Skip to main content

Section 5: Place Shaping Policies Royal Tunbridge Wells


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

Contents

General comments

Comment No.

Name/Organisation

Response

DLP_1798

Royal Tunbridge Wells Town Forum

In paragraph 5.7, mitigation of transport impact from new development is mentioned. In practice this will prove very difficult to achieve to the required extent in the case of major developments. Thus the failures of mitigation policy in relation to the Berkeley Homes site at Hawkenbury are not encouraging, but a more determined policy in the new Local Plan must at least improve on the present lack of effective mitigation on major development.

Paragraph 5.9 will have to be redrafted in the light of the political decision not to proceed with the Calverley Square development.

In paragraph 5.10 and 5.11 we support a policy seeking to retain and improve the wider retail and leisure offer in RTW to take account of the significant changes actual and predicted in the present retail economy of the town, including adaptability within the design of new buildings.

DLP_3181

Kent County Council (Growth, Environment and Transport)

Royal Tunbridge Wells: Overview

Waste 

KCC would wish to see the North Farm Waste Transfer Station and Household Waste and Recycling Centre included in the Overview Table, as it is a key piece of infrastructure that serves the whole of the District.

DLP_4290

Changing Cities for 42 Leisure PLC

Royal Tunbridge Wells: Paragraph Numbers 5.8-5.52

42 Leisure objects strongly to the omission of land at Montacute Gardens as a site allocation from the Draft Local Plan and would request that it is reinstated. The site is allocated for development as Site AL/RTW 4B in the Tunbridge Wells Sites Allocations Local Plan adopted in July 2016. The Strategic Housing and Economic Land Availability Assessment concludes that the site (ref: 7) is unsuitable for development but fails to recognise that it is allocated for development in the adopted Development Plan and has previously been assessed by an independently appointed Inspector who concluded it was suitable for mixed use development. The SHEALA provides no justification as to why the site should now be excluded from the Local Plan. 

42 Leisure Ltd has a long standing commitment to helping Tunbridge Wells fulfil its great potential. The Company was established with the purpose of delivering high quality development and area regeneration which will ensure the town centre remains prosperous and vibrant whilst protecting and enhancing its unique character and heritage- making it the destination of choice with a stronger visitor economy and cultural offer. 42 Leisure has prepared a comprehensive vision for the area incorporating Montacute Gardens, Union House and the surface car park (formerly referred to by the Council as the Eridge Road Area of Change) and is committed to working with the Council and other landowners in delivering this. 

The allocation of Land at Montacute Gardens in the Tunbridge Wells Sites Allocation (Policy RTW4) for mixed use development as part of a comprehensive strategy to regenerate and revitalise the southern part of the Town Centre was the subject of extensive discussion at the Examination in Public when the Inspector recommended the Eridge Road Area of Change should be split into two sites – RTW 4A Union House and RTW 4B land at Montacute Gardens to allow the Union House site to come forward in advance of comprehensive proposals and a Master Plan for the whole area. However, in approving the Union House development, the Council required the applicant to demonstrate that it would not preclude the development of land at Montacute Gardens and the achievement of strategic objectives for the regeneration of this part of the town centre. 

The proposed deletion of land at Montacute Gardens is contrary to the adopted Development Plan for the area and would have serious implications for achieving the Council’s overall objectives for the town centre. 

Policy AL/RTW4B states:

This site, as shown on the Royal Tunbridge Wells & Southborough Proposals Map, is allocated for mixed use development. 

The following uses would be acceptable as part of a mixed use scheme:

  • office (B1): high quality (B1) office space * hotel and conference uses (C1)
  • leisure and cultural uses
  • residential use: the provision of approximately 30 units
  • parking: any development should reinstate at least the same amount of public car parking spaces with the provision to include additional or fewer spaces as considered necessary, subject to the latest available evidence. The siting of any parking will need to consider the sensitive location of this site, being an ‘entrance’ into the centre of the town, close to Tunbridge Wells Common
  • transport improvements: development shall contribute to transport improvements, to include traffic mitigation along the A26 (Eridge Road and London Road) within the vicinity of the site

Proposals for redevelopment and refurbishment shall accord with the following principles:

  • a townscape assessment must be produced to inform and guide redevelopment and refurbishment within the site area. This will focus on enhancing the Conservation Area and the setting of Tunbridge Wells Common and The Pantiles
  • proposals must be accompanied by an Air Quality Assessment and appropriate mitigation measures the development shall provide a connection to the sewerage system at the nearest point of adequate capacity , as advised by the service provider
  • development proposals will be expected to:
  • deliver public realm improvements that will enhance the pedestrian route between Linden Park Road and The Pantiles, through the site to the West Station/Sainsbury’s and Homebase area, and also linking to Tunbridge Wells Common and its car park * create active frontages along the pedestrian routes
  • create green infrastructure links within the site and to Tunbridge Wells Common and The Pantiles
  • provide public art, which may include water features, within the site

Proposals for developing the site shall not compromise the wider aims and development proposals of Policy AL/RTW4A (Union House) and wider Core Strategy objectives. This requirement is replicated for site RTW4A

The Eridge Road Area of Change presents one of the key development opportunities in Royal Tunbridge Wells and a unique opportunity for the wider regeneration of this part of the town centre. It is underutilised and poorly integrated with the Pantiles and wider town centre. Development within the Area of Change will act as a catalyst for the rejuvenation of the Pantiles and the wider town centre and help to ensure the future prosperity and vitality of the town. The redevelopment of the Union House site has started this process but will not deliver the full potential for revitalisation and enhancement of this part of the town centre. Development and enhancement of the existing properties and land at Montacute Gardens and the surface public car park are essential to realising the benefits for Tunbridge Wells. This should be acknowledged in the new Local Plan which should adopt a vision for the Town centre and promote high quality development which is well integrated with the wider Area delivers a rich mix of uses, high quality design and attractive streets and public spaces which respect the character and heritage of Royal Tunbridge Wells. This will require collaborative working between the Council, landowners and other stakeholders.

DLP_5577

Rusthall Parish Council

Paragraph 5.37: The Sports Strategy for Royal Tunbridge Wells

This includes:

  • Policy AL/RTW 21 Land at Culverden Stadium, Culverden Down
  • Policy AL/RTW 22: Land at Bayham Sports Field West
  • Policy AL/RTW 23: Land to the north of Hawkenbury Recreation Ground
  • Policy AL/RTW 24: Land at Cadogan Sports Field, St John’s Road
  • Policy AL/RTW 25: Land at Colebrook Sports Field, Liptraps Lane

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected. My reasons for wishing to retain these sites include the following:

1. We need green spaces for children/families to be able to play. Some families don’t have gardens, or only small ones. They need places near their homes to play with a ball, cycle on their bikes, and play with friends and family without having to be driven across the borough.

2. People need them to walk, run and socialise with others in their community.

3. They are good for our mental health and physical wellbeing. They beautify an urban area and make people feel better about the environment they live in.

4. The trees and plants help provide good air quality. Removing the local playing fields will do much harm to the borough. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable. It will also force more people into cars on our already congested roads, increasing traffic congestion and pollution. Other sites should be considered that do not involve building on playing fields.

DLP_7371

Tunbridge Wells Over Fifties Forum

Tunbridge Wells Over Fifties Forum have concerns about:

Needing even, tidy, car free kerbs and pavements.

Bus stops with shelters and easily legible, correct timetables on site which do not require mobile usage to get info.

Pot hole free roads.

24/7 accessible shops, amenities and train stations.

We have many elderly and/or infirm members who would benefit from the above improvements.

Policy STR/RTW 1: The Strategy for Royal Tunbridge Wells

Comment No.

Name/Organisation

Response

DLP_20

Darren White

also there is significantly greater supporting infrastructure being proposed for these 1,222 properties which means that everyone will be expected to travel into TW for school etc

DLP_573

Anne Backshell

I am a Rusthall resident who is also a cyclist concerned about any new housing development which would increase the traffic on the A264 between Langton Green and Tunbridge Wells. The road is dangerous for cyclists as there is not enough space for cars to pass.

A proper cycle path separate from the road for cars is needed.

This would have many advantages:

  1. Alleviate the traffic congestion in the rush hour as school children could cycle safely to school
  2. Increase the fitness of the children
  3. Improve everyone’s health by reducing the air pollution from cars

If the Council was prepared to spend millions on a new Civic Complex surely it could spend a fraction of this amount to improve the health, fitness and general well-being of its residents.

DLP_594

Sport England

Sport England supports points 6 an d7 together with c and d in the Contributions Required which is supported in the adopted playing pitch strategy and the indoor/built sports facility needs assessment.

Sport England supports contributions being sought towards the new sports hub at Hawkenbury as it is in line with the Playing Pitch Strategy.

DLP_942

Tom Clarke MRTPI

We support part 1 of this policy which seeks to deliver a new 1,200 seat theatre at Calverley Square.

DLP_2883

Chris Gow

The proposed Calverley Square should be scrapped immediately, and further expenditure stopped, and the losses written down as an example of the folly of ambition over appropriate development for Tunbridge Wells.

DLP_2884

Chris Gow

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

DLP_2885

Chris Gow

Paragraph 3

I object to the use of Green Belt land for any development, and an alternative location should be found.

DLP_1804

Royal Tunbridge Wells Town Forum

Policy Number:  STR/RTW 1: Strategy for Royal Tunbridge Wells 

Support with conditions + General Observations

In Paragraph 4, the need to ensure the maximum potential for active travel to primary schools makes the expansion of St Peter’s and Skinners Kent Primary School grossly inadequate. KCC’s focus on overall capacity and providing and maintaining school places at the lowest initial outlay has resulted in unsustainable long-term consequences for the town in terms of traffic congestion and public health. In view of the climate emergency, provision of primary schooling within walking distance of target populations should in future take precedence over the previous KCC policy of expansion of existing schools, which makes extra car journeys inevitable. At this moment, at the very least, St Peter’s existing site should be maintained as a primary school and work should then be undertaken to identify additional sites.

The Draft Plan refers to Kent’s Commissioning Plan for Education Provision 2019-2023, which is inadequate because:

  • It only covers part of the period of the Local Plan because the plan periods of the Education Commissioning Plan and the Local Plan do not coincide
  • Its recommendations are based on the current local plan with its significantly lower housing numbers
  • It only deals with the total number of school places required without considering the point of need and where they can be accessed sustainably.

Lack of walking access to primary schools is a significant contributor to traffic congestion and therefore pollution, especially from private vehicles. 46% of primary school children are now driven to school by car with numbers on the increase since 2003. [i]Every primary school child driven to school entails four road trips (to and from school twice a day).

KCC’s recent wave of school expansions (still advocated under the Draft Plan) has created ever contracting and expanding catchment areas. This has given rise to thousands of unnecessary rush hour car journeys every week. Bishop’s Down Primary School, Tunbridge Wells, illustrates the problem. It was expanded in order to meet the rising demand in school places since 2004. Because the school premises could not support an additional classroom for every year in the 7-year primary school cycle, classrooms were added for three years to facilitate the intake of an additional class (30 children) during those years. After three years, the intake was reduced from two classes back to one class for the following four years.

The effect has been that children from areas beyond reasonable walking distance were admitted during expanded years. School admissions criteria stipulate that siblings of existing pupils be granted priority access before any children are admitted based on the distance between their home and school. After three years of expansion and the following reduction to the original class size, the school’s reception class consisted exclusively of siblings and no children could be admitted on distance criteria. Moreover, ten siblings were still unable to gain a place. Therefore, those siblings and all local children were assigned different schools and sent to far away schools such as Pembury, which was partially expanded to absorb the overspill. Pembury Primary School in turn started an expanding and contracting catchment cycle of its own requiring children from Tunbridge Wells to travel to Pembury and vice versa. There are thus overlapping areas where parents beyond active travel distance for young children presently drive across town into each other’s neighbourhoods to deliver young children to school.

Under the duty to cooperate, TWBC should collaborate with KCC to protect the last remaining sites where neighbourhood primary schools can be built. We therefore propose adding to the Draft a Policy that would make the potential for a primary school on a site a “material consideration” to be taken into account in deciding any planning application in the town centre. KCC/TWBC should prepare maps that illustrate where the lack of provision already exists and where it will be exacerbated by any residential allocation under the Plan. There are already too many areas without sustainable local primary school provision in Tunbridge Wells. The New Local Plan must ensure that additional town centre sites are reserved for the building of new primary schools during the whole period of the plan.

In Paragraphs 6-8, we support the provisions to expand sport and recreation facilities to mitigate the impact of future development. However, we do have concerns about the potential loss of other local sports facilities to development, which would lead to additional car journeys unless active travel infrastructure is first provided.

We cannot see how any proposal for development within the AONB can make a positive contribution as required by Paragraph 9 when it actually consists of using the AONB for built development. This can only be justified by exceptional circumstances.

We strongly support the provisions in Paragraph 10 to the effect that sites adjoining AONB will have similar characteristics and are likely to contribute to the setting of designated landscapes and that the AONB Management Plan will therefore be a material consideration for these sites.

Paragraph 11 will need to be rewritten in relation to the Great Hall and Mt Pleasant car parks in view of the decision to abandon the planned Calverley Square development. The lumping of the informal Fairground car park with the other publicly owned facilities seems inappropriate. This car park remains controversial and not an appropriate use of the Tunbridge Wells Common in the long term. Similarly the long term use of the coach park behind Sainsbury’s will become inappropriate in the event of the protected alignment of the Grove Junction to Eridge railway line being returned to railway use.

In relation to RTW Town centre:

Paragraphs 1-3 will need to be redrafted to take account of the abandonment of the Calverley Square project.

We support Paragraphs 6-7, pedestrian and cycling infrastructure being vital to ensure active travel from any new residential development in the town centre.

[i]https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/476635/travel-to-school.pdf

DLP_2042

Terry Everest

The number of new dwellings needs to be reduced by at least 50% in order to be a more sustainable level of growth around the town, and local green spaces need to be protected and not widely developed over as currently proposed. In particular playing fields and sports pitches need to be retained locally as it is incorrect both from a functional and an environmentall point of view that these can be replaced or reprovided at any proposed hub. The vast majority of users  (circa 90%) of local green spaces are those that live and work in the vicinity. Most users would not or could not benefit from a distant hub as it would be impractical and unenvironmental. It would create additional unneccessary journeys by car or transport but in actual fact the principle amenity would be lost and the reprovision largley not uptaken.

Tunbridge Wells currently is a nice place to live because of its parks and green spaces and it needs to protect and safeguard all of these from develpopment if it is to remain pleasant. The site for the new theatre at the Calverley grounds is the wrong site because too much of the park in destroyed by the development, the old cinema site would be better.

All proposals to develop on playing fields, greens and sports pitches should be abolished as these are vital parts of the green infrastructure of the town, and key green corridors exist where people can walk and travel away from the pollution of roads and buildings and these must be maintained.

DLP_2220

Dr Cameron Davies

The "new theatre" and its plan should be removed from the Local Plan. Calverley Square was abandoned following the vote at the October 8th full council meeting.

DLP_2433

J Coleman

TWBC should ensure more houses are developed in Tunbridge Wells than currently shown in the Local Plan. Tunbridge Wells is the economic and cultural centre of the Borough but is not taking its fair share of the developments. It has fast road and rail transport links, unlike the eastern rural side of the Borough, so should get more numbers of houses developed.

TWBC should not have all the employment opportunities yet put such a large number of housing developments on the rural eastern side of the Borough. This is not sustainable for the eastern rural villages such as Sissinghurst.

DLP_3093

Philip Day

This is not a joined up plan for sustained parking facilities in and around the Pantiles

The on road parking which has fought off numerous minority resident attempts at curtailment is an asset and should be left alone or increased.

Because

1 In the absence of adequate affordable Railway Station car parking literally hundreds of commuters use it at no hinderance to the residents who are protected where necessary by Zone A. There is nowhere for them to go if on road parking is curtailed.This state of affairs has grown organically over the last ten years at no inconvenience to the locals as they all have their own drives/ permit spaces. Tonbridge has 874 Railway Station spaces Tunbridge Wells 84. Tonbridge has a growing economy we do not.On street parking is our greatest assett.

2 In the absence of adequate short/medium car parking facilities in and around the Pantiles the on road parking allows sufficient fluidity to just about sustain accessibility to shops on a pop in basis.Any reduction will be terminal for the few business surviving on the Pantiles. Similarly the short stay system on the High Street/Pavement works for them. A large affordable dedicated car park for the lower end of town is the only alternative.

Failure to encourage our best retail attractions The High Street and the Pantiles. This is completely reliant on better parking arrangements. With new hotels and domestic developments in and around this area something must be done to expand parking facilities .The owners of the Pantiles have limited motivation and resources, the Council must take this into account when planning parking facilities. For example the complete lack of a dedicated coach park and the loss of a substantial Tourist Information Office has seen our town lose a vast amount of tourist revenue.

This is a beautiful town full of historic interest and we squander it for lack of a joined up plan...every day I see the bemused expressions of visitors baffled by the apparent indifference of the picturesque surroundings to their desire for information. No clear signage,no attractive Tourist Office,no engagement not even toilet facilities. The High Street and the Pantiles are the future they are niche, they are shopping experiences that make Tunbridge Wells different ,indeed unique and attractive, failure to appreciate this and act accordingly will be economically and culturally unforgivable.

DLP_3182

Kent County Council (Growth, Environment and Transport)

Highways and Transportation

Comments on sites mentioned in this policy are set out in individual policy comments.

The County Council agrees with the 'Contributions required' introductory paragraph with the following alterations:

“In order to mitigate the impact on infrastructure, for the development of sites allocated under Policies AL/RTW 1 to AL/RTW 32, and all other development within Royal Tunbridge Wells that creates a requirement for new or improved infrastructure beyond existing provision, mitigation measures must be implemented by the developer to address that impact, including for...”

As Local Highway Authority, KCC considers paragraph a) to be acceptable but the particular reference to cycling amended as follows:

“enabling means of active and sustainable travel infrastructure...”

DLP_3562

Lynne Bancroft

Object 

TWBC should ensure more houses are developed in Tunbridge Wells than currently shown in the Local Plan. Tunbridge Wells is the economic and cultural centre of the Borough but is not taking its fair share of the developments. It has fast road and rail transport links, unlike the eastern rural side of the Borough, so should get more numbers of houses developed.

TWBC should not have all the employment opportunities yet put such a large number of housing developments on the rural eastern side of the Borough. This proposed development is not sustainable for the eastern rural villages such as Sissinghurst.

