artificially inflates the assumed rate of completions set out in Table 9 of the Topic Paper.

The available evidence does not support nor justify relying upon 150 completions from Tudeley village (AL/CA1) in 2025/26 and nor does it justify 333 completions from Paddock Wood (AL/PW1) in 2024/25.

A more robust assessment, with a more realistic start date and annual rate of completions would require additional site allocations in order to demonstrate a deliverable and developable supply of housing land sufficient to meet the minimum housing target during the plan period.

Suggested Change

Revise the delivery assumptions for the sites to provide for a more realistic date for first completions as well as a more realistic annualised build rate.

[TWBC: see full representation, site context plan, access improvements and site location plan].

[TWBC: see also Comment Numbers DLP_6548-6450, 6452-6453, 6456-6457, 6459]

DLP_6597

Jane Spicer

I live on the outskirts of Paddock Wood off Badsell Road.  My family has lived in The Greenways since 1983.  Sadly we have recently lost our lovely orchard to 309 Berkeley Homes and now they plan another 117 on the same site.  My husband commutes daily to London and can hardly get a seat on the 06.30 to Cannon Street now, so heaven knows how he will manage when all the current planned houses are built and occcupied - let alone another 4,000 in the local plan.

I worked at The Schools at Somerhill for 23 years and the traffic along Tudeley Lane/Five Oak Green Road at school time is manic.  With 4,000 odd new homes in Paddock Wood, Capel and Tudeley,  it will be extremely difficult to travel along the lane between Paddock Wood and Tonbridge during peak/school times.

It seems ludicrous to me that all this proposed building of houses (local plan) in both Paddock Wood, Capel and Tudeley even come under TWBC as they directly impinge on the people and infrastructure of Tonbridge and do not affect Tunbridge Wells in any shape or form.  The people of Tonbridge will bear the brunt of the services, trains, Health services, schooling etc.

Flooding:

Building on the flood plain from Tonbridge towards Paddock Wood makes absolutely no sense.  I have seen over 43 years of living in Paddock Wood and driving to Tonbridge many many occasions when Five Oak Green Post Office/store has been flooded, the houses nearby and all along The Medway, Hartlake Road being submerged either side of the bridge and impassable. The Leigh barrier isn’t always enough to halt the river!  In any event, insurance companies are unlikely to insure houses along the flood plain, but I guess whether the houses sell isn’t a worry to the local plan!

Infrastructure:

As Greg Clarke pointed out in his speech in Parliament last week, the infrastructure does not get done ahead of building works.  The sewerage system in Paddock Wood is already suffering, without even the latest houses being added to the system.    This, along with commuters suffering a long journey without a seat on the train to and from London, GP waiting lists currently around 3 weeks and schooling at Paddock Wood, Capel Primary and the local villages at capacity, another 4,000 odd houses between Paddock Wood and Tonbridge is, in my view, beyond belief.

There is already gridlock with the two girls grammar schools in Tonbridge. Another secondary school opposite Somerhill will cause an unfathomable amount of traffic chaos.

Also there is obviously the danger of the school being bisected between the mainline to London.  Surely there is a safer sight for a new school?

Green Belt:

There are plenty of brownfield sites available.  There are no ‘exceptional circumstances’ in my view, to build on green belt.  Land which will be lost forever to animals, birds, recreation. I have seen many deer, badgers and smaller mammals over the years and seen owls, many herons - they will all go once the houses are built.  All that will remain, are the public footpaths and Medway towpath (hopefully).

Roads:

The B2017 from Paddock Wood to Tonbridge, especially towards both roundabouts at each end, will be totally gridlocked with thousands more cars on a daily basis. Cars will undoubtedly use Alders Road as a ‘rat run’, which will be dangerous, as it’s very narrow in parts.

Heritage and Woodland:

All Saints, Tudeley with its unique Marc Chagall windows is inundated with coachloads of tourists visiting this wonderful church.  To be surrounded by housing? Really? What a shame.  Thank heavens Grade 1 Listed Somerhill has its own substantial acreage and more precious woodland won’t be lost to development.  All the woodland that will be lost between Paddock Wood and Tudeley will be dreadful, increasing pollution (trees absorb carbon dioxide and produce oxygen).  It’s not exactly a ‘green’ local plan is it!

I hope you consider my comments.

DLP_6599

Victoria Marshall

As a resident of East Peckham, I am very concerned with regard to Tunbridge Wells Council’s proposed development to build 4,000 houses in Paddock Wood and an additional 2,000 houses in Tudeley. Building on this scale is totally unacceptable and will impact the Tonbridge & Malling area ie:

* Of utmost concern, the proposed developments are just off the floodplain. East Peckham and the surrounding villages are on the floodplain and construction of this magnitude will have a monumental environmental impact on the current waterways, increasing flood risk to low lying properties dramatically, due to water run-off from the developed land.

* South Eastern Rail currently struggle to run an efficient and effective service from Paddock Wood and the surrounding stations, I commute to London daily. The impact of an additional c.24,000 (conservative estimate) people in the area, a percentage of whom I am sure will commute into London daily, will severely impact the rail network.

* Currently, I have to wait two weeks for an appointment with my local GP. Additional head count from the proposed development will put ever increasing pressure on the current services, there being no plans to provide extra facilities. Hospitals too will be impacted greatly.

* The road network in the local area is already under strain as over the years traffic volume has increased dramatically. Additional traffic from 6,000 new builds will render local roads not fit for purpose.

* Parking in the local areas will be even more problematic than currently.

* Local schools/nurseries will be oversubscribed, which again will add to the current system being put under extreme pressure.

In summary, the development of 6,000 homes in Paddock Wood and Tudeley is totally unsustainable. Many developments have been built locally over the years and the current infrastructure is not fit for additional development I am totally against this proposed development.

DLP_6751

Joanna Ginsberg

OBJECTION TO “THE STRATEGY PADDOCK WOOD” (POLICY STR/ PW1)

INCLUSION OF THE LAND AT EAST CAPEL

All the reasons as stated above for objecting to the building of a new town apply to the East Capel site.  The proposed building on Greenbelt and the loss of rural agricultural land and allowing urban sprawl between Paddock Wood and the village of Five Oak Green, lack of suitable infrastructure in particular the country lanes, flooding – this area of the Parish is the most vulnerable to flooding, the historical assets – this area is home of Badsell Manor which is the oldest continusely inhabited moated home in the area.

LIAISON WITH TWBC

From the commencement of this process there has been a considerable lack of information, misinformation and a lack of detail from Tunbridge Wells Borough Council.  Mistakes have been made and specifically to us, our home was not included and shown as a freehold property on the map of the site of Tudeley New Town.  Bank Farm Cottages as a group of four cottages were covered in ‘pink’ and incorporated within the new town buildings.  This has caused a great deal of upset and has been hugely unsettling to ourselves and our immediate neighbours as our home is one of the few properties in the centre of the proposed development and we would be surrounded by a new town. There seems to be a total disregard for the individuals in our community and our homes and security.

Also I would add that the Local Plan of over 500 pages makes it extremely difficult to ‘translate’, navigate and then to try and understand the process to respond.  It should have been made so much more straightforward to encourage all to respond and have their say.

SUMMARY

The large scale, disproportionate proposed developments in Tudeley and East Capel are unsustainable, inappropriate and do not protect the beautiful countryside.  The Parish of Capel currently consists of approximately 940 homes, to add 4000 new homes in these two sites alone would devastate this small strong rural community. The sites seem to have been chosen entirely on landownership and deliverability.  Development should be spread across the whole borough and not concentrated in one corner, the Parish of Capel have been allocated 60% of development in the proposals regardless of the land being Greenbelt.

The building of houses needs to be sustainable environmentally friendly solutions, which reduce the impact on wildlife and nature, whilst meeting the needs of local people.

DLP_6827

Mrs Carol Richards

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 - see full 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 - see full 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 - see full 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 - see full 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_6877

Barton Willmore for Crest Nicholson

i) Policy STR/PW1 [with ref to Policy STR/CA1]

6.12 This policy offers the overarching strategy for the development of Paddock Wood sites in addition to the preceding over-arching strategic Policy STR1.

6.13 Paddock Wood is identified within the Draft Plan as suitable for a series of urban extensions in line with garden village principles. The NPPF (Para 72) encourages the use of larger scale development for the delivery of significant numbers of homes, and Crest welcomes the opportunity to come forward as part of the broader masterplan for Paddock Wood. However, we have some reservations with regards to the arrangement of policies associated with this allocation.

The Strategy for Paddock Wood

6.14 We note that Criterion 1 sets the overarching housing, infrastructure and facilities to be delivered through the allocation policies (AL/CA3, AL/PW1, AL/PW3). The quantum of development is reiterated in Criterion 4 of STR/CA1. Whilst Polices STR/PW1 [and STR/CA1] are strategic in nature, they do actually go into a significant degree of detail.

6.15 It is this criterion which introduces the concept of a comprehensive masterplan approach for the 4,000+ new dwellings. Whilst we recognise the importance of a comprehensive approach for the settlement as a whole, it will likely prove challenging if seeking to prepare a settlement-wide masterplan and may result in unnecessary costs and delays to delivery of housing, employment and infrastructure.

6.16 As an alternative, albeit a similar approach in principle, we would suggest the preparation of the following:

Town-wide Framework Plan

[]      []     []     []

Separate “east”; “west”; and “town centre” masterplans

[]      []     []     []

Individual Planning Applications thereafter

6.17 We explore the rationale for this further below (see “masterplanning and delivery” subsection).

6.18 Criterion 2 requires that the development provides for the regeneration and revitalisation of Paddock Wood Town Centre. Whilst the delivery of sites on the edge of Paddock Wood will clearly have an indirect positive contribution to the overall viability and vitality of the Town Centre, the policies explicitly state that the wider allocations should provide for the regeneration and re-vitalisation of the Town Centre.

6.19 It is assumed the intention here being that is the “town centre sites” providing for the direct regeneration and re-vitalisation of the Town Centre, albeit it is understood that the Draft Local Plan does not presently provide for any such “allocations” per se.

6.20 This reinforces our suggested approach above, ie separate actual “masterplans” for the 3No areas. As presently drafted the policy is not “justified” or “effective”, and we consider the aims of TWBC would be better served by separate sub-sections for the 3No areas across Paddock Wood.

6.21 Criterion 3 requires the provision of a “community hub” and “sporting hub”, and Crest welcomes the principle of such provision – to be identified as part of our suggested “town- wide Framework Plan”.

6.22 Criterion 4 [and STR/CA1 #5] requires the provision of flood storage/attenuation and mitigation to reduce flood risk from existing residential areas. We support this requirement, and Crest’s Site (and proposed drainage strategy) will, along with other parts of the allocations at Paddock Wood, help achieve this objective.

6.23 Criterion 5 [and CTR/CA1 #6] relates to the provision of strategic transport links within the Borough and makes reference to the need to provide an off-line A228 Colts Hill bypass. The policy commits development around Paddock Wood to the delivery of this strategic link in this early stage of the plan which is not “justified”. Whereas in reality, it is the County Council (as Highway Authority) that will actually deliver the off-line improvements – with financial contributions from the various development sites in and around Paddock Wood.

6.24 Crest supports the principle of an off-site financial contribution to such works, albeit on a fair and equitable basis with all other strategic and development sites, and of course, subject to the over-arching viability of Crest’s future development.

6.25 Criterion 6 refers to the future redevelopment of potential sites within the existing delineated settlement boundary. It is considered all such sites could/should be identified as part of our suggested over-arching “town-wide Framework Plan”, in order to ensure the comprehensive provision of services and facilities.

6.26 We support the reference in Criterion 7 [and #9 of STR/CA1] as to the need to release Green Belt land to deliver development at the settlement of Paddock Wood [and Capel].

6.27 Criterion 8 states that proposals should provide natural and semi natural green space. We support these objectives, albeit that such provision should be proportionate to the respective development area alongside which it is being delivered. We also note that this reiterates the requirements of Policy OSSR2.

Town Centre+

6.28 We support the stated principles and objectives of Town Centre regeneration. However, it is only “town centre sites” that can assist with the “reconfiguration of the town centre”. It would not be “justified” to seek the peripheral sites to the east and west of Paddock Wood to play any direct part in these regeneration objectives.

Masterplanning and Delivery

6.29 The principle of a comprehensive approach to the future development proposals at Paddock Wood is supported. However, and as previously indicated, this should be based upon:

* A settlement-by-settlement basis; and

* A “town-wide Framework Plan” (as opposed to a “masterplan”).

6.30 As rehearsed previously, Crest’s land interests fall within both Paddock Wood Parish and Capel Parish. It is inevitable that future residents will relate directly with Paddock Wood (as a settlement), as opposed to Capel as a Parish. We can therefore already foresee potential problems and misunderstandings for Crest’s future residents in respect of the administrative practices/operations, ie the maintenance of areas of open space, or the use of any precepts added to Council Tax, etc…, by way of a couple of examples.

6.31 Criterion 1 [also STR/CA1 #1] sets out a two-tier approach to masterplanning of development in Paddock Wood [and Capel]. At the higher level would be a strategic infrastructure plan to set out the provision of infrastructure, which we have suggested should be called a “town- wide Framework Plan”.

6.32 We would then advocate the use of 3No separate “master plans” for each of the following areas – to be prepared reflecting the higher level “framework plan”:

* Paddock Wood East;
* Paddock Wood West; and
* Paddock Wood Town Centre.

6.33 We would support the “town-wide Framework Plan” being a SPD, but we do not consider it necessary (or effective) for each of the 3No masterplans to be SPDs too.

6.34 As presently drafted, there is some repetition between Criteria 1&2, and Criterion 3 is simply a statement. [Also Criteria #1-3 of STR/CA1 (masterplanning)].

6.35 Criterion 3 states that “It is highly likely that the delivery of development will require land equalisation agreements.” We would suggest that it is highly unlikely that it would be possible to create any land equalisation agreement for the entire settlement. It is possible that “understandings” or “agreements” could be reached between the component parts of the relevant “east” and “west” development areas, which reinforces again our suggested approach of the 3No area masterplans. We suggest that this sentence be removed and TWBC can use the proposed town centre framework plan to set out its expectation of any strategic infrastructure whose delivery would be a shared responsibility as regards cost of delivery including infrastructure costs and land and which allocated areas should have shared responsibility.

6.36 Criterion 4 duplicates the content of Policy STR3, and we would ask that clarification is required on how TWBC intends to use its Compulsory Purchase Powers. We interpret this as being that TWBC will use its CPO powers where a small element of an allocated site might hold up delivery of a wider allocation scheme. TWBC should clarify that it will not be intending any wholesale acquisition of land to deliver allocations in their entirety.

6.37 This section also includes reference to Site Allocation AL/PW4, which it requires to be incorporated into the masterplan, along with a land outside the Borough but adjacent to allocations. [This is repeated in STR/CA1]. We do not necessarily consider this would be “effective” or “justified”, and greater clarity is sought in this regard.

Flooding

6.38 This section requires the provision of flood storage/attenuation/mitigation areas and flood defence works to reduce the flood risk to particular existing residential areas of Paddock Wood, Capel and Five Oak Green.

6.39 This is broadly in line with the NPPF (paras 163 and 165) and sustainable drainage systems can be satisfactorily incorporated into any development on site. However, as the sites do not lie within the same hydrological catchment as Five Oak Green, the requirement to provide mitigation measures to this settlement is not reasonable or in fact technically possible. On this basis the policy is not “sound” for the purposes of the NPPF (para 35) as it is not “justified”, “effective” or “consistent with National policy”. To be considered ‘sound’ the policy should delete reference to Five Oak Green.

Transport

6.40 An over-arching “infrastructure plan” would be useful in providing an understanding for determining how the costs of providing the other strategic off-site transport measures and schemes would be apportioned. However, the responsibility for funding and implementation have not been defined. We consider this is the area of the Draft Local Plan that would benefit the most from greater clarification and understanding.

6.41 Crest supports the principles of what is being sought to be achieved, however we presently have reservations as to the “justification” and “effectiveness” of the actual delivery thereafter.

6.42 Sustainable transport improvements will allow the expansion of Paddock Wood to improve accessibility as well as promote active and healthier lifestyles. A focus of the masterplan layout is to place pedestrians (and other non-motorised users) at the heart of the design of streets and spaces. Improvements to existing public rights of ways, and the creation of new functional and leisure cycle routes will also extend the range of destinations which can be reached sustainably.

Landscape

6.43 The Strategy for Paddock Wood states that developments must provide natural and semi natural green space and a range of formal and informal open space; and provide strong multi- functional green and blue infrastructure to tie in with the surrounding landscape and to integrate with flood defence measures. This policy is supported by the “Green Infrastructure Framework” (TWBC, 2019) and complies with requirements of the NPPF (para 127). Therefore it is considered to be sound and in accordance with the NPPF (section 12).

Infrastructure

6.44 Crest recognises and supports the provision of supporting infrastructure related to its proposed development. This criterion provides a list of suggested infrastructure improvements that must be provided for to mitigate any impacts.

6.45 We largely support the listed items of infrastructure that may need to be provided across the settlement of Paddock Wood, and have suggested the preparation of a “town-wide Framework Plan” would be the most appropriate manner of apportioning these across the development sites coming forward.

6.46 We would reiterate our concerns that greater clarity is required in respect of the “transport measures” being sought, and would also seek specific clarification in respect of “secondary education” places:

* Policy STR/PW1 seeks the expansion of Mascalls Secondary School (via financial contributions), which Crest fully supports; whereas

* Policy STR/CA1 seeks either a new Secondary School (to the east of Tonbridge) or the expansion of Mascalls Secondary School, to which Crest only supports the latter (in respect of its land interests at Paddock Wood settlement). This is because we have concerns that it would result in undue travel demands that would result from a school that would be remote from the development.

Summary of Policy STR1/PW1 [Policy STR/CA1]

6.47 We support the overarching aims of Policies STRPW/1 [and STR/CA1], however there remain a number of concerns relating to the overall structure of the policies, especially when considered in context with Policies AL/PW1 [and AL/CA3]. These policies, although strategic, go into a significant degree of detail that extends beyond the purposes of a strategy policy. Furthermore, we have reservations regarding the overall structure of the policies and the parish-by-parish based approach as set out above, which has led to a significant degree of unnecessary crossover and repetition of policies across the Plan, contrary to the NPPF (para

16).

6.48 With regards to the detail of Policies STR/PW1 [and STR/CA3], significant clarification needs to be provided in the next iteration of the Plan in order for it to be “effective”, and we look forward to the opportunity of working alongside TWBC in helping to develop these policies for Paddock Wood.

6.49 Specifically the “masterplanning” and “delivery” approach could be far more “effective”, and the requirements for each of the component parts of the development need to be better “justified".

6.50 Notwithstanding the above concerns and requests for greater clarification, Crest supports the overall thrust of Policy STR/PW1 [and Policy STR/CA1].

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

DLP_6955

Shipbourne Parish Council

On behalf of the above Councillors at Shipbourne Parish Council, I have been asked to forward our concerns on the draft Tunbridge Wells Local Plan. We have particular concerns about the  STRATEGIC SITES:  LAND AT CAPEL AND PADDOCK WOOD, AND TUDELEY which border Tonbridge. Tonbridge is our nearest service town and is already extremely congested. We object to the level of proposed development  as it will cause an increase in traffic and put pressure on our local services, amenities and infrastructure such as schools, transport and GP's surgeries. We also object to the loss of 600 acres of greenbelt.

DLP_7002

Kember Loudon Williams for Mr Anthony Whetstone

1 Introduction

1.1 This Statement has been prepared by Kember Loudon Williams, on behalf of Mr and Mrs Whetstone, to promote the allocation of land at Tudeley Brook Farm, Whetsted Road, Paddock Wood as part of the strategic allocation for Paddock Wood. These submissions have been

prepared in response to Tunbridge Wells Borough Council’s  consultation Draft Local Plan (Regulation 18) and provide a technical assessment about the site demonstrating that the land is suitable, available and deliverable for development. The report addresses the site in the context of national policy explained through the National Planning Policy Framework (NPPF) and local policy in the form of the emerging Local Plan and in turn drawing positive conclusions.

1.2 This is the first time that the Council have been made aware of this site as it was not promoted in the earlier two Call for Sites exercises. However, now that the comprehensive expansion of the settlement of Paddock Wood is proposed (under Policy AL/PW1 and AL/CA3) we believe that there is a strong and credible planning case to support its inclusion within this planned growth. As a result, we are seeking to secure its allocation as an integral part of the planned growth for Paddock Wood framed/contained, as it is, by the A228 Whetsted Road.

1.3 In order to demonstrate the deliverability of this site, this report takes account of the key technical considerations including flood-risk, accessibility, ecology, landscape and visual impact and impact on the Green Belt.

2 Planning Policy Context

National Planning Policy

2.1 National planning policy in the form of the National Planning Policy Framework (NPPF) explains that the purpose of the planning system is to contribute to the achievement of sustainable development. A central aim of the NPPF is to achieve a significant boost in housing delivery to

meet the needs of present and future generations. The social and economic benefits of providing for the full development needs of the area have however to be pursued in a balanced way to contribute to the achievement of sustainable development.

2.2 The NPPF states that strategic policies should be informed by a local housing need assessment. The objectively assessed housing need for the borough over the plan period to 2036 is confirmed as 13,560 dwellings (678 per year). With regards to identifying land for new

homes, Paragraph 72 of the NPPF explains that:

“The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities”.

Local Planning Policy

2.3 The emerging Local Plan indicates how the full development needs of the borough can be most appropriately met and proposes a development strategy based on dispersed growth across the borough along with a new ‘stand-alone’ garden settlement at Tudeley Village and the transformational expansion of Paddock Wood.

2.4 The two strategic allocations at Paddock Wood and Tudeley are to be delivered on a comprehensive masterplan basis. These sites are in relatively close proximity to the borough boundaries adjoining Tonbridge and Malling Borough Council and Maidstone Borough Council. The image at Figure 1 shows the location of these two strategic allocations in relation to the wider area.

2.5 The preferred development strategy for the growth of the Borough is set out in full in Policy STR 1. With regards to the expansion of Paddock Wood, Policy STR 1 states that this should be delivered through:

“…garden settlement principles to deliver housing and employment growth, new and expanded educational facilities, and provide strategic flood risk solutions to reduce flood risk and provide betterment to particular existing area. Regeneration of the town centre to provide

a vibrant and viable new centre for the communities it will serve, as well as the delivery of a range of other community facilities and infrastructure, including new health facilities, a sports hub, new primary schools, expansion of the existing secondary school, and potentially the ‘offline’ A228 strategic link (i.e. the Colts Hill bypass)”.

2.6 The influences that have shaped the preferred Development Strategy are set out in the Distribution of Development Topic Paper. This acknowledges that the major urban extension of Paddock Wood would involve the loss of Green Belt land but following detailed assessments (including testing the Local Plan objectives against a Sustainability Appraisal) it was found unreasonable for large growth to occur in Areas of Outstanding Natural Beauty (AONB).

2.7 Alternative locations for growth have been considered as part of the Sustainability Appraisal, including the potential urban extension of other settlements including Tunbridge Wells, Southborough, Hawkhurst and Cranbrook but ultimately the Sustainability Appraisal concludes

on Page 3 of the non-technical summary that:

“Paddock Wood was the only reasonable location for an extension and that a scale set away from the constrains in the south (ancient woodland and AONB), but with land take in the Green Belt to the west of Paddock Wood, would provide a suitable scale of extension with benefit for the economic, environmental and social elements of sustainability”.

2.8 The proposed strategy for the development of Paddock Wood is set out in Policy STR/PW 1. This explains that the scale of the proposed development for the urban expansion is set to include 4,000 new homes, considerable employment and associated educational, leisure and health facilities. This is to be developed using a comprehensive master-planning approach to include the proper provision of the necessary infrastructure, including highway works, active travel provision and flood mitigation measures. The inclusion of the subject site at Tudeley Brook Farm is an important and helpful addition in meeting the development need.

2.9 The land to be allocated for this urban extension (Allocations AL/CA 3 and AL/PW1) includes land parcels to the north, east and west of the centre of Paddock Wood. It also includes land located west of Paddock Wood that lies in the eastern part of Capel parish.

2.10 The wider site allocation has been broken down into 12 smaller parcels of land. The plan provided at Figure 2 below shows where the subject site sits in relation to the 12 parcels of land comprising of the strategic allocation for 4000 new dwellings.

2.11 The subject site borders PW 1_2 (North West Parcel) to the west and PW 1_3 (North Central Parcel) to the east. Both parcels of land have been identified within the Plan as being able to accommodate a mix of uses including housing, small scale commercial development, flood compensation/open space and scope for neighbourhood centre/mixed uses/primary school/sports pitches.

Tudeley Brook Farm

2.12 Tudeley Brook Farm immediately abuts the proposed strategic site allocation for the expansion of Paddock Wood. If the Council accepts the strategic growth at Paddock Wood at this scale, it is considered entirely logical to include the subject site as part of this extension.

2.13 The site is physically, functionally and visually interlinked with the proposed allocation. It is well contained and would integrate seamlessly with the proposed allocation. Whetsted Road (A228) acts as a strong defensible boundary and there would be no impact on the landscape when considered in the context of the strategic allocation. Overall, the site represents a logical extension to this allocation.

3 Site and Surroundings

3.1 Tudeley Brook Farm is private home with several outbuildings and extensive grounds. The site extends to 2 hectares and a redline plan showing the extent of ownership is attached at Appendix 1. The site is located within the Parish of Capel and lies to the north of Paddock

Wood directly south of Whetsted Road (A228).

3.2 At present, the site lies beyond the development boundary for Paddock Wood in an area defined as open countryside. It is on the edge of, but within, the Green Belt.

3.3 The site benefits from one of the only already established access arrangements direct from the A228 (Whetsted Road) onto land parcels PW1-1 and PW1-2 and has an extensive road frontage of approximately 170 meters. The road acts as a strong defensible boundary to the north of the site, a significant benefit when considering the benefit potential of the site.

Site Description

3.4 The house and outbuildings are located on the northern part of the plot, running parallel with the road. The built floorspace amounts to a total of 550 sqm comprising of the main house (270 sqm), the garage (130 sqm), the games room (100sqm), and the stables (50sqm).

3.5 The southern part of the plot comprises of a field which is more open in character. It is flat and a mature tree belt runs along the south and western boundary of this field. The land is used for recreational purposes and a photograph of this field and the tree belt is provided below for reference.

3.6 It should be noted that the whole plot is being promoted for development. The existing farmhouse is not listed and has been extended considerably over the years. The associated outbuildings are relatively new structures, with the garage and workshop obtaining consent in October 2002 (LPA Ref: 02/01858). There are no special characteristics or circumstances to warrant the retention of these buildings.

Site Context

3.7 Paddock Wood benefits from excellent transport links and higher order facilities, such as a secondary school and sports centre. There is also a large employment area to the north of the railway line.

3.8 The Development Strategy (STR1) has already recognised Paddock Wood as being a sustainable location for new housing and the comprehensive expansion of the settlement will provide further infrastructure, employment, community and educational uses in the area.

3.9 Tudeley Brook Farm is well served by public footpaths. Public Right of Way (PRoW) WT175 runs the eastern boundary of the site and links onto PRoW WT174 which provides access to the centre of Paddock Wood and the train station. These footpath links are shown on the plan

provided below in Figure 4.

3.10 Estimated walk time to the train station (which provides services to London and other towns and transport hubs such as Tonbridge, Ashford International and Dover Priory) is approximately 18 minutes.

4 Site Appraisal

4.1 In order to demonstrate the deliverability of this site, this Section provides a summary of the key technical considerations, including flood risk, ecology, landscape and visual impact and impact on the Green Belt.

Green Belt

4.2 The five objectives of the Green Belt are set out in Paragraph 134 of the NPPF:

a) to check the unrestricted sprawl of large built-up areas;

b) to prevent neighbouring towns merging into one another;

c) to assist in safeguarding the countryside from encroachment;

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

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

4.3 The subject site is located in the Green Belt. The land surrounding the site is also located in the Green Belt. The current version of the Plan is seeking to remove this land from the Green Belt in line with the proposed strategic site allocation (under Policy AL/PW1 and AL/CA3). The Plan explains that there are exceptional circumstances to alter the Green Belt boundary in this location in order to bring forward a wide range of land uses to deliver strategic development.

4.4 The release of Green Belt land to the west of Paddock Wood is supported. However, on the basis that the subject site should be part of this strategic allocation, Tudeley Brook Farm should also be released from the Green Belt. The release of Tudeley Brook Farm in the context of the planned strategic allocation would not undermine any of the Green Belt objectives set out above.

Flood Risk

4.5 Planning policy at both the national and local level states that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, defined as being Flood Zone 3. – this is acknowledged. Where development is necessary, it must be made safe without increasing flood risk elsewhere.

4.6 A Strategic Flood Risk Assessment has been produced to inform the Draft Local Plan and the distribution of development. The SFRA has been prepared in two parts – a Level 1 SFRA for the whole borough and a Level 2 SFRA focussing on the land around Paddock Wood and East of the Parish of Capel.

4.7 The land around Paddock Wood and East of the Parish of Capel is prone to flooding - falling within areas of Flood Zone 2 (areas with a medium probability of river or sea flooding) or Flood Zone 3 (areas of high probability of river or sea flooding). A map showing the flood zone of this area, taken from the Council’s SFRA, is provided below for reference.

4.8 The flood zone map demonstrates that the subject site is identified as being located in Flood Zone 2. The testing completed as part of the Level 2 SFRA provides a strategic understanding of the potential effect of development and the potential for mitigation by implementing flood risk management measures.

4.9 The strategic assessment finds that the principle of development around Paddock Wood can be supported. It identifies opportunities for flood risk management and it also finds that some of the measures could have a large positive effect on flooding in Paddock Wood, with the potential to provide ‘betterment’ for the existing settlement. The provision of flood storage/attenuation/mitigation areas to substantially reduce the flood risk to particular existing residential areas in Paddock Wood is one of the key justifications for the release of Green Belt land.

4.10 As a result of the above, the delivery of strategic flood risk measures is a key component of the master planning approach for the comprehensive development of site allocation Policy AL/PW1 and AL/CA3 and all development is expected to contribute to the provision of flood storage/attenuation/mitigation areas and flood defence works to reduce the flood risk to particular existing residential areas at Paddock Wood,

4.11 It is important that the subject site is not excluded from this exercise, especially given that it is in a lower flood zone than some of the other sites in the immediate vicinity and within the proposed allocation. Overall, the site, like those surrounding it, provides an opportunity for the delivery of strategic infrastructure or betterment. It could contribute proportionally with other allocated sites for these important infrastructure improvements.

Ecology

4.12 The site is well maintained and regularly mowed. As a result, it is considered that are no significant ecological constraints that would preclude the development of this site.

4.13 It is acknowledged that a more detailed ecological assessment of the site is required. This will be conducted during the more appropriate season.

Highways

4.14 As explained in Section 3 of this report, Paddock wood benefits from good transport links and higher order facilities. As a result, it has been identified in the Development Strategy (Policy STR 1) as a settlement that can accommodate significant growth.

4.15 Policy AL/PW 1 recognises that the allocation would be subject to a comprehensive master planning exercise and this would include further necessary highway and transport work. It continues to state that transport provision shall be delivered on a strategic basis, with transport infrastructure links between Paddock Wood, Tudeley Village, Tonbridge and Royal Tunbridge Wells.

4.15 It is worth noting that the subject site is currently one of the only sites that benefits from an already established and safe access onto the A228 (Whetsted Road). Subject to further investigation, this could provide a useful access point onto the wider development.

5 Conclusion

5.1 The site is in single ownership and represents an excellent opportunity to be part of the sustainable strategic urban extension to Paddock Wood. The site is available now, is entirely suitable and deliverable within the plan period. There are no legal or ownership constraints to delivery and when combined with the draft site allocation that bounds the site, the flood risk and Green Belt constraints do not prevent the delivery of the land.

5.2 Overall the site could contribute proportionally with other allocated sites for important infrastructure improvements. It represents a logical extension to the draft allocation. We would welcome the opportunity to work with the Council to develop the masterplan for Paddock Wood and to include the land at Tudeley Brook Farm

[TWBC: See full representation]

DLP_7050

Stewart Gledhill

[TWBC: for full report, including diagrams, figures and pictures, see full representation].

As a member of the SaveCapel Steering Team and the campaign, I am submitting the attached Representation in response to the consultation under Regulation 18 -- The Town and Country Planning (Local Planning) (England) Regulations 2012.

I understand the national policy constraints applied to the development of the Local Plan and will watch its progression post-consultation and the evolution of national planning policy with great interest.

OBJECTION – POLICIES STR/PW1 & AL/PW1 CAPEL EAST

OBJECTION – POLICIES STR/CA1 & AL/CA1 TUDELEY


FOREWORD

This report has been prepared by the Flooding (including strategic flood risk and sewerage) Group on behalf of the SaveCapel Campaign Team. This group is made up of seven local residents who have lived in the area for a considerable length of time and are all familiar with the degree, frequency, and location of the flooding problems in the area which quite simply does flood on a regular basis. Members have detailed knowledge of flood prevention measures already taken and those being investigated to prevent flooding in Capel. In addition, members include professionals in their field of water management science, surveying, engineering, construction and accountancy.

Whilst this report raises specific issues relating to each of the above policies in the Draft Local Plan, there are also many common matters and relevant background information sections. Rather than duplicate many sections of this representation, it is intended that the contents are read as our response to the consultation on each of the above policies.

Whilst we all have many concerns about the development in general these are being addressed by other working groups. Our primary concern is to demonstrate the danger and costs that flooding issues will produce with a view to getting the existing plan moved to a more sensible and suitable location that will reduce costs and bring it into line with government policy of not building on areas liable to flooding.

1 : GEOLOGY

1.1 The soil is described in the National soil resources Institute as “Loamy and Clayey floodplain soils with naturally high groundwater”.

1.2 Geology of the site mainly comprises of impermeable clay which does not drain easily and is susceptible to volume change, with changes in moisture content. The undeveloped land at both sites PW1 and CA1 is likely to contain high levels of sulphates from the agricultural use of the land which attacks the integrity of concrete. Historic Ironworks and mining deposits are scattered over the southern side of CA1 with shafts up to 15 metres deep.

1.3 Special material and Foundation design are likely to be required and building out of the ground would be costly with possible retaining structures and terracing design required to accommodate sloping ground in places.

1.4 The map below of the Capel area (Figure 1) has been built using the boundary maps from the Tunbridge Wells Borough Council Master Plan and the British Geological Society UK bedrock (625k Version 5) map and the British Geological Society UK superficial geology map. This shows sites CA1 Tudeley and PW1 Capel East in red outline.

[TWBC: for Figure 1 see full representation]

1.5 Variations in the superficial geology are shown, with the lighter colours indicating mainly clay and the purple areas largely sand. * CLSS – Clay Sand and Silt. * SAGR – Sand and Gravel.

