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Section 5: Place Shaping Policies Pembury


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

Contents

General comments

Comment No.

Name/Organisation

Response

DLP_385

Mr Terry Cload

STR/PE 1

I support the MGB and LBD boundaries for Pembury.

DLP_518

Mr Neil Franklin

“Transport -buses” – the information is mostly wrong

“Retail” – shops are hardly numerous

“Recreational facilities” – two long distance walking routes pass through Pembury parish and need to be preserved or improved (without worsening their character):  the High Weald Landscape Trail and the Tunbridge Wells Circular.

DLP_1442

Pembury Society

THE PEMBURY SOCIETY’S RESPONSE to the DRAFT LOCAL PLAN

Before considering individual points of concern raised by the Draft document we would like to say that, from a straw poll of Pembury Society members, it is apparent that the over-riding concern is INFRASTRUCTURE, or rather the apparent lack of provision for improving the existing infrastructure to a standard necessary to absorb the large increase in population that is envisaged if the plans are adopted. Their second concern is the type of housing that is being considered. The issue of infrastructure is briefly mentioned by reference to 106 contributions, but there is no real substance nor commitment to ensure that all necessary infrastructure will be of an adequate standard before any building is commenced.  The main issue for Pembury is the 300 new houses for the village but there is no indication as to what type of housing is envisaged. These two important issues make any further discussion of the proposals purely academic.

By infrastructure we mean, at the very least, not only highways but also all utilities, primary healthcare and education. We cannot overemphasise the importance of planning for these before any building is undertaken if the lives of existing residents are not to be disrupted in the long term. One consideration of planning applications is to ensure that existing residents are not adversely affected if the development is allowed and this must be taken seriously.

If the required improvement in infrastructure is put in place before any building is considered the residents of Pembury would probably, if reluctantly, accept 300 new houses in the village provided they are the type of housing that is deemed suitable. The perceived need is for housing that is suitable for first-time buyers and, at the other end of the scale, for those who are trying to down-size from large family homes but want to stay in the area. In order to help first-time buyers, it is essential that the 40% ‘affordable’, that is mentioned in the Draft, is adhered to without exception. The people of Pembury do not see a need for executive housing that just gives developers large profits. Also, if older people are able to downsize the larger, executive style, properties will automatically be released onto the market.

[TWBC: see site-specific comments - Comment Numbers DLP_1444-1447, 1449, 1451-1453].

In conclusion, this Draft document presents as a good desk-top exercise to satisfy Westminster but does not show any sensitivity to local conditions. It suggests sites for new housing in sufficient numbers as required, regardless of whether or not those sites have suitable access and does not even begin to consider the necessary improvements to the existing infrastructure that would be required if these proposed building plans were to be implemented. If it is implemented in its entirety it will be seriously detrimental to the lives of current residents of Pembury.

It will also affect everyone in the wider area who needs to access the hospital, both staff and patients, unless proper attention is given to the highway situation at Woodsgate and along the Pembury Rd.

DLP_4319

Kember Loudon Williams for Kent College Pembury

Proposals Map

We represent Kent College, Pembury and who are part of the Methodist Independent Schools Trust. The college is based on a site within the Metropolitan Green Belt.

Kent College is an all girls school which caters for students from early years through to sixth form. (ages 3 to 18). It is an independent school, including boarding, catering for over 500 students. It is located just to the north of Pembury and the A228 off Old Church Road. The site comprises a significant number of school buildings surrounding a Victorian Mansion House, including classrooms, sixth form centre, library, swimming pool, studios and school playing facilities including tennis courts and an all weather pitches. The school is extremely successful and a valued organisation locally employing 234 individuals.

Within the Adopted Local Plan 2006 the Kent College, Pembury site had been identified under Policy MGB2 as a ‘major developed site within the Metropolitan Green Belt’. This policy identified previously developed land as locations where limited infilling or complete and / or partial redevelopment was considered acceptable. The policy defined a boundary within which this type of development was considered appropriate.

Policy MGB2 included a variety of criteria to enable planning applications to be judged and these included:

Seeking to ensure that new development did not adversely impact on the openness or visual amenity of the Metropolitan Green Belt; did not exceed the height of any existing buildings; did not result in a major increase in the developed parts of the defined area; and sought a similar footprint to the buildings to be replaced unless there were other benefits such as a reduction in height.

The Draft Local Plan (Regulation 18 Consultation Draft) 2019 does not include a similar Policy. Draft Policy STR4 sets out a protectionist stance towards the Green belt unless land is released by other planning policies for the purposes of development. Draft Policy STR4 refers to the National Planning Policy Framework and explains that this will be used when determining proposals affecting the Metropolitan Green Belt.

The National Planning Policy Framework (NPPF) includes a variety of planning policy paragraphs concerned with protecting the Green Belt. New buildings are considered to be inappropriate forms of development within the Green Belt. However, Paragraph 145 sets out the exceptions to this policy approach. Those relevant to Kent College, Pembury are:  Criterion b) provides for an exception if the building is for outdoor sport or recreation which does not harm openness. Criterion c) allows the extension or alteration of a building provided it does not result in disproportionate additions over and above the size of the original building. Criterion d) allows the replacement of buildings where they are in the same use and not materially larger and criterion g) which allows limited infilling, partial or complete redevelopment of previously developed land (excluding temporary buildings) provided they would not have a greater impact on the openness of the Green Belt than the existing.

The Council appear to be content to allow the NPPF to guide future proposals and this seems to be the reason for not including a policy similar to MGB2 in the adopted Local Plan. However, Kent College, Pembury feel that this is not an appropriate policy approach for a number of reasons.

Firstly, paragraph 145 contains a variety of policy advice ranging from extensions and alterations that are not disproportionate, replacements which are not materially larger and limited infilling which has no greater impact on openness. The criteria mean slightly different things and for a large organisation like Kent College, Pembury it would be important for them to be able to understand the approach the Council would take to these different criteria.

Secondly, it is important for Kent College, Pembury to understand the boundary of the previously developed land that is referenced in the NPPF. They need to understand its extent and want to be assured that the master plan which they prepared several years ago, and which the Council has used in recent planning applications, remains relevant. Often it is important for those funding the new development to have certainty that the site is consistent with the various policy sections of paragraph 145.

As a result, Kent College, Pembury are seeking the inclusion of a new policy or an adjunct to Policy STR4 to list those sites which are considered to fall within the advice of paragraph 145 of NPPF, together with a set of criteria to help provide guidance for new development and a Plan identifying the extent of the previously developed part of the site. The NPPF does not prevent or guide against such an approach and it remains within the gift of the Council to include such a policy. Given the status of the school and many other similar sites, it would be important to have a clear and unambiguous policy approach.

In relation to the last matter we note that the on-line Proposals Map for Policy MGB2 is not accurate and a new assessment of the previously developed land area must be undertaken. We note that some temporary buildings and classrooms have been on site for many decades and our initial review suggests that some of these portacabin classrooms to the northwest of the site have existed for over 25 years but without any recent planning permission. Location plan 502/Location B submitted under application TW/05/00604/FUL identifies these buildings. Consequently, the previously developed land boundary ought to reflect a slightly larger area than is currently shown.

DLP_5791

Hugh Boorman

Please find enclosed my comments to the Draft Local Plan for Pembury and I have to say that I am somewhat astonished by some of the inaccuracies in the document. I also have to add that nowhere near enough time has been given to many of the residents to get their heads around the details in the document bearing in mind that many of them are quite elderly and were totally unaware of this document and the importance of filling it in and returning it.

I have sent this reduced version to some of my friends who did not know it even existed and I therefore suggest that the deadline for returns should be extended until January 2nd 2020 otherwise the number of returns will be that low that the authorities will think the people of Pembury do not careless what happens.

I would also like to point out some minor issues that , and I mean this with the utmost of respect that not a lot of research was put into this project and was possibly from historical information. Let me list some of these before enter my main objections and concerns

1, Churches, you list 3 when in fact there are 4. Pembury Old Church down by the Kent College, St Peters at the top of the village, The Roman Catholic Church adjacent to the Village Green and the Free Church, Romford Road",

2, Public Houses. 2 are listed when in fact there are 3. The Camden Arms and the Blackhorse in the High Street and the King William in the Hastings Road.

3, The Parish Office is listed as being in Woodside Road when in fact it has been in the Recreation ground in Lower Green Road for many years , the new one being opened in 2012.

4, HawkenBury Sports Hub is mentioned , what on earth for?

5, Improvements to the Allotments is mentioned several times, what improvements, please list them and I mean this respectfully, when ?

6, Colts |Hill Link? Where is it being linked to if the intention is to relieve the traffic congestion into and from Pembury at Woodsgate and Beyond.

7, The impact of additional traffic anywhere on Henwood Green Road will be catastrophic especially with the proposed development on Map91 Policy AL/PE 5, which will result in more traffic coming onto the road opposite Canterbury Road which is already a traffic hazard for local residents and pedestrians with many residents having to park on the pavements. That stretch of Henwood Green Road, like many other parts is already a stop start situation.

8, Could you please explain what the Public Realm is at the Centre of Pembury and what are the intended improvements.

9, There are several mentions of traffic calming. There are several stretches of Highway in Pembury where Traffic Calming is natural because of the natural slowing down of traffic due to the restrictions of normal traffic, parked or otherwise. Concentration should be given to Lower Green Road from the Recreation Ground down past Pembury School to Downingbury Farm where it should be reduced to 25mph and also through the High Street and the Hastings Road.

10, MAP87 Policy AL/PE 1 I cannot believe that the intention is to bring traffic in and out of the High Street , opposite a large Old Peoples home, alongside the Village Hall and an area where traffic parking where traffic parking can be an issue.

11 MAP90 Policy AL/PE 4. With the utmost of respect the comments printed on Page 333 tell me that no one has visited Church Road to experience the chaos that would be introduced to this road with the introduction of additional traffic, not only that of new residents but that of visiting vehicles. You really do need to reassess this proposed site and access.

12,MAP93 Policy AL/PE 7 This application should have been rejected and the whole thing has raised certain queries as to its background and possible support. It does not need a written explanation as to why it should be rejected.

a, The surrounding road network to and from Pembury, Tunbridge Wells and Paddock Wood area has been a nightmare for some years and yet here we are seeking to introduce more traffic not counting the additional traffic which will develop if the local plan is actioned.

b, Should it go ahead it will involve possibly an additional eighty to one hundred Hendy Staff Cars coming from all directions onto the. site each end of the day.

c, Customer vehicles making four journeys each day to and from site. ie, Customer brings car to site first thing in the morning and gets picked up only to repeat the same journey, same day in the evening to pick the car up .

d, Car recovery vehicles.

e, Parts delivery vehicles.

f, Other company parts collection vehicles.

g, Waste collection vehicles.

I, We are all involved in Environmental issues and air quality and yet here we are proposing the addition of hundreds more vehicles and their exhaust emissions on what is a very busy School route to and from Pembury, with many pupils walking or cycling and the intention is to make it worse, and that is not taking into account the vehicle numbers which will increase due to the local plan if it develops as intended.

I think all of these issues need a serious rethink instead of just plucking the answers to a problem out of thin air

Please accept this presentation of my response to the local plan and if I have offended anyone please accept my apologies. I will hopefully send to you this week my attempt at filling in the forms that were sent to me but on behalf of the residents of Pembury please give them extra time to absorb the contents and the importance of this plan.

Policy STR/PE 1: The Strategy for Pembury Parish

Comment No.

Name/Organisation

Response

DLP_217

Tony Nicholls

My concern is for the overloading of our ancient sewers, and I write about this as someone who has had over capacity sewers spew raw sewage into my garden over the last few years.  The majority of the new build will be just behind the High Street and Hastings Road. This is the highest part of the village, along a natural ridge. Most of the sewers run eastward, downhill toward the sewage treatment works just off the Maidstone Road near the Hawkwell Business Centre. These sewers have been in place for decades, many from Victorian days, and have been fed by all new developments.  Many are overloaded and have tree routes restricting their flow capacity. In times of severe rain the sewers also take a lot of surface water and burst at known inspection chambers causing raw sewage to flood into gardens for sometimes several hours.

My argument is for new sewers or greater capacity sewers to handle the local plan requirements. The problem is location. Imagine a new house behind Hastings Road feeding into its new sewer, which in turn feeds into an existing sewer in Hastings Road which then feeds into a network of old sewers down Belfield Road, then Henwood Green Road, to the south of Heskett Park, Romford Road, all the way down the the Water Treatment Works at Maidstone Road.  The troubled areas are way downstream where the sewers get accumulated feeds from any new houses higher up the hill.  This will is unlikely to be given any consideration by the developers of the new local plan houses. It is a TWBC issue as a part of the village's physical infrastructure, and it was noticeable that the TWBC Local Plan exhibition at the Pembury Parish Hall did not include sewers as an infrastructure issue.

We cannot tolerate such large residential development on high ground without considering the consequences of more sewage spills downstream.

My personal experiences are documented here [TWBC: web address redacted at consultee's request] and I am in regular contact with Southern Water to ensure they inspect my sewer line every 6 months.  I have previously involved local councillors and TWBC Planning Dept over the existing sewer infrastructure, and I intend to bring it to the attention of the folk running the Local Plan for the appropriate consideration.

Attached is a map showing the topographical contours of Pembury in the direction of the Water Treatment Works - the destination of all Pembury's sewers.

DLP_389

Karene Helen Bloxham

Firstly ….. .Your on line comment method is dreadful ! You can not copy and paste. thus preventing one from getting thought down properly and reading through ( in large type and making corrections and amendments then copying and pasting  into comment box

Also you “downloadable” form downloads but does not open ..I had to ring you for help but in the end used Google to find a way to down load.

We would like to object to Major Development in Pembury for the following reasons :

  • The basic infrastructure is wholly inadequate, Hastings road is currently potholed and breaking up, after construction traffic is added it would require major reconstruction.
  • There is already inadequate provision for parking and cars are often parked on both sides of the road (and often on the pavement as well!) rendering it difficult for traffic to pass, causing major traffic congestion every workday morning and evening.
  • The surface water drainage is inadequate and often after heavy rainfall there is localised flooding; more paved over areas will exacerbate this.
  • The local Water Supply Company is overstretched especially in the summer when it is not unusual to have hosepipe bans, this will only get worse with more development.
  • There is insufficient parking in the centre of the village for the present population and this will only become a much larger problem with additional people needing to use the post office (no parking at all now) Chemist etc.
  • The Doctors surgery has already said it cannot accommodate any further patients.
  • The village school is not big enough for the present size of population as many houses already built (some for nearly 100 years) are not in the catchment and have not been for over 30 years due to the numbers.
  • The Bus service is unreliable and expensive so accessing the towns of Tonbridge, Tunbridge Wells and Paddock Wood is very time consuming. The above explains why the busses are often empty, more people will therefore mean more cars trying to negotiate the Pembury Road etc.
  • In addition, Plot PE3, with its mature Kent Cob hedge bordering Hastings Road has an abundance of wildlife which would probably disappear with construction of houses. Wildlife observed over recent years include, badgers, foxes, field mice, rabbits, dozens of birds often nesting in the hedge, a tawny owl has also been spotted. Bats are regularly seen at dusk flying between 133 and 135 Hastings Road directly into the field. Sparrow Hawk and Buzzards are seen hovering overhead.
  • There is a Tree barrier already in place between the bypass and the field, but noise is still quite intrusive to the houses already in existence on the Hastings Road. the proposed development is even closer and will be subject to even greater noise making it unbearable for the occupants.

DLP_456

Mr Nick Sturcke

I have been  a resident of Kings Toll Road at the eastern end of Pembury for 32 years.

The above sites propose the addition of up to 279 new residential properties  close to the centre of Pembury Village, all of which will will need access via Hastings Road/Pembury High Street. They clearly contradict the enhancements listed in Policy STR/PE 1, 5; and should not be included in the Local Plan.

Pembury High Street and Hastings Road are the main west to east route through the village for pedestrians, cyclists, buses and other traffic. Vehicles are parked for much of the day along most of the length of Hastings Road already hindering the free movement of all traffic, including cycles and buses. There is insufficient space for effective cycle lanes along Hastings Road.

The addition of up to 279 properties, an increase in population of perhaps as many as 700, all of which will need access to Hastings Road and Pembury High Street, will result in bringing traffic on this route to a near standstill. The need for the traffic calming measures included in the Plan will be negated by the congestion caused by the additional traffic from the nearby new developments. In effect, traffic from the east end of Pembury Village will be reduced to accessing Tunbridge Wells and elsewhere by using the dangerous Henwood Green Road/A21 junction and travelling along the A21 via Kippings Cross where there are substantial on-going tail back problems which Highways  England are unwilling to address for the foreseeable future.

It will certainly be more difficult for cyclists to ride through the village as there is clearly no room for a dedicated cycle lane along Hastings Road/ Pembury High Street.

The proposed developments are in clear contradiction to the aspirations of the enhancements listed in Policy STR/PE 1, 5 and the measures to enhance bus travel included in the above individual sites. They should not be included in the Local Plan.

DLP_484

Alan Semple

These comments concern the proposed development of 300 houses in Pembury.

Before any development on this scale, the infrastructure needed to support it, i.e. extra resources for doctors, dentists, Pembury Primary School, Pembury Hospital, nurseries, etc. needs to be addressed and put in place BEFORE any planning consents are provided.

The proposed developments at Hastings Road (AL/PE2 and AL/PE3 90 dwellings each) will more than double the existing number of houses on this road. This is already a very crowded road, where, due to the considerable number of parked cars and the narrowness of the road in places, there are very limited areas where 2 lanes of traffic can pass each other safely and without difficulty. This problem will be significantly exacerbated by 180 extra houses whose vehicles will all have to use this road. There should therefore be plans to either widen the road and/or impose parking restrictions before any development commences.

There is provision for a Colts Hill bypass, but no mention of any improvements to the notoriously congested road (A264) from Pembury into Tunbridge Wells.

At the Hubbles Farm Land (AL/PE2) proposed development, there will be the destruction of Green Belt land in an Area of Outstanding Natural Beauty, leading to the loss of mature trees, wildlife habitat (French Partridges are seen on this site) and a very peaceful and pleasant area will be concreted over, with a considerable increase in noise pollution.

This site (AL/PE2) is also right next to 2 Telephone Relay Masts, which raises concerns about the possible health risks to people living underneath the masts, and the suitability of building on this site.

Finally, the proposed development at the Eastern end of Hastings Road (AL/PE3) would seem more justifiable, as this site is right on the road.

DLP_519

Mr Neil Franklin

The 300 houses proposed are too many for the parish.

If the problems of access and lack of adequate infrastructure (drainage, school places, doctor’s surgery capacity, High Street capacity, etc) could be overcome, then perhaps AL/PE1, 2 and 3 are less damaging sites than the alternatives, but any loss of green belt is unacceptable.  If any is lost, it should be replaced with land elsewhere in Pembury.  Solving the infrastructure’s shortcomings needs to be demonstrated before even thinking about extra development.  However, I am still against such a scale of development in Pembury due to:  loss of green belt, loss of an adequate buffer between Pembury and Tunbridge Wells and making the area much busier than it can cope with, with resultant loss of quality of life.

Should Pembury School’s intake be increased, life nearby (already overburdened with parked cars at certain times of the day) will become even worse.  Parking at or for the school needs addressing.

The centre of Pembury village needs public parking provision for people to use the shops, pubs and businesses if they are to thrive and this would be even more so with more people living here.  Off-street parking is needed for many of the houses already here.

Item 6   The proposed new A228 Colt’s Hill bypass takes up or blights too much pleasant countryside in the north of Pembury parish.  Any loss of countryside or woodland to new roads or road improvements must be minimal.

Item 7   The junction of the A21 and Hastings Road coming westbound into Pembury is a vital one but dangerous and needs action now – if the further development threatened by this plan does take place, then this will become an even more urgent requirement.  Any loss of countryside or woodland to new roads or road improvements must be minimal.

Contributions required:

c What is meant by “cultural infrastructure”?

d Hawkenbury is simply not easily accessible to Pembury residents. The Pembury Parish Council offices are not near Henwood Green Road

g Are these woodlands all public?

“windfall sites” must not be simply nodded through

DLP_1444

Pembury Society

OVERVIEW and STRATEGY for PEMBURY

1. We are pleased to note that the Plan acknowledges that Pembury is largely a Forested Plateau with farmland and that 90% of this is Green Belt and 89% AONB. Within this the built-up area is tightly defined and it is important to us that the village remains a village surrounded by countryside and development is not allowed to extend beyond the limit to build more than is absolutely necessary.

2. Highways are a big issue with the residents of Pembury.

We all know that the A228/A264 Pembury Rd into Tunbridge Wells has been working at overcapacity for years but there is great reluctance on the part of the authorities to do anything about it. Now is the time to deal with the problem once and for all. It is, therefore, our contention that no house building, or other development, should be allowed anywhere in the area, including Capel, Tudeley and Paddock Wood, until a satisfactory solution has been completed.

The application to build a Motor Village at Woodsgate has brought this issue to a head and it cannot be ignored any longer. Local knowledge and experience dictate that the extra traffic generated by this proposed Motor Village cannot be absorbed into the already over-stretched system and this is confirmed by the report from KCC Highways and that commissioned by Pembury Parish Council. How much worse will it be if 300 houses are built in Pembury and that is without all the building proposed for Capel and Paddock Wood? The proposed Colts Hill bypass is all very well but it will inevitably generate more traffic through the Woodsgate junction and unless improvements are made to that junction and the Pembury Rd the congestion there will only deteriorate further and this will exacerbate the problems already experienced by emergency ambulances trying to get to the hospital, with its large A&E and maternity departments.

3. The dualling of the A21 to Kippings Cross has created new traffic problems within the village. The narrow lanes between Pembury and Matfield are now being used as a ‘rat run’ because of the traffic jams at Kippings Cross. This situation will only get worse as Paddock Wood is extended and therefore a solution to the problem is needed now, and not left until everywhere becomes gridlocked and tempers flare.

4. We believe that 300 houses will generate a population of about 660. This is equivalent to an increase of about 10% on the existing population of the village and will, inevitably, have an impact on the two most important facilities in the village which are the Primary School and the GP surgery.

Even now Pembury School is over-subscribed, yet Pembury is a village and therefore it is a reasonable expectation for families who live here that the children should have access to their village school if that is what they want. Proper provision must be made for this increased demand from local children.

The GP surgery is also stretched to the limit and it is often difficult to get an appointment within a reasonable time. However, it would be required by law to absorb a further 72 elderly dementia patients if the Owlsnest application is allowed to proceed, even without the extra 660 patients generated by the proposed new housing.

It is unlikely that 106 contributions will do more than scratch the surface towards the cost of providing the necessary expansion of these facilities and, therefore, existing residents will suffer.

5. We do not believe that proper attention is currently being given to the objectives of the AONB management plan, so what guarantee is there that future applications will be properly considered?

6. Who is going to be responsible for maintaining the public rights of way? In rural areas this has always been a County matter but KCC have not maintained footpaths for several years now. Currently all footpath maintenance in Pembury is done by volunteers under the auspices of the Parish Council. We also note that in the Plot specific sections, PE2 in particular, there are mentions of cycle tracks to public rights of way that are in fact footpaths and not bridleways. This cannot be right.

7. We would also like to express our concerns about the other aspects of the infrastructure, namely the utilities:

a) Can the sewage system cope with 300 more houses? Houses built on the ridge at the highest point of the village may not have a problem, but residents in low-lying areas already have problems from time to time and this is likely to be exacerbated if the system is inadequate.

b) Will the water pressure be sufficient for all those houses on the ridge?

c) How robust is the electricity supply? Are we going return to the situation of 30 years ago when power cuts were both frequent and prolonged?

Attention needs to be given to all the utilities now. By the time there is proof that the systems are over-loaded it will be too late and we will all be suffering. This would go against the expectation that no development should adversely affect the lives of existing residents.

DLP_2111

Terry Everest

STR/PE1

This village is a very nice village set in the countryside and I call for a severe reduction in development plans here by at least 75%.

DLP_2743

John Duffy

Pembury cannot support the proposed numbers of new residential units without prior construction of infrastructure and implementable local services plans. This village already struggles to find places for local school children and the excellent GP surgery is extraordinarily pressured by the increasing demands placed upon it.

DLP_3348

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 - “Maintenance and enhancement of, and/or linkages to, public footway network and public rights of way and the local strategic cycle network in accordance with Policy TP 2: Transport Design and Accessibility. To include development of a segregated cycle route...”

Paragraph 7- “Measures to be taken to reduce the impact of proposed development on the local and strategic road networks at key links and junctions.”

Additional paragraph (i) - Public transport service and infrastructure improvements.

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

Public Rights of Way and Access Service

The specific reference to PRoW and Tunbridge Wells Circular route (paragraph 5) is supported. It is requested that PRoW enhancements are also included in the list of expected contributions, to mitigate the impact of future development.

DLP_4146

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

The development proposed in this strategy is a classic example of how the building of a bypass through an AONB and Green Belt leads eventually to further degradation of the AONB and Green Belt landscape through the infilling by development of land adjacent to the bypass.

CPRE objects to allocations PE 1, 2 and 3 as major development in the AONB which has not been adequately justified under NPPF paragraph 172.  However, if these allocations go ahead, CPRE would welcome the provision of a cycle link to Tunbridge Wells as proposed in these three allocation polices.  However, the wording on this needs to be strengthened so as to make sure this will be provided.  Chalket Lane ought to be a public bridleway, as it connects to a public bridleway, leading to the Hawkenbury area in Tunbridge Wells, which currently changes status at the parish boundary.

We are concerned that the part of this policy referring to developments larger than 100 residential units could encourage applications for major developments which are thoroughly unsuitable in the AONB.  Arguably, for sustainability, any development of more than 20 dwellings in villages and the rural area ought at least to provide some employment possibilities, for example through live/work units.