DLP_4105

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

CPRE objects to a number of aspects of this policy.

Royal Tunbridge Wells Main Urban Area

Section 1

CPRE questions whether the proposed conversion of local sports fields to residential in order to concentrate sports provision at a new hub north of Hawkenbury recreation ground is sustainable, in terms of health, transport and informal recreation, if this means that existing communities who currently use the smaller sports fields that are to be built over will no longer have access to a sports field within easy walking distance.  Often local sports fields are used as much, or indeed more, for informal recreation as for formal sports.  The council will need to provide clear evidence that the local sports fields truly will be redundant before they are allocated for residential use.  Moreover, if these local sports fields are to be replaced by the proposed new sports hub, then there should be  policies ensuring that they are not built on until the new sports hub has been provided.

Sections 3 and 4

Secondary Education

CPRE objects to the proposed new secondary school and major residential allocation at Spratsbrook Farm (AL/RTW18).

This site is located on the East Sussex boundary within the green belt and AONB and is allocated for 270 dwellings and a seven form entry secondary school. CPRE is concerned about the impact of this development on the AONB and green belt, as well as its impact on heritage assets and its potential impact on the Ashdown Forest SPA through the traffic generated by it.

It is not clear from policy AL/RTW18 where the requirement for such a large school comes from and which catchment area it is designed to serve. No evidence appears to have been provided as to consideration of alternative sites and solutions for expansion of secondary education in Tunbridge Wells that would be less damaging to the AONB and Green Belt.  (We note that through lack of forward thinking by KCC and the Borough Council the opportunity was lost for a secondary school to be provided as part of the previous large residential allocation at Hawkenbury).

Primary Education

In Paragraph 4, the need to ensure the maximum potential for active travel to primary schools makes the expansion of St Peter’s and Skinners Kent Primary School grossly inadequate. KCC’s focus on overall capacity and providing and maintaining school places at the lowest initial outlay has resulted in unsustainable long-term consequences in terms of traffic congestion and public health. In view of the climate emergency, provision of primary schooling within walking distance of target populations should in future take precedence over the previous KCC policy of expansion of existing schools, which makes extra car journeys inevitable. At this moment, at the very least, St Peter’s existing site should be maintained as a primary school and work should then be undertaken to identify additional sites.

The Draft Plan refers to Kent’s Commissioning Plan for Education Provision 2019-2023, which is inadequate because:

  • It only covers part of the period of the Local Plan because the plan periods of the Education Commissioning Plan and the Local Plan do not coincide
  • Its recommendations are based on the current local plan with its significantly lower housing numbers
  • It only deals with the total number of school places required without considering the point of need and where they can be accessed sustainably.

Lack of walking access to primary schools is a significant contributor to traffic congestion and therefore pollution, especially from private vehicles. Nationally, 46% of primary school children are now driven to school by car with numbers on the increase since 2003.[1]Every primary school child driven to school entails four road trips (to and from school twice a day).

KCCs recent wave of school expansions (still advocated under the Draft Plan) has created ever contracting and expanding catchment areas. This has given rise to thousands of unnecessary rush hour car journeys every week.

Bishop’s Down Primary School, Tunbridge Wells, illustrates the problem. It was expanded in order to meet the rising demand in school places since 2004. Because the school premises could not support an additional classroom for every year in the 7-year primary school cycle, classrooms were added for three years to facilitate the intake of an additional class (30 children) during those years. After three years, the intake was reduced from two classes back to one class for the following four years. The effect has been that children from areas beyond reasonable walking distance were admitted during expanded years. School admissions criteria stipulate that siblings of existing pupils be granted priority access before any children are admitted based on the distance between their home and school. After three years of expansion and the following reduction to the original class size, the school’s reception class consisted exclusively of siblings and no children could be admitted on distance criteria. Moreover, ten siblings were still unable to gain a place. Therefore, those siblings and all local children were assigned different schools and sent to far away schools such as Pembury, which was partially expanded to absorb the overspill. Pembury Primary School in turn started an expanding and contracting catchment cycle of its own requiring children from Tunbridge Wells to travel to Pembury and vice versa. There are thus overlapping areas where parents beyond active travel distance for young children presently drive across town into each other’s neighbourhoods to deliver young children to school.

Under the duty to cooperate, TWBC should collaborate with KCC to protect the last remaining sites where neighbourhood primary schools can be built. We therefore join with the Town Forum in proposing adding to the Draft a Policy that would make the potential for a primary school on a site a “material consideration” to be taken into account in deciding any planning application in the town centre. KCC/TWBC should prepare maps that illustrate where the lack of provision already exists and where it will be exacerbated by any residential allocation under the Plan. There are already too many areas without sustainable local primary school provision in Tunbridge Wells. The New Local Plan must ensure that additional town centre sites are reserved for the building of new primary schools during the whole period of the plan.

[1][1]https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/476635/travel-to-school.pdf

Section 6

The proposal for a new sports hub at Hawkenbury recreation ground, to include standing/seating for supporters and other ancillary structures, appears to be major development within the AONB which has not been adequately justified under NPPF paragraph 172.  Moreover, while the proposal for upgraded sports facilities for Royal Tunbridge Wells is laudable, this proposal on the outskirts of the town cannot be held to be sustainable in transport terms if it is at the expense of the conversion to residential development of more local sports and recreation fields which are within walking distance of the communities they serve.

Royal Tunbridge Wells Town Centre

Section 1

Following the abandonment by the Council of the Calverley Square proposal, this section requires amendment.

Section 2

There is a severe undersupply for sustainably accessible primary school places in and around the town centre (see our comments above concerning the main urban area). The current shortage needs to be addressed and future deterioration of the situation pre-empted. This requires immediate action on the part of TWBC under this Plan to avoid any suitable sites being lost to alternative development.

Under the Duty to cooperate, TWBC needs to ask KCC to update its outdated Commissioning Plan for Education 2017 to reflect the much increased population forecasts and request that suitable sites are identified immediately by mapping catchment areas and travel patterns, so that sites can be protected by assigning them exclusive D1 use.

North Farm/Longfield Road defined Key Employment Area

Section 1

CPRE objects to these allocations in the Green Belt and AONB, which alone vastly exceed the 14ha of additional employment land identified in the Economic Needs Study as required throughout the Borough, and which are major development that has not been adequately justified under NPPF paragraph 172.

DLP_4263

RTW Civic Society

Point 7 seems to indicate sports and recreation grounds will be provided elsewhere other than Hawkenbury. However, point c later in the policy suggests only Hawkenbury will be developed.

DLP_4291

Changing Cities for 42 Leisure PLC

Policy STR/RTW1 fails to recognise the need to regenerate and revitalise the southern part of the Town Centre. There is an over emphasis on development and the provision of new cultural facilities in the northern part of the Town Centre which will be further detrimental to the area around the Pantiles unless this imbalance can be addressed. This was a key part of the rationale for the identification of the Eridge Road Area of Change in the Draft Site Allocations Local Plan (later sites AL/RTW 4A and AL/RTW 4B). The deletion of site RTW 4B (land at Montacute Gardens) will prejudice the potential for regeneration and enhancement of this key gateway to the Town Centre.

DLP_4366

British Horse Society

Support with conditions

Bullet point 6, the new sports hub at Hawkenbury should include horse riding facilities and link to public bridleways in the area

Bullet point 8 should mention provision of public bridleways

DLP_4409

Alison Adams

I am a resident of Horsmonden and have lived here for the last 6 years.  During my time I have been the Chair of the local Horsmonden Kindergarten and I have been very busy renovating my home and garden.  I love living in this village with its community spirit and feel very involved and integrated in the society here.

Although I appreciate that new housing is inevitable and do not object to sensitive and structured new building I am concerned greatly by the idea of large scale new development which does not take into account the requirements of the existing community or the actual requirements of the prospective purchasers of the homes.

Horsmonden like most villages provides a mixture of housing and there are many residents living here who do not foresee living anywhere else. Houses however do come onto the market and at present there are a number in the village that have been up for sale for over a year. My question is therefore, how have the “powers that be” come up with the decision that we need to create 13,560 new homes (Para 4.7)?  If we do need these homes I sincerely hope that the main priority is to create homes that will fulfil the specifications that these new prospective owners are looking for.  In my view one of the biggest problems that we face is that large family homes continue to be occupied by parents well after their children have left, couples in their 60s, 70s and 80s are reluctant to downsize due to the lack of smaller but prestigious, spacious, convenient houses/apartments/bungalows that also offer attractive outside space. This creates a barrier to the upward movement of younger families who wish to gain more space.  Space in the South East is at a premium so there needs to be some incentive to free up these family homes for the new generation.

I would also like to be 100% certain that the companies that are employed to build all these new homes are actually controlled so that the new homes are good quality and sustainable with eco-friendly initiatives being used. Why is it not compulsory to have solar panels, permeable paving, grey water storage?  All these design features are available and if every builder was enforced to use them there would be economies of scale so the price of these technologies would ultimately come down.

In terms of the Consultation I would like to comment on the following:

Strategy for Royal Tunbridge Wells – STR/RTW1

This beautiful Spa Town seems to have already lost its sole.  Development I hope would provide a new lease of life to a town with a dwindling shopping centre. Considering that the modern generation are less likely to shop in the High Street there should be consideration of a change of use to the many retail outlets that are closed.  These closed retail units and undeveloped areas do not enhance morale, for residents and shopkeepers alike, and reduce pride in their surroundings.

I appreciate the opportunity to comment and hope that the Borough Council will take into account the many and varied views of the people of the borough.  Maybe building thousands of new homes will boost the economy in the short term but once built these homes cannot be removed so let’s hope there is a real demand and that the houses built actually satisfy that demand.

DLP_4538

Historic England

Policy STR/RTW 1: The Strategy for Royal Tunbridge Wells - Royal Tunbridge Wells Main Urban Area – the policy sets an ambitious target for new development in the primary town centre in the Borough that could be transformational if fully implemented. This ambition must be balanaced, however, with the requirement to conserve and enhance the important and pervasive historic character of the town (the whole town centre and adjoining urban areas are within the Tunbridge Wells Conservation Area) and the many heritage assets within it, including their settings. We are not convinced that that sense of achieving such a balance has been adequately set out in the current text of the policy.

DLP_5202

Culverden Residents Association

Support with conditions + General Observation

In relation to paragraph 1, we are not able to comment on whether the housing need identified is correct, but if it is, the proposed distribution of allocations seems to take account of the concerns we have previously expressed about further development in St John’s and Culverden Wards and we therefore broadly support it.

As an association we have not previously objected to increases in the local population from housing developments. We have rather sought to engage with developers such as Berkeley Homes to secure the best outcome from proposed developments, initiating the idea of the new Free School on Mt Ephraim, the dividing of the former hospital site and the extra care housing on Culverden Park Road. However, it is now clear to us that any further significant development in Culverden or St John’s Wards would have intolerable consequences both for older established residents and also residents of the many existing new developments. Our views are not based on anecdotal evidence, strong though it is, but on local census and other statistical population figures. Without taking account of the developments that have come on stream at the Dairy Crest site and will occur at the Arriva site and also recent local windfall developments, these show that:

  • In Culverden the population increased from 6,310 in 2001 to 8,503 in 2015
  • In St John’s the population increased from 6,690 in 2001 to 7,639 in 2015

There was hardly any improvement in community or other amenities during that period and a general diminution in the quality of life. Social cohesion would definitely be threatened by any further increases in population in our Wards.

In paragraph 4, The policy does not provide for the creation of sufficient local primary schools to allow substantial reduction in the motorised “school run” across the town. The problem of allocation of unsuitably located primary school places continues to become more acute. We urge TWBC to be more active in seeking solutions from KCC. It should promote site allocations in the town that would include the possibility of educational provision if required at a future date.

In view of the climate emergency, provision of primary schooling within walking distance of target populations should in future take precedence over the previous KCC policy of expansion of existing schools, which makes extra car journeys inevitable. [i]Every primary school child driven to school entails four road trips (to and from school twice a day). This outdated policy has given rise to thousands of unnecessary rush hour car journeys every week.

KCC’s recent wave of school expansions has created ever contracting and expanding catchment areas. This has affected us particularly badly in Culverden and St John’s Wards. Bishop’s Down Primary School, Tunbridge Wells, illustrates the nature of the problem. It was expanded in order to meet the rising demand in school places since 2004. Because the school premises could not support an additional classroom for every year in the 7-year primary school cycle, classrooms were added for three years to facilitate the intake of an additional class (30 children) during those years. After three years, the intake was reduced from two classes back to one class for the following four years.

The effect has been that children from areas beyond reasonable walking distance were admitted during expanded years. School admissions criteria stipulate that siblings of existing pupils be granted priority access before any children are admitted based on the distance between their home and school. After three years of expansion and the following reduction to the original class size, the school’s reception class consisted exclusively of siblings and no children could be admitted on distance criteria. Moreover, ten siblings were still unable to gain a place. Therefore, those siblings and all local children were assigned different schools and sent to far away schools such as Pembury, which was partially expanded to absorb the overspill. Pembury Primary School in turn started an expanding and contracting catchment cycle of its own requiring children from Tunbridge Wells to travel to Pembury and vice versa. There are thus overlapping areas where parents beyond active travel distance for young children presently drive across town into each other’s neighbourhoods to deliver young children to school. This problem has to be solved as soon as reasonably practicable.

We therefore strongly support the proposal from the Royal Tunbridge Wells Town Forum that there should be a Policy in the new Local Plan that would make the potential for a primary school on a site a “material consideration” to be taken into account when deciding any planning application in the town. KCC/TWBC should urgently prepare maps that illustrate where the lack of provision already exists and where it will be exacerbated by any residential allocation under the Plan.. The New Local Plan must then ensure that additional town centre sites are reserved for the building of new primary schools during the period of the plan.

If the existing allocation on the Arriva Garage site is not built out for any reason under the present planning consent, we would advocate that the rear part of the site should be developed as a primary school to meet the existing unfulfilled need on both sides of the A26 in this area.

The STR/RTW 1 policy does not specifically provide for creation of further 20mph zones in the town. A recent AGM of our association unanimously called for such a zone to be established in the whole of the area bounded by the A26/ Mt Ephraim, Molyneux Park Road, Culverden Down and Whitefield Road. We set out further justification for such a zone with accompanying filtered permeability and a safe route to schools to reduce the “School run”, in our comments on the Transport Strategy Review post.

We support paragraph 10 which recognises that some sites outside the AONB but within the High Weald National Character Area or close to the boundary with the AONB have similar characteristics and contribute to the setting of the AONB. This is particularly the case for the farmland between Broomhill Road, Speldhurst Road and Reynolds Lane which not only provides buffer to the adjoining AONB, but is also the setting for the historic house and park at Salomons. We therefore support the concept of the AONB management plan and supporting guidance being a material consideration for these sites.

[i]https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/476635/travel-to-school.pdf

DLP_5690

Mark Wright

We write regarding our land to the north of Hawkenbury Road, adjacent to Hawkenbury Recreation Ground. We want our land to be considered for housing development within the Local Plan. We have permission to submit this site and agree that the Council can use use our information.

We enclose the following documents:

  1. Official Copy of Register Of Title No. K484485.
  2. Site Submission Plan.

Please note that I am Mark Richard Wright, the Proprietor, and would be grateful if all correspondence could be sent to me via this email address. Alternatively I can be contacted at my new address at xxx [TWBC: postal address redacted].

DLP_5753

Woolf Bond Planning for Castle Hill Developments Ltd

I write on behalf of my clients, Castle Hill Developments Limited, in respect of a large area of land situated to the north of Tunbridge Wells. The site comprises approximately 285 acres (115.4 hectares) undeveloped land to the north of the Longfield Road employment area (see enclosed site plan; area edged red). The site includes undeveloped field parcels together with some areas of ancient woodland, and is bounded to the west by the railway line, to the north by established woodland and to the east by the A21.

To the south east, part of the site is included in the consultation draft Local Plan allocation at North Farm/Longfield Road under Policy AL/RTW 12. The draft policy allocates the land to the east of the existing employment area for approximately 80,000 sq.m business (B1), general industrial (B2) and storage and distribution (B8) floorspace. The northern part of the draft site allocation extends into our client’s land, and is predominantly identified for allocation as “open space and landscape buffer”.

Firstly, we confirm our support for the proposed employment site allocation to the east of the existing employment land; the land shown white on the draft Map 12 of the consultation Local Plan. We consider that the proposed extension of the existing key employment area represents a suitable and sustainable form of development on this side of Tunbridge Wells. It is also noted that draft Strategic Policy STR/RTW 1 The Strategy for Royal Tunbridge Wells identifies that the proposed employment allocation area is also potentially suitable for leisure and ancillary facilities. This would also be supported and it is considered fundamental to a sustainable neighborhood to have a broad mix of uses within close proximity of housing and employment sites.

It is considered that the Council is missing a genuine opportunity to allocate further land in this location for a sustainable urban extension to Tunbridge Wells, which could deliver additional housing to support the draft allocated employment land.

The site identified on the enclosed plan represents a logical northwards extension of Tunbridge Wells, which in our view, is spatially preferable to the proposed garden village at Tudley. Tunbridge Wells is the largest settlement in the Borough, and it therefore makes for the most sustainable location in which to direct a large proportion of the Borough’s housing requirement. We support the Council’s acknowledged housing need of 13,560 dwellings across the Plan period 2016 – 2036, which equates to an annual requirement of 678 per year, based on the Standard Method approach set out in the NPPF. The NPPF also seeks to encourage sustainable patterns of development, which in our view means directing development to the largest and best serviced towns in the housing market area. The allocation of a modest 780 dwellings at Tunbridge Wells is not considered sufficient or sound to meet the needs of a growing centre.

The site is physically well contained, by virtue of the A21 to the east, which would also provide transport links to the strategic highways network; significant woodland and ridge to the north, which would provide a natural buffer and northern boundary to development in this location; the railway and further woodland to the west, which would again limit development in this direction, and Tunbridge Wells to the south.

The new employment floorspace planned on land within and adjacent to the site would support a logical neighbourhood-scale extension to Tunbridge Wells to the north. Furthermore, the planning of additional residential development within close proximity to planned employment growth would make for a more sustainable pattern of development, by providing people with the opportunity to travel to work using sustainable modes of transport.