1.6 The geology of a catchment can be an important influencing factor in the way that water runs off the ground surface. This is primarily due to variations in the permeability of the surface material and bedrock stratigraphy.

1.7 Potential development parcels located in the west of Paddock Wood are underlain by the Tunbridge Wells Sand Formation consisting of interbedded sandstone and siltstone whilst sites in the east are underlain by the Weald Clay Formation consisting of mudstone.

1.8 The area is therefore likely to have a varied response to rainfall events, with eastern areas of Paddock Wood underlain by typically less permeable mudstones being characterised by a quicker catchment response. Flood volumes will be more critical for areas underlain by the less permeable Weald Clay Formation with areas underlain by the Tunbridge Wells Sand Formation having a slower response to rainfall.

1.9 There is a variety of superficial (at the surface) deposits including River Terrace Deposits, head Deposits and Alluvium.

1.10 However, both of the proposed allocations have very similar immediate substrates; namely alluvial deposits under a clay cap. This is shown by the beige and purple areas. These immediate substrates will require significant ground works to make any buildings stable, as they are inherently unstable and liable to subsidence.

1.11 The southern area of CA1 shows the extent of the sandstone bedrock (the purple area that is darkly shaded). This is sufficiently porous that it allows the aquifer it contains to self-balance by expelling water through springs. This higher area is capped with impervious clay, which means that surface water run-off from this area must be considered a serious risk (see Tudeley levels map Figure 5).

1.12 In addition, this aquifer will seriously hinder excavations for building, sewage transport, and drainage; puncturing the clay cap will release the aquifer and mean that such excavations and any permanent holes will require constant pumping. The effects of compression on the aquifer of any buildings and roads/driveways, as well as the compaction of the surface clay, will affect the ability of the surface and underlying geology to take up surface water.

1.13 All three types of substrate have porous aquifer substrates under a clay cap. If that cap is punctured by excavations, pipes and flood defences, then the risk of aquifer leakage will be very high. In addition, the aquifer is often above capacity, as shown by the large number of local springs. This means that its capacity for taking additional water load will be low or indeed will have a negative contribution to water absorption. Interfering with this aquifer will have a seriously detrimental effect on flooding prevention.


2 : TOPOGRAPHY

2.1 Topographical history: From The History & Topographical Survey of The County Of Kent. Published in 1798. “Capel is a very obscure and unfrequented place, the surface of it is very low and flat, except in the middle of it where there is a small rise, on which the church stands; … in the rest of the parish it is deep miry clay.”

2.2 Bagshaw’s Directory of Kent in 1841 refers to the soil as being “mostly a miry clay”

2.3 This clay is hydratable and extremely unstable; it is subject to swelling when wet and to contraction when dried out.

2.4 The only major change between 1798, 1841, and 2019 is that while we still have thick wet clay, and still have a slope, since the 1840’s there has been a railway embankment in place to prevent the water from getting away.

2.5 Levels and Topography: The map below (Figure 2) has been built using the boundary maps from the Tunbridge Wells Borough Council Master Plan and the European Union 10 metre resolution Digital Elevation Model. This Digital Elevation Model is produced from data collected as part of the SRTM (Shuttle Radar Topography Mission) and ASTER GDEM (Advanced Spaceborne Thermal Emission and Reflection Radiometer Global Digital Elevation Model) projects.

[TWBC: for Figure 2, see full representation]

2.6 What this map shows is how little variation in levels across the PW1 and the northern side of the CA1 area: for the majority of both areas there is around 1m variation in levels. Such small variations in Height above Mean Sea-Level [HSL] indicate a greater risk of flooding.

2.7 The clay cap, aligned with slower drainage times and an over-abundance of supply, would mean that these areas are more likely to flood, even under moderate rainfall or moderate storm events.

2.8 CA1 Flood Risk: The Draft Local Plan has not included a comprehensive assessment of flood risk at the proposed site in Tudeley. However, Flood Risk Assessments were prepared in 2018 by Waterco to inform KCC’s Mineral Plan, sites M10 Moat Farm and M13 Stonecastle/Hartlake, which are in close proximity and relevant to this allocation (see Figure 7, page 16). The issues relating to Stonecastle Quarry are discussed in more detail in section 7 below.

2.9 The border of the M13 site is within 500 metres of CA1 and this FRA¹, in particular, is relevant to our understanding of the ground levels in the allocation. Waterco predict flood water levels of up to 1.12m, calculations have been used for the “Defended 1% AEP + 35% Climate Change event” modelling, and shows that much of the solar farm at risk of being seriously flooded (see Figure 4 below).

2.10 The land levels from the Hammer Dyke moving south towards the railway line remain low before dropping lower in the fields prior to the start of the solar farm. The Waterco report data indicates a potential flood risk level at this point of up to 1.7 metres, allowing for climate change of 35%.

2.11 Furthermore, the Waterco mapping clearly shows much of the land in M13 to be at risk of flooding between 0.6 metres to 1.2 metres, with some areas at risk of flooding between 1.2 - 2.4 metres. The EA stress concern in a letter dated 5.7.2018 contained within the document that flooding could be increased elsewhere as a result of the proposed mineral extraction. This has implications for CA1 and this FRA provides the best evidence available.

2.12 Ground survey: The Flood Group decided that further investigation into the ground levels of the north-east section, in particular, of the proposed CA1 development site (north of the railway line) was needed.

2.13 A levels survey was undertaken from footpaths at both the Tudeley and Capel East sites on the 13.7.2019. This used laser technology and followed a traditional rise and fall method. The results of the survey confirm this minimal variation of ground levels.

2.14 A map showing the path of the survey undertaken at CA1 Tudeley is shown below (Figure 3):

[TWBC: for Figure 3, see full representation].

2.15 This map shows the position of each survey point and the blue dotted line shows a cross-section of the mean values. This should be read in conjunction with the graph below (Figure 4) which highlights the recorded levels and anticipated flood levels from point A to B.

2.16 From the Environment Agency’s Flood Model, the highest flood level above sea-level in the proximity to the site is 18.4m which is the likely path level rather than field level at the border position of CA1 (circled).

2.17 The graph below (Figure 4) shows the variation in levels along the survey undertaken compared with anticipated flood levels and should be viewed in conjunction with the survey map above (Figure 3):

[TWBC: for Figure 4, see full representation].

2.18 The Datum is taken from the Waterco data and deduced land levels at 16.030m 16.660m 15.780m 16.710m and 22.925m ending at Lilley Farm are shown below the horizontal line. The figures of 1.67m 1.09m 1.92m and 1.0m above the horizontal line are approximate levels to which flood water could reach based on the Waterco data¹ [¹ Flood Risk Assessment for Site M13: Stonecastle Quarry   Waterco consultants 13-July-2018   Online: consult.kent.gov.uk/file/5165135].

2.19 These levels do not include the assessment of climate change over the ‘lifetime’ of the proposed residential development (>100 years) and therefore understate the potential flood risk (see section 10).

2.20 Assessment of the data and levels indicates flooding to a depth of approximately 1.12 metres in fields around the Hammer Dyke.

2.21 The Flood Group’s levelling survey revealed fields to be reasonably level from the Hammer Dyke to Sherenden Farm, but then dropping significantly by up to O.8 metres giving a potential flood depth of considerably more than 1.12 metres up to the Solar Park from where the land starts to rise at the southern end.

2.22 Land to the east of CA1 Tudeley running to Capel East, from available data, generally appears lower.

2.23 These maps and figures demonstrate that there are three areas to note:

  • Firstly, that there is so little variation in levels that flood water is likely to spread across a significant proportion of the entire area. Over much of the northern area of CA1 and the majority of PW1, there is less than 1m variation in levels above Mean Sea Level.
  • Secondly, that the Environment Agency’s flood risk model has obvious shortcomings in this area. For example, it show areas that are lower, in terms of level above Mean Sea Level, than immediately adjacent higher areas not flooding, while those higher areas do flood.
  • Thirdly, given the small variations in level over the entire PW1 area and the norther section of the CA1 area, there will be a much higher risk of flooding as the effects of climate change continue to develop. This is further explained in section 10.

2.24 Essential flood protection systems, such as bunds, flood storage and so on, are less likely to be remain feasible options; there is a limit to the size these can be built to, without impacting on the development’s viability.

3 : FLOOD HISTORY

3.1 Tunbridge Wells Borough has a well-documented history of flood events; the main sources of which are from fluvial (river/watercourse) and pluvial (surface water) sources. 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:

  • November 1960: The heavy and prolonged rainfall caused widespread flooding across much of Kent as the Rivers Medway, Teise and Beult exceeded their channel capacities. The areas surrounding Five Oak Green, Lamberhurst, Buckhurst, Ashurst and Ashour Wood are recorded to have flooded during this event.
  • November 1963: The Rivers Medway, Teise and Beult exceeded their channel capacities. However, the flood event was not as extensive as that during November 1960 as records only show the area north of Tudeley Hale and Whetsted to have flooded within Tunbridge Wells Borough.
  • September 1968: Prolonged heavy rainfall associated with a slow-moving depression and thunderstorms caused severe flooding across the south east of England. Between the 14th and 15th of September, 150mm-200mm of rainfall was recorded across Kent and consequently the river flow on the Medway was recorded at 225 cubic metres per second. As a result, the River Medway exceeded its channel capacity and caused extensive flooding in many areas of the borough including Tudeley Hale, Five Oak Green and Paddock Wood.
  • Christmas 1999: Floods in Five Oak Green, the playing field and the road leading down to it. The centre of the village was flooded with water entering a number of homes and the village shop. Residents erected barriers at each end of the village to prevent vehicles passing through the village causing problems with their bow waves. The Alder Stream overtopped its banks and the path beside it became impassable due to the rate of flow and depth of water. One end of Nortons Way and all of Willow Crescent flooded. The small lane leading down to the hop processing plant flooded along with all the land at the end of it down to the railway. Fire Engines were brought in to pump out the Village, Nortons Way and Willow Crescent. Fifty properties in Five Oak Green flooded including the village shop. The Alder stream overtopped its banks, surface and ground water inundated the foul water system, and gullies and culverts failed. Half of the village lost power.
  • May 2000: The Alder Stream overtopped. Areas of Five Oak Green were flooded.
  • October 2000: The wet weather in the autumn of 2000 resulted in many river catchments being subjected to multiple flood events. Large areas of Kent and Sussex were left under water as several rivers burst their banks. The river flow on the Medway exceeded that of 1968 at 260 cubic metres per second. Consequently the reservoir behind the Leigh barrier rose by 3cm per minute on an area of 278 hectares. The barrier had to be released gradually which helped protect Tonbridge but the flooding in Five Oak Green, Yalding and other villages downstream made national news.

    The police were forced to close the Five Oak Green Road after residents erected barriers at each end of the village to prevent vehicles causing further problems with their bow waves. Parts of the road had water up to 2 feet deep. At least one house on that road was flooded to the depth of 3 feet, others in the village reported depths inside properties of 18 inches. Properties affected included parts of Nortons Way Willow Crescent, around the village green - The Forge, Whetsted Road and Falmouth Place. Householders in the village renewed their call for better drainage systems after they had been evacuated from their flooded homes for the third time in 10 months.

    Paddock Wood also recorded flooding at Mascalls Court Farm and at the Hop Farm livestock drowned. In total, around fifty properties were flooded from the Gravelly Way Stream and Tudeley Brook.
  • January 2002: Firefighters spent four hours pumping out flood water from the King’s Head Pub and neighbouring cottages, Badsell Road, and Five Oak Green Village.
  • 2008/2009: Southern Water recorded sewer flooding for Five Oak Green. The EA also describes issues of hydraulic overload from foul sewers and surface water in Five Oak Green.
  • 2011: Five Oak Green Rd / Tudeley Lane flooded.
  • 2012: Roads flooded - Colts Hill, Willow Crescent, Church Lane, Alders Road, and Badsell Road.
  • March 2013: Flooding in Alders Road, Capel, to a depth of 30cm - the worst in living memory.
  • December 2013: During the winter of 2013-14, a series of Atlantic depressions brought heavy rainfall and stormy conditions to much of England and Wales when Kent received 242% of the long-term average rainfall causing widespread flooding.

    Of particular note is the storms of 19th-24th December when 110mm of rain fell on already saturated catchments which caused river, surface water and foul water flooding across the area affecting hundreds of homes and businesses, including in Five Oak Green and Paddock Wood.

[TWBC: for image of Five Oak Green village 2013, see full representation].

The Army were put on standby for evacuation assistance when the whole of the Medway valley was flooded upstream and downstream. The Leigh Barrier had to be released to relieve the water volume upstream and failed to stop Tonbridge from flooding. This was close to a national emergency.

Five Oak Green suffered a power cut and the pumping station failed. As a consequence roads and properties were flooded to such an extent that some families had to vacate their homes for several months.

Since this time, significant flooding occurred within the borough during August 2015, July 2017, and July 2018. 3.2 Flooding incidents have been reported historically in Paddock Wood, with the corner of Church Road, The Cedars and The Ridings being subjected to floods every year. The area to the north of the railway is reported to have been affected by flooding from the rivers Teise and Medway (flood events occurred in 1960, 1968, 2000/2001, and 2013/14). Flooding south of the railway is noted to generally be associated with heavy rainfall, resulting in flooding from surface water and watercourses that flow south to north through and adjacent to Paddock Wood. 3.3 Hartlake Road also has a history of regular flooding. Last winter it was closed for a complete 4 week period! 3.4 At Crockhurst Street, the south west part of the CA1 Tudeley proposed development, which is one of the highest points of the area, flash flooding often occurs (left and centre below):

[TWBC: for images referred to above, see full representation].

3.5 Surface water flooding at the site of the Solar Farm in June 2014 is shown in the above picture (right). This is immediately adjacent to the eastern boundary of CA1 north of the railway.

3.6 Sherenden Road has a history of flooding - with flooding of the Roads and adjacent fields up to 3 feet deep in places. The road was closed three times in two weeks in 2014:

[TWBC: for image of record of road closure referred to above, see full representation].

3.7 CA1 Tudeley north side of railway floods up to Lilley farm and at the lower section of the south of the site adjacent to the railway embankment. In May 2018, not a notable flood event for the borough, surface water flooding was severe along Sherenden Road at Lilley Farm:

[TWBC: for images of Lilley Farm referred to above, see full representation].

3.8 Rail tracks that dissect the CA1 plan have flooded in the past.

3.9 Historical points of interest:

3.10 The accounts records at Tatlingbury, in the 1700‘s, record the costs of drainage and the failed attempts at improvement. The new method was to dig ditches in the direction of the river and then backfill them with brushwood. This failed because the flood plain covered the same area as it does today. The water table is 450mm, in the wet season, in between the industrial estate and Badsell Roundabout. There will be no improvement until the water table and the depth of the river are sustainably lowered. This could then interfere with bore holes and aquifers affecting water quality.

3.11 The John Bowra surveying map of Stone Castle c 1760 shows: Great Mead, Footway Mead, Bridge Mead, The Marsh Orchard, Little Huntley Mead, and Great Huntley Mead. Other names: Whetsted, Hart Lake, Poors Mead, Ottershaw, Moat Farm. Lilly Hoo. Tudeley Brook farm. Gold Hill Mill, Little Mill. Oak Wear.

3.12 KCC Heritage maps 1871 – 1890 show that: Whetsted was also known as Washlingstone. The Hop Farm was Wateringbury.

3.13 In 1545 King Henry III was assembling an army and navy in Portsmouth to meet the threat of a French invasion. Tonbridge was described as being a small town on the Medway much subject to flooding and poor ground hampering the efforts to get men and materials from London and the North down to Portsmouth.


4 : REGULATORY POLICY & GUIDANCE

4.1 PLAN NEEDS TO MEET NPPF:

  • Section 149: Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk.
  • Section 155: Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk (whether existing or future). Where development is necessary in such areas, the development should be made safe for its lifetime without increasing flood risk elsewhere.
  • Section 157: All plans should apply a sequential, risk-based approach to the location of development – taking into account the current and future impacts of climate change - so as to avoid, where possible, flood risk to people and property….. seeking opportunities to relocate development, including housing, to more sustainable locations.
  • Section 158: Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower risk of flooding (such sites are available).

4.2 FLOOD RISK AND CLIMATE CHANGE - GUIDANCE FOR PLANNERS:

Inogen Environmental Alliance Inc. (June 2019): The NPPF sets out how the planning system should help minimize vulnerability and provide resilience to the impacts of climate change, and alongside planning policy guidance demonstrates how flood risk should be managed now and over the lifetime of the development, taking into account climate change. Consequently, the Environment Agency (EA) has recently updated their climate change guidance in 2016, providing climate change allowances to support the NPPF which is now split by river basin district rather than a blanket percentage increase in river flow. See photo of River Medway, Tonbridge 2013 below.

If the Site is within a floodplain then the proposed development is typically raised above the flood level. The exact level of land raising is dependent on the predicted flood levels and the EA allowance for climate change. However, the displaced floodwaters will need to be compensated for through flood compensatory water storage. This impacts development as the location of the storage will undoubtedly impact the masterplan as it needs to be located within or on the edge of the floodplain and demonstrated on a level for level basis. This could also potentially affect the developable area, building design and access. If climate change is not considered, the modelled water levels are likely to be deemed too low and the planning application objected by the EA on flood risk grounds.

The EA’s Flood Zones do not take into account climate change so if not formally provided by the EA, hydraulic modelling may be needed to be conducted which can be time and cost prohibitive.

[TWBC: for image within text, see full representation].

Aside from river flooding, surface water is a key risk as demonstrated in the Pitt Review- the Government’s response to the 2007 summer floods. The EA climate change guidance applies climate change allowances to peak rainfall to determine runoff rates. This may mean you need larger attenuation storage to protect the proposed development for its lifetime. As per the risk from rivers, the location of surface water attenuation storage or other forms of Sustainable Drainage Systems (SuDS) will impact the masterplan in terms of developable area, building design and access. In addition to the statutory planning requirements, building occupiers are increasingly aware of the potential for flooding to impact their operations. As a result, some major occupiers are imposing their own flood risk standards which are more stringent than the planning requirements. Where an investor is considering an asset that satisfies the statutory requirements, this may not be sufficient to truly consider the potential for re-letting, with some occupiers being unwilling to compromise their own demanding flood standards.

4.3 RECOMMENDATIONS FROM OTHER AGENCIES:

4.4 Environment Agency document – Lessons learned from autumn 2000 Floods - Ground water from hidden springs brought misery to many. Despite flows being held back on the river Medway by the Leigh barrier the swollen rivers of the Medway, Teise, and Beult converged on Yalding leading to extensive flooding. Five Oak Green and East Peckham flooded up to 5 times in 2000. The policy statement 6 from this EA document states “when developing in the floodplain prevention is better than cure”.

4.5 In 2000, the United Nations Economic Commission for Europe listed points to note: “2. Human interferences with natural processes has increased the threat of flooding and should where possible be reversed and in future prevented”.

4.6 From KCC select committee report 2007 - “flooding can happen at any time in any season and with enough severity to overwhelm defences” - as we know, we have no formal defences.

4.7 I D Oliver, of the Romney Marsh area Internal Drainage Board, wrote - “Few if any surface water systems would have coped with the intensity or duration of rainfall experienced in other parts of the country, we in Kent were very fortunate to have escaped”

4.8 Mr Older, Flood Risk manager of EA quoted “Flash flooding and water run-off was a key contributor to flooding in 2007”.

4.9 Historically, a point of reference for heights above sea level has been provided by reference to benchmarks, which were located, in times gone by, at intervals all around the country. Given the flooding disasters in recent times, and bearing in mind the Somerset Levels as a particular case in point, perhaps we should remind ourselves of a statement made at the time. “If you build on an area that floods, you will flood.”

4.10 Let us also remind ourselves of the statements made by the Government and others after recent flooding events, such as the Somerset Levels, that “lessons would be learned about building in areas at risk of flooding”.

5 : PLANNING PRECEDENT

5.1 MAIDSTONE LOCAL PLAN – REGULATION 19 REJECTION DUE TO FLOOD RISK: Neighbouring Parish site located at Yalding, downstream from Capel, has been rejected by the Inspector:

Former Syngenta Works, Hampstead Lane, Yalding. Extract from Inspector’s report: “The former Syngenta site at Yalding is a large flat brownfield site that was previously used for agro-chemical production. The site has been mainly cleared of buildings and remediated for land contamination. It was identified in the submitted Local Plan for 8,600 sq m of business space and 200 dwellings. However the site is wholly within Flood Zone 3a and is at high risk of flooding. The national policy aims for Flood Zone 3a in the NPPF are to relocate development to areas with a lower probability of flooding. The Environment Agency therefore objects to residential development on the site. The deletion of a housing allocation is necessary for reasons of flood risk. However as the housing was needed to assist development viability of the mixed use scheme the site is also unlikely to be developed for the proposed business use”.

5.2 GARDEN SUBURB REJECTED FOR FLOOD RISK: A large urban extension to the town of Maldon in Essex has been refused against officer advice over flood concerns:

  • The ‘garden suburb’ proposal submitted by developer Countryside Properties would have seen the creation of 1,138 new homes to the north of Heybridge covering 76 hectares. However, members of the Maldon District Council North West Area planning committee voted to refuse the application, going against the Planning Officer’s recommendation of approval.
  • Within the Officer’s Report for the application, it said “Delivery of the site will assist the Council in achieving its five year housing land supply requirements”. The site is one of three strategic locations contained within the Council’s local plan for the creation of a garden suburb in the area, guided by a strategic masterplan framework.
  • Despite the apparent policy compliance, Councillors voted to refuse the application due to concerns with flooding issues. Citing the Council’s formal reason for refusal, it said “Insufficient evidence has been submitted with the application to demonstrate that the proposed development would be able to incorporate adequate surface water drainage infrastructure and that the infrastructure that would be proposed would be maintained in a manner that would ensure that the development would not cause increased flooding risk within the vicinity of the site and the catchment areas of the watercourses that are within the site”.
  • Maldon Council released a statement which said that the potential impact on flood risk from the development was unacceptable and contrary to both local and national planning policies.

5.3 TUDELEY PUBLIC HOUSE EXTENSION REJECTED: Proposals for the extension of the Poacher & Partridge PH, Hartlake Road have been rejected by TWBC for the following reasons:

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

(2) The proposal, by virtue of creating new buildings with associated domestic paraphernalia, works to alter the land levels and potential additional impacts from further parking and works in close proximity to the trees at the rear would have more than a minimal impact on the landscape character of the locality. It would not conserve and enhance the rural landscape, nor would it protect the countryside for its own sake, nor preserve the interrelationship between the natural and built features of the landscape. The overall impact is harmful to the rural character of the area.

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

The application was considered to be fundamentally contrary to the provisions of the Development Plan and the NPPF, and there were not considered to be any solutions to resolve this conflict. This decision directly contradicts the promotion of the adjacent development of 2,800 homes (CA1) by the same TWBC Planning department.

5.4 OTHER PROPOSED DEVELOPMENTS REJECTED FOR FLOOD RISK:

  • South Stanley: Plans to build 290 homes in South Stanley were unanimously rejected by council bosses. The application for land south of Hustle Down road and Middies Road was thrown out due to concerns about traffic congestion, road safety and flooding as well as harm to the character of the local landscape. It was felt the application represented a significant encroachment into the countryside.
  • Cannon Bridge: Plans for 27 houses in Cannon Bridge rejected by the Highland Council planning officers after flood risk fears raised by the Scottish Environment Protection Agency (SEPA) and the councils flood risk management team.
  • Yatton: Plans for a new estate in Yatton near Bristol were rejected. A risk of flooding was one of the chief concerns expressed about the proposed development by members of the North Somerset Council planning committee.
  • Dublin: Plans for 900 new homes in South Dublin have been refused due to concerns about flooding and traffic impact. The board said it was not satisfied that the developer had provided adequate information around how it would manage storm waters on an area at risk of flooding. It had serious concerns in relation to the effectiveness of the proposed solution including plans for a water storage area, and overall calculations of the surface water runoff rates. Furthermore the board was not satisfied that the storm water outflow could be limited or that the site when developed would no result in flooding in the Ballyogon Stream and related catchment downstream of the development site. It said that the proposed development would therefore lead to a risk of flooding lands outside the subject site and be contrary to the proper planning and sustainable development of the area.
  • Kings Lynn: Housing development in Clenchwarton near Kings Lynn rejected for fears regarding flooding.
  • Stockton-on-Tees: The appeal site lay partly within flood zone 2. The developers had produced a flood risk assessment that demonstrated a reduced risk of flooding and the Environment Agency withdrew its objection. However, the appeal Inspector found no evidence that alternative sites had been considered. Notwithstanding the absence of an objection from the Environment Agency or the local planning authority on this issue, the Inspector considered that the proposal did not meet the requirements of national guidance and refused planning permission.

6 : CURRENT HYDROLOGY & FLOOD RISK

6.1 Flooding from reservoirs

6.2 Reservoir flooding is very different from other forms of flooding. It will happen with little or no warning and evacuation will need to happen immediately. The likelihood of such flooding is difficult to estimate, but it is less likely than flooding from rivers or surface water. It may not be possible to seek refuge upstairs from floodwater and buildings could be unsafe or unstable due to the force of the water from the reservoir breach or failure.

6.3 Reservoirs with an impounded volume greater than 25,000 cubic metres in England are governed by the Reservoir Act 1975, as amended by the Flood and Water Management Act, 2010 and are listed on a register held by the Environment Agency. Recent changes to legislation under the Flood and Water Management Act require the Environment Agency to designate the risk of flooding from these reservoirs.

6.4 The only such reservoir in our area is at Leigh (see section 8). Flooding as a result of a breach/failure (or deliberate release) of this reservoir structure would impact allocation parcels in the north of the Paddock Wood (SFRA prepared for the DLP). This may be up to 2 metres high in some cases, and perhaps 1 to 1.5 metres in the CA1 Tudeley area and Five Oak Green, when levels are fully assessed.

6.5 Fluvial flood risk

6.6 The principle watercourses flowing through Tunbridge Wells Borough are the River Medway and its tributaries, which include the Alder Stream, Paddock Wood Stream, River Beult, and the River Teise, the longest watercourse within the borough. The main source of fluvial flood risk is associated with the Rivers Medway, Teise and Beult, caused by run-off and catchment inflows across the borough.

6.7 In addition to these watercourses, flooding within the borough has also been associated with Alder Stream, which flows through Five Oak Green, and Paddock Wood Stream, which flows through Paddock Wood. The Alder Stream catchment is described as particularly flashy, resulting in regular flooding from the Stream. Railway embankments act as a dam, which consequently worsens the flooding in this area of the borough with roads and property having been affected in the past. In some instances, high water levels in the Alder Stream have affected highway drains, gullies, and local sewer networks.

6.8 A number of ordinary watercourses flow through the Paddock Wood area including the Alder Stream, Paddock Wood Stream and Tudeley Brook. In the east, a number of unnamed smaller ordinary watercourses flow off the hills to the south of Paddock Wood and through a number of allocated sites before flowing into Paddock Wood Stream. Paddock Wood Stream flows through the central area in a northerly direction towards the River Medway. Tudeley Brook flows in a northerly direction through the west of the area before joining Alder Stream which flows in a north easterly direction.

[TWBC: for Figure 5, see full representation].

6.9 Numerous water courses are marked on the above map at CA1 and the Tudeley Brook at Capel East. By the very nature of such watercourses a myriad of underground branches are likely to exist beneath the slopes at CA1 and possibly at the site Capel East. Water also runs under and over the southern sloping areas. Much of southern CA1 slopes in more than one direction.

6.10 The southern section of CA1 floods and ponds with flooding at the railway line down from the church, the ground from the church level being uneven, and sloping in different directions in wave patterns. Tudeley levels floods, bringing water to Tudeley Road, this being water from springs and watercourses on higher ground. The lions head spring passes down through Somerhill and can often be seen flooding across the road into the fields at Postern.

6.11 There are noticeable run-offs from spring points, e.g. southern section of CA1. Springs are present to the rear of All Saint's Church, Tudeley and behind Crockhurst Street, another spring can be seen opposite Park Farm on the higher ground to the south west.

6.12 Groundwater Flooding

6.13 The groundwater (water table) is stated as being naturally high in the Capel area by the National Soil Resources Institute. 6.14 Current understanding of the risks posed by groundwater flooding is limited and mapping of flood risk from groundwater sources is in its infancy. Groundwater level monitoring records are available for areas on major Aquifers. However, for low lying valley areas, which can be susceptible to groundwater flooding caused by a highwater table in mudstones, clays and superficial alluvial deposits, very few records are available.

6.15 Mapping suggests that susceptibility to groundwater flooding is greatest in the north-east of the borough, specifically in the areas of Whetsted, Tudeley Hale and Five Oak Green. This groundwater flood potential is consistent with the location of more permeable strata and superficial deposits to the north of the borough.

6.16 Additionally, there is increased risk of groundwater flooding where long reaches of watercourses are culverted as a result of elevated groundwater levels not being able to naturally pass into watercourses and be conveyed to less susceptible areas. Mapping for the Local Plan has shown that 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.

6.17 The playing field in Five Oak Green regularly floods to a greater or lesser extent a few times every winter. Significantly when this happens the water remains in place for days or even weeks due to the underlying nature of the soil and/or the high water table.

6.18 Pluvial flooding

6.19 Flooding from surface water runoff (or ‘pluvial’ flooding) is usually caused by intense rainfall that may only last a few hours and usually occurs in lower lying areas, often where the natural (or artificial) drainage system is unable to cope with the volume of water. Abnormally heavy rainfall can also occur for an extended period of time.

6.20 Surface water flooding problems are inextricably linked to issues of poor drainage, or drainage blockage by debris, and sewer flooding.

6.21 The risk of flooding from surface water predominantly follows the topographical flow paths of existing watercourses or dry valleys with some isolated ponding located in low lying areas.

6.22 For the most part, surface water flooding could be attributed to heavy rainfall overloading carriageways, drains and gullies. However, there are other instances where the source of flooding is perceived to be from blocked drains and gullies, or due to high water levels within receiving watercourses impeding free discharge from surface water drains and gullies. It is noted that roads within the borough are regularly flooded due to run-off from adjacent agricultural land discharging into watercourses that do not have sufficient capacity to convey the flows.

6.23 Paddock Wood has experienced several incidents of surface water flooding associated with small watercourses, sewerage and private drainage systems, often occurring relatively rapidly from the onset of heavy rainfall.

6.24 Thanks to the Parish Council Flood Committee and the Five Oak Green Flood Action Group, with the aid of various agencies, especially the environment agency, the regularity of incidence and severity of flooding in Five Oak Green has been greatly reduced. Despite this the centre of the village does still flood on a regular basis. Much of the improvement has been due to extra measures taken to get the water through the village and away. Maintenance of the stream leading to the culvert, keeping the screen at the start of the culvert clear, unblocking and lining the culvert, clearing the exit of obstructions, and the regular maintenance of the ditches all the way down to the Medway have brought about dramatic improvements. Anything such as the proposed development which impeded this would inevitably increase the frequency and severity of flooding in Five Oak Green/Capel.

6.25 The surface water drainage system has not been increased and upgraded in terms of layout, positioning, and capacity to keep pace with the continued and continuing construction of new houses, extensions to existing houses, conservatories, and other buildings in and around the village.

6.26 Development of two new dwellings at Pendore, Five Oak Green. The previous building and hardstanding areas had a gross area of approximately 276 m². The two new dwellings have a footprint of 267 m² with a total impermeable area of 697 m². EA prescribed a total of 28 m³ of attenuation (swales etc.) with restricted discharge via a hyrdobrake of 2 l/s to the adopted sewer in Five Oak Green Road. This demonstrates the large size of storage that is required by the EA under each dwelling and curtilage to attenuate the flood risk.

6.27 Three houses have recently been built on Five Oak Green Road near the centre of the village, three more houses are being constructed opposite the allotments, and two more recent builds are now on Sychem Lane, one of them newly completed. A Planning Application has recently been approved for five new houses on Sychem Lane. To the north of the railway, more new houses are being completed on Whetsted Road. All in this small village. And the former Kings Head site awaits development!

6.28 It is also noted that much of the drainage infrastructure has been in place for well over a century and was not designed and built for the current and future demands. Further, the current water company has made clear that not all of the layout of the system is known to them or mapped by them.

6.29 Over the two sites, just 50mm of rain falling would amount to 26.4million gallons of water, equivalent to 40 Olympic size swimming pools. All in addition to that resulting from developments in Paddock Wood and Tonbridge.

6.30 Flood defences

6.31 There is presently only one (modest) flood defence in the local vicinity. A small raised embankment (<40 metres long) is located along the banks of the Alder Stream near Brook Farm, approximately 0.2km south of Five Oak Green Road. This is accompanied by concrete bank protection works and is owned and maintained by the Local Authority.

6.32 The condition grade of the defence is ‘Fair’, meaning that defects may be present that could affect the overall performance of the defence lining the Alder Stream. The defence has been designed to provide a standard of protection of 20% AEP and thus only protect the surrounding properties from a 1 in 5-year flood event.

6.33 A Five Oak Green flood alleviation scheme has been proposed to reduce fluvial flood risk from the Alder Stream which has been discussed over many years. Options are being assessed by the EA which include additional flood defences around the Alders Road area behind Colts Hill. This may include a reservoir but no decision has been taken.

6.34 The Policy AL/PW1 includes reference to Five Oak Green (FOG) but only states specifically Paddock Wood (see strategic storage in section 11). It is now understood that the Alder stream project would not be progressed and the ‘betterment’ for FOG would be through CA1 Tudeley, as confirmed by TWBC Head of Planning (12-Nov-2019).

6.35 EA Flood Map

6.36 The mapping of current flood risk from fluvial flooding in Capel is shown below (Figure 6) which confirms that the majority of PW1 Capel East is in Flood Zone 3. In addition, there is a significant area of the northern part of CA1 Tudeley that is within the flood mapping.

6.37 It is important to note that this mapping does not include an allowance for climate change nor the additional effects of surface water flooding. There is also no consideration of the run-off from the proposed development and the replacement of agricultural land with hard surfaces.

6.38 The Environment Agency’s current flood model is based on assumptions that are 25 years old, which is reflected on its inability to cope with such small variations in HSL. It is also clear that, in some key areas, the underlying data may be out of date – newer land use mapping would have shown that the surface roughness in these areas had decreased as agricultural use has moved away from hedge-bound orchard systems to open-field cereal and rootvegetable crops.

[TWBC: for Figure 6, see full representation].

6.39 This area regularly floods throughout the year to a greater or lesser degree. In addition those areas that don’t flood become very muddy. With global warming and building on the site matters can only get worse. Whilst it is possible to protect properties by building up its a bit pointless if the roads flood - damaging vehicles – and making access to the houses difficult and potentially dangerous.