DLP_4445

James Whitehorn

a] There is no proven need for a further 294-304 new dwellings in Pembury. These proposals should not outweigh the merits of preserving the Green Belt and AONB especially on Site AL/PE 1 [Land rear of High Street and west of Chalket Lane] which is partly inside and more generally abutting the Conservation Area. The fact that the Chestnut Walk development was allowed on appeal should not afford an excuse to compound the problem with further development of this adjacent area of land.

b] With respect to the housing allocation for Pembury, the Housing Supply & Trajectory Topic Paper shows most of the new housing on sites AL/PE 1-4 occurring between 2023/24 and 2029/30. There is no evidence that we need so many new houses in the earlier part of the plan period. Instead of being concentrated in this 7 year period the new build should be spread over the whole plan period up to 2036. It would be more evenly distributed if, for example, site AL/PE 1 was postponed to around the year 2033/34. Table 9 shows the total housing trajectory for the borough with an average of over 1,000 new houses per annum between 2024/25 and 2026/27. This also suggests that the development of some sites should be postponed to later in the plan period.

c] With respect to Policy AL/PE 7 Woodsgate Corner, I have already submitted a detailed objection to the premature Planning Application by Hendy for car showrooms, primarily on highway grounds, subsequently endorsed by an objection from the Highway Authority. ‘Contributions to mitigate any impact that is considered to be severe' would not solve the inherent traffic problem with this policy. This land should be retained for a Park & Ride site as per the existing designation. The feasibility study by WSP suggests that Park & Ride is still a viable option which would reduce traffic on the A264 corridor, but car showrooms on this site would undoubtedly increase traffic.

DLP_4564

Historic England

Policy STR/PE 1: The Strategy for Pembury Parish et seq. - as with the foregoing comments, we would expect the allocation of sites following on from this Strategy policy to be subject to appropriately robust and detailed heritage impact assessment prior to the allocations being adopted.

DLP_5699

Mr Stuart Law

After seeing plans PE2 and PE3 which will both have a massive impact on my property I have decided that as I am retiring I would rather move elsewhere in Pembury where I won't have to endure the noise of the building works.

As such, I would like to propose that my plot of land be included in the proposed draft local plan.

Please find attached copies of PE2 and PE3 on which I have marked out my property in red.

DLP_5730

Stephen Roughton-Smith

I am submitting additional land as a site submission, being the garden of my property named on page 1. I enclose a photocopy of the land registry plan (Title No. K351832). Thank you.

DLP_6007

Katherine Wallwork

Preference is for housing development on the lower end of the range, allowing for lower visual impact on AONB than simply retention and improvement of existing hedges. Further tree planting along the southern edge of the site to act as a further screen, contribute towards the county-wide and nationwide increase in tree planting, helping to soak up rainfall and hold the ground of the southern edge of the site together.

Ensure that the appropriate level of affordable housing is adhered to.

Ensure that Pembury school and other local schools are suitable increased in size or new schools built to cater for the increase in child population. Ensure that the local GP surgery is expanded (upwards if necessary as no additional land available on current site). Ensure that improvements to sewerage services are carried out before any groundworks are commenced. Indeed, no building works should begin until all measures are in place to accept the new housing.

Improvements to cycle and pedestrian routes on the A21 dual carriageway need to be implemented.

DLP_6088

Pembury Parish Council

On behalf of Pembury Parish Council, I write to register its formal response to the Draft Local Plan ('The Plan').

As part of our considerations, we have consulted with local residents at a public meeting and invited them to complete a paper and online questionnaire covering the main issues emanating from The Plan as regards Pembury itself. Consequently, our response to The Plan reflects residents' main concerns and issues, as well as our own.

Strategy for Pembury Parish - Policy STR/PE1

1. Housing

We fundamentally object to the proposed target of 294-304 new dwellings, which we feel is excessive for our village. 90% of development falls within the Metropolitan Green Belt (MGB), which if lost cannot be replaced elsewhere within our parish. TWBC also do not propose to replace lost MGB elsewhere in the borough which we strongly object to. We do not accept that ‘Exceptional Circumstances’ exist to warrant loss of so much irreplaceable MGB.

89% of development within Pembury falls within the High Weald Area of Outstanding Natural Beauty (AONB) and is contrary to the aims of the AONB designation.

We would not want to see any significant number of houses being built without the essential Infrastructure being in place first.

For all of the allocated sites to be developed for housing, we would want Affordable Housing targets met (as indicated by TWBC) and conditions to ensure that those with a strong connection to Pembury are given a high priority.

We also object to the strategy for additional housing “through the redevelopment of appropriate sites and other windfall development in accordance with Policy STR1” being included in the strategy for Pembury. This would make the village vulnerable to unplanned development.

2. Infrastructure

Our overriding concern, shared by many residents, is that Pembury already suffers from an Infrastructure deficit, such that if some or all of the proposed sites were developed, Pembury would be unable to cope.

These are the main Infrastructure issues:

2.1. Roads and Traffic

We would remind you that in TWBC’s Core Strategy Site Allocations Local Plan (July 2016), policy TP4 states: “Proposals will be permitted provided (inter alia) the road hierarchy and the function of routes have adequate capacity to cater for the traffic generated, and the traffic generated by the proposal does not compromise the safe and free flow of traffic or the safe use of the road by others”.

Notwithstanding the proposed A228 Colts Hill relief road, and unspecified improvements to A21/A264 and A21/Hastings Road/Lower Green Road junctions, we remain concerned about the ability of the local road system to cope with the extra traffic generated by developments at Pembury, plus those proposed at Capel and Paddock Wood.

The Draft Local Plan for Capel and Paddock Wood includes the provision of over 6,000 new homes, employment, social and physical infrastructure (such as schools and health facilities) and retail development in Paddock Wood centre. These proposals will have very significant implications for transport along the A264, A228 corridor between Tunbridge Wells, Pembury and Paddock Wood. Additional homes in Pembury, focused behind the High Street and Hastings Road, will further exacerbate the problem.

The National Planning Policy Framework (NPPF) (February 2019) seeks to “promote sustainable transport and patterns of movements, streets, parking and other transport considerations are integral to the design of schemes and contribute to making high quality places” and the Parish Council does not believe that the Plan will deliver this requirement.

The A264 Pembury Road already suffers from severe traffic congestion at any time throughout the day, causing knock-on traffic problems for roads such as Pembury High Street, Cornford Lane and both the A21 and A228. It should be a pre-requisite that Pembury Road traffic congestion (with its associated pollution) is properly addressed before there are any new major developments in Pembury.

Extra traffic within Pembury will potentially impact on the safety of road users and pedestrians. We would like there to be well executed traffic calming measures, including speed restrictions by the Primary School.

We would dispute that there is capacity for the additional traffic generated by 300 new homes in this area. The existing road network currently compromises the safe and free flow of traffic and therefore the additional traffic movements caused by the new homes will only make the situation worse.

The junction of Hastings Road and the A21 at Bo Peep Corner is a notorious accident blackspot. Insufficient signage for the entrance at the junction may have played a part in the recent fatality after a road traffic accident. Speeding vehicles through the village are a regular occurrence. Additional houses here will compromise road safety to an unacceptable level.

Problems on the A21 inevitably lead to rat running through the country lanes in and around Pembury such as Kings Toll Road and Romford Road. The current problems experienced here will get significantly worse as a result of the proposed developments and mitigation must be put in place to address this problem.

The Development Constraints Study (p.15 Section 3.3) states that no evidence has been collated on how the highways capacity could impact on the development strategy. As such a large proportion of the proposed development is concentrated in the North East section of the borough, which includes Pembury, we believe that knowing the impact on the highways network, and planning for its mitigation, is of paramount importance. The Parish Council are surprised that this critical piece of evidence has not been undertaken before proposing over 6,000 new residential homes in the area.

We note that the proposed Colts Hill Bypass joins the existing A228 at the junction with Maidstone Road to the north of Pembury village. The cumulative effect of traffic generated from Colts Hill to the A21 from the large proposed developments in Capel and Paddock Wood and elsewhere needs to be modelled to show the impact on the A21 junctions and Woodsgate Corner before we can comment further.

The Parish Council is also concerned about the ability of ambulances to safely negotiate around congestion at Woodsgate Corner and the A21 slip roads with such significant amount of development proposed. The hospital has major Accident and Emergency and Trauma units for a wide geographical area and access must be maintained at all times.

2.2. Air Pollution

Most of the proposed housing will back on to A21 and be affected more with poor air quality than existing houses. It is also likely that increased traffic from the additional development in Pembury, Capel and Paddock Wood will lead to increased air pollution. Stationery traffic at Woodsgate Corner will also contribute to the problem. The Parish Council request that current base line air quality is assessed, particularly at Woodsgate Corner and along the A21, in order to monitor the air quality in future.

2.3. Parking

There is currently a dire shortage of on/off street car parking available within Pembury, which discourages people from being able to make use of various outlets so trade is affected. Any new housing developments should provide sufficient car parking for their new occupiers which should comply or, preferably, exceed the Kent Design Guide Interim Guidance Note 3. Car ports and car barns should be avoided. Pembury is a rural village and residents rely on their cars.

We would like to see additional parking created at the Village Hall and the Hospital as overspill parking from both sites currently creates significant problems on Pembury High Street and adjacent roads.

2.4. Medical Facilities

An inevitable consequence of so many extra households would be additional pressure on the already limited local medical resources. We hear complaints from residents about the difficulties of booking an appointment at present. Therefore, our G.P.s will need additional funding to extend their current surgery by 2 or 3 consultation rooms and associated additional staffing requirements.

The Hospital struggles to service West Kent’s swelling populace, demand may accelerate unsustainably when one factors in the effect of the Capel and Paddock Wood developments. Current waiting times are at unacceptable levels, with stories of patients already sleeping in the corridors when the hospital is under pressure.

The most recent Care Quality Commission (CQC) report published in March 2018 states that “from August 2016 to July 2017 the trust reported 364 “black breaches” (at Tunbridge Wells Hospital), with an upward trend over the period. A black breach is said to have occurred when the emergency department is unable to take over the care of a patient and release the ambulance crew to attend other jobs within 60 minutes of their arrival. It goes without saying that the hospital will require significant investment into the expansion to cope with the increased population.

2.5. Schooling

Pembury’s Primary School should be consulted to ensure they can cope with the growth in population proposed and that their needs are met. Any increase in pupil numbers will have a negative impact on road safety and parking and mitigation measures are required. The proximity of the school to the junction from Church Road onto Maidstone Road is also a concern especially if the proposed development (PE4) at Downingbury Farm is accessed via Church Road.

2.6. Public Transport

Local bus services are insufficient to encourage less car usage in a rural village, they need to be more frequent, with better services to run later into the evening. Existing services stop before 7pm Monday to Saturday and by 4pm on Sundays.

The Parish Council supports a workable Park & Ride solution for Tunbridge Wells, at Woodsgate Corner as per the current TWBC land allocations, which is a critical location on a radial route into the town centre.

2.7. Sewerage

We are concerned that the large number of houses planned for sites PE1, PE2 and PE3 could overstretch Pembury’s existing sewerage system which has already shown some signs of strain. An assessment of required capacity is essential prior to development commencing, and if there is a deficit in the current system this will need to be addressed.

2.8. Retail

The Sustainability Appraisal (p.94) refers to the "loss of a local supermarket” which is of significant concern to the Parish Council and Pembury residents. If this goes ahead, it will result in further car journeys inevitably using the Pembury High Street / A264 junction which is already very congested. Residents strongly supported keeping a supermarket at the Tesco site when answering the Parish Council’s questionnaire. Many elderly residents do not drive and need to walk to the shops. If the supermarket were to go, then provision of better public transport to alternative shops would be required.

2.9. Cycling

Pembury Parish Council object to the permanent cycle lane proposed along the High Street. If this is implemented, on-street car parking will be reduced and aggravate an existing problem which would be made worse with additional development.

2.10. Sport and Recreation

The Parish Council are particularly concerned at the suggestion that S106 contributions from Pembury would be diverted to the mooted Hawkenbury Sports Hub and other recreation and play areas on the site. Both the Parish Council and Pembury Athletic Youth Football Club (PAYFC) consider this site would be unreasonably difficult for Pembury children to access as it is located on the opposite side of Tunbridge Wells.

Please find attached comments from PAYFC (Appendix 1) which highlights the problems that would occur. Every route that children could use to travel to the sports hub and recreation grounds is notoriously congested. The A264 into Tunbridge Wells; Halls Hole Road; and Cornford Lane, which is a narrow, often single track, rural lane renowned as a rat-run, will only be made worse by the significant development proposed in this part of the borough. Therefore, contributions for sports and recreation provision for Pembury residents should focus on Pembury itself.

Current sport provision in Pembury is oversubscribed and it is vital that more is provided in Pembury to mitigate against the additional residents living in the village as a result of the proposed development.

2.11. Environmental issues

The Parish Council want TWBC to pay high regard to measures to mitigate against the Climate Emergency in their Local Plan. The NPPF requires that the planning system should “support the transition to a low carbon future” and “contribute to radical reductions in greenhouse gas emissions”. All development should be required to support this aim.

3. Section 106 Contributions

We completely support the principle of developers being required to mitigate the impact of their developments by making appropriate Section 106 contributions. The Parish Council consider that developers should be obliged to make a contribution rather than this be an expectation. We are also concerned that developers will try to avoid many contributions due to “lack of viability” which has been the case in the current planning application for the Sturgeon’s site (PE5).

As so much of the development is proposed in this part of the borough, Pembury Parish Council believe that the majority of S106 contributions should be focused here to mitigate against the development.

For such developments that might proceed within Pembury, we would particularly want to include the following as beneficiaries of Section 106 contributions:

3.1. Highways Improvements particularly at the A21 junctions, Woodgate Corner and Bo Peep Corner.

3.2. Primary School Education

3.3. Contribution for Secondary School education

3.4. Health and medical facilities

3.5. Provision of amenity/natural green spaces; children’s and youth play spaces within Pembury

3.6. Improvements to public woodlands within Pembury

3.7. Improvements to public transport provision

3.8. Improved sports and recreation facilities within Pembury.

[TWBC: see Pembury Parish Council's full response (including appendices referred to in this comment)]

5. In Conclusion

Whilst we understand that TWBC is in a difficult position trying to allocate sites to match arbitrary Government imposed targets for housing, we do not wish to see Pembury’s fragile infrastructure overwhelmed by an unsustainable, excessive allocation of housing.

We have objected to the significant loss of irreplaceable MGB that would be incurred should some of these developments proceed on the basis of the suggested allocations and consider it would be inappropriate development in the AONB.

We have significant concerns about the highways network’s ability to cope with increased traffic and the lack of strategic planning to mitigate against the proposed development in the Draft Local Plan.

Where any new housing is permitted, we would want the essential Infrastructure to be in place first, for issues such as density, access and egress, traffic etc to be fully considered. Wherever possible, the relevant sites should include public open spaces and the environment protected and enhanced (e.g. with landscaping and tree planting).

In order to address climate change issues, building plans need to include clear and definite ways in which developers build for the future. Renewable energy is a major issue and various heat sources need to be essential planning requirements, not just suggestions.

Pembury is still a clearly defined village; it would be an irreversible mistake to allow ill-considered developments (such as at Woodsgate) that would have the effect of Pembury losing its identity and becoming a suburb of Tunbridge Wells.

DLP_6258

Kember Loudon Williams for Mr R Barnes

Object

Site number 354: Stone Court Farm should also be allocated for development and as such the housing numbers should be increased to 350 dwellings in Pembury. (In order to avoid duplication please refer to Comment Box 9 which provides further details about the suitability, deliverability and availability of the Stone Court Farm site).

DLP_6652

Sarah Clarke

I make these comments as an individual, not the member of or representative of any organisation; as former Chairman of Pembury Parish Council and long term Pembury resident.

General

The local plan seeks to establish the allocation of housing for this village within the Borough for the immediate future.

It is unfortunate that the plans for Pembury appear in isolation from the plans for other areas of the Borough immediately adjacent to the village and the potential impact of those for the future.

The proposals are for Pembury’s population to be increased by potentially more than 10% based on at least 2 adults per household, (and associated car ownership) without taking into account the permissions already granted. The plan proposals are made with little consideration of the impact on the community, its infrastructure, amenities and services. Particularly the plan appears to ignore the impact on the infrastructure, particularly travel, of the plans for Paddock Wood and Tudeley and the very extensive increase in population.

As long ago as the 1950’s Pembury was already burdened with the increase in traffic. The A 21 was not able to cope with the level of congestion and eventually following a public inquiry the A21 bypass was built and the A228 was substantially improved. The later opening of the dual carriageway from Tonbridge to North Farm roundabout increased the traffic flow into Tunbridge Wells from Pembury along the A264 to the extent that a straightforward journey to and from Tunbridge Wells can now take at least 30 mins to cover a distance of 3 miles. There are no proposals to improve traffic flow now before adding to the substantial increase in vehicle use (of all kinds whether public, private or commercial). The plan is silent as to the impact on Pembury.

The local school is oversubscribed, the local medical practise is not able to turn away new residents and the local hospital, the Tunbridge Wells Hospital at Pembury, was built and planned on the basis of projected but limited population growth. In the past there have also been major issues over drainage, although Pembury does not suffer from flooding. Pembury had been a viable local community with stores, a butchers, bakers, greengrocers and other shops, most of which have failed to survive the opening of Tesco’s , access to which is from the roundabout connecting the A264 and the A21. There are no proposals in the local plan apart from a medical hub to address the local infrastructure issues.

Pembury has had the benefit of Green Belt designation surrounding the village envelope following the Structure Plan approval in 1984 and thereafter following the most recent local plan. It is now proposed that the Green Belt protection/designation should be varied without any guarantee for its future status. The comment from an official following the opening of the bypasses was “Pembury has got its bypasses; now it will have to pay for them”

The various proposals need to be considered within the context of the whole of the impact on the area.

Pembury is also in the High Weald area of outstanding natural beauty.

Conclusion

The local plan proposals will have a major impact on the village of Pembury and all its residents if approved. Whilst it is accepted that there needs to be provision of housing, attempts should be made to mitigate the impact of the proposals. The local infrastructure projects should form part of the whole plan, and not be left to be dealt with, piecemeal, after the event.

DLP_7070

Brown & Co Planning Ltd for The Hendy Group

Policy Number: Policy STR/PE 1 – The Strategy for Pembury Parish

Comments; Support with conditions

1.42 The Strategy for Pembury Parish should support the delivery of all of the allocated sites, including Site PE 7, in order to ensure that the summary objectives do not stifle growth or provide a brake on development.

AONB

1.43 The policy wording does not recognise that sites allocated for development in the Local Plan have already been considered with respect to the AONB, as set out in the Council’s evidence base [3 Distribution of Development Topic Paper for Draft Local Plan, Regulation 18: Appendix 3 - Assessment of AONB sites].

1.44 In order to ensure that allocations are brought forward in line with the Local Plan, sites should not have to go through the process of demonstrating that the proposal will make a positive contribution toward achieving the AONB Management Plan objectives.

1.45 To ensure that the wider AONB areas can be effectively protected whilst still ensuring that the Council meet their growth targets it is essential that full and proper use is made of the identified locations for new growth. The identification of site PE 7 supports this policy objective and the Council are urged to ensure that maximum productive use is made of this site.

Limits to Built Development

1.46 Our Client fully supports the inclusion of allocation AL/PE 7 within the Limits to Built Development.

1.47 However, the whole allocation site, as outlined on Map 93 (page 338 of the TWBDLP), has not been included on the draft Policies Map.

1.48 To avoid confusion in bringing forward the allocation of AL/PE 7, our Client would recommend that the Limits to Built Development is amended to include the whole allocation outline.

Support subject to the following proposed changes:

Our Client strongly recommends the following changes to ensure that this policy is robust and consistent with national policy:

* 2. “Where a site is within the AONB, and not allocated in the Local Plan, 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;”

Amend the Limits to Built Development to include the whole of the site AL/PE 7 allocation outline

[TWBC: see full representation and supporting documents; Park and Ride Feasibility Review and Site Location Plan].

DLP_8182

Highways England

Location:

No/Type:

Distance to SRN:

Impact:

Current traffic flows:

Recommendations

Pembury

300 residential dwellings (5 site)

Majority of the sites share boundary with A21.

<1km

A21 /A228/Hastings Road/Maidstone Rd/A264/ Longfield Rd

>15km

M25, M20

Significant impact expected on

Traffic data flags up current congestion problems in local and strategic road network surround Pembury during AM and PM peaks, particularly Kipping’s roundabout and A21/A228/A264 interchanges .

Direct; mitigation required for the A21/A228 Interchanges.

Modelling at these junction and Kipping’s roundabout and mitigation measures required.

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

DLP_8305

NHS West Clinical Commissioning Group

General Observation

Waterfield House Surgery provides general medical services to Pembury and the surrounding area. The impact of the draft Local Plan allocations is expected to be c700 new patient registrations (c800 when including extant). The CCG has assessed this with Waterfield House and can confirm that the existing premises will require reconfiguration and extension at a point in the future to accommodate this growth.

The CCG can therefore confirm that contributions will be required to mitigate the impact of development in Pembury.

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 therefore important that in order to ensure proactive development of premises capacity the trigger of any healthcare contribution should be made available linked to commencement or at an early stage of development.

Policy AL/PE 1: Land rear of High Street and west of Chalket Lane

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_452

Mr Nick Sturcke

Object

I have been  a resident of Kings Toll Road at the eastern end of Pembury for 32 years.

The above sites propose the addition of up to 279 new residential properties  close to the centre of Pembury Village, all of which will will need access via Hastings Road/Pembury High Street. They clearly contradict the enhancements listed in Policy STR/PE 1, 5; and should not be included in the Local Plan.

Pembury High Street and Hastings Road are the main west to east route through the village for pedestrians, cyclists, buses and other traffic. Vehicles are parked for much of the day along most of the length of Hastings Road already hindering the free movement of all traffic, including cycles and buses. There is insufficient space for effective cycle lanes along Hastings Road.

The addition of up to 279 properties, an increase in population of perhaps as many as 700, all of which will need access to Hastings Road and Pembury High Street, will result in bringing traffic on this route to a near standstill. The need for the traffic calming measures included in the Plan will be negated by the congestion caused by the additional traffic from the nearby new developments. In effect, traffic from the east end of Pembury Village will be reduced to accessing Tunbridge Wells and elsewhere by using the dangerous Henwood Green Road/A21 junction and travelling along the A21 via Kippings Cross where there are substantial on-going tail back problems which Highways  England are unwilling to address for the foreseeable future.

It will certainly be more difficult for cyclists to ride through the village as there is clearly no room for a dedicated cycle lane along Hastings Road/ Pembury High Street.

The proposed developments are in clear contradiction to the aspirations of the enhancements listed in Policy STR/PE 1, 5 and the measures to enhance bus travel included in the above individual sites. They should not be included in the Local Plan.

DLP_520

Mr Neil Franklin

Object

Access via High Street is problematical.  If it goes ahead, however, the undeveloped area along the A21 must keep its green belt status by placing any new boundary tight against the housing to protect against future development (though it would have been proved that green belt status is worthless).  More parking for the village hall must be a priority.  Traffic using the narrower parts of the High Street and Hastings Road already has to weave through an obstacle course of parked vehicles which is unacceptable and a solution to this would have to be found.  What is the “community facility” and what are the “improvements to the public realm” proposed?

DLP_1445

Pembury Society

General Observation

PLOT SPECIFIC COMMENTS

PE1, PE2 and PE3 are, in effect, one continuous plot. We would expect all the vegetation along the boundary with the A21 to be maintained along the whole length regardless of whether or not a tree preservation order is in place. This is contrary to what has happened in plot PE7 where all the vegetation has been removed even before the application to develop the site has been considered.

  1. PE1 has no obvious point of access because the High Street is developed along its entire length and would probably require the demolition of an existing property in order to gain access. Is it ethical to propose plans, in what is basically a numbers game to satisfy Westminster, that may require a compulsory purchase order on someone’s home if they do not give it up willingly? In any event they will be required to move. A proper Car Park at the Village Hall must be a priority in any development of PE1. It would obviously have to be to the rear of the Hall but access, as indicated in the Draft, via the current access from the High St would be problematic because there is only a single car width alongside the hall itself. Access, therefore, from this direction would require demolition of the next-door property and, as stated above, may not be acceptable. Would an access via Chalket Lane be a possibility, even though at present it is in private ownership beyond Camden Court?

DLP_2112

Terry Everest

Object

Strongly Object

This is a poorly thought out fringe development on what is currently green field and important green buffer zone between Pembury and the A21.

DLP_2806

Nicola Duffy

Object

Insufficient local infrastructure to support this and other planned developments in the local plan along this section of Pembury. The High street, Hastings Road and Lower Green Raod will become traffic rat runs for residents and visitors alike with the potential long queues tio exit the village in the morning and evening. Unsustainable site and an absence of remedial solutions that would alleviate the over crowding of a relatively peaceful environment.

DLP_2980

Finance Manager
Pembury Village Hall

Support with conditions

Policy Number: Policy AL/PE 1, Land rear of High Street and west of Chalket Lane.

1] Pembury Village Hall Management Committee (PVHMC) notes the proposal to allocate a combination of existing land plots for a mixed use housing scheme with 70-80 dwellings, a community facility and extended village hall public parking. PVHMC also notes that the site of 51 High Street, adjacent to the village hall, is included in the draft policy.

2] Clearly the proposed development will require significantly improved vehicular access on to the High Street. PVHMC would object in principle to any scheme which seeks to use part of the village hall land to create a new access road. It would be much safer if the access to the houses was well away from the hall entrance through the site of 55 High Street. A combined access to both the hall and the new houses incorporating the site of 51 High Street would be unsafe and impractical for users of the hall.

3] PVHMC welcomes the intention to provide extended village hall public parking as part of this proposal. This extended provision should be on the site of 51 High Street in combination with the existing parking facilities at the front of the village hall. This could create enough land for a car park with around 40 spaces which would be a considerable improvement on the existing facility. It would significantly reduce the disruptive and often illegal on-street parking in the High Street which currently occurs during larger events at the village hall.

4] The east/west boundary behind the village hall and 51 High Street [the limit of the Conservation Area] should be retained to provide separation from the new housing development and ensure as far as possible that the car park does not become an overspill parking facility for the new residents. The car park should only be available for users of the village hall. PVHMC would be opposed to a car park extension on land at the rear of the village hall as this would be too far from the main hall entrance and would also be very difficult to manage.

5] PVHMC notes but does not consider there should be a requirement for a contribution towards improvements to pedestrian access serving the village hall, which is perfectly adequate at present. However, if the car park was extended as outlined above, then a footpath from the High Street to the front doors of the village hall could usefully be included as part of the scheme.