Through recent plan-making, land has already been omitted from the AONB and Green Belt to the north of Tunbridge Wells (Site Allocations reserved land AL/GB4). This demonstrates that this part of the AONB is not as sensitive in landscape terms as other areas in which the boundaries have been maintained. Furthermore, the Council acknowledges the need for Green Belt releases to provide sufficient land to deliver its housing strategy. The NPPF allows for releases of land to support sustainable patterns of development (para. 138). The land north of Tunbridge Wells is more sustainably located than the planned Green Belt release at Tudley, with a well-developed existing network of infrastructure. It is therefore considered a more logical and appropriate location to provide additional housing.

A further consideration is the housing market at Tunbridge Wells. This is stronger  and better placed to support the delivery of additional houses, in preference to the planned Tudley village, where the housing market will be saturated by completions at both the garden village and Capel/Paddock Wood.

This site is in the ownership of two landowners, and therefore represents a deliverable option for housing development which the Local Planning Authority can rely upon to deliver its housing needs.

The site could be allocated in preference to the new garden village at Tudley, which in our view represents an unsustainable community set in an isolated location within the Green Belt.

We genuinely believe that this site represents a realistic development option and would like to engage with the Council to discuss its merits in greater details. Through that process we will commission additional technical reports to support the suitability of the site including the following disciplines;

  • Landscape
  • Transport
  • Ecology
  • Drainage and flood risk

I look forward to hearing from you in respect of this site, and can be contacted on the details below.

See site location plan

DLP_5933

S J Ireland

My personal interest is as a local resident of Cranbrook with professional experience as past Director of Open Spaces for City of London (recently retired), a career in Landscape Management and a Fellow of the Landscape Institute.

  1. Having reviewed the retail study and your proposals for Tunbridge Wells, I object to the number of houses you have allocated to the main urban area. Your report accepts that the retail sector is changing significantly and yet your proposal to locate on average 1271 houses (whilst for example, requiring Cranbrook to take 761) is proportionately wrong. This is the ideal location for apartments- particularly one and two bed accommodation aimed specifically at younger and older elements of the population; where all the services are located close by and limited transport requirements. needed. By increasing the housing in the main urban area, your sustainability requirements will be easily achieved.
  2. Cranbrook has substantial AONB landscapes. I found no explanation , within the plan, as to why you are ignoring government policy which allows the Council to reduce the housing pressure by 50% in such cases. You have a duty to protect theses landscapes.
  3. The use of the term " affordable housing" is unhelpful because such units are not affordable by local people. I would encourage you to review your policy and instead focus on 1 & 2 bed properties, which can better suit need.

DLP_6192

Turley for Bellway Homes Strategic

We have set out comments elsewhere regarding the disproportionally low levels of development directed to Tunbridge Wells in comparison to other settlements.

Point 6 of the draft policy refers to “A new sports hub at Hawkenbury Recreation Ground, to include standing/seating for supporters and other ancillary structures.” This scheme is also referred to elsewhere in the policy as point c under the heading ‘Contributions Required’. We understand this refers to the development expected under Policy AL/RTW 23 which, as these representations sets out, should be considered undeliverable with the Council’s own evidence suggesting that this area would be a suitable, sustainable and logical site for housing/economic development (in the SHELAA). These references should therefore be removed from Policy STR/RTW 1.

[TWBC: see full representation and Comment Numbers DLP_6189-6198].

DLP_6273

Susan Heather McAuley

Paragraph 5.6

As the Local Plan states, Royal Tunbridge Wells is a sustainable location in every aspect.  Therefore RTW should be taking a much larger share of the new building.  It has facilities, services, employment, leisure and cultural offerings which will enable it to easily sustain more residents.

DLP_6559

Woolf Bond Planning for Millwood Designer Homes Ltd

Site 60: The Paddocks, Home Farm, 92 Lower Green Road, Rusthall TN4 8TT

Policy STR/RTW1: The Strategy for Royal Tunbridge Wells

Representation

As set out in response to Policy STR4 above, Rusthall forms part of the wider environs of Royal Tunbridge Wells. As such, it represents one of the most sustainable locations in planning for housing growth during the plan period.

However, the restrictive approach to the Green Belt boundary serves to prevent sustainable growth in this location.

Omission Site: Land at Home Farm, Lower Green Road, Rusthall

General

Our client’s site comprising land at Home Farm, Lower Green Road, Rusthall (SHELAA Site Ref: 60) is submitted as an additional housing allocation. The Site is edged red on Plan WBP1 attached and extends to approximately 1.3ha.

We have undertaken a thorough assessment of the character of the site and surrounding area and consider that it affords a sustainable development opportunity for approximately 25 dwellings.

The site is well related to the urban area and is well contained from the wider Green Belt, which conclusion is supported by the Council’s assessment of the site as set out in Appendix A of the Council’s Green Belt Study (LUC) (July 2017) (see our response to Policy STR4 above).

Development of the site for approximately 25 dwellings would enabling a high-quality housing scheme to be located within walking distance from local services and facilities, including the High Street which is within an easy 0.5km walk to the south of the site.

Access can be readily achieved from Lower Green Road, and there is a pedestrian footway to the High Street which enables safe and convenient access to local services and facilities by foot.

The site is also within a short 0.25km walk to a bus stop which provides regular services to Tunbridge Wells.

The proximity of the site to local services is shown on supporting Site Context Plan No. WBP2.

Accompanying Plan No. P352/MDR explains how improvements to the site access can be achieved in order to provide for a safe means of access to serve development of the site for housing.

Overall, the site has no physical constraints, and is well-related to the existing residential development. It is in close proximity to local services and facilities such that it affords a sustainable location in helping to meet identified housing needs whilst providing for sustainable patterns of growth.

Suggested Change

Allocate land at Home Farm, Rusthall (SHELAA Site Ref: 60) as a housing allocation for approximately 25 dwellings.

[TWBC: see full representation, site context plan, access improvements and site location plan].

[TWBC: see also Comment Numbers DLP_6548-6450, 6452-6453, 6456-6457, 6459]

DLP_7068

Brown & Co Planning Ltd for The Hendy Group

Policy Number: STR/RTW 1 - The Strategy for Royal Tunbridge Wells

Comments; Support with conditions

1.18 Our Client supports the need to mitigate against the impact of development in Tunbridge Wells, however, it is considered that this policy should recognise that contributions to mitigate the impact of a development should be proportionate and cannot address existing deficiencies.

1.19 A proportionate approach is supported by paragraph 2.27 of the Infrastructure Delivery Plan (IDP, draft 2019) which states that new development is generally expected to meet the needs for infrastructure that are generated from the development itself.

1.20 As set out at paragraph 34 of the NPPF, plans should set out the contributions expected from development, but this “should not undermine the deliverability of the plan”.

1.21 The Council cannot rely solely on new development to meet infrastructure needs and both the Council and statutory providers will also need to contribute in order to address existing deficiencies in infrastructure in Tunbridge Wells (see comments below on the Vision and Objectives 1).

Support subject to the following recommendations:

* To ensure that development is not overburdened, the policy should state that the contributions should be proportionate and based on the relative impact of the development.

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

DLP_7097

Richard Hopkinson Architects for J Murphy & Sons and SGN

Policy Number: Policy STR/RTW 1 – The Strategy for Royal Tunbridge Wells

Support with conditions

The Policy Strategy for Royal Tunbridge Wells set out in Policy STR/RTW 1 includes a list of “Contributions Required” in connection with all Tunbridge Wells development sites. As with Policy STR 5, flexibility should be applied to this Policy to ensure that account can be taken of site-specific circumstances that may influence site viability and deliverability.

JMS and SGN therefore request that Policy STR/RTW 1 be amended to incorporate the following wording:

“For the site allocations, the policies set out in this Plan may be applied flexibly to ensure that the sites are viable and deliverable.”

DLP_7106

Williams Gallagher for Canada Life Ltd

Policy STR/RTW 1- The Strategy for Royal Tunbridge Wells

We welcome clauses 2 and 6 outlined under the part of the policy titled Royal Tunbridge Wells Town Centre that support a new mixed scheme for the area around Torrington Car Park  and for the provision of residential uses as part of an appropriate mix of uses within the town centre (see also comments on AL/RTW 4 below. The extent of new retail floorspace provision will need to be carefully considered and justified in order to ensure that the amount does not undermine objectives to refresh/rejuvenate the existing retail offer of the town.

We trust that you find these comments constructive and look forward to on-going dialogue with the Council. Please keep us informed of progress with the local plan preparation.

Should you have any queries, please do not hesitate to contact us.

[TWBC: see also Comment Nos. DLP_7102-7117].

DLP_7352

Wealden District Council

General Observation

Policy STR/RTW 1 identifies the strategy for Royal Tunbridge Wells and includes an allocation of between 20,000 – 30,000 sqm for A1 comparison floor space and an allocation of between 6,000 – 7,500 sqm for A1 convenience floor space.

As stated previously, the Retail and Leisure Study identified a need for between 21,700 and 34,000 sqm of additional comparison floor space and between 7,500 and 9,500 sqm additional convenience floor space within the Borough.

Therefore, the retail floor space needs of the Borough are generally being met within these proposed Royal Tunbridge Wells allocations. Wealden District Council supports TWBC in attempting to meet their retail needs in this centre.

Policy STR/RTW 1 also identifies that approximately 1,222-1,320 new dwellings will be delivered on 17 sites allocated in the draft Tunbridge Wells Local Plan for the plan period. It is noted that a number of sites share, or are in close proximity to the administrative boundary of Wealden District. These allocated sites are discussed in detail below. It is considered the town of Royal Tunbridge Wells should be a focus for new development and specifically employment and retail development.

DLP_7639

Mr J Boxall

TWBC should ensure more houses are developed in Tunbridge Wells than currently shown in the Local Plan.  Tunbridge Wells is the economic and cultural centre of the Borough but is not taking its fair share of the developments.  It has fast road and rail transport links, unlike the eastern rural side of the Borough, so should get more numbers of houses developed.

TWBC should not have all the employment opportunities yet put such a large number of housing developments on the rural eastern side of the Borough.  This proposed development is not sustainable for the eastern rural villages such as Sissinghurst.

DLP_8034

Rose May McAuley

The Draft Plan says Royal Tunbridge Wells is a sustainable location.  So why is Tun Wells not getting more of the new houses – there is plenty of space around the new A21 area which will not hurt the town.  You are saying that RTW has employment, leisure, theatres which will make it a good place to live.

DLP_8181

Highways England

Location:

No/Type:

Distance to SRN:

Impact:

Current traffic flows:

Recommendations

Royal Tunbridge Wells

Approx 780 dwellings allocated on 17 sites, plus 440 dwellings which

already have planning permission

● 14 hectare business park with over 80,000 sqm floorspace (North Farm/Longfield Road Key Employment Area)

● New secondary school and two primary schools extended

● New sports hub

● New cultural and leisure facilities

● Major new business park adjoining North Farm

3km

A21/A264(Pembury Bypass)

~20km

M23 – J10

M25 – J5

M20 – J4/5

Impact will be widely felt on the A21/A264 interchange and will need to be monitored.

Trip distribution likely to be needed for the wider impact on the M23/M25 and M20 network. Especially movements associated with the business park.

Current traffic at A21/A264 Pembury indicate higher than normal levels in the AM/ PM peak.

A21/A26 (Mabledon) interchange does shows higher than normal southbound flows during the AM peak period.

Transport Assessment likely for this area given the relationship to the A21 at various junction points, especially A21/A26.

Trip distribution and assignment to the wider M25/26 should also be assessed.

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

DLP_8285

NHS West Clinical Commissioning Group

General Observation

It is noted that health and medical facilities, including for the provision of one new medical centre, is detailed as a requirement that contributions must be provided for to mitigate the impact of development in this area.

As an output of the assessment with existing GP practices in the RTW urban the CCG confirms that the need may be one or more new medical centres to support relocation of existing general practices. Having strategically assessed with general practices the CCG is currently working on the basis that new premises capacity alongside existing general practice capacity could accommodate the potential growth in the area.

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 and maximum utilisation of contributions that the trigger of any healthcare contribution should be made available linked to commencement or at an early stage of development.

The CCG can confirm that it is contributions will be required towards medical facilities to mitigate the impact of the development.

Policy AL/RTW 1: Mount Pleasant car park, surgery in The Lodge, public toilets, Mount Pleasant Road, Calverley Grounds, Great Hall car park and Hoopers' car park/service yard

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_8313

Jean Glendinning

Object

Policy AL/RTW 1.  Regulation 18. Pages 70 - 73 

In light of the recent vote by TW councillors the plans on these pages for constructing an unwanted town hall and theatre are no longer relevant.  Please update.

DLP_2556

Mrs Shirley Wise

Object

Considering this proposal was rejected at full council recently I was surprised to see this here. This paragraph should be deleted in its' entirity and it should be made quite clear that the residents of Tunbridge Wells do not want any part of the Calverley Grounds built on, be it a new theatre, underground car park or new offices. This is an historic park dating back to the 1830's right in the centre of town that is used by the young and old alike and has been here many years. I still have an old photo of my mother (now deceased) with her parents and family in the Calverley Grounds not far from where the Burmese Bell used to be. We are so lucky to have this park in town and should cherish it. The old park-keepers lodge also is a beautiful building to look at, in the style of Decimus Burton, and should not be demolished. Please preserve our park as was agreed,, by rejection at your council meeting, and delete this from the local plan.

The existing Town Hall can be refurbished, still at a hefty cost I realise, but this is where the Town Hall should be. I am not anti a new theatre but do not see why the current one cannot be upgraded, they manage to do this in many other towns as has been previously mentioned in correspondence on this issue.

I disagree with CPO of any of the businesses, we surely do not have that many that we can afford to deter those we still have remaining! The car park is a vital part of Hoopers and encourages shoppers there, as is the Torrington Car Park also valuable to the bottom end of town. You should be encouraging shoppers not deterring them, and your idea of a theatre bringing shoppers in is ludicrous, if I am going to the theatre this will be in an evening and I will not go laden down with a lot of shopping!

DLP_667

Ms Carole Freeman

Object

My husband Graham J Freeman and myself, Carole A Freeman of XX Broadwater Down TN2 XX [TWBC: postal address details redacted] are totally against any development in Calverley Park - this is a historic park and precious green  space  in the centre of the town.  It is not for TWBC to purloin!  This park is for the good of the ratepayers and visitors to Tunbridge Wells - the plan to build on it is totally inappropriate at a ridiculous price and totally not necessary. We do not agree either to the CPO on Hooper's car park.  The existing theatre and council offices can  be refurbished  - yes at a cost but they would be in the right place next to existing art hub in the town and if old London theatres can be refurbished and still put on great entertainment so can the existing assembly hall.  The Assembly Hall has the right access at the front and rear with existing roads and if it has to be closed for refurbishment so be it.  Other theatres in the country have closed for refurbishment without detriment.  YOU DO NOT HAVE THE RIGHT TO USE RATEPAYERS MONEY FOR A NEW THEATRE AND COUNCIL OFFICES WHICH VERY FEW LOCAL PEOPLE WANT!!!  These comments are in  respect of AL/RTW1 

DLP_716

Mrs Jane Fenwick

Object

Calverley Square project comprising Mount Pleasant car park, surgery in The Lodge, public toilets, Mount Pleasant Road, Calverley Grounds, Great Hall car park and Hoopers' car park/service yard. 

Since the TWBC decided to abandon this whole project and consider other options it is no longer appropriate for this scheme to be described as the development option. Therefore, the full details of the project and the map showing the extent of its impact on Calverley Grounds should be removed from the Draft Local Plan. The map indicates the full extent to which Calverley Grounds would have been used in the construction of this now abandoned project. Most of this was for temporary use only during the construction phase. This is clearly shown in the Public Notice published by TWBC for the Appropriation of Open Space Land. This distinction is not reflected in the map in the Draft Local Plan.

In my view the only areas that should be marked for potential development would be the properties owned by TWBC including the two car parks, lodge and toilets. Any additional land required – temporarily or otherwise,  or acquired by compulsory purchase, should be excluded until such time as a different Planning Application is submitted.

DLP_733

Dr P Whitbourn

Object

It came as a great relief on 8th October 2019, when TWBC in full Council session decided by a convincing majority not to give the go-ahead to the wrong-headed and locally highly unpopular "Calverley Square" scheme. From a planning point of view this was always an utterly inappropriate scheme that should never have been put forward in the first place. The principle of building on public open space, especially where commercial development is concerned, is clearly a bad one; within the designated Conservation Area no fewer than sixty six trees would have been chopped down; an enormous hole would have been dug in the registered historic park and garden for a deep and badly located underground car park; the visually pleasing traditional park-keeper's lodge would have been demolished, together with the replica Decimus Burton gates, and rep[laced with large angular modern blocks that would have seriously marred the picturesque landscape of the seminal Calverley Park layout; drama, music and dance would have been separated from the art gallery, museum, library and other cultural facilities; and the civic centre would have been moved out of the formally established and currently strengthened Civic Quarter where it so obviously belongs, leaving the listed present civic complex with an uncertain and probably less suitable future. The opportunity now exists for fresh thinking and the exciting prospect of a properly joined up, well located, cultural, community and civic complex that can serve the needs of the local community as well as attracting tourists, visitors and shoppers to the town.

POLICY AL/RTW 1 SHOULD THEREFORE NOW BE TOTALLY DELETED FROM THIS AND ALL FUTUIRE PLANS, AND THE ALLOCATION EXPUNGED FROM THE ROYAL TUNBRIDGE WELLS TOWN CENTRE DRAFT POLICIES MAP.

The site should remain basically as it is, but with an enlightened Management Plan for Calverley Grounds that should include strengthened tree planting along its western border and suitable improvements to the entrance from Mount Pleasant, along the lines indicated in the approved Urban Design Framework document.

Great Hall car park is a relatively low building, well treated with arches and appropriate architectural details reflecting those of Great Hall itself, and it should remain basically as it is, subject possibly to the provision of a suitably designed roof structure, to shield the view of parked cars from the higher reaches of Calverley Grounds. Great Hall car park is important to the BBC, and businesses in the High Street, station and lower Mount Pleasant areas, as well as being user-friendly, and it should remain intact for the plan period.

GREAT HALL CAR PARK SHOULD NOT BE REGARDED AS FAIR GAME FOR SOME BLOCK OF FLATS OR OTHER DEVELOPMENT AND SHOULD NOT FEATURE AS AN ALLOCATION ON THE PROPOSALS MAP.