7 : STONECASTLE QUARRY

7.1 The map below (Figure 7) shows clearly how the area of the proposed allocations in Capel, the historic landfill parcels, and adjacent land proposed for mineral extraction are closely linked.

7.2 The Draft Local plan has stated in its policies that the strategy must “have regard to Kent County Council minerals allocations in the vicinity” and therefore the cumulative effect of any quarry expansion and new housing plans needs full assessment.

[TWBC: for Figure 7, see full representation].

7.3 Historic Landfill

7.4 The Mineral Planning Authority (MPA) permitted the importation of various waste materials to Stonecastle Quarry under condition (xii) of the planning permission TW/79/753 and subsequent other conditional consents. We understand that this continued through the 1980s and 1990s.

7.5 The landfill areas comprise of two large parcels of land which were backfilled with these waste materials following the completion of mineral extraction. These areas are located to the north & south-west of the previous processing area and we understand that the southern parcel was backfilled first (see map above).

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

7.7 Our research and the limited monitoring information obtained from the Environment Agency has raised the following initial concerns:

  • The southern site is bordered by the Hammer Dyke and is dissected by the Alder Stream (Main River).
  • The levels of highly toxic leachate in the segregated cells that make up the northern parcel have consistently been around 4.5 metres higher than the level prescribed in the Waste Disposal Licence.
  • Excess leachate has seemingly not been removed from these sites, with the licence stating that this should have been done within four weeks of a monitoring level exceeding the permitted level.
  • The northern parcel appears to have contaminated the adjacent Primary Silt Lagoon (immediately west and north) as there appears to be an absence of wildlife in contrast to the other lagoons.
  • The leachate may have escaped into the surrounding water courses/aquifers especially during the severe flood events in 2000 and 2013. Volatile readings and elevated substances have been found in the groundwater.
  • Volatile and apparently high levels of methane gas and carbon dioxide have been recorded.
  • Numerous readings have not been made due to bore holes/wells being flooded, damaged or inaccessible.
  • The waste materials in the cells are bunded/contained by clay overburden and silt remnants from aggregate washing and any ground movement could severely compromise the security of the leachate.

7.8 There is extreme concern in our community, especially as the area has historically flooded, and numerous people are asking for a comprehensive independent report that provides full analysis of the contamination risks of these landfills and whether our health has been affected by evidently uncontrolled methane gas emissions.

7.9 This matter is relevant to the Draft Local Plan because of the contamination risks on the water courses and aquifers (see section 14), and also due to the connectivity of numerous water courses in the immediate area, especially Alder Stream and Tudeley Brook (within PW1).

7.10 KCC Minerals Plan

7.11 The Kent Minerals and Waste Local Plan 2013-30 is currently being assessed by the inspectorate under Regulation 19 and members of the Flood Group participated at the hearings in October 2019. The Inspector’s report will only be available after the end of this Regulation 18 consultation on the Draft Local Plan.

7.12 TWBC was not represented at the hearings for sites M10 Moat Farm and M13 Stonecastle and no Statement of Common Ground between KCC and TWBC was provided to the Inspector. This raises serious concerns about the fulfilment of “Duty to Co-operate” requirements and whether either of these plans meet the test of soundness.

7.13 M10 Moat Farm: The map above highlights that the eastern boundary of the proposed site M10 Moat Farm envelopes the historic southern landfill and the north-east section is adjacent to the northern landfill area. Any disturbance of the contaminants, the elevation of these landfill areas and substantial contamination risks of leachate, Methane gas, and other toxic substances on the water courses is of significant concern.

7.14 In addition, the proposed mineral site borders the Hammer Dyke and is dissected by the Alder Stream which raises significant further concerns as to the effect of this proposed extraction on the flood risk and water courses/aquifers.

7.15 The Draft Local Plan is proposing a new road link from the new town CA1 at Tudeley to the A228 (orange arrows in Figure 7) that would follow a route across M10 Moat Farm and the southern parcel of the historic landfill. Whilst this new road link is not included in the Transport Assessment Review prepared in support of the Draft Local Plan, the Strategic Sites Map released for the consultation still includes it.

M10 Moat Farm is expected to produce the extraction of 1.5 million tonnes of sand and aggregate (combined) over a period of 15 years. The restriction on Stonecastle Quarry activity because of the road access at the A228/Whetsted Road junction means that the various mineral sites must be worked consecutively (not concurrently).

Tarmac have stated that M10 Moat Farm would be scheduled for extraction after the completion of the Stonecastle extensions. By implication, this proposed mineral extraction could run from the late 2020s to the mid-2040s.

The Draft Local Plan covers the period 2016 to 2036 and it is therefore inconceivable how both the Mineral Plan and the new road link can be achievable during this period.

7.16 M13 Stonecastle extension: This proposed site is expected to produce the extraction of one million tonnes of sand and aggregate (combined) over a period of 7 years. As with the above site M10, the restriction on Stonecastle Quarry activity means that the various mineral sites must be worked consecutively.

7.17 This site is the centre of the catchment area of the EA designated Groundwater Protection Zone (GSPZ) related to the aquifers at Hartlake (see section 14). These aquifers have historically been an environmental concern. In 2002 KCC refused planning permission for the proposed extension of Stonecastle Farm Quarry phases 3 & 6 (now M13) on the grounds of potential pollution and contamination. Further quarry working was deemed to be a public health risk as the Hartlake aquifers are a source of public and commercial water supply.

7.18 The Flood Risk Assessment (FRA) prepared by Waterco in support of the Mineral Plan states that the site M13 is an important setting for local water supply and extensions to this quarry may impact water supply. Questions remain as to whether the full extent of these extensions are acceptable on this functional floodplain.

7.19 There is also uncertainty about the sustainability of the restoration plan and how the integrity of the watercourses will be maintained. Groundwater maps show the northern parcel has a 25-50% susceptibility to ground water flooding and the southern parcel 75%. Any effect on further waterbodies adjacent to the river Medway may result in the risk of further flooding.

7.20 Given the proximity and land levels of CA1 Tudeley, the resulting rainfall run-off and drainage, together with potential contamination and increased flood risks, needs to be fully assessed in relation to the proposed mineral extraction in this area.

7.21 Mineral Processing

7.22 Tarmac have applied to the MPA for new processing facilities (KCC/TW/0093/2019) and this is currently under consideration by KCC.

7.23 The proposal is that silt laden waters resulting from the mineral washing process will be discharged to the Primary Silt Lagoon which is adjacent to the northern landfill parcel. Given the close proximity of the proposed operation to the landfill and the interaction with the lagoons, the contamination risks need to be fully assessed.

7.24 It is important to note that KCC and the Environment Agency have been asked to provide a comprehensive review of the contamination risks from the historic landfill before determining this planning application. Although originally scheduled for consideration at the November 2019 Planning Committee, this has been deferred.

7.25 In addition, KCC Highways are reviewing the level of traffic entering/leaving the quarry site at the junction with Whetsted Road/A228. Given the potential vast increase, which could continue for up to 30 years, the cumulative effect of the proposed development of PW1 Capel East and resulting traffic needs to be fully assessed.

7.26 KCC Policy DM7 - Safeguarding Mineral Assets

Planning permission will only be granted for non-mineral development that is incompatible with minerals safeguarding where it is demonstrated that either:

  1. the mineral is not of economic value or does not exist; or
  2. that extraction of the mineral would not be viable or practicable; or
  3. the mineral can be extracted satisfactorily, having regard to Policy DM9, prior to the non-minerals development taking place without adversely affecting the viability or deliverability of the non-minerals development; or
  4. the incompatible development is of a temporary nature that can be completed and the site returned to a condition that does not prevent mineral extraction within the timescale that the mineral is likely to be needed; or
  5. material considerations indicate that the need for the development overrides the presumption for mineral safeguarding such that sterilisation of the mineral can be permitted following the exploration of opportunities for prior extraction; or
  6. it constitutes development that is exempt from mineral safeguarding policy, namely householder applications, infill development of a minor nature in existing built up areas, advertisement applications, reserved matters applications, minor extensions and changes of use of buildings, minor works, non-material amendments to current planning permissions; or
  7. it constitutes development on a site allocated in the adopted development plan where consideration of the above factors (1-6) concluded that mineral resources will not be needlessly sterilised.

7.27 The TWBC Draft Local Plan states “The Kent Minerals and Waste Local Plan is part of the Development Plan. Issues including minerals safeguarding are important considerations during decision taking on planning applications. Given the strong relationship between minerals and the delivery of new building, it is important that decisions do not put at risk the delivery of both Plans”.

7.28 KCC have specified that the criterion ‘adopted development plan’ should be interpreted literally, such that provided there is an adopted development plan with allocations, regardless of whether the development is incompatible with the mineral safeguarding principles, development in those areas is, in all cases, exempt from the need to consider safeguarding.

7.29 Clearly, although we understand that TWBC will have consulted with KCC, the Draft Local Plan by definition is not “adopted” and no further details have been provided to explain how the policy DM7 has been applied. This raises further serious concerns about the fulfilment of “Duty to Co-operate” requirements and whether either of these plans meet the test of soundness.

7.30 It is also relevant to explain that the substrates of the area are mainly alluvial deposits under a clay cap which extend over the CA1 Tudeley site. Indeed, this site was included in the early KCC Draft Minerals Plan and there now appears to be a contradiction between the safeguarding of these minerals and the proposed development of CA1 Tudeley.

8 : LEIGH RESERVOIR

8.1 The Leigh flood storage area (FSA) was built in 1982 following the devastating 1968 floods and is formed by a 1.3 kilometre-long, five-metre-high earth embankment across the Medway valley.

8.2 The River Medway passes through a reinforced concrete control structure built into the embankment. The 3 steel radial gates can be moved to either let the river flow normally, or to restrict the flow and hold water in the FSA, to control the amount of water flowing downstream.

[TWBC: for image showing concrete structure referred to above, see full representation].

8.3 The Environment Agency operates it at the peak of a flood event, when river levels passing through the structure are at their highest. However, at times of exceptional rainfall there will still be some flooding downstream.

8.4 It currently has a capacity to store 5.5 million cubic metres of water and plans to increase this have been approved. This will allow the Environment Agency to increase the flood reservoir water level from 28.05 metres to 29 metres at Leigh, upgrade an existing embankment near Hawden Farm in Hildenborough, and install a new control structure and pumping station to prevent water from the Medway backing up into the village.

8.5 The total cost of the project is estimated at £15.5million, with contributions expected to come from the South East Local Enterprise Partnership (£2.3m); the Environment Agency Flood Defence Grant (£10.1m); Kent County Council (£2.5m); and Tonbridge and Malling Borough Council (£0.5m).

8.6 The expected construction of the additional storage capacity is scheduled to commence in 2020, with anticipated completion in 2023, providing up to 30% additional river storage upstream.

8.7 The barrier was released in October 2000 and December 2013.

8.8 If we were to face another December 2013, namely that the barrier would be compromised or breached again, with the additional flood storage capacity, the velocity of the release would be greater than the 2013 release. This is likely to cause extreme damage to properties and a serious risk to human life.

8.9 There should be a requirement that that suitable assurances and mitigation are implemented to protect the communities that were flooded in 2013 by the barrier breach.

8.10 Photos of the December 2013 major flooding event when the Leigh barrier was released, Tonbridge Park:

[TWBC: for images, see full representation].

8.11 There are proposals for two further Reservoirs to be constructed to the south of Paddock Wood. These would have a maximum storage capacity of 220,000m³ (see section 11) and there is concern on the implications, e.g. flooding levels from the 2013 Leigh event exceeded 2.14m at Hartlake Bridge. This proposal would present a further significant risk to human life.

9 : TMBC LOCAL PLAN

9.1 Tonbridge & Malling Borough Council has prepared a new borough wide Local Plan focussed on the period up to 2031, which has been consulted upon and has reached the examination stage. The Inspector has raised several issues that are now subject to a further public consultation process that ends on 16-Dec-2019.

9.2 The T&M Borough covers a total area of 240 km² (70% Metropolitan Green Belt) which compares with a total area of 326 km² in the Tunbridge Wells Borough.

9.3 The plan is proposing a housing requirement within the Local Plan of an additional 6,834 dwellings to meet the projected population growth:

* 121,900 (2012)
* 133,000 (2021)
* 145,000 (2031)

9.4 Flood risk: The River Medway runs through the Borough, flowing from the upper reaches through the town of Tonbridge to the downstream section through and beyond Aylesford. The Medway is fluvial between the outer north-western limits of Hildenborough down to Allington Lock (in Maidstone). Downstream from the Lock, including Aylesford, the Medway is tidal, eventually feeding into the Thames Estuary.

9.5 Flood mapping shows that a significant section of the central area of the principal town in the Borough, Tonbridge, is at high risk from flooding. In addition, the Rural Service Centre of East Peckham is at high risk whilst parts of Aylesford, in the north-eastern parts, are at medium and high risk from flooding.

9.6 Significant rainfall fell during the days leading up to Christmas 2013 making it the wettest December in 79 years. During the Christmas period the flow in the Upper Medway was the highest ever recorded at 300+m³/sec. To put this into context, a figure of 220 m³/sec. was recorded in the year 2000 and 250 m³/sec. in 1968, the last two severe rain events.

9.7 High flows in the River Medway are controlled by sluice gates and a flood storage area at Leigh. Within the town itself there are flood walls which are built along the banks of the Medway. Even with the presence of flood defences, the town of Tonbridge is not completely protected from flooding.

9.8 Flood Policy: The Council has responded to the issue of flood risk during the preparation of the Local Plan by pursuing a development strategy that avoids areas at high risk of flooding, particularly for residential development. This assessment took account of an allowance for climate change over the plan period and the likely effect this will have on the flows of watercourses.

9.9 The increased likelihood of flooding is widely recognised as one of the key consequences of climate change in the UK. Severe flooding has, from time to time, been a key concern in Tonbridge & Malling causing distress to many local communities and damage to properties and infrastructure. The Council with its partners have striven to bring forward capital proposals to address issues and is working in partnership with other agencies to mitigate flood risk through other means.

9.10 In determining planning applications the Council will apply the requirements of the Government’s policy in the NPPF and the PPG on flood risk. If a development proposal is in conflict with the relevant national policy then it will be in conflict with this Policy.

9.11 Implications on TWBC Plan: The proposed development of housing, commercial, and associated infrastructure in T&M Borough will already lead to considerable additional water flows to the Medway and the floodplain. The cumulative effect on flooding implications, when added to by the TWBC plan, has not been fully assessed.

9.12 TMBC appears to have followed NPPF flood risk policy guidelines closely which highlights its efforts to discourage development within vulnerable flooding areas, where as TWBC have taken the opposite approach. TWBC are challenging current Green Belt Policy, requesting the removal of 100’s of hectares of MGB, and keen to promote many sites that are situated within Flood Zones 2 and 3.

9.13 TMBC have elected to promote a combination of small and larger developments widely across the borough, with the largest development a garden village at Borough Green. This will have a maximum of 1,700 dwellings, compared to TWBC’s largest two developments that propose around 8,000 dwellings within a 3 mile radius of each other and parts of these developments will be situated within Flood Zone 3 areas.

9.14 At a recent Extraordinary General Meeting of the TMBC Cabinet Advisory Board that discussed the TWBC Draft Local Plan, several members of TMBC raised serious concerns about the increased flood risk that could arise from the proposed developments in Capel. There is also concern that the TWBC plan does not demonstrate how the flood risk to several residential areas in Tonbridge Borough will be mitigated.

10 : CLIMATE CHANGE

10.1 The NPPF sets out how the planning system should help minimise vulnerability and provide resilience to the impacts of climate change. The Environment Agency published updated climate change guidance on 19 February 2016, which supports the NPPF and must now be considered in all new development plans and how allowances for climate change should be included.

10.2 The guidance presented in the Strategic Flood Risk Assessment (SFRA) prepared by JBA for the Paddock Wood area is based on UKCP09, but it should be noted that following the publication of UKCP18, updated Environment Agency guidance on climate change is expected to be issued in 2019, after the publication of this SFRA.

10.3 The 2016 climate change guidance includes climate change predictions of anticipated change for peak river flow and peak rainfall intensity. The guidance also covers sea level rise and water height. These allowances are based on climate change projections and different scenarios of carbon dioxide emissions to the atmosphere. Due to the complexity of projecting climate change effects, there are uncertainties attributed to climate change allowances related to the confidence in the prediction. As a result, the guidance presents a range of possibilities to reflect the potential variation in climate change impacts over the three periods that reflect the differing levels of confidence in the predictions.

10.4 Peak river flows: Climate change is expected to increase the frequency, extent and impact of flooding, resulting from an increase in the magnitude of peak river flows. Wetter winters and more intense rainfall may increase fluvial flooding and surface water run-off and there may be increased storm intensity in summer. Rising river levels may also increase flood risk. The peak river flow allowances provided in the guidance show the anticipated changes to peak flow for the river basin district within which the subject watercourse is located.

Once the river basin district has been identified, guidance on uplift in peak flows are provided for three allowance categories, Central, Higher Central and Upper End which are based on the 50th (Central), 70th (Higher Central) and 90th (Upper End) percentiles respectively. The ‘percentile’ is a measure of the confidence in the prediction of the magnitude of the allowance, i.e. lower uplift values (50th percentile – ‘Central) are statistically more likely and thus attributed with greater confidence compared with higher uplift values (e.g. 90th percentile – ‘Upper End’) which allow for future conditions that accept a greater level of uncertainty.

The allowance category to be used is based on the vulnerability classification of the proposed development and the flood zones within which it is to be located. These allowances are provided, in the form of figures for the total potential change anticipated, for three climate change periods:

* The ‘2020s’ (2015 to 2039)
* The ‘2050s’ (2040 to 2069)
* The ‘2080s’ (2070 to 2115)

The time period used in the assessment depends upon the expected lifetime of the proposed development.

10.5 Time frame: Residential development should be considered for a minimum of 100 years.

10.6 Fluvial flooding: Climate change does not just affect the extent of flooding. Even where flood extents do not significantly change; flooding is likely to become more frequent under a climate change scenario. The impact of an event with a given probability is also likely to become more severe. For example, as water depths, velocities, and flood hazard increase, so will the risk to people and property. Although qualitative statements can be made as to whether extreme events are likely to increase or decrease over the UK in the future, there is still considerable uncertainty regarding the magnitude of localised impact of these changes.

10.7 The map below (Figure 8) shows the fluvial flood projections that have been included in the SFRA using the following methodology:

  • Some climate change modelling was available from the Environment Agency for Alder Stream and part of the River Teise (downstream of Goudhurst Road) for the Flood Zone 3a event in the 2080s epoch for the Higher central and Upper end estimates. This information has been used to inform the predicted climate change extents presented in the mapping.
  • Additionally, modelling prepared as part of the SFRA for Paddock Wood also simulated these events, and this information has also been used to inform the mapping.
  • Where no climate change modelling and mapping is available, a precautionary approach has been adopted for the SFRA, in which the present day Flood Zone 2 extent has been used as a conservative indicator of the potential changes to Flood Zone 3a in the future. This does not directly relate to published guidance on potential changes to fluvial flood flows but used as an indication for the SFRA. Note that future modelling that does use the published values may produce outlines that differ from the mapping presented in the SFRA.
  • The modelling and mapping completed focused on predicted flood risk at the 2080s epoch (2070-2115) under increased flow rates of +30% and +70% for the undefended case 1% AEP event (Flood Zone 3a). The fluvial flow allowances represent the Higher Central and Upper End allowances under the latest guidance for the Thames River Basin District in which the River Medway catchment is located.

[TWBC: for Figure 8, see full representation].

10.8 This map is un-defendable as it appears to show no detailed modelling. All that it appears to have happened is that the lower risk areas have been “upgraded” to higher risk areas in certain areas. That is not modelling.

10.9 It also does not take into account the cumulative effects of surface run-off and groundwater flooding (see below).

10.10 All current climate change models strongly indicate that, while summer droughts will be more prevalent, storm events will be more common and stronger, as well as winters being milder and wetter. Both of these factors will mean that flooding events are likely to be more frequent and have a greater magnitude. At the moment, it is not entirely clear what new flood water levels will be: modelling a specific drainage basin's response to an increase in supply is difficult, as there are often too many variables. However, it is clear that even the conservative estimates of between 35% (by 2030) and 70% (by 2080) show increases in precipitation that are likely to be under estimations. This will have an impact on the long term sustainability of both of the Capel development sites.

10.11 Surface Water flooding: 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.

10.12 Groundwater flooding: The effect on groundwater flooding problems, and those watercourses where groundwater has a large influence on winter flood flows, is more uncertain. The updated climate change guidance released in February 2016 does not provide information on expected changes to groundwater flooding under future climate change. However, milder wetter winters may increase the frequency of groundwater flooding incidents in areas that are already susceptible. Where groundwater flooding is expected to influence a development site, it will be expected that consideration of groundwater flooding under a changing climate is assessed and measures taken to mitigate any change in risk.

10.13 Guidance: The NPPG contains information and guidance for how to identify suitable mitigation and adaptation measures in the planning process to address the impacts of climate change. In addition, assessments are required to demonstrate future implications of climate change have been considered, and risks managed where possible, for the lifetime of the proposed development:

  • Considering future climate risks when allocating development sites to ensure risks are understood over the development’s lifetime
  • Considering the impact of and promoting design responses to flood risk and coastal change for the lifetime of the development
  • Considering availability of water and water infrastructure for the lifetime of the development and design responses to promote water efficiency and protect water quality
  • Promoting adaptation approaches in design policies for developments and the public realm, for example, by building in flexibility to allow future adaptation if needed, such as setting new development back from watercourses
  • Identifying no or low cost responses to climate risks that also deliver other benefits, such as green infrastructure that improves adaptation, biodiversity and amenity, for example by leaving areas shown to be at risk of flooding as public open space.
  • Consideration of the vulnerability of the proposed development types or land use allocations to flooding and directing the more vulnerable away from areas at higher risk due to climate change.
  • Use of ‘built in’ resilience measures. For example, raised floor levels.
  • Capacity or space in the development to include additional resilience measures in the future, using a ‘managed adaptive’ approach.

The last consideration acknowledges that there may be instances where some flood risk management measures are not necessarily needed now but may be in the future. This ‘managed adaptive’ approach may include, for example, setting a development away from a river so it is easier to improve flood defences in the future.

10.14 Sea levels: BBC News (25-Sep-19) highlighted a scientist’s prediction of sea level increases of up to 1.1 metres by the mid 2000’s. [TWBC: for image within text, see full representation].

It is also very clear (from someone who has worked on climate change models), that the SFRA models and the longterm models in this report are very seriously underplaying the impact of climate change - especially as the ice-cap data from the North-Atlantic Ice reservoir indicates that we are almost certainly looking at something a lot more severe.

In a recent study on Greenland ice-caps (sadly, at the moment, unpublished), a figure of an 8 metre rise in sealevel was considered to be conservative.

10.15 Planning: Climate change is a serious worldwide problem, with far reaching consequences, and the Draft Local Plan fails to demonstrate that it has fully addressed the current understanding of the impact of climate change:

  • The Local Plan polices, e.g. Policy EN 5, lack any detail or clarity and should be far more robust.
  • NPPF 14 Meeting the challenge of climate change, flooding and coastal change:

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

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

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

10.17 Greenhouse gas and Carbon emissions will increase substantially over the development period, with the large number of HGV’s, and various construction machinery accessing the sites, as well as the local road network.

10.18 In addition, the proposed quarry extension at Stonecastle Farm, and additional quarries at the adjoining Moat Farm, will all have a detrimental effect on local air quality and increased carbon emissions.

11 : PW1 CAPEL EAST DEVELOPMENT

11.1 Draft Local Plan: The proposed development of Paddock Wood in the Draft Local Plan is listed as Policy AL/PW1 Land at Capel and Paddock Wood. Land to be allocated under this policy falls within both the parishes of Capel and Paddock Wood. Sites which lie outside the allocation(s) at present may be included in the Regulation 19 Presubmission version of the Local Plan. [TWBC: for Figure 9, see full representation].

11.2 This site, as defined on the Policy Map, is allocated for:

  1. The provision of approximately 4,000 new dwellings and a three pitch (one mobile home and one touring caravan per pitch) gypsy/traveller site on this land and in Paddock Wood Town Centre (AL/PW2);
  2. Additional employment provision, including expansion of Key Employment Areas (B1/B2/B8 uses);
  3. The provision of an enlarged Mascalls Secondary School and additional primary schools;
  4. The provision of a new medical centre;
  5. The provision of open space, youth and children's play and sports facilities (including a new outdoor sports hub) and recreational facilities as well as areas of natural and semi-natural green space and allotments/food growing.

11.3 Flood Policy Statement AL/PW1 Land at Capel and Paddock Wood: The development on the site should demonstrate that it will not exacerbate flooding elsewhere in the vicinity and through the provision of flood storage, attenuation/mitigation areas (including those outside the allocations) to substantially reduce the flood risk to particular existing residential areas in Paddock Wood, and potentially at Five Oak Green. This is one of the key justifications for the release of Green Belt land.

11.4 Focus: This report is focussed on the allocations within Capel Parish (sites PW 1-1 and PW 1-2 on the above map) and the effect on existing local communities and surrounding areas. Herein referred to as PW1 Capel East.

11.5 Strategic Flood Risk Assessment (SFRA)

11.6 The SFRA prepared by JBA for the Paddock Wood area has established that a large section of the proposed allocations are within Flood Zone 3. Development in Flood Zone 3a is significantly constrained by flood risk. Highly Vulnerable development is not permitted within this zone and More Vulnerable development and Essential Infrastructure are only permitted if the Exception Test can be passed.

11.7 Exception Test: Local Authorities are guided to adopt a precautionary approach to the issue of flood risk, avoiding such risk and managing it elsewhere. An Exception test is applied when it is not possible to locate development in zones with a lower risk of flooding.

The Draft Local Plan appears to fail the test as it does NOT steer new development to areas with a lower risk of flooding, and has not put forward obvious safer sites.

11.8 It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk and:

a) A site-specific Flood Risk Assessment must demonstrate that the development will be safe for its lifetime, taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall

b) It should be demonstrated that flood defences provide an acceptable standard of protection, including an allowance for climate change for the lifetime of the development.

c) Residual risks should be assessed, and the Environment Agency consulted regarding whether there is a need for a breach analysis to map a rapid inundation zone.

d) The layout of buildings and access routes should adopt a sequential approach, steering buildings towards areas of lowest risk within the site. Where rapid inundation zones have been identified, development should be avoided in these areas.

e) Development should not impede flow routes, reduce floodplain storage or consume flood storage in a ‘flood cell’ within a defended area. If the development does result in a loss of storage, compensatory floodplain storage should be provided on a ‘level for level’ and ‘volume for volume’ basis.

f) If existing defences are to be upgraded as part of the development, an assessment should be undertaken to ensure it does not result in an increase in flood risk elsewhere.

g) Development design should incorporate mitigation measures, to manage any flood risk to the development, including residual risk for the lifetime of the development. FFLs should be above the 1 in 100-year (1% AEP) flood level, plus an allowance for climate change.

h) It is recommended that all types of new development behind flood defences is avoided, where possible, due to the residual risks of breach and overtopping

i) Consideration should be given to the type of building that will be permitted, for example single-storey buildings and basements should be avoided.

11.9 The plan does not demonstrate that the proposed development at Capel East will provide wider sustainable benefits that outweigh flood risk, nor that it will be “safe for its lifetime”. The sustainability of any residential development should be considered over a minimum of 100 years. Therefore, the plan does not justify that this site, in such a location that requires measures to mitigate its flooding risk on a floodplain, will not flood in its lifetime, especially with the climate change uncertainties that must be taken into account (see section 10).

11.10 TWBC have not demonstrated how the proposed mitigation measures will ensure that the development will not cause flooding in the vicinity or further down river. The loss of flood water storage in the agricultural terrain and run-off/drainage from the buildings and hard surfaces will certainly increase the flood risk to all surrounding areas.

11.11 Development Parcels: Parcels within PW1 Capel East (1a-1b; 2a-2d) are separated by the railway line and comprise of a total of 114.5 hectares (280 acres) of undeveloped agricultural land. There are no formal drainage systems or any formal flood defences within or upstream of the parcels. See map below (Figure 10).

11.12 Ground levels slope from south/southwest to north/northeast. The largest watercourse through parcel 1 is Tudeley Brook, which enters the parcel in the south, before bifurcating into two streams that exit the parcel through separate culverts under the railway line. There is a smaller overland flow route in the southwest of the parcel that joins Tudeley Brook at the bifurcation, as well as an easterly overland flow path that joins a channel running along the east of the parcel.

11.13 An unnamed ordinary watercourse flows along the western boundary of parcel 2. This bifurcates and a branch of the watercourse flows through to the centre of the parcel before then flowing in a northerly direction. A further unnamed tributary flows into this watercourse from the south to the west of Whetsted Wood. Tudeley Brook flows along the eastern boundary of the parcel in a northerly direction.

11.14 Flood risk (present day): There are localised areas within Flood Zone 3b (functional floodplain), predominantly adjacent to Tudeley Brook and other minor watercourses, and in the east of Parcel 2.

11.15 Larger areas of land are designated Flood Zone 3a and these occupy much of the north of parcel 1, which appears to be exacerbated by flood water accumulating behind the railway embankment, as well as surrounding the easterly overland flow route and west of Tudeley Brook. Also, large areas of Parcel 2 are Flood Zone 3a, most notably in the north and east with localised areas to the west near the watercourses.

11.16 Fluvial flood risk is associated with the network of drains and ordinary watercourses as well as Tudeley Brook. These watercourses convey water from the hills to the south of the parcel and ultimately onward into the River Medway.

11.17 Surface water flood pathways generally align with the fluvial network, although rain falling directly on the parcel causes localised ponding of flood water.

11.18 Large areas of the north/north-west of parcel 2, and southern parts of Parcel 1, are susceptible to groundwater flooding.

11.19 Flood risk (climate change): The following mapping (Figure 10) displays the change in peak flood depths for the 1% AEP (+70% flows) event when the flood depths for the ‘with development’ model simulation are subtracted from the ‘SFRA baseline’ (no development at the parcel).

11.20 49% of the proposed area PW1 Capel East is at risk of fluvial flooding (67% of Parcel 1 and 33% of Parcel 2). [TWBC: for Figure 10 see full representation].

11.21 Flood risk increases, with changes in flood depth of up to +0.25m are typically predicted through the open space areas, although a portion of Parcel 1 has changes in peak flood depths greater than this predicted.

11.22 Flood depths across the railway line are predicted to increase. Flood depths and extents to the north of the railway line also increase, with some areas increasing by >0.25m.

11.23 The most influential factor predicted to change flood risk is residential area 1a and the impact this has on flood flow pathways.

11.24 This residential area potentially impedes the north-easterly flow of flood water, resulting in the deflection of water westward through the centre of the parcel and northward beyond the railway line.

11.25 The position of proposed development 2c is also influential, deflecting water eastward into Paddock Wood.

11.26 Flood Risk Management

11.27 Measures recommended by the SFRA to mitigate the impact of development and manage flood risk in the Capel and Paddock Wood area include:

11.28 Floodplain: The SFRA states “Compared to flood defences and flood storage, floodplain restoration represents the most sustainable form of strategic flood risk solution, by allowing watercourses to return to a more naturalised state, and by creating space for naturally functioning floodplains working with natural processes”.

11.29 This strategy has been understood in environmental science for years. However, the proposed development of PW1 on the floodplain is in direct contrast with the policy of using the Sequential approach of locating development away from watercourses. The opportunity to restore floodplain in previously developed areas is extremely limited.

11.30 Even re-wilding the flood plain would not protect the areas from surface water, drainage, and groundwater flooding together with the risks of sewage system failures and reservoir breaches.

11.31 Flood defences: There is a proposed defence that would extend from residential area 1a to the railway line, and aims to reduce the risk of flood water from Tudeley Brook along this eastward flow route. This would need to be considered in combination with other measures to help manage changes in flood risk.

11.32 When the defence is assessed, flood risk increases notably within Parcel 2, given the increase in flows across the railway line onto the north of the parcel. Flood risk also increases to the north of the parcel and in the area immediately east of proposed development 2c.

11.33 It is difficult to see how any effective further flood defences could be put in place within PW1 Capel East given that most of the flooding is simply caused by rain falling on the site faster than it is able to be absorbed due to the nature of the soil. Some water may flow onto the site from adjacent areas but to block this would result in unacceptable problems for those areas.

11.34 Increased conveyance: When the conveyance measures are assessed there remains increased flood depths predicted within Parcel 1 and to north of the railway line. Increased channel conveyance/new channels are predicted to provide only marginal flood risk benefits at a more localised scale rather than strategic benefits.

11.35 There also remains increased flood depths predicted across the majority of Parcel 2 and to the north.

11.36 Sustainable drainage systems (SuDS): These systems aim to alleviate surface water flooding by storing or re-using surface water at source. As surface water flows through the system, flow velocity to watercourses is controlled and pollutants are removed.

11.37 The SFRA states “Investigations will be required to evaluate whether infiltration SuDS are a feasible option. Drainage can utilise the existing watercourses within the parcel, and ditches and surface water sewers that may be present around existing development”. This statement of “feasibility” directly contradicts regulatory guidance and extensive SuDS initiatives must be considered in relation to the raised floor level requirements:

  • Planners should be aware of the conditions set by the LLFA (KCC) for surface water management and ensure development proposals and applications are compliant with the policy.
  • SuDS should be promoted (and implemented) on all new developments to ensure the quantity and quality of surface water is dealt with sustainably to reduce flood risk. On substantial development sites consideration should be given to the integration of sustainable water management with the provisions for green infrastructure within urban areas.

11.38 The raised levels (see below) facilitate the construction of containment tanks and other SuDS initiatives that should be included in the masterplanning. Comprehensive SuDS are required to mitigate the flood risk of the development on this fully functional floodplain and to ensure pre-treatment of contamination risk prior to infiltration.

11.39 Strategic Storage: The potential strategic storage parcels considered as part of the SFRA are positioned upstream of Parcel 1 on land within Capel Parish (see Figure 11) on Tudeley Brook - in order to reduce peak flow of flood events by reducing flood depths within Paddock Wood.

[TWBC: for Figure 11, see full representation].

11.40 Location 1 provides most opportunity for meeting the storage volume requirements (max storage 680,000m³). However, the area identified and maximum storage level/volumes would mean that development would not be possible at the Parcel 1 site and the PW1 plan would not be deliverable.

11.41 Location 2 (max 130,000m³) provides slightly greater other potential for flood storage and therefore reduction in flows. It is also further downstream so would capture greater volumes of run-off compared with location 3.

11.42 At location 3 (max 90,000m³), it is identified that greater storage volumes may be possible if the maximum storage could be increased.

11.43 It was agreed with the council that locations 2 and 3 should be considered in combination for model testing as part of the SFRA. However, there remains a localised increase in flood risk at the southern end of the parcel 1 due to reflection of flood water.