DLP_3102
DLP_3120

Andy Bashford
Teresa Stevens

Object

TWBC: the following identical comment was submitted by the two responders listed on the left:

Destroying Green Belt purely for the benefit of the new home owners, not the general public is totally unacceptable. Congestion on High St, Hastings Rd, Pembury Rd and A21 to Kippings Cross will get significantly worse than it already is. The extension of Penns Yard to create Chestnut walk a few years ago was thought to be setting a precedent for this type of proposal. We were right to make that point back then.

DLP_3349

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy. The following changes are requested:

Paragraph 1 - Vehicular access onto High Street from western point to be informed by a Transport Assessment. Village Hall access to be emergency/pedestrian/cyclist route only.

Paragraph 2 – “Provision of links to the wider public footway network, public right of way network, and cycle network...”

Paragraph 4 - “Opportunities for the provision of a segregated cycle route linking to the A264 Pembury Road cycle route into the town centre to be explored and where feasible, provided

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

Public Rights of Way and Access Service

The provision of new links between the site and the wider PRoW network is supported. It should also be expected that contributions will be made towards off-site improvements along PRoW.

Heritage Conservation

Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval.

Low archaeological potential

DLP_3467

High Weald AONB Unit

Object

The proposal is major development in the AONB which has not been adequately justified under paragraph 172 of the NPPF.

DLP_3577

Ian Bull Consultancy for Jarvis Strategic Land Ltd

Support with conditions

Jarvis Strategic Land Ltd support the proposed allocation of land rear of the High Street and west of Chalket Lane, Pembury, providing approximately 70-80 dwellings. The proposed development will deliver benefits to Pembury, including improved access and parking for the Village Hall, the provision of links to the wider public rights of way network and enhanced recreation provision. The site lies in a highly sustainable location, with easy access to local facilities and employment opportunities and public transport.

DLP_3851

Natural England

Object

Development of this site is considered to be major development within the AONB. Natural England advises that AONBs should not be considered as suitable locations for major development. All allocations for major development within the AONB need to be robustly assessed against the criteria set out in paragraph 172 of the NPPF. We advise further information is submitted to demonstrate that the criteria of para 172 can be met, and this should include a Landscape and Visual Impact Assessment (LVIA) in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition). Subject to the provision of further information to support this site allocation, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to this allocation.

DLP_4102

Devine Homes PLC

Support

Paragraph Number 5.128

Access to the site is also afforded to it from Chalklet Lane. TWBC: see site location plan attached.

Policy AL/PE 1

  • Devine Homes fully support the general direction of the policy and the principle of releasing this unconstrained element of Green Belt land;
  • There are a number of access iterations which could see suitable provision afforded to the site. It would offer greater flexibility to tweak point 1 of the policy to state:
  • “Improved vehicular access onto Pembury High Street, or otherwise agreed access with KCC Highways”
  • Policy Criterion 5 requires a landscape visial impact assessment “to inform height of buildings and protect long range views of the site from the south”. Criterion 6 requires “Proposals to consider and mitigate the impact of development on the setting of the adjacent Pembury Conservation Area”. Other criteria seek a noise buffer, and landscape mitigation. It is therefore put to the Council that if all of these mitigation criteria can be addressed adequately, then the number of dwellings on the site should be written as “approximately 70-80 residential dwellings, subject to design”
  • All other aspects of the policy are supported at this stage.

DLP_4147

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

CPRE objects to allocations PE 1, 2 and 3 as major development in the AONB which has not been adequately justified under NPPF paragraph 172. However, if these allocations go ahead, CPRE would welcome the provision of a cycle link to Tunbridge Wells as proposed in these three allocation polices.  However, the wording on this needs to be strengthened so as to make sure this will be provided.  Chalket Lane ought to be a public bridleway, as it connects to a public bridleway, leading to the Hawkenbury area in Tunbridge Wells, which currently changes status to footpath at the parish boundary.

If these allocations do go ahead, the treatment of the proposed 40 metre-wide landscape and noise buffer will be very important.  CPRE recommends that it should consist of a mixture of native evergreen and deciduous trees, both to shield the new development from the A21 and to preserve as far as possible the perception of the AONB countryside from the A21.

DLP_5793

Hugh Boorman

Object

10, MAP87 Policy AL/PE 1 I cannot believe that the intention is to bring traffic in and out of the High Street , opposite a large Old Peoples home, alongside the Village Hall and an area where traffic parking where traffic parking can be an issue.

DLP_5826

George Brand

Object

Policy Number: Map 87 Policy Al/PE1; AL/PE2;AL/PE3

Object / General Observation

There are statements which apply to the proposed mitigation of noise / pollution for any development emanating from the proximity of the A21. Our ability to effectively control air pollution is increasingly under threat and recent cases of fatal damage to children from this are now on the increase.

It is appreciated that this land is “available” but the cost of placing approx. 300 homes effectively hard by the A21 where the recent extension has certainly added to the traffic as the traffic jams at Kippings Cross testify, must be weighed very heavily.

DLP_6091

Christopher Wallwork

Support with conditions

Policy Number:  AL/PE 1, 2 and 3 

Each of these refers to exploring opportunities for provision of a cycle link to Royal Tunbridge Wells. It is likely that such a link would be deemed unfeasible in any individual case. The feasibility should be considered within the context of the three policies in combination.

Whilst there is logic to using these sites to provide additional housing, the total number of dwellings proposed is excessive for the available or even for potential infrastructure. Hastings Road is already dangerous and would not cope with the additional vehicle movements; sewerage systems in Pembury are already overloaded.

DLP_6104

Pembury Parish Council

Object

The main problem here is determining the most appropriate access to Pembury High Street. Although there is a suggestion that this could be via the narrow driveway to the Village hall (in combination with no 51 High Street), please note that the Parish own that existing driveway and would not consider allowing access along it to the land behind on safety grounds. (The Village Hall Management Committee have met and would also object in principle to such a plan, they would rather see access via 55 High Street, with additional car parking for the Hall created at 51 High Street if that house is demolished. They do not want additional parking created behind the Hall. See Appendix 2 for their response).

The Parish would support shared use of any such additional car parking accessed at 51 High Street, with say 50% for use as limited car parking for the public. However, consideration of pedestrian safety must be paramount.

Overall, we abhor the loss of MGB and inappropriate development in the AONG, we think the proposed density of housing is too high, and because of these factors and the significant concerns about the impact onto the existing road network, we object to the site being allocated.

[TWBC: see Pembury Parish Council's full response, including appendices referred to in this comment].

DLP_6655

Sarah Clarke

Object

Land at Rear of High Street AL/PE 1, Land south of Hastings Road AL/PE 2, Land to south and west of Hastings Road AL/PE3

All 3 sites are south of the former A21 running through the village centre; with new and significant construction proposed. The access areas to each of the sites are already very congested with car parking along the main road in all areas where new road entrances will lead onto the main road. The land to the south and east of Hastings Road immediately adjoins the junction onto the A21 bypass, a junction which has major problems being near the Kippings Cross roundabout and the reduction from dualling to a single carriageway road. The impact of the traffic problems on the rural roads to the east of Pembury has been great, and the plan contains no solution to the inherent problems that will arise from the proposed 260 houses.

The access to the land at AL/PE1 is in the narrowest area of the High Street, and the traffic calming measures outlined will not solve the impact of the increased traffic in this area or make if safer for pedestrians and cyclists.

DLP_8333

S Allen

 

Late Site 5: Dayspring Cottage, 55 High Street, Pembury TN2 4PH

We confirm that the site is available, deliverable and developable and we are appointing development surveyors and solicitors to secure a suitable delivery partner.

We as landowner are looking to facilitate delivery of a high quality development in line with the policy aspirations of the Council and neighbourhood plan.

Policy AL/PE 2: Land at Hubbles Farm and south of Hastings Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_102

Miss Mary Bird

Object

Pembury is a village and change happens, however 300 additional homes are not acceptable.

The village roads cannot accommodate 600+ cars which will come with the additional housing, even if looking at the Pembury bypass and enhance A21 the roads around Pembury and through the village will become gridlocked.  You may offer buses, but we know that won't happen.

The village is already oversubscribed with no room to extend it, where would the new families send their kids to school unless driving to schools further out and so creating more traffic which is already non moving at many times during the day.

The doctor's surgery is already busy and has limited parking - I cannot see how more patients can be taken in, and I cannot imagine that a new surgery will be built at the same time as housing - many people will have no access to a doctor.

The current access to Hubbles Farm is on a narrow section of road with houses on both sides and across with cars parked on the road, due to no off street parking for those properties.  Any traffic turning right into the new development will be blocking an already busy and narrow road.

With 300 planned houses, the pollution from building - eg the additional large lorries needed to build will add noise pollution as well as fumes.

Our property borders the PE2 building plans and the PE3 development.  We paid a premium for the property because we believed we had greenbelt around us and now suddenly we are going to be surrounded by firstly the building works and then by houses.

The fields around us are a haven for wildlife.

In conclusion,  I feel that this development is ill thought out and will be detrimental to village life

DLP_106

Mr Stuart Law

Object

Pembury is a village and change happens, however 300 additional homes are not acceptable.

The village roads cannot accommodate 600+ cars which will come with the additional housing, even if looking at the Pembury bypass and enhance A21 the roads around Pembury and through the village will become gridlocked.  You may offer buses, but we know that won't happen.

The village is already oversubscribed with no room to extend it, where would the new families send their kids to school unless driving to schools further out and so creating more traffic which is already non moving at many times during the day.

The doctor's surgery is already busy and has limited parking - I cannot see how more patients can be taken in, and I cannot imagine that a new surgery will be built at the same time as housing - many people will have no access to a doctor.

The current access to Hubbles Farm is on a narrow section of road with houses on both sides and across with cars parked on the road, due to no off street parking for those properties.  Any traffic turning right into the new development will be blocking an already busy and narrow road.

With 300 planned houses, the pollution from building - eg the additional large lorries needed to build will add noise pollution as well as fumes.

Our property borders the PE2 building plans and the PE3 development.  We paid a premium for the property because we believed we had greenbelt around us and now suddenly we are going to be surrounded by firstly the building works and then by houses.

The fields around us are a haven for wildlife.

In conclusion,  I feel that this development is ill thought out and will be detrimental to village life

DLP_453

Mr Nick Sturcke

Object

I have been  a resident of Kings Toll Road at the eastern end of Pembury for 32 years.

The above sites propose the addition of up to 279 new residential properties  close to the centre of Pembury Village, all of which will will need access via Hastings Road/Pembury High Street. They clearly contradict the enhancements listed in Policy STR/PE 1, 5; and should not be included in the Local Plan.

Pembury High Street and Hastings Road are the main west to east route through the village for pedestrians, cyclists, buses and other traffic. Vehicles are parked for much of the day along most of the length of Hastings Road already hindering the free movement of all traffic, including cycles and buses. There is insufficient space for effective cycle lanes along Hastings Road.

The addition of up to 279 properties, an increase in population of perhaps as many as 700, all of which will need access to Hastings Road and Pembury High Street, will result in bringing traffic on this route to a near standstill. The need for the traffic calming measures included in the Plan will be negated by the congestion caused by the additional traffic from the nearby new developments. In effect, traffic from the east end of Pembury Village will be reduced to accessing Tunbridge Wells and elsewhere by using the dangerous Henwood Green Road/A21 junction and travelling along the A21 via Kippings Cross where there are substantial on-going tail back problems which Highways  England are unwilling to address for the foreseeable future.

It will certainly be more difficult for cyclists to ride through the village as there is clearly no room for a dedicated cycle lane along Hastings Road/ Pembury High Street.

The proposed developments are in clear contradiction to the aspirations of the enhancements listed in Policy STR/PE 1, 5 and the measures to enhance bus travel included in the above individual sites. They should not be included in the Local Plan.

DLP_481

Alan Semple

Object

These comments concern the proposed development of 300 houses in Pembury.

Before any development on this scale, the infrastructure needed to support it, i.e. extra resources for doctors, dentists, Pembury Primary School, Pembury Hospital, nurseries, etc. needs to be addressed and put in place BEFORE any planning consents are provided.

The proposed developments at Hastings Road (AL/PE2 and AL/PE3 90 dwellings each) will more than double the existing number of houses on this road. This is already a very crowded road, where, due to the considerable number of parked cars and the narrowness of the road in places, there are very limited areas where 2 lanes of traffic can pass each other safely and without difficulty. This problem will be significantly exacerbated by 180 extra houses whose vehicles will all have to use this road. There should therefore be plans to either widen the road and/or impose parking restrictions before any development commences.

There is provision for a Colts Hill bypass, but no mention of any improvements to the notoriously congested road (A264) from Pembury into Tunbridge Wells.

At the Hubbles Farm Land (AL/PE2) proposed development, there will be the destruction of Green Belt land in an Area of Outstanding Natural Beauty, leading to the loss of mature trees, wildlife habitat (French Partridges are seen on this site) and a very peaceful and pleasant area will be concreted over, with a considerable increase in noise pollution.

This site (AL/PE2) is also right next to 2 Telephone Relay Masts, which raises concerns about the possible health risks to people living underneath the masts, and the suitability of building on this site.

Finally, the proposed development at the Eastern end of Hastings Road (AL/PE3) would seem more justifiable, as this site is right on the road.

DLP_521

Mr Neil Franklin

 

Access via High Street is problematical.  If it goes ahead, however, the undeveloped area along the A21 must keep its green belt status by placing any new boundary tight against the housing to protect against future development (though it would have been proved that green belt status is worthless).  More parking for the village hall must be a priority.  Traffic using the narrower parts of the High Street and Hastings Road already has to weave through an obstacle course of parked vehicles which is unacceptable and a solution to this would have to be found.  What is the “community facility” and what are the “improvements to the public realm” proposed?

Item numbered 4: 

Public Rights of Way to be preserved or improved.  The Public Footpath along the south of this site is WT239A not WT239 and must be preserved or improved.  It appears to me that Public Footpath WT237, which must also be preserved because it accesses the Public Rights of Way network south of the A21, belongs in site AL/PE3.

DLP_1446

Pembury Society

General Observation

PLOT SPECIFIC COMMENTS

PE1, PE2 and PE3 are, in effect, one continuous plot. We would expect all the vegetation along the boundary with the A21 to be maintained along the whole length regardless of whether or not a tree preservation order is in place. This is contrary to what has happened in plot PE7 where all the vegetation has been removed even before the application to develop the site has been considered.

2. PE2 does not appear to present any major issues provided the access is via the existing access to Hubbles Farm.

However, there is mention of an assessment of traffic along the Hastings Rd with the potential for traffic calming measures. The only problem here is too many parked cars which effectively render the carriageway single track. Nothing can be done about this as the car owners live in older, terraced, houses with no possibility for off-street parking. Unless this parking situation can be resolved any access/egress on to Hastings Rd will be dangerous.

DLP_2113

Terry Everest

Object

Strongly Object

Another green field whcih needs protection as a buffer and for itself.

DLP_2803

Nicola Duffy

Object

90 additional residences with potentially 180 vehicles? Hastings Road is already a dangerous access and egress for the village that with parking on each side is in the narrower parts nothing less than a dangerous gamble between oncoming traffic. The footways offer little protection to pedestrians wishing to cross from East to West footways towards the village. It is an unsuitable and unsustainable plot for such numbers of properties, the village infrastructure is not there and historical lack of investment here in that and local services suggests it will not be if this is developed as planned.

DLP_3103
DLP_3121

Andy Bashford
Teresa Stevens

Object

TWBC: the following identical comment was submitted by the two responders listed on the left:

Destroying Green Belt purely for the benefit of the new home owners, not the general public is totally unacceptable. Congestion on High St, Hastings Rd, Pembury Rd and A21 to Kippings Cross will get significantly worse than it already is. There are virtually no tall trees on the site along the Public Footpath side (outside site boundary, close to A21) of the site (for noise buffer), which would take many years to grow from scratch. The 2 transmission/receiver masts/aerials by the west end of Public Footpath could be affected by Houses being built close by.

DLP_3350

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy. The following changes are requested:

Paragraph 1 - “Vehicular access onto Hastings Road to be informed by a Transport Assessment. A suitable stagger will be required between the new access road and Belfield Road”.

Paragraph 3 – “Provision of pedestrian and cycle link to west to join existing Public Right of Way WT240 and the wider footway/cycleway network

Paragraph 4 - “Provision of pedestrian and cycle link to south to join Public Right of Way WT239 and east to join WT237 and the wider footway/cycleway network

Paragraph 5 – “Opportunities for the provision of a segregated cycle route linking to the A264 Pembury Road cycle route into the town centre to be explored and where feasible, provided.

Additional paragraph - Provision of adequate visibility splays within site and/or highway land (again see criterion 5 of Policy EN 1: Design and other development management criteria)

Paragraph 2 should be removed. The Transport Assessment will highlight specific mitigation measures: should not be pre-empted at this stage.

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

Public Rights of Way and Access Service

The requirement to provide pedestrian/cycle links with the surrounding PRoW network is supported. However, the surrounding Public Footpaths will need to be upgraded to facilitate cycling and enable onward connectivity. It is therefore requested that contributions will be made towards off-site improvements along PRoW.

Opportunities for upgrading the PRoW network surrounding the development site, including the establishment a Bridleway link with PRoW WB43, should be explored and, if feasible, provided. This is because Public Bridleway WB43 provides a valuable walking, cycling and equestrian link with Hawkenbury/South East Tunbridge Wells. Establishing higher access rights would unlock opportunities for active travel and outdoor recreation.

Heritage Conservation

Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval.

Low archaeological potential

DLP_3469

High Weald AONB Unit

Object

The proposal is major development in the AONB which has not been adequately justified under paragraph 172 of the NPPF.

DLP_3624

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Pembury. As such, we have undertaken a preliminary assessment of the capacity of our existing infrastructure and its ability to meet the forecast demand for this proposal. The assessment reveals that existing local sewerage infrastructure to the site 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.

Proposals for 90 dwellings at this site will generate a need for reinforcement of the wastewater network in order to provide additional capacity to serve the development. This reinforcement will be provided through the New Infrastructure charge to developers, and Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of network reinforcement aligns with the occupation of the development. 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 criterion is added to Policy AL/PE 2

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in liaison with the service provider.

DLP_3852

Natural England

Object

Development of this site is considered to be major development within the AONB. Natural England advises that AONBs should not be considered as suitable locations for major development. All allocations for major development within the AONB need to be robustly assessed against the criteria set out in paragraph 172 of the NPPF. We advise further information is submitted to demonstrate that the criteria of para 172 can be met, and this should include a Landscape and Visual Impact Assessment (LVIA) in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition). Subject to the provision of further information to support this site allocation, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to this allocation.

DLP_4148

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

CPRE objects to allocations PE 1, 2 and 3 as major development in the AONB which has not been adequately justified under NPPF paragraph 172. However, if these allocations go ahead, CPRE would welcome the provision of a cycle link to Tunbridge Wells as proposed in these three allocation polices.  However, the wording on this needs to be strengthened so as to make sure this will be provided.  Chalket Lane ought to be a public bridleway, as it connects to a public bridleway, leading to the Hawkenbury area in Tunbridge Wells, which currently changes status to footpath at the parish boundary.

If these allocations do go ahead, the treatment of the proposed 40 metre-wide landscape and noise buffer will be very important.  CPRE recommends that it should consist of a mixture of native evergreen and deciduous trees, both to shield the new development from the A21 and to preserve as far as possible the perception of the AONB countryside from the A21.

DLP_5827

George Brand

Object

Policy Number: Map 87 Policy Al/PE1; AL/PE2;AL/PE3

Object / General Observation

There are statements which apply to the proposed mitigation of noise / pollution for any development emanating from the proximity of the A21. Our ability to effectively control air pollution is increasingly under threat and recent cases of fatal damage to children from this are now on the increase.

It is appreciated that this land is “available” but the cost of placing approx. 300 homes effectively hard by the A21 where the recent extension has certainly added to the traffic as the traffic jams at Kippings Cross testify, must be weighed very heavily.

DLP_6008

Katherine Wallwork

Support with conditions

90 dwellings seems too high: suggest reduction to 80.

Traffic calming: There are at present problems with many parked vehicles along much of Hastings Road, since a number of houses along the northern side of the road do not possess drives or garages. Some residents who live in Canterbury Road (where there are only two dwellings with garages) overspill parking their cars onto Hastings Road. In effect, this creates its own traffic calming. If the Authority is considering official traffic calming along Hastings Road, then it needs to take into consideration the needs of local residents who do not have anywhere else to park their cars.

Further tree planting along the southern edge of the site to act as a further screen, contribute towards the county-wide and nationwide increase in tree planting, helping to soak up rainfall and hold the ground of the southern edge of the site together.

Ensure that the appropriate level of affordable housing is adhered to.

Ensure that Pembury school and other local schools are suitable increased in size or new schools built to cater for the increase in child population. Ensure that the local GP surgery is expanded (upwards if necessary as no additional land available on current site). Ensure that improvements to sewerage services are carried out before any groundworks are commenced. Indeed, no building works should begin until all measures are in place to accept the new housing.

Improvements to cycle and pedestrian routes on the A21 dual carriageway need to be implemented.

DLP_6092

Christopher Wallwork

Support with conditions

Policy Number:  AL/PE 1, 2 and 3 

Each of these refers to exploring opportunities for provision of a cycle link to Royal Tunbridge Wells. It is likely that such a link would be deemed unfeasible in any individual case. The feasibility should be considered within the context of the three policies in combination.

Whilst there is logic to using these sites to provide additional housing, the total number of dwellings proposed is excessive for the available or even for potential infrastructure. Hastings Road is already dangerous and would not cope with the additional vehicle movements; sewerage systems in Pembury are already overloaded.

DLP_6105

Pembury Parish Council

Object

Again, the suggested access point is problematic as it is opposite Belfield Road which is a dangerous junction. The sight lines are not good and egress from the site to the narrow Hastings Road is dangerous.

There is currently only 10-15 years, approximately, left at Pembury Burial Ground and therefore we strongly support that land is to be safeguarded for an extension of the cemetery.

Overall, we abhor the loss of MGB and inappropriate development in the AONB, we think the proposed housing density is too high, and because of these factors and the significant concerns about the impact onto the existing road network, we object to the site being allocated.

[TWBC: see Pembury Parish Council's full response, including any appendices referred to in this comment].

DLP_6658

Sarah Clarke

Object

Land at Rear of High Street AL/PE 1, Land south of Hastings Road AL/PE 2, Land to south and west of Hastings Road AL/PE3

All 3 sites are south of the former A21 running through the village centre; with new and significant construction proposed. The access areas to each of the sites are already very congested with car parking along the main road in all areas where new road entrances will lead onto the main road. The land to the south and east of Hastings Road immediately adjoins the junction onto the A21 bypass, a junction which has major problems being near the Kippings Cross roundabout and the reduction from dualling to a single carriageway road. The impact of the traffic problems on the rural roads to the east of Pembury has been great, and the plan contains no solution to the inherent problems that will arise from the proposed 260 houses.

The access to the land at AL/PE1 is in the narrowest area of the High Street, and the traffic calming measures outlined will not solve the impact of the increased traffic in this area or make if safer for pedestrians and cyclists.

DLP_6824

Barton Willmore for Obsidian Strategic

Support

Introduction

We act on behalf of Obsidian Strategic HFP Ltd (‘our client’) and have been instructed to submit representations to Tunbridge Wells Borough Council’s Draft Local Plan (Regulation 18) Consultation (‘the Draft Plan’). This follows previous representations submitted as part of the ‘Call for Sites’ Consultation in March 2018.

This representation supports the draft Local Plan strategy and in particular the allocation (Policy AL/PE 2) of land at Hubbles Farm and South of Hasting Road, Pembury (‘the Site’) for residential development.

In accordance with the Council’s requirements, we have submitted as part of this written representation a Site Location Plan, prepared by Enplan (Drawing Ref: 01-742-001) and the duly completed Tunbridge Wells Draft Local Plan and Sustainability Appraisal response forms, which should be read in conjunction with this letter. This written representation also includes further technical assessment in support of the future allocation of the Site, including:

i. Flood Risk Assessment dated June 2018, prepared by Glanville;

ii. Landscape and Visual Appraisal dated November 2017, prepared by Enplan;

iii. Landscape and Visual Appraisal Addendum dated November 2019, prepared by Enplan; and

iv. Transport Feasibility Study dated November 2018, prepared by DHA Transport.

TWBC: see also Figures 1-11, Site Location Plan, and Sketch Layout

A proposed illustrative layout plan, prepared by thrive architects (Drawing Ref: SKL-03), has also been provided, demonstrating the ability to accommodate a residential scheme comprising circa 126 units with associated access and comprehensive landscape/open space.

Site Context and Policy Justification

The Site currently lies immediately outside the ‘Limits to Built Development’ (LBD) Boundary of Pembury. It falls within the wider Metropolitan Green Belt, wider High Weald AONB and wider Kent Special Landscape Area. The Site also lies in close proximity to the Pembury Conservation Area (to the north-west) and an existing cricket pitch (identified as Recreation Open Space).

The National Planning Policy Framework (NPPF) is clear that local planning authorities should, through their Local Plans, meet objectively assessed needs unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits (Paragraph 11).

It also confirms at Paragraph 136, that once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation of or review of the Local Plan. Prior to concluding exceptional circumstances exist to justify changes to the Green Belt boundaries a sequential approach must have been applied in seeking to meet identified housing needs, including:

a) Making as much use as possible of suitable brownfield sites and underutilised land;

b) Optimising density of development, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and

c) Informed discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.

The Local Plan confirms that TWBC has suffered from a significant shortfall in housing supply and acute affordability issues. We are aware that the Council has undertaken detailed urban capacity work and had discussions with neighbouring authorities to ascertain whether they could assist in accommodating housing requirements. However, in order to fully address the housing need, it has rightly been concluded that there is a requirement to couple high density development within ‘urbanised areas’ with the release of Green Belt Land. To this end, the sequential approach has been undertaken, and exceptional circumstances exist to justify changes to the Green Belt. We support this approach and clarity of this decision making should be made in the Evidence Base.

In addition, whilst we support the Council in meeting its Objectively Assessed Need (OAN) in full, for robustness, the Council should also consider the implications of providing more or fewer homes. This is not to say the Council should follow any other strategy, it is simply to show that other options have been considered and the Council can be aware of the issues of alternative strategies in informing the current Local Plan proposals.

Turning to the Site, it is noted that the Site’s development potential was considered in context of housing needs, the Green Belt Review and as part of the Sustainability Appraisal of the Draft Local Plan (September 2019). This ‘stepped’ assessment is supported by Paragraph 138 of the NPPF, in that when reviewing Green Belt boundaries, the need to promote sustainable development should be taken into account, whilst setting out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt Land.