Mount Pleasant Avenue car park should also remain so, but could made more than one level, taking advantage of the steeply sloping ground.

Access to Galverley Grounds from the refurbished Civic, Cultural and Community Complex, mentioned on the previous page, is currently somewhat unclear and circuitous, around the Roman Catholic Church. I am suggesting therefore that, in the event of the idea of such a community facility being adopted, the possibility of a paved and clearly marked route from the refurbished Complex to Calverley Grounds be investigated, making use of Upper Mount Pleasant Avenue and across the northern end of the Car Park, as indicated on the attached diagram.  

This would be better not to feature in Policy AL/RTW 1, which should be deleted altogether, but could feature in the Management Plan for Calverley Grounds, or in the Urban Design Framework or both.

DLP_804

Debbie Cooper

Object

The full details of the theatre project and the map showing the extent of its impact on Calverley Grounds is still in the Draft Local Plan. Please remove it.

The appropriations notice under which TWBC obtained the use of the parts of the parkland and the larger area for the construction was in large part for temporary use only but this is not reflected in the map in the Draft Local Plan.  

It is important that the Draft Local Plan is changed to remove the Calverley Square project (AL/RTW 1) entirely as the Council decided not to proceed with the project. However, the properties it owns may still be available for development – the two car parks, lodge and toilets. Only these individual sites should be shown as available for development. Any additional land required – temporarily or otherwise - would be considered again through the Planning Application system.

DLP_887

Mr David Cooper

Object

Re para 5.15 and site map for AL/RTW1. Map 1 (page 71) shows the proposed land, outlined in red that was to be appropriated for the now abandoned theatre/ offices/ underground carpark. This map needs to be redrawn to make clear that all land within Calverley Grounds is now outside any area for development/ redevelopment, regardless of whether it was included in the land designated for the theatre/office project either permanently or temporarily. If, exceptionally, there are proposals in the future to take land from Calverley Grounds for development, it must be made clear that they must be subject to full scrutiny under a completely new application through the planning system at that time, untainted by the previously appropriation.

DLP_884

Simon Weatherseed

Object

I object to the proposed site allocation policy boundaries on Map 1/Policy AL/RTW 1 which encroach substantially into Calverley Grounds (a historic park).  Any future permitted development should be limited to the brown-field sites as formerly permissioned for development prior to the planning approval provided for the proposed Calverley Square development which has now been aborted.  This is imperative to ensure that there is no further challenge to impinge upon Calverley Grounds.

DLP_2886

Chris Gow

Object

This development should be scrapped, and the Park restored to former state, and exist for the amenity of town visitors.

The existing Town Hall should be refurbished, and the Theatre refurbished.

Since the loss of the Victoria Hall in Southborough there is no small theatre other than Trinity, so the existing Theatre has an important place in out community.

DLP_2887

Chris Gow

Object

I object to this development.

The scale and ambition of the project is overwhelming for the area, and the justification for a large theatre is questionable. The loss of park amenity is large, and the requirement of parks and open spaces is compelling.

DLP_945

Tom Clarke MRTPI

Support with conditions

As articulated previously, the Trust remains supportive of a new theatre at this location.  Should current plans be revised we urge early engagement with the Trust, particularly in the context of this facility providing a replacement for the Assembly Rooms.  

DLP_4106

Tunbridge Wells District Committee Campaign to Protect Rural England

General Observation

This policy requires deletion following the abandonment of the Calverley Square proposal.

DLP_3585

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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/RTW 1

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

DLP_4539

Historic England

Policy AL/RTW 1 - we are not convinced that the nature and scale of the development proposed on this site is achieveable in the context of the heritage impacts that are likley to arise from them, notwithstanding the wording relating to protecting and mitigating the effects on heritage assets. We also cannot support the policy until the future of the existing listed Civic Complex is satisfactorly resolved, and the assets on that site (ref. Policy AL/RTW 6) are secured by sympathetic regeneration, which my include an option to retain the important collection of listed buildings in local authority and other public services use.

DLP_1805

Royal Tunbridge Wells Town Forum

General Observation

Policy Number:  AL/RTW 1 Calverley Square

There is no consensus in the Town Forum about this proposed allocation which now appears likely to require substantial re-writing prior to the Regulation 19 Submission Draft in the light of the abandonment of the present project. There is, however, a consensus that an underground car park under parts of Calverley Grounds is inappropriate on a number of grounds, whatever the revised scheme which may emerge.

DLP_4268

RTW Civic Society

It is essential that this policy is completely rewritten, among other things to make it clear that the allocations for Council offices and a theatre will only be implemented if made necessary by prior Council decisions affecting the Town Hall and Assembly Hall.  We believe a 5,000 sqm office building is too large for the Mt Pleasant Avenue site, and this allocation, if retained, should be scaled down.  The proposed underground car park has an unacceptable effect on Calverley Grounds and this allocation should be removed.  It should be made clear that any other developer coming forward with proposals for these sites will be required to go through the whole planning process and achieve exceptionally high environmental standards.  Any proposal for all the components of AL/RTW1 should be required to conform to a master-plan developed in conjunction with the Council.

Further, on the Policies map, the site shown ought to be shrunk so it no longer impacts on Calverley Grounds.

DLP_2818

Mr Nicholas Pope

Object

The site allocation for the proposed offices, theatre and underground car park on Calverley Grounds and adjacent to Calverley Grounds (Mount Pleasant car park, surgery in The Lodge, public toilets, Mount Pleasant Road, Calverley Grounds, Great Hall car park and Hoopers' car park/service yard (CfS reference: Sites 262 & 263)) should be removed from the Local Plan. This project was terminated by Full Council on 8th October 2019.

The provision for offices, theatre and other facilities should focus on the existing civic site or other brown field sites in the town and borough.

DLP_2543

Ms S Daniels

Object

The Calverley Square project was resoundingly voted down by the full council in Octobr 2019.  This reference should therefore be removed from the future local plan thus ensuring that Calverley Grounds, a Grade II listed park, is not encroached on by any future development plans (for a theatre, civic centre or any other use). In fact the trees within the park that were to be removed for the project should be issued with tree preseveration orders.

DLP_2469

TWBC Property and Estates

TWBC

General Observation

In the light of recent decisions on this project, it is anticipated that the allocation policy is now likely to be modified.

No comment is therefore submitted at this Reg 18 stage, but we reserve the right to to be able to submit comments on any future policy as it emerges. 

DLP_1570

Mr John Hurst

Object

Leave Calverley Grounds to be the beautiful asset that it is.

Fit each floor of the Great Hall Car Park with electric vehicle chargers - a bank on one side of each floor - to support shoppers and commuters coming into town with ELVs.

DLP_2043

Terry Everest

Object

Strongly object, besides the enormous financial risk and difficulty in trying to compete with London or Canterbury with this provision  - the site is not appropriate for the building as too much of the beloved and well used park is sacrificed for the building and crucially other and better sites exist if the project is to go ahead. Better solutions exist than those suggested. It is not necessary to provide council offices in the same development as a theatre.

DLP_2002

E G Simpson

Object

Calverley Square Project: Despite the fact that this will not proceed - thank goodness - the full details of the project and the map showing the extent of its impact on Calverley Grounds, however, is still in the Draft Local Plan which implies that any future developer COULD expect that large parts of Calverley Grounds are also available for development. Thus AL/RTW1 should be totally removed.

Local Green Space No. AS81, Calverley Park: The Local Green Space Assessment describes the Park as "an important open space used by the local community for informal recreational activities (e.g. walking, dog walking etc.)". THIS IS COMPLETELY WRONG. It is clearly time for The Planning Policy Team (and the BBC South East Team of broadcasters) to understand, clearly, the difference between Calverley Park and Calverley Grounds.

Signs at both ends of the Park state "Residents' Dogs Only". See attached photographs of the signs displayed.  Thus, Calverley Park (NOT "CALVERLEY PARK EAST" - which is an incorrect title) is not available for "dog walking" by members of the public. Management of the Park is by the Calverley Park Association whose programme includes provisions for the maintenance and enhancement of its rich wildlife and unimproved grassland.  Contrary to public opinion and assumption, there is NO public right of way through the Park and its gates are closed every Sunday afternoon and all day on Good Friday. At other times, the general public are welcome to walk through the Park providing that they keep to the carriageway or the main path across the parkland.  In order to protect the grassland, the parkland is NOT available for picnicking or other general "informal recreational activities".  Thus Calverley Park's designation as a "Local Green Space" should be totally removed, together with its entry in the Local Green Space Assessment since this is incorrect and potentially damaging to this delicate and historic ecology.

[TWBC: Image 1, image 2 and image 3 attached]

DLP_2221

Dr Cameron Davies

Object

Policy AL RTW1 should be deleted from the Tunbridge Wells Draft Plan.

Calverley Square development was abandoned after the vote against at the full council meeting on October 8th 2019

DLP_2636

Irene Fairbairn

Object

I do not want to see large scale development of the lovely and historic Calverley Grounds with proposed theatre and large office accomodation . Council offices can be built on a less sensitive site. Similarly a theatre should be built on a more suitable site.

DLP_3002

Alison Howard

Object

At the Full Council meeting on 8 October 2019 the Council decided not to proceed with the Calverley Square project. Following on from this decision, policy AL/RTW 1 should be deleted from the Local Plan.

Calverley Grounds is a much-loved and important town centre park. Any replacement policy must not include the large proportion of Calverley Grounds that is included in Map 1 Policy AL/RTW 1. Much of the land in this map was included in connection with the specific plans for the Calverley Square project and is no longer required for this purpose. The extent of the planning permission granted for the Calverley Square project must not be used as a reference point for any future developments. Any future plans relating to the Great Hall Car Park or the Mount Pleasant Car Park must not encroach into Calverley Grounds or require the felling of any trees currently within the boundary of Calverley Grounds.

DLP_3109

Andy Bashford

Object

Far too expensive and costs ever increasing. Very glad it has been abandoned at the meeting on 8 October, Therefore no more waste of the tax payers time and money making their views heard. Existing Town Hall and Assembly Hall may not be perfect but they are good enough. Given that it is TWBC that is the applicant, the Planning Committee shouldn’t decide but should leave it up to the residents of the Borough because they effectively own the land not TWBC.

DLP_3127

Teresa Stevens

Object

Far too expensive and costs ever increasing. Very glad it has been abandoned at the meeting on 8 October, Therefore no more waste of the tax payers time and money making their views heard. Existing Town Hall and Assembly Hall may not be perfect but they are good enough. Given that it is TWBC that is the applicant, the Planning Committee shouldn’t decide but should leave it up to the residents of the Borough because they effectively own the land not TWBC. 

DLP_3183

Kent County Council (Growth, Environment and Transport)

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following amendments are requested:

Paragraph 4 - “Vehicular access/egress to/from the office and underground car park shall be via the northern Mount Pleasant Avenue/Mount Pleasant Road junction.”

Paragraph 5 – “The theatre shall be serviced from Grove Hill Road, through Hoopers' car park/service yard. The section of highway between 36 Mount Pleasant Road and the Great Hall Arcade shall be predominantly for pedestrian access to the development and Calverley Grounds...”

Heritage Conservation

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

Potential for prehistoric remains and especially Post Medieval remains associated with spa town and designated landscape of Calverley Park. Remains associated with Calverley Park of particular sensitivity in heritage and archaeological landscape terms.

Pre-determination heritage assessment essential including desk-based assessment (DBA) and fieldwork 

DLP_5265

Tunbridge Wells Friends of the Earth

Object

Object , General Observation

Now that plans have been cancelled for the ‘Civic Complex’ or ‘Calverley Square’ project, this policy needs to be reconsidered. 

We object to altering the boundaries, landscape and treescape of Calverley Grounds and would like to see a retraction of the intention to develop the area that is inside Calverley Grounds as shown on your Map 1 Policy AL/RTW 1.

DLP_5575

Rusthall Parish Council

Object

I am writing to object to the following policies within the Local Plan.

Policy AL/RTW 1: Mount Pleasant car park, surgery in The Lodge, public toilets, Mount Pleasant Road, Calverley Grounds, Great Hall car park and Hoopers' car park/service yard At the Full Council meeting on 8 October 2019 the Council decided not to proceed with the Calverley Square project. Following on from this decision, policy AL/RTW 1 should be deleted from the Local Plan. Calverley Grounds is a much-loved and important town centre park. Any replacement policy must not include the large proportion of Calverley Grounds that is included in Map 1 Policy AL/RTW 1. Much of the land in this map was included in connection with the specific plans for the Calverley Square project and is no longer required for this purpose. The extent of the planning permission granted for the Calverley Square project must not be used as a reference point for any future developments. Any future plans relating to the Great Hall Car Park or the Mount Pleasant Car Park must not encroach into Calverley Grounds or require the felling of any trees currently within the boundary of Calverley Grounds.

DLP_7249

Mr John Telling

Object

Following recent Council decisions is this policy redundant now?

The public toilets should be retained. Any new proposals should not involve development within the Park boundary and not adversely affect the amenity and setting of the Park.

DLP_5733

Kate Bourne

Object

Along with thousands of other residents in the borough, I was horrified that planning permission was granted for major build works to take place on and under parts of Calverley Grounds.

Thankfully this plan has been halted when it was recognised by the elected councillors that it was a hugely unpopular plan.

I therefore am writing to regarding paragraph 5.15 and then site map for AL/RTW1 - Map 1 (page 71) which shows the proposed land, outlined in red that was to be appropriated for the now abandoned theatre/ offices/ underground carpark project. It is imperative that this map needs to be redrawn to make clear that all land within Calverley Grounds (a grade two listed park) is now outside any area for development/ redevelopment, regardless of whether it was included in the land designated for the theatre/office project either permanently or temporarily.

I would also like to see each of the parks given protected status and tree preservation orders put on the trees native to the parks to secure their existence for future generations of residents and visitors to the borough.

DLP_7142

Siobhan O'Connell

Object

As a result of the decision taken by Full Council on 8th October, the scheme known as Calverley Square was cancelled. Therefore all references to it should be removed. In particular, it should be made clear that no building should now take place within Calverley Grounds. I also fail to understand why the Great Hall Car Park is under threat. It was designed to complement the Great Hall and is relatively unobtrusive. It is an important amenity for shoppers, office workers and visitors. It should not be developed into residential or office use. 

DLP_5754

Sally Antram

Object

Policy AL/RTW 1: Mount Pleasant car park, surgery in The Lodge, public toilets, Mount Pleasant Road, Calverley Grounds, Great Hall car park and Hoopers' car park/service yard

At the Full Council meeting on 8 October 2019 the Council decided not to proceed with the Calverley Square project. Following on from this decision, policy AL/RTW 1 should be deleted from the Local Plan.

Calverley Grounds is a much-loved and important town centre park.

Any replacement policy must not include the large proportion of Calverley Grounds that is included in Map 1 Policy AL/RTW 1. Much of the land in this map was included in connection with the specific plans for the Calverley Square project and is no longer required for this purpose. The extent of the planning permission granted for the Calverley Square project must not be used as a reference point for any future developments.

Any future plans relating to the Great Hall Car Park or the Mount Pleasant Car Park must not encroach into Calverley Grounds or require the felling of any trees currently within the boundary of Calverley Grounds.

However, my view is that these should remain as car parks for the period covered by the local plan. The Great Hall car park is relatively low and unobtrusive. It is important for the BBC and other businesses in the Great Hall, the train station, and businesses in the High Street. It should not be redeveloped. Mount Pleasant Car Park should also remain as a car park to service offices in that area and to ensure that the many trees and shrubs that surround it do not have to be removed.

DLP_6120

Angela Funnell

Object

Policy AL/RTW 1: Mount Pleasant car park, surgery in The Lodge, public toilets, Mount Pleasant Road, Calverley Grounds, Great Hall car park and Hoopers' car park/service yard

At the Full Council meeting on 8 October 2019 the Council decided not to proceed with the Calverley Square project. Following on from this decision, policy AL/RTW 1 should be deleted from the Local Plan.

Calverley Grounds is a much-loved and important town centre park.

Any replacement policy must not include the large proportion of Calverley Grounds that is included in Map 1 Policy AL/RTW 1. Much of the land in this map was included in connection with the specific plans for the Calverley Square project and is no longer required for this purpose. The extent of the planning permission granted for the Calverley Square project must not be used as a reference point for any future developments.

Any future plans relating to the Great Hall Car Park or the Mount Pleasant Car Park must not encroach into Calverley Grounds or require the felling of any trees currently within the boundary of Calverley Grounds.

Policy AL/RTW 2: Land at Royal Victoria Place Shopping Centre, Calverley Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_734

Dr P Whitbourn

Object

Adjoining the Calverley Road pedestrian shopping precinct, Royal Victoria Place is the town and borough's only enclosed shopping centre and, being the principal shopping focus of this regional shopping centre, it is a place where several of the main retail names and brands are to be found. Thus the Council and the local community have been keen that the centre should be a vibrant place, attracting any necessary investment from the owners, if updating works are needed to meet changes in the volatile world of retailing.

The previous owners, Hermes, proposed sweeping and costly changes and, unfortunately for the centre and the town, started to empty units before selling the centre on to new owners, British Land, who rightly saw the Hermes scheme as flawed, and not one that they were willing to implement. Thus followed a dispiriting period of empty shops, particularly in Ely Court and at the prominent junction of Camden and Calverley Roads.

At the present time, there are encouraging signs that some efforts are being made to rejuvenate Ely Court, which was once an attractive and vibrant enclave. It is greatly to be hoped that this may be the start of a wider process of rejuvenation, and that the approach of the new owners may proves more beneficial to the centre and the town than the flawed Hermes approach. So far , the works in Ely Court appear largely to have consisted of refurbishing and fitting out existing units, and restoring their attractive traditional shop fronts. And it remains to be seen to what extent the new owners may wish to make other changes to the centre.

Royal Victoria Place was opened in 1992 by the iconic figure of HRH Diana, Princess of Wales, and although the land defined in policy AL/RTW 2 contains no statutorily listed buildings of special architectural or historic interest, there are aspects of the site that ought to be taken into account from the point of view of the architectural and historic character of the centre and its surroundings.

Policy AL/RTW 2 should point out that the frontage of older buildings to Camden, Calverley and Good Station Roads are within the Royal Tunbridge Wells Conservation Area, and should generally be retained, especially where these feature in the 2007 Local List of Heritage Assets.

This is of particular importance in the case of the group buildings at the corner of Camden and Calverley Roads, which contribute greatly to the character of the street scene. The Local Plan should be encouraging their retention, and not offering undesirable observations on possible replacement buildings.