11.44 These proposed measures would probably be categorised as Reservoirs under the 1975 Act and Flood and Water Management Act, so would need to be designed, constructed and maintained accordingly. The required land parcels for this storage have not yet been safeguarded, as confirmed by TWBC Head of Planning (12-Nov-2019).

11.45 Raising levels: The raising of occupied floors of buildings above ground level so that a relatively unobstructed flow route under buildings may substantially reduce flood depths. The raising of floor levels within a development also avoids damage occurring to the interior, furnishings and electrics in times of flood:

11.46 * Finished Floor Levels (FFLs) should be set to the higher of a minimum of 600mm above the 1 in 100-year (1% AEP) plus climate change peak flood level, or 300mm above the general ground level of the site. This additional height is referred to as the “freeboard”. Additional freeboard may be required to account for risks such as blockages to the channel, culvert or bridge, reservoir breaches, and the uncertainty in the predictions.

11.47 The SFRA states “This measure was not implemented as it was agreed with the council that it would be unlikely to be deliverable given the scale and type of development being proposed”.

11.48 There have been several relevant developments recently in Capel where the EA has insisted on raised floor levels and containment (tanks, swales, etc.) with restricted discharge. In some cases, the EA have specified the inclusion of voids below the raised ground floor level to allow flood water to run and lay below the ground floor accommodation, including bedrooms.

11.49 Given the nature and likely EA requirement of these being compulsory measures within the development, it follows that the PW1 plan is not likely to be deliverable as stated by TWBC. Several points are relevant to the need for raising the levels of the developments:

  • The SFRA understates the impact of climate change over the >100 year horizon for residential development
  • The dwellings would need to be protected from a potential breach of the new reservoirs
  • These parcels are most affected by surface water and groundwater flooding
  • The wealth of guidance on flood risk and climate change (see sections 4 and 10)
  • Occupiers (and insurers) are imposing more stringent measures than the basic statutory requirements
  • The existing agricultural ditches and watercourses have been in place for centuries and are not designed to accommodate the run-off and drainage from this proposed level of development
  • Flooding risk resulting from the construction of buildings, roads, driveways, and other impermeable areas would not be materially affected by the raising of these levels. The EA are likely to prefer these measures.
  • The raising of the levels would facilitate the incorporation of storage tanks and other SuDS (see above)
  • Strategic drainage flows and watercourses can be accommodated within the freeboard

11.50 Therefore, the plan is not sound as it has not properly addressed the measures necessary to mitigate the flood risk from the PW1 Capel East development.

11.51 Increased Flood Risk

11.52 Our principle objections to the Policies STR/PW1 & AL/PW1 CAPEL EAST are that the proposed development will increase the flood risk both within the development and to the existing communities in Paddock Wood, Five Oak Green, and the surrounding areas.

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

  • These development proposals are very reliant on additional storage capacity at Leigh and do not provide any contingency plans should there be a repeated breach. The planned further storage capacity upriver at Leigh will increase river flows down river when under stress causing significant risk to human life.
  • The impact of climate change has not been adequately assessed over the >100 year horizon and appropriate cautionary allowances have not been made.
  • The parcels are not currently protected by formal flood defences and the SFRA admits that the development will cause increased flood risk. Given that the proposals remove so much floodplain storage by building on it, then the contradiction should be fairly obvious. There is also an admission that other areas 2 - 12 can only be seen as "not influencing flooding" if they are considered in isolation. That is a seriously weak fudge.
  • Given that, for the majority of the sites, flooding from the Medway is mostly irrelevant, the Leigh Barrier should be discounted as effective mitigation for these sites - as are widening the Medway, etc.
  • Loss of floodplain connectivity within rural upper reaches of tributaries which flow through/around the development site is likely to increase flooding.

    The SFRA does not conclude that the limited mitigation will eliminate future flood risk or provide evidence of ‘betterment’ to the existing residential areas.

11.54 The above policies are inconsistent with Policy EN 1 : Water/Flooding:

  1. Ensure there is adequate drainage provision. This will ensure that the surface water is appropriately controlled within the development site, flood risk is managed on-site and off-site, and any existing flood risk, in the locality is not exacerbated: and
  2. Avoid inappropriate new development within areas at risk from flooding, or mitigate any potential impacts of new development within such areas whereby mitigation measures are integral to the design of the buildings.

    Development/removal of this part of one of the UK’s largest floodplains is not appropriate and the presented plan does not provide the necessary justifications for the release of Green Belt land.

11.55 It is extremely concerning that TWBC have not provided sufficient evidence and assurances that the identified sites, situated in a well-documented flood vulnerable area, will be protected and are prepared to ignore NPPF guidelines, and local community concerns, in pursuit of achieving their housing targets.

12 : CA1 TUDELEY DEVELOPMENT

[TWBC: see full representation for Figure 12].

12.1 Draft Local Plan: The proposed development of Tudeley in the Draft Local Plan is listed as Policy STR/CA1 with the following requirements:

  1. The provision of a standalone garden settlement (referred to as Tudeley Village) of 2,500-2,800 dwellings, together with appropriate employment, including retail provision, within the settlement. This shall be developed using a comprehensive masterplanning approach;
  2. The delivery of a new secondary school to the west of Tudeley Village (and to the east of Tonbridge);
  3. The provision of a new primary school within Tudeley Village and the expansion of Capel primary school;
  4. Together with land outside of Capel parish on the northern, eastern, and southern sides of Paddock Wood, and within the town centre, a proportion of approximately 4,000 new dwellings and associated education, leisure, and health facilities to be delivered (on the wider allocations);
  5. The provision of flood storage/attenuation/mitigation areas to reduce the flood risk to particular existing residential areas in Five Oak Green and Paddock Wood;
  6. 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;
  7. Strong green infrastructure must be provided to tie in new development with the surrounding landscape. Multifunctional green infrastructure (green wedges) to be integrated with drainage and flood defence measures;
  8. Additional housing may be delivered through the redevelopment of appropriate sites and other windfall development inside the defined Limits to Build Development of Five Oak Green;
  9. Tudeley Village and land at Capel and Paddock Wood will both require the release of Green Belt land.;
  10. Furthermore, the northern part of the site allocation for employment at Land adjacent to Longfield Road (Policy AL/RTW12) (which predominantly comprises land indicated as Open Space and Buffer and will not include built development on it and therefore will not be released from the Green Belt), also lies within Capel parish;
  11. Zero and low carbon energy production to be considered during early design stages and incorporated to provide an exemplar scheme;
  12. Where a site is within the AONB, it should be demonstrated that the proposal will make a positive contribution towards achieving the objectives of the most recent AONB Management Plan and show how relevant guidance from the AONB Joint Advisory Committee has been considered to meet the high standards required of the other policies in this Plan for the High Weald AONB landscape;
  13. Sites outside the AONB but within the High Weald National Character Area, or 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. The AONB Management Plan and any supporting guidance will be a material consideration for these sites.

12.2 Flood Policy Statement AL/CA1 Tudeley: The provision of flood storage/attenuation/mitigation areas to reduce the flood risk to particular existing residential areas in Five Oak Green and Paddock Wood;

- Contributions will be required for flood storage/attenuation/mitigation;

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

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

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

12.3 Strategic Flood Risk

12.4 Whilst we acknowledge the SFRA report on Paddock Wood, there is no such assessment for CA1 Tudeley. This is despite the Policy Overview stating “Flood Zones 2 and 3 in northern part of Tudeley”. It is well known that many parts of this site are regularly subjected to flooding, as demonstrated in this report.

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

  • The northern section of the proposed development CA1 includes areas within the floodplain as shown in the EA current flood risk map (Figure 6) even before any adjustment for climate change.
  • There is no assessment of the effects of this proposed development on the surrounding communities located along this flood plain.
  • The increased risk of flash flooding from surface water given the vast amount of lost agricultural land.
  • Run-off from developments, including roofed and paved surfaces.
  • The specification of adequate SuDS to mitigate the flows and filter contaminated run-offs.
  • The site is already at risk from extensive surface water flooding (Figure 13 below).
  • The assessment of the impact of climate change on local and wider areas.

12.6 The EA map below shows the likelihood of surface water flooding, and is a general indicator of an area’s flood risk but does not include flood risk from sources such as blocked drains and burst pipes.

[TWBC: for figure 13 referred to above, see full representation].

12.7 The area proposed for removal from the Green Belt designation is shown in red outline. This surface water map confirms the existence of several flow routes that dissect the site, particularly in the northern parcel, and is supported by extensive flood history (see section 3).

12.8 Railway

12.9 The site is divided by the South Eastern Main Line and both the CA1 Polices and Infrastructure Plan do not include any explanation of how the two main parts of the “garden village” will be connected. The location of these developments would lead to significant noise and other pollution problems. Also, a bridge(s) over the line will need to be built to connect the two halves of the proposed village. The specification would undoubtedly be required to be high enough to allow for possible future conversion of the line to overhead power cables.

12.10 There is currently only one small bridge under the line to allow access for farm vehicles and the small number of 14 dwellings along Sherenden Road in the central portion. However, this is frequently flooded in the winter months and regularly throughout the year. The possibility of solving the problem with a level crossing is almost certainly to be rejected given how busy the rail line is and how much road and pedestrian traffic there would be using it. A new station at Tudeley has been refused by Network Rail.

12.11 There are a number of existing culverts running under the Railway line. These would need to be regularly maintained to prevent flooding. It is likely that additional culverts will be necessary but these will need to consider flood risk and water flows on to the northern section in particular.

12.12 Increased Flood Risk

12.13 The geology, topography, and hydrology of the CA1 Tudeley site has been explained earlier in this report (sections 1, 2 and 6). The area to the north of the railway is much lower and the water flows are broadly south to north. The railway embankment provides some restriction and banking of water, particularly at the eastern section.

12.14 This area of approximately 375 acres of substantially undeveloped agricultural land already sends vast amounts of water northwards to the fully functional floodplain and aquifers. The scale of the proposed development would mean that extensive flood mitigation measures are needed due to the substantial increase in flood risk (see below):

  • Substantial run-off from the construction of buildings, roads, driveways, and other impermeable areas
  • Restriction of the existing agricultural ditches and watercourses that have been in place for centuries which are not designed to accommodate the run-off and drainage from this proposed level of development
  • Loss of floodplain connectivity within rural upper reaches of tributaries which flow through/around the development site
  • A large proportion of existing vegetation would be destroyed - trees, wooded areas, hedges, surface vegetation and crops. This vegetation absorbs large quantities of water during active growing periods significantly reducing the ground water level ahead of the winter. Water volume and flood height will increase, e.g. a single mature Oak tree can absorb 100,000 gallons of water from the ground each year (Building Research Establishment).
  • Contamination risk from pollutants in run-off flows to the GSPZ aquifers at Hartlake and other watercourses.

12.15 Flood Risk Management

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

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

12.18 The masterplanning will likely include the construction of additional strategic storage facilities/reservoir(s) to restrict the water flows from the development. Whilst the location is unidentified, there are several relevant issues that need to be considered:

  • The southern parcel (south of the railway) of the CA1 site does not directly benefit from the strategic storage at Leigh, given that the existing flooding here is from run-off from higher ground to the south, surface water, and watercourses that are downstream.
  • The southern parcel comprises c. 250 acres of agricultural land (with 9 dwellings) and, given the sloping nature of the terrain (see Figure 14), the development would result in vast amounts of run-off that will descend towards the railway and eastwards across the Sherenden Road area. The railway embankment already acts as a buffer, particularly in the north-east, and this is also shown in the above surface water map.
  • The design of strategic storage in the southern parcel would need to take account of the risk of a possible future breach and, in particular, its effect on the northern parcel. This also has implications for the build design and other mitigation measures (see below). [TWBC: for Figure 14, see full representation].
  • Large areas of the northern parcel are already subject to risk from fluvial flooding of the Medway and, whilst the increased capacity at Leigh would provide some strategic mitigation, a repeated breach would cause increased flood levels compared to those in 2000 and 2013.
  • The northern parcel comprises c. 125 acres of substantially agricultural land (with 5 dwellings) and is closely linked with the Medway floodplain. Given the relatively flat landscape, and closer proximity to the water table, any strategic storage for this parcel would need to be considered along with other extensive mitigation measures (see below).

12.19 Residual risk of any new reservoir(s) and potential flood defences (see below) should be understood and managed and maintenance arrangements (including funding mechanisms) will need to be evidenced for the lifetime of the development (>100 years) including appropriate allowances for climate change.

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

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

12.22 Increased conveyance: There are a number of well-maintained and regularly dredged streams and ditches that exist on the proposed site. These are important both in allowing water from adjacent areas to pass through and providing water storage capacity. Robust sustainable provision will need to be made to ensure this capacity is sufficient to mitigate the increased flood risk from the proposed developments.

12.23 Raising levels: The raising of occupied floors of buildings above ground level so that a relatively unobstructed flow route under buildings may substantially reduce flood depths. The raising of floor levels within a development also reduces the risk of damage occurring to the interior, furnishings and electrics in times of flood.

12.24 Given the nature and likely requirement of these being compulsory measures within the northern parcel, and northern/eastern parts of the southern parcel (see Figure 14) in particular, the exact level of land raising is dependent on the predicted flood levels and the EA allowance for climate change. The building design must specify how the flood risk from ALL sources is adequately mitigated.

12.25 Finished Floor Levels (FFLs) should be set to the higher of a minimum of 600mm above the 1 in 100-year (1% AEP) plus climate change peak flood level, or 300mm above the general ground level of the site. Additional freeboard may be required to account for risks such as blockages to the channel, culvert or bridge, reservoir breaches, and the uncertainty in the predictions.

12.26 The raising of building levels facilitates the construction of containment tanks, and other SuDS initiatives, and strategic drainage flows and watercourses can be accommodated within the freeboard.

[TWBC: for image see full representation].

12.27 Sustainable drainage systems (SuDS): These systems aim to alleviate surface water flooding by storing or re-using surface water at source. As surface water flows through the system, flow velocity to watercourses is controlled and pollutants are removed. Regulatory guidance must be considered in relation to the raised floor level requirements:

  • Planners should be aware of the conditions set by the LLFA (KCC) for surface water management and ensure development proposals and applications are compliant with the policy. SuDS should be promoted (and implemented) on all new developments to ensure the quantity and quality of surface water is dealt with sustainably to reduce flood risk. On substantial development sites consideration should be given to the integration of sustainable water management with the provisions for green infrastructure within urban areas.
  • The location of surface water attenuation storage or other forms of SuDS will impact the masterplan in terms of developable area, building design and access. In addition to the statutory planning requirements, building occupiers are increasingly aware of the potential for flooding to impact their operations. As a result, some major occupiers are imposing their own flood risk standards which are more stringent than the planning requirements.
  • Where an investor (and insurer) is considering an asset that satisfies the statutory requirements, this may not be sufficient to truly consider the potential for re-letting, with some occupiers being unwilling to compromise their own demanding flood standards.

12.28 Comprehensive SuDS are certainly required to mitigate the flood risk within the development and to ensure pretreatment of contamination risk prior to infiltration to the fully functional floodplain and the aquifers.

12.29 Policies STR/CA1 & AL/CA1 have not identified the measures necessary to mitigate the flood risk within the development and the stated ‘betterment’ of flood risk to the existing residential areas would need to be evidenced with a suitable guarantee that would satisfy insurance underwriters.

12.30 This report has highlighted the many inconsistencies within the Draft Local Plan and, considering the evidence, it seems incomprehensible that the Council has not conducted a SFRA for CA1, unlike other identified flood vulnerable sites. The presented Plan is neither sound nor deliverable and does not provide the necessary justifications for the release of Green Belt land.

13 : SEWERAGE

13.1 Flood risk

13.2 Since 1980, the Sewers for Adoption guidelines have meant that most new surface water sewers have been designed to have capacity for a rainfall event with a 1 in 30 chance of occurring in any given year, although until recently this did not apply to smaller private systems. This means that, even where sewers are built to current specification, they are likely to be overwhelmed by larger events of the magnitude often considered when looking at river or surface water flooding (e.g. a 1 in 100 chance of occurring in a given year).

13.3 Existing sewers can also become overloaded as new development adds to the discharge to their catchment, or due to incremental increases in roofed and paved surfaces (urban creep). Sewer flooding is therefore a problem that could occur in many locations across the Tunbridge Wells Borough and more specifically in Paddock Wood.

13.4 In Five Oak Green, we are aware that some surface water finds its’ way into the foul system at times of elevated stress on the system overall. That is why some houses have had to be fitted with non-return valves under their bathrooms to prevent sewage coming up from the drains.

13.5 In Paddock Wood, the areas susceptible to sewer flooding are generally located from the allocated parcels in the plan which are predominantly in rural locations. One notable exception is the parcel to the west of Maidstone Road which is located adjacent to an area which has experienced at least six instances of sewer flooding.

13.6 Current Infrastructure

13.7 There is a single treatment plant that serves Capel, Paddock Wood, and surrounding areas which is located at Rhoden, Paddock Wood (see drainage map below). The total catchment area is approximately 3,600ha, with an elevation range of 7mAOD to 149mAOD and the sewerage system is primarily separate.

[TWBC: for Figure 15, see full representation].

13.8 The Paddock Wood foul drainage system is split into two distinct areas by Tudeley Brook. The western area comprises of the village of Five Oak Green and a number of hamlets and farms to the south, connected to the network by a terminal SPS. In Paddock Wood piped flows drain north east to two terminal SPS discharging to the treatment works.

13.9 The surface water drainage network follows the highway layout and discharges at a number of locations to the Rhoden Stream, Gravelley Ways Stream and Paddock Wood Brook. There are also surface water attenuation ponds predominantly located in the south of the town, for which Paddock Wood Town Council are responsible for.

13.10 Paddock Wood Brook passes through the urban area and is culverted for the majority of its length. There are two unculverted sections, one off Rowan Close and a section alongside The Cedars. The Gravelley Ways Stream is a narrow water course which borders the western extent of the town into which some of the urban runoff discharges.

13.11 Sewerage from Five Oak Green is pumped to the treatment plant at Paddock Wood by a pumping station situated between Oak Road and Larkfield. There is a catchment tank which can hold enough to give time to bring tankers if the station fails. Failure occurs on a regular basis due to plant failure, pipe failure both upstream and downstream or power supply failure (there is no backup generator). Failures mainly last for days or in some cases weeks. In the event of such a failure three large tankers are brought in to remove the sewerage, with one full tanker load being removed every hour. The regular failures that occur are due to the existing system being overloaded and the age of the system.

13.12 The current sewer infrastructure is already under excessive strain, there are two very old large pumps, and one has been out of commission. The pumps are so old that parts have to be specially made as the manufacturer no longer exists.

13.13 The current house building programme in Paddock Wood has been halted due to inadequate sewerage infrastructure and we believe that one developer (Berkeley Homes) is working on the provision of huge sewerage/water storage holding tanks with Southern Water.

13.14 Flood history

13.15 Historical incidents of flooding are detailed by Southern Water in their DG5 register. This database records incidents of flooding relating to public foul, combined or surface water sewers and displays which properties suffered flooding. The data provided by Southern Water covers all reported incidence as of its export of 3 October 2016.

13.16 DG5 records provided by Southern Water indicate that there have been more than twenty reported flood instances in the Paddock Wood area as a result of overloading public sewers.

13.17 Town Council committee minutes reveal that many more flood instances occur but residents were unable to get through to Southern Water at the time. There are residents living in bungalows in Paddock Wood that are unable to use their toilets in times of heavy rainfall as they will overflow.

13.18 Southern Water recorded sewer flooding in 2008 and 2009. The EA also describes issues of hydraulic overload from foul sewers in Five Oak Green.

13.19 Proposed Development

13.20 Southern Water have confirmed that any projects of a strategic scale that are required to increase the local sewer network capacity, in particular in the Paddock Wood/Capel area, will need to be included in their next AMP. This will cover the period from 2025-2030 and will be agreed by Ofwat.

13.21 Where capacity constraints for new development have been identified in the sewer network, occupation of development will need to be phased with the delivery of network reinforcement, in liaison with the service provider and Southern Water has requested that this requirement is set out in the Local Plan.

13.22 Current Development: Sewer flooding is already a regular problem within Paddock Wood/Five Oak Green and, due to lack of investment over many years, the current system is already at capacity. Recent developments have been delayed/suspended as Southern Water are working with developers on additional storage capacity solutions as any further connectivity to the current infrastructure will seriously compromise existing users.

13.23 Existing sewers have become overloaded already as new developments add to the discharge to their catchment, due to incremental increases in roofed and paved surfaces at the individual property scale and sewer flooding is already a major problem. New homes are being built and connected to a sewerage system that is already so inadequate that it results in sewage flowing through the streets and the flooding of existing properties. The overload of the current network has unacceptable, unhealthy and frankly disgusting consequences for residents.

13.24 Greg Clark MP met with representatives of Southern Water, members of Paddock Wood Town Council, and officers and members of Tunbridge Wells Borough Council and Kent County Council on 7 September. All those local representatives were dismayed to discover that the previous plans were not even going to be proceeded with, and that the company had in effect gone back to the drawing board to consider what could be done about the capacity in Paddock Wood.

13.25 Mr Clark also raised this matter in a Parliamentary debate in the House of Commons on 28-Oct-2019 and asked three questions of The Under-Secretary of State for Environment, Food and Rural Affairs (Rebecca Pow):

1) Will she intervene to insist that Southern Water present comprehensive infrastructure plans without further delay to the community of Paddock Wood and others in my constituency where development is being considered, and that it implement those plans?

2) Will she strengthen the powers of local councils to require water companies to make an assessment of the infrastructure needs, and not to approve new development until it is certain that the infrastructure will be provided before or at the same time as the development?

3) Will she accept that if we as a nation are to support development, whether it is in the town or the countryside, commercial or residential, the rules should be established and acted upon, and that there is always I before E: infrastructure before expansion?

Ms Pow replied “Without a doubt, evidence highlights that the performance of Southern Water has left a great deal to be desired. If improvements are not forthcoming, I shall be requesting a meeting with Southern Water. I believe my right hon. Friend asked whether I would step in and take some serious action, and I shall be doing that and asking some serious questions” and agreed to meet with Mr Clark saying “Of course I will meet my right hon. Friend. We want water companies that are working effectively and efficiently, and we need to understand the pressures they are under and how to deliver for all new houses. We are committed to building new houses as a Government. We need new houses, but they need to function properly, with the right infrastructure, so of course I will meet him. In conclusion, we want to see a water industry that puts customers at the heart of the business, contributes to communities, and protects and enhances our precious natural environment. I will continue to push the sector and hold water companies, such as Southern Water in this case, to account if necessary”.

13.26 Paddock Wood and Capel: Southern Water note that treatment capacity is currently limited at Paddock Wood, and the levels of development proposed exceed the current catchment forecast. The level of growth outlined at this stage for Paddock Wood will more than double the size of the catchment, triggering the need for investment in network and treatment capacity solutions.

13.27 There will be a need for investment in the Paddock Wood treatment works to deliver increased capacity for the proposed housing growth. Therefore, new development would need to be coordinated with the provision of additional capacity and Southern Water will need clarification on the potential phasing of new development to ensure that this issue is addressed early in the process and to ensure that this investment is delivered alongside the housing growth.

13.28 Whilst land around the existing plant has been safeguarded for necessary expansion, Southern Water do not currently have an allocated budget for any extension, and have not provided any guidance on its expected delivery.

13.29 Capel (CA1 Tudeley): Southern Water will be carrying out further capacity assessments at both the existing Paddock Wood and Tonbridge treatment works to assess capacity to meet the future needs of all the proposed developments in Capel parish, including CA1 Tudeley.

13.30 In terms of the sewage network, this is upgraded in line with the specific requirements of individual development proposals as they come forward. It is likely that some sites will necessitate reinforcement of the sewerage network in order to accommodate additional foul flows. Southern Water aims to provide timely infrastructure in cooperation with developers and the local authority, and therefore early engagement is encouraged.

13.31 Given the above constraints at Paddock Wood and extensive increased demands on the Tonbridge sewerage plant, there is a very real likelihood that a complete new treatment plant will be required at Tudeley. Whilst the provision of sewerage facilities has not been specified, the consequent run-off to the Medway floodplain from new plant would further add to flooding risk and adequate/enhanced mitigation from SuDS and other measures must be incorporated in the build design at CA1 Tudeley (see section 12).

13.32 TWBC has confirmed (12-Nov-2019) that there are no detailed plans for sewerage infrastructure provision at CA1 and this would be ‘determined through infrastructure masterplanning’. They expect to receive further information from Southern Water in their response to this Regulation 18 consultation.

13.33 Funding sources: Developer contributions for local sewerage infrastructure will be secured through the New Infrastructure Charge.

13.34 Additional investment in waste water treatment works is funded by Southern Water through the water industry's price review process as agreed by Ofwat. Over the lifetime of the Local Plan, there will be repeated opportunities to fund any future investment as it is needed.

14 : POTABLE WATER SUPPLY

14.1 Current Infrastructure

14.2 At present the water supplying the Capel/Paddock Wood area (WRZ7) is taken from Trottiscliffe and the surrounding areas (from groundwater) where it is treated. This supply is then transported via strategic mains to a storage reservoir at Bour Beech (Seven Mile Lane), then onto the Paddock Wood Service reservoir (Gedges Hill) and then out to supply the local areas. Occasionally the water is also taken from Bewl Water (a surface reservoir) and transferred to the area via trunk mains and a storage reservoir.

[TWBC: for Figure 16, see full representation].

14.3 The EA has applied a Groundwater Protection Zone (GSPZ) related to the aquifers at Hartlake (Figure 16 above) with the route of the supply from the Hartlake Wells shown on the right:

* Hartlake Wells pump → Lilley Farm → Paddock Wood reservoir → Pembury/Tunbridge Wells customers

14.4 In 2018 work near Brampton Bank was carried out to replace pipe section being 350mm diameter that feeds from Lilley Farm to the Paddock Wood Reservoir, Pembury.

14.5 Out of the five public wells at Porters Lock Hartlake, the old Well route is to the West, and a newer uPVC pipe runs to the East which scales 800m downstream. This indicates that a while ago Hartlake needed to draw more because Tunbridge Wells needed it, so another draw line was drilled and built to tap into the old system being the concrete bases in the middle of the hoppers, now corn field.

14.6 A system of private water mains belonging to Hadlow Place Estates exists around the area of the proposed CA1 development which they would like to pass over to South East Water (SEW). Given that SEW also have a mains in Hartlake road this seems unlikely to happen. In any event, the water pressure in both systems is very low and even combined they would have no where the needed capacity to supply the proposed new town. Indeed where any of these pass under the site they may well be required to be capped off to reduce the risk of future leeks causing subsidence.

14.7 Proposed Development

14.8 SEW have stated that the same sources will be used in the future and forecasts for WRZ7 show there would be a deficit in the amount of water available to supply the growing demand by 2030.

14.9 A number of different options are being investigated to ensure enough water is available including demand management, reducing leakage, metering, recycling water, creating new sources, sharing water with other companies and expanding our current sources and treatment capacity.

14.10 Paddock Wood and Capel: Whilst SEW have stated that there is sufficient capacity in the existing network to supply the planned developments in East and Central Paddock Wood, there will also be large strategic mains installed to take surplus water from a new source of water at Aylesford towards Beech reservoir by 2023.

14.11 This will allow for more water to be transported in and around the WRZ7 area via the large strategic mains and to support the expected growth in consumption at PW1 Capel East. For the new source at Aylesford some of the existing network between Beech and Paddock Wood will need to be reinforced.

14.12 For the properties near Tudeley, SEW plan to lay new mains to connect back to a strategic trunk main that transfers water from Beech reservoir to Paddock Wood reservoir as the existing pipes are typically much smaller at around 5” and unable to sustain higher demands. They plan to link in the Capel East development to the same main with a short section of reinforcement main.

14.13 Funding sources: The Water Act enables South East Water to charge developers for a contribution towards any reinforcement and new mains required as a result of new development to ensure it maintains levels of service for both new and existing customers. The cost of contribution is based upon the cost of both on-site and off-site mains less all the revenue South East Water receives over the first 12 years for the new properties.

14.14 Capel (CA1 Tudeley): Although there is some capacity already in their plans to serve the proposed Tudeley garden settlement, it is considered that it may require an adaption or expansion of the existing mains. This is in addition to the laying of new mains within the residential area.

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

14.16 The Hartlake catchment is already at risk from nitrate and pesticides and the investigation found a significant relationship between groundwater levels in the river terrace gravels at the Hartlake site and River Medway levels and flows. Metaldehyde has been applied to the nearby neighbouring agricultural land surrounding the abstraction and high levels of metaldehyde concentrations have also been found in the River Medway.

14.17 The GSPZ catchment area of the significant Aquifer at Hartlake, which is SPZ3, extends under almost all the section of CA1 Tudeley that is north of the railway line. Any further development of this area may impact water supply options that serve SEW customers in Pembury and Tunbridge Wells:

  • SEW have stated they intend to use the same sources of Hartlake Wells for future supply but have not anticipated additional provisions for 2,800 new homes, which would result in a deficit in the area by 2030.
  • SEW will be required to increase the current water infrastructure which will require a substantial developer contribution under the water Act, but there are currently no details of these financial obligations required of the developer/landowner. Furthermore, there is very little detail regarding the improvements of supply, treatment facilities, and timing of their provision which the above highlights is critical to the delivery of the development.
  • Polluted run-off from the proposed development in both construction and general pollutants/chemicals will find its way into groundwater and aquifer/rivers without extensive SuDS filtration, and indeed as a result of any breach or failure of these measures.
  • The Council states the protection of ground water resources is particularly important in Tunbridge Wells Borough, since the majority of the public water supply is abstracted from water-bearing strata or aquifers. The quality of ground water is easily polluted, directly and indirectly, and can pose a serious risk to public health.
  • Clearly CA1 is situated within an area where its water resources are already under serious stress, and currently there are a number of issues outstanding with the Environment Agency, KCC and local residents.
  • In 2002, KCC refused planning permission for quarry extensions at M13 Stonecastle Farm (see section 7) on the grounds of potential pollution and contamination to the Aquifers, as well as concerns of public health risk, as the Hartlake Aquifers are a source of public and commercial water supply. Future mineral extraction would involve wet excavation methods, and recharge trenches, which will certainly affect the capacity of the Hartlake drawdown.
  • The draft plan does not identify the neighbouring two historic landfill sites which have had millions of tonnes of household and industrial rubbish deposited there in the 1980’s and 1990’s. Given the historical issues regarding previous mineral workings, and the major concerns of further pollution to the surrounding aquifers it is very concerning that the Council have not appeared to have considered the potential environmental and health risks prior to the inclusion of CA1 Tudeley in the Draft Local Plan.

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

14.19 The Aquifer and natural springs within the CA1 site will seriously hinder excavations for building, sewage, drainage, etc. as suitable mitigation schemes will have to be implemented to avoid puncturing the natural clay membrane that protects the Aquifers.

15 : SUSTAINABILITY APPRAISAL

15.1 There were 13 sites brought forward as proposed Garden Settlement Sites:

1) Blantyre House, (Former Prison) Goudhurst Parish,
2) Capel,
3) Frittenden Area,
4) Horsmonden,
5) Iden Green,
6) Kippings Cross, East of Pembury and adjacent to the northern and southern carriageways of the A21,
7) Land Adjacent to Colliers Green Primary School, Colliers Green
8) Land at Great Bayhall, East of RTW,
9) Land between Cranbrook & Sissinghurst,
10) Land between Sandhurst and Iden Green,
11) Langton Green, adjoining western edge of existing development
12) Paddock Wood, land surrounding the existing settlement
13) Walkhurst Farm, Benenden

15.2 Eleven sites were rejected or did not come forward in the final call for sites process.

15.3 The two allocated sites (PW1 and CA1) are within a 3 mile radius and situated on/adjacent to a dedicated floodplain with a well-known flood history, all the other sites are not situated at such flood vulnerable locations. It very much appears that Flooding has a much lower score rating with TWBC within its Sustainability Assessment commentary than other LPAs.

15.4 Given the flood history of the two identified areas and the substantial size of the developments, the overwhelming evidence seems to indicate that the scoring/rating assessment/analysis has not been considered/evaluated equally across the Borough, and has failed to evaluate the potential risk to human health/life should further flooding occur.

15.5 Chapter 4: Methodology (Table 4 pg.24) states “KCC Draft Minerals and Waste Local Plan - Sites at Moat Farm and Stone Castle, Five Oak Green are adjacent to the boundary with Tunbridge Wells Borough (TWB)”.

Since both Moat Farm and the entrance to/large parts of Stone Castle Quarry are within TWB, and adjacent to the proposed CA1 site, this error reinforces our view that the Mineral Assets have not been adequately considered in the Draft Local Plan (see section 7).

15.6 Chapter 6: Spatial Development Strategy (Table 15 pg.42) states “There is also potential for increased flood risk due to cumulative effects. However, significant betterment of flooding issues at Paddock Wood and Five Oak Green, and policies for other smaller sites, will provide significant positive benefits. Overall score is mixed”.

It is now understood that the Alder stream project would not be progressed and the ‘betterment’ for FOG would be through CA1 Tudeley, as confirmed by TWBC Head of Planning (12-Nov-2019).

Given the total absence of any specification of flood mitigation at CA1, this “mixed” score is certainly not sustainable as it cannot be proven to be deliverable.

15.7 Chapter 6: Spatial Development Strategy (Table 16 pg.45) states “A mixed/positive water scores is applied to [CA1] as it would represent a substantial demand for water and wastewater treatment and would provide significant benefits to Five Oak Green in the form of reductions in existing flood risk. The presence of the total catchment of a Groundwater Source Protection Zone north of the railway line also creates a risk that must be carefully managed”.

Here, again the “mixed/positive” score is not proven to be deliverable. Even with extensive storage of increased run-off from the CA1 development, the risk of breach, and/or sewerage/drainage failures, increases the overall flood risk to the existing residential areas. The effect on the Aquifer cannot be determined due to the lack of detail. 15.8 Chapter 6: Spatial Development Strategy (Table 17 pg.48) states “A mixed water scores is applied equally across the options as all 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…An improvement to flooding issues for existing residents is one of the key justifications for the proposed release of this Green Belt land on the west side of the settlement”.

The “mixed” score is not sound as the SFRA has not properly addressed the measures necessary to mitigate the flood risk from the PW1 Capel East development (see section 11).

The SFRA does not conclude that the limited mitigation will eliminate future flood risk or provide evidence of ‘betterment’ to the existing residential areas.

16 : OTHER CONSIDERATIONS

16.1 The character of the parish of Capel, situated in the green belt, would be virtually destroyed by the cumulative effect of these developments, together with quarry extensions, with the removal of more than 1,000 acres of agricultural land. The Capel sites comprise of a total of around 650 acres and each acre of wheat can absorb nearly 600,000 gallons of water per crop (USDA & NIFA²) [² eXtension.org. Supported by USDA United States Department of Agriculture and NIFA National Institute of Food and Agriculture.]. It is estimated that around 60% of annual rainfall could be taken up by the vegetation and crops, when compared with the average annual rainfall of 600mm (MetOffice).