The Site was considered within the Green Belt Review (GBR) Stage Two (July 2017) parcel reference PE1 and the Strategic Housing and Economic Land Availability Assessment (SHELAA) – Jul 2019 (Site Ref 50). The GBR rightly concluded that the larger land parcel (PE1) within which the Site is situated, performed ‘ relatively weakly ’ in meeting the purposes of the Green Belt. In these terms, its potential level of harm to the Green Belt associated within its release was found to be ‘ low’ , and that ‘the A21 would represent a stronger boundary than the existing settlement edge’ .

The land to the north of the Site comprises of the existing built up settlement of Pembury and would be defined by the physical and enduring boundary of the A21 to the south. The eastern boundary is defined by open Green Belt Land, also proposed as a draft allocation (AL/PE 3), bound by Henwood Green Road and to the west by safeguarded land to protect the existing community uses including the cemetery and cricket ground. This provides a clear defensible boundary between the built limits of the Settlement and the Green Belt.

The SHELAA also concluded that, ‘the Site is suitable as a potential Local Plan allocation subject to further consideration ’. The basis for this finding was that the

site lies mostly in proximity to the LBD and is likely to be sustainable in this context. It includes some PDL land. It would form a logical extension to the LBD in conjunction with other site submissions’ .

To supplement the detailed site assessment undertaken within the above reports, additional assessment work was carried out within the LBD (September 2019) and Distribution of Development (September 2019) topic papers. This additional assessment considered what possible contributions development included in a proposed allocation can make to Green Belt and AONB objectives in terms of improving access, providing locations for outdoor sport, landscape and visual enhancement, increasing biodiversity and improving damaged and derelict land.

A requirement to safeguard land for the potential future expansion of St Peter’s cemetery, in addition to a landscape buffer along the A21 was identified. The LBD topic paper confirms ‘ the Inclusion of site allocation AL/PE 2 (land at Hubbles Farm and south of Hastings Road) into new LBD boundaries with buffers (for noise, in relation to the A21 ) included as it is likely that some form of built development will be permitted on this part of the site in accordance with this site allocation policy in the draft Local Plan. The safeguarded land is to be excluded. This site (including noise buffers; excluding the safeguarded land) will form part of a Green Belt release’.

In accordance with Paragraph 32 of the NPPF, ‘Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal’. The SA prepared in support of the Draft Plan includes and assessment of the Site against sustainability objectives. The findings of which include a negative land use score associated with the loss of Green Belt Land (low harm) and negatively against noise objectives due to the proximity of the A21.

The enclosed indicative layout identifies the provision of pedestrian links to join existing Public Right of Ways, delivering significant benefit through increased public accessibility. The retained landscape buffer to the south and open space across the site will mitigate any ecological and biodiversity impacts, with a goal of achieving a net environmental gain. The supporting Transport Feasibility Study outlines the improvements which will be made to the highways network. The negative aspects of the Site’s development identified in the SA can therefore be mitigated. The SA should be continually updated to inform each stage of the Local Plan process and reflect the findings of additional assessment.

Overall, we consider the evidence base has been prepared in a logical and transparent manner in accordance with Paragraph 31 -33 of the NPPF. It recommends the Site for inclusion as a draft allocation for 90 residential units, within draft policy AL/PE 2. The NPPF requires LPAs to allocate sites to meet identified needs and, in line with this, it is considered that the Site will contribute towards meeting this requirement in a sustainable location. The proposed residential allocation of the Site is therefore supported in line with the identified need and the conclusions of the sustainability appraisal.

Draft Plan Representations

The OAN for the Borough was calculated as 13,560 dwellings over the plan period to 2036, or 678 dwellings per annum. Our client supports the Councils Growth strategy, combining Option 3 (dispersed growth) and Option 5 (a new ‘stand alone; garden settlement), to meet the OAN in full. This approach is required for the Local Plan to meet the soundness tests of the NPPF and meet the presumption in favour of sustainable development.

We also agree that any development strategy should first seek to make efficient use of existing previously developed land and promote regeneration. This is entirely consistent with the NPPF and Planning Practice Guidance. However, in providing a wide choice of housing and locations, such aspirations need to be balanced with greenfield release in sustainable locations as the Council proposes.

In these terms, we support the Council in proposing to allocate the Site which is fully justified through the evidence base to the Local Plan, including the Sustainability Appraisal as noted above. This approach is fully compliant with the NPPF which states that, for a local plan to be considered sound, it must comply with the legal and procedural requirements of plan making and demonstrate that it is positively prepared, justified, effective and consistent with national policy.

The Site is controlled under a single ownership and as such is immediately available to contribute towards the identified housing need. Furthermore, the Site represents a viable and deliverable option which can be brought forward within the early years of the Plan period (0-5 years).

Draft Policy AL/PE 2 ‘Land at Hubbles Farm and south of Hastings Road’

The Site is proposed, as part of draft allocation AL/PE 2, for the delivery of approximately 90 residential dwellings. The enclosed illustrative layout plan has been informed through the development requirements within the draft policy wording, alongside analysis of the wider site context, including immediate land uses, setting of adjacent Pembury Conservation Area and landscape impact.

The design concept establishes a residential layout surrounding a central green space, with strong landscape buffers comprising the peripheries of the Site. The Site already benefits from direct vehicular access from Hastings Road and this will be modified to support a ‘circular’ internal road arrangement. In this respect, discussions have already taken place with the County Highway Authority. Strong pedestrian and cycle linkages are provided within the site to the existing Public Right of Way along the southern and eastern boundaries. A further potential link could be provided through the existing Cemetery on the western boundary.

The enclosed Transport Feasibility Study, prepared by DHA, considers the traffic impact of the Site as well as the cumulative impacts of the neighbouring Countryside sites. The Study identifies that 89% of the trips, associated with the site, would route to the west towards the Pembury crossroads. The results demonstrate that the crossroads will operate over capacity in the future years with or without development coming forward. Given the forecasted capacity overload at the junction either with or without the proposed developments, the junction has been redesigned to provide an additional lane on the High Street and Pembury Road arms. The mitigation plans would have a positive impact on the junction’s operation, addressing the existing issue and mitigating future traffic generation arising from the proposed developments.

In accordance with the draft policy wording, an area of safeguarded land for the future expansion of the cemetery is maintained in the western corner of the Site. Children’s playspace is located alongside the safeguarded land to allow for the potential future function as shared recreation/amenity space. Given the Site’s location within close proximity to the A21, the development would be set back from the southern boundary. This buffer also serves as a noise barrier for the residential buildings, shielding the units from the vehicle generated noise of the adjacent A21.

All existing trees and hedgerows on the Site are identified to be retained with further enhanced planting along the southern boundary to improve noise mitigation. Improved public open space and landscaping across the Site will protect and enhance existing biodiversity. The proposed enhancements will also contribute to the existing landscape character retaining key views across the Site. The proposals provide an opportunity to contribute to the landscape character of the area and allowing public access. Please refer to the supporting Landscape and Visual Appraisal, prepared by Enplan for further detail, including the location of proposed landscape buffers. This concludes that the site has a low landscape sensitivity and there would only be limited visual effects following development through a careful masterplanned approach. he illustrative layout has been informed through the enclosed Flood Risk Assessment and initial drainage strategy. Attenuation features are located on the lowest part of the site adjacent to the access point. An additional smaller feature within the central space and infiltration soakaways within plots and public realm, provide sufficient drainage capacity.

The illustrative layout, informed through the enclosed technical assessments, identifies a potential site capacity of circa 126 units. The total site area equates to 5.1 ha, equating to a site density of 25 u/ha, considered to be entirely in keeping with the context of the site’s location. In these terms, it is considered that the wording of draft policy AL/PE 2 should be revised as follows:

This site, as defined on the Pembury draft Policies Map , is allocated for residential development (C3) providing approximately 120 residential dwellings’.

Summary

The site has a potential site capacity of circa 126 units with associated strategic landscaping, with a new vehicular access point proposed from Hastings Road.

The NPPF sets out a presumption in favour of sustainable development. There are three dimensions to sustainable development: economic, social and environmental. The planning system is expected to contribute towards building a strong, responsive and competitive economy, support strong, vibrant and healthy communities and contribute to protecting and enhancing the natural, built and historic environment.

The proposed development at the Site as part of draft allocation AL/PE 2, meets with the three overarching objectives of sustainable development in accordance with the NPPF, whilst having the ability to contribute to delivering needed infrastructure for the benefit of Pembury. In summary these benefits include:

Economic Benefits - The proposed development will make a significant and meaningful contribution to meeting housing needs within the Borough, through the provision of circa 126 units in a sustainable location. It will allow for the retention of residents in accordance with projected population growth. Resident expenditure will in turn contribute to the vitality of local amenities and services.

Social Benefits – The proposed development would be able to contribute to local housing need. Improvements to community infrastructure through the provision of recreation space, safeguarded land for the provision of potential future community facility expansion (cemetery or cricket ground), strong connections to cycle routes and footpaths.

Environmental Benefits – Utilising land (incorporating some previously developed land) of lesser environmental value within the Green Belt. Enhancement of site buffers and retention of the existing natural environment on the site will provide suitable habitat delivering a net gain in biodiversity on the existing.

It is considered that the Site is suitable for Green Belt release, in context of its poor performance against national Green Belt objectives meaning its release would not adversely affect the wider function of the Green Belt. The inclusion of the Site within the LBD of Pembury would therefore represent a natural extension to the existing settlement pattern. The defensible boundaries of the Site including the A21 to the South, provides a logical augmentation of the settlement boundary.

As set out above, the Site represents a deliverable and suitable opportunity to deliver residential development on a smaller site, within a sustainable and accessible location, meeting the objectives and commitments of the Development Plan. Paragraph 14 of the NPPF states that there is a presumption in favour of sustainable development and that ‘local planning authorities should positively seek opportunities to meet the development needs of the area’ in the plan making process. The Site should therefore be brought forward as part of the Local Plan Review process, for residential development, to positively contribute to housing delivery.

We trust that these representations will be fully considered and would welcome the opportunity to discuss them with the Council in more detail. We look forward to receiving acknowledgement of this submission marked for the attention of Jamie Wallace / Graeme Warriner at this office. We would also be grateful if you could keep us notified of the progress of the Local Plan and other emerging planning policy documents.

In the meantime, should you require any additional information please do not hesitate to contact us directly.

Policy AL/PE 3: Land north of the A21, south and west of Hastings Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_101

Miss Mary Bird

Object

Pembury is a village and change happens, however 300 additional homes are not acceptable.

The village roads cannot accommodate 600+ cars which will come with the additional housing, even if looking at the Pembury bypass and enhance A21 the roads around Pembury and through the village will become gridlocked.  You may offer buses, but we know that won't happen.

The village is already oversubscribed with no room to extend it, where would the new families send their kids to school unless driving to schools further out and so creating more traffic which is already non moving at many times during the day.

The doctor's surgery is already busy and has limited parking - I cannot see how more patients can be taken in, and I cannot imagine that a new surgery will be built at the same time as housing - many people will have no access to a doctor.

Any traffic turning right into the new development will be blocking an already busy and narrow road with cars and trucks going to the new  housing and commercial units.  With a massive retail and industrial site at North Farm why would anyone think it is a good idea to put commercial units in Pembury Village?

With 300 planned houses, the pollution from building - eg the additional large lorries needed to build will add noise pollution as well as fumes.

Our property borders the PE3 building plans and the PE2 development.  We paid a premium for the property because we believed we had greenbelt around us and now suddenly we are going to be surrounded by firstly the building works and then by houses.

The fields around us are a haven for wildlife.

In conclusion,  I feel that this development is ill thought out and will be detrimental to village life

DLP_107

Mr Stuart Law

Object

Pembury is a village and change happens, however 300 additional homes are not acceptable.

The village roads cannot accommodate 600+ cars which will come with the additional housing, even if looking at the Pembury bypass and enhance A21 the roads around Pembury and through the village will become gridlocked.  You may offer buses, but we know that won't happen.

The village is already oversubscribed with no room to extend it, where would the new families send their kids to school unless driving to schools further out and so creating more traffic which is already non moving at many times during the day.

The doctor's surgery is already busy and has limited parking - I cannot see how more patients can be taken in, and I cannot imagine that a new surgery will be built at the same time as housing - many people will have no access to a doctor.

Any traffic turning right into the new development will be blocking an already busy and narrow road with cars and trucks going to the new  housing and commercial units.  With a massive retail and industrial site at North Farm why would anyone think it is a good idea to put commercial units in Pembury Village?

With 300 planned houses, the pollution from building - eg the additional large lorries needed to build will add noise pollution as well as fumes.

Our property borders the PE3 building plans and the PE2 development.  We paid a premium for the property because we believed we had greenbelt around us and now suddenly we are going to be surrounded by firstly the building works and then by houses.

The fields around us are a haven for wildlife.

In conclusion,  I feel that this development is ill thought out and will be detrimental to village life

DLP_454

Mr Nick Sturcke

Object

I have been  a resident of Kings Toll Road at the eastern end of Pembury for 32 years.

The above sites propose the addition of up to 279 new residential properties  close to the centre of Pembury Village, all of which will will need access via Hastings Road/Pembury High Street. They clearly contradict the enhancements listed in Policy STR/PE 1, 5; and should not be included in the Local Plan.

Pembury High Street and Hastings Road are the main west to east route through the village for pedestrians, cyclists, buses and other traffic. Vehicles are parked for much of the day along most of the length of Hastings Road already hindering the free movement of all traffic, including cycles and buses. There is insufficient space for effective cycle lanes along Hastings Road.

The addition of up to 279 properties, an increase in population of perhaps as many as 700, all of which will need access to Hastings Road and Pembury High Street, will result in bringing traffic on this route to a near standstill. The need for the traffic calming measures included in the Plan will be negated by the congestion caused by the additional traffic from the nearby new developments. In effect, traffic from the east end of Pembury Village will be reduced to accessing Tunbridge Wells and elsewhere by using the dangerous Henwood Green Road/A21 junction and travelling along the A21 via Kippings Cross where there are substantial on-going tail back problems which Highways  England are unwilling to address for the foreseeable future.

It will certainly be more difficult for cyclists to ride through the village as there is clearly no room for a dedicated cycle lane along Hastings Road/ Pembury High Street.

The proposed developments are in clear contradiction to the aspirations of the enhancements listed in Policy STR/PE 1, 5 and the measures to enhance bus travel included in the above individual sites. They should not be included in the Local Plan.

DLP_482

Alan Semple

Object

These comments concern the proposed development of 300 houses in Pembury.

Before any development on this scale, the infrastructure needed to support it, i.e. extra resources for doctors, dentists, Pembury Primary School, Pembury Hospital, nurseries, etc. needs to be addressed and put in place BEFORE any planning consents are provided.

The proposed developments at Hastings Road (AL/PE2 and AL/PE3 90 dwellings each) will more than double the existing number of houses on this road. This is already a very crowded road, where, due to the considerable number of parked cars and the narrowness of the road in places, there are very limited areas where 2 lanes of traffic can pass each other safely and without difficulty. This problem will be significantly exacerbated by 180 extra houses whose vehicles will all have to use this road. There should therefore be plans to either widen the road and/or impose parking restrictions before any development commences.

There is provision for a Colts Hill bypass, but no mention of any improvements to the notoriously congested road (A264) from Pembury into Tunbridge Wells.

At the Hubbles Farm Land (AL/PE2) proposed development, there will be the destruction of Green Belt land in an Area of Outstanding Natural Beauty, leading to the loss of mature trees, wildlife habitat (French Partridges are seen on this site) and a very peaceful and pleasant area will be concreted over, with a considerable increase in noise pollution.

This site (AL/PE2) is also right next to 2 Telephone Relay Masts, which raises concerns about the possible health risks to people living underneath the masts, and the suitability of building on this site.

Finally, the proposed development at the Eastern end of Hastings Road (AL/PE3) would seem more justifiable, as this site is right on the road.

DLP_522

Mr Neil Franklin

Object

If it goes ahead, the undeveloped area along the A21 must keep its green belt status by placing any new boundary tight against the housing to protect against future development (though it would have been proved that green belt status is worthless).  Traffic using the narrower parts of the High Street and Hastings Road already has to weave through an obstacle course of parked vehicles which is unacceptable and a solution to this would have to be found.  It appears to me that Public Footpath WT237, which must also be preserved because it accesses the Public Rights of Way network south of the A21, belongs in this site rather than site AL/PE2.

DLP_1447

Pembury Society

General Observation

PLOT SPECIFIC COMMENTS

PE1, PE2 and PE3 are, in effect, one continuous plot. We would expect all the vegetation along the boundary with the A21 to be maintained along the whole length regardless of whether or not a tree preservation order is in place. This is contrary to what has happened in plot PE7 where all the vegetation has been removed even before the application to develop the site has been considered.

3. PE3 does not appear to present any major issues but parking in Hastings Rd may become an issue depending on what happens along the stretch by PE2. Any increase in parking along this eastern end of Hastings Rd could impede access/egress to this site.

DLP_2114

Terry Everest

Object

Strongly object

It is important to maintain green spaces next to major highways as they act as mitigation of some of the pollution. These proposals are all wrongheaded as housing here would be fully exposed to this pollution and remove the vital green corridor.

DLP_2707

John Duffy

Object

Pembury does not have the infrastructure of roads and local services to cope with this influx of dwellings and the ascoaited vehicular movements and additional residents demands on the available services. The vague assertion that additional road traffic management and local services will be provided is not supported by the lack of any such occurrence as the village has been allowed to develop ad hoc in the absence of a viable local plan.

DLP_3031

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 at Pembury, which Countryside is promoting for residential redevelopment as part of the wider development plan review.

1.1.3 Based on the current national and local planning context, we consider these sites to be suitable for development and we consider there to be ‘exceptional circumstances’ to prioritise these sites in the High Weald Area of Outstanding Natural Beauty (‘AONB’). Furthermore, the sites are of a size and scale to play a role in accommodating the wider overspill of housing need from London and elsewhere within the South East of England.

1.1.4 This representation therefore responds to the content of the draft plan (and relevant supporting documents), reinforces why the sites represent suitable locations to accommodate growth and outlines how development could be delivered on site.

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 the Parish of Pembury;
  • Development Management Policies; and
  • Omission Sites.

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

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

2.3.7 We support the general principle of proportionately spreading the benefits of growth and we recognise the opportunity to direct a greater level of growth to Pembury compared with previous plan periods. Furthermore, adopting a pattern of dispersed growth approach would allow a number of sites to be developed at the same time, serving different segments of the local housing market, which is preferable to saturation of the market in a single area.

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

2.3.9 In this regard, we would draw the Council’s attention back to the 2016 document published by Nathaniel Lichfield’s and Partners (NLP) - ‘Start to Finish: How Quickly do Large-Scale Housing Sites Deliver’, which provides evidence pertaining to the speed and rate of delivery of large-scale housing, based on a large number of sites across England and Wales.

2.3.10 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.

2.3.11 Figure 1 below is taken from the NLP report, which shows the average planning approval period and delivery of first dwelling by site size.

[TWBC: to view Figure 1 please see page 6 of full representation].

2.3.12 Whilst the NLP report does not represent practice guidance, it is widely accepted as being a reliable and credible source of evidence and is referenced by TWBC in their Housing Trajectory Paper.

2.3.13 Despite evidence elsewhere, TWBC has set a very optimistic trajectory for delivery of Tudeley Garden Village and the strategic extension of Paddock Wood, which is detailed in the Housing Trajectory Paper.

2.3.14 The Council forecasts that the Tudeley Garden Village will begin to deliver homes from 2025/26 onward, with an initial build out rate of 150 dwellings per-annum, rising to 200 dwellings per annum from year 6 onward. Likewise, they suggest that the extension to Paddock Wood will start to deliver in 2024/25 at an average build out rate of 333 dwellings per annum – which is nearly double the average rate for larger schemes identified in the NLP document. This higher build out trajectory is predicated on the basis that there would be a number of house builders involved the construction of different parts/phases. However, by their own admission, TWBC do not currently know how many housebuilders will be involved.

2.3.15 Taking the above into account, our view is that the Council have applied an overly optimistic development trajectory for the delivery of strategic sites, both in terms of the start date for completions and the expected build out rates.

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

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

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

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

2.3.20 The enclosed Vision document illustrates opportunities within our client’s land to deliver more homes than currently permitted by the draft allocations at Pembury. These homes would be delivered early in the plan period and help to ensure the plan is effective.

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.

Comments on Policy AL/PE3

Stance: Support with Conditions

2.4.2 Countryside supports this policy, which is generally in line with its early proposals for the residential redevelopment of the site. The proposed site capacity of 90 units is specifically supported.

2.4.3 A Vision Document for the site (and also further land to the east – see section 2.6 below) is enclosed which sets out a strong case for development on these sites. This has previously been submitted on an informal basis, but is now formally submitted in support of these representations.

2.4.4 However, this support is subject to the comments and concerns set out below.

Vehicular, pedestrian and cycle access

2.4.5 Countryside are undertaking detailed work to inform consideration of the most appropriate vehicular access point. This work will also inform the strategy for pedestrian links including a pedestrian crossing over Hastings Road.

2.4.6 Countryside confirm that they are willing to investigate ways of improving cycle links between the site and Routes 2 (Pembury Road) and 6 (Pembury-Tonbridge) as set out in the Council’s Cycling Strategy 2016-2020. For example, there could be an opportunity to provide a cycle connection into the neighbouring proposed allocation site (AL/PE2), from where further links could be provided to the Village Green and beyond.

Proposed 40m landscape and noise buffer

2.4.7 There is no objection to the principle of a wide landscape and noise buffer to the A21, but this element of the policy should be worded to allow some flexibility rather than imposing a strict 40m width. Indeed, an illustrative scheme prepared by Countryside provided a buffer ranging between 40m and 106m for most of the site, although in other parts a slightly narrower 28m buffer was considered acceptable. We consider it unnecessary and overly restrictive for the policy to set an arbitrary buffer at this stage, especially prior to more detailed landscape and noise assessment work being undertaken.

2.4.8 The policy should also clarify that some uses, such as amenity space, can be accommodated within the landscape buffer. For example, some structures, such as play equipment, may be built in this area, making appropriate use of the site topography. The current wording of “no built development” may also be interpreted as precluding the construction of noise barriers, which may be appropriate within this zone.

2.4.9 These concerns could be overcome by:

  • Removing the proposed landscape buffer from the proposals map; and
  • Amending criterion 8 to read:

“8. Noise buffer, with no residential development along southern edge of site adjacent to A21; landscape buffer to A21the width of which is to be informed by landscape and noise assessments, in addition to existing vegetation along A21 (see Policy EN 30: Noise);”

Small business units

2.4.10 Countryside strongly objects to criterion 11, which requires consideration to be given for the inclusion of small business units within the scheme. We enclose an Employment Feasibility Study for the site, submitted informally to TWBC in November 2018, which explains in detail why the site is unsuitable for small business units.

2.4.11 In summary, and taking into account the remainder of the Regulation 18 draft Local Plan, our concerns can be summarised as follows:

  • The site topography is unsuitable for employment development;
  • The access from the A21/ Hastings Road junction is not suitable for HGV traffic;
  • Employment development would be incongruous with the character of the surrounding area, which is overwhelmingly residential;
  • Requiring part of the site to be developed for employment uses in a way which would have the least impact on existing and proposed neighbouring residential uses will significantly reduce the area available for housing; and
  • There is no need for employment development in this location: the Local Plan makes more than adequate provision for employment development in a wide variety of locations elsewhere including in Tunbridge Wells, North Farm, Pembury (Woodsgate Corner), Paddock Wood and Hawkhurst.

Public realm improvements

2.4.12 The final part of the policy currently states an expectation that contributions will be required to various measures, including “Improvements to the public realm at the centre of Pembury”.

2.4.13 It is not clear from the information in the draft Local Plan what such improvements are planned or how this is reasonably related to the development of this site. It is understood from discussions that this may mean to refer to a scheme of traffic calming on Hastings Road, similar to that expressed in Policy PE/AL 1. If this is the case, the policy wording should be amended to reflect this.

2.4.14 Countryside has no objection to making a fair and proportionate contribution to measures to a traffic calming scheme on Hastings Road, if this is required.

2.5 Development Management Policies

2.5.1 The development management policies seek to achieve the vision established by the strategic and place making policies aforementioned. They provide more detail for decision making in relation to particularly issues and assess the acceptability of development.

Comments on Policy EN 11: Net gains for Nature - Biodiversity

Stance: Comment

2.5.2 Countryside recognises the Council’s wish to introduce a policy requiring a net gain for ecology to be achieved. If such a policy is considered necessary, Countryside agrees with the Council that it is important that the option is available to provide a net gain through an off-site contribution, where this is appropriate.

Comments on Policy EN 17: Local Green Space

Stance: Object

2.5.3 Whilst Countryside has no objection to the aims and objectives of this policy, there is a specific objection in terms of how it has been applied on land adjacent to Woodside Recreation Ground, Pembury. There are two aspects of concern:

(i) That it is no longer necessary to designate the majority of this land as Local Green Space; and

(ii) That criterion 2 of the draft policy needs to allow greater flexibility.

Land adjacent to Woodside Recreation Ground

2.5.4 The draft Local Plan allocates Woodside Recreation Ground and two parcels of adjacent land as Local Green Space. There is no objection to the allocation of the existing recreation ground (the large, westernmost EN17 rectangle shown in Figure 2).

2.5.5 Countryside’s concerns relate to the two adjacent areas, to the south-west and north-west of the recreation ground, as shown in Figure 2. These have been long since allocated for the potential expansion of Woodside Recreation Ground in previous Local Plans but the Council has failed to deliver these to date. Indeed, the Council has recently withdrawn an application submitted in 2018.

2.5.6 The criteria for allocating Local Green Space is set out in the Council’s Local Green Space Designation Methodology, dated July 2019. This sets out specific criteria which must be met if a site is to be allocated as a Local Green Space.

[TWBC: to view Figure 2 please see page 11 of full representation].