As for the malls and public spaces within the centre itself, these benefit greatly from having good natural light, that should generally be maintained, and also from having a certain architectural style, with columns and various post-modern type architectural details and floor patterns that give the centre a certain character that is lacking in other more anonymous centres of this kind. Maintaining the architectural integrity of the centre will be important if any infill or other changes are contemplated.

DLP_3586

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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/RTW 2

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

DLP_1806

Royal Tunbridge Wells Town Forum

 

Policy Number:  AL/RTW 2 RVP Support + General Observations

We support this allocation. Given the rapid change in the nature of retailing and leisure activities a further review of use classes for this site may become appropriate at the 5 year review stage of the Local Plan to take account of developments.

We suggested to the previous owners of the site that scope may exist for the creation of outdoor cafes and other restaurants at Level 9 of the car park to take advantage of vistas over the town and more distant landscapes, as has been done in the remodelling of the Westgate Centre in Oxford.

DLP_2888

Chris Gow

Object

I question the development of further retail when High Street shopping in decline in the UK, and major retail stores have already closed outlets in the town.

The data that underpins the development is out of date, and fails to recognise the downturn in retail economy.

DLP_4269

RTW Civic Society

 

This policy should mention that various frontages of buildings along Calverley precinct, Camden Rd and Goods Station Rd fall within a conservation area and should therefore be retained.

Should consideration be given to pedestrianising Camden Road between Calverley Road and Victoria Road rather than simply assuming to improve the Calverley Rd/Camden Rd junction?  We think a more realistic proposal would be to make Camden Road one-way northbound from Calverley Road to Victoria Street.  This would mean diverting the bus service via Lansdowne Road.

DLP_2545

Ms S Daniels

Object

Given the current owners' rejection of their predecessor's plans for a major expansion of RVP, the council now has an opportunity to scale back any future redevelopment plans. In particular, the buildings that form an interesting and architecturally balanced corner of Calverley Road and Camden Road should be specifically retained..

DLP_1662

TWBC Property and Estates

TWBC

Support

Bullet 2. It is considered that the use of the word ‘strong’ for the corner development could be taken out of context. It should not necessarily mean a development that is high or too assertive. Focal point might be a better term to use.

DLP_3184

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:

Additional paragraph - All servicing and delivery activity to be contained within the site boundary.

The standard paragraph regarding contributions should also 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 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

There is potential for Post Medieval industrial heritage remains. An Archaeological DBA is recommended.

Policy AL/RTW 3: Former Cinema Site, Mount Pleasant Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_19

Darren White

Support

i support the development on this site, and think the number if properties could be increased

DLP_8287

NHS West Clinical Commissioning Group

General Observation

As per policy STR/RTW 1 the CCG has identified that one or more new medical centres may be required to support relocation of existing surgeries. Specific sites have not been explored or confirmed. The CCG notes AL/RTW 3 is proposed as a mixed use site and includes the opportunity for medical (D1) use.

DLP_739

Dr P Whitbourn

Object

Policy AL/RTW 3 will only apply if the current planning permission does not come to be implemented. This very prominent central site is one of the most important in the town and has been a disgrace for nearly two decades. For several years a derelict cinema stood there, and more recently it has been a cleared site.

The property has changed hands a number of times, and various unsatisfactory schemes have come forward for its redevelopment. The current one features an ugly and ungainly corner block of accommodation for old people, hardly a use destined to add a great deal to the vibrancy of the town centre.

Linking the upper and lower ends of the town centre, Mount Pleasant hill is a very fine tree-lined boulevard, with dignified classical buildings lining its eastern side. Ideally, the western side should reflect the character architecturally, and introduce uses such as a town centre hotel and a Waitrose that would add to the vitality of this key central site in a way that the present scheme almost certainly would not.

It would be a great thing for the town if a better scheme, both architecturally and in land use terms could come forward, but if the present permission comes to be implemented, there the matter will rest, and policy AL / RTW 3 will become redundant. As drafted the policy is highly unsatisfactory and in need of a completely fresh approach should the opportunity arise. It should, incidentally, be pointed out that the former Trinity Church does not have a spire.

DLP_3587

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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/RTW 3

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

DLP_4540

Historic England

 

We note that Policy AL/RTW 3 now has planning permission.

DLP_4270

RTW Civic Society

 

As worded this policy is confusing.  The consented development conforms to neither the previous Plan under which it was permitted, which was for a commercially-led development with the possibility of some residential as an ancillary, nor to the draft Plan.  The approved scheme is about two thirds high cost retirement flats; the design doesn’t enhance the Conservation Area, use locally distinctive materials, or protect the setting of the adjacent listed buildings; it doesn’t have a strong architectural element on the corner.   The development has required a public right of way to be extinguished, and there is no publicly accessible amenity space or play area.  We feel the policy should either be rewritten to reflect the elements of the consented development or it should be made clear that the policy refers to any future proposal for the site.

DLP_4814

DP9 Planning Consultants for Prime Finance (Tunbridge Wells) SARL (Elysian Residences)

Support

REPRESENTATIONS BY ELYSIAN RESIDENCES

We write on behalf of our client, Elysian Residences, in relation to the draft Local Plan (Regulation 18 stage). Our client is in control of the Former ABC Cinema Site, which is allocated in the draft Local Plan under AL/RTW3.

DP9 have been instructed by Elysian Residences to undertake a review of the Regulation 18 draft of the new Tunbridge Wells Local Plan, which is made up of the following documents:

- Draft Tunbridge Wells Borough Council Local Plan (Regulation 18 Consultation draft September 2019); - Draft Local Plan Policies Map (Regulation 18 Consultation draft August 2019).

The evidence base which has informed the preparation of the Local Plan documents includes the Tunbridge Wells Housing Needs Assessment, which has also been subject to our review. The Local Plan is intended to cover the period 2021 to 2036 (‘the plan period’).

On the 2nd of February 2018, planning permission 17/02262/FULL was granted for the mixed-use redevelopment of the Former ABC Cinema site. In order to make this planning permission viable, deliverable and buildable, a series of amendments were proposed, and a Section 73 application was submitted in July 2019.

On the 12th of September 2019, planning permission 19/01869/FULL was granted (via the Section 73) for the comprehensive mixed-use redevelopment of the site. Elysian Residences are now continuing to develop detailed design information and are currently targeting a start on site in early 2020. The consented development comprises 108 elderly care residential units (class C3), the reinstatement of a cinema on the site (D2), 2,604 sqm of flexible retail and restaurant floorspace (A1 and A3), alongside other minor alterations and enhancements to the scheme as first consented under 17/02262/FULL.

Policy Number: AL/RTW3 - Former ABC Cinema Site Allocation

The Former ABC Cinema Site is allocated within the adopted Site Allocations Local Plan (2016) under policy AL/RTW2B and is also allocated for development within the Regulation 18 draft Local Plan under policy AL/RTW3. As afforementioned, our client Elysian Residences secured planning permission for the Site in September 2019, and the approved scheme principally conforms with the development criteria outlined in both the adopted and draft allocation.

We support the alterations made between the adopted Site Allocation AL/RTW2B and the draft Site Allocation AL/RTW3, as they make the redevelopment of the Site more viable and deliverable. Firstly, the targeted quantum of A1 retail floorspace under the adopted Allocation AL/RTW2B was approximately 3,500 sqm. This is a substantial amount of retail floorspace, and it is considered that due to the continued uncertainty surrounding the retail sector and the decline of the high street due to changes in consumer behaviour, that this quantum of floorspace simply could not be sustained on the Site, nor incorporated into a successful mixed-use development. Additionally, the provision of this vast amount of A1 floorspace would have exacerbated the current market conditions of the retail sector in the town centre, which is already suffering from a large number of vacant retail units. As such, it is considered that the provision of 3,500 sqm of additional retail floorspace in this location would not be a positive addition to the town centre, as it would have either been very difficult to let or pulled shops from elsewhere in the town but still creating vacant units.

As such, we consider the less prescriptive approach to the provision of A1 floorspace in the draft Allocation AL/RTW3 to be positive. The draft Allocation takes a more relaxed approach in relation to the delivery of this floorspace and does not prescribe a targeted quantum of floorspace to be delivered, removing the somewhat impractical 3,500 sqm target. The draft Site Allocation recognises the importance of creating an active frontage along Mount Pleasant Road as a strategic aim for the Site. Elysian Residences also recognise the importance of creating an active frontage in this location, and as such support this aspect of the draft Site Allocation. The creation of active frontage was carefully considered throughout the design development associated with the revised scheme for the site (ref. 19/01869/FULL), and the retail units fronting Mount Pleasant Road enhanced accordingly, including the improvement of floor to ceiling heights to create more attractive offers for retailors. Furthermore, it is considered that the creation of an active frontage in this location is of key importance in interlinking the currently disjointed north and south of the town centre, hence this aspect of the draft Site Allocation AL/RTW3 is supported.

Additionally, we also support the incorporation of other A Class land-uses into the draft Site Allocation AL/RTW3. The previous Site Allocation AL/RTW2B solely targeted the delivery of A1 floorspace, whereas the draft Allocation AL/RTW3 targets the delivery of A1/A3 and A4 uses on the Site. We consider this to be a positive alteration to the site allocation, in line with paragraph 85 of the NPPF, which encourages flexible town centre uses to promote their diversity and ensure their vitality. The redevelopment approved for the Site under 19/01869/FULL provisions 2,604 sqm of flexible A1/A3 uses, in accordance with the draft Site Allocation and NPPF policy, to ensure that the scheme is adaptable to the changing trends in the retail sector. Furthermore, we support the fact does not target a specific quantum of A1/A3/A4 uses within the redevelopment, giving a degree of flexibility between the uses and further according with NPPF policy.

DLP_2222

Dr Cameron Davies

 

This site should include a medical centre and sufficient parking for the number of flats.

DLP_3110

Andy Bashford

General Observation

Why has it taken about 18 years to stop the site being an eyesore? Are the concerns from previous potential developers that building work could cause the railway tunnel underneath to collapse, no longer valid? If it got planning permission in February 2018, there must have been plans provided by a Developer, so why hasn’t work already started?

DLP_3129

Teresa Stevens

General Observation

Why has it taken about 18 years to stop the site being an eyesore? Are the concerns from previous potential developers that building work could cause the railway tunnel underneath to collapse, no longer valid? If it got planning permission in February 2018, there must have been plans provided by a Developer, so why hasn’t work already started?

DLP_3185

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:

Additional paragraph - All servicing and delivery activity to be contained within the site boundary.

The standard paragraph regarding contributions should also 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 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

An Archaeological DBA is recommended.

DLP_4410

Alison Adams

Object

I am a resident of Horsmonden and have lived here for the last 6 years.  During my time I have been the Chair of the local Horsmonden Kindergarten and I have been very busy renovating my home and garden.  I love living in this village with its community spirit and feel very involved and integrated in the society here.

Although I appreciate that new housing is inevitable and do not object to sensitive and structured new building I am concerned greatly by the idea of large scale new development which does not take into account the requirements of the existing community or the actual requirements of the prospective purchasers of the homes.

Horsmonden like most villages provides a mixture of housing and there are many residents living here who do not foresee living anywhere else. Houses however do come onto the market and at present there are a number in the village that have been up for sale for over a year.  My question is therefore, how have the “powers that be” come up with the decision that we need to create 13,560 new homes (Para 4.7)?  If we do need these homes I sincerely hope that the main priority is to create homes that will fulfil the specifications that these new prospective owners are looking for.  In my view one of the biggest problems that we face is that large family homes continue to be occupied by parents well after their children have left, couples in their 60s, 70s and 80s are reluctant to downsize due to the lack of smaller but prestigious, spacious, convenient houses/apartments/bungalows that also offer attractive outside space.  This creates a barrier to the upward movement of younger families who wish to gain more space.  Space in the South East is at a premium so there needs to be some incentive to free up these family homes for the new generation.

I would also like to be 100% certain that the companies that are employed to build all these new homes are actually controlled so that the new homes are good quality and sustainable with eco-friendly initiatives being used. Why is it not compulsory to have solar panels, permeable paving, grey water storage?  All these design features are available and if every builder was enforced to use them there would be economies of scale so the price of these technologies would ultimately come down.

In terms of the Consultation I would like to comment on the following:

AL/RTW3 - I have been living in the borough of Tunbridge Wells since 2002 and in all those 17 years this area has looked a complete mess.  If this is the speed at which development is going to take place then I would abandon all the ideas in your Local Plan now as they will never come into fruition!

I appreciate the opportunity to comment and hope that the Borough Council will take into account the many and varied views of the people of the borough.  Maybe building thousands of new homes will boost the economy in the short term but once built these homes cannot be removed so let’s hope there is a real demand and that the houses built actually satisfy that demand.

Policy AL/RTW 4: Torrington and Vale Avenue

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_743

Dr P Whitbourn

General Observation

Policy AL/RTW4 should omit the reference to Calverley Square, which should no longer apply, following the convincing decision of full Council not to give the go-ahead to that flawed scheme.

I support the principle of a Master Plan for the site, the boundaries of which might be the subject of further discussion. The Master Plan should have particular regard to the desirability of a proper pedestrian link to Mount Pleasant, and to better picking up and setting down facilities at the railway station.

It is important too that the settings of listed buildings in the vicinity are respected, particularly those of the railway station and the Bridge Club.

The Master Plan should be available for public comment before its adoption by the Council.

DLP_3588

Southern Water Services Plc

 

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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/RTW 4

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

DLP_2889

Chris Gow

Object

This development should be entirely residential, and specifically low cost flats for poorer buyers. It is ideal for non-vehicle ownership, and should be delivered for non-vehicle owning purchasers. It is near good established transport communications.

DLP_2890

Chris Gow

Object

I object to this development being mixed use.

It should be an entirely residential complex, with no other use.

It is ideal for non-vehicle ownership, and should be delivered for non-vehicle owning purchasers. It is near good established transport communications.

DLP_4541

Historic England

 

Policy AL/RTW 4 – this site, the Torrington & Vale area, includes  the listed railway station and allows for for a “slender tall building” to be built .  Putting aside any concerns realting to the feasibility or viability of providing such a building, a tall structure at this location could be problematic if dominated the railway station in a way that dteracts form its significance or if it was visible in some key views of the town from elevated positions.  The policy requires that a master plan is prepared in advance of consent being sought; Historic England would wish to be consulted on this in light of our previous engagement for a detailed proposal for the site.

DLP_1807

Royal Tunbridge Wells Town Forum

 

Policy Number:  AL/RTW 4 Torrington

Support + General Observations

This site offers major redevelopment potential which should be realised through the proposed Masterplan to include the detailed prospectus set out under the policy. We fully support the desire to achieve considerable density of residential development at this extremely sustainable location for active travel. The possibility of direct pedestrian connectivity between the retained car parking and Mount Pleasant and Calverley Grounds should be explored in the possible form of an elevated walkway passing above the railway at a point to be determined with Network Rail.

DLP_4271

RTW Civic Society

 

Is it certain that there is only one applicant responsible for the site in its entirety?

In the past, various schemes were devised to widen Vale Road, make it one-way and build another road south of the bridge club, utilise Vale Avenue or Clarence Road so as to assist access to the station and remove the sharp bend in Vale Road near the station entrance.  Will the masterplan include anything about road access and the dropping off of passengers at the station forecourt?

DLP_1663

TWBC Property and Estates

TWBC

Support with conditions

AL/RTW4

This car park provides approximately 243 valuable public parking spaces for the town centre. Bullet 1. Should therefore also include a reference to the re-provision of public car parking in the interim, whilst the site is being redeveloped.

DLP_2596

Richard Bysouth

Support with conditions

I support the redevelopment of this rather unloved area of town, provided that point 1 is adhered to "The retention of public car parking, at an amount no lower than currently provided". There can be no loss of car parking as this is key, particularly as it is next to the station.

DLP_2638

Irene Fairbairn

 

Development Torrington and Vale Avenue

This is a very important area of the town and located opposite the station, it provides an introduction to the town. The current development proposals sound much too large with inadequate parking.

The current site housing the Range Store and Iceland plus car parking is run down and architecturally a mess and would benefit with a high standard replacement .It is an ideal site for much needed offices and car parking. Car Parking is very important for both shoppers and commuters plus the nearby Premier Inn hotel. This site needs a development which is sensitive to nearby buildings and crucially in proportion to nearby architecture.

DLP_3186

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:

Additional paragraph - All servicing and delivery bays to be contained within the site boundary.

This policy states that “Proposals must be informed by a Transport Assessment”. This does not feature in every policy. Either this should be removed and the requirement for a Transport Assessment be accepted throughout, or it should be repeated for all major site policies.

The standard paragraph regarding contributions should also 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 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

There is potential for Post Medieval industrial heritage remains. An Archaeological DBA is recommended which should include a review of the extent of previous groundworks. Site may be entirely truncated.

DLP_7102

Williams Gallagher for Canada Life Ltd

Support with conditions

Williams Gallagher is instructed to submit these representations by Canada Life with regard to the proposals in the draft local plan. The comments are provided in the spirit of constructive dialogue with the Council and are considered to provide a basis for future discussion with the Council as they continue to prepare the local plan prior to the formal Reg 19 consultation in due course.

BACKGROUND TO COMMENTS

Canada Life is the owner of land at Vale Road which is presently developed as a Multi-Storey car park with ground floor retail. The development is outmoded in terms of the efficient use of the land and the contribution that it makes to Tunbridge Wells. There is opportunity for the use of the site to be reconsidered to make a greater positive contribution to meeting the development needs of the borough and for the visual appearance of the site to be significantly enhanced through redevelopment through provision of a new mixed-use development. Initial, positive pre-application discussion on potential proposals has already been held with the Council and Canada Life looks forward to continued positive engagement as the proposals progress. The comments provided through these representations are framed to ensure that the ability to realise these aspirations remains and are provided in the context of the guidance in the National Planning Policy Framework 2019 (NPPF) which require plan making to:

“[…]positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change;’ (para 11a)

* “be prepared with the objective of contributing to the achievement of sustainable development” (para 16a)

* “be prepared positively, in a way that is aspirational but deliverable” (para 16b)

* “contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals” (para 16d)

* “The preparation and review of all policies should be underpinned by relevant and up-to-date evidence. This should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned, and take into account relevant market signals.” (para 31)

* Plans should set out the contributions expected from development…[…] Such policies should not undermine the deliverability of the plan. (para 34) 

In seeking to comply with these requirements, the plan will be assessed at Examination to ensure that it is:

* Positively prepared

* Justified

* Effective

* Consistent with national policy

The following comments are set out in order of the relevant policies as they appear in the local plan.