16.2 Poor sales potential: House prices, given the increased flood-related building costs resulting in higher selling prices, may well reduce sales potential. This has already become evident with the current development in Paddock Wood, and also it appears at Marden. Two new houses in Five Oak Green, built with elevated ground floors to accommodate surface water storage underneath, have been on the market for well over a year and despite a significant drop in the price have significantly failed to sell.

The required elevation of FFLs, as in the case of Ellis Close in Five Oak Green village, would add additional height to the houses themselves and added costs to the construction. This would also mean that the houses may be more difficult to sell to families with members who have disabilities and/or young children.

Even more important, with the floods that have occurred in many parts of the country and the publicity they have received, potential customers may well avoid purchasing in low lying areas where such flood risk exists. This could have a devastating effect on sales. It may well be that potential developers may decide that it was not even worth the risk of becoming involved with such a development!

16.3 Setting: The proposed extension of Stonecastle Farm Quarry and additional Quarry at adjoining Moat Farm, within Kent County Councils Minerals and Waste Local Plan 2013-2030, has not been fully considered within the CA1 development plans. Who will want to buy a house looking into a quarry for possibly the next 20-30 years?

Virtually all the residential development at CA1 will be affected by the noise, air and light pollution from the South Eastern Main Line. This would restrict the market’s attraction for the new homes.

Much of the residential development at PW1 will back on the A228, with a vast increase in traffic resulting from the housing increases and quarry trucks.

16.4 Affordable housing: Ground conditions will mean that foundations for buildings will need to be deep and pass through a bed of highly unstable gravel. Foundations for roads etc. will also need to be robust enough to prevent subsidence and Piling may be used but, if deep, will be very expensive. The required extensive installation of SuDS, to mitigate flood risk, would likely wash fines/soil flows under foundations and lead to possible failure. This adds to the costs of strategic storage and other measures; all of the above will make the site expensive to develop.

16.5 The landowners/developers and LPA are blithely promising a high percentage of affordable housing. This is a regular promise made for similar developments which are then almost inevitably ignored. Given the high cost of building at these flood affected sites, it is difficult to see how these targets could be achieved unless such costs are offset by a sizable reduction in the realized values from the development land.

16.6 Site Access: Sites will be difficult and potentially dangerous to access, made even more so by clay based mud deposited on the road by construction traffic leaving the site that by its nature would be difficult to remove, presenting a very real skidding hazard to traffic.

16.7 Much of the area becomes very muddy. Access and site roads would need to be established before work could start. Working conditions would, at best, be very difficult and in the winter the whole site could easily turn into a muddy quagmire that could well lead to work having to be suspended. Trenches dug for foundations would fill up with water even while they were being dug, throughout much of the year.

16.8 Even simple matters such as providing parking for cars and vans would need to be addressed. When the nearby Solar Farm was being built, which needed relatively little site traffic, some areas became simply impossible to walk on due to deep glutinous mud!

16.9 Insurance: For some properties within these developments insurance cover for flooding is likely to be difficult, expensive or even impossible to obtain. No houses built from 2009 onwards can benefit from the Flood Re. Scheme as, if they are in a flood risk area, they are required to have resilience built in to the development. If new developments cause a greater flood risk to older houses these may have insurance problems, obviously.

16.10 Mortgages: There may also be problems obtaining mortgages - we understand that mortgages have been recently been refused on some properties along Maidstone Road in Paddock Wood because of flood risk.

17 : CONCLUSION

17.1 The Capel sites in the Draft Local Plan are neither sound nor deliverable. The policies do not demonstrate that planners have considered the full effects of flood risk, they have not specified adequate flood mitigation measures, and have inadequately assessed the impact of climate change. There is an over-reliance on the Leigh barrier, which provides no benefit to much of the area, and the stated ‘betterment’ is not proven. Therefore, the justification for the removal of Green Belt land is not substantiated at both sites.

17.2 In Paddock Wood (PW1), the exclusion of raised levels in the build design, and the necessary SuDS initiatives, demonstrates that planners have not addressed the flood risk on this floodplain and the effects of any breach of the reservoirs. Development/removal of this part of one of the UK’s largest floodplains is not appropriate.

17.3 In Tudeley (CA1), there is no assessment of the flood risk to existing communities (no SFRA) and the additional costs of railways crossing(s), and necessary extensive flood mitigation, would likely make the development unviable. This, together with the masterplan approach with the landowner, who has no proven development experience, renders the Plan unsound, not sustainable, and an unacceptable risk for the Borough.

17.4 We understand the pressure TWBC is under to deliver its housing targets but it should not be at any cost, especially when it involves so many people/communities and the effects will be irreversible. There are numerous precedents where plans have been rejected for flood risk, e.g. at neighbouring Yalding and the Garden Village in Essex, and TWBC should be adopting a robust defence of the Green Belt and floodplain.

17.5 There is wide condemnation of the 2014 housing needs assessment and the Council should be defending more appropriate (and current) projections. Given we are in an General Election campaign, and with the ongoing Brexit uncertainties, we urge the Council to reconsider and remove these flood affected sites from the plan now before committing to further costs and taxpayers money.

17.6 Existing developments in Paddock Wood have halted due to inadequate sewerage infrastructure and questions were raised in Parliament. After record fines this year, there is no confidence that Southern Water will fulfil the needs of the proposed 4,000 additional houses in Paddock Wood and a possible new sewerage system in Tudeley.

17.7 In this final week of the consultation period we have seen the tragic death of the former High Sheriff of Derbyshire after being caught in floodwater. In Doncaster, 1200 properties were evacuated and 1900 people had to be rescued. This adds to an extensive list of major flood incidents, including the Dam breach and bridge collapse earlier this year, which are now occurring ever more frequently. Planners should take careful regard of these warnings.

17.8 This reports sets out the Capel landscape, flood history, regulatory guidance, external factors, and effects of the proposed developments. The Flood Group have carried out extensive research from the limited information in the DLP and highlight the many dangers, challenges, risks and extraordinary costs any development would have at these inappropriate locations in Capel. These sites Flood and are widely known as flood vulnerable areas on a floodplain.

We submit that Sites PW1 Capel East and CA1 Tudeley must be removed from the Plan – thus preventing the Council from having to re-learn the mistakes of the past………building on/near a floodplain with fatal consequences!

SUBMITTED BY:

Stewart Gledhill, Whetsted
Flood Group Convenor – SaveCapel

ENDORSED BY MEMBERS:

Alan Chilvers, Tudeley
Geoff Croker, Tudeley
Megan Forster, Five Oak Green
Colin Leake, Five Oak Green
Peter Miller, Whetsted
Alaric Smith, Five Oak Green

DLP_7141

Chrissie Wise

I have grown up in and around Capel and the surrounding area. Walking every day in the fields from Paddock Wood to the A228 by pass.

Please add my contact details to your consultation database so that I can be kept informed of all future consultations on planning policy documents. I understand that my comments will be published by the Borough Council, including on its website.

I am writing to object to THE STRATAGY FOR CAPEL PARISH [POLICY STR/CA1] and also the inclusion of land in East Capel in THE STRATEGY FOR PADDOCK WOOD [POLICY STR/PW1]

I understand that we require more houses but feel that Capel is not a viable option. Capel is low and flat with the soil being mostly clay. It is a wet place with many ponds and streams which with the extra housing would be liable to flooding as it is close to the river Medway.

Creating 2800 homes will cause a major impact on Capel and the surrounding area.

Increased traffic, which our roads cannot take as they barely accommodate the traffic we have at present.

Tonbridge station has already been named as the busiest outside of London, keeping up with the increasing numbers of commuters will mean another overhaul of this site, T & MBC will not be receiving council tax from the proposed planning to implement the overhaul of infrastructure required to accommodate the above.

Our hospital and doctors are already overstretched and again I believe T & MBC will be affected more than Tunbridge Wells council.

The planning would destroy green belt land and natural habitats for many creatures/insects. We need to keep as many trees as possible to off set our carbon foot print.

DLP_7205

DHA Planning for Inter-Leisure Ltd

1 Local Plan Representation

1.1 Introduction

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

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

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

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

1.2 The Tunbridge Wells Draft Local Plan

Overview

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

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

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

* Development Strategy and Strategic Policies; and

* Place Shaping Policies for Paddock Wood;

[TWBC: see representation. See also Comment No. DLP_7206 (The Development Strategy].

Place Shaping Policies

1.2.13 The place shaping policies establish the spatial priorities for different areas in the borough, organised according to non-parish and parish areas. For each area, there is an overarching policy that development should adhere to and details are provided for individual allocated sites that will deliver the quantum of development proposed. The site specific allocations provide both strategic and development management guidance.

1.2.14 In respect of Paddock Wood, policy STR/PW1 states that provision will be made for circa 4,000 new homes, considerable employment provision and associated uses. This vision shall be developed using a comprehensive master-planned approach.

1.2.15 The site is broken down into 12 development zones, which each have different constraints and opportunities – as identified in Table 4 of the plan.

1.2.16 The Garden Centre is situated between Zone 3 (AL/PW3) and Zone 5 (AL/PW5) (see figure 1 below). For context, Zone 3 is identified for residential use and flood compensation, with additional scope for a neighbourhood centre, mixed uses and/or a primary school. Zone 5 is identified for economic development.

[TWBC: for Figure 1 see representation].

1.2.17 Our clients land was not put forward for as part of the Call for Sites process, so we can only assume that it has been excluded from the allocation area due to uncertainty regarding its availability for development, rather than its lack of suitability for inclusion in the plan. Indeed, should the site remain excluded, there would be an underutilised parcel of previously developed land adjoined by comprehensive redevelopment. It is our view that the land could be put to better use in meeting identified needs, specifically commercial and/or retail needs to serve a growing population.

1.2.18 Taking the above into account, whilst we do not object to the overall thrust of the place making policies for Paddock Wood, we can now confirm availability of the land and respectfully request that the Council amend the allocation boundary so our clients land is included.

1.2.19 In order to confirm availability, the subsequent sections of this representation provides an overview of the site opportunities and constraints and illustrates how development could be accommodated.

1.3 Site Context

1.3.1 The site is an established and operational retail Garden Centre located on the northern periphery of Paddock Wood (see figure 2).

[TWBC: for Figure 2 see representation attached].

1.3.2 It consists of a mix of hardstanding, permanent buildings, glass houses and temporary structures. It constitutes previously developed land but is situated outside of the Tunbridge Wells ‘limits to built development’ (‘LBD’).

1.3.3 The site falls within the administrative area of TWBC, albeit close to the borough boundary with Maidstone Borough Council, which is demarked by Wagon Lane.

1.3.4 The built up area of Paddock Wood is located approximately 400m to the south of the site, whilst the town centre is situated approximately 1km in the same direction. Immediately north of the site is a commercial plant hire yard, whilst adjacent to the southern boundary is a residential caravan park.

1.3.5 The closest railway station is Paddock Wood (1km) to the south.

1.3.6 Paddock Wood is a sustainable location and offers a good range of services and facilities, including convenience and comparison shopping, job opportunities and public transport links.

Planning History

1.3.7 The site has been subject to a significant degree of planning history. Those considered the most relevant to the suitability of the site for future redevelopment are listed in table 1 below.

Reference

Description

Outcome

75/00306

Use of existing site as a garden/small buildings display centre, extension of centre to provide additional display area and car parking provision

Refused Permission

78/01318

New store office and portaloo, sale of garden buildings and leisure products. Internal and reorganisation of car parking and landscaping

Approved

83/00005

Swimming pool for display purposes

Refused – PP required

84/00480

Use of land as temporary site for camping equipment, portakabin for rent, sales.

Approved (Restricted Seasonal use and personal to Mr G Carmichael)

85/0315

Alterations to front of shop

Approved

86/0236

Continuance of use without complying with condition 2 of TW/84/0480 (use limited to individual person)

Approved

86/0972

Re-site plant house and change of use to coffee shop.

Approved – but restricted to 30 Nov 1991. Conditions to restrict use as ancillary and for in store consumption.

86/01597

Change of use to pet centre

Decision Unavailable online

88/00666

Replacement single storey building for garden centre sales. Additional car parking and open sales area.

Approved (conditional)

89/00942

Temporary stationing of mobile home for office use.

Approved

90/01014

Temporary stationing of mobile home for office use

Refused

91/00158

Extensions to Garden and Leisure Centre and car park

Refused

92/00689

Retrospective - Enclosure of covered patio as extension to coffee shop

Approved

92/00689

Approval of revised landscape proposals; (ii) Retrospective - use of existing polythene tunnels for display of garden furniture; (iii) Approval of revised parking proposals.

Refused

93/00617

Extension to existing garden centre building and retention of conservatory display

Refused

94/00262

Retrospective - change of use from garden centre to display and sale of conservatories, sheds, garages and other small buildings

Refused

(Appeal Allowed)

96/00643

Erection of a horticultural plant shade for plant protection

Approved

96/01739

Retention of six containers in a fenced and landscaped position

Approved

05/01021

Horticultural plant shade for the protection of small and vulnerable plants.

Approved
Extended 2010
10/01185/FUL

16/07659

Operation of hand car wash and siting of wooden storage shed

Approved

Site Opportunities and Constraints

1.3.8 According to the Council’s adopted proposals map, the site is free from any restrictive planning designation. However, it is situated outside of the current limits to built development where policies of countryside restraint apply.

1.3.9 Nevertheless, there are no nearby listed buildings that would impact upon development proposals, the closest being the Grade II listed Beltring House - located circa 450m to the north.

1.3.10 The site is located in Flood zone 3 but with the benefit of flood defences.

1.3.11 Furthermore, the land adjoins areas of land that are allocated for residential and economic development in the TWBC draft Local Plan. Therefore, an opportunity exists to make efficient use of the site in meeting development needs in the forthcoming plan period.

1.4 Illustrative Proposals for Paddock Wood Garden Centre

1.4.1 Policy AL/PW1 of the plan allocates land at Capel and Paddock Wood for the following:

1) The provision of circa 4,000 new homes and a three pitch gypsy traveller site on this land and in Paddock Wood Town Centre;

2) Additional employment provision;

3) New Schools;

4) New Medical Centre;

5) The provision of open space, youth and children’s play and sports facilities as well as recreational facilities semi-natural green space, allotments and publicly accessible open space.

1.4.2 It is the Councils intention to deliver the development through a comprehensive master-planned approach, and the land has been broken down into a number of zones to assist with this process. In this respect, the Garden Centre is located between Zone 3 - which is marked for mostly residential use - and Zone 5, which is identified for economic development.

1.4.3 We have included an illustrative masterplan with this representation (Appendix 1) to show how the site could be developed to provide additional retail provision to support the new housing and employment uses proposed. An extract is provided below for ease of reference.

[TWBC: for Figure 3 see representation].

1.4.4 The proposals highlight the potential to provide additional comparison or convenience retail development (circa 1,895 sqm) by making efficient use of the extensive and underutilised parking areas.

1.4.5 Notwithstanding the proposals for retail led redevelopment, the site could be made available for alternative employment generating uses should there be a greater unmet need.

1.5 Conclusion

1.5.1 This representation has been prepared on behalf of Inter-Leisure Ltd in response to the Tunbridge Wells Borough Council Draft Local Plan Consultation.

1.5.2 Our client controls Paddock Wood Garden Centre, which is a well-established and operational garden centre on the northern periphery of Paddock Wood. The site was not put forward as part of the Call for Sites process, however it is available for redevelopment and represents a logical location to extend the land allocated for the Paddock Wood expansion.

1.5.3 The purpose of this representation has been to provide comment on the Council’s proposed development strategy and specific proposals for allocated sites within the plan.

1.5.4 In this respect, we support the overall principle of the strategy and consider that Paddock Wood represents a sustainable location to deliver housing and other development needs. However, we consider that Paddock Wood Garden Centre should be included within the allocation boundary

1.5.5 To illustrate how additional retail floorspace could be accommodated, we have included an illustrative masterplan, albeit the site could equally be redeveloped for alternative commercial uses and Inter-Leisure Ltd are flexible in this respect.

1.5.6 I trust the contents of this representation are clear and I hope the comments are useful in guiding the forthcoming stage of the plan making process.

DLP_7242

DHA Planning for Barth-Haas UK Ltd

1. Introduction

1.1 Overview

This representation has been prepared on behalf of Barth-Haas UK Ltd (herein referred to as ‘BarthHaas’) in response to the Tunbridge Wells Borough Council (‘TWBC’) Draft Local Plan Consultation, which runs until an extended deadline of 15th November 2019.

Our client controls BarthHaas UK, Hop Pocket Lane, Paddock Wood (herein ‘the Site’). The extent of their ownership is shown by figure 1 below and a site location plan drawn to scale is included as Appendix 1.

[TWBC: for Figure 1, see full representation].

The site was not put forward as part of the Call for Sites process, however it is located within one of seven ‘Key Employment Areas’ in the draft Local Plan. These areas are defined for the provision of employment uses to serve the borough over the plan period and draft policy ED 1 states that proposals for new employment provision through redevelopment and intensification will be accepted as a matter of principle, for a select range of uses.

Our client’s land falls within the ‘Paddock Wood Transfesa Road East and West Area’ (herein the ‘Transfesa Road Area’), which is identified as being suitable for Business, (B1) General Industry (B2) and Storage and Distribution (B8) uses.

We support the redevelopment and intensification of these Key Employment Areas and have no in-principle objection to the site being retained for employment purposes. Moreover, we welcome the flexible and positive wording of policy ED1, which would permit both the expansion and re-development.

However, it is considered that a wider range of uses could be acceptable on our client’s land. For example, the site is less than half a mile north of Paddock Wood Town Centre and an even shorter walking distance to the train station. It is therefore a potentially suitable location for retail provision to meet the needs of a growing population. Further, it could assist with the regeneration and revitalisation of the town centre.

In addition, some of the policies are ambiguously worded and leave much to be desired in terms of the proposed strategy. We therefore ask the Council for clarity in respect of the status of Key Employment Areas in the draft plan and more detail on whom is able to participate in the master-planning process.

1.2 Document Structure

Having regard to the above, this representation comments on the content of the draft plan (Chapter 2), outlines why the site represents a suitable location for alternative uses to those proposed in policy ED 1 (Chapter 3), and suggests potential modifications to the draft plan (Chapter 4).

2. The Tunbridge Wells Draft Local Plan

2.1 Overview

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

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

This representation comments on the following elements of the plan:

  • Development Strategy and Strategic Policies;
  • Place Shaping Policies for Paddock Wood; and
  • Development Management Policies.

2.2 Development Strategy and Strategic Policies

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

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

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

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

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

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

Paddock Wood  Housing Allocations

Retail and Town Centre Uses

Employment

Infrastructure

Capel Land around the settlement of Paddock Wood  4,000

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

To be determined as part of masterplanning.

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

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

Other highways and junction improvements

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

Expansion of secondary school  New primary schools

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

New medical centre

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

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

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

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

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

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

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

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

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

2.3 Place Shaping Policies

The place shaping policies establish the spatial priorities for different areas in the borough, organised according to non-parish and parish areas. For each area, there is an overarching policy that development should adhere to and details are provided for individual allocated sites that will deliver the quantum of development proposed. The site specific allocations provide both strategic and development management guidance.

In respect of Paddock Wood, policies AL/CA 3 and AL/PW 1 confirm the land that will be allocated in the local plan and refers to the draft policies map for details of the proposed allocations. The policies map allocates land for additional employment provision, including expansion of Key Employment Areas. It states that the makeup of the employment provision will be determined by the master planning process, which will look to broaden and significantly increase the employment provision for Paddock Wood and the surrounding area.

[TWBC: for Figure 2 see full representation].

An extract of the draft policies map for Paddock Wood is included above (See Figure 2), showing the location of our client’s site within the Transfesa Road Key Employment Area. To reiterate comments made at paragraph 1.3.13 of this representation, we would ask for greater clarity on whether these existing Key Employment Areas are classed as being ‘allocated’ for the purposes of policies AL/CA 3 and AL/PW 1.

In terms of wider considerations, policy AL/PW 2 allocates Paddock Wood Town Centre and sets criteria for its regeneration. It states that a town centre masterplan will be developed alongside the larger masterplan for Paddock Wood with details of development to revitalise and regenerate the town centre. This includes the provision of approximately 400-700 sqm of comparison retail floorspace; one medium sized food store (convenience retail); and the retention and provision of additional professional services (A2) food and drink (A3), drinking establishments (A4), hot food takeaways (A5), office (B1), appropriate leisure (D2) and suitable sui generis uses.

However, there is a lack of suitable sites within the Town Centre boundary to deliver this new retail provision and the Council have not identified any sites that could be capable of meeting identified needs. Further, according to the Councils Strategic Housing Land Availability Assessment (’SHLAA’) only two sites within the town centre were put forward as part of the Call for Sites process (SHLAA ref. 276 and 272). We do not consider these sites to be suitable for retail provision, owing to their location and a lack of opportunity to accommodate the scale of development needed.

With this in mind, we would encourage the Council to look beyond the defined town centre boundary to accommodate these town centre uses.

In this respect, by virtue of its location, our clients land could be suitable for retail development, which we explain in greater detail within chapter 3 of this representation.

3. Site Context and Opportunities

3.1 Overview

The site comprises the BarthHaas UK headquarters and production facility, which is located east of Hop Pocket Lane in Paddock Wood.

BarthHaas UK forms part of the Barth Haas Group – who are the world’s largest supplier of hop products and services. It operates across all continents and provides support to its customers and partners throughout the production and sale cycle. This includes research and development, breeding /growing and marketing.

Our client is currently considering options to expand their facilities. This is likely to require relocation, with an alternative location in or close to Paddock Wood preferred, which will then free up the site. As the existing premises are dated and no longer suit the needs of modern businesses, it is likely that the site would need to be redeveloped in order to be attractive to future occupiers.

As mentioned previously, we fully support the retention of the site for employment purposes and welcome the positive and flexible wording of policy ED 1, which would allow comprehensive redevelopment. However, by virtue of its proximity to the Town Centre the site would also be suitable for a range of complementary uses – particularly retail. Moreover, we consider there to be a lack of opportunity within the proposed town centre boundary to deliver the quantum of development outlined within policy PW 2.

3.2 Site Location and Accessibility

The site is located to the north of the railway line and within one of the seven Key Employment Area in the draft plan. It is less than 500m from Paddock Wood Town Centre and an even shorter distance from Paddock Wood Railway station.

To illustrate this, we have produced an accessibility plan that shows the site in relation to the proposed town centre boundary, Paddock Wood railway station and a number of bus stops. The plan is included as Appendix 2 and an extract is shown below for ease of reference (see Figure 3). We have also produced a plan showing pedestrian access to the railway station on the northern side of the railway line, which is included as Appendix 3.

[TWBC: for Figure 3 see full representation].

3.3 Opportunities for Town Centre Uses

We acknowledge that it would be sequentially preferable for new retail provision to be delivered within the town centre boundary, however edge of centre sites can also be acceptable and are often required when suitable town centre sites are not available.

Paragraph 87 of the framework explains that when considering edge of centre proposals preference should be given to accessible sites which are well connected to the town centre. Likewise, paragraph 85 states that planning policies should allocate accessible edge of centre sites for town centre uses when suitable and viable town centre sites are not available.

We consider there to be a lack of suitable town centre sites available to deliver the retail development identified and would therefore encourage the Council to permit a wider range of acceptable uses on our clients land.

To illustrate the lack of opportunity within Paddock Wood town centre, we have provided an aerial view of proposed town centre boundary. As one would expect, the area is very built up and the only opportunity to deliver meaningful retail provision at the scale identified would be appear to be through the redevelopment of car parking facilities. This would not be appropriate and we note that draft policy TP 4 seeks to retain public car parks.

The aerial map is included as Appendix 4 and shown below for ease of reference (See Figure 4).

[TWBC: for Figure 4 see full representation].

Taking the above into the account, given the physical constraints within the town centre boundary in combination with the fact that no suitable sites have been identified to deliver the retail needs for Paddock Wood, we would encourage the Council to permit a wider range of uses within our clients land.

Conclusion and Recommendations

4.1 Overview

This representation has been prepared on behalf of Barth Haas UK Ltd, in response to the Tunbridge Wells Borough Council Draft Local Plan Consultation.

Our client controls BarthHaas UK, Hop Pocket Lane, Paddock Wood. It is part of Barth Haas Group – the world’s largest supplier of hop products and services.

The site was not put forward as part of the Call for Sites process, however it is located within one of seven Key Employment Areas in the draft Local Plan. These areas are defined for the provision of employment uses to serve the borough over the plan period.

The purpose of this representation has been to comment on the Council’s proposed development strategy, proposals for allocated sites and relevant development management policies.

In this respect, we support the general thrust of the strategy and agree that Paddock Wood represents a sustainable location to deliver housing and other development needs. Likewise, we do not object to the site being retained for employment purposes and we welcome the positive wording of policy ED1, which encourages the redevelopment and/or intensification of existing sites within Key Employment Areas.

However, some of the policies are ambiguously worded and leave much to be desired in terms of the proposed strategy and delivery of development.

For example, policies AL/CA 3 and AL/PW 1 state that land is allocated for additional employment provision - including expansion of Key Employment Areas . However, it is unclear whether this refers to the expansion of existing Key Employment Areas (listed by policy ED 1) or the newly created development parcels.

In turn, the plan does not provide any clarity on whom will be involved during the mater-planning process. Barth Haas would like to participate, and it seems logical for the Council to support this given that policy ED1 has the same effect as an allocation, in so-far-as it confirms in principle support for redevelopment and intensification. Therefore, this new development should be planned comprehensively alongside the provision of new housing and infrastructure.

Furthermore, redevelopment and intensification within the Transfesa Road Area is currently restricted to redevelopment for B1, B2 and B8 uses, however for reasons set out within this representation we consider that parts of the area would be suitable for other complementary uses - including retail and leisure.

4.2 Recommendations

Having regard to the above, we would ask the Council to permit greater flexibility in the uses that are deemed appropriate within Key Employment Areas, particularly where this could assist with wider plan objectives. This could be achieved by creating smaller sub-parcels where alternative uses might be acceptable by virtue of their relationship with the town centre and public transport hubs. Our clients land would certainly align with this criteria.

Furthermore, the Council should clarity the status of Key Employment Areas within the plan and whom is able to participate in the master-planning process.

4.3 Closing

I trust the content of this representation is clear and I hope the comments are useful in guiding the forthcoming stage of the plan making process.

[TWBC: see full representation. Also Comment Nos. DLP 7242, 7260 (the Development Strategy) and DLP_7261 (Policy ED 1)].

DLP_7259

Mr John Telling

With regard to the proposal for development at Capel (Tudeley and to the west of Paddock Wood); Development would:

1. put enormous pressure on services in Tonbridge;

2. destroy the rural character of this part of the Medway Valley;

3. eat into the Greenbelt, destroying agricultural land and natural habitats;

4. increase flood risk downstream in the Medway Valley;

5. overload the limited road capacity in this area and generate a great increase in vehicle movements.

6. ruin the historic rural setting of Tudeley Church.

DLP_7270

Mrs Katie Lee-Amies

Comments on Section 2 & 3

I object to the proposed Vision and Strategic Objectives, the provisions of STR1 and STR/PW1, AL/PW1, AL/PW2, AL/PW3, AL/PW4, STR/CA1, AL/CA2, AL/CA3,  for the reasons explained above [TWBC: See comments DLP_7265-7267]. To summarise:

  • the evidence base is inadequate and inconsistent,
  • the evidence base does not support a new settlement allocation in Tudeley,
  • the growth option 5 development strategy is not justified,
  • ‘exceptional circumstances’ to release Green Belt are not provided – housing need is not an exceptional circumstance,
  • the strategic site selection process is skewed to favour an area with one landowner,
  • the AONB setting and High Weald National Character Area are given low priority
  • The low priority placed on Green Belt, the HW AONB and its setting and the environment conflicts with the high priority placed on the natural environment in the previous Local Plan, the NPPF, Core Strategy 2010, Public Consultation Boards and by local residents,
  • Grade 2 and grade 3 agricultural land at site CA1 is not acknowledged,
  • A settlement 3-5km from the nearest town and train station creates unsustainable transport patterns, current residents are predominantly car dependent and current road network is at capacity.
  • Tudeley Garden Village will harm the landscape character, and have significant impact on long distance and panoramic views of the locality. Green Belt will be released and the HW AONB and its setting will be considerably harmed,
  • The existing land within site CA1 is undeveloped agricultural land, rich in ecosystems and biodiversity.
  • There are no existing or proposed transport links to support a new settlement at Tudeley,
  • The railway divides the proposed new settlement at Tudeley into two settlements, north and south of the railway,
  • The proposed location for a new secondary school on the Somerhill roundabout is unsustainable. It is too far from any settlement and train station and it will encourage further car-dependency, congestion and air pollution. Children cannot be safeguarded on a school site with a railway line running across it.
  • The expectation that new cycle paths will attract hundreds of new cyclists away from their cars is unrealistic given the local topography and British weather,
  • The Climate Emergency should be driving development away from the countryside and focussing on built-up areas and extending settlements – Objective 8 cannot be met with the current Draft Local Plan,
  • The flood risk will increase in Paddock Wood, East Capel and Tudeley with the loss of hundreds of hectares of woods, trees, hedges and fields,
  • The setting of 71 Listed buildings in Tudeley, including the Grade 1 Listed Tudeley Church visited by thousands each year, will be harmed by the new settlement and associated infrastructure,
  • The TWB is too constrained to accommodate the OAN 2014 housing growth and TWBC should challenge the figures,
  • 6,000+ proposed new homes within 5 miles of each other in Paddock Wood and Tudeley is unreasonable and far exceeds TWBC’s evidenced local need. With additional homes proposed at Mabledon Farm/Bidborough, and the loss of Green Belt to proposed quarry sites and existing Solar Farm in Capel parish, the local area will be swamped, unrecognisable and destroyed. Strategic site allocations are being considered in isolation and their cumulative impact is not being assessed or considered,
  • Increasing the number of homes in a small parish by 500% is unreasonable, unnecessary and unjustified,
  • A new settlement with 2,500-2,800 homes close to the boundary of TMB warrants consultation with Tonbridge residents. Tonbridge will bear the impact of the development and its infrastructure. A new settlement should not follow the same planning procedure as a development of 10-20 homes. Use some common sense.
  • Tudeley Garden Village is a vague outline on a plan in the Reg 18 Draft Local Plan. A schematic or zoning diagram indicating transport links, railway crossings, footpaths and green infrastructure should be included for a large new settlement comprising 63% of TWBC’s new homes. Too much information has been held back for the ‘masterplanning phase’ to enable objective assessment. TWBC are seeking comments on an incomplete Draft.

DLP_7529

Charterhouse Strategic Land Ltd

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

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

Charterhouse supports the strategy for Paddock Wood which is set out in Policy STR/PW1. Further, we support the Council’s comprehensive expansion principle. We are willing to engage constructively and collaboratively, and continue to participate in the Strategic Sites Working Group meetings for the Paddock Wood and are supportive of the masterplanned approach to the strategic allocation.

Item 3 under ‘Masterplanning and Delivery’ as outlined in policy STR/PW1 states that it is highly likely that the delivery of development will require land equalisation agreement. It is not simply a case of being highly likely but rather it is essential given the fragmented ownerships and differing interests within the strategic allocation. Without equalisation between the various parties there is a risk that the allocation and guiding principles will not be achieved and the expansion of Paddock Wood will fail to satisfy the objectives of the plan.

Further, it is clear from the SFRA work undertaken that one of the most significant issues affecting the expansion of Paddock Wood is flooding and flood risk. The SFRA suggests when modelling the impacts of all the development at Paddock Wood that there is a particular sensitivity around how each parcel is brought forward in order to reduce flood risk elsewhere. Accordingly it is fundamental that land equalisation be entered into, to ensure landholdings within the allocation are not prejudiced so that the strategic site is delivered. The scale of expansion being considered means the Council cannot simply sit back and reasonably expect the development industry to bring forward the site. Without the Councils intervention there is a risk that small, but significant land holdings including ours, may otherwise become marginalised by other third parties which could undermine the whole Local Plan.

Regardless as to the end use of our land (be that residential, green infrastructure or flood mitigation), the land is an essential part within the overall context and, on this basis it is imperative that there is equalisation on all land within the strategic allocation.

Charterhouse supports the strategy for Paddock Wood which is set out in Policy STR/PW1. Further, we support the Council’s comprehensive expansion principle. We are willing to engage constructively and collaboratively, and continue to participate in the Strategic Sites Working Group meetings for the Paddock Wood and are supportive of the masterplanned approach to the strategic allocation.

Item 3 under ‘Masterplanning and Delivery’ as outlined in policy STR/PW1 states that it is highly likely that the delivery of development will require land equalisation agreement. It is not simply a case of being highly likely but rather it is essential given the fragmented ownerships and differing interests within the strategic allocation. Without equalisation between the various parties there is a risk that the allocation and guiding principles will not be achieved and the expansion of Paddock Wood will fail to satisfy the objectives of the plan.

Further, it is clear from the SFRA work undertaken that one of the most significant issues affecting the expansion of Paddock Wood is flooding and flood risk. The SFRA suggests when modelling the impacts of all the development at Paddock Wood that there is a particular sensitivity around how each parcel is brought forward in order to reduce flood risk elsewhere. Accordingly it is fundamental that land equalisation be entered into, to ensure landholdings within the allocation are not prejudiced so that the strategic site is delivered. The scale of expansion being considered means the Council cannot simply sit back and reasonably expect the development industry to bring forward the site. Without the Councils intervention there is a risk that small, but significant land holdings including ours, may otherwise become marginalised by other third parties which could undermine the whole Local Plan.

Regardless as to the end use of our land (be that residential, green infrastructure or flood mitigation), the land is an essential part within the overall context and, on this basis it is imperative that there is equalisation on all land within the strategic allocation.

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

[TWBC: see site location plan].

DLP_7593

Mrs Pollyanna Bishop and Mr Pierre

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_7703

Richard Ventin

I wish to register my objection to the so called Local Plan. Given the enormity of the damage this plan will inflict on the Parish of Capel it is difficult to know where to start in condemning it, and how to describe it in a concise way.

These plans are Lazy planning and the position of these new developments is only due as admitted by your Head of Planning at the Capel Village meeting in September as “the Council have only to deal with Two landowners”.

I remain unconvinced that so many houses are required at all, and they are certainly not being built in response to local demand. It is evident that the majority of houses currently being built are 'executive properties' way beyond 'affordable'. Already in this parish TWBC has granted itself planning permission for five 4/5 bedroom houses off Sychem Lane, obviously ignorant of the fact that 2 such houses were built in Five Oak Green two years ago which remain unsold.