2.5.7 The two parcels of land adjacent to Woodside Recreation Ground clearly fail to accord with Criterion 5, which requires that “The space is demonstrably special to the local community and holds particular local significance”. Paragraph 3.10 of the Methodology explains that evidence will be considered in relation to the relevant sub-criteria set out in NPPF paragraph 100(b). These are considered below, with the relevant sub-criteria highlighted in bold:

(i) The proposed space is of particular local significance because of its beauty. Whilst these parcels are not unattractive, there is nothing particularly special or significant about them which would warrant the conclusion that they are of particular local significance due to their beauty, compared with any other greenfield site around the edge of Pembury. These parcels do not contain any specific features of interest, do not contribute to the setting of a historic building, and do not contribute to any especially valued views.

(ii) The proposed space is of particular local historic significance. The parcels are not of local historic significance. There are no local historic features, and no important historic events or rituals are known to have taken place here.

(iii) The proposed space is of particular local significance because of its recreational value. In contrast to the recreation ground itself, the adjacent parcels are not used for playing sport. Whilst there is a public right of way (footpath WT234) running across the middle of the southern parcel, there is no right of public access to the remainder of either parcel. Whilst the parcels have previously been allocated for recreational uses, no such uses have actually taken place.

(iv) The proposed space of particular local significance because of its tranquillity. This is not the case for either parcel, but especially not the southern parcel which is adjacent to the A21 dual carriageway.

(v) The proposed space of particular local significance because of its richness of wildlife. It has not been designated as a Local Wildlife Site and is not known to be of notable biodiversity interest.

2.5.8 For the above reasons, the parcels adjacent to Woodside Recreation Ground fail to meet the relevant criteria and should not be allocated as Local Green Space.

Flexibility

2.5.9 Draft Policy EN 17 should retain sufficient flexibility to take account of circumstances where the redevelopment of a Local Green Space might be acceptable if the LGS is being replaced within the wider development. We believe that criterion 2 of Policy EN 17 may be trying to achieve this, but the current wording could be interpreted as requiring the LGS to be retained in the same place.

2.5.10 There may be circumstances where the re-provision, and indeed potentially the expansion of Local Green Space may be more appropriate, or could lead to greater benefits, if it were relocated to a different part of a larger development.

2.5.11 Our concerns would be overcome if Criterion 2 was reworded as follows:

2. The proposed development would incorporate and preserve the main features, use, and purpose of the designated area of Local Green Space within the same site or relocated as part of a wider development site, including, where already in existence, continued community access to the area. The proposals may involve plans to expand the existing Local Green Space and/or improve its existing use and purpose, such as new recreational facilities;

3 Omission Sites

3.1 Comments on Appendix 6: Submitted Sites not included in this Draft Local Plan

3.1.1 This section relates to the following sites which have not been included in the draft Local Plan:

  • 190: Land south east of Sandhurst Avenue, Pembury
  • 191: Land north of Henwoods Mount, Pembury
  • 208: Romford House, Kings Toll Road, Pembury
  • 241: Land south east of Sandhurst Avenue [1] It should be noted that site 241 is essentially an amalgam of sites 190 and 191

3.1.2 As can be seen from the submitted Vision document, these sites have been considered together (Site B in the Vision document) and so our comments below relate to all of the above sites.

3.1.3 The enclosed Vision document demonstrates how these parcels can be developed in a sustainable manner, to provide 114 additional dwellings. A comprehensive development of this area could also deliver the additional sports and recreation facilities sought in previous iterations of the Local Plan, if these are still required.

3.1.4 We comment below on matters arising from various aspects of the evidence base, in relation to these parcels.

SHELAA and related considerations

3.1.5 The SHELAA is not a policy document, but is supposed to be a technical assessment of site suitability. For this reason, it is usual for such documents to adopt a ‘policy off’ position and identify sites as being suitable for development even where those sites are not then proposed for development in the Local Plan. This normally results in a greater amount of land being found suitable for development than is actually required for the Local Plan, which then leads to judgements being made about the best planning strategy.

3.1.6 By contrast, TWBC’s SHELAA appears to only find sites suitable for development where they are then allocated, which is unusual in our experience. It begs the question whether the SHELAA findings are robust and reliable, or whether other policy objectives have influenced the findings.

Sustainability Appraisal (SA)

3.1.7 A number of sites submitted through the Call for Sites process have been assessed against the Sustainability Objectives as ‘reasonable alternatives’.

3.1.8 To determine how well a policy strategy or site contributes to each objective, a score is determined from an eight point scale of impact. The results published in the Sustainability Appraisal Consultation Document.

3.1.9 In this case, the SA scores for the omitted parcels are similar to sites that have been selected for allocation. For clarity, figure 3 below outlines the scores for the omission sites in question.

3.1.10 Whilst we do not take issue with the scoring of these sites generally, we do not agree that the sites score very negatively against the landscape and land use objectives. We provide comment on the landscape and green belt studies below to elaborate on this.

3.1.11 Likewise, the conclusions in respect of noise are confusing, as sites 191 and 208 are deemed to be affected by noise to the same extent as allocated sites, despite being further from the A21.

[TWBC: to view Figure 3 please see page 14 of full representation].

3.1.12 Taking the above into account, whilst we acknowledge that sites should not be allocated based on a favourable SA score alone, the omission sites align with the development strategy (policy STR1) and would contribute additional housing without any greater negative effects than the allocated sites.

3.1.13 It is therefore difficult to comprehend why these parcels are considered to be unsuitable for development despite having very similar characteristics to suitable sites nearby.

Landscape

3.1.14 The TWBC Landscape Sensitivity Assessment considers sites 191, 208 and part of 190 to be located within Character Area 14: Pembury Forested Plateau, sub-area Pe7, a very large sub-area which contains significant areas of woodland with very different characteristics to these sites. In terms of landscape character, sites 190, 191 and 208 have much more in common with sub-area Pe8, which includes draft allocations PE1, PE2 and PE3, than it does with much of Pe7. Indeed this is recognised in the sensitivity conclusions on p.109, where it notes that:

“Only in fields adjacent to the south-eastern edge of Pembury, where there is a closer relationship to existing development, is sensitivity to small-scale development reduced to medium.”

3.1.15 The commentary then continues on p.110 stating that:

“Development in fields immediately adjacent to the Henwood Green settlement edge, on Henwoods Mount and Sandhurst Avenue, would have the least impact on landscape character.”

3.1.16 This is a similar level of landscape sensitivity to that of sub-area Pe8, which includes draft allocations PE1, PE2 and PE3 (noting that PE3 is at the lower end of landscape sensitivity).

Green Belt Study

3.1.17 TWBC’s Green Belt study divides the Green Belt around Pembury into several zones. The sites here are shown to each form a small part of three wider zones:

  • Site 190 forms part of Zones Pe2a (shown to make a weak to moderate contribution to Green Belt purposes) and Pe2b (weak to relatively strong contribution);
  • Site 191 forms part of Zone Pe3 (weak to relatively strong contribution); and
  • Site 208 forms part of Zone Pe2a (weak to moderate).

3.1.18 We are surprised that Site 191 has been included in zone Pe3 when it appears to relate much more closely with Pe2a, with Woodside Road making a more natural boundary between the two zones. It is clear from the description of the zone set out in the Appendix to the Study that the main characteristics of zone Pe3 relate to the steep sided valley to the north of Woodside Road, abutting the Henwood Green and Heskett Park areas of the village.

3.1.19 The characteristics of parcel 191 do not relate well to Pe3 and are much more similar to those assessed within Zone Pe2a. This is especially the case in relation to Green Belt purposes 1 and 3, the contribution to which is considered to be relatively strong at Pe3 but only moderate at Pe2a. Parcel 191 is adjacent to residential development on two sides - Henwoods Mount and Woodside Close, and with the Woodside Recreation Ground also adjacent, this means that in relation to purposes 1 and 3 the parcel can sensibly described in the same terms as the rest of Zone Pe2a, i.e.:

  • In relation to Purpose 1, the parcel is adjacent to the large built-up area and relates to both the settlement and the wider countryside (Moderate rating); and
  • In relation to Purpose 3, the parcel relates to both the settlement and the wider countryside (Moderate rating).

3.1.20 We would add that the above conclusions should be reached in relation to parcel 191 regardless of which wider zone the parcel is deemed to fall within.

Noise

3.1.21 The conclusions in the SHELAA about noise appear inconsistent and unreliable.

3.1.22 The presence of the A21 will clearly have an effect on the sites closest to it. However, rightly, this hasn’t prevented draft allocations PE1, PE2 and PE3 being found suitable for development so long as suitable noise attenuation is in place.

3.1.23 As can be seen in our Vision document, parcel 190 is proposed for sports uses, as part of Countryside’s wider vision, which are much less sensitive to noise. Yet parcels 191 and 208 are also considered to be equally affected by noise from the A21, if the SHELAA is to be believed, despite being located much further away from the A21 – much further indeed than existing areas of housing. This cannot be right, and no evidence has been provided to support this view.

Highways / Access

3.1.24 It is considered that safe and suitable access can be achieved in the form of priority junction with Hastings Road. We consider this access conforms with relevant highway design standards including visibility splay requirements. Dialogue with the highways authority is on-going in relation to the access, and we will update TWBC as this continues.

3.1.25 In the meantime, we note that the SHELAA finds that site 208 lacks a vehicular access. However, as can be seen from the enclosed Vision document, when considered comprehensively with sites 190 and 191, it is clear that a suitable access can be achieved.

4 Section 6: Development Management Policies

4.1.1 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.

4.1.2 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.

4.1.3 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.

4.1.4 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.

4.1.5 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’.

4.1.6 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’.

4.1.7 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’.

4.1.8 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

4.1.9 The Council will also be aware that commencement of development is often prohibited by seasonal restrictions in respect of ecology and wider constraints.

4.1.10 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’.

4.1.11 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.

4.1.12 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.

4.1.13 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.

4.1.14 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.

4.1.15 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.

4.1.16 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.

4.1.17 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.

4.1.18 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.

4.1.19 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.”

4.1.20 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

4.1.21 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.

4.1.22 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.

4.1.23 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.

4.1.24

5 Conclusion

5.1.1 This representation has been prepared on behalf of Countryside Properties in response to the Tunbridge Wells Borough Council Draft Local Plan Consultation.

5.1.2 Countryside control various land parcels at the eastern end of Pembury and are promoting these for residential redevelopment as part of the wider development plan review. Part of this land is included as a draft allocation (AL/PE 3) whilst the wider land was also promoted via the initial ‘call for sites’ process.

5.1.3 The purpose of this representation is to provide comment on the Council’s proposed development strategy and specific proposals for allocated sites within the plan.

5.1.4 In this respect, we commend the Council for aspiring to meet their housing need in full and consider that a dispersed growth strategy represents the optimum means to achieve this. Further, we support the inclusion of our client’s land at AL/PE 3 as a residential allocation, subject to the comments in this document.

5.1.5 However, we also consider that land on parcels 190, 191 and 208 is also suitable for residential and sports related development, which should also be allocated.

5.1.6 Notwithstanding our in-principle support, we consider that the Local Plan strategy relies heavily on the delivery of strategic sites that would require the provision of supporting infrastructure. Moreover, the Council have applied overly optimistic projections to the delivery of housing for the extension of Paddock Wood and the Tudeley Garden Village, largely disregarding the NLP 2016 report and the time it would take to masterplan the strategic sites and deliver the required infrastructure.

5.1.7 In our view, a more realistic trajectory would see some housing delivered, albeit not at the suggested build out rates and much later in the plan period.

5.1.8 It should be noted that we have no in principle objection to the allocation of strategic sites of this nature. Nonetheless the extension of Paddock Wood and the garden village at Tudeley would serve to meet development needs at the latter stage of the plan period and continue past 2036. Accordingly, we would stress the importance of making efficient use of proposed site allocations to ensure that enough housing is bright forward early in the plan period. Likewise, additional sites are available within the borough that are suitable for development.

5.1.9 For these reasons, there is an opportunity to allocate land at sites 190, 191 and 208 to deliver a further 114 new homes, as well as improving local sports facilities. A Vision Document is included with this submission to demonstrate that this could be achieved, whilst delivering the required green infrastructure and without prejudice to the wider strategic and development management requirements that need to be fulfilled.

5.1.10 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.

[TWBC: see also supporting documents 'Pembury Vision' and Employment Feasibility Report].

DLP_3104
DLP_3122

Andy Bashford
Teresa Stevens

Object

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

Destroying Green Belt purely for the benefit of the new home owners, not the general public is totally unacceptable. Congestion on High St, Hastings Rd, Pembury Rd and A21 to Kippings Cross will get significantly worse than it already is. There are insufficient tall trees along a significant proportion of the site (for noise buffer), which would take many years to grow from scratch.

DLP_3351

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy. The following changes are requested:

Paragraph 3 - “Provision of links to the public footway network (to include crossing points on Hastings Road) and public rights of way and the local strategic cycle network in accordance with Policy TP 2: Transport Design and Accessibility”

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

Public Rights of Way and Access Service

The requirement to provide pedestrian/cycle links with the surrounding PRoW network (paragraph 2) is supported. However, the surrounding Public Footpaths will need to be upgraded to facilitate cycling and enable onward connectivity. It is therefore requested that contributions will be made towards off-site improvements along PRoW.

Opportunities for upgrading the PRoW network surrounding the development site and establishing a Bridleway link with PRoW WB43 should be explored and, if feasible, provided. This is because Public Bridleway WB43 provides a valuable walking, cycling and equestrian connection with Hawkenbury/South East Tunbridge Wells. Establishing higher access rights would unlock new opportunities for active travel and outdoor recreation.

Heritage Conservation

Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval.

Low archaeological potential

DLP_3470

High Weald AONB Unit

Object

The proposal is major development in the AONB which has not been adequately justified under paragraph 172 of the NPPF.

DLP_3625

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Pembury. As such, we have undertaken a preliminary assessment of the capacity of our existing infrastructure and its ability to meet the forecast demand for this proposal. The assessment reveals that existing local sewerage infrastructure to the site 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.

Proposals for 90 dwellings at this site will generate a need for reinforcement of the wastewater network in order to provide additional capacity to serve the development. This reinforcement will be provided through the New Infrastructure charge to developers, and Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of network reinforcement aligns with the occupation of the development. 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 criterion is added to Policy AL/PE 3

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in liaison with the service provider.

DLP_3853

Natural England

Object

Development of this site is considered to be major development within the AONB. Natural England advises that AONBs should not be considered as suitable locations for major development. All allocations for major development within the AONB need to be robustly assessed against the criteria set out in paragraph 172 of the NPPF. We advise further information is submitted to demonstrate that the criteria of para 172 can be met, and this should include a Landscape and Visual Impact Assessment (LVIA) in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition). Subject to the provision of further information to support this site allocation, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to this allocation.

DLP_4149

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

CPRE objects to allocations PE 1, 2 and 3 as major development in the AONB which has not been adequately justified under NPPF paragraph 172. However, if these allocations go ahead, CPRE would welcome the provision of a cycle link to Tunbridge Wells as proposed in these three allocation polices.  However, the wording on this needs to be strengthened so as to make sure this will be provided.  Chalket Lane ought to be a public bridleway, as it connects to a public bridleway, leading to the Hawkenbury area in Tunbridge Wells, which currently changes status to footpath at the parish boundary.

If these allocations do go ahead, the treatment of the proposed 40 metre-wide landscape and noise buffer will be very important.  CPRE recommends that it should consist of a mixture of native evergreen and deciduous trees, both to shield the new development from the A21 and to preserve as far as possible the perception of the AONB countryside from the A21.

DLP_5828

George Brand

Object

Policy Number: Map 87 Policy Al/PE1; AL/PE2;AL/PE3

Object / General Observation

There are statements which apply to the proposed mitigation of noise / pollution for any development emanating from the proximity of the A21. Our ability to effectively control air pollution is increasingly under threat and recent cases of fatal damage to children from this are now on the increase.

It is appreciated that this land is “available” but the cost of placing approx. 300 homes effectively hard by the A21 where the recent extension has certainly added to the traffic as the traffic jams at Kippings Cross testify, must be weighed very heavily.

DLP_6010

Katherine Wallwork

Support with conditions

90 dwellings seems too high: suggest reduction to 80.

Traffic calming: There are at present problems with many parked vehicles along much of Hastings Road, since a number of houses along the northern side of the road do not possess drives or garages. Some residents who live in Canterbury Road (where there are only two dwellings with garages) overspill parking their cars onto Hastings Road. In effect, this creates its own traffic calming. If the Authority is considering official traffic calming along Hastings Road, then it needs to take into consideration the needs of local residents who do not have anywhere else to park their cars.

Further tree planting along the southern edge of the site to act as a further screen, contribute towards the county-wide and nationwide increase in tree planting, helping to soak up rainfall and hold the ground of the southern edge of the site together.

Ensure that the appropriate level of affordable housing is adhered to.

Ensure that Pembury school and other local schools are suitable increased in size or new schools built to cater for the increase in child population. Ensure that the local GP surgery is expanded (upwards if necessary as no additional land available on current site). Ensure that improvements to sewerage services are carried out before any groundworks are commenced. Indeed, no building works should begin until all measures are in place to accept the new housing.

Improvements to cycle and pedestrian routes on the A21 dual carriageway need to be implemented.

DLP_6093

Christopher Wallwork

Support with conditions

Policy Number:  AL/PE 1, 2 and 3 

Each of these refers to exploring opportunities for provision of a cycle link to Royal Tunbridge Wells. It is likely that such a link would be deemed unfeasible in any individual case. The feasibility should be considered within the context of the three policies in combination.

Whilst there is logic to using these sites to provide additional housing, the total number of dwellings proposed is excessive for the available or even for potential infrastructure. Hastings Road is already dangerous and would not cope with the additional vehicle movements; sewerage systems in Pembury are already overloaded.

DLP_6106

Pembury Parish Council

Object

It is not clear where the access point(s) would be, but it seems imperative that the A21 junction (with Hastings Road and Henwood Green Road) is completely remodelled to allow for safe egress and access of the proposed development site.

We abhor the loss of MGB and inappropriate development in the AONB, we think the proposed housing density is too high, loss of pen space amenity would be regrettable, also we do not want to see business use on the site, so we object to the site being allocated.

[TWBC: see Pembury Parish Council's full response, including any appendices referred to in this comment].

DLP_6660

Sarah Clarke

Object

Land at Rear of High Street AL/PE 1, Land south of Hastings Road AL/PE 2, Land to south and west of Hastings Road AL/PE3

All 3 sites are south of the former A21 running through the village centre; with new and significant construction proposed. The access areas to each of the sites are already very congested with car parking along the main road in all areas where new road entrances will lead onto the main road. The land to the south and east of Hastings Road immediately adjoins the junction onto the A21 bypass, a junction which has major problems being near the Kippings Cross roundabout and the reduction from dualling to a single carriageway road. The impact of the traffic problems on the rural roads to the east of Pembury has been great, and the plan contains no solution to the inherent problems that will arise from the proposed 260 houses.

The access to the land at AL/PE1 is in the narrowest area of the High Street, and the traffic calming measures outlined will not solve the impact of the increased traffic in this area or make if safer for pedestrians and cyclists.

Policy AL/PE 4: Land at Downingbury Farm, Maidstone Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_523

Mr Neil Franklin

Object

Access for new houses via Church Road is unacceptable – the junction with Maidstone Road/Lower Green Road is already problematical due to narrowness of Church Road and parked vehicles most of the time (and residents have little choice but to park there).  How would access on to Maidstone Road from any small businesses work?  Any economic-use development must be in keeping with the surroundings. Public Rights of Way to be preserved or improved.

DLP_846

Melvyn Cole

Object

This response form is difficult for the average resident to comprehend, many are not computer literate, it would have been far better to have posted the consultation to all the residents instead of the magazine you now send. Perhaps it was your intention to not have to many responding.

My objections to the local plan in general is that any building on the green belt is not acceptable except for hospitals, schools or any public amenity.

There are two of the proposed sites that are of particular concern to me.

[TWBC: see also comment number DLP_843 on AL/PE7].

The site AL/PE4 Downingbury Farm also has some of the site 'Economic' use, one can only presume that this means a business site, when there is also a proposal for one at Colebrook. With very little unemployment in the district it is unnecessary and better off in a business park.

The 25 houses proposed with access on to Church Road would be making the junction onto Maidstone Road even more hazardous than it is at present.

A safer route would be directly on to Maidstone Road.

I agree with retaining land for the expansion of the hospice and the graveyard is worthwhile.

DLP_1449

Pembury Society

Object

4. PE4 (Downingbury Farm) is unsuitable for development. Church road, with the roads off it, is a cul-de-sac and cannot take any more traffic, not even from 25 houses. This is a very narrow road that is reduced to a single lane by residents parking and is already very dangerous. Nothing can be done about this because the cottages on the west side have no off-road parking facilities. The road is not straight so it is impossible to see if anything is coming up as you turn into it. The situation is also exacerbated by poor parking in Lower Green Rd to the north of the junction with Church Rd which means visibility to the left when exiting from Church Rd is often non-existent. If this plot is to be developed we believe that all traffic must have its access via Maidstone Road.

Also, will the owners of the old farm buildings, which are now residential and listed, accept commercial buildings on their doorstep with the inevitable traffic passing by all day?

DLP_2115

Terry Everest

Object

Strongly Object Stongest Possible

This is woodland, orchard and farmland and is well used as it is and should not be developed over.

DLP_2295

Kember Loudon Williams for Hospice in the Weald

Support

Paragraph 5.131 of the draft Local Plan is the explanatory note to draft Policy ALPE4: Land at Downingbury Farm, Maidstone Road, Pembury. As currently drafted the policy allocates the land for a mixed-use scheme consisting of residential development (C3), economic use (B1/B2/B8) and safeguarding land for the expansion of the Hospice in the Weald. The policy implications of this are addressed fully in Comment Box 2B below.

We support the draft wording of paragraph 5.131.

The Pembury site of the Hospice in Weald is the hospice’s main focus for palliative care, counselling, bereavement support and education/training – it is critically important too, to support and administer the hospice’s out-reach and medical care services, which cover West Kent and North East Sussex.

The core care facilities offered at Pembury have developed and expanded in response to local demand. Whilst the current operation of the site is manageable, in order to maintain the highest standards of care, the facility is reaching a point where in the near future it will be necessary to expand: certainly within the plan period to 2036. This may include the provision of a children’s hospice: specialist facilities that are seriously lacking in Kent / Sussex.

We will also look to provide a second ‘Cottage Hospice’ once the newly opened Cottage Hospice in East Sussex has proved that the model works. This will be in the next 5 to 10 years and we would look to this site first.

The physical constraints of the Pembury site are such that opportunities for growth are very limited or do not exist at all. The site is triangulated and is bound to the east by Maidstone Road and to the west by the rear gardens of properties fronting onto Elmhust Avenue: the two converge at the southern-most end of the site. Other than relocating the entire facility or providing further facilities off-site elsewhere – both costly and inefficient solutions – the only real growth avenue open to the hospice is to expand sensitively to the north. To that end we are supportive of the Council’s forward-thinking solution to safeguard part of site AL/PE 4 for potential future growth.

Whilst welcome, the hospice is keen to ensure that any future expansion to the north of the current operation does not impact on the visual or residential amenities of its neighbours to the north. In view of this, we would invite the Council to consider amending paragraph 5.131 to create an additional safeguard.

Recommendation: Paragraph 5.131 be amended to add the following text (or similar) into the second ‘bullet’:

“Any necessary expansion of the Hospice in the Weald’s facilities into the safeguarded land should be subject to a landscape strategy to include the retention / provision of a landscape amenity / buffer strip on the northern and north western boundaries of the site with Downingbury Farmhouse and adjoining properties to the north, to include where appropriate the retention of established trees.”

This is to afford additional protection of the visual and residential amenities of the occupiers of the houses located to the north and north west of the site and protect the setting of the heritage assets.

DLP_2304

Kember Loudon Williams for Hospice in the Weald

Support

Policy Number: AL/PE 4

Policy AL/PE 4 of the Draft Local Plan allocates the land at Downingbury Farm, Maidstone Road for mixed-use development comprising housing and employment. The policy also safeguards an area of land for the future expansion of the Hospice in the Weald. The following representations should be considered alongside those made on Paragraph 5.131 in Comment Box 2A.

Obviously the Hospice in the Weald’s interest and expertise lies in the specialist fields of health and palliative care. It does not extend to the needs of land for housing and employment provision and/or the environmental merits or otherwise of introducing housing/employment uses on the western land parcel of the draft allocation in AL/PE 4. In view of this the following submissions relate solely to the need / merits of creating a safeguarded area of land to support the future needs of the Hospice.

At present the parcel of land to the north of the Hospice lies within the Green Belt and part of the site is within the Area of Outstanding Natural Beauty. It is important, therefore, that in this period of review and in re-considering the development strategy for the Borough to the 2036 horizon, that all interests are carefully considered and planned for in advance.

Key to this is foresight and flexibility. In this regard, Part (d) of paragraph 81 of the National Planning Policy Framework (NPPF) requires that planning polices, ‘..be flexible enough to accommodate needs not anticipated in the plan .. and enable a rapid response to changes in economic circumstances..” Flexibility, therefore, and the ability of land use policies to be able to respond positively to changing physical, economic, social and political circumstances, quite rightly, lies at the heart of the Government’s Framework for growth and change. To these ends we are supportive of Policy AL/PE4, which recognises the social importance of the Hospice in the Weald to the communities of Kent and East Sussex and directly responds to the unique physical constraints and limitations of the Hospice’s site in Pembury.

The flexibility and opportunity afforded by the policy is welcome and aligns, we believe, with the provisions of the National Framework. From an operational standpoint, it is essential that the Hospice has the facility to be able to expand responsibly and sensitively in Pembury– the village become its centre of operation. The current site is reaching capacity and there will come a time in the near future (certainly within the plan period to 2036) that the facilities on the site will need to be improved and expanded, with the possibly of introducing new, ancillary specialist services such as a children’s hospice to provide support for seriously ill children, young people and their families. Consideration of the latter simply would not be possible without the potential access to the safeguarded land.

The introduction of any additional care facilities or a specialist children’s unit would benefit from the existing professional expertise, experienced highly strained staff and volunteers and common facilities such as servicing, storage, café, parking, etc on the main site. The integration of current and future uses, the promotion of dual use facilities and the economies of scale all support the continued and efficient running of the hospice’s core facilities. The integration of facilities and services is, therefore, key and can only be achieved efficiently through carefully planned expansion at Pembury. The safeguarding of the land to the north provides the flexibility and the facility to achieve this should the need arise over the lifetime of the plan.

To this end the provisions of Policy PE4 and the safeguarding land to the north of the Hospice for future ‘hospice-related uses’ are fully supported.