Policy AL/TRW 4 – Torrington And Vale Avenue (includes SEELA ref SALP AL/TRW3 and sites 200 and 268)

The proposed allocation which effectively rolls forward the allocation in the existing local plan with an amended site boundary that takes account of, and excludes, recent developments on Vale Avenue, is welcomed and supported subject to the following comments:

Clause (i) should include provision for potential uses within use classes A5 (takeaway), D1 (non-residential institutions) and D2 (assembly and leisure) within the list of suitable uses to maximise the opportunity to ensure occupation at ground floor and help provide active frontages. The potential uses could for example include a gym, a creche or a takeaway. The policy as drafted would exclude this possibility.

Clause (ii) should be reworded by deleting the wording “A significant element of any development to comprise…” as the wording is superfluous in a list of acceptable uses

Clause 2 – comments with regard to Policy TP3: Parking Standards are set out below. However the provision of parking within the allocation boundary, particularly in regard to the site owned by Canada Life, should be assessed on its own merits and balance the requirement to maintain the existing level of public car parking with the opportunity to create a new development that significantly improves the appearance of the conservation area and meets the mixed-use aspirations for the proposed development. However, it should be noted that the site is highly sustainable being next to the station, within walking distance of the town centre facilities. Mandatory provision of parking as proposed through Policy TP3 would undermine the potential to achieve the density of development aspired to in the policy and have detrimental implications for its design and highways impact.

Clause 3 – we note the requirement for a masterplan to be produced by the applicant in consultation with the Council which is then to be adopted as a Supplementary Planning Document. This will have implications for the timescales for the potential delivery of any development as set out in comments under Policy STR3 above. Furthermore, a similar requirement is set in the existing Local Plan: Site Allocations DPD (2016) for the area of the former larger allocation. However, no such masterplan was ever produced by either the Council or the developers of those recent developments now excluded from the new allocation area .

Redevelopment within the allocation is unlikely to come forward as a single comprehensive redevelopment proposal of the whole site which is under different ownerships. Aspirations of the different owners of the separate parts of the allocation may differ including timeframe within which they may wish to commence development. It is therefore more important that, as they come forward, proposals for development clearly show that they do not prejudice the potential future redevelopment of the remaining part of the allocation.

Clause 5 and separate contributions list – the requirement to provide public art and other requests for planning obligation contributions will need to meet the tests of the CIL Regulations and the Planning Practice Guidance and be considered in the context of para 56 of the NPPF.

Para 57 of the NPPF also noted the need to ensure that viability evidence of the plan should be produced to support the provisions within it to minimise the need for viability assessments to be submitted alongside future planning applications. At this stage, only viability into the introduction of a potential Community Infrastructure Levy has been published and not for the local plan and the allocations as a whole. We would wish to hold further discussion with the Council at an early opportunity, and certainly in advance of any work being progressed on the Reg 19 version of the plan on the potential contribution requirements for the allocation.

We trust that you find these comments constructive and look forward to on-going dialogue with the Council. Please keep us informed of progress with the local plan preparation.

Should you have any queries, please do not hesitate to contact us.

[TWBC: see also Comment Nos. DLP_7102-7117].

Policy AL/RTW 5: Cultural and Learning Hub (The Amelia Scott)

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_747

Dr P Whitbourn

Object

Policy AL/RTW 5 will be deleted, as paragraph 5.20 makes clear, if the current planning permission for a Cultural and Learning Hub is implemented. My impression is that there is a general hope and expectation, both within the Council and among the general public that this will indeed be the case, especially as the Library, Museum, Art Gallery and Adult Education Centre are now closed preparatory to the planned works. However progress on the project has given the impression of being rather slow, closure of the Library, in particular, having been delayed.

At the present time, it is understood that there are funding difficulties with the project, and there have been wholly unsubstantiated rumours that it may not happen at all. While I personally would have approached the project differently, I have always been a strong supporter of it in principle, and I spoke in favour of the grant of the prospect of quite extensive demolition of lesser parts of the original Library listed building, in the interest of providing better facilities and attractions.

Nevertheless, if not actually extravagant, the approved scheme is certainly not frugal. New lifts that have been recently installed, after a long wait, are to be taken out and replaced with fresh lifts in different positions and, similarly newly installed lavatories are to be replaced, together with some structure that could be retained. In short, it would in my opinion be possible to produce a less ambitious scheme for combining these to listed buildings, and replacing the huts, to produce this much needed Cultural Hub. The Museum has nationally important collections of Costume, Art and Tunbridge Ware, that should be properly displayed, both for the benefit of residents and as a valuable resource so far as the tourist industry is concerned. The Cultural Hub must not, in my opinion in any event be allowed to fail.

A further point may be that if the Town Hall complex now comes to be refurbished for cultural, community and civic purposes, there could be scope for relocating facilities such as Gateway and cafe space, thus allowing more room for the otherwise cramped displays.

To sum up, it may well be that the approved scheme could yet go ahead as planned and that Policy AL / RTW 5 will simply be deleted. Failing that, and if the scheme has to be significantly modified, the policy might be amended somewhat, perhaps omitting requirement 2, and adding a reference to the possibility of investigating the possible advantage of cooperating with any refurbishing scheme for the Town Hall.

DLP_774

Beth Dawson

Object

There is no need for a new secondary school in RTW. The evidence presented in the KCC Education and Infrastructure Needs and Requirements document and the TWBC Infrastructure Development Plan shows there is currently above average spare capacity (12.4%) in TW secondary schools, and with the planned expansions of existing schools, any additional need in RTW will be met in the planning period. Given that less than 10% of the planned housing development will be in RTW, siting a new school at the south west edge of the borough is not appropriate when the need will be in the north.

DLP_3589

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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/RTW 5

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

DLP_4542

Historic England

 

Policy AL/RTW 5 – we note that this site comprises two important listed civicc buildings and that permission has been obtained for their redevlopment.

DLP_4272

RTW Civic Society

 

Given the demise of Calverley Square we think these two sites should be considered as a single entity since a redevelopment/upgrade of the town hall site might usefully include letting the Amelia Scott centre to expand its cultural offering eg. by transferring the café and Gateway to the town hall site.  Policy 6 needs a complete rewrite.

RTW 6 contains the Police Station.  We think it is vital that the town retains an effective police presence.  Whilst this doesn’t have to be in its current location, it is probably realistic to plan on the basis that it will remain.  However, this does not mean the police have to retain the courthouse.  Consideration should be given to utilising this listed building to greater effect by using it for items where there is insufficient space in the Amelia Scott centre.

DLP_1664

TWBC Property and Estates

TWBC

Support

The inclusion of the word Gateway in the actual policy wording is considered too be too specific (visitor information centre would suffice) The RJ at paragraph 5.20 is enough to explain.

DLP_2223

Dr Cameron Davies

Support

Support

DLP_3188

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:

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

Policy AL/RTW 6: The Civic Complex: the Town Hall, Assembly Hall Theatre, and Police Station

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_754

Dr P Whitbourn

Object

The Civic Complex in Tunbridge Wells is a cluster of seven statutorily listed public buildings, all of which were the work of top architects and designers of their time. Calverley Terrace, 9/10 Crescent Road was designed by the distinguished architect Decimus Burton ; the Adult Education building is the work of Henry Thomas Hare, architect of Oxford Town Hall, and sometime President of the RIBA; the Library, Town Hall, Assembly Hall and Police Station were the competition-winning designs of Sir Percy Thomas, also a Past President of the RIBA; and the bronze War Memorial is the work of S Nicholson Bebb. In front of the War Memorial an upgraded civic space is currently being formed, and the area around the complex has been formally established and marked as the "Civic Quarter". The whole complex should, in my view, form a single allocation for an enlightened scheme of refurbishment but, failing this, the two policy areas AL/RTW 5 and 6 should be contiguous.

It was always an illogical and perverse idea to move the Civic Centre out of the Civic Quarter and in the light of the full Council's convincing decision not to give the go-ahead to the flawed "Calverley Square" scheme, Policy AL/RTW 6 should be completely rewritten, with no reference to mixed use development nor to extending the listed Town Hall upwards.

Instead Policy AL/RTW 6 should be for a sympathetic refurbishment of the listed Town Hall, Assembly Hall, Police Station and Calverley Terrace to provide an open, vibrant Cultural, Community and Civic Centre, having due regard to the significance assessment contained in the AHP Conservation Statement commissioned jointly by the Council and English Heritage.

Wing space should be added to the Assembly Hall on land to the rear of the Police Station on one side, and into the Town Hall on the other, connection to the stage being made AFTER the wing space has been completed, the whole refurbishment operation being managed so that there can be sufficient continuity of use by organisations such as the Symphony Orchestra and the Choral Society. Given the fact that the Town Hall is too large for present requirements, it should prove possible to organise a phased refurbishment programme, working on one wing at a time, and thereby avoiding a wholesale move of the Council's operations to temporary accommodation elsewhere.

The refurbishment scheme should address the desirability of linkage with the Cultural Hub, and it may be that the new steps up from Mount Pleasant by the War Memorial, which at present lead nowhere in particular, could lead to a new entrance to the whole complex being formed in Monson Way.

The future of Decimus Barton's listed Calverley Terrace also needs to be addressed, and one possibility might be to form a Visitor Centre, wit one house presented as an example of a period house from Decimus Burton's Calverley New town, perhaps run by a Trust, rather as 1 Royal Crescent is in Bath. Royal Tunbridge wells needs attractions such as that if it is to be taken seriously as a historic destination town in the future. The old Court House, and cells beneath, might be another such historic attraction. The area in front of Calverley Terrace could lend itself well for tourist coaches to set down and pick up.

The Policies Map definition of AL/RTW 6 should be extended to include Calverley Terrace, and the War Memorial, and so that it abuts directly on AL/RTW 5, as indicated on the attached diagram.

The listed Police Station is an integral part of the Civic Complex, and an essential component of Sir Percy Thomas' Competition Winning Design. Like the Library building and the Adult Education Centre, The Police Station and Court House were built by Tunbridge Wells Council for the benefit of the local population and, notwithstanding changes over the years in the arrangement of some public services, these public buildings should remain in public ownership and continue to be a public asset.

Recent reports that the Police Station was up for sale on the open market gave rise to local consternation, and the Plan should make it clear that the Police Station is to remain a public building, with the listed Court House retained and open to the public as a heritage attraction, and that planning permission will not be granted for private residential or commercial speculative development.

It should be unthinkable that a Regional Centre such as Tunbridge Wells could be without a Police Station, especially in these days when Knife and other forms of crime are constantly in the news. the right and obvious place for Tunbridge Wells Police Station is where it is now, occupying the front part of the listed building.

The back part is needed for wing space for the refurbished Assembly Hall, and any other parts not needed by the Police or the Assembly Hall could become Art Gallery or other heritage attractions associated with the retained historic Court House and cells.

DLP_952

Tom Clarke MRTPI

Support with conditions

The proposed new theatre for Tunbridge Wells cited previously within this plan is intended as a replacement for the Assembly Rooms.  We urge that the Trust is engaged at an early stage with regards to the future of the Assembly Rooms particularly in the context of us being a statutory consultee within the planning system and suggest this is drafted into the policy text.  We also urge the policy to be amended in order to make clear that theatre use at the Assembly Rooms cannot cease or the site be redeveloped until such time as a replacement theatre is operational.

DLP_2891

Chris Gow

Object

I object to this development.

The buildings should remain as Council Offices, located at the centre of town and accessible from all directions by bus. The buildings could be refurbished at a fraction of the cost of the office element of the Calverley Square development.

DLP_4107

Tunbridge Wells District Committee Campaign to Protect Rural England

General Observation

This policy requires substantial amendment following the abandonment of the Calverley Square proposal.

DLP_4543

Historic England

 

Policy AL/RTW 6 - the Civic Centre site is allocated for mix use; we note the policy for the Calverley Ground site (i.e. Policy AL/RTW 1) includes a pre-amble about possible changes to the allocation which the wording of this policy should also reflect. In our view, the Civic Centre is capable of being upgraded and adapted to meet the Council’s the current needs, but at the moment that option is precluded in the policy.

DLP_1808

Royal Tunbridge Wells Town Forum

General Observation

Policy Number:  AL/RTW 6 Town Hall 

There is no consensus in the Town Forum on the possible redevelopment of this site as its future will depend on decisions taken in relation to policy AL/RTW 1. However, owing to its strategic importance at the heart of the town, we believe it should remain under TWBC ownership or that, at the very least, TWBC should retain a controlling legal interest in the site as it has done in the case of the RVP.

DLP_4273

RTW Civic Society

 

Given the demise of Calverley Square we think these two sites should be considered as a single entity since a redevelopment/upgrade of the town hall site might usefully include letting the Amelia Scott centre to expand its cultural offering eg. by transferring the café and Gateway to the town hall site.  Policy 6 needs a complete rewrite.

RTW 6 contains the Police Station.  We think it is vital that the town retains an effective police presence.  Whilst this doesn’t have to be in its current location, it is probably realistic to plan on the basis that it will remain.  However, this does not mean the police have to retain the courthouse.  Consideration should be given to utilising this listed building to greater effect by using it for items where there is insufficient space in the Amelia Scott centre.

DLP_2548

Ms S Daniels

Object

As the white elephant Calverley Square project has been cancelled, this site should not be listed for mixed use development. Instead the existing Town Hall and Assembly Theatre (which may incorporate the adjacent police station as a studio space/box office area) should be reconfigured and upgraded for 21stC office, theatre and civic use. There should be an ambition to marry up the area behind these buildings with the Amelia Scott, possibly to create a glazed interior courtyard cafe/social area.

DLP_1666

TWBC Property and Estates

TWBC

Object

  1. Map 6. - Extend the eastern boundary of the allocation to include the footpath and the section of road.
  2. Bullet 2. -The opportunity of extending the roof upward must also include the front section of the Assembly Hall and the Police Station for consistency and in order to maintain the architectural integrity of the whole group of listed buildings. The buildings comprising the Civic Complex are listed for their Group Value.

Para 5.22 - 30-36 Crescent Road.

Do not agree that these properties should be classed as non-designated heritage assets. There is no analysis to justify them, and the particular buildings are similar to many other late Victorian properties in the town. They also have no significant architectural qualities, with later indifferent shopfronts. These buildings seem to have been randomly /specifically picked out.

Inclusion should be through the adopted Local Heritage Assets SPD process which indicates that their formal identification should be by the local authority usually in tandem with developing the evidence base for plan making. The National Planning Policy Guidance (NPPG) indicates that ’Irrespective of how they are identified, it is important that the decisions to identify them as non-designated heritage assets are based on sound evidence.’ Furthermore ‘It is important that all non-designated heritage assets are clearly identified as such’

It is suggested that this has not been done and that this paragraph should be removed from the document.

DLP_1571

Mr John Hurst

 

Golden opportunity to rejuvenate, both in terms of "hardware" (the buildings) and upgrading the "software" (the people and events that could transform this central area of town).

Q: Why do I open the Trinity programme and see several events my wife and I would like to go to, but when we open the Assembly Hall programme there is usually nothing? That's what I mean by "software" upgrade.

DLP_2225

Dr Cameron Davies

Object

I support the retention of the Civic complex with suitable modifications to bring it up to date - insulation, solar power and low energy heating technology.

Refurbishment of the Assembly Hall Theatre should be considered but not as a restrictive venue for West End musicals which are easy to access by train but as a multi function venue not a lyric theatre.  Any demolition within the listed buildings complex should be kept out of the plans except where essentail for the upgrade.

DLP_2644

Irene Fairbairn

 

Civic Complex area

This is a most important area and any development needs to be carefully designed to fit in with the demands of listed buildings and the nearby former cinema development.

It is the obvious site for a redeveloped theatre plan with appropriate car parking or possibly a higher education complex.

A high quality development is essential here.

DLP_3003

Alison Howard

Object

At the Full Council meeting on 8 October 2019 the Council decided not to proceed with the Calverley Square project. Following on from this decision, policy AL/RTW 6 should be rewritten.

The new policy should provide for a sympathetic refurbishment of the Town Hall, Assembly Hall Theatre, Police Station and Calverley Terrace to provide a cultural, community and civic centre.

DLP_3130

Teresa Stevens

Object

The Police Station is to remain, so why does this policy still include it? Town Hall and Assembly Hall may not be perfect but they are good enough. What does “mix of uses” actually mean? Offices or homes or both or something completely different? If the existing buildings are to be reused, will numerous extra windows need to be created on all sides, therefore changing the look of the listed buildings?

DLP_3111

Andy Bashford

Object

The Police Station is to remain, so why does this policy still include it? Town Hall and Assembly Hall may not be perfect but they are good enough. What does “mix of uses” actually mean? Offices or homes or both or something completely different? If the existing buildings are to be reused, will numerous extra windows need to be created on all sides, therefore changing the look of the listed buildings?

DLP_3189

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:

Reference is to be made to parking requirements within the policy. For certain use classes it may not be suitable to rely solely on the town centre public car parks.

The standard paragraph regarding contributions should also 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 1 - Development of this site (or part of) should be avoided

The site contains three designated heritage assets; Grade II listed buildings; careful consideration of conservation issues required and advice of Conservation Officer essential. Archaeological issues minimal but if any groundworks some potential for post medieval.

DLP_7143

Siobhan O'Connell

Object

Now that the Calverley Square scheme has been cancelled, The Civic Complex Buildings should continue to be used for their original purpose. It never made sense to commission The Amelia Scott, which is on part of the site, whilst planning to sell off the Town Hall for mixed use development. This whole policy needs to be completely rewritten in the light of the cancellation of Calverley Square and the strong local opposition to building of a new Town Hall elsewhere in the town. There should be an imaginative refurbishment of the whole site, at a minimum retaining the shell of these listed buildings. The recent “public realm improvements” are also an integral part of the Civic quarter.

DLP_5576

Rusthall Parish Council

Object

Policy AL/RTW 6: The Civic Complex: the Town Hall, Assembly Hall Theatre, and Police Station

At the Full Council meeting on 8 October 2019 the Council decided not to proceed with the Calverley Square project. Following on from this decision, policy AL/RTW 6 should be rewritten. The new policy should provide for a sympathetic refurbishment of the Town Hall, Assembly Hall Theatre, Police Station and Calverley Terrace to provide a cultural, community and civic centre.