The increased traffic these new houses and the several thousands who will presumably live in them will generate. The parish's roads are already at capacity. Further, the construction of roads in or near the AONB will compound the loss of open land and all that implies such as intrusive noise, light pollution and obstruction of wildlife movement.

To inflict the cancer of 'Tudeley New Town' on the green lung which lies between Tonbridge, Pembury, Royal Tunbridge Wells, Southborough and Paddock Wood is a matter for which the landowner and TWBC, members and officers, should be deeply ashamed.

West of Paddock Wood Development.

The land that this development is to be built on is Green Belt Land, having lived in Five Oak Green for the last 35 years and travelled the A228 the number of times that this land has been flooded and water logged in winter has been a numerous yearly occurrence. Although your statement says flood mitigation measure will happen, I trust that the Council has good insurance to cover the damage claims by these new home owners as I’m sure that with climate change flooding will occur at some point in the future should this development go ahead.

The road and infrastructure that this proposed development will require is seen to be totally inadequate, lack any planning and funding proposals apart from a mention the developers will have to contribute to these cost at some point !!!!.

My Overall Comments -

As I have stated above. These plans are Lazy planning and the position of these new developments is only due as admitted by your Head of Planning at the Capel Village meeting in September as “the Council have only to deal with Two landowners”.

Besides the mere problem of 'getting around' I have no confidence that such essentials as doctors, policing, community facilities etc. will be provided at the same time as houses are built. My impression from the waffling answers of TWBC planners is that they might come later, i.e. once money has been allocated from the selling of the houses, or not at all. There are no guarantees, and the consequences of building houses without provision for health care etc. need not be explained. In the meantime it will be the nearby town of Tonbridge which has to absorb the pressures of the increased population on its doorstep, and without receiving a penny to fund its services. And what of the other essential services? For example, how is the sewage to be disposed of? Building at Paddock Wood has had to be halted because Southern Water cannot provide the necessary sewerage infrastructure

So far I have not drawn attention to the map which shows Tudeley New Town, and the proposed school site contiguous with the Tonbridge boundary, straddling the railway line. How anyone, least of all a planner claiming competence, can imagine this is practical, desirable – or even safe – is beyond me.

I urge the Council to think again, withdraw this threat to our precious environment, and tell Her Majesty's Government that the Green Belt in general and the Parish of Capel in particular is not to be sacrificed to provide houses for wealthy commuters

DLP_7752

Nathan Marshall

Re: Policy STR/CA1 and STR PW1

I write to object to “The Strategy for Capel Parish” (Policy STR/CA1) and “The Strategy for Paddock Wood” (Policy STR/PW1).

My family and I reside in Tonbridge and we have serious concerns regarding the scale of the proposed development on green belt land. While we have only lived here for around six years, we have already seen a significant increase in residential development and associated traffic and rail use in this area. It is submitted that the proposed development will have a serious detrimental effect which will be felt throughout the Tunbridge Wells, Tonbridge and Malling, and Maidstone areas. This will irreparably change the character of this region and negatively impact on the lives of many people.

Traffic

The proposed development will clearly cause a significant increase in road traffic with which, it is submitted, the current infrastructure will be unable to cope. Indeed, the roads into Tonbridge are already severely congested during the morning and evening rush-hours and it is hard to see how the public transport system could improve upon the situation. In particular, Vale Road and the Pembury Road are frequently at a standstill at these times despite local schools encouraging the use of buses for school children.

It is submitted that the ensuing increase in pollution from slow moving vehicles, coupled with the increased congestion and noise pollution, will have a severely detrimental effect on the town of Tonbridge.

It is further submitted that the same can be said for Tunbridge Wells and Paddock Wood, which are the alternative directions in which commuters may drive to get to their places of work or education.

Rail

It is to be expected that a large percentage of the proposed new housing units will be occupied by commuters, who will expect to use local rail links, primarily into London. There is already pressure on the car parking available in Tonbridge and, it is suggested, that further demand will push up the cost of parking significantly.

The commuter trains are already crowded at peak times, with standing room only by Sevenoaks and beyond and, it seems with increasing frequency, sometimes impossible to board due to overcrowding. It is unlikely that Southeastern Rail has the ability to add the required capacity to cope with the expected additional demand for the trains.

I believe that there has been a suggestion that a new station could be built at Tudeley, which would absorb this extra demand. I do not, however, believe that this is viable. In particular, I do not see how the rail lines could cope with additional trains since their timetable is already full at peak times.

Flooding

The proposed development appears to be placed on the floodplain of the River Medway, a river which is known periodically to burst its banks and cause serious flooding. While work has been done to attempt to ‘tame’ the river in the Tonbridge area, I suggest that much of the positive impact of this work will be reversed by paving over the important soak-away areas that this development will cover. Notwithstanding the disruption and distress that will be caused to residents of the proposed development, should there be a major flood, the removal of such a large area of natural soak-away is bound to have a detrimental effect on those in flooding areas for miles downstream as they will be faced with an increased volume of water being quickly discharged into the river. Further, it is unclear the extent to which current predictive models of flooding account for the uncertainties of climate change.

Woodland and environment

While there is, of course, pressure on local authorities to increase the housing stock in their areas, it is important to recognise that this proposed development entails the wholesale destruction of a vast area of green belt land. This land includes fields, meadows, hedgerows

farmland and woodlands. The impact on the local environment will be catastrophic. Not only will there be a loss of natural environment which is home to English wildlife, but the proposed development will lead to massive air, light and sound pollution that is associated with residential areas.

The National Planning Policy Framework (“NPPF”) states clearly, at paragraph 133:

“The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts is their openness and permanence.”

It is submitted that the proposed development clearly violates this “fundamental aim” in that it is removing the “openness” of the countryside which separates the larger centres of population in this area, and in doing so it not only demonstrates that the Local Authority does not respect the requirement of “permanence” but is willing to go further and promote damage which is irreversible.

Requirement of “very special circumstances” for building on Green Belt

Paragraph 143 of the NPPF states:

“Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.” (My emphasis.)

And, paragraph 145 states:

“A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt.”

The paragraph does go on to state a number of exceptions listed (a) to (g), and the subsequent paragraph also contains some exceptions focusing on other forms of development. It is submitted that the proposed development does not fall within any of these exceptions and, therefore, should automatically be considered “inappropriate”. In particular, it is clear from paragraph 145 that the exceptions all relate to small scale developments of a single building or, at most, a handful of buildings. Further, a review of the planning applications covering this area demonstrates a large number of planning refusals for single buildings and/or extensions to existing buildings, where very special circumstances were not found.

Requirement of “exceptional circumstances” for moving Green Belt boundaries

It is noted that the Local Authority anticipates that, instead of this being viewed as a development on the Green Belt, it will first move the boundary of the Green Belt to remove this area from it. It is submitted that this approach is acting in bad faith merely in order to get around the issues highlighted in my paragraph above. In any event, the NPPF requires that this can only be done in “exceptional circumstances” (at paragraph 136), and that these must be “fully evidenced and justified”. The reference to “exceptional circumstances” clearly sets a higher requirement than the “very special circumstances” referred to above. This in itself points to the inability to get around the prohibition on development on Green Belt areas by merely declassifying the area.

While the Plan states that a great deal of evidence has been produced, it is submitted that volume of evidence does not equate to quality. In particular, it is submitted that taken as a whole, the evidence does not disclose the required “exceptional circumstances”. To find otherwise, it is suggested, is not something that any reasonable authority would do.

In conclusion, I remind the Local Authority of the five purposes of Green Belt (paragraph 134 of the NPPF):

a) To check the unrestricted sprawl of large built-up areas;

b) To prevent neighbouring towns merging into one another;

c) To assist in safeguarding the countryside from encroachment;

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

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

The aggregate purpose of the existence of the concept of Green Belt land is to prevent the very thing that this proposed development is attempting, and it is for this reason, coupled with those highlighted above, that I wish to object to the proposals put forward.

I trust that you will give my comments due consideration and I look forward to hearing the outcome of your deliberations on this matter.

DLP_7786

Dean Parsons

I have lived in & around Five Oak Green all my life. I am now 55 years old.

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

​This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel.

I would like to know how it is acceptable for TWBC to think they can try & build 4000+ houses on Green Belt land & AONB when there are countless brownfield sites that have been turned down for planning permission. Is it the ease of dealing with one landowner?

Why was it that I was only informed of this plan by word of mouth in my local village? Trying to slip this application through the back door is not the way to get local people on board.

We are being told there are less people coming to Britain so why do we need to keep building houses when we have houses that are not selling?

DLP_7833

Debbie Parsons

I have lived in the Capel area since 1977. I was raised in Five Oak Green, married in All Saints Church in Tudeley in 1988 & lived on Postern Lane in Tudeley. I now live in Golden Green with my family.

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

​This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel.

I hope you listen to the comments of all your residents & reconsider this plan. There has not been enough community engagement or involvement, in fact, we would not have known about this plan for Tudeley Village had we not been told by friends in Five Oak Green. We had to run our own surgeries in Golden Green to inform residents about the plan. We have not had enough time to consider all the implications & it appears that TWBC have not considered all options available. To deal with one landowner is extremely lazy by TWBC.

DLP_7885

M Sheppard

I have lived in Five Oak Green for over 20 years, returning to the village where my parents lived.

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

​This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel.

I hope you listen to the comments of your residents & reconsider this plan. We have not had enough time to consider all the implications of this plan & did not know anything about it until family informed us.

DLP_7887

Mrs M Sheppard

I have lived in Five Oak Green for over 40 years. I moved to Five Oak Green to enjoy a quiet village life and raise my family in the countryside.

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

​This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel.

I hope you listen to the comments of your residents & reconsider this plan. We have not had enough time to consider all the implications of this plan & did not know anything about it until family informed us.

DLP_8007

Mrs Michelle Perry

I am the owner of Badsell Manor wrongly described as Badsell Manor Farm in the Draft Area Plan of East Capel. I have lived here for some 24 years. The Manor dates back to the 13th century, is a Grade 2 Listed property and is surrounded by a Moat currently fed from the running water of Tudeley Brook. It is adjacent to the proposed Agricultural land earmarked for development of approximately 1,600 houses in East Capel. It is in a Greenbelt Area and as such, I feel very strongly that its surroundings, should be protected and preserved.

I am writing to voice my objections to the proposed strategy for the development of East Capel  Tudeley and Paddock Wood.

The land at East Capel is agricultural and woodland and is in a Greenbelt Area. Green and Open Spaces are important and should therefore be safeguarded for future generations from Development. It is also in a high risk flood area of 3.3% as stated in the flood -warning-information service.gov.uk website. As we have seen with climate change, this area could be under water in the future if conditions persist. Even with flood mitigation and “betterment”, I feel that this might  be disastrous as we have seen what has happened in parts of the UK recently. On a more personal note, I have actually seen Tudeley Brook burst its banks and flooded my neighbour. Moreover, this proposed development would have catastrophic impact on the rural landscape, environment and wildlife in the area,  which we all enjoy at the moment.

The economic development of the local area of East Capel, Tudeley and Paddock Wood, does not necessarily rest on building more houses and overpopulating these areas. Infrastructure to ensure that  the local residents and visitors can access services , trains, shops, work, recreation fairly easily. There does not seem to be much thought to put in infrastructure until after the development is complete. Planning Officers dictate that people will walk and cycle to their places of work etc and there will be more bus services to connect to these new developments. It is very naïve in my opinion to think that people, would not own cars, or if they did, leave them at home. The residents of Badsell Road have been asking for many years for a footpath from the A228 roundabout towards Paddock Wood, but to no avail. Yet we are told that the new developments will have foot and cycle paths This road has a SPEED LIMIT OF 50MPH. There has been numerous accidents over the years outside our properties, even as recent as earlier this year(2019) when a car demolished 2 neighbours walls and parts of their homes. The proposed development in East Capel  and Paddock Wood will increase traffic significantly  (as will the present Mascalls Farm Development) on the Badsell Road, with traffic coming in and out of Paddock Wood.

We all accept that there is a problem with the lack of housing. However, the proposed developments of East Capel, Paddock Wood and Tudeley  with about 9,000 houses, seems to be too intense for this one area in the Borough of Tunbridge Wells. Of all the homes needed in the Borough, some 13,560 calculated by the Government it is proposed that ¾ of these, approximately 9,000 are earmarked  for these areas over the next 15/20 years. In the Borough of Tunbridge Wells, with 20 wards, it seems that the Borough Council has adopted the easiest strategy, by taking advantage of a relaxing of the rules by the Government, of building on Greenbelt land with this proposed intense development, rather than adopting a more environmental strategy of using Brownfield sites with smaller developments.

Designated Greenbelt sites are fundamentally aimed at preventing  Urban Sprawl and preserving open spaces, which is exactly the opposite of what will happen, with an Urban Sprawl from Paddock Wood to Tonbridge. If these proposed developments go ahead, we will lose a lot of our Greenbelt areas. This cannot be the right thing to do for local inhabitants as a whole. Destroying large areas of Greenbelt (fields and woodlands) to build houses, will only be detrimental to the biodiversity of the area, increase carbon emissions with increased traffic, cause more flooding and bring  untold misery to local people.

DLP_8117

Ashley Saunders

The expansion of Paddock Wood can be achieved without using land at East Capel for housing. Flood storage attenuation/mitigation measures may be useful there, but no housing is required. In fact, providing housing will contravene the NPPF as East Capel is Green Belt and the removal of East Capel from the Green Belt will cause convergence with Five Oak Green, as our comments on the SA suggest. This does not amount to “exceptional circumstances”. This is further described in comments on the Sustainability Appraisal.

DLP_8179

Highways England

Location:

No/Type:

Distance to SRN:

Impact:

Current traffic flows:

Recommendations

Five Oak Green

The provision of either one 3 FE or two 2 FE primary schools within Tudeley Village and/or 1 FE expansion of the existing Capel primary school at Five Oak Green;

No specific housing allocation but may be impacted by either Paddock Wood or Tudeley Development

6km

A21/ B2017/A228/ Pembury Bypass B2017

Bypass link for the A228 should help to alleviate traffic along the B2017.

Main aim is to minimise impact upon Five Oak Green.

Slightly higher than normal traffic flows during the AM/PM peak that may be exacerbated by any further development at Paddock Wood or Tudeley;

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.

The exact location of such a link has not been determined;

Paddock Wood

Employment site and

approximately 4,000 new

homes on land at Capel and Paddock Wood, including a rejuvenated Paddock Wood town centre.

Four new primary schools and expansion of Mascalls secondary school

A new swimming pool, outdoor sports hub and a new community hall

A new doctors surgery (either here or in Tudeley village)

Addition waste water treatment, and strategic sewerage provision

6km

A21/B2160 (Kippings Cross), A228 (Tonbridge Rd Rdbt)

~15km

M20 – J4/J5

Significant/ any movement along this route will need mitigation as traffic is already operation at higher levels during peak hour. Opportunity for railway station enhancement as on direct line to Tonbridge.

Majority of movement would be either direct towards A21; which indicates heavier traffic flows in the AM/PM peak at the A21/A228/B2160 junctions

Movements northwards are likely to impact on M20 – J4 – which demonstrates a higher level of traffic in the PM period.  J5 currently has a mitigation scheme in place and undergoing works.

Transport infrastructure to include the A228 Colts Hill bypass, a distributor road in the eastern part

of Paddock Wood, and bus and cycle links from Paddock Wood to Tonbridge via Tudeley.

Mitigations measures required for Kippings Cross/ Tonbridge Rod Roundabout; full modelling assessment.

Trip distribution assessment onto M20.

Tudeley

Residential garden village at Tudeley of up to 2,800 homes, to include employment and other facilities, including retail, community facilities etc

It is anticipated that 1,900 of these homes will be built before 2036

Two new secondary schools (between Tonbridge and Tudeley, and at Spratsbrook,

south of Royal Tunbridge Wells)

2.5km (West)

A21/B2017/A26 (Pembury Rd Rdb)

>15km

M20 – J4, M26 – J2a or M20 – J4

Significant; given proximity to A21, this is the major route choice to onwards western destinations and any development along this route will need mitigation as traffic.

Potential to provide railway station as on direct line to Tonbridge.

Current traffic flows for AM/PM peak hours are currently acceptable at the A21/A26 Pembury Road roundabout.

Local road network improvements for A228 (Colts Hill bypass).

Eastern link from Tudeley Village to be considered.

TA required with junction modelling and trip distribution for A21/A26 Pembury Rd Roundabout and further distribution onto M20 and M26.

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

DLP_8234

Maidstone Borough Council

Policy STR/PW 1 – The strategy for Paddock Wood

This policy details the strategy for Paddock Wood – comprehensive masterplanning for a proportion of approximately 4,000 new dwellings, considerable employment and associated education, leisure and health facilities.

Given the location of Paddock Wood and the proposed allocations abutting Maidstone’s administrative boundary, it is essential that MBC is involved in the comprehensive masterplanning of the area, including for the provision of strategic, cross-boundary infrastructure and the phasing of development associated with the timely delivery of infrastructure.

Importantly for MBC, we would wish to fully understand the impact of these allocations on the road network north of Paddock Wood, into Maidstone borough – primarily along the A228. The supporting Sweco transport evidence includes a modelled junction upgrade to provide additional capacity at the A228 Whetsted Road/B2160 Maidstone Road. However, it is not immediately apparent how far beyond the TW borough boundary the modelling has been taken and therefore what impact any additional trip generation may have further north along the A228, into Maidstone borough. It is crucial for MBC to understand the impact of increased vehicular movements in both directions associated with an additional 4,000 new homes and a regenerated town centre at Paddock Wood. If there are likely to be impacts on the highways network further into Maidstone as a direct result of the development proposed in/around Paddock Wood, MBC would expect to see the planned provision of appropriate mitigation measures. Any impacts will also require factoring into transport modelling for MBC’s potential growth options as the LPR progresses.

The final conclusions from the Sweco transport assessment state that “the traffic modelling… has shown that the measures proposed will mitigate the impacts of the Local Plan housing and employment allocations.” MBC wishes to clarify this sentence insofar as asking whether or not this mitigation extends beyond TWBC administrative boundaries, where traffic from the housing and employment allocations may impact upon highways infrastructure in Maidstone borough and further mitigation may be required as a result?

Also key is the strategic cross-boundary issue of flood risk from all sources and any proposed mitigation measures. MBC requests confirmation as to whether any additional land within Maidstone borough is likely to be sought for flood storage, attenuation or mitigation purposes as a result of the proposed levels of development across the boundary in TWBC? From the supporting SFRA Level 2 parcel information it is our understanding that the residential development proposed at Paddock Wood north west parcel 3 would result in a reduction in flood risk on land to the north of the allocation (i.e. into Maidstone borough) when mitigation measures are factored in. However, this is all subject to further, more detailed modelling on a parcel specific basis. Could TWBC please confirm this to be the case?

MBC seeks assurance that any proposed development adjacent to our administrative boundary would not result in increased flood risk from any sources on land in Maidstone borough.

DLP_8291

NHS West Clinical Commissioning Group

General Observation

The CCG notes the policy details that together with land outside Paddock Wood parish (in Capel parish, immediately to the west of Paddock Wood the settlement), provision will be made for a proportion of approximately 4,000 new dwellings and that health facilities have been referred to within this to be delivered on land referred to as land at Capel and Paddock Wood (Policy AL/PW 1), and in Paddock Wood Town Centre (AL/PW 2).

The proposed development will require capacity c 10,000 new patient registrations in general practice (c12000 when including existing permissions). Given the scale of development there will be a requirement for a new general practice premises to ensure the growth can be accommodated.

There is currently one practice located in Paddock Wood and a small number of other practice boundaries also provide currently coverage to all/part of the area. Capacity does not exist to accommodate the proposed growth and whilst the information has been shared with general practices a detailed strategic assessment has not been undertaken at this stage. The CCG has been included in early discussions regarding the comprehensive approach to master planning and expects to be fully involved as this develops in order to strategically assess and identify the requirements for general practice capacity. Critical to this will be the phasing of development, availability of contributions and the timing of the delivery of required infrastructure.

Planning for growth in general practice is complex; physical infrastructure is one element but alongside this workforce is a critical consideration both in terms of new workforce requirements and retirements. Any plans developed need to support delivery of sustainable services for the future.

It is noted that :

  • Policy STR/PW 1 details that in order to mitigate the impact on infrastructure contributions or on/off site provision must be provided to mitigate that impact on health/medical facilities.
  • Policy AL/PW 1 details that the site includes allocation for a new medical centre.

The need will be defined as part of the master planning approach.

DLP_8379

Mr Raymond Moon

Policy STR/PW 1 OBJECT. 

The Strategy for Paddock Wood

  1. The number of 4,000 houses allocated for PW is not represented in the individual sites so how was this number derived at in the Draft Plan? More detail should be provided in the Draft Plan. Also the allocation is predominately in high risk flooding areas and with mitigation against flooding the cost of the houses build will be high and potentially reduce the amount of 106 monies available for infrastructure improvements.

    Masterplanning & Delivery & Flooding.

    A major concern of PW residents is the threat of increased surface water flooding and foul water flooding in PW. The Masterplan must deliver the required infrastructure to cope with the new houses with real proposals and TWBC commitment to ensure that happens. This issue should be mentioned in stronger terms in the Draft Plan. All of the proposed houses will have their own impact on the infrastructure and on the other houses proposed in the Draft Plan. The Masterplan must have a joined up strategy to deliver these houses without failures within the proposed infrastructure.

    Transport.

    It is essential that the new ring/access roads required are built from the East of PW to the North and to the West via Eastlands. More detail must be included in this section of the draft plan.

    Infrastructure.

    Many infrastructure areas are mentioned but again there is lack of detail in the Draft Plan. Who’s is going to provide these improvements and where is the Capital Expenditure coming from?

DLP_8384

Paddock Wood Labour Party

Masterplanning & Delivery & Flooding.

A major concern of PW residents is the threat of increased surface water flooding and foul water flooding in PW. The Masterplan must deliver the required infrastructure to cope with the new houses with real proposals and TWBC commitment to ensure that happens. This issue should be mentioned in stronger terms in the Draft Plan. All of the proposed houses will have their own impact on the infrastructure and on the other houses proposed in the Draft Plan. The Masterplan must have a joined up strategy to deliver these houses without failures within the proposed infrastructure.

Transport.

It is essential that the new ring/access roads required are built from the East of PW to the North and to the West via Eastlands. More detail must be included in this section of the draft plan.

Infrastructure.

Many infrastructure areas are mentioned but again there is lack of detail in the Draft Plan. Who’s is going to provide these improvements and where is the Capital Expenditure coming from?

Policy AL/PW 1: Land at Capel and Paddock Wood

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_61
DLP_1625
DLP_868

Thomas Weinberg
Maggie Fenton
Ian Pattenden

 

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

Comments on Policy AL/PW 1 (Land at Capel and Paddock Wood) p.170


The expansion of Paddock Wood can be achieved without using Green Belt land at East Capel for housing. Only 3,000 new dwellings are required, not 4,000 (based on 2016 ONS statistics). If TWBC is not willing to argue that the housing need given to them by government is too high, they can use the NPPF’s protection of Green Belt to adjust their explansion plans.

DLP_143

Gregg Newman

 

Comments on Policy AL/PW 1 (Land at Capel and Paddock Wood) p.170

Again, the following are quotes which are totally supported:

QUOTE

The expansion of Paddock Wood can be achieved without using Green Belt land at East Capel for housing. Only 3,000 new dwellings are required, not 4,000 (based on 2016 ONS statistics). If TWBC is not willing to argue that the housing need given to them by government is too high, they can use the NPPF’s protection of Green Belt to adjust their expansion plans.

UNQUOTE

DLP_254

Chris Sutton

Object

Proposed allocation of 126 hectares of greenfield agricultural land at Paddock Wood for development (area north of railway, west of Maidstone road) – PW1.1, 1.2,1.3, 1,4

I am surprised that there is no mention of the impact of the proposals on 1 and 2 Eastlands Cottages in the Local Plan, despite the fact that the map shows that they are squeezed into a tiny plot of land between PW1.3 and PW1.4. These two family homes are local heritage assets converted from a single large oast house in the 1950s, and their oast roofs are a distinctive feature of the local landscape. They sit 100m from Eastlands Farm (also known as 3 Eastlands Cottages) which sits on the other side of Tudeley Brook. Presumably these are among the properties mentioned in SHELAA for AL/PW1 where it states that “the negative heritage score reflects the land take required and thus negative impacts that would occur largely upon the setting of heritage assets.”

However, the more detailed SHELAA reports for sites 315 and 316 (the land immediately to the south and north of 1 and 2 Eastlands Cottages) states there are no buildings on the site. This is strictly true, but gives a very misleading impression as the Local Plan proposal is to develop both sites with Eastlands Cottages squeezed in between. Given the emphasis in the Local Plan that piecemeal development around Paddock Wood is unacceptable, and policies STR7 around avoiding overbearing development around existing residences and 6.452 on Heritage Assets, it is unacceptable that there is no mention of any proposal of how Eastlands Cottages would be sensitively incorporated into the proposed development that would appear to completely surround it. Given this absence, I object to the development of PW1.1 to PW1.4 as stated in the Local Plan.

The SHELAA report also has overlap between sites 315 and site 51. Why does this overlap exist? Is it in case the overall development of PW1.1 to 1.4 does not take place, and TWBC is trying to reserve the ability to develop site 51 in isolation? If so, this must be made very clear. Planning officers at TWBC will be very aware that previous versions of the Local Plan have proposed the area of site 51 for development, only to be overruled by the independent Planning Inspector who decided that the site was unsuitable for development due to flooding and other risks. The Local Plan should acknowledge this, and not only be specific on the grounds of how it will seek to develop land that the Planning Inspector rejected for development, but also acknowledge that the Local Plan causes stress for local residents who relied on the judgement of the Planning Inspector in terms of continuing to invest in their properties believing that current values, influenced by the rural setting, would be maintained. TWBC planning officers will recall the “Fight the Blight” campaign by residents of Paddock Wood living north of the railway line to protect 51 from development in the late 1990s, on the basis that this would cut off residents of Maidstone Road, Lucknow Road and Nursery Road from access to green open spaces and can be assured that this campaign would resume if the Local Plan continues to include this site for development in the next version of the Local Plan.

The descriptions of the two overlapping sites are inconsistent. Site 315 talks of existing buildings (plural – there is only one) to the north, site 51 talks of sporadic buildings to the north. The word sporadic suggests multiple buildings, again wrong. Site 51 correctly mentions public footpath WT176 on the western edge of the site, Site 315 ignores it. Site 51 has the two word sentence “Appears Lacking” in the Site Description. What is the significance of this statement (other than perhaps to suggest that the assessment was not properly quality reviewed?). The SHELAA report for adjacent site 313 states “The site is a managed arable greenfield which appears to be in agricultural use.” What is the significance of the word “appears” here?  The reality is that all of PW1.1 to PW 1.4 (except for a very tiny area at the south of site 51) has been in continual agricultural use since before the existence of Paddock Wood, first as hop fields, then as orchards, and now for more than thirty years for growing crops.

The Local Plan for Pw1.1 to 1.4 also fails to mention that this land is a very popular area for walkers, or how residents of Maidstone Road (north of the railway line) will be able to walk to other green areas. Eastlands Lane is a bridleway which leads from the north of Paddock Wood to Whetstead, and WT176 follows the west bank of Tudeley Brook from the railway level crossing up to the A228 where it continues into Hop Farm land on the other side of the A228. The northern edge of the field marked as 316 is also popular with walkers, enabling a circuit route around 316 which is an important open space for residents of Paddock Wood who live north of the railway line, given that the Transfesa estate provides no green walking opportunities to the eastern side of Maidstone Road. The circuit route described is accessed either from Maidstone Road or Nursery Road. The July 2018 Landscape Sensitivity Assessment for Paddock Wood, commissioned by TWBC suggests that arable agricultural land is not a distinctive feature of the Low Weald, and therefore is relatively attractive for development. Local residents beg to differ. TWBC officers might wish to consider that comments in the Local Plan which state how the Common is integral to the character of Royal Tunbridge Wells (for example on page 22) cause offense to residents of Paddock Wood when there is no acknowledgement that the greenfield land surrounding Paddock Wood is integral to Paddock Wood’s character. TWBC thereby creates an impression that the preservation of the environment of Royal Tunbridge Wells is more important than the preservation of the environment of Paddock Wood.

DLP_362

David Marriott

Object

These allocations and virtually all in flood zone 3 and should not be developed. All of these sites have flooded on a regular basis over many years. We live right next door to these sites and worry about the Archimedes effect of displacing flood water into hour house. Having such devices as voids under buildings and storage tanks under parking areas are just that, devices. Devices go wrong. With the passage of time openings to allow flood water to flow get blocked up by owners who don’t want flood water under their homes or they just get full of weeds, silt or rubble.

On the EA flood maps part of the flood zone 3 land is shown defended. What happens when UMIDB gets disbanded or there are Council / Government cutbacks? I hardly classify keeping drainage ditches cleared of weeds once a year as defended. Paddock Wood is largely flat and the ground mostly clay so the heavy rains neither soak away nor flow away quickly and hence we have floods. Building in these areas will only exacerbate the problem.

The proposed quantum of 4,000 houses for the town even on the remaining proposed allocations that are outside of flood zone 3 is far too much for the town to bear. The current town centre is not big enough to support the additional housing. Even with the small plot of land owned by Tesco being able to provide additional retail space, what happens if Churchill win their planning appeal?

Foul drainage and surface water drainage.

It is well known that PW have capacity problems for both foul and surface water drainage. When there is a flood, those houses that are not flooded are still affected as foul water will not flush away as the drains below ground are flooded.

Health matters

We already have to wait 2 weeks for an appointment to see a doctor because of the shortage of doctors. Leaving the EU will only make the situation worse. Where will the doctors come from to service existing residents let alone new residents to the area. Saying that it is another Government’s department problem is NOT an answer.

Any development needs to have adequate health centre facilities AND be staffed in advance of housing being occupied. Who pays for this, presumably the developers under s106 agreements?

DLP_1540

Tonbridge & Malling Borough Council

Object

Although Paddock Wood is further from the borough boundary than the sites at Tudeley and Capel, the size of the allocation here means that the same comments made above are also applicable, particularly for communities in East Peckham.

The aspiration to improve the A228 at Colts Hill is a long held West Kent priority and is supported by TMBC. However, TMBC has significant concerns about the impact of works on the A228 and the potential wider implications need to be thoroughly considered in a holistic fashion, working with KCC Highways, TMBC and Maidstone Borough Council. Following officer discussions, TMBC are requesting that this approach to the A228 corridor is enshrined in the relevant policies.

The implications of this allocation (and the new settlement at Tudeley, which is unlikely to justify the introduction of an additional railway station between Tonbridge and Paddock Wood) on future rail capacity to London will need to be the subject of on-going discussions with Network Rail and the rail service providers and be included in the Infrastructure Delivery Plan. This extends not only to train services but to commuter parking and likely travel habits. The frequency of services at Tonbridge station make this the more likely destination for commuters when compared to Paddock Wood. There is also the need to consider planned development at Marden, Staplehurst and Headcorn that will put additional pressure on the line.

DLP_1647

Tom Tugendhat MP

 

STR/PW 1 and AL/PW 1 - The Strategy for Paddock Wood

The Draft Local Plan proposes approximately 4,000 additional homes on land at Capel and Paddock Wood. This gives me huge concerns, specifically for the impact on those neighbouring communities.

Over the past few years I, along with East Peckham Parish Council and many patients and local residents, fought hard to save the East Peckham Doctors Surgery. We managed to in the short term, before it shut last year and residents were forced to travel to Paddock Wood to access Woodlands Health Centre as their local GP instead. This was a shame but it was felt that £250,000 was needed to bring the existing surgery up to scratch, a figure which Woodlands did not dispute when I quoted this to them in a letter dated 31 January 2018 about the closure.

On Page 170 of the Draft Local Plan, I note that it is referenced that Paddock Wood has its own doctors surgery. This is seen as one of the justifications for such large scale development here. However, in order for the existing surgery to cope with the demand from 4,000 additional homes in the town alone it will need to expand, and repurchasing a branch in East Peckham would be the best way to achieve this. It would enable the village to keep its facilities for the local population and ensure that Woodlands Health Centre can adequately deal with the greater number of patients visiting it from Paddock Wood. Meanwhile, East Peckham gets its branch surgery back and reduces the need to travel into Paddock Wood. I hope this is an issue which TWBC will pursue alongside West Kent Clinical Commissioning Group (WKCCG) to ensure that a significant increase in the population of Paddock Wood will not impact on the ability of East Peckham residents to see a doctor.

Furthermore, an additional impact of the Paddock Wood development which gives me great concern is capacity on the Southeastern mainline. We are already seeing significant development in the adopted Maidstone Borough Council (MBC) Local Plan in Marden, Staplehurst and Headcorn, the next stations down the line. The justification used by MBC to designate each of these areas as Rural Service Centres was that they had a railway station. Indeed, as some of these developments have been brought forward and built out they have already gone above the indicative figures in the MBC Local Plan. For example at Marden, Land South of The Parsonage on Goudhurst Road has an allocation for 50 dwellings, yet planning permission was granted for 65 dwellings in 2017. This represents an uplift of almost an additional third of the site allocation.

Consequently, we must accept that there will be significant additional demand on the rail network from Maidstone borough, and I am hugely concerned that, coupled with the volume of development proposed at Paddock Wood, it will result in overcrowding from these stations on the Southeastern mainline. At present, Tonbridge is the last realistic stop where passengers heading to London can expect a seat, and on the way back commuters are almost always standing from London Bridge. With further stops at Orpington and Chelsfield planned by the Department for Transport in the Invitation to Tender for a future Southeastern franchise, this line will only get busier.

I am hugely concerned that the only perceived impact on the rail network identified in the Draft Local Plan is the need for improved vehicle and cycle parking at Paddock Wood station. While this may be needed, it will do absolutely nothing to mitigate the impact of the development on commuters from Tonbridge and only seek to encourage more people to use the Southeastern mainline. I am extremely disappointed that there is no assessment of this and would urge TWBC to include this as part of their Regulation 19 consultation.

[see also full response - Comment Number DLP_1577 in general comments on whole Plan section].

DLP_1788

CPRE Kent

Object

It is noted that this development, together with the proposed secondary school and proposed new village at Tudeley will result in development stretching from Tonbridge in the west right through to the east of Paddock Wood – approximately some seven miles long.

CPRE recognise that, even if the OAN is not met in full because of NPPF paragraph 11(b), given the housing figures that the borough is likely to have to accommodate, in addition to building more densely in the towns there will need to be some major green field development.  We agree with the Council that major development should not take place within the AONB – and object to all proposed major developments in the AONB which are identified in this draft local plan (see also the comments of CPRE Tunbridge Wells district committee on Cranbrook and Sissinghurst, and Hawkhurst).  Because of the presence of the railway station and the fact that Paddock Wood is an existing town with many services already present, this strategic allocation within the green belt may be the most sustainable way of meeting the housing requirement.  Nevertheless, we have concerns about it which mean that we must object to it at present.