Recommendation: Draft Policy AL/PE 4 be revised (along with paragraph 5.131) include the provision of a landscape strategy to include the retention / provision of a landscape amenity / buffer on the northern and north western boundaries of the site with Downingbury Farmhouse and adjoining properties to the north, to include where appropriate the retention of established trees.

DLP_2625

Richard Burdge

Support

Comments in support of Policy AL/PE 4 – Land at Downingbury Farm, Maidstone Road, Pembury. of the Draft Local Plan (Regulation 18)

Identity of commenting party and reason for interest/comment

These comments are made by Richard Burdge and Amanda Perkins (Nee Burdge) who are the majority and controlling owners of all the land at Downingbury Farm, Maidstone Road, Pembury, Kent. TN24AD, except the existing residential properties and their curtilages. (see Plan 1). This land was identified in the SHELAA as comprised of two sites: 373 and 375.

Our family has a long history with Downingbury Farm. Our parents owned and farmed the land since the 1980’s and our family lived at the farm for many years. Our father died in January 2019, passing control of the land to us.

We would like to reaffirm that all the land in our ownership and control is available immediately for development should it be included in the Local Plan submission.

The land at Downingbury Farm used to form part of a viable smallholder fruit farming business with a retail sales farm shop. In the 1990’s the farm was divided by the construction of the A228 Pembury bypass which consumed some of the land and started to reduce its viability as a working farm. The farmed area was further reduced by the building of the Hospice in the Weald.

In 2017, a large proportion of the remaining land, to the north of the A228, was sold prior to our control and ownership. This meant the residual area of land (bounded by Church Road/Rowley Hill to the West, the A228 to the North, Maidstone Road to the East and existing residential development and the Hospice in The Weald to the South) became isolated on the edge of the built area of Pembury. This land is increasingly unviable for agricultural use, because of the reduction in scale, leading to its unsuitability for modern farming practices.  We anticipate a continued decline in its use for this purpose. There is an increasing risk that this land becomes further sterilised, dilapidated and unkempt.

Consequently, we have been exploring alternative uses for the land and we support the proposals put forward for use of part of this land in the TWBC draft local plan to meet the pressing need for housing, economic development and social benefit.

As our family has long ties with the Pembury, we intend to work with the local authorities to ensure that the land be developed sensitively in terms of landscape, its environment, ecology, infrastructure, social benefit and local needs and we believe we have reflected this in our comments.

General Comments

We support the Policy AL/PE 4 as laid out in the Draft Local Plan.

We are not opposed to proposed safeguarding of part of the land for potential use for a hospice, although we feel the current proposal could be improved in this regard which we cover in our Enhancements section below.

We support the mixed-use scheme as proposed in the policy, although we feel there may be some alternatives that could be explored which we cover in our Enhancements section below.

We support all the Specific Policy Requirements No’s 1-10 and we feel there are opportunities to extend these which we cover in our Enhancements section below.

With regard to point 8 of the specific requirements: the historic farmstead and listed farmhouse and buildings themselves have all been converted into dwellings and are well protected in separate private ownership. These historic conversions align well with the guidance in the Supplementary Planning Document – Farmsteads Assessment Guidance for Tunbridge Wells Borough (February 2016). The farmstead residences are well defined as a residential enclave, they all have generous private amenity space within their curtilage and are consequently inherently protected from new development encroachment becoming too close (see Plan 2).

We recognise the requirement to protect the sensitive landscape value of this farmstead, particularly from the best view afforded by the topography of the land i.e. from the East along the farm access road onto Maidstone road and we make specific suggestions that could sustain this protection in our Enhancements section below.

The green belt was implemented in the 1950’s and does not take into account the changes in land use and landscape since. We support the proposed amendment of the metropolitan green belt boundary on Downingbury Farm, particularly as this recognises the land was significantly altered by the construction of the A228 in the 1990’s which created a clear hard boundary on the land, dissecting a working farm and associating some of the land more closely with the developed area. We note that the proposed amendment repositions the green belt boundary to a new defensible boundary line of the A228 which reflects the guidance of the National Planning Policy Framework.

Pembury Parish Council and Local Support

We have been in close contact with Pembury Parish Council throughout the consultation process and have attended their meetings in connection with the Draft Local Plan.

Pembury Parish Council has consulted widely with the local community through an open public meeting, a survey gathering comments both online and in paper format and various meetings of the planning subcommittee and full Council.

Of all the Draft Local Plan Policies proposing sites in Pembury, the local feedback is on balance supportive of the Policy AL/PE 4. We understand that in Pembury Parish Council’s comments on the Draft Local Plan, reflecting the local opinion, they raise no in-principle objections to Policy AL/PE 4, submitting an official comment of “neutral”. There has been some specific feedback including access and the use of Church Road, access across Downingbury Farm itself and the mix of development proposed, with some respondents suggesting more housing could be accommodated on this site in comparison to the concentrations proposed in sites at the southern end of the village. We have listened to the support from the local community, and the specific comments and we have offered some potential alternatives in our Enhancements section below.

We are also aware of Pembury’s needs for community facilities for social benefit such as new medical facilities.

Potential Enhancements

Introduction

Policy AL/PE 4 has included only some of the remaining land at Downingbury Farm by including all of Site 375 and part of Site 373 submitted in the call for sites. We are concerned that the partial inclusion of Site 373 will further reduce the viable use of the remainder of Site 373 for any productive purpose and this land could become sterilised and consequently dilapidated.

With regards to the landscape sensitivity of the land, we feel it important to protect the landscape view, particularly the view of the historic farmstead from the East and Maidstone road.

The safeguarded area designated currently for “Hospice in the Weald” could be designated more generally for potential more general community facilities including but not exclusively a hospice. We feel that this current area is ample in size (larger than the existing Hospice in the Weald site) and if developed in full for the safeguarded purpose, it could reduce the landscape value of the historic farmstead and listed buildings when viewed from the East along Maidstone Road. This could present challenges when meeting AL/PE 4 point No 8 of the specific requirements –“Design Proposals to consider and minimise the impact on the listed farmhouses and buildings within the site”.

We also recognise the concerns raised by the local community of the potential for increased traffic using Church Road.

Alternative Proposals

We propose that the site be enhanced by the inclusion of all of Site 373 in the Policy.

We believe this would create the opportunity to significantly enhance the site in terms of protection of landscape value, environment, ecology, transport design and accessibility, provision of public green space and recreation, social benefit and optimal development mix and land use of the site.

We have developed a series of plans which build up to show how these enhancements could be achieved.

Plan 2 shows the existing protected residential enclave which preserves the original historic farmstead in converted residential dwellings

Plan 3 shows the current AL/PE 4 land with the safeguarded land for the Hospice

Plan 4 shows a proposed enhanced AL/PE 4 that includes all of site 373. This proposal includes larger areas of Open Space and Landscape Buffer improving alignment with Policy OSSR2. It also improves alignment with Policy EN11 by creating protected spaces for the preservation of biodiversity and extended ecological mitigation, including the existing pond near the entrance onto Maidstone Road. This proposal also enhances the protection of the landscape view, particularly of the historic farmstead from the East. This proposal reduces the size of safeguarded land currently designated for the Hospice and redefines this land as safeguarded land for “community facilities” rather than just a hospice. This broadens the scope of the draft local plan and presents the opportunity of this land providing a site for a community facility (which might be a hospice or another health facility) yielding social benefit for the local community.

The extended area of Open Space and Landscape Buffer to the North alongside the A228 creates a noise and pollution buffer and a potential area for recreational use.

This proposal also makes more land available between Maidstone Road and the A228 to the on the east side of the site for housing or economic development.

Plan 5 shows the creation of two new roadways across the site, creating a new highway access onto the planned Colts Hill bypass junction with the A228 and Maidstone Road. This would enable vehicular traffic to easily access the North of the site. A new road branching off the existing Maidstone Road access road could enable vehicular access to the South of the site along an existing farm road, potentially alleviating the requirement to use Church road for vehicular access to this site. We believe this improves the site in alignment with Policy TP2 and the offers increased links to the wider public right of way network. The new access roadways could be used as walkways and cycleways to link to the main public transport provision along Maidstone Road. Walkway and cycle access would be available in addition onto Church Road and Rowley Hill. All existing public rights of way would be retained and indeed enhanced in accordance with Policy WT218.

These alternative proposals would move the boundary of the metropolitan green belt and the AONB to new defensible boundary of the A228 to the North, Maidstone Road to the East and Church Road/Rowley Hill to the West reflecting the guidance within the National Planning Policy Framework.

The development mix on the South West of the site could see the housing allocation increased as an extension of the existing residential development to a new residential boundary in alignment with the furthest extent of existing residential development boundary along the West side of Church Road/Rowley Hill denoted by the end boundary of the existing back gardens. We have marked this new residential boundary on the plan as a dotted line.

The remaining open land across the site could be allocated for economic use to the North and West side of the site and housing, economic use, or a mix of the two to the North and East side of the site.

DLP_2648

John Duffy

Object

Access proposed for the 25 homes by Church Road is already a dangerous area with traffic turning blind into it from Maidstone Road travelling South towards the village centre. The residential parking is by neccesity on street and is already heavily oversubscribed. These are quiet residential streets that are already overlaoded and in close proximity to a primary school and thereby will produce additional traffic at times of greatest risk to the children attending. An ill thought out proposal that should be consigned to the proverbial bin of planning ideas that are inappropriate and impractical. The site allocation should not be proceeded with in the final plan

DLP_2802

Nicola Duffy

Object

25 residential units ecxiting onto Church Road is a recipe for accidnts and congestion, the proximity of the nearby primary school and additional traffic departing onto Miadstone Road at their arrival time is a significant risk. Church road is a quiet residential road that is heavily reliant on roadside parking due to the nature of the housing along its length. Access to and from this road is onto a dangerous junction and the additional residential traffic will exacerbate the danger and risks to pedestrians, residents and other road users

DLP_3105
DLP_3123

Andy Bashford
Teresa Stevens

Support with conditions

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

Access in/out of Church Rd to Maidstone Rd is already difficult. This will make things worse.

Allowing for extending the Hospice is a good idea.

DLP_3352

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy. The following changes are requested:

Paragraph 4 – “Provision of links to the public footway network and public rights of way and the local strategic cycle network in accordance with Policy TP 2: Transport Design and Accessibility”

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

Public Rights of Way and Access Service

The specific references to PRoW in paragraphs 2 and 3 are supported.

Heritage Conservation

Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval.

Low archaeological potential

DLP_3626

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Pembury. As such, we have undertaken a preliminary assessment of the capacity of our existing infrastructure and its ability to meet the forecast demand for this proposal. The assessment reveals that existing local sewerage infrastructure to the site 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.

Proposals for 25 dwellings at this site will generate a need for reinforcement of the wastewater network in order to provide additional capacity to serve the development. This reinforcement will be provided through the New Infrastructure charge to developers, and Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of network reinforcement aligns with the occupation of the development. 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 criterion is added to Policy AL/PE 4

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in liaison with the service provider.

Southern Water is the statutory wastewater undertaker for Pembury. As such, we have undertaken a preliminary assessment of the capacity of our existing infrastructure and its ability to meet the forecast demand for this proposal. Our assessment has 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/PE 4

Layout is planned to ensure future access to existing wastewater infrastructure for maintenance and upsizing purposes

DLP_4150

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

Recognising that there will need to be some development at Pembury, this site seems a sensible option, albeit in the Green Belt and AONB.  We support the safeguarding of part of the site for possible expansion of the Hospice, which will surely be needed with the expansion of the population of the borough that is implied by the housing figures.  However, the site is adjacent to ancient woodland and Church Road (currently stopped up to vehicles) is used as, and connects with, an important public bridleway.  These aspects need to be conserved and their tranquillity protected.  Therefore we strongly object to the proposal for the access to the residential units to be accessed via Church Road and consider that all the vehicular access should be from the Maidstone Road.  It is in any case not clear to us how it makes sense for the business units proposed to be located in the northwest of the site to be accessed from Maidstone Road (i.e. via the southeast of the site, going through the area safeguarded for the Hospice and then through the south of the site) when the residential units will be in the south of the site which vehicles using a separate access to the business units would have to traverse.

We recommend that a landscape buffer be required between Church Road and the new residential and business units, to shield them from Church Road/bridleway and the adjacent woodland.

DLP_4512

Richard Promfrett

Object

  1. What is the point of having Green Belt and AONB if they just get built on anyway? Surely it must now be recognised how important it is to keep and preserve any green spaces we have left. Mitigation can only go so far.
  2. Maidstone road already has its problems. Parking is an issue, and parking on the junction with Church road, and on Lower Green road, is a hazard. Introducing more homes, businesses, and traffic can only make this worse.
  3. Church road is not suitable for access to this development. Parking is a big issue again - the traffic is basically one way all the time. It has been a quiet road since the bypass was built and we'd like to keep it that way!
  4. It's good the public right of way will be retained, but I fear it's character will be lost.
  5. Nice to see ecological mitigation but we still worry for the impact on the biodiversity of the area. Deer and rabbits are seen, and I'm sure much more calls the farm home.

DLP_5794

Hugh Boorman

Object

11 MAP90 Policy AL/PE 4. With the utmost of respect the comments printed on Page 333 tell me that no one has visited Church Road to experience the chaos that would be introduced to this road with the introduction of additional traffic, not only that of new residents but that of visiting vehicles. You really do need to reassess this proposed site and access.

DLP_5830

George Brand

Object

Policy Number: Map 90 Policy AL/PE4

Object / General Observation

“Kent Sir…Everyone knows Kent..cherries, apples, hops …” so wrote Kent resident Charles Dickens

1. The Grade 2 Historic Buildings in this group of 3 Oasts, and 17thC Barns together with the Grade 2 * Farm House represent all that is quintessentially Kentish history. The importance of maintaining the setting and surroundings of this group of historic buildings cannot be underestimated, once changed and the surrounding land lost for agricultural purpose another part of Kentish history will be forever damaged and lost. Once lost it never be restored.

2. The area to the North of The Hospice in the Weald being designated as to be safeguarded for the Hospice for possible development is to be supported. However the present surroundings as being rural and tranquil should be maintained for the benefit of both the residents and their families. The proposal for housing to the West of the Hospice would undoubtedly be detrimental to the Hospice as would the creation of B1/B2/B8 development. Construction and subsequent vehicle traffic could only materially diminish the immediate surroundings.

The Hospice in the Weald is without doubt the most widely supported charity in in this part of the County and any proposals of a negative nature should be resisted.

3. Within the proposals here access is to be via Church Road and or Maidstone Road. Any visual appraisal of Church Road ( the clue is in the name ) will make it abundantly clear that it was once merely an access to the approx. 900 year old St Peters Church to the North. Narrow and already crowded by the gradual development either side, introduction of even more usage is really a very bad idea.

Pembury has a history of very nearly 1000 years and what still remains of its historic buildings and agricultural way of life should not be diminished and damaged.

The plans for AL/PE4 show a very marginal benefit to the overall housing need but at a highly significant cost and as such this proposal should be withdrawn.

DLP_6012

Katherine Wallwork

Support with conditions

Further tree planting along the northern edge of the site to act as a further screen as necessary, contribute towards the county-wide and nationwide increase in tree planting, helping to soak up rainfall and hold the ground of the northern edge of the site together.

Ensure that the appropriate level of affordable housing is adhered to.

Ensure that Pembury school and other local schools are suitable increased in size or new schools built to cater for the increase in child population. Ensure that the local GP surgery is expanded (upwards if necessary as no additional land available on current site). Ensure that improvements to sewerage services are carried out before any groundworks are commenced. Indeed, no building works should begin until all measures are in place to accept the new housing.

Improvements to cycle and pedestrian routes on the A21 dual carriageway need to be implemented.

DLP_6090

Ian White

Object

REFERRING to Map 90. POLICY AL / PE4 Land At Downingbury Farm.

The proposal ‘Safeguards’ land for the ’Potential expansion of The Hospice In The Weald which I would strongly support as the Hospice is a very important part of village life and has strong support from the community of Pembury.

I do not support any other use of the land designated PE4 especially the suggested 25 residential Dwellings and Economic units, assumed to be Business or Industrial Units.

The amenity of The Hospice in The Weald and in particular its views over the fields and woodlands must be preserved to the benefit of its patients. It cannot be called ‘In The Weald’ if its outlook is over houses, and residents cars or indeed industrial units with the inevitable high traffic flow that economic units would attract.

Given that this land is currently Green belt agricultural land having been farmed for many years, I fail to see how it can now be given over to residential and economic use.

Once agricultural land has been taken it can never be restored. It has been the policy of successive governments to encourage reduced ‘Food Miles’ and to support local farming, therefore, to build on fertile farm makes no sense.

Kent is the Garden of England and we must do all we can to preserve and encourage future generations to take up farming which cannot happen if the land is not available. The local land based college, Hadlow College, is the only one of its kind in Kent and is forefront in looking at new technologies and practices whilst working with the local young farming groups to develop their skills.

Understandably the local council planning department and English Heritage strive to ensure buildings with listed status are stringently protected from inappropriate changes to their historic importance. However, it would appear that this has been overlooked in allowing the plans to be put forward for housing and business units to be built within the setting and surroundings of this historic farmstead.

All of the properties on Downingbury Farm are listed buildings within this historic farmstead comprising an iconic Kentish Oast House with 3 roundels, c 17th century Threshing Barns and a Grade II* Farmhouse, (there are only 2 grade II* listed properties in Pembury and only 6% of all buildings are listed grade II* in the UK).

A decision made by The Court Of Appeal ( Barnwell v East Northamptonshire DC204) Clarifies that ‘Decision Makers’ MUST give ‘Considerable Importance and Weight’ to the desirability of preserving the setting of listed buildings when carrying out the balancing exercise.

In addition the whole area within Downingbury Farm has mature trees that should be preserved for the benefit of all. The whole site borders ancient woodland which is both crucial to wildlife, the environment and the wellbeing of residents who use these green areas for recreation.

According to the policy, access for the 25 houses would be via Church Road. This is already a very busy and dangerous entrance/exit and at the top of the road it is very narrow allowing only single file traffic due to inadequate parking for the houses currently there. Any additional traffic flow would be particularly dangerous to children and parents attending the local school which is sited at the top of the junction.

Finally with the above considerations I find that this policy is lacking in detail. There are no clear details on precisely where the economic units will be, how or where access will be for these or indeed what type of use will be granted.

The area shaded in blue on Map 90 is designated as safeguarded for the Hospice, therefore, no access or building other than that associated for the Hospice should be allowed. The position of the 25 houses is not clear or indeed how you will ensure that the additional traffic flow will be safely managed.

This policy is not adequate as it stands.

DLP_6107

Pembury Parish Council

 

We are unclear about the exact positioning on the site of the residential and business use buildings, and their respective points of access. We note the safeguarding of some MGB land for possible future expansion of the Hospice.

There are concerns that the residential dwellings would be accessed off Church Road. The top of the road is narrow with cars parked either side and is close to the Pembury School. This junction is also a blackspot for accidents. Subject to satisfactory access, we are neutral about this site.

[TWBC: see Pembury Parish Council's full response, including any appendices referred to in this comment].

DLP_6663

Sarah Clarke

Object

Land at Downingbury Farm, Maidstone Road AL/PE4

This area is immediately adjacent to the Hospice in the Weald. There is no access to the site apart from the farm entry and limited made up track to the farm shop. While the use of the site preserves the future of the Hospice, the mixed commercial (business) and residential use could impact on the Hospice itself. The proposed route for residential access to Church Road is again onto a very narrow road, unsuitable for increased traffic.

DLP_7133

Jonathon & Zamira Benthall

Support

Policy AL/PE 4 (land at Downingbury Farm, Maidstone Road, Pembury)

1. We strongly endorse the Council’s decision to safeguard the land to the North of Hospice in the Weald for future needs of the Hospice as and when they arise. The Hospice has a very high reputation for the quality of its medical and caregiving services, which are much appreciated and supported within a wide radius. It has also been a good neighbour as regards its physical footprint, by designing buildings and by landscaping trees and a garden that tone in as far as possible with its surroundings. Its name "Hospice in the Weald” is very much part of its image and branding. If it were to lose its view of fields, woods and oast-houses to the North, to be replaced by a view of houses and offices, the name would cease to be justified. The future needs of the Hospice should, in our opinion, take precedence over other considerations.

2. A second priority – subject to the above – should be the preservation of agricultural land for food production. There is now a national trend towards seeking to produce more food locally, in order to reduce food imports and transportation costs. The western part of the PE 4 plot (next to the North Pembury Bypass) is not required for expansion by the Hospice, and we urge that this priority for agricultural land should apply.

3. A third priority should be to preserve the amenity of the setting and surroundings of the historic farmstead, Downingbury Farm, in all directions – including both sections of the PE4 plot and also the small triangular plot of woodland just to the south of the Downingbury Farm House curtilage. All the buildings in the historic farmstead are listed. The Farm House is listed as Grade 2* – the only building in the Parish of Pembury so listed, apart from Pembury Old Church. The pond next to Maidstone Road (which is outside the allocated area) should be regarded as an integral part of the historic farmstead, since oast-houses were always built near a pond because of the fire risk. We understand that a Court of Appeal decision in 2004 (Barnwell v. East Northamptonshire DC) requires planning decision makers to give “considerable importance and weight” to the desirability of preserving the setting of listed bulidings.

4. Insofar as nearly all the allocated site is within the Green Belt and also AONB, this status supports the argument put forward in para. (iii) above.

5. With regard to paras. (i) and (iii) above, we urge that mature trees of good quality, both within the allocated site and adjoining it, should be retained. We have already suggested a TPO with regard to a mature oak tree on the southern apex of the small triangular plot of woodland which is within the allocated site – and almost adjoining the Hospice’s garden at the north-west corner of their land. We understand from the Hospice’s officials that they would strongly support the grant of a TPO for this threatened tree.

6. The question of access to any proposed development is a cause for concern, but we cannot comment further as there is no detailed information so far available.

Policy AL/PE 5: Land at Sturgeons fronting Henwood Green Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_455

Mr Nick Sturcke

Object

I have been  a resident of Kings Toll Road at the eastern end of Pembury for 32 years.

The above sites propose the addition of up to 279 new residential properties  close to the centre of Pembury Village, all of which will will need access via Hastings Road/Pembury High Street. They clearly contradict the enhancements listed in Policy STR/PE 1, 5; and should not be included in the Local Plan.

Pembury High Street and Hastings Road are the main west to east route through the village for pedestrians, cyclists, buses and other traffic. Vehicles are parked for much of the day along most of the length of Hastings Road already hindering the free movement of all traffic, including cycles and buses. There is insufficient space for effective cycle lanes along Hastings Road.

The addition of up to 279 properties, an increase in population of perhaps as many as 700, all of which will need access to Hastings Road and Pembury High Street, will result in bringing traffic on this route to a near standstill. The need for the traffic calming measures included in the Plan will be negated by the congestion caused by the additional traffic from the nearby new developments. In effect, traffic from the east end of Pembury Village will be reduced to accessing Tunbridge Wells and elsewhere by using the dangerous Henwood Green Road/A21 junction and travelling along the A21 via Kippings Cross where there are substantial on-going tail back problems which Highways  England are unwilling to address for the foreseeable future.

It will certainly be more difficult for cyclists to ride through the village as there is clearly no room for a dedicated cycle lane along Hastings Road/ Pembury High Street.

The proposed developments are in clear contradiction to the aspirations of the enhancements listed in Policy STR/PE 1, 5 and the measures to enhance bus travel included in the above individual sites. They should not be included in the Local Plan.

DLP_1451

Pembury Society

General Observation

5. PE5 (Sturgeons) currently has permission for development that includes an element of ‘affordable’ housing. This ‘affordable’ element must be retained and not be overridden by another application, similar to the one that has recently been withdrawn, where all units were to be at market rate.

DLP_3353

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy. The following changes are requested:

Paragraph 4 – “Provision of links to the public footway network and public rights of way and the local strategic cycle network in accordance with Policy TP 2: Transport Design and Accessibility”

Additional paragraph - Small business units to be located on the north western part of site (subject to evidence of demand) with adequate on site parking and servicing facilities

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

Heritage Conservation

Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval.

Low archaeological potential

DLP_5792

Hugh Boorman

Object

7, The impact of additional traffic anywhere on Henwood Green Road will be catastrophic especially with the proposed development on Map91 Policy AL/PE 5, which will result in more traffic coming onto the road opposite Canterbury Road which is already a traffic hazard for local residents and pedestrians with many residents having to park on the pavements. That stretch of Henwood Green Road, like many other parts is already a stop start situation.

DLP_6014

Katherine Wallwork

General Observation

This proposal for 19 dwellings at the Sturgeons site was in fact withdrawn, so it is surprising that it is still included in the Draft Local Plan. Both the number of houses proposed for the site, the lack of affordable housing proposed, the insufficient car parking space allocation, the site line at the front of the site and the later proposal for a zebra crossing were all inappropriate for the location. Also, the height of some of the proposed properties and the impact on listed buildings nearby.

It is not possible to object to a policy that has already been withdrawn.

DLP_6094

Christopher Wallwork

General Observation

The policy states that this site has planning permission for 19 dwellings, whereas the documents on the TWBC planning website state that the application was withdrawn by the applicant. It is not possible to support or object without details of a proposed development.

The withdrawn proposal provided very inadequate parking for the number of dwellings, would have resulted in increased dangers on Henwood Green Road, failed to comply with the building line of existing properties (including listed buildings) and had several other major failings.

DLP_6108

Pembury Parish Council

 

Given that planning permission has already been granted for housing on this site, we find this allocation acceptable provided that the stated Affordable/Social Housing quotient is included.

[TWBC: see Pembury Parish Council's full response, including any appendices referred to in this comment].

Policy AL/PE 6: Land at Tunbridge Wells Hospital, Pembury and adjacent to Tonbridge Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_347

Charlotte Raleigh

Object

I strongly object to developing the field around Sandhill Farm. This is an important area for wildlife and is part of the RSPB Nature Reserve and importantly forms part of the water catchment area for Pembury Reservoir. (I know that the land does not belong to the RSPB). The field is an important hunting ground for large raptors and is part of a heathland regeneration scheme. It is not an 'empty' space on the map. Newbars Wood and this field should be preserved to provide sanctuary for wildlife, and amenity and wellbeing for people. As well as providing good quality water to the reservoir.

DLP_524

Mr Neil Franklin

Object

This site includes Public Footpath WT216 which needs to be preserved or improved.