DLP_5755

Sally Antram

Object

Policy AL/RTW 6: The Civic Complex: the Town Hall, Assembly Hall Theatre, and Police Station

At the Full Council meeting on 8 October 2019 the Council decided not to proceed with the Calverley Square project. Following on from this decision, policy AL/RTW 6 should be rewritten.

These buildings, which were built for public use and occupy a key site in the town centre, should be kept in public use. The new policy should provide for a sympathetic refurbishment of the Town Hall, Assembly Hall Theatre, Police Station and Calverley Terrace to provide a cultural, community and civic centre.

DLP_6121

Angela Funnell

Object

Policy AL/RTW 6: The Civic Complex: the Town Hall, Assembly Hall Theatre, and Police Station

At the Full Council meeting on 8 October 2019 the Council decided not to proceed with the Calverley Square project. Following on from this decision, policy AL/RTW 6 should be rewritten.

The new policy should provide for a sympathetic refurbishment of the Town Hall, Assembly Hall Theatre, Police Station and Calverley Terrace to provide a cultural, community and civic centre.

Policy AL/RTW 7: Land at Goods Station Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_2584

DHA Planning for John Jarvis Holdings Ltd

 

1 Introduction

1.1 Purpose of this report

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

1.1.2 John Jarvis Holdings Ltd control land at Goods Station Road, Tunbridge Wells, which is identified as a draft allocation for residential development within the emerging Local Plan.

1.1.3 Based on the current national and local planning context, we consider the site to be suitable for allocation. Given this context, this representation responds to the content of the draft plan (and relevant supporting documents) and reinforces why the site remains suitable and deliverable. However, we also highlight where consider the draft policy criteria needs amendment if the allocation is to be shown to be deliverable.

1.2 Background to the Site

1.2.1 The land within our client’s control constitutes previously developed land and is situated within the Tunbridge Wells ‘limits to built development’ (LBD).

[TWBC: to view map/plan please see page 2 of full representation].

1.2.2 It includes residential properties fronting Goods Station Road and a vehicle repair workshop and car park to the rear.

1.2.3 The site is within a predominantly residential area close to town centre services and facilities and is partly in established residential use. It lies within the heart of Tunbridge Wells. With the town’s railway station situated 700m to the south.

1.2.4 The site is free from any restrictive planning designations. It is located within defined urban confines, adjacent to the town centre boundary and outside of the town’s conservation area. Furthermore, there are no nearby listed buildings that would impact upon development proposals. The closest listed building is the Grade II 18 Goods Station Road, located in excess of 100m to the south.

1.2.5 The land forms part of a formal allocation within the Site Allocations Plan 2016. Policy AL/RTW 11 states:

‘This site, as shown on the Royal Tunbridge Wells & Southborough Proposals Map, is allocated for residential development (C3) providing approximately 47 dwellings. Proposals for redevelopment shall seek to retain the existing Victorian warehouse building and the development shall provide a connection to the sewerage system at the nearest point of adequate capacity, as advised by the service provider’

[TWBC: to view map/plan please see page 3 of full representation].

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; and
  • Place Shaping Policies for Royal Tunbridge Wells.

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. Furthermore, our client concurs that Tunbridge Wells should be the focus for development.

2.2.5 Nonetheless, we would suggest some minor modification to clarify that the plan is positively prepared and fully aligned with the provisions of the National Planning Policy Framework (‘NPPF’). Indeed, we acknowledge that the Plan aspires to achieve the full development needs of the borough and therefore we consider that objective 1 should be modified to make certain on this point.

“To deliver the full housing, economic and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led and high quality development”

2.3 Development Strategy and Strategic Policies (Policy STR1)

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

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

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

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

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

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

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

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

2.4 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.

Royal Tunbridge Wells

2.4.2 Policy STR/RTW1 sets the proposed strategy for Royal Tunbridge Wells and states that Approximately 1222-1,30 new dwellings will be delivered across 17 sites, including our client’s land at Goods Station Road.

2.4.3 Policy AL/RTW 7 states that the land is allocated for residential development (conversion of existing warehouse building) providing approximately 10-15 dwellings. Development on the site shall accord with the following requirements:

  1. Utilise existing vehicular access; and
  2. Provide improvements to existing allotments, amenity/natural green space, parks and recreation grounds, children’s play space and youth play space in accordance with the requirements of Policy OSSR 2: Provision of publicly accessible open space and recreation.

2.4.4 It is expected that contributions will be required towards the following if necessary, to mitigate the impact of the development:

a) The provision of sustainable and active transport mitigation measures; and/or potential highway works within the vicinity of the site, including the provision of pedestrian crossings; and/or potential town centre-wide, or town-wide transport mitigation measures (see Policies TP 1: Transport Assessments, Travel Plans, and Mitigation and TP 2: Transport Design and Accessibility);

b) Primary and secondary education;

c) Health and medical facilities;

d) The provision of buildings and spaces to provide cultural infrastructure;

e) A new sports hub at Hawkenbury Recreation Ground, to include standing/seating for supporters and other ancillary structures, other sports and recreation grounds and built facilities, open space, and children's play space (see Policy OSSR 2: The provision of publicly accessible open space and recreation);

f) Other mitigation measures identified through the pre-application process and planning application.

2.4.5 Having regard to these draft requirements, our client supports the principle of the proposed allocation and can confirm that the land is available for development and deliverable. Furthermore, we consider that 10-15 units are deliverable. However, a series of amendments to the policy are needed.

2.4.6 First, we do not consider that ‘conversion of the existing warehouse building’ is warranted. Whilst the warehouse is Victorian it is not a heritage asset and is not of such significance that it should be retained. Furthermore, if the building is to be retained, initial masterplanning has shown that only 6 homes would be achievable, which would fail to be prudent use of the land.

[TWBC: to view map/plan please see page 8 of full representation].

2.4.7 Furthermore, even with the demolition of the warehouse, only 12 units is deliverable within the extent of the illustrative red line allocation area as outlined overleaf.

2.4.8 With this in mind, we consider that the proposed allocation boundary should be amended to include the wider car park area situated to the eastern extent of the site, which is also within our client’s ownership. In our view the wider inclusion of the land is essential for two reasons;

  1. Inclusion of the land would allow the parking provision for the new development to be facilitated on the additional space. This would be a continuation of the existing use and would have no greater or more significant adverse impact upon the amenities of neighbouring properties. In turn, up to 15 quality apartments could be created; and
  2. The failure to include the additional land from the allocation will render it an area of ‘no man’s land’ without a lawful use or viable use.

[TWBC: to view maps/plans please see page 9 of full representation].

2.4.9 In summary, the land is available for development and deliverable within the plan period. However, not for the form of development included within the consultation draft.

2.4.10 The detailed concepts for a deliverable amended allocation are included as Appendix 1.

3 Conclusion

3.1.1 This representation has been prepared on behalf of John Jarvis Holdings Ltd response to the Tunbridge Wells Borough Council Draft Local Plan Consultation. The purpose being to provide comment on the Council’s proposed development strategy and the draft allocation reference AL/RTW 7.

3.1.2 In this respect, we support the aspiration to meet housing need in full and consider that a dispersed growth strategy represents the optimum means to achieve this. Furthermore, we support the inclusion of our client’s site in Royal Tunbridge Wells. Such opportunities must be maximised in order to help limit the degree of greenfield land that needs to be released elsewhere.

3.1.3 It is important that these town centre sites are retained and maximised within the Regulation 19 draft, as we consider that the Local Plan strategy relies too 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.

3.1.4 I trust the contents of this representation are clear and I hope the comments are useful in guiding the forthcoming stage of the plan making process.

[TWBC: to view Appendix 1 please see full representation].

DLP_1809

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Numbers:  AL/RTW 7,8,9,10,14,15,19, 24, 26,28,29,31,32

The above sites seem suitable for allocation subject to the proposed conditions written into the policies.

DLP_3190

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following change is requested:

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

Policy AL/RTW 8: Land at Lifestyle Ford, Mount Ephraim/Culverden Street/Rock Villa Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_969

Mr Mark Poulton

Object

If you develop the areas around Culverden Street (and Grosvenor Road), perhaps you could read the following comments and answer the questions?

  1. How will you guarantee the structure of the local Victorian houses and ensure their foundations are not compromised?
  2. Where will the numerous commercial and residential refuse bins be located/stored?
  3. The substantial building work planned over a number of years will have a significant impact on the lives of the residents of The Old Coach House, in Culverden Street. This is totally unacceptable in terms of access, road quality, noise, disruption, etc. Who will mitigate this and owns the development site?
  4. Unadopted Areas and Consultation Areas around Culverden Street.

Please do not refer to this area as a Conservation Area. That is a complete misnomer. Nobody enforces conservation and TWBC will not allow anybody to take ownership of it. A few examples:

a) The unadopted area, not included in your plans, are regularly used for illegal activities. Late night revellers use them for various forms of unsocial behaviour such as drinking, drug taking, urinating, deficating. Flytippers use it regularly throughout the day and night. What will you do to stop this?

b) I am sure you are already know, there is currently a multi-thousand pound insurance claim going through the Courts following an accident where, not for the first time, somebody fell over in this area due to hazardous surface. Will you leave the unadopted pathways and garage forecourt area as it is, for rats and foxes to have somewhere to thrive, or will you develop it?

c)  There is an unadopted right-of-way between Culverden Street and 55 Grosvenor Road which is currently used as a footpath? The path is, effectively, in the centre of the town and used by hundreds of people every day of the week. These numbers will increase significantly when the proposed new development is implemented. The path is on a slope and currently has five commercial bins located along one side. The area is a disgusting health hazard, particularly in the Winter, when it is icy and people slip on the decaying food, chicken skins and discarded take-aways that have been strewn across it or scattered by vermin.

The issues have been reported many times to TWBC and Street Scene - with photos and incriminating information on flytippers. Street Scene say it is the worst place in the town centre and an accident waiting to happen. There has been a hole in the footpath for the last 18-months measuring circa 45cm in diameter and 60cm deep - yes, 60cm deep. We, the local residents, would like to own, maintain and control the area. However, Mr Rob Campbell, TWBC Planning Compliance Officer, has said we are not allowed to do anything with the pathway because: "...this is an established right of way by dint of continuous use...". He has also said: "...the upkeep and public liability falls in the juristiction of Tunbridge Wells Borough Council...". However, TWBC will not: police the path, tidy it, repair it, spray it with weedkiller or spend any money looking after it.

After numerous letters to TWBC to try to resolve the ownership, issues and maintenance we have been told by Laura Gardener-Browne (TWBC's Senior Solicitor): "[TWBC] ...will not be entering into further correspondence..."

So, who will own and maintain this unloved, hazardous, unadopted right-of-way?

All of these areas are generally maintained by the best will and endeavour of local residents.

How can TWBC justify this dereliction of duty but then commit to spending millions of pounds on a new development that abuts it?

Potential solution - include the unadopted areas and The Old Coach House in the development plans please?

DLP_3590

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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/RTW 8

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

DLP_4544

Historic England

 

Policy AL/RTW 8 - the principle of development at this site on Mount Ephraim may be acceptable but the planning and design of new buildings needs particular care in view of its prominent position in the Conservation Area, the setting of adjacent Listed Buildings, and the views of the skyline of the town.

DLP_2893

Chris Gow

Object

This development should be low cost housing. It is ideally located close to shops and amenity, and to bus routes and is suitable for non-vehicle owning residents.

The temptation to deliver high cost exclusive housing should be resisted, the less well of of the town deserve better than to be priced out of well located property.

DLP_2894

Chris Gow

Object

I object to this development.

The development should deliver low cost housing. It is ideally placed close to shops and amenity and should only be considered for low cost housing. It is close to bus routes and thus residents will not need to own vehicles.

DLP_1810

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Numbers:  AL/RTW 7,8,9,10,14,15,19, 24, 26,28,29,31,32

The above sites seem suitable for allocation subject to the proposed conditions written into the policies.

DLP_5203

Culverden Residents Association

Support with conditions

We support the redevelopment of this site provided that No 15 Mt Ephraim is retained and light continues to reach the stained glass window in the United Reform church. Any redevelopment should respect the character of the area, particularly the rest of Mt Ephraim and Grosvenor Road. Being right in the centre of town, this could be an area particularly suitable for home-working in the creative/tech industries and some of the residential units might be designed specifically with those needs in mind for mixed uses.

DLP_2598

Richard Bysouth

Support with conditions

This area would certainly benefit from redevelopment, but the A26 is at a near-constant standstill there, with considerable pollution. That needs resolving before this would be suitable for residential use, surely.

The development must allow for the creation of a complete cycle network along this part of the A26 (or better, along Culverden Street).

DLP_3191

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 - “Pedestrian access shall be provided through the site from west to east, providing a pedestrian link from Royal Wells Park to Rock Villa Road, and from there to Grosvenor Road and the town centre, including improvements to the existing pedestrian network where required.

Additional paragraph - Vehicular access, delivery and servicing from Culverden Street.

The standard paragraph regarding contributions should also 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 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

The Site of Tunbridge Wells United Reformed Church which is a building highlighted as being of local importance. Potential for Post medieval remains. An Archaeological DBA is recommended.

DLP_7069

Brown & Co Planning Ltd for The Hendy Group

Support with conditions

Policy Number: AL/RTW 8 - Land at Lifestyle Ford, Mount Ephraim/Culverden Street/Rock Villa Road

Comments; Support with conditions

1.22 Our Client supports the continued inclusion of Site RTW 8, Land at Lifestyle Ford and the increase in the number of approximate dwellings that is considered developable on this site.

1.23 The Council have maintained the allocation and so are clearly of the view that the site remains an important and deliverable part of their strategy.

1.24 Our Client has undertaken initial design and feasibility assessment work which indicates that the site has the capacity for an increased density which would enable a greater contribution to the Council’s housing need. As such our Client strongly recommends that this policy is reworded to ensure that the policy allows the site to be developed to its maximum potential of circa 100 dwellings to enable the delivery of more housing.

This policy sets out very prescriptive requirements for the site as set out below. Our Client is concerned that some of these could stifle, rather than encourage, development contrary to the presumption in favour of sustainable development (NPPF, paragraph 11).

Point 1

1.25 Initial design assessment work suggests that it may be possible to retain the façade of No. 15 Mt Ephraim, however, whilst it is agreed that it would be desirable to retain this frontage the building is not specifically designated, and it should not be a definitive requirement of the policy that it is retained. Furthermore, the other buildings on site do not merit retention and cannot realistically be adapted. In order to make effective use of the site it will, therefore, be necessary for comprehensive site clearance.

Point 6

1.26 The setting of the adjoining stained glass window in St Andrew’s United Reform Church is currently very compromised. Our Client would therefore suggest that the policy is positively reworded to encourage development on site to ‘improve the current setting of the window’, rather than ‘obscuring or preventing adequate light from reaching the window’.

Point 8

1.27 Point 8 of the policy identifies that development on the site should provide on-site amenity/natural green space and children’s play space and improvements to existing allotments, parks and recreation grounds and youth play space.

1.28 Although plans should set out the contributions expected from development, such policies should not undermine the deliverability of the plan (paragraph 34, NPPF).

1.29 Our Client recognises that some form of public space where possible, including landscaping, should be provided on site, however, it is an urban site and as such there is a limit to what can be realistically and viably provided on site.

1.30 The policy furthermore requires additional contributions (a-f) ‘if necessary’. To ensure that development is not overburdened, the policy should state that the contributions should be proportionate and based on the relative impact of the development.

Points a

1.31 By virtue of the nature of the proposed use and sustainable location of the site, it is less intrusive than the current use and will create less traffic.

1.32 Mitigation measures for ‘highway works within the vicinity of the site’ should also be proportionate and reflect the likely overall significant reduction in vehicle movements from the current use of the site.

1.33 Our Client believes that as currently worded, the policy is potentially misleading and infers that town-wide mitigation measures could be sought, without appropriate assessment of the specific impact of the proposed use compared to the current use of the site.

Point d

1.34 Point d of policy AL/RTW 8 requires the provision of buildings and spaces to provide cultural infrastructure [2 Defined as Infrastructure to mitigate the impact on cultural need through the provision of buildings and spaces (Policy STR 5, TWBDLP). The NPPF defines cultural infrastructure as coming under community facilities (paragraph 20, NPPF).].

1.35 As set out in the TWBDLP and IDP, the only current planned provision in Royal Tunbridge Wells is for the Cultural and Learning Hub (The Amelia Scott). This however already has a secured grant funding of over £5m and the development is expected to start on site later in 2019 (paragraph 3.262, IDP, draft 2019).

1.36 No other proposals for cultural infrastructure have been identified in the Local Plan or IDP.

1.37 As stated at paragraph 3.260 of the IDP (draft 2019), ‘it is recognised that public art is a key component of the delivery of cultural provision’. Public art is already required in point 3 of the policy. This does not need to be duplicated in point d of the same policy.

1.38 Our Client therefore considers that the requirement of providing cultural infrastructure to mitigate the impact of development is not clear or justified and as such is contrary to Paragraph 35 of the NPPF.

1.39 The long list of proposed mitigation measures could significantly risk the viability of the site as it will already be a costly and challenging site to redevelop given the site constraints. The development cannot be overburdened with additional infrastructure and it should be reasonably expected to only provide mitigation based on the assessed impact of the proposed development compared to the existing site.

1.40 As currently drafted, our Client would question the robustness of this policy and its consistency with national policy to enable the delivery of sustainable development.

1.41 It should also be noted that the redevelopment of the Mt Ephraim site for future residential development is dependent on identifying a suitable relocation site for the motor dealership business. Hendy have identified a new site at Pembury Road as an appropriate alternative for the development of a Motor Village Car Dealership. This site is proposed as a separate allocation – Woodsgate Corner, AL/PE 7.

Support subject to the following changes:

Our Client strongly recommends that this policy is reworded as follows to ensure that this policy is robust and consistent with national policy:

“This site, as defined on the Royal Tunbridge Wells draft Policies Map, is allocated for residential development (C3) providing approximately 80 100 dwellings.

Development on the site shall accord with the following requirements:

1. While it is accepted that considerable demolition will be necessary, this should be avoided where possible, particularly at existing buildings on site will need to be cleared, the front façade of No.15 Mount Ephraim, which must should be retained if possible as part of any redevelopment.

6. Development on the site shall be designed to improve the current setting of s o as not to obscure or prevent adequate light from reaching the large stained glass window in St Andrew's United Reform Church;

8. Provision of on-site amenity/natural green space and children’s play space and where necessary and justified wider improvements to existing allotments, parks and recreation grounds and youth play space in accordance with the requirements of Policy OSSR 2: Provision of publicly accessible open space and recreation.

It is expected that proportionate contributions based on the relative impact of the development will be required towards the following if necessary, to mitigate the impact of the development:

a. The provision of sustainable and active transport mitigation measures, highway works within the vicinity of the site (proportionate to and based on the specific impacts arising from the proposed development) including the provision of pedestrian crossing and/or town centre-wide, or town-wide transport mitigation measures (see Policy TP 1: Transport Assessments, Travel Plans, and Mitigation and TP 2: Transport Design and Accessibility);

d. The provision of buildings and spaces to provide cultural infrastructure;

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

Policy AL/RTW 9: Land at 1 Meadow Road and 8 Upper Grosvenor Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_759

Dr P Whitbourn

 

Eton Lodge, no. 8 Upper Grosvenor Road is one of a pair of detached Victorian villas prominently set at the corner of Upper Grosvenor and Meadow Roads. Eton Lodge has rusticated quoins, shouldered window surrounds and other classical architectural features, and it fits harmoniously with other Victorian villas in this part of Grosvenor Road.

The building is currently in use as the Driving Test Centre for the area, and appears in fair condition. No. 1 Meadow Road is a modern office block which, in relatively recent times has been occupied by Canterbury Christchurch University as an applied psychology institute.

Section 2 of Policy AL/RTW 9 rightly encourages the avoidance of demolition where possible, but particularly advocates retaining no. 1 Meadow Road. In townscape terms, Eton Lodge has distinctive local character, which is lacking in no. 1 Meadow Road, and it is Eton Lodge, no. 8 upper Grosvenor Road, that Policy AL/RTW 9 should be advocating particularly for retention, on account of its positive contribution to the street scene on this prominent corner.

Should Eton Lodge no longer be required in future times as a Driving Test Centre, the a higher educational use for the building would seem an appropriate alternative.

DLP_1811

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Numbers:  AL/RTW 7,8,9,10,14,15,19, 24, 26,28,29,31,32

The above sites seem suitable for allocation subject to the proposed conditions written into the policies.

DLP_2895

Chris Gow

Object

This site should be developed for residential housing only, preferably low cost, close to shops and amenity.

DLP_3192

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:

Additional paragraph - Consideration to be given to adequate space for congregation of pedestrians.

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

Policy AL/RTW 10: Land at the Auction House, Linden Park Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_885

Kember Loudon Williams for Lower Pantiles LLP

 

Paragraph 5.26 of the draft Local Plan is the explanatory note to draft Policy AL/RTW 10: Land at The Auction House, Linden Park Road, Tunbridge Wells. As currently drafted the policy allocates the land for B1(a) Office Use – the policy implications of this are addressed fully in Comment Box 2B below. [TWBC: see comment number DLP_886].

The explanatory note confirms that the former Auction House site lies within the existing Limits to Build Development of Tunbridge Wells and that the site has planning permission for offices within use Classes B1 (Business) and A2 (Financial and Professional Services): approved under reference 18/01928/FULL). Whilst both are correct statements, we would invite the Council to consider the following points:

  • Limits to Built-Development: The use of Limits to Build Development (LBD) is a long standing and accepted policy tool to provide certainty and clarity on where new development will be acceptable in principle. In effect, establishing a presumption in favour of development/change as a means to focus growth / change in sustainable locations / settlements.

The former Auction House site is a large brown field parcel of land that lies within The Pantiles in a highly sustainable, mixed-use, town centre location with direct and ready access to strategic public transport infrastructure. As such the site falls at the very top of the sequential hierarchy for the allocation of land for development - to that end we support the allocation of the land for office development.

However, the identification of the land for a single, mono-use, as offices is too narrow and short sighted and has the potential to fetter future more creative and responsive mixed-use development solutions / options. These need not be provided at the expense of the provision of offices. As with any town centre site, (particularly those that lie within the sensitive environment and fragile economy of The Pantiles) the emphasis must be on maintaining, supporting and encouraging land-use flexibility. This is consistent with the inclusion of the site within the LBD and central commercial area for Tunbridge Wells. The National Planning Policy Framework (NPPF), February 2019, requires that planning policies “..help create the conditions in which businesses can invest, expand and adapt..” – paragraph 80 refers.

Paragraph 81 of the Framework, expands the theme, at clause (d) advising that policies should be “..flexible enough to accommodate needs not anticipated in the plan, allowing for new and flexible working practices, and to enable rapid response to changes in economic circumstances...” The latter is particularly relevant given the political and economic circumstances that prevail at present.

The physical character of the Pantiles, together the wide variety and mix of land uses adjoining (which are typical of a town centre location), supports the allocation of the Auction House site for a variety of potential uses comprising employment (office), retail, residential, leisure and health related uses: as indeed the site has been allocated in Policy AL/RTW/24 in the adopted Site Allocations Development Plan.

To focus purely on offices now is inconsistent with Government Policy and lacks the flexibility and foresight needed to enable any redevelopment of the site to respond positively to changing circumstances. In our view a mixed-use development represents a better more integrated solution that would respond more readily to the character / variety of uses in the Pantiles. The facility to introduce more than one use would be better insulate the wider site from any future fluctuations in the economy / market.

  • Planning Permission 18/01928/FULL: Planning permission for the change of use of the Auction Hall to offices within use Classes B1 (Business) and A2 (Financial and Professional Services) was approved in September 2018.

As currently drafted, the focus of paragraph 5.26 (and policy AL/RTW 10) on office (B1 uses) is so restrictive and narrow that it would prevent the implementation of the A2 (financial and professional services) of the extant planning permission – there is an obvious contradiction.

The wording of the explanatory paragraph and Policy RTW 10 is so unjustifiably restrictive, that unchecked it will introduce a strangle hold on the future of this site and limit the ability to respond to expected changes in the market. Moreover, a mixed-use solution would, in our view, provide a more satisfactory integrated land-use solution that is more consistent with the varied and intricate character of the Pantiles:

Recommendation: Paragraph 5.26 be amended to include (in addition to offices – B1 and A2) the potential redevelopment of the site for a variety of town centre uses including employment uses, retail, residential, entertainment and health related uses.

DLP_886

Kember Loudon Williams for Lower Pantiles LLP

Object

Policy AL/RTW 10 of the Draft Local Plan allocates the land at The Auction House, Linden Park Road, Tunbridge Wells for B1(a) Office Use. The following representations should be considered alongside those made on Paragraph 5.26 in Comment Box 2A. [TWBC: see comment number DLP_885]

The ‘presumption in favour of sustainable development’ lies at the heart of the planning system. For the purposes of ‘plan making’, paragraph 11 of the Framework (February 2019) explains that this means that “..plans should positively seek opportunities to meet the development needs of their area and be sufficiently flexible to adapt to rapid change..” The creation of a responsive adaptable policy framework is essential to support investment, regeneration and change to respond to varying market and political conditions: both are particularly volatile at the movement and, in all likelihood, will remain so for the foreseeable future.

Part (d) of paragraph 81 of the Framework continues the thread, requiring that 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 and political circumstances, quite rightly, lies at the heart of the Government’s Framework for growth to build a strong and competitive economy.

The draft wording of Policy AL/RTW 10 is so limiting and restrictive as to be at complete odds with the Government’s stated aims for land-use flexibility to support the town centre economies. Whilst there is no objection to the use of the site for B1 office use in principle, this should not be at the exclusion of other suitable town centre uses, such as retail, residential, entertainment/leisure and health related uses – all of which are consistent with a town centre location such as this and would complement the existing uses in this part of The Pantiles, many of which have recently been approved by the Council. The key is to maintain flexibility and variety.

In this regard we would invite the Council to take into account the recent approval under reference 17/02097/FULL for the change of use of The Corn Exchange, which adjoins the Auction House, from its former retail, entertainment, leisure and food and drink uses to a business centre comprising open plan offices falling within Use Classes B1 (Business) and A2 (Financial and Professional Services). This is a substantial development, now completed and in the process of being offered to market.  Taken alongside the extensive office (B1) uses in a combination of Frant, Eridge and Dowding Houses, also adjoining the site, there is a considerable body of office accommodation, taken up and available, within this part of The Pantiles.

That is not to say that office accommodation would be an inappropriate use of the Auction House site. However, the B1 (office) use classification should be retained as one potential / optional future use with the facility to be combined with other town centre uses should the market / physical circumstances determine this. In this regard it is envisaged that the future use of the Auction House site should include the potential to include residential: again, if circumstances dictate. The residential re-use of the site, in whole or as component part of a mixed-use scheme, would help to support the fragile economy of this part of the Pantiles.

The benefits of residential use(s) to ensuring the vitality and viability of town centres is recognised at Part (f) of Paragraph 85 of the Framework, which requires that planning policies should “.. recognise that residential development often plays an important role in ensuring the vitality of centres and encourage residential development on appropriate sites..” The facility to use part of the Auction House site (upper floor(s)) for accommodation would be consistent with the character of this part of the Pantiles where residential uses sit comfortably and sustainably alongside retail, office and other town centre commercial uses.

This more flexible approach that aligns with the Government’s clearly stated aims as set out, is correctly provided for within Policy AL/RTW 24 within the Council’s adopted Site Allocations Local Plan.

Recommendation: Draft Policy AL/RTW 10 be revised (along with paragraph 5.26) to allocate the Land at the Auction House, Linden Park Road for a mixed-use development comprising, in addition to Offices – B1 and A2 employment uses, retail, residential, entertainment and health related uses.

DLP_3591

Southern Water Services Plc

 

Southen Water is the statutory wastewater undertaker for Tunbridge Wells. 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/RTW 10

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

DLP_4546

Historic England

 

Policy AL/RTW 10  - we note that planning permission has been given for conversion of the exiting the former auction house at Linden Park Road but that redevelopment oif the site is retained as an option in the policy.  The site is very close to the iconic Pantiles and adjacent to other listed buildings; particular care need to be taken in respect on any redevelopment’s impact on the setting of these assets.

DLP_1812

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Numbers:  AL/RTW 7,8,9,10,14,15,19, 24, 26,28,29,31,32

The above sites seem suitable for allocation subject to the proposed conditions written into the policies.

DLP_1668

TWBC Property and Estates

TWBC

Support with conditions

a. Should the approved B1 use not be implemented for whatever reason, or the approval lapse, it is suggested that the site should remain allocated for a range of developments comprising employment, retail, residential, hotel, leisure and health-related uses.

b. Also Map 10 to retain the full extent of site. (as current local plan policy) Inclusion of replacement car parking would need to be part of the mix.

DLP_2226

Dr Cameron Davies

Support

 

DLP_3193

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:

Additional paragraph - All servicing and delivery activity to be contained within the site boundary.

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

Heritage and Conservation

Archaeological DBA is requested.

Policy AL/RTW 11: Former Plant & Tool Hire, Eridge Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_668

Ms Carole Freeman

Object

Re:  AL/RTW11 - This proposed development seems to be rather a large number of dwellings for such a small space. The Eridge Road is all ready very busy at most times of the day with almost continual traffic and if 37-70 properties, each  with  at least 1 vehicle coming out on to the Eridge Road even more hold ups will follow - especially it being so close to traffic entering and leaving the road from Sainsburys and Homebase and the station and restaurant close by.  At peak times of the day the roads in and out of the town are already totally jammed and this will increase traffic problems even further.  Many people I know who live outside the town do not come in to shop unless it is absolutely necessary because of the traffic jams everywhere across the town - they prefer to go to areas where there is free parking and no aggravation or shop online.  It is about time that TWBC realise that everyone  is fed up with the poor flow of traffic around and through the town and the huge lorries taking short cuts through residential roads - where people park on the pavements to avoid their cars being damaged by these huge vehicles.

DLP_878

Anna

Object

I would like to respectfully strongly oppose the designation of the Former Plant &Tool Hire site on Eridge Road as “(C3) providing approximately 37-60 dwellings or for a range of uses to include residential and/or A1 retail and/or employment”.

The site is relatively small (for example, I would note that it proved difficult for previous proposed developers to produce a workable plan for the site, once car parking had been accommodated) and it is directly bordered by a number of residential dwellings that run along Nevill Terrace, who enjoy various rights over the plot. The site has one means of access, via entrance and exit onto Eridge Road, one of the busiest roads in Tunbridge Wells.

In light of the above constraints, it would be inappropriate to allow it to accommodate 37 – 60 dwellings and/or a retail/ commercial premises. At a more granular level, our objections to these designations are as follows:

  • It does not have the transport infrastructure or size to support the vehicles that would accompany this number of dwellings, further making it fundamentally incompatible with an A1 designation.
  • Any use of the site that would allow high volumes of vehicles (e.g. a commercial use or high density population of dwellings) would increase the already high pollution and traffic volumes that affect Nevill Terrace and Eridge Road. In particular, it is likely that it will be extremely difficult for existing residents to exit and enter the plot if vehicle numbers increase.
  • Due to the size of the plot, a high density residential and/or retail use of this site would adversely impact the quality of life for the existing residents of Nevill Terrace, whose dwellings and gardens directly border this site. In particular, the proposed designation would almost certainly require multiple story windows/viewings at close proximity that look directly into the existing residents’ houses and gardens (creating privacy and light pollution concerns). I would note that such rights have previously been relatively unencumbered for in excess of 20 years.

Given these concerns and the rights of the existing residents, it is unclear how the designation of the site for this purpose has been justified, or why it was arrived at. It is clear that the rights of the surrounding residents have not been taken into consideration in this process.

I request that the designation of this site is reconsidered and that the existing residents be allowed to continue to enjoy the same quality of life they have done to date. The site would be best suited to a low density residential area with provisioning for green space to counter the inevitable increase in traffic flow and pollution.

As an additional note, I would add that the “proposed site allocation policy boundaries” labelled RTW 11 has been incorrectly drawn with respect to the land owned by the existing residents, meaning that the site is actually slightly smaller than shown.

DLP_3592

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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 60 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/RTW 11

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 Tunbridge Wells. 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/RTW 11

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

DLP_1822

Royal Tunbridge Wells Town Forum

General Observation

Policy Number:  AL/RTW 11 Plant and Tool

While housing may appears an adequate use of the site taken in isolation, this would significantly reduce the opportunities for long term redevelopment of a much greater area behind it for transport and other mixed uses. This site might have far greater potential as a multi-storey car park as part of a future remodelling of the site at the West Station in conjunction with restoration of a public transport rail service. The site might also be considered as a suitable alternative for car parking if the Calverley Square scheme (AL/RTW 1) goes ahead in revised form.

DLP_4274

RTW Civic Society

 

Given this is up for sale, might it not be better to restrict this to residential?

DLP_2227

Dr Cameron Davies

Support with conditions

The site should be considered for low rental housing association owned properties.

DLP_3195

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:

Additional paragraph - All servicing and delivery activity to be contained within the site boundary.

Additional paragraph - Suitable pedestrian links from the west to be provided.

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

DLP_2896

Chris Gow

Object

This site should be developed for housing, in keeping with the houses along Eridge Road.

There is no justification for another supermarket.

The access via the roundabout if frequently congested by peak traffic flow into Sainsburys.

DLP_2897

Chris Gow

Object

I object to this site being used for a supermarket.

It should be developed only for housing.

Policy AL/RTW 12: Land adjacent to Longfield Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_8227

Lichfields for U + I Group Plc

 

Representations relating to Land South of Appletree and Devils Wood (north of North Farm Lane)

On behalf of our client, U+I Group PLC (U+I), we submit below representations in response to the regulation 18 Tunbridge Wells Borough Council (TWBC) Draft Local Plan issued for public consultation until 15 November 2019.

By way of background, on behalf of our client, we have proactively engaged with the Council through the Local Plan preparation stages, including the submission of two sites at Land adjacent to Longfield Road and Land South of Appletree and Devils Wood in July 2016, in response to the Call for Sites for the Strategic Housing and Economic Land Availability Assessment. Subsequently, we responded to the Issues and Options consultation and Call for Sites in June 2017 promoting these sites for development as a natural extension to the existing industrial area to the north of the city.

Employment land

U+I welcomes the allocation of Land adjacent to Longfield Road for a new business park as part of the consultation document under Policy AL/RTW12. U+I is committed to the delivery of this site to assist in meeting the Council’s employment needs in the short term and as such an application for outline planning permission has been submitted for development at the site (ref. 19/02267/OUT).

Housing land

In addition, U+I is aware of the wider development pressures and the need to accommodate considerable amounts of new development over the plan period to meet the needs of the Borough. We consider that the site at Land South of Appletree and Devils Wood can make a valuable contribution to meeting housing need. This site constitutes a parcel of land to the north of Tunbridge Wells with an area of 53.95 ha, portions of which are currently in agricultural use. The site would form a natural extension to the built up area of Tunbridge Wells to the south and has the potential to deliver up to 850 residential units.

Representations

Land South of Appletree and Devils Wood is identified in the consultation document in Appendix 6 as a site that has not been allocated in the draft Local Plan.

The identification of future suitable housing sites must form a strategic priority for Tunbridge Wells Borough Council, with the area’s significant future housing need providing a key challenge for the Borough going forward. This site offers an opportunity for U+I to lend its significant technical knowledge and draw upon its longstanding track record of sensitive and successful delivery of development sites to help TWBC to meet those local housing needs. As is demonstrated by U+I’s ongoing work to deliver employment land at Kingstanding, it is committed to high-quality design that responds to the sensitive site context.

Paragraph 67 of the National Planning Policy Framework (NPPF) states that planning policy should identify a sufficient supply of sites, taking into account their availability, suitability and likely economic viability. The site in question is in line with these requirements:

  • The entire site is under single ownership and is available for development.
  • It is suitable for development, presenting a natural, high quality extension to the north of Royal Tunbridge Wells in a sustainable location. Development would be led by a masterplan approach to ensure that the design is appropriate to its context and it is considered that through this approach supported by robust technical assessments site constraints can be responded to and mitigated as necessary.
  • It presents a viable development opportunity with no abnormal site constraints on development anticipated at the site.

Accordingly, the site will be readily available and deliverable over the plan period and can make a substantial contribution to meeting housing need in TWBC as part of an appropriate strategy in the Local Plan