It is considered that all strategic development should be built at high density, demonstrating excellence in design and environmental sustainability - especially with regard to carbon emissions.

AONB

There needs to be careful assessment of the impact that this development would have on the setting of the High Weald AONB.

Green Belt

Policy AL/CA3 does not set out what the site area is for the proposed urban extensions at Paddock Wood 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 (148.19ha) than is allocated (123.97ha). 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 sits at the eastern most extremity of the large 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.

The western side of Paddock Wood 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.  Given the findings of the study and the absence of an assessment of all the Paddock Wood allocations there is no evidence to suggest that it is appropriate to release these sites from the green belt and allocate them for development.

It is difficult to understand how the Council’s stated aims of optimising density (to minimise loss of green belt) has been applied. Will these urban extensions be built out at low, medium or high density in the interests of minimising green belt release?

The Council’s SHELAA set out that this site has a gross area of 307.79ha, of which the developable area is 269.65.  With an anticipated final yield of 4000 units density would be less than 15 dwellings per ha.  This is far lower than the density usually associated with suburban development of 40dpa.  On this basis it is not clear how this demonstrates optimised density and efficient use of land in compliance with paragraphs 122 and 123 of the NPPF. Agricultural land has a vital role to play in absorbing carbon and preserving biodiversity, including the biodiversity in soils.  Once it is built over the soil biodiversity is lost.  Therefore, to minimise land take, it is essential that density of developments on green field sites is as high as reasonably possible.

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. CPRE Kent considers that replacement green belt should be designated at Paddock Wood, in order to ensure that future residents have access to green spaces.

In any event, assurances are 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”.

A high proportion of the land in this proposed allocation lies in in flood zones 2 and 3.  While it is noted that the proposed policy requires that development will not exacerbate flooding elsewhere (potentially at Five Oak Green, Whetsted, Paddock Wood and further afield) and should deliver flood storage/attenuation/mitigation measures, it must be questionable whether development in an area at risk of flooding, and which could exacerbate flooding further afield, should be permitted in this location, especially in the light of impending climate change.  Moreover the policy does not at the moment appear to require building standards and designs that will make the new dwellings and other development resilient to any flooding that may occur despite the flood storage/attenuation/mitigation measures.

Foul drainage

Given that we understand that building work has currently stopped on the approximately 1,000 new dwellings already allocated at Paddock Wood, because of existing problems with foul drainage and lack of sewerage capacity, it remains to be seen whether there will be sufficient sewerage capacity provided in time for a further 4,000 dwellings.  We question whether Southern Water can raise the necessary funds.  This is a matter of crucial importance.  Unless there is clear evidence that the necessary infrastructure will be provided before the new dwellings are inhabited, this allocation should not be permitted.

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 allocated land is classified as Grade 2 and 3 – which is at least in part best and most versatile land.  There appears to be 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 Paddock Wood is in the darker skies category (one up from brighter) and the AONB to the south and the river plain north to Hadlow are both in the next to darkest category.  The scale of the development will introduce light pollution into the area of dark skies contrary to the NPPF.

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 30 sets out assumptions for the delivery of the 4,000 dwellings at Paddock Wood. It assumes that 333 dwellings will be delivered from 2024/25 delivering all 4,000 dwellings by the end of the plan period. This is likely to require groundworks in 2023/24. CPRE Kent queries whether there is sufficient time to prepare and agree a masterplan and outline application. These figures do not seem to have made an allowance for lower completions in the first two years as set out in paragraph 4.13.5 of the Trajectory Topic Paper.

Other matters

Development at Paddock Wood does have the merit of being close to a railway station.  In the event that this allocation goes ahead it is considered that provision should be made for a public swimming pool. The nearest pools are at Tonbridge, Cranbrook and Tunbridge Wells, meeting need locally would be more sustainable and, as an added advantage would be a useful focus as a meeting point for young people.  Consideration should also be given to providing a venue for a small cinema.

The road system in the centre of Paddock Wood needs to be improved. There needs to be additional public parking space and/or new, very frequent public transport from the surrounding villages (including East Peckham in Tonbridge & Malling and Yalding, Laddingford and Collier Street in Maidstone) - as Paddock Wood lies at the junction of three boroughs - to ensure that the residents of outlying villages who will continue to need to rely on Paddock Wood as their local service centre are not excluded by the vehicles from the additional 4,000 dwellings.

DLP_1950

Ms Madeleine Bohringer

Object

All this development will do is to expand Paddock Wood. It isn't going to be possible to make these new areas as 'distinctive' independent areas. The idea of having 'green wedges' is complete hogwash. It'll just be a utter mess, like Ashford.

It is never possible to mitigate the flooding. If you don't want to deal with excess water don't build over green areas.

DLP_2074

Terry Everest

Object

Refer to comments for STR/CA1  and STR/PW1

About 10% of this volume can be sustainably supported - the rest should be dropped in order to protect the town, its environs and the villages and hamlets around it. There must be thousands who oppose this scale and pace of development and I certainly do.

DLP_3011

DHA Planning for Countryside Properties

 

1 Introduction

1.1 Purpose of this report

1.1.1 This representation has been prepared on behalf of Countryside Properties – hereafter referred to as Countryside - in response to the Tunbridge Wells Borough Council (‘TWBC’) Draft Local Plan Consultation, which runs until 15th November 2019.

1.1.2 These representations relate to land within Countryside Properties’ ownership at Church Farm, Church Road, Paddock Wood. The site benefits from a hybrid planning permission (reference 14/504140/HYBRID) for 300 dwellings, including 105 affordable units and associated infrastructure. However, we consider there o be an opportunity to revisit the approval and to secure an improved design and an uplift in housing units to circa 370 dwellings

1.1.3 Based on this context, we consider this site to be suitable for continued allocation and support the relevant references within draft policy AL/PW 1.

2 The Tunbridge Wells Draft Local Plan

2.1 Overview

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

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

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

  • Vision and Strategic Objectives;
  • Development Strategy and Strategic Policies;
  • Place Shaping Policies for Paddock Wood; and
  • Development Management Policies.

2.2 Vision and Strategic Objectives

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

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

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

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

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

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

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

2.3 Development Strategy and Strategic Policies (Policy STR1)

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

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

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

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

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

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

2.3.7 We support the general principle of proportionately and recognise the sustainability of Paddock Wood and its ability to absorb increased growth. Nonetheless, we have some concerns regarding the balance between strategic and non-strategic scale allocations and the anticipated delivery trajectory. For example, 65% of new allocations would be delivered as part of the new strategic extension to Paddock Wood (4,000 homes) and the proposed Garden Village at Tudeley (1,900 homes within the plan period), both of which require a fully master-planned approach, which is a time-consuming process. A cautious approach is therefore needed.

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

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

2.3.10 Despite this evidence, TWBC has set a much more optimistic trajectory for delivery of Tudeley Garden Village, which is detailed in the Housing Trajectory Paper. The Council forecast that the Tudeley Garden Village will begin to deliver homes from 2025/26 onward, with an initial build out rate of 150 dwellings per-annum, rising to 200 dwellings per annum from year 6 onward.

2.3.11 Taking the above into account, our view is that the Council have applied overly optimistic development trajectory for the delivery of strategic sites, both in terms of the start date for completions and the expected build out rates. Accordingly, we would encourage the Council to disaggregate our clients land from the wider policy for Paddock Wood to ensure that the development can be brought forward swiftly and not delayed by the less certain elements of the strategic expansion.

2.4 Place Shaping Policies

2.4.1 The place shaping policies establish the spatial priorities for different areas in the borough, organised according to non-parish and parish areas. For each area, there is an overarching policy that development should adhere to and details are provided for individual allocated sites that will deliver the quantum of development proposed. The site-specific allocations provide both strategic and development management guidance.

2.4.2 Policy AL/PW1 sets the proposed strategy for Paddock Wood and states that approximately 4000 new dwellings will be delivered along with wider employment provision and supporting infrastructure. The policy concludes by stating:

‘Land at Church Farm is included in this allocation as, although it has outline planning permission for 300 dwellings, there is not a fixed layout. There is the potential that proposals at Church Farm could be refined to allow greater permeability through this site to land to be allocated further to the west. As part of this, there is the potential that a greater number of units than the 300 dwellings permitted could be accommodated on the site. For this reason, Church Farm is included in the allocation, and should form part of the masterplanning approach’.

2.4.3 Countryside support this acknowledgement that there is an opportunity to revisit the proposals and capacity for the site. However, we consider that the presence of an established planning consent means that the site should be subject to its own standalone policy that encourages the development to come forward in a timely manner. In contrast, by including it within the generic wider reaching policy for the strategic expansion of Paddock Wood, the draft plan is making the site susceptible to unnecessary delay.

2.4.4 In addition to a bespoke policy for the site, we consider the site capacity can be increased to 370 homes. In this regard, we attach an illustrative masterplan as Appendix 1.

3 Section 6: Development Management Policies

3.1.1 In addition to our comments on the strategy, we have reviewed the proposed replacement development management policies as set out in chapter 6 of the document.

3.1.2 In general terms, we would refer back to paragraph 15 of the NPPF that promotes succinct and up-to-date plans, which provide a positive vision. In contrast, the draft policies currently proposed are of such prescriptive detail that they are neither positively prepared nor flexible enough to allow for a range of different circumstances. Furthermore, many aspirations result in inevitable conflict. On this basis, we would recommend that the majority of proposed policies are simplified and where additional guidance is needed, this be included within secondary Supplementary Planning Documents.

3.1.3 Turning to detailed policies, there are a number of contradictory elements that need to be remedied before the plan proceeds to Regulation 19. For example, policy EN1 seeks to ensure development is consistent with the established character and surrounding form. However, policy EN4 places significant emphasis on measures to radically reduce greenhouse gas emissions. The provision of a step change towards more sustainable construction and climate change is, inevitably going to result in a need for a change in attitude towards design, material and construction. Accordingly, a cohesive policy approach is needed that allows innovative and different design if supported on wider environmental and planning grounds. As drafted the policies are too inconsistent.

3.1.4 A number of policies also seek to provide guidance rather than policy. For example, policy EN6 seeks to clarify what information is needed in order to assess a heritage proposal. This level of information should instead feature within a support SPD not policy.

3.1.5 In respect of the natural environment, policy EN20 seeks to protect the rural landscape. It states that development will be required to:

‘1. Conserve and enhance the unique and diverse variety and juxtaposition of the borough’s landscape and the special features that contribute positively to the local sense of place; and

2. Not cause significant harm to the landscape setting of settlements, including historic farmsteads and hamlets; and

3. Not result in unsympathetic change to the character of a rural lane, which is of landscape, amenity, nature conservation, or historic or archaeological importance; and

4. Restore landscape character where it has been eroded; and

5. Preserve intrinsically dark landscapes in accordance with Policy EN 10: Outdoor Lighting and Dark Skies’.

3.1.6 We support the principle of the policy but consider amendments are needed to ensure that it does not result in a blanket reason to refusal otherwise sustainable greenfield development. We suggest it be amended to read:

‘1. Conserve and enhance the unique and diverse variety and juxtaposition of the borough’s landscape and the special features that contribute positively to the local sense of place; and

2. Not cause Include appropriate mitigation to ensure against significant harm to the landscape setting of settlements, including historic farmsteads and hamlets; and

3. Not result in unsympathetic change to the character of a rural lane, which is of landscape, amenity, nature conservation, or historic or archaeological importance; and

4. Restore Enhance landscape character where it has been eroded; and

5. Preserve intrinsically dark landscapes in accordance with Policy EN 10: Outdoor Lighting and Dark Skies’.

3.1.7 Turning to housing policies, we have significant concerns about the drafting of several policies, that show a degree of misunderstanding of the development industry. For example, policy H1 states:

‘Unless there are exceptional circumstances due to specific site or development constraints, a condition will be attached to any grant of planning permission for new major residential development (including change of use) requiring one or the other of the following conditions:

1. That the permission be implemented within two years from the date of decision; or

2. That groundworks and the construction of the ground floor base of at least two buildings be completed within three years of the permission’.

3.1.8 Whilst the majority of developers would aspire to be ‘on site’ and under construction within 2 years, the reality is that there are often processes that need to be adhered to that are outside of the applicant’s control, including the need to formally conclude land purchases, to discharge conditions and to deliver off site mitigation. There are also ‘non planning’ consents that need to be achieved for example Section 278 Highway works, infrastructure agreements (S38 of the Water Industry Act), ecology licensing etc

3.1.9 The Council will also be aware that commencement of development is often prohibited by seasonal restrictions in respect of ecology and wider constraints.

3.1.10 The second requirement for two buildings to be commenced is arbitrary, for example what is the test for single unit schemes or conversion works? The correct test should be as set out in statute i.e. ‘a material start’.

3.1.11 With the above in mind, we consider the Council’s policy should be deleted or modified to the extent that it will endeavour to agree a two year start date based on site circumstances.

3.1.12 In respect of policy H2, and the preference for Multi-developer schemes and comprehensive masterplanning, we understand the aspiration. However, in reality such stringent requests often result in conflict and further delay and the Council should be careful not to try and impose itself on wider commercial arrangements that may prohibit rather than assist delivery. With this in mind, it is our view that the Council should shift focus away from how it wishes to change development industry practices and instead concentrate on what it can influence, namely the provision of detailed guidance for the proposed site allocations (including potential phasing plans and areas zoned for different forms of development). The Council could also consider imposing a illustrative delivery trajectory as part of the validation process.

3.1.13 We note that policies H3 and H4 have regard to housing mix and density yet provide little or no detailed requirement. On the basis that mixes must reflect market requirements, we consider any aspirational densities would be better placed being inserted into the wider reaching policy EN1.

3.1.14 Policy H5 sets out affordable housing requirements. Whilst we support the general thrust of the objectives and the securing of affordable provision, we object to the rounding up of the calculations and contributions being based on a net rather than gross number of units. For small scale proposals this will often see the proposed percentage increase to closer to 45% and 35% respectively. Such thresholds would therefore need to be tested and justified by evidence. A pragmatic approach would be to apply traditional rounding up or down.

3.1.15 The phasing of affordable provision also needs to be sufficiently flexible so as to not prohibit wider delivery. In this regard, we consider that entering into contract with a registered affordable prior ahead of the 50% occupation should provide the certainty of delivery, but without risking a wider delay in market delivery.

3.1.16 We also object to the expectation of sites that provide between one and nine units to pay a contribution towards affordable housing. This conflicts with Paragraph: 023 Reference ID: 23b-023-20190901 of National Planning Practice Guidance, which states planning obligations for affordable housing should only be sought for residential developments that are major developments. Any reduced threshold should be restricted to designated areas only and should be underpinned by detailed evidence.

3.1.17 The Council will be aware of wider country wide discussions regarding the viability of providing social rented accommodation as part of a wider offer. Such provision is becoming increasingly difficult and without robust policy in place that addresses this matter, this matter is likely to significantly slow delivery.

3.1.18 We note that the Council is only willing to allow the use of Vacant Building Credits in exceptional circumstances. However, the test proposed appear significantly more onerous than have been considered and applied elsewhere. Based on the tests proposed, we fear that there will be a delay in genuinely vacant buildings, that are entitled to use of VBC, to be delayed in coming forward in order to meet the overly onerous criteria.

3.1.19 Finally, we note paragraph 6.160 states:

“…The Council will assume a buffer of 25m from the edge of [ancient] woodland expecting through assessment for developers to confirm that this or any other distance is appropriate and that the priority for such buffers will be ecological mitigation and enhancement for the woodland rather than the amenity of the proposed development.”

3.1.20 The advice from the Government’s statutory advisor on biodiversity, Natural England, states that:

“For ancient woodlands, you should have a buffer zone of at least 15 metres to avoid root damage. Where assessment shows other impacts are likely to extend beyond this distance, you’re likely to need a larger buffer zone.” [1] https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences

3.1.21 Whilst it is recognised that every case will need to be treated on its merits, the Council has provided no justification for imposing a new starting point of 25m, which is nearly double the standard minimum requirement set out by Natural England. This increased buffer zone does not appear to have been based on any evidence. It will simply reduce the quantum of development that can be achieved on many sites, which will in turn increases the risk that additional land is likely to be required elsewhere to meet development needs. We object to this proposed buffer, and request that the standard accepted minimum distance of 15m should be stated instead.

3.1.22 Rather than increasing the size of the necessary buffers based on an arbitrary figure, the policy should instead provide clarity on the functions and forms of the buffer zones, the purpose of which is to minimise recreational pressure on ancient woodlands by preventing uncontrolled access by people and pets. Buffer zones however can also provide benefit for the schemes they fall within by forming part of open space provision and can include planting, paths and play equipment, but not buildings or roads.

3.1.23 In summary, whilst this overview is not exhaustive, we do have concerns about the nature of the proposed policy framework and the degree to which it appears to be trying to limit and frustrate development. Accordingly, in the interests of positive planning, we recommend that the policy framework is simplified and refined and subject to further detailed consultation and focussed on planning matters.

4 Conclusion

4.1.1 This representation has been prepared on behalf of Countryside Properties in response to the Tunbridge Wells Borough Council Draft Local Plan Consultation. The purpose being to provide comment on the Council’s proposed development strategy.

4.1.2 In this respect, we support the aspiration to meet housing need in full and consider that a dispersed growth strategy represents the optimum means to achieve this. Furthermore, we support the continued allocation of our client’s land at Church Farm, Paddock Wood, albeit we favour a bespoke policy for the site.

4.1.3 In this respect, it is important that mechanisms are put in place to allow this site to be brought forward promptly, as we consider that the Local Plan strategy relies too heavily on the delivery of a new village that would require the provision of supporting infrastructure.

4.1.4 I trust the contents of this representation are clear and I hope the comments are useful in guiding the forthcoming stage of the plan making process.

DLP_3275

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

Table 4

The Local Highway Authority conditionally supports this table and provides the following comments on Highways/Sustainable transport sections for individual sites:

Parcel 1- Optimum access point/s should be decided as part of the masterplanning - not at this stage. Dedicated bus route thorugh site could be a result of masterplanning exercise, plus segregated footway/cycleway routes.

Parcel 2 - Optimum access point/s should be decided as part of the masterplanning - not at this stage. Dedicated bus route thorugh site could be a result of masterplanning exercise, plus segregated footway/cycleway routes.

Parcel 3 - Optimum access point/s should be decided as part of the masterplanning - not at this stage. Dedicated bus route thorugh site could be a result of masterplanning exercise, plus segregated footway/cycleway routes. Pedestrian permeability vital for potential Primary School site.

Parcel 4 - Optimum access point/s should be decided as part of the masterplanning - not at this stage. Dedicated bus route thorugh site could be a result of masterplanning exercise, plus segregated footway/cycleway routes. Assessment of junction has not been undertaken, and reference to this should be removed. Assessment should take place as part of masterplanning exercise.

Parcel 5 - Optimum access point/s should be decided as part of the masterplanning - not at this stage. Dedicated bus route thorugh site could be a result of masterplanning exercise, plus segregated footway/cycleway routes. For this parcel, the 'Use' is down as ED, but housing is subsequently mentioned. Different transport requirements: will need further defining at Masterplanning stage.

Parcel 6 - Optimum access point/s should be decided as part of the masterplanning - not at this stage. For this parcel, the 'Use' is down as ED, but housing is subsequently mentioned. Likely to be unsuitable for housing from a transport perspective: remote from town and key facilities owing to location betwen two railway tracks.

Parcel 7 - Optimum access point/s should be decided as part of the masterplanning - not at this stage. Dedicated bus route thorugh site could be a result of masterplanning exercise, plus segregated footway/cycleway routes. Assessment of junction has not been undertaken, and reference to this should be removed. Assessment should take place as part of masterplanning exercise.

Parcel 8 - Assessment of junction has not been undertaken, and reference to this should be removed. Assessment should take place as part of masterplanning exercise.

Parcel 9 - Optimum access point/s should be decided as part of the masterplanning - not at this stage. Dedicated bus route thorugh site could be a result of masterplanning exercise, plus segregated footway/cycleway routes - especially if developed as a neighbourhood centre. Assessment of junctions/widening have not been undertaken, and reference to this should be removed. Assessment should take place as part of masterplanning exercise.

Parcel 10 - Assessment of junction has not been undertaken, and reference to this should be removed. Assessment should take place as part of masterplanning exercise.

Parcel 11 - No built development proposed. Assessment of junction has not been undertaken, and reference to this should be removed. Assessment should take place as part of masterplanning exercise.

Parcel 12 - For this parcel, the 'Use' is down as School Expansion Only, but housing is subsequently mentioned. Unlikely that school access could be jointly used for residential access.

Policy AL/PW 1

The following changes are requested:

Paragraph 2 - “Transport – 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.

Reference should also be made 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 Tudeley Village, 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. Developers will be required to fund and construct 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”

Paragraph 10 – “A strategic approach to increase walking and cycling permeability that is accessible to all and permeable by all modes will be included in the masterplanning (see Policy TP 2: Transport Design)”

Public Rights of Way and Access Service

The County Council recommends tha considering the scale of the proposed development and the existence of the PRoW that pass through the proposed development sites, reference should be made to PRoW within this policy. 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.

Heritage and Conservation

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

This site is a composite site surrounding Paddock Wood and there is potential for prehistoric remains in the River Terrace Gravels and there is potential for prehistoric and later activity along the river channels. This area is known to have been utilised in the Medieval and Post Medieval Periods for industrial activity. There are many historic farm holdings in the area some of which are moated complexes suggesting medieval origins.

The historic landscape in this area is of considerable importance with a strong horticultural and post medieval industrial character. Given the size of this proposed development scheme, there is a need for detailed consideration of the impact on the surrounding historic landscape, including nearby villages, key historic buildings, sensitive archaeological landscapes, including lanes, field boundaries and historic land use features.

Prior to allocation of this site, there needs to be a thorough Archaeological, Historic Buildings and Archaeological Landscape DBA and fieldwork.

The County Council would like to ensure that there is an adequate supply of open space across Tunbridge Wells, including at Paddock Wood. Studies have shown that green spaces provide considerable health and well-being benefits for the public, but it is acknowledged that these spaces are facing increasing pressures from new developments and a growing population. There is a risk that the attractive qualities of green spaces will deteriorate unless appropriate steps are put in place to protect the sites and manage access. To cope with the increasing demands of a growing population, it is recommended that Local Plan ensures that adequate green open spaces are provided across the borough.

DLP_3430

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_3565

Mrs G M L Sinclair

Object

I write to object in the strongest possible terms to the proposed Local Plan for Paddock Wood and surrounding villages.

First, I specifically address the area designated PW 1_2, where I have lived for 35 years, and have direct knowledge of flooding issues over the years.whenever it rains Nursery Road floods and overruns the curbs onto the pavement, reaching residents' gardens, as the drain running in Maidstone Road cannot cope with the rain-water run-off from the adjacent land. Since the main area of the land has been left to nature, trees, shrubs and wildlife have filled it. The result is that all the plants take up the water and the flooding is reduced - this re-wilding has resulted in a proliferation of bats, birds, hedgehogs, foxes and the like. If, as proposed, the land is covered in concrete with houses/industrial units then this flooding will be exacerbated as the area is a Zone 3 flood plain, as designated by the Environment Agency, that is "an area with a high probability of flooding." The previous Local Plan denied any planning permission on the grounds that it was a Zone 3 Flood Plain. We have seen the devastation of flooding in the country the last two weeks and you now propose a similar fate for the residents here. How will you protect my single-story home, and the other houses which will be directly affected, if this happens? The evidence is clear, areas designated as Zone 3 flood plain should never be built on, so why are you proposing to do so? The land has to my knowledge been used informally for recreation - walking, dog walking children climbing trees, people enjoying nature and the open air for 35 yeas. There is no other such area at this end of Paddock Wood, and you are proposing to deprive people of this simple yet vital pastime - "green wedges" really are not sufficient.

Second, I turn to infrastructure, which the plan out-lines in almost fairy tale manner as a "wish list", as Tunbridge Wells Borough Council have no jurisdiction over enforcing it - people cannot be forced to walk or cycle around nor can companies be forced to build or expand.

Permission was given for 300 homes to be built despite the drainage and sewage problem which was well known by Officers and Members of Tunbridge Wells Borough Council. Southern Water have not expanded their sewage works to accommodate this increase and so far, only a small proportion of these new homes have been connected to the main drainage system. How will you force Southern Water to expand their system before any of these proposed homes are built in order to safeguard current residents from sewage backing up into their homes?

a. Medical Care

Woodlands Surgery has struggled over many years to find permanent G.P.s to join the practice, and now all the current G.P.s work part-time. Those registered to the practice find great difficulty in getting an appointment, and often see one locum after another with no continuity of care. This plan blithely states that we will need further medical practices and practitioners: how do you propose to force doctors to come here and build another practice? You can lay down a policy, but you cannot enforce it.

b. Education

Our Primary School is almost full and the secondary School, Mascalls, is reaching its limit. Both can cope with the current population; however, any increase will require expansion and more schools, which you state in the plan. Kent County Council has reversed its decision to build another Primary School here, in conjunction with the Diocese of Rochester, as the population curve does not warrant it, considering the further 300 homes being built. How will you force K.C.C. to build further schools before these proposals for 4,000 homes go ahead?

c. Roads

The road structure into and around Paddock Wood just about copes but becomes very congested at specific times of the day, obviously the morning and afternoon rush hour. The congestion is exacerbated at the Nursery Road/Eldon Way junction with large multi-wheeled lorries which can only enter Eldon Way by using the wrong side of the road as they cannot manoeuvre into the junction. Users of Eldon Way very rarely obey the Give Way sign and I have seen numerous "near misses" to residents as they enter or leave our road. The danger has increased severely now as permission was granted, despite every Nursey Road resident objecting, to the siting of the Make Ready Ambulance Unit on Eldon Way. Ambulances, often with "blue lights", entering a very congested road junction and then traversing a road of parked cars on Maidstone Road, whilst lorries and cars try to make their way into Paddock Wood is absolute madness. Further traffic from this proposed expansion of Paddock Wood will result in total gridlock at certain times of the day. All your policies cannot force Kent Highways/County Council to build more roads to alleviate the prospective problem. Will necessary infrastructure roads be built before any new homes are built?

d. Job Opportunities

Paddock Wood attracts commuters from surrounding villages as we have a good rail service to London. However, the available designated parking is full most days and commuters now are forced to park on residential roads, creating many traffic difficulties. By the time morning trains reach Paddock Wood from the coast there are very few seats available and the trains are uncomfortably over-crowded. If more houses are built, then this will be hugely exacerbated. How will you force the rail companies to increase rolling stock, or new railway lines to be built to accommodate all the proposed new passengers from 4,000 new homes before they are built?

There are few job opportunities in Paddock Wood - warehousing offers few jobs now, and companies have not chosen to move here. Land designated for Light industrial use by the previous Local Plan was not taken up as landowners could sell their land for much more if housing permission was given. How do you propose forcing landowners to sell their land for light industrial/commercial use? We could see a scenario of thousands of people living in Paddock Wood with no job opportunities and the resulting social problems which would arise. This Local Plan delivers a nightmare prospect of social unrest for Paddock Wood.

e. Commerce

Paddock Wood town centre has useful local shops but as you have seen from out proposed Neighbourhood Plan, residents' desire is to expand the centre in line with our small community. We have many small businesses which are well supported but a vast influx of people will change the entire ambience of a rural town. There is a small parcel of land available for commercial use in the centre of the town but planning permission is being sought by Churchill Homes for retirement living, which does not fit with our Neighbourhood Plan at all. Will you support our Neighbourhood Plan and refuse permission again?

In conclusion, I ask all Borough Councillors to consider the needs of our small rural town. We live here because we desire a certain small community in a rural area: this proposed Local Plan would turn us into a concrete suburb fit only for commuters.

DLP_3606

Southern Water Services Plc

Support with conditions

Southern Water is the wastewater undertaker for Paddock Wood, and has a statutory duty to serve new development. Proposals for 4000 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 such a significant development, a strategic masterplanning approach on infrastructure delivery is required, and Southern Water supports criteria 4 of Policy AL/CA3 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 3 & AL/PW1

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, …

Our assessment has also revealed that Southern Water's underground infrastructure crosses this site. This needs to be taken into account when designing the site layout. Easements would be required, which may affect the site layout or require diversion. Easements should be clear of all proposed buildings and substantial tree planting.

In consideration of the above, we recommend the following criterion is added to Policy AL/CA 3 and AL/PW 1

Layout is planned to ensure future access to existing wastewater infrastructure for maintenance and upsizing purposes

DLP_3608

Southern Water Services Plc

Support with conditions

PW1_6 and PW1_7

We have assessed these sites and note their close proximity to Paddock Wood Wastewater Treatment Works (WTW). Southern Water endeavours to operate its WTWs efficiently and in accordance with best practice to prevent pollution. However, unpleasant odours inevitably arise as a result of the treatment processes that occur. New development must be adequately separated from WTWs to safeguard the amenity of future occupiers. This is in line with paragraph 180 of the National Planning Policy Framework (NPPF, 2018), which states that 'Planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on [...] living conditions' and Paragraph 182 which states ‘Planning policies and decisions should ensure that new development can be integrated effectively with existing businesses and community facilities […] Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established.’ 

In addition, paragraph 7.6.5 of the Kent Waste & Minerals Local Plan 2016 (p106) states that 'certain types of development which require a high quality amenity environment (e.g. residential) may not always be compatible with [...] waste management activities which are industrial in nature.' Policy DM 8 further stipulates ' Planning applications for development within 250m of safeguarded facilities need to demonstrate that impacts, e.g. noise, dust, light and air emissions, that may legitimately arise from the activities taking place at the safeguarded sites would not be experienced to an unacceptable level by occupants of the proposed development and that vehicle access to and from the facility would not be constrained by the development proposed.' 

In consideration of the above, we recommend the following criterion is added to the list of considerations for Parcel 6 (North East Parcel) and Parcel 7 (East Parcel) in Table 4: Table showing parcels of land; 

The development layout must provide sufficient distance between Paddock Wood Wastewater Treatment Works and sensitive land uses, such as residential units, schools and recreational areas, to allow adequate odour dispersion, on the basis of an odour assessment to be undertaken in consultation with Southern Water.

DLP_3692

Capel Parish Council

 

The expansion of Paddock Wood can be achieved without using Green Belt land at East Capel for housing. 4,000 new dwellings in Paddock Wood is excessive given the scale of recent developments and overambitious, and Green Belt land in a neighbouring parish should not be taken to provide for this. Capel Parish Council believe that if TWBC is not willing to argue that the housing need given to them by government is too high, they can use the NPPF’s protection of Green Belt to adjust their expansion plans.

DLP_3835

Natural England

 

This is a large strategic site which is likely to impact of the setting of the AONB. Landscape Sensitivity Studies indicate that the site has medium-high sensitivity for even small scale development. Whilst policy wording requires provision of a masterplan is welcomed, further landscape studies are required to inform the allocation at this stage. . It is advised that a Landscape and Visual Impact Assessment (LVIA) in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition) is prepared to inform this allocation. Additional information is required in order to understand how the allocation may impact the AONB and indicate the scope for mitigation.

DLP_3932

Ide Planning for Paddock Wood Town Council

Object

OBJECT as per STR/PW1 above

This policy covers 12 parcels. For those that propose residential development, it would be helpful in an appendix to set out expected housing numbers by site so clarifying how the overall figure is arrived at. This to be read alongside housing development elsewhere including that at Mascalls Court Farm, Mascalls Farm and Church Farm.

In addition -

  • Could noise/green buffers be considered for the whole area?
  • There is a national shortage of GPs, impactng on practices across West Kent at the current time, with additional problems recruiting practice nurses. Doubling the size of the town will require another GP practice with 6 or more GPs and it is unclear where these will be recruited from. Similarly, hospitals would need to expand to accommodate a significant expansion in local population. There is no quick fix to the recruitment of healthcare staff, as a GP takes more than 8 years to train & numbers entering the training are falling.
  • Land should be allocated for a cemetery.
  • There is an aging population, but no apparent inclusion of additional adult social care provision e.g. residential care and nursing homes. There almost no facilities for elderly residents requiring residential and nursing care in the town and those people requiring nursing care have to be accommodated outside the town, separating them from family.
  • There are inadequate sports and recreation facilities, with proposals addressed by the Neighbourhood Plan, some of which have been included in the draft plan. The outdoor sports hub should be included within the boundary of Paddock Wood, in the area north of the railway which is be less suitable for housing as much of the area is in flood zone 3.
  • In response to flood risk, there are a number of overarching concerns –

A. Confusion by the consultant, upon whom TWBC is reliant, to provide sound engineering advice. The main rivers Bewl and Beult are confused which potentially will provide the wrong river flow data used in the modelling for the SFRA documents. The rivers Bewl and Beult have entirely different flood, flow and catchment characteristics (the Beult is wide and flat; the Bewl is very short and graded). Bear in mind that these are “Final” issues of both reports, not a draft issue of either. TWBC clearly believes the information to be correct and accurate for it to be issued to the public domain in “Final” version. These final reports contain fundamental errors so both SFRA1 and 2 are not correct and accurate.

B. NPPF/PPG Sequential or Exception Tests have not been applied. Neither have any comparable, alternative tools in assessing flood risk. This appears intentional. Lack of test application is clearly stated in each report by JBA (TWBC Consultant).

C. Comparison of each land parcel on its own merits for flood resilience and then against the other land parcels identified, but NOT assessing any impact on existing residents in Paddock Wood. Indeed most of the parcels of land actually increase predicted flood depth – doesn’t that INCREASE flood risk, contrary to the NPPF/PPG?

D. There is no apparent understanding by the SFRA1 and SFRA2 authors of the flood mechanisms affecting Paddock Wood. They are relying solely on the modelled effects of each parcel which is incorrect.

E. There is no evidence of betterment being provided by bringing forward any of the land parcels for development to existing residents by REDUCING flood risk first and then deciding if new construction is possible.

F. No confirmation or detail of any flood relief or attenuation measures in either report (SFRA1 or SFRA 2) that would enable the Land Parcels to be deemed suitable for development following provision of the same attenuation.

G. Some of the proposals appear to be in breach of Riparian Law.

In relation to specific parcels, comment is made as indicated firstly, in the generality and secondly, in specific response to the SFRA 2019 -

Parcel 1: Whetsted Woods should be retained, as this area needs all the trees it can get to soak up the water. A significant proportion of this sector is in flood zone 3 with further areas in zone 2 – this would only be suitable for low density housing with considerable cost and creation of surface water management schemes, which may make it unprofitable for developers. Any housing built here should fit in with the surrounding area and should not be of high rise design, as this might be the temptation to fit the numbers in. There is a need to retain an attractive view of the town as visitors enter from the west. The Eastlands track running in this parcel and #3 and 4, should be upgraded to at least B road status – this is to relieve traffic that would otherwise run through town. Access from Maidstone Road, Paddock Wood should not be an option as this simply encourages more traffic through the single main road in the town. The public rights of way/cycle routes should link to the town centre, not the existing houses.