DLP_1452

Pembury Society

General Observation

6. PE6 (Health Hub – the Hospital) is entirely within the Green Belt and any further development of this plot would lead to significant loss of ancient woodland. Also, as indicated above (Overview 2), if this site is further developed it will generate more traffic and this will lead to greater delays for access by emergency vehicles. However, the present car parking capacity at the hospital is inadequate for even current usage and more is needed in the hope that the overspill into Pembury High St will be reduced.

DLP_2116

Terry Everest

Object

Object strongly

The woodland and green space must be preserved here, these are very nice natural spaces around this site and have public footpaths on and are well used so no further development outside of the hospital grounds can be supported.

DLP_2479

TWBC Property and Estates

TWBC

Support

Support

DLP_3106

Andy Bashford

General Observation

Use of Green Belt land purely for the benefit of the Hospital and therefore the public is OK

DLP_3124

Teresa Stevens

General Observation

Use of Green Belt land purely for the benefit of the Hospital and therefore the public is OK

DLP_3354

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy. This policy should be split into 3: Hospital land, Notcutts and Owl's Nest. Preferable in highway terms to understand proposed land use of each site and respond accordingly.

The following changes are requested:

Paragraph 5.133: “Tonbridge Road crosses through the site, linking this allocation to the A21, a major Public Highway controlled by Highways England”

Paragraph 2 – Provision of a new/improved segregated cycle route to Royal Tunbridge Wells

Additional paragraph - Maintenance and enhancement of, and/or linkages to, public footway network, public rights of way

Additional paragraph - Proposals must be informed by a Transport Assessment and Travel Plan...

Additional paragraph - Access arrangements to Owl's Nest to be incorporated into the existing signalised junction serving the hospital

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

Public Rights of Way and Access Service

The specific reference to PRoW in paragraph 1 is supported.

Heritage Conservation

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

There is potential for prehistoric remains and there may remnants of the earlier hospital structures. If remains survive they would be of local heritage interest and need to be appropriately considered

An Archaeological DBA would be helpful with clarification of the extent of previous ground disturbance.

DLP_3471

High Weald AONB Unit

Object

The proposal is major development in the AONB which has not been adequately justified under paragraph 172 of the NPPF.

DLP_3854

Natural England

Object

Development of this site is considered to be major development within the AONB. Natural England advises that AONBs should not be considered as suitable locations for major development. All allocations for major development within the AONB need to be robustly assessed against the criteria set out in paragraph 172 of the NPPF. We advise further information is submitted to demonstrate that the criteria of para 172 can be met, and this should include a Landscape and Visual Impact Assessment (LVIA) in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition). The Landscape Sensitivity Assessment considers this site to have medium-high sensitivity for medium scale development, and states that there is little scope for more large scale development without significant impact on this containment and wooded setting. Subject to the provision of further information to support this site allocation, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to this allocation.

DLP_4151

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

The site is in the Green Belt, it lies partly within the AONB, it includes an SSSI and it includes and lies adjacent to ancient woodland.  It is an extremely sensitive site where arguably any development will conflict with paragraph 11b oo the NPPF.

With the proposed expansion of the population of the borough that will flow from the very large increase in housing proposed over the Plan period, and the hospital’s facilities already overwhelmed at times, it seems very likely that some expansion of the hospital and its associated parking and other facilities, including better public transport to serve the hospital, will be needed.  Therefore we would not object in principle to the safeguarding of this site for most of the purposes stated in the proposed allocation, which are undoubtedly preferable to the proposal which was previously made for extra care housing on the Owlsnest part of this site.  However, we consider that allocation at this stage is inappropriate, given the extreme sensitivity of the site and the fact that there do not appear yet to be any firm plans for any of the stated purposes.  There needs to be full and clear evidence of justification for this allocation before it is made.

We note that the hospital’s key worker housing in Pembury has previously been sold off as market housing and we therefore have reservations about the proposal to use the site for possible key worker housing, given the strong possibility that the same could happen again.

We are concerned that the part of this policy referring to developments larger than 100 residential units could encourage applications for major developments which are thoroughly unsuitable in the AONB.  Arguably, for sustainability, any development of more than 20 dwellings in villages and the rural area ought at least to provide some employment possibilities, for example through live/work units.

DLP_4513

Richard Promfrett

Support with conditions

More Ancient woodland being destroyed. This has to stop. It cannot be replaced, it's has grown and evolved over years and years, the soil structure for example (centuries of undisturbed soil and natural wood decay) cannot be replicated. We must preserve all the Ancient woodland left; they are, as the Woodland Trust says "Unique and complex communities of plants, fungi, and other microorganisms,.... They are our most complex and richest habitat."

I understand the need for expanding the hospital, so I might support this if the Ancient woodland can be preserved.

DLP_5832

George Brand

Support with conditions

Map 92 Policy AL/PE6

The proposals here are overall in support of Pembury Hospital and its, and therefore community, needs for the future.

Its proximity to the newly improved A21 for urgent cases by ambulance is positive.

However movement to the South and West of vehicles is significantly hampered by the bottleneck of the A228 and its junction with the A264 leading into the main residential area of Tunbridge Wells.

Any development to the East and in particular the proposal of the Tesco site being used by the Hendy Group can only be viewed as highly detrimental and dangerous to access to the Hospital.

DLP_6016

Katherine Wallwork

Support with conditions

That all mitigations must be adhered to and that sewerage and treatment works must be undertaken before groundworks are commenced. All transport links to be improved prior to works being commenced.

DLP_6109

Pembury Parish Council

 

We recognise that in coming years there could be a need for a variety of hospital linked uses of the undeveloped parts of this site, which we note would remain in the MGB. Such acceptable uses could include key worker accommodation, hospital expansion, clinical facilities, medical research/education centre, additional parking and a public transport hub.

[TWBC: see Pembury Parish Council's full response, including any appendices referred to in this comment].

DLP_6664

Sarah Clarke

General Observation

The land is designated to provide for increased medical and hospital use, for members of staff and for future clinical facilities. Provided that there is no change in designation with a Green Belt designation preserved, and release only for this use, there is no comment. There would need to be significant improvement to access to the highway, perhaps with some form of ambulance route from and to the hospital along the A264.

DLP_7022

Turnberry for Hadlow Estate

Support with conditions

Policy Number: AL/PE 6 Land at Tunbridge Wells Hospital, Pembury and adjacent to Tonbridge Road

Comment advocating for the revision of certain aspects of Policy AL/PE 6. Additional text is highlighted in blue: [TWBC: additional text has been marked here as underlined]

This site, as defined on the Pembury draft Policies Map, is allocated for use as a key medical facility, to include the following uses:

i. Proposed development will have a direct functional link with the hospital or any emergency services associated with it; for example, uses that involve significant levels of hospital staff working at the site to provide, for example, rehabilitation or training, or a ‘blue light hub’;

ii. Key worker housing for hospital and/or medical staff, and/or housing for medical students;

iii. Hospital expansion;

iv. Clinical facilities;

v. Medical research/education; vi. Potential for additional hospital parking (see Policy TP 3: Parking Standards)

vii. Potential for public transport interchange facilities (see Policy TP 2: Transport Design and Accessibility)

DLP_7216

DHA Planning for Notcutt Nurseries Ltd

 

Local Plan Representation

1.1 Introduction

This representation has been prepared on behalf of Notcutts Ltd (herein ‘Notcutts’) 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 is owns and operates Notcutts Garden Centre, Tonbridge Road, Pembury (herein ‘the Site’ or ‘the Garden Centre’) and they are promoting it for allocation as part of the wider Development Plan review. A site location plan is included as Appendix 1.

The site was put forward as part of the Call for Sites process and it has been included as a draft allocation (policy AL/PE 6) within the regulation 18 plan. The allocation comprises Tunbridge Wells Hospital and surrounding land, including Notcutts Garden Centre and Owls Nest. It is identified as a key strategic element in delivering current and future health provision for West Kent and the land is allocated for use as a key medical facility. Nonetheless, it does not preclude Notcutts from carrying out Garden Centre related development that would otherwise be acceptable.

As a matter of principle, we support the identification of the Garden Centre site as being one which is suitable for further development. However, the land should be formally removed from the Green Belt to provide certainty that development can come forward, rather than requiring a case of Very Special Circumstances to be demonstrated.

1.2 Document Structure

With the above in mind, this representation provides an overview of the Garden Centre (Chapter 2), comments on the content of the draft plan (Chapter 3) and outlines a number of modifications to relevant policies (Chapter 4).

2. Site Context

2.1 Site Overview

The site is situated on the western outskirts of Pembury, entirely within the Metropolitan Green Belt (‘MGB’) and just outside of the High Weald Area of Outstanding Natural Beauty (‘AONB’).

The main A21 dual carriageway and A228 Pembury Road lie along the southwestern and south-eastern boundaries respectively. The site is bound to the northwest by existing woodland, whilst to the north-east is a narrow band of vegetation including trees and mown grass areas, and the main Tonbridge Road.

The site currently consists of a range of brick and timber clad buildings and green houses, including the main Garden Centre building, polytunnel, planteria, associated storage areas together with car parking facilities. At the rear of the main building is also an outdoor seating area for the on-site restaurant and a children’s play area.

Access to the site, both vehicular and pedestrian, is from Tonbridge Road via a single main access on the north-eastern edge of the site.

2.2 Planning History

A review of the Council’s online records indicates that the site was first granted temporary planning permission for the retention of display greenhouses, sheds and a sales office in 1977 (reference 77/0728). This temporary permission was successfully renewed in 1982 with full permanent planning permission being granted for the retention of the greenhouses, sheds and sales office as well as an extension of the use of land in connection with the garden centre in 1987 (reference 87/01237/FUL).

A number of other planning permissions for minor development associated with the garden centre have been approved since 1987 and more notably permission was granted in 2008 (reference 08/00239/FULMJ) for the redevelopment of the existing overspill car park to the far south of the site to provide a temporary car park for construction workers, who were building the approved new Tunbridge Wells Hospital for Maidstone and Tunbridge Wells NHS Trust.

Planning permission was granted in 2010 (reference TW/10/03112) for the redevelopment of the site to provide a new garden centre building and associated parking, landscape and plant display areas. This permission was not implemented. In 2013, planning permission was granted for a garden centre with a reduced built footprint (reference 13/00056/FUL). This permission was implemented.

In July 2019, the Council granted full planning permission for an extension to the garden centre, improvements to the front entrance, rationalisation and formalisation of existing overflow car park, provision of new polytunnel/ canopy, creation of feature garden, reconfiguration of existing play area, planteria and associated storage area.

3 The Tunbridge Wells Draft Local Plan

3.1 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 (Section 3.2);
  • Place Shaping Policies for Pembury (Section 3.3);
  • Stage 1 & 2 Green Belt Study (Section 3.4); and
  • Distribution of Development Topic Paper (Section 3.5).

3.2 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.

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 specific areas/ settlements. Table 1 below summarises the scale and distribution of development to be delivered within and around Pembury.

Table 1 - Scale and Distribution of Development at Pembury 

Parish/Settlement

Housing Allocations

Retail and other Town Centre Uses 

Employment Infrastructure 

Pembury

294-304 (Average 299)

0

Limited increase through mixed use place shaping policies

‘Health hub’

Contributions to improvements to A264, A228 and/or A21 and/or relevant junctions

Policy STR 1 states that to deliver the development allocated within the plan, Green Belt land will be released around the settlements of Royal Tunbridge Wells, Southborough, Paddock Wood, Pembury and the parish of Capel.

Policy STR 4 confirms that a Green Belt review has been undertaken and the preamble to the policy explains that the evidence and justification underpinning the Councils decisions is detailed within the Distribution of Development Topic Paper. We discuss this within section 3.5.

Notcutts support the general thrust of the strategy and consider that Pembury represents a suitable location to deliver housing and other development needs. Further, the Garden Centre is well placed to contribute toward meeting these needs. Notcutts also agree that there are exceptional circumstances to alter Green Belt boundaries and remove land from the Green Belt designation, to enable the Local Plan to include proposals for development.

Nevertheless, despite identifying the site as being suitable for development, the Local Plan does not propose to remove the land from the Green Belt. We object to the failure to remove the site from the Green Belt, which is not considered a sound approach for reasons we explain within sections 3.3 and 3.4.

Likewise, there is scope to redevelop the Garden Centre without compromising the function and purpose of the Green Belt designation. As the Council know, the site is previously developed land, contiguous with the built up area of Pembury and contributes nothing to the five purposes of Green Belt. We discuss this in detail within section 3.4.

3.3 Place Shaping Policies for Pembury

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 sites that will deliver the quantum of development proposed. The scale, distribution and nature of development is established by policy STR 1. The site specific allocations provide both strategic and development management guidance.

In respect of Pembury, policy STR/PE 1 summarises the requirements that all new proposals should accord with. It states that the Limits to Built Development are defined on the draft proposals map and now include sites to be allocated at policies AL/PE 1-5 and 7.

However, it states that the new Limits to Built Development does not include land allocated under policy AL/PE 6.

The Garden Centre forms part of policy AL/PE 6, which is identified for use as a key medical facility to include the following uses:

i. Proposed development to have a direct functional link with the hospital or any emergency services associated with it; for example, uses that involve significant levels of hospital staff working at the site to provide, for example, rehabilitation or training, or a 'blue light hub';

ii. Key worker housing for hospital and/or emergency service staff;

iii. Hospital expansion;

iv.Clinical facilities;

v. Medical research/education;

vi. Potential for additional hospital parking (see Policy TP 3: Parking Standards);

vii. Potential for public transport interchange facilities (see Policy TP 2: Transport Design and Accessibility).

The pre-amble to the policy states that the site is considered to be a key strategic element in delivering the current and future health provision for West Kent.

Figure 1 below shows the Garden Centre boundary in relation to the wider policy boundary, which we include as a scaled plan at Appendix 2.

[TWBC: for Figure 1 see full representation].

As a matter of principle, we support the identification of our client’s land as being suitable for development and its inclusion within the allocation boundary for AL/PE 6. Likewise, we welcome confirmation in the policy that the allocation does not preclude Notcutts from carrying out Garden Centre related development that would otherwise be acceptable.

However, we object to a number of aspects of the policy as set out below.

We object to the failure to remove the site from the Green Belt, which is not considered a sound approach given that delivery of any development here would rely on any future applicant advancing a case of Very Special Circumstances (‘VSC’). Moreover, the failure to remove the site from the Green Belt whilst recognising that the site is suitable for development only leads to uncertainty.

The Council also appear to have confused the exceptional and very special circumstances tests. Criteria 4 to policy AL/PE 6 states that all proposed development must demonstrate exceptional circumstances supported by evidence of need. However, the plan has already identified the need for development in this location as part of the plan making process, and therefore ‘exceptional circumstances’ are already fully evidenced and justified.

This confusion is compounded further, as the Council confirm that there are exceptional circumstances to alter Green Belt boundaries within the Distribution of Development Topic Paper (paragraph 6.60).

Finally, although the policy wording does not preclude Notcutts from carrying out Garden Centre related development the site is still located in the Green Belt and therefore a case of VSC would need to be demonstrated.

There is a very strong case for removing the site from the Green Belt on the basis that it is a fully developed brownfield site on the very edge of the Green Belt boundary adjacent to the built up confines of Pembury, and it does not contribute to any of the purposes of the Green Belt.

This is discussed further in our comments on the Green Belt Study and Distribution of Housing Topic Paper below.

3.4 Green Belt Study

The Green Belt around Tunbridge Wells has existed since the formal approval of the Kent Structure Plan in 1980 and has broadly remained unchanged since.

The Government continue to attach great importance to Green Belts and national policy is clear that Green Belts can only be changed when exceptional circumstances are fully evidenced and justified through the review and updating of local plans.

As part of its Local Plan preparation TWBC has taken the opportunity to review the Green Belt designation, in the context of the changes to the Borough since 1980 and potential future changes that may be required to accommodate a growing population.

In 2016, the Council commissioned LUC to undertake a strategic assessment of the Green Belt in Tunbridge Wells in the context of the wider Metropolitan Green Belt within adjacent authorities. It is undertaken in relation to the contribution of land to each of the five Green Belt purposes.

The review considered whether and for which areas, a further ‘Stage Two’ Green Belt review should be undertaken, which would comprise a more detailed and focussed review of parcels of land around identified settlements.

The Stage 1 assessment identifies 33 parcels and 10 broad areas for assessment at Stage 2. One of the parcels was PE6, which is largely a tree covered area between the A21 and Tonbridge Road. However it also includes Notcutts Garden Centre and a Hotel and several dwellings on the north side of Tonbridge Road. For clarity, the parcel is included as figure 2 below.

[TWBC: for Figure 2 see full representation].

The Stage 2 assessment was published July 2017 and assessed the identified parcels against the five Green Belt purposes.

The conclusions reached in respect of PE6 are included below (Table 2).

Purpose

Strength

1. Checking the unrestricted sprawl of built up areas

Moderate

2. Preventing towns merging

Moderate

3. Safeguarding the countryside from encroachment

Relatively Weak

4. Preserving the setting and special character of historic towns

Weak/None

5. Assisting with urban regeneration.

Not assessed

Table 2 - Stage 2 Green Belt assessment of Site PE6

Overall, the assessment found that the site makes a moderate contribution to Green Belt purposes. It also states that the A21 would form a strong Green Belt boundary to the west and the woodland to the north of the hotel constitutes a strong edge.

However, it is our view that these conclusions cannot be reasonably applied to the Garden Centre site in isolation, given its characteristics and relationship with the Pembury settlement.

The majority of the parcel comprises undeveloped and tree covered land that extends north-west of the Garden Centre, which is closer to the built up area of Royal Tunbridge Wells. As such, it is not entirely unreasonable to suggest that it provides a moderate contribution to purpose 1 and 2 and a weak contribution to purpose 3.

However, the same cannot be said for the Garden Centre, which comprises previously developed land adjacent to the built up confines of Pembury and does not contribute to the openness of the Green Belt or indeed any of the five purposes. We provide further explanation below, taking each purpose in turn.

Purpose 1: To check the unrestricted sprawl of built - up areas

The Garden Centre is adjacent to the built up confines of Pembury and the majority is covered by buildings and hardstanding. It is brownfield land by definition and largely viewed as an extension to the built up area of Pembury by virtue of its contiguous relationship.

Accordingly, it does not serve to check unrestricted sprawl as it is already developed and lacks the open characteristics one would associate with the Green Belt.

Purpose 2: To prevent neighbouring towns merging into one another

As mentioned above, the site is situated on the outskirts of Pembury and adjacent to the settlement confines. It retains a reasonable distance from the settlement confines of Royal Tunbridge Wells with intervening land providing a sufficient buffer to prevent the settlements merging. Moreover, the A21 represents a clear and defensible boundary that would prevent merging in any event.

Purpose 3: T o assist in safeguarding the countryside from encroachment

As specified above, the site is in use as a Garden Centre and the majority is covered by buildings and hardstanding. Therefore, it does not display a typically open Green Belt character with the cumulative built form giving the site an urban character.

Purpose 4: To preserve the setting and special chara cter of historic towns

The development would not have any impact on the setting or special character of historic towns.

Purpose 5: T o assist in urban regeneration, by encouraging the recycling of derelict and other urban land

This is not considered relevant for the purposes of this assessment.

In addition to the above, whilst we would agree that the woodland to the north of the hotel constitutes a strong Green Belt boundary, equally the woodland to the north west of the Garden Centre represents a clear and defensible boundary that will endure. Indeed, the area is designated as ancient woodland, which both adopted and emerging policies seek to retain in perpetuity.

Finally, we note that the plan proposes to remove the other 6 allocations from the Green Belt (Policy AL/PE 1 – 5 and AL/PE 7). Not only this, with the exception of AL/ PE 5, the sites are all located within the High Weald AONB.

In contrast, the Garden Centre does not fall within the AONB designation and does not contribute to the landscape of scenic beauty of the surrounding area. This reinforces why it would be illogical not to remove the Garden Centre from the Green Belt.

Taking the above into account, it is clear the Garden Centre makes no contribution to any of the Green Belt purposes. Likewise, it does not fall within the AONB designation.

Distribution of Development Topic Paper

The purpose of the Distribution of Development Topic Paper (herein ‘the Topic Paper’ or ‘the Paper’) is to explain the background to the proposed Development Strategy. This includes the consideration of development potential in the Green Belt (Chapter 6(F)).

The Topic Paper makes clear that the Council considers there to be exceptional circumstances to alter Green Belt boundaries, in order for the Local Plan to meet identified needs. This includes ‘Areas providing opportunities for delivering key infrastructure’, with land adjacent to the Tunbridge Wells Hospital at Pembury used as an example.

At paragraph 6.62 of the paper, the Council state that the approach for each allocation has taken into account the outcomes of the Green Belt study at a site specific level as well the usual assessment of planning opportunities and constraints.

In this respect, the Council conclude that there are exceptional circumstances to release Green Belt - having regard to constraints, development needs and the lack of reasonable alternatives - and then go on to consider whether specific sites are suitable to deliver development to meet identified needs.

The assessment followed a three stage process, with the Green Belt study assessing both broad locations (Stage 1) and smaller parcels of land (Stage 2). This was followed by a detailed assessment of individual sites.

The finer grained assessment undertaken by TWBC included the following:

  • An analysis of the percentage of the site in the Green Belt;
  • A review of the outcomes of the Green Belt study (Stage 1 and 2) to determine what contribution the site allocations make towards the Green Belt criteria;
  • A review of the outcomes of the Green Belt study (Stage 1 and 2) to determine the existing boundary strength and if this can be improved and made more permanent through development opportunities;
  • Review against the beneficial uses of green belt and what possible contributions development included in a proposed allocation can make to green belt objectives.

Section 3.4 of this representation summarises the conclusions of the Stage 1 and 2 Green Belt study, however it is our view that they cannot all be reasonably applied to the Garden Centre site in isolation.

Further, we consider that the woodland to the north west of the Garden Centre is a strong and defensible boundary that will endure beyond the plan period. This boundary could also be strengthened as part of wider proposals for redevelopment.

The above matters aside, the Topic Paper goes on to list the proposed site allocation policies in the plan and provides a summary of the development type and whether it is proposed to remove it from the Green Belt. A summary of mitigation is also provided and attempts to rationalise the policy approach.

However, a number of allocated sites are proposed to remain in the Green Belt despite being allocated for development, and the rationale section does not explain why this is the case.

In our view, it is entirely illogical to identify sites for future development or infrastructure provision and then decide not to remove the land from the Green Belt when exceptional circumstances have been fully evidenced and justified through the plan making process.

Taking the above into account, AL/PE 6 should be removed from the Green Belt to provide certainty that the required infrastructure can be delivered. At the very least, the Garden Centre should be removed from the Green Belt on the basis that it no longer contributes to the five purposes of Green Belt.

4. Conclusion and Recommendations

4.1 Overview

This representation has been prepared on behalf of Notcutts Ltd, in response to the Tunbridge Wells Borough Council Draft Local Plan Consultation.

Our client owns and operates Notcutts Garden Centre, Tonbridge Road, Pembury and they are promoting it for allocation as part of the wider Development Plan review.

The site is included within draft allocation boundary for policy AL/ PE 6, which is allocated for use as a key medical facility and identified as a key strategic element in delivering current and future health provision for West Kent.

The purpose of this representation has been to comment on the Council’s proposed development strategy, the supporting evidence and proposals for allocated sites.

In this respect, Notcutts support the general thrust of the strategy and agree that Pembury represents a suitable location to accommodate development needs. Moreover, they agree that there are exceptional circumstances to amend Green Belt boundaries to accommodate the needs identified.

Notcutts also support the inclusion of the Garden Centre within the allocation boundary for AL/PE 6 and consider that it could be well placed to assist with meeting development needs. Nonetheless, we welcome the confirmation in the policy wording that the allocation does not preclude Notcutts from carrying out Garden Centre related development.

Notwithstanding the above, the Council are not proposing to remove the site from the Green Belt and we do not consider this a sound approach. Moreover, it is illogical to remove sites from the Green Belt that also form part of the AONB, but not our clients land.

Our biggest concern is that any application for future redevelopment would need to demonstrate VSC, which provides limited certainty that the development will be enabled to come forward.

In addition to the above, the Garden Centre site contributes nothing to the five purposes of the Green Belt given that it comprises previously developed land, sits immediately adjacent to the built up area of Pembury and represents a logical location to extend the settlement boundary and take land out of the Green Belt.

4.2 Recommendations

In light of the above, we would ask the Council to formally remove AL/ PE 6 from the Green Belt. At the very least, the Garden Centre should be removed from the Green Belt so Notcutts can carry out Garden Centre related development that would otherwise be acceptable.

Closing

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.

[TWBC: see full representation]. See also Comment No. DLP_7233 (the Distribution of Development Topic Paper)].

Policy AL/PE 7: Woodsgate Corner

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_72

The Access Group

 

The Hendy Car Centre at Pembury raises issues regarding:

  • Parking - will spill over into side roads causing congestion and obstruction to local residents
  • misuse of a site set aside for park & ride
  • cause congestion for people trying to get into the Tesco car park to shop
  • congestion on the Pembury Road which will have serious consequences for ambulance and patient access to Pembury Hospital
  • Pembury Road must first be made dual carriageway to such a Centre being constructed. That should be a condition of any planning approval, irrespective of the cost to the developer or Hendy

There are serious concerns surrounding Hendy being too close to local charities and acting as sponsors to local events in an effort to gain approval for this unwelcome development, opposed by 90% of residents in Pembury, the Parish Council and Pembury Society

DLP_104

Miss Mary Bird

Object

Why  would the council even consider putting a massive commercial development on the edge of the village? when Hendy  should be in North Farm with the other car show rooms.

Already at most times of the day the dual carriage way to the Tesco roundabout and onwards to Tunbridge Wells is solid with traffic and access for emergency vehicles especially ambulances getting the hospital are blocked.

The slip road from the A21 is blocked for a large portion of the day with existing traffic.

With 180 staff who will all have cars, and car transporters blocking the road and customers cars, it will be ridiculous.

This is a really stupid idea and I cannot believe that the council are even considering it, based on the increased traffic and pollution it will bring.

DLP_108

Mr Stuart Law

Object

Why  would the council even consider putting a massive commercial development on the edge of the village? when Hendy  should be in North Farm with the other car show rooms.

Already at most times of the day the dual carriage way to the Tesco roundabout and onwards to Tunbridge Wells is solid with traffic and access for emergency vehicles especially ambulances getting the hospital are blocked.

The slip road from the A21 is blocked for a large portion of the day with existing traffic.

With 180 staff who will all have cars, and car transporters blocking the road and customers cars, it will be ridiculous.

This is a really stupid idea and I cannot believe that the council are even considering it, based on the increased traffic and pollution it will bring.

DLP_349

Charlotte Raleigh

Object

I object to the proposal for a car showroom. Please no!. There are plenty of car showrooms on North Farm and it is a good idea to cluster them there.

This site is in a potentially valuable and interesting location. And surely deserves to be put to some more imaginative use? Why not canvass the shoppers at the Tescos? Have a design competition? This would actually be a sort-after site because of the footfall to Tescos. As well as the hospital, Nottcutts, proximity to A21, Skinners school and Pembury, etc. Perhaps it could include a picnic area? Especially as many people already take their meal- breaks in the Tesco car park? Any large commercial development should be required to contribute financially to the Pembury community.

DLP_525

Mr Neil Franklin

Object

Proposed Motor Village is the wrong thing in the wrong place – too big and with access via a road (the A264/A228 Pembury Road) already too busy.  It will create hundreds of new vehicle movements of its own.  Parking will undoubtedly overspill into Pembury itself, making life even more intolerable for residents who already have to endure parked vehicles from the hospital.  Emergency vehicles will also have more problems than they do even now.  Objections to this development have already been made by myself and hundred of other Pembury residents.

DLP_843

Melvyn Cole

Object

This response form is difficult for the average resident to comprehend, many are not computer literate, it would have been far better to have posted the consultation to all the residents instead of the magazine you now send. Perhaps it was your intention to not have to many responding.

My objections to the local plan in general is that any building on the green belt is not acceptable except for hospitals, schools or any public amenity.

There are two of the proposed sites that are of particular concern to me. [TWBC: see also comment number DLP_846 on AL/PE4].

The first AL/PE7, the Hendy application. My objections to this are the effect of having a business dealing with so many vehicles, customers and workers would have on Pembury Road, causing more hold ups to traffic on the main road to Tunbridge Wells. Ambulances are already held up, a major concern when a life may be at stake.

The road is used by school children either on their way to school by cycle or walking as well as many others on foot or cycle being exposed to air pollution, so much for encouraging people to walk or cycle.

There is an industrial estate half a mile away, built in the 1960s for the very purpose of such a business and where there are many other car dealers.

This application must not be allowed, it will not be to the advantage to Tunbridge Wells and will be a disaster to Pembury.

DLP_1453

Pembury Society

Object

7. PE7 (Hendy at Woodsgate) is the most controversial plot as far as Pembury residents are concerned. The planning application for a Motor Village on the site has already been the subject of more than enough discussion elsewhere and the public’s response to it is well documented. Given that local response it is beyond comprehension why this proposed development has been included in the Draft. We would point out that in recent correspondence between Stephen Baughen and the Pembury Society, with regard to general planning concerns, Mr Baughen stated, with reference to comments made by residents to specific applications, ‘The comments provide local knowledge and input, and are important in informing the overall planning balance.’ Therefore, if ‘Public Consultation’ is to be seen to be taken seriously, development of this site with a Motor Village must be removed from the final document because local knowledge, together with the response from KCC Highways, both say, in effect, the proposed development would be an unmitigated disaster for the area. Despite assurances from Councillors and the Planning Department there are many local residents who are still convinced that this development has always been a ‘done deal’ and recent activity on the site has reinforced this conviction since no developer would spend significant sums on land they neither own nor have permission to develop. If this proposed development is retained in the final document the planning process at TWBC will have lost all credibility with the people of Pembury and the personnel will have lost all respect.

DLP_1626

Maggie Fenton

Object

Objection to Policy AL/PE7 Woodsgate Corner

This site is mostly in the AONB, has TPOs & also is an SSSI.

This is an appalling addition to the Local Plan & such a large development would be better suited to one of the industrial estates.

“Development on the site SHALL accord with:

  1. Enhancement of biodiversity ON THE SITE”
  2. a robust assessment on transport & highways, and a contribution to mitigation” 

How will biodiversity be enhanced on site? Given that the site is already being cleared it seems highly unlikely that TWBC will be able to achieve this.

KCC Highways object to this application, quite rightly, as they recognise the severe congestion at this hotspot and 180 staff entering and leaving the site at rush hour will do nothing to solve the problem. I refer TWBC to their Transport Assessment by SWECO who have no ideas for solving the problem at Woodsgate Corner except for suggesting cycling & buses (this would need an unprecedented change in public behaviour which is unlikely) & tinkering with the traffic lights at Halls Hole to try to improve flow.

DLP_2117

Terry Everest

Object

Query / Object

Is this needed here? with so many other local dealers it seems unneccessary, support increase of tree cover but unsure of need for development.

DLP_2652

John Duffy

Object

Over 100 local objections have already been received by TWBC to this highly destructive and ill thought out porposal for a commercial vehicle sales premises which is totally unsuited to the local Pembury Village area.

Issues on parking, access and traffic congestion already exisit without the additional staff 7 customer and vehicle movements that the site will generate. This proposal is hugely opposed throughout Pembury and by those having to suffer the already tortuous congestion along Pembury Road travelling to or from Tunbridge Wells.

The proposed car sales village should be located at the natural home for such: ie North Farm were there is adaquete transport, parking and land available. This if allowed will destroy the ambience of Pembury and the architects and supporters of it were removed from local authority office by the voters in May 2019. It should be refused and the site allocation removed from any local plan.

DLP_2799

Nicola Duffy

Object

1. Unsustainable for impact on through traffic to Tunbridge Wells on an already congested and over used road and also the surrounding village roads.

2. Unwanted by the local population who do not want a commercial vehicle sales village with the additional traffic and pollution nearer the village.

3. An inappropriate site, far better suited to alternative use as a park and ride with the benefits to both Pembury and the far wider Tunbridge Wells community. There is ample space in the natural environment of North Farn were the road infrastructure and environment would suit a large commercial premises attracting the natural footfall to that area.

4. Loss of parking at Tesco and the undoubted potential of the store closure should footfall drop, impacting on the significant elderly and family populations of Pembury having no major walkable supermarket for provisions.

DLP_3107
DLP_3125

Andy Bashford
Teresa Stevens

Object

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

Modern garages (let alone Multi-garages) should only be built on Industrial Estates, where roads are designed for HGVs. Hendy taking over the vast majority of existing Tesco car parking space will lead to fewer people going to Tesco’s and Tesco’s sooner or later shutting down, which will mean more unnecessary driving of cars by customers to get their weekly food etc. Congestion at the access roundabout to Pembury Rd is bad a lot of the time and it will only get worse with long HGV vehicle transporters needing to get in/out on the roundabout. KCC Highways have already made this clear and commented that the current plan relates to a Park & Ride scheme. Why have Newt barriers been installed before any such development has been permitted?

DLP_3355

Kent County Council (Growth, Environment and Transport)

Object

Highways and Transportation

The Local Highway Authority objects to this policy.

This site is in the current Site Allocations as a Park & Ride. The proposed removal of this Park & Ride allocation from the new Local Plan effectively removes the chance of an improved direct public transport service into the town. With the levels of proposed growth to the north of this site further along the A228 corridor, the safeguarding of this well located site for Park & Ride (or innovative alternative) is vital. The inability to deliver a Park & Ride site could put uncertainty on the Borough Council’s ability to deliver the preferred growth strategy.

In addition, the current live application for this site does not show how new trips on this part of the network can be mitigated.

Heritage Conservation

Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval.

Low potential for archaeological remains

DLP_3770

Martin Robeson Planning Practice for Tesco Stores Ltd

Support with conditions

Policy AL/PE7 – Woodsgate Corner (support with conditions)

As noted under the heading ‘Tesco in Royal Tunbridge Wells’, our client has entered into a contract with Hendy Group in respect of surplus land at Woodsgate Corner (currently being promoted for a motor village). Tesco firmly supports this scheme and the Council’s proposal to allocate the site for “car showrooms and associated uses/equipment”. Tesco firmly endorses the representations submitted in respect of Policy AL/PE7 by agents acting for Hendy Group. However, Tesco has a number of its own comments, as follows:

  • There appears to be an inconsistency between the extent of the allocation shown on Map 93 and how this is depicted on the Proposal Map for Pembury. The latter should be corrected to indicate all land shown on Map 93.
  • Whilst the removal of the allocated land from the Green Belt is supported (reflecting the existing developed nature of the site and the development now proposed), Tesco raises concern regarding the application of Policy EN17 to land between the store/car park and Pembury Road (see our objection to Policy EN17, below).
  • The ‘open space and landscape buffer’ shown on the southern edge of the site on Map 93 should be removed to achieve consistency with both the present planning application scheme and the Proposal Map for Pembury .
  • It is recommended that the limit to built development boundary is coterminous with the Green Belt boundary (ie, includes the whole of Policy AL/PE7) reflecting the allocation of the site and existing development here.

DLP_4446

James Whitehorn

Object

c] With respect to Policy AL/PE 7 Woodsgate Corner, I have already submitted a detailed objection to the premature Planning Application by Hendy for car showrooms, primarily on highway grounds, subsequently endorsed by an objection from the Highway Authority. ‘Contributions to mitigate any impact that is considered to be severe' would not solve the inherent traffic problem with this policy. This land should be retained for a Park & Ride site as per the existing designation. The feasibility study by WSP suggests that Park & Ride is still a viable option which would reduce traffic on the A264 corridor, but car showrooms on this site would undoubtedly increase traffic.

DLP_4515

Richard Promfrett

Object

  1. Another AONB
  2. We do not want a motor village; we do not want the increased traffic from employees and visitors, and it is not in keeping with the feel of the village. Why can they not find somewhere in the industrial estate?

DLP_5795

Hugh Boorman

Object

12,MAP93 Policy AL/PE 7 This application should have been rejected and the whole thing has raised certain queries as to its background and possible support. It does not need a written explanation as to why it should be rejected.

a, The surrounding road network to and from Pembury, Tunbridge Wells and Paddock Wood area has been a nightmare for some years and yet here we are seeking to introduce more traffic not counting the additional traffic which will develop if the local plan is actioned.

b, Should it go ahead it will involve possibly an additional eighty to one hundred Hendy Staff Cars coming from all directions onto the. site each end of the day.

c, Customer vehicles making four journeys each day to and from site. ie, Customer brings car to site first thing in the morning and gets picked up only to repeat the same journey, same day in the evening to pick the car up .

d, Car recovery vehicles.

e, Parts delivery vehicles.

f, Other company parts collection vehicles.

g, Waste collection vehicles.

I, We are all involved in Environmental issues and air quality and yet here we are proposing the addition of hundreds more vehicles and their exhaust emissions on what is a very busy School route to and from Pembury, with many pupils walking or cycling and the intention is to make it worse, and that is not taking into account the vehicle numbers which will increase due to the local plan if it develops as intended.

I think all of these issues need a serious rethink instead of just plucking the answers to a problem out of thin air

DLP_5803

Richard Bayles

Object

I wish to register a comment on the new Local Plan with specific reference to Pembury and the proposed Motor Village at Woodsgate Corner (A264).

I think this proposed development is ill advised and at odds with current Borough Council policy, following the declaration of a Climate Emergency and the adoption of a policy to make the Borough Carbon Neutral by 2030.

The A264 Pembury Road, along the intersections with the A21, is one of the most polluted stretches of roadway in the Tunbridge Wells borough. At certain times and on certain days it can take twenty minutes for cars to travel along this section of road. Cars are static and idling for long periods of time as they inch along this section in heavy traffic. As you are no doubt aware, idling cars can produce twice as much air pollution as a moving vehicle and Public Health England has recognised reducing idling traffic as one of the main ways to tackle air pollution and air pollution is one of the major contributors to our current climate crisis. I accept that air quality studies have been done along this stretch of road but I can see no evidence that these studies have been over a sustained period of time both in terms of number of days and the number of hours required to build an accurate picture of the declining air quality along this stretch of road.

Building a “Motor Village” on the proposed site can only increase the amount of traffic along this already over-burdened stretch of road and the thought of car transport vehicles, in particular, needing to regularly access the site is particularly worrying. Given the close proximity of the Tunbridge Wells Hospital at Pembury, and the need for Ambulances to regularly use this stretch of road, the potential for chaos and, let’s face it, loss of life if ambulances are stuck in traffic, would be considerably increased by the presence of this proposed development.

My understanding is that this site had already been designated as a potential location for a future Park & Ride scheme for Tunbridge Wells. This would seem a far better use of this site and a far better benefit to village residents than a bunch of car showrooms. We already have a large number of car showrooms on the industrial estate around Knight’s Park and this would seem a far more sensible location for a business of this kind. Keeping the Woodsgate Corner site as a location for a future Park & Ride scheme would be far more in keeping with the Council’s own commitment to tackling Climate Change and achieving Carbon neutrality by the target date. Our village does not need car showrooms – it needs better air quality around it and an improved public transport system, including a park and ride option, that will allow better access to the main town. This proposed development threatens our health and our connection to the town of Tunbridge Wells and is not appropriate for the proposed site.

DLP_6017

Katherine Wallwork

Object

I have already objected to the proposed building of the Hendy motor village adjacent to the Tesco superstore, for reasons of increased traffic, increase in pollution, an increase in problems for emergency vehicles moving to and from Tunbridge Wells Hospital, and an increase in parking problems in the village due to insufficient parking for Hendy staff and a severe reduction in car parking for Tesco staff and customers.

Many people are worried about the huge increase in housing that is proposed in the local area, demanded by the Government. The impact on traffic, roads, water supply and sewerage, schools, medical services (including the overstretched A & E and ambulance services) requires greater investment in order to cater for a new influx of people to our area. There is also the impact of housing development on greenbelt land and the AONB. People moved to places such as Tudeley because they wanted to live in a pretty village that was undeveloped and are understandably upset that their vision will be destroyed by a massive new housing development.

I should prefer that the land between Pembury and the A21 dual carriageway is not filled in with housing. However, I understand the need for more houses for people to live in and hope that the developers find a market for them.

Tunbridge Wells feels like a depressed place to be at the present time with so many closed shop units. Is an increase in housing development and destruction of visual amenity really the way towards betterment?

DLP_6095

Christopher Wallwork

Object

This proposal/policy would have major adverse impacts on local traffic, on car parking on nearby roads, on the utility of the existing retail space and on existing car showroom employers on the Longfield Road Industrial estate.

The policy states that it should include “measures to enhance bus travel”. This contradicts the purpose of a car showroom. The appropriate measure would be to use this site for a park and ride.

DLP_6100

Julia Speight

Object

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_6110

Pembury Parish Council

Object

TWBC will be aware of the overwhelming public opposition to the proposed use of this site for a huge car showroom and workshop complex.

Pembury Parish Council has strongly objected to the current planning application (see Appendix 3, email dated 17 May 2019 to Planning Support), which has been 'called in'. Our principal objection (which the majority of individual objectors also cited) is the inevitable extra traffic congestion this plan would create in the locality, particularly in Pembury Road but also Pembury High Street and Cornford Lane. We also expressed concerns about access to and egress from the site; increased vehicle emissions; insufficient car parking; also noise nuisance for nearby residents.

We share the concern of many, that if the car dealership is permitted, then Tesco will vacate its part of the site, which would leave Pembury without a significant asset. The Loss of the local supermarket is already mentioned in the Sustainability Appraisal and is a major concern.

Crucially the undeveloped land remains allocated for Park and Ride in the current Local Plan, and both we and K.C.C. (please refer to their recent Transport Assessment) believe it should remain so in order for current congestion to be improved into Tunbridge Wells. Our clear view is that a car dealership complex is a wholly unsatisfactory allocation for this site, such a business would be far better sited on North Farm in company with such other dealerships.

[TWBC: see Pembury Parish Council's full response, including any appendices referred to in this comment].

DLP_6665

Sarah Clarke

Object

Land at Woodsgate Corner AL/PE 7

Of all the proposals contained in the Local Plan, for reasons which have already been made clear in the various objections to the proposed Hendy application, this is the area which causes most concern. It is the gateway to Pembury.

The arrival of Tesco in the village, after much consultation with the Parish Council, and following a planning inquiry, had a major impact on Pembury itself. The store has eliminated most of the local shops/stores and as a result many parishioners are dependent on Tesco’s for their local shopping.

The mixed use of this site, especially for an intensive use commercial motor village is almost incomprehensible. There is the potential impact on the viability of the Tesco store as a result of the size of the motor village, as disclosed on the premature application currently before the Council. The impact on Pembury of planting a motor village, not just car showrooms (currently 11 dealerships are proposed with associated workshops and deliveries) makes a mockery of the remainder of the local plan in this village, with future reliance on increased cycle ways and public transport. Even ambulances have HUGE problems getting into Tunbridge Wells and area along the A 264 and from the A 21, now, without adding to the congestion and pollution on this section of the highways.

The creation of employment opportunities said to be as many as 180 employees does not mitigate the impact of the proposal for this area of Pembury. This is without the impact of the increased traffic from the increase in houses in the High Street and Hastings Road, and the traffic from the thousands of new homes at Tudeley and at Paddock Wood.

Of all the elements of the Local Plan, this is the most objectionable, especially as there would now appear to be alternative locations for a commercial venture of this nature.

The protection to be afforded to the site in the recommendations in the local plan consultation appears to have been ignored as work is already taking place at the site to remove vegetation.

DLP_7066

Brown & Co Planning Ltd for The Hendy Group

Support with conditions

Introduction

1.1 Brown & Co Planning Ltd are instructed by the Hendy Group (our client) to submit the following representations to the Tunbridge Wells Borough Draft Local Plan (TWBDLP), Regulation 18.

1.2 Brown & Co Planning have undertaken a comprehensive review of the Tunbridge Wells Borough Draft Local Plan document as well as the relevant supporting evidence base. In accordance with the guidance set out within the Planning and Compulsory Purchase Act 2004 as amended by the Localism Act 2012, the following representations relate specifically to the “legal compliance” and “soundness” of the draft Local Plan. As well as the specific tests of soundness set out in the NPPF.

1.3 For ease of reference we have set out our representations within this single document which addresses the relevant questions set out within the questionnaire and which makes clear references to specific; paragraphs, policies and site allocations within the draft plan. Where relevant we have cross reference Topic Papers and other supporting documents.

1.4 The representations highlight where; the plan has made critical omissions which strike at the heart of “legal compliance” and “Soundness.”

1.5 For further ease of reference, we have adopted the Council’s rating system: Object, Support, Support with conditions, and General Observation and this is stated before each comment.

1.6 These representations relate specifically to our clients’ land interests at Mount Ephraim/ Culverden Street/ Rock Villa Road (allocation RTW 8), Woodsgate Corner, Pembury [1 There is currently a live application for the development of a Motor Village Car Dealership on land to the south of the Tesco Car Park, Pembury Road, Pembury (Ref: 19/00884/FULL).] (allocation PE 7), and the existing Renault site on Langton Road.

The Hendy Group

1.7 The Hendy Group is a family run motor dealership group founded in 1859 and with a presence across the south. The Company’s geographic reach stretches across the South Coast, spreading from Devon, through Hampshire and West Sussex into East Sussex, Surrey and Kent.

1.8 In 2016, Hendy acquired the Lifestyle Group. This was a major acquisition which has transformed the business and provides a platform for future growth and investment. The deal increased Hendy’s presence in Tunbridge Wells.

1.9 Throughout the past 150 years, Hendy businesses have thrived by looking forward and building better ways of looking after customers. The quest for improvement is constant and the organisation excels when it reinvents itself to deal with the challenges of intense competition.

1.10 Tunbridge Wells is today a strong market area for the business and represents a key focus for future growth.

The Hendy Group’s Land Interests

1.11 The Hendy Group have land interests in 3 sites in the Tunbridge Wells Borough.

1.12 The first site is the Hendy Mount Ephraim dealership site (formerly the Lifestyle Ford site) (allocation RTW 8). The Client is the freehold owner of this site and has progressed initial proposals for the residential led redevelopment of the site.

1.13 The use of the Mount Ephraim site has grown organically over many years to now accommodate four motor manufacturers on a very small site. The level of activity has developed to the point where, due to the urban character of this location and the obvious physical constraints there is no opportunity to improve the site layout or facilities to meet current manufacturers standards.

1.14 With new residential led mixed-use development taking place all around the Mount Ephraim area and the change in character that this brings, the current motor trade activity has now almost become a non-conforming user, which impinges upon neighbouring uses. The buildings on site are dated and do nothing to contribute to the surrounding area. The lack of public access through the site from Mount Ephraim isolates the new Royal Wells Park Development from the main town centre commercial area.

1.15 The second site is at Woodsgate Corner, Pembury (allocation PE 7). Hendy have agreed to purchase the site from Tesco subject to the grant of planning. There is currently a live application for the development of a Motor Village Car Dealership (Ref: 19/00884/FULL) on the site. The proposed site encompasses part of the existing underutilised Tesco car park together with land that was previously part of the adjoining Tesco site and which Tesco originally acquired for the potential future expansion of the foodstore. As part of the Tesco, implemented but not progressed, proposals for a store expansion as granted under planning permission Ref: 09/01265/FULMJ, the land was proposed as a potential future Park and Ride site. The site represents a historic allocation for Park and Ride use which has been rolled forward from previous iterations of the Local Plan to the current Adopted Local Plan. The Park and Ride site has not, however, been delivered and is now not included as part of the emerging Local Plan for a variety of reasons as set out in the Park and Ride Feasibility Review prepared by Mayer Brown, dated 21st December 2018, submitted with the current Full Planning Application at Pembury Road (Ref: 19/00884/FULL) (Document 1). As set out in this report, the key reasons the Park and Ride has not been delivered include:

  • The cost of acquiring the site;
  • The limited projected benefit – a maximum three-minute potential journey time reduction (dependent on wider road widening measures) and projected limited take-up with minimal impact on current traffic levels;
  • The significant physical challenges of delivering the necessary road widening measures to achieve the necessary bus priority measures on the A264 Pembury Road;
  • The impact on existing town centre parking charges;
  • The need to amend existing parking restrictions;
  • The annual operating costs for the facility would run at a significant deficit.

1.16 The proposed Motor Village use on Pembury Road will facilitate a reorganisation and expansion of the Hendy Group business within the region including facilitating relocation from the existing Mount Ephraim Hendy dealership within the centre of Tunbridge Wells which will then free this site up for redevelopment.

1.17 The third site is the Renault site on Langton Road. Hendy do not own the freehold of this site; however, they have an existing long term leasehold interest and an active existing use.

Policy Number: Policy AL/PE 7 (Woodsgate Corner)

Comments; Support with conditions

1.49 Our Client fully supports the allocation of this site which will protect existing jobs in the Borough, create new jobs and facilitate the relocation of the Mt Ephraim site (AL/ RTW 8), freeing up this site for development. However, the policy should be reworded as follows to ensure consistency with the live planning application.

Point 1

1.50 The general wording of ‘provision of car showroom and associated uses/employment’ should be reworded to ‘the provision of a Motor Village Car Dealership with associated employment uses’.

Point 6

1.51 As no buildings are proposed to be demolished, the reference to ‘avoidance of demolition’ is not relevant and should be removed from the policy wording.

Point 7

1.52 As the site is not located in a Groundwater Protection Zone [4 Figure 5, Flood Risk Assessment and Drainage Strategy, Nolan Associates, January 2019, submitted with the currently live application at Pembury Road, Ref: 19/00884/FULL.], this is not relevant to the allocation and should be removed from the policy wording.

Other Contributions

1.53 The broad range of mitigation measures can also be more focussed given that this is a live application. The improvements to the public realm at the centre of Pembury are not considered necessary to make the development acceptable in planning terms or required to mitigate the impact of the development. Improvements are better focussed within the vicinity of the site. In this regard the current planning application proposes to include additional woodland edge and shrub planting, provision of a green roof on the rear showroom, provision of ‘green walls’ along the gabion retaining wall, and provision of Bird and Bat boxes.

1.54 Our Client therefore recommends that point (a) is removed from this policy.

1.55 Points (b) and (c) of the Policy identifies that ‘other highways related works’ and ‘measures to enhance bus travel’ may be necessary to mitigate the impact of the development.

1.56 These measures should directly relate to the impact of the proposed development and should be balanced against the consented and implemented Tesco Park and Ride consent (Ref: 09/01265/FULMJ).

1.57 Point (5) of the Policy already states that development should assess the impact of the proposal on transport and highways and is clear that contributions should be provided to mitigate any impact that is considered to be severe.

1.58 As such, our Client considers that the additional points (b) and (c) are thus unnecessary and can also be removed from the Policy wording.

Other

1.59 The supporting text at paragraph 5.134 notes that the site includes an SSSI. This is not correct, and our Client suggests that reference to the SSSI is removed.

1.60 Map 93 (Page 338 of the TWBDLP) should be amended to reflect the proposed development boundary as defined on the Site Plan (Ref: 1710 PL.04 P2) as submitted as part of the current planning application Ref: 19/00884/FULL (Document 2). The development area including all buildings, car parking, circulation areas, site access and areas of proposed signage should be shown as white land within the Proposed Site Allocation Policy boundary. These areas should not be included under any designation as open space or as a landscape buffer.

1.61 As stated above under Policy STR/PE 1 the whole allocation site, as outlined on Map 93, has not been included on the draft Policies Map. 

1.62 To avoid any confusion in bringing forward allocation AL/PE 7, our Client would recommend that the Limits to Built Development is amended to include the whole allocation area.

Support subject to the following amendments:

Our Client strongly recommends that this policy is reworded as follows to ensure that this policy is robust and consistent with national policy:

1. “Provision of car showroom and associated uses/employment a Motor Village Car Dealership with associated employment uses;

6. Avoidance of demolition wherever possible (see Policy EN 2: Sustainable Design and Construction);

7. Regard to be given to the Groundwater Source Protection Zone affecting the site, in consultation with the Environment Agency;

a. Improvements to the public realm at the centre of Pembury;

b. Any other highways related works;

c. Measures to enhance bus travel.

Our Client strongly recommends the following change to the supporting text:

“5.134

This site:

* Includes a Tree Preservation Order and SSSI;”

Amend the Limits to Built Development to include the whole of the site AL/PE 7 allocation outline

[TWBC: see full representation and supporting documents; Park and Ride Feasibility Review and Site Location Plan].