SFRA –

  • There is an area used by the UMIDB pipe to the north east sector of the parcel for flow attenuation during a flood. This is a defence and MUST NOT be compromised. Any modelling for the parcel must show this. If JBA had consulted with the UMIDB, then this would be highlighted in this section of text.
  • Under Fluvial flooding (climate change) it is stated ‘When potential changes in flood flows due to climate change are considered (flow rates increased by 70% for the 1% AEP event), there is an increase in the extent of Flood Zone 3a, most notably in the west of the parcel’. It is unclear why the sequential test has not been applied.
  • How exactly will betterment be provided? TWBC must explain this. This is very far from clear.
  • It is stated that when the residential area 1a was extended southwards to Badsell Road, increases in flood depth arose as a consequence of diversion of flood waters onto the B2017 south of the parcel. How is this justified?
  • The parcel is described as being currently undeveloped and there are no formal drainage systems in place. However, Tudeley Brook and the watercourse flowing along the eastern boundary of the parcel are maintained by the Upper Medway Internal Drainage Board. Tudeley Brook flows through the parcel in a northerly direction and there are a number of minor watercourses and drainage ditches flowing through the parcel - this appears to refer to Gravelly Ways. If 1a is to discharge to either the Tudeley Brook or Gravelly Ways, then the effectiveness is only as good as the grilles and culverts under the railway being kept clear by Network Rail. An existing problem could be amplified.
  • Residual risk at the parcel primarily concerns fluvial and surface water (rainfall) flood events occurring larger than those for which the parcel/development design has been developed – this is unquantified.
  • Flood risk in the northeast corner of the parcel is predicted to decrease, and flood depths are predicted to reduce by circa 0.25m across a large area of Paddock Wood northeast of the parcel as residential area 1a reduces the easterly flow of flood water – this too needs to be demonstrated.
  • It is stated that flood risk within the parcel increases, with changes in flood depth of up to +0.25m typically predicted through the open space areas, although a portion of land north of Badsell roads has changes in peak flood depths greater than this predicted. Increased flood depths extend a relatively short distance south of Badsell Road. North of the parcel, flood depths across the railway line [my emphasis – itself?!] are predicted to increase – reference is next made to land north of the railway ‘Flood depths and extents to the north of the railway line also increase, with increases in flood depths of up to 0.25m typically reported, although there are localised areas where the change in depths are greater’.
  • It is contended the proposed development at Parcel 1 has the greatest impacts on flood flow pathways and therefore depths in the SFRA area (due to residential area 1a). More localised changes in flood risk are apparent at and closer to other parcels, due to their specific impact on flood risk. However, this is in the context of no sequential testing.
  • In considering influential factors on flood risk, what account has been taken of surface water flows from all of the new buildings? This will add to the flows needing to go through the Tudeley Brook and Gravelly Ways culverts. This increased volume will increase the flood risk if the Tudeley Brook Bridge and the Gravelly Ways trash screen are not kept clear unconditionally by Network Rail. There is no mention of this here.
  • Strategic storage measures appear not to have been defined in either SFRA 1 or 2? How can they be used to put the parcel forward when not defined anywhere in SFRA1 or 2?
  • Increased conveyance i.e. the effect of introducing new channels through the parcel 1 by increasing the existing channel capacity, is only feasible if they can discharge under the railway.
  • It is stated defences would potentially be located in the northeast corner of the parcel, further reducing the eastward flow of flood water into existing communities in Paddock Wood. The potential defence extends from residential area 1a to the railway line, and aims to reduce the risk of flood water along this eastward flow route. There is however no further detail.
  • It appears that without an upstream flood storage reservoir then the railway line will be flooded – the safety of the railway would otherwise be compromised.
  • It is noted there remains a localised increase in flood risk at the southern end of the parcel due to ‘reflection of flood water’, but this does not extend beyond the parcel, south of which reduced flood depths are predicted on the B2017.
  • Can the principle of development at the parcel be supported? It is stated substantive development at the parcel can be supported in principle , although delivery of the scale of development proposed will require formulation of more detailed analyses in a parcel specific FRA to validate the total area footprint area that is viable.
  • It is noted additional work is required to refine proposed development at the parcel and plausible delivery of flood risk management mitigation measures which are required to facilitate development at the parcel. The evidence base in terms of understanding flood flows, connectivity of drainage assets (both natural and man-made on and off parcel), and costs of flood risk management measures (operation and maintenance) and ownership/responsibilities will be key considerations – this is insufficient justification for the proposed allocation on flood risk grounds.

Parcel 2: Whetsted Woods should be retained, as this area needs all the trees it can get to soak up the water. A significant proportion of this sector is in flood zones 2/3 – this would only be suitable for low density housing with considerable cost and creation of surface water management schemes, which may make it unprofitable for developers. Any housing built here should fit in with the surrounding area and should not be of high rise design, as this might be the temptation to fit the numbers in.

SFRA –

  • Defences and flood risk management measures – it is stated there are no formal defences within or upstream of the parcel, but Leigh Flood Storage Area, located on the River Medway upstream of Tonbridge, acts to reduce the depth of flood water originating from the River Medway. For watercourses originating south of Paddock Wood, actual risk is aligned with the magnitude of events that inform the Flood Zones. For the River Medway, Leigh Flood Storage Area reduces flood extents and levels on the floodplain at the north of Paddock Wood and so actual flood risk is less than the risk presented in Flood Zones. However, there are MANY watercourses that flow uncontrolled into the Medway below the Leigh Barrier which itself is only designed to protect Tonbridge (Pen Stream, Hilden Brook, Bourne, etc). The Leigh scheme RMFRS should not be considered as a flood defence which provides any protection to Paddock Wood. The site is CERTAINLY within the affected area if the Leigh Reservoir were to fail though. The operation of the RMFRS is there to protect Tonbridge; as such this may not be in the best interests of Paddock Wood at the same time.
  • The southwest corner of proposed development 2a was tapered from the central watercourse through the parcel during an iteration of parcel layout testing to reduce the impact of the development on increasing flood risk. This was undertaken at the modellers (Engineers) discretion and is not in accordance with the NPPF which seeks to apply the Sequential Test to divert areas of development to zones of lower flood risk.
  • There is no indication that the UMIDB is aware of these development proposals for the parcel. As such they may not be aware of any impending maintenance implication or need to increase their maintenance budget within the IDB to accommodate the parcel being progressed for development.
  • Summary of flood hazards – this fails to mention the information contained in the table listed on page 101 of SFRA1. This clearly states that the parcel is affected by any failure of the Leigh Barrier and the River Medway Flood Relief Scheme, which is omitted in the assessment of Land Parcel 2. This assessment of the parcel is therefore unsound.
  • Reservoir risk of failure – here it is acknowledged that only large areas to the north of the parcel are at risk of flooding from RMFRS failure. This is still not totally consistent with the table on page 101 of SFRA1.
  • The area is not protected by any formal or Main River flood defences but does flood, as either the current or previous owners of Tudeley Brook Farmhouse have installed/constructed earth banks around their property (these are private defences). It would appear that these defences have NOT been considered by this report or modelling therein for the parcel and therefore they have not been identified as being overrun in the event of a flood if the site were developed. This again is unacceptable and an omission. If they had consulted with the UMIDB these would be listed here. There is also an increase in predicted flood depth around Tudeley Brook Farmhouse with the proposal which will be detrimental to residents there.
  • There is no proof or evidence that the RMFRS will either reduce or prevent flooding in the parcel. The parcel floods as the flood water cannot discharge through a backed up drainage system to the River Medway to the north. Any infrastructure will need to demonstrate betterment for the area prior to implementation.
  • “Flood risk is predicted to increase in the area east of the parcel, with rises in flood depths of up to 0.25m immediately adjacent to the parcel and widespread increases between 0.001m and 0.05m across the north of Paddock Wood.” The development WILL INCREASE the risk of flooding to existing residents as stated in the analysis here. Development of the parcel is shown to increase flood depth (and hence flood risk with no betterment) to all areas of Paddock Wood (see “Mapping” section plan for details).
  • Development of Parcel 1 causes parcel 2 to flood and parcel 3 also causes any benefit from parcel 2 to be removed; Parcel 4 causes an INCREASE in flood risk to Paddock Wood, but that is acceptable as the modellers deem this to occur over a smaller area. No betterment is provided. A general theme is that flood risk is increased elsewhere as a direct result of development of parcel 2.
  • There is an admission that flood waters will be directed in an easterly direction towards the existing settlement of Paddock Wood from the parcel. No details of any flood storage are given despite mention of some scheme compliant with the Reservoirs Act 1975 (this would be of large scale construction indeed). Assumptions are made within the modelling that have not been explained or adequately quantified (e.g. a new channel was introduced…..). Also if the defences upon which the modelling is based do not even exist (yet) or there is a degree of uncertainty as to if they can built and there is a stated increase in flood risk, then this is a fundamental flaw in the whole process.
  • Infiltration solutions suggested – SuDS – will not work in a clay based catchment.

Parcel 3: Parcel 316 is allocated in the draft Neighbourhood Plan for an outdoor sports hub to accommodate all four football clubs, the rugby club and potentially tennis, netball and cricket. 316, 318 & 319 are often under water in the wet months of the year, so would not be suitable for residential properties, unless these were low density and considerable surface water management infrastructure was employed, which would be costly for developers. Much of this area is below the level of the B2160 as it leaves the main settlement of Paddock Wood. It is important to consider here any plans Maidstone Borough have to build near Beltring Station, as this may adversely affect flood mitigation features planned to protect Paddock Wood. The Head of Planning at Maidstone admitted that this was up for consideration. There is also rumoured expansion of the industrial area at the top end of the B2160 before the Hop Farm roundabout.

SFRA –

  • The assumption that the RMFRS will reduce flooding in the parcel is wrong (see above). THE RMFRS WILL NOT REDUCE THE RISK OF FLOODING AS THE PRIMARY CAUSE IN THE PARCEL IS THAT FLOOD WATERS CANNOT DISCHARGE THROUGH THE SYSTEM TO THE MEDWAY IN SPATE. IT BACKS UP CAUSING FLOODING. THE FLOOD RISK IS NOT LESS THAN SHOWN IN THE FLOOD ZONES – IT IS AN INCORRECT ASSUMPTION TO STATE OTHERWISE. Indeed 75% of the land parcel is shown to be at risk in the assessment of the parcel from the failure of the SAME quoted reservoir.
  • Parcel 3 requires that Parcel 2 will store flood waters for a prolonged period; how will this work – and not cause flooding – during a prolonged event?
  • No consideration of any existing private defences in the assessment of the parcel, e.g. at Tudeley Brook Farm.
  • No Natural England input into selection of the parcel apparent, despite being in one of their zones of influence.
  • Parcel is acknowledged as increasing flood risk to other parts of Paddock Wood.
  • Noted increase in flood risk around Eastlands Lane. To quote improvements to the centre of Paddock Wood generated by the scheme appears to be incorrect. Due to local geography, topography and flood routing pathways, this cannot be right.
  • Parcel 3 development increases flood risk to the south east of the parcel.
  • A reliance has been placed on “strategic flood storage sites” which have not been detailed in either SFRA1 or SFRA2. Therefore such sites cannot be considered when assessing the parcel or undertaking modelling.

Parcel 4: Nursery Road is an area of significant regular flooding (last in August 2019) and would make developing this site difficult without significant improvement in surface water drainage. Additional traffic in this area would cause problems for existing residents, who currently experience overspill parking from Eldon Way. This could be improved by access from the Whetsted road, along the existing farm track (if expanded). The plan for the Outdoor Sports Hub suggests opening this access to allow access from the Whetsted Road.

SFRA –

  • There are no residential dwellings in Eldon Way. Fundamentally inaccurate statement.
  • Current flood risk is quite high with a 30% chance of 0.1 AEP being met or exceeded.
  • As there is no hard defence line between parcels 1, 2, 3 and 4, then parcels 1, 2 and 3 cannot also benefit from any defence or storage reservoir as there is free flow (i.e. no hard walls or defences) between any of the parcels stated. These are knock on effects which have not been considered.
  • Up to 250mm of acknowledged INCREASED flood risk to Eldon Way, so also Maidstone Road/Lucknow Road, Transfesa and Lambs Park will also suffer.
  • Combination of all parcels effects by and on Parcel 4 is unacceptable.
  • Again hypothetical channels adding in to the modelling but no basis or foundation is given for this alteration when considering the parcel.
  • Strategic storage again mentioned but not detailed as to what has been considered to make this parcel modelling “work”.
  • Parcel 4 on its own and with other parcels increases flood risk. There is no betterment generated by development of the same parcel 4.

Parcel 5: This site should not be used for housing, as it is well below the road level and regularly floods. Would only be suitable for employment development, which would make sense in terms of Maidstone Borough Council allowing expansion of the commercial development further north. Footpaths should be maintained and the rural communities of Lucks Lane, with listed buildings, have a character that would be lost from over development of this area. Lucks Lane itself is not suitable for increased traffic movement and would need considerable work to widen and strengthen the carriageway if traffic was to increase in this area.

SFRA –

  • Surrounding land use as described is incorrect.
  • North of Lucks Lane (the agricultural sale field) currently floods every winter and is situated much lower than the Maidstone Road. An IDB watercourse drains the parcel. No input from the UMIDB evident in the parcel assessment.
  • All of the parcel is acknowledged as being within Zone 3a, so how will it ever pass a Sequential Test let alone an Exception Test??
  • Knock on effects to the existing residents in the flood sensitive area of Lucks Lane have not been assessed.
  • The summary of flood hazards is wrong. The site floods as water cannot discharge to the Medway in spate; the site DOES NOT flood as a result of flood water running off of the hills to the south of Paddock Wood. See point D at the start. This mechanism of flooding is not considered here.
  • Majority of the parcel is acknowledged as being in an area at risk of Reservoir failure (RMFRS).
  • Parcel is a Natural England SSSI Impact Risk Zone. No discussion with Natural England evident.
  • Parcel will increase local flood risk with no betterment for existing homes and businesses.
  • Proposed adjoining parcel 5 increases the modelled flood risk!
  • The centre of Paddock Wood WILL NOT be protected by the parcel, as the parcel is downstream of the centre of Paddock Wood! This is fundamentally a wrong statement and casts doubt on the whole document.
  • To state that Parcel 1 works will benefit parcel 5 is nonsense. They are on different sides of the railway line for starters.
  • Some sort of flood defence in mentioned, but it is not detailed in type or scope. This cannot be relevant to determining the viability of the parcel for development.

Parcel 6: a specific allocation for expansion of the WWTW should be made; consideration must be given to safeguarding the rural character of the hamlets here – there is already considerable loss of character from building large farm/storage buildings close to these hamlets/listed buildings. It is not possible to see where any housing might go on this site (the allocation makes no reference in the Plan to residential development), especially in such close proximity to the sewage treatment works. Road access to this site would be difficult without a new road.

SFRA –

  • The local network of drainage ditches relied upon to drain this parcel cannot be deemed to be effective for such new development. This has not been confirmed in any way by the Upper Medway Internal Drainage Board. Recent planning application correspondence has shown this inadequacy.
  • Incorrect RMFRS protection statement used again here.
  • Ground levels are proposed to be raised to permit development on the site. There is no confirmation that existing residents will not be affected adversely by such a suggestion.
  • Part of the parcel in the analysis is described as residential, when the parcel is potentially destined for non-residential use in the title.
  • Drainage from the parcel is destined for the Rhoden system. This is already accepting increased volumes of surface water from the Mascalls Court Farm (Persimmon) and Church Farm (Countryside) developments. These volumes have not been included in the modelling for the SFRA1 or 2 and should be. No consideration has been given to the effects of the parcel, the permitted developments and existing residents. THEREFORE THE MODELLING OF THIS PARCEL IS DEFICIENT AND CANNOT BE RELIED UPON. IT DOES NOT CONSIDER ALL THE FACTORS THAT MUST BE CONSIDERED. THIS MAKES THE MODELLING UNRELIABLE AND NOT FIT FOR PURPOSE. The outcomes of such all inclusive modelling MUST be communicated to the developers of other sites connecting to the same system(s).
  • Parcel is deemed to be at risk from reservoir failure. There is a smaller developable area inside the parcel which is outside the modelled flood extents.
  • The rivers Beult and Bewl are confused again. Each have vastly different flow characteristics.
  • Flood risk is increased off site and elsewhere as a result of the proposal.
  • Development of the parcel potentially compromises expansion of the existing Paddock Wood Wastewater Treatment Works.
  • Flood risk in parcel 6 CANNOT be reduced by bringing forward development of parcel 1. There is a railway and town centre in the way. The defence mentioned is therefore irrelevant (north east corner of parcel 1). This will possibly only protect Bramley Gardens from the parcel 1 runoff.
  • Additional drainage channels have been added into the modelling, over and above those which are currently present on site. No information is given on these, or who will maintain them.

Parcel 7: Although this area can become very wet, it is largely south of the flood zones 2/3 and would make sense to build out this way if Church Farm development is to go ahead. However, there are still problems with surface water drainage and consideration of housing density would be needed. It would be important not to lose the character of existing rural communities/heritage sites, so development would need to complement these and not encroach on them.

In addition, land should be identified within this parcel for a new trunk sewer – it is uncertain whether Southern Water are taking this development into account in their modelling/long term financial planning.

SFRA –

  • Parcel is within the UMIDB Internal Drainage District and there is no evidence of input from the UMIDB. Discharge from Mascalls Court Farm and Church Farm comes in further up the same system. There is also a large angling lake in the parcel that has not been considered. The Modelling outputs are therefore unsound.
  • Flood waters are acknowledged as being pushed off site by the parcel development, but where to is not given. This is an increase in flood risk elsewhere, most certainly to existing residents. Lucks Lane and Five Furlongs Park are the main recipients.
  • Development of the parcel is potentially detrimental to the safety of railway infrastructure. No consultation or mention of interaction with Network Rail is stated.
  • The parcel is NOT influenced by the River Beult in any way. This assertion is incorrect.
  • Significant increase in flood depths stated as a result of the parcel development. This is an unacceptable increase in flood risk. Increases in flood depths quoted are also close to existing dwellings.
  • Modelled flood depths increase around the perimeter of the parcel with development included – stated in the parcel analysis.
  • Flood depth reduction in the centre of Paddock Wood will not reduce the depth of flooding in parcel 7.
  • How will strategic storage reduce flooding caused any development of parcel 7, especially as the strategic storage has not been defined in the parcel analysis?
  • Developments at Mascalls Farm and Church Farm have not been considered here, so how can it be confirmed that development of parcel 7 will reduce flood risk/create betterment in terms of flood risk to existing residents as a result of developing parcel 7?

Parcel 8: This should become a green buffer zone along the road to provide a green boundary to the town and protect hamlets and the ancient farmstead at the lower edge of this site along Pearsons Green Road.

Parcel 9:

SFRA –

  • Surface water and flood discharge from the parcel increases flood risk – with no additional development in the parcel included.
  • The parcel must discharge through the Rhoden system, but no outflows from the Mascalls Court Farm or the Church Farm development have been considered in the flood modelling for parcel 9 on its own merits.
  • Existing areas of the site are affected by the 0.1% AEP event.
  • No consideration of extant planning consent to the west of the parcel (Mascalls Court Farm) included in the modelling or consideration of the parcel.
  • “There have been no specific flood instances reported from other sources within the parcel boundary” – really? Worth checking against PWTC records.
  • Parcel is affected by a rarer but greater magnitude event than a 0.1 AEP event BEFORE any development is considered.
  • “Parcel drainage arrangements should be developed so that exceedance pathways are designed into the development form enhancing management of flood water.” This is not correct. How will Dimmock Close/Ballard Way/Le Temple Road be affected by such pathways? They should receive betterment from any development.
  • Surrounding areas are acknowledged as being at increased flood risk as a result of development of this parcel.
  • Development of the parcel will not result in betterment for existing residents.
  • Use of the Beult data and not the Bewl data undermines the whole modelling process for this parcel and indeed the SRFRA 1 and 2 reports.
  • No consideration of permitted developments or existing residents have been considered when modelling the parcel for acceptability for development.
  • Infiltration SuDS are not a feasible option in a clay geology such as Paddock Wood.

Parcel 10: Not submitted in call for sites – currently used as a sports field and is unusable during episodes of wet weather – unplayable for most of season 2017/18 due to water logging. Below road level along road side

Parcel 11: This is a long way from the Town Centre, has a small collection of historic buildings and poor roads which would make it unsuitable for increased traffic.

SFRA –

  • Drainage of the site totally dependent upon Kent Highways keeping a culvert clear and in good order. Outside the remit of the parcel developer. No input from Kent Highways evident in the parcel analysis.
  • No consideration of the discharge effects from the parcel of those downstream. Flood risk to existing residents is thus increased. No consideration of existing permitted developments and cumulative effects of the proposed parcel have been considered.
  • Residual risk of flooding for areas immediately outside of the parcel have not been considered.
  • No appreciation of the downstream effects upon residents of Ballard Way/Dimmock Close/Le Temple Road undertaken. The mitigation measures for Church Farm do not include any consideration of the outflows from parcel 11 and so cannot be relied upon. They have not even been modelled.

Parcel 12:

SFRA –

  • No consideration undertaken of the effects of any outflows upon the downstream mitigation measures already permitted by TWBC. This parcel outflows potentially may overwhelm such measures. No consideration given by the modelling undertaken by TWBC.
  • No confirmation given that development of the parcel will reduce any flood risk downstream of the same parcel.

DLP_4119

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

Please see the response to AL/CA3/PW1 submitted by CPRE Kent’s Head Office [see DLP_1778].

DLP_4229

Maple Planning & Development for The Exall Family

 

On behalf of my clients, the Exall family, I write to detail their representations in respect of the above referred matter.

The Exall family own the extent of land as detailed on the attached plan. It represents the north-eastern corner plot of ‘Parcel 4’, which is itself a constituent part of the wider allocation as set out at Policy AL/PW1.

The wider policy designation promotes a comprehensive mixed use development for Paddock Wood, encompassing approximately 4,000 dwellings, employment provision, an enlarged secondary school and new primary schools, a new medical centre, and sports, recreation and play facilities.

Parcel 4 of that wider allocation is located to the north-west of the town, immediately to the west of Eastlands Estate (which is where, amongst other commercial occupiers, Baxall Construction are based), to the west of the houses on Maidstone Road and Nursery Road, and to the north of the commercial units on Eldon Way.

Beyond established field boundaries – comprised of a track along the northern boundary, and Tudeley Brook along the western boundary - open countryside bounds Parcel 4 to the north and west.

Table 4 ‘Table Showing Parcels of Land’ states, in relation to Parcel 4:

Sensitivity assessment indicates capacity for housing and small scale commercial and economic development.

In relation to the issue of highways and access, Table 4 goes on to suggest:

  • Consider potential for vehicular access to the site through Nursery Road.
  • Main access from Maidstone Road.
  • Junction improvements needed at Maidstone Road in NE corner.

The Exall family are supportive of both the wider aspirations for the growth of Paddock Wood, and the identification/allocation of Parcel 4 as part of that allocation.

In advancing any such allocation, of course, it is though necessary to consider each potential site against the tests of suitability, availability and deliverability. These shall be considered in turn as follows:

  1. Suitability – The site is an edge of settlement location, bound by existing built form to the east and south. The land is well contained by existing field boundaries to the north and west, meaning that it is self-contained, and not sensitive in terms of wider landscape and visual impact. The railway station, employment opportunities, town centre shops and services, various bus links, and the Paddock Wood Primary Academy are all located within a very short walking distance. The site is sustainably located, and not sensitive or subject to restrictive policy designations. It is suitable for development.
  2. Availability – The parcel of land as detailed on the attached plan is in single ownership, and the Exall family are committed to working with the owners of land to the west and south (together comprising Parcel 4), who are also understood to be promoting allocation. The site is available for development.
  3. Deliverability – The site is unencumbered by any physical constraints to the delivery of development. It is a largely level site, historically used as a brickworks, and subsequently used as a builders yard/for open storage since 1964. It is understood to be free from contamination. The access at the north-eastern corner of the parcel (and therefore improvements to that access) are within the control of the Exall family. There is no reason why, following allocation, development of the parcel could not be realised within the early years of the Local Plan period – making a valuable contribution towards short term housing and / or employment supply.

In terms of the detail and logistics of the allocation of Parcel 4, it is noted, as indicated above, that there is an aspiration for the development to incorporate junction improvements at Maidstone Road in the north-eastern corner.

Clearly those junction improvements would come at a cost, and would serve to benefit the entirety of Parcel 4 – not just the first part of the allocation that would ultimately be delivered, and which might encompass the physical act of providing for those junction improvements.

It is therefore critical that the cost of any such junction improvements – together with any other infrastructure costs associated with delivery of the wider site allocation – are shared in an equitable manner between the constituent parts of Parcel 4.

Going forward, therefore, it is respectfully suggested that Policy AL/PW1 be amended/expanded to provide greater clarity in this regard, in order to give greater commitment that no individual landowner shall be unduly burdened by infrastructure costs, but that – instead – those costs will be shared in an equitable manner between all parties that would benefit from said infrastructure.

The mechanism for ensuring this proper sharing of infrastructure costs should be set out within the policy, or in an associated Supplementary Planning Document.

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

DLP_4424

Lambert & Foster LLP for Mr Steven Sault

Support

Paragraph Number 5.65 and Policy AL/PW 1

Commercial allocation appropriate.

Engineering and constructional detailing can be addressed relative to specific site criteria. Example of such engineering can be seen at the East Peckham commercial development betwixt the Medway and the filling station.

No new commercial allocations in Paddock Wood since the mid-1980’s.

Proven need, particularly for medium-sized and small business units.

Potential for Local Plan to incorporate live-work units in part of allocation.

DLP_4481

Paddock Wood Neighbourhood Plan Steering Group

 

Could noise/green buffers be considered for the whole area?  The Neighbourhood Plan group has proposed green wedges to be used throughout.

There is a national shortage of GPs, impacting on practices across West Kent at the current time, with additional problems recruiting practice nurses.  Doubling the size of the town will require another GP practice with 6 or more GPs and it is unclear where these will be recruited from.  Similarly, hospitals would need to expand to accommodate a significant expansion in local population.  There is no quick fix to the recruitment of healthcare staff, as a GP takes more than 8 years to train & numbers entering the training are falling.

There is an ageing population, but no apparent inclusion of additional adult social care provision e,g. residential care and nursing homes.  There almost no facilities for elderly residents requiring residential and nursing care in the town and those people requiring nursing care have to be accommodated outside the town, separating them from family.

There are inadequate sports and recreation facilities, with proposals addressed by the Neighbourhood Plan, some of which have been included in the draft plan.  The outdoor sports hub should be included within the boundary of Paddock Wood, in the area north of the railway which is be less suitable for housing as much of the area is in flood zone 3.  The area will need to be sufficiently sized to accommodate the pitches listed in the PWN Plan policy S&R 1, with additional space for expansion.  This is due to the current list of pitches being what would be required for the increase related to Mascalls Farm, Mascalls Court Farm and Church Farm developments.  A further expansion in housing would require an increase in pitch numbers and thus space requirements, estimated to be about 50% increase in current proposals.  Site 316 is the only area big enough for this.

The Sports & Recreation group welcome the proposed increase in walking and cycling for transport & recreation

Increase in youth facilities are also welcomed and the S&R group would like to see a youth hub to provide sports and recreation facilities in a designated area, with the aim of reducing antisocial behaviour in the town and increasing opportunities for young people to get involved in sport, recreation and the community.

We would like to see more explicit detail about youth facilities with items such as an outdoor camp site and climbing wall, which are included in the Neighbourhood Plan The approach to recreation should be a lifespan approach recognising that recreational facilities are essential to good mental health for all age groups

The NP group welcomes the recommendations for an enlarged Mascalls Secondary school and for additional primary schools as demand for places is expected to increase as new homes from the three larger consented developments are delivered, leading to a deficit of primary provision.

In relation to specific parcels -

Parcel 1: Whetsted Woods should be retained, as this area needs all the trees it can get to soak up the water.

There is a need to retain an attractive view of the town as visitors enter from the west.  The Eastlands track running in this parcel and #3 and 4, should be upgraded to at least B road status – this is to relieve traffic that would otherwise run through town. Access from Maidstone Road, Paddock Wood should not be an option as this simply encourages more traffic through the single main road in the town. The public rights of way/cycle routes should link to the town centre, not the existing houses.

Parcel 2: Whetsted Woods should be retained, as this area needs all the trees it can get to soak up the water.

Parcel 3: Parcel 316 is allocated in the draft Neighbourhood Plan for an outdoor sports hub to accommodate all four football clubs, the rugby club and potentially tennis, netball and cricket. The area will need to be sufficiently sized to accommodate the pitches listed in the PWN Plan policy S&R 1, with additional space for expansion.  This is due to the current list of pitches being what would be required for the increase related to Mascalls Farm, Mascalls Court Farm and Church Farm developments.  A further expansion in housing would require an increase in pitch numbers and thus space requirements, estimated to be about 50% increase in current proposals.  Site 316 is the only area big enough for this.

Parcel 4:  The NP plan for the Outdoor Sports Hub suggests allowing access to it from the Whetsted Road.

Parcel 5:  Footpaths should be maintained and the rural communities of Lucks Lane, with listed buildings, have a character that would be lost from over development of this area.  Lucks Lane itself is not suitable for increased traffic movement and would need considerable work to widen and strengthen the carriageway if traffic was to increase in this area.

Parcel 6: consideration must be given to safeguarding the rural character of the hamlets here – there is already considerable loss of character from building large farm/storage buildings close to these hamlets/listed buildings.  Road access to this site would be difficult without a new road.

Parcel 7: It would be important not to lose the character of existing rural communities/heritage sites, so development would need to complement these and not encroach on them.

In addition, land should be identified within this parcel for a new trunk sewer – it is uncertain whether Southern Water are taking this development into account in their modelling/long term financial planning.

Parcel 8:  This should become a green buffer zone along the road to provide a green boundary to the town and protect hamlets and the ancient farmstead at the lower edge of this site along Pearsons Green Road.

Parcel 11: This is a long way from the Town Centre, has a small collection of historic buildings and poor roads which would make it unsuitable for increased traffic.

DLP_4678

CBRE Ltd for Dandara Ltd

 

Badsell Farm, Paddock Wood

4.8 The site is c.45 hectares and is contiguous with the western edge of the settlement of Paddock Wood. It is bound to the east by existing residential areas, to the south by Badsell Road, to the west by the A228 and to the north by an existing railway line in part (nearest the settlement to the east), and existing hedgerows. A Site Location Plan is provided in Figure 2 below.

[TWBC: for Figure 2 see page 15 of full representation].

4.9 The site, which Dandara refers to as Badsell Farm, forms part of a wider parcel of land and Draft Local Plan site allocation, known as ‘Land at Capel and Paddock Wood’ (Policy AL/CA 3), as shown in Figure 3 below. The site comprises the majority of land parcel ‘PW1_1’. The north-west section of PW 1_1 does not form part of Dandara’s land interest.

4.10 The wider allocation is to be a key source of housing supply and is expected to provide 4,000 new dwellings, employment and associated education, leisure and health facilities. This is anticipated to involve the release of the Badsell Farm site from the Green Belt.

4.11 In respect of the AL/CA 3 development parcels identified in Figure 3 below, parcels PW1_1 – PW1_3 are all proposed to be released from the Metropolitan Green Belt as currently shown on TWBC’s Local Plan 2006 adopted Proposals Map.

4.12 Land at Capel and Paddock Wood (comprising all sites in allocation AL/PW1 and AL/CA3) was assessed as part of the Strategic Housing and Economic Land Availability Assessment (‘SHELAA’) in July 2019. The assessment references the exceptional circumstances test in terms of releasing land from the Green Belt. The exceptional circumstances case, as set out in Distribution of Development Topic Paper for Draft Local Plan Regulation 18 Consultation (September 2019) relates to provision of strategic development opportunities; delivery of housing in a sustainable location, infrastructure led improvements and flooding betterment associated with flood risk mitigation measures. Dandara supports these reasons, but highlights that TWBC will need to ensure they have a full and robust case and supporting evidence base.

4.13 In order to ensure that the site allocation is in accordance with paragraph 35 of the NPPF, which sets out the tests of soundness (positively prepared, justified, effective and consistent with national policy) Dandara has provided the following policy comments in relation to this site.

Draft Local Plan Policy AL/PW1 ‘Land at Capel and Paddock Wood’- Dandara notes the following:

4.57 Dandara’s comments on the strategic approach to growth at Paddock Wood are set out above. This section specifically addresses Dandara’s comments in relation to Policy AL/PW1.

4.58 It has been demonstrated that the Badsell Farm site can be delivered in the short to medium term with commencement from 2023/24 (within the five years of the Plan adoption), is not reliant on the delivery of other sites within the wider allocation and has very different timescales for delivery compared to Tudeley Village.

4.59 The expansion of Paddock Wood should take advantage of the town’s sustainable location. The site is located on the periphery of the town, in close proximity to the town centre and benefits from existing infrastructure connections with moderate public transport access. The site is therefore a suitable location for Green Belt release as part of facilitating new strategic growth in accordance with Paragraph 138 of the NPPF.

4.60 In respect of the requirement for an infrastructure plan to be prepared, as detailed above Dandara suggests the delivery of infrastructure at Paddock Wood and Tudeley Village should not be linked, and separate infrastructure plans should be prepared that are site specific but coordinated, to the extent necessary reflecting the timescales associated with the different allocations.

4.61 Furthermore, Paddock Wood should not have to rely on any strategic improvements to be delivered at Tudeley Village or vice versa. This is to reflect the different anticipated timescales for delivery, and particularly the complexity of unlocking Tudeley Village, which will require significant infrastructure investment over longer timeframes compared to Paddock Wood, which benefits from its sustainable location and good existing infrastructure connections.  We have described elsewhere within these representations the risk of delay and fettering of each other’s growth potential, and how this could be mitigated.

4.62 In terms of Paddock Wood itself, it is suggested that TWBC modify the wording of Policy AL/PW1 to introduce greater flexibility to enable land parcels within the allocation to come forward separately if parts of the allocation are delayed. The suggested approach of an overarching Framework will ensure that if this happens, each land parcel could come forward and be consistent with infrastructure, phasing and development principles that collectively will ensure comprehensive development. This approach will ensure housing is delivered at the rate the Local Plan and in doing so will add to the resilience and deliverability of the strategy over the Plan period in accordance with the Local Plan soundness tests as set out under paragraph 35 of the NPPF.

4.63 Dandara will work collaboratively with stakeholders and the Developer Forum to support the expansion of Paddock Wood, and to help prepare the overarching Framework which will facilitate growth and allow individual sites to come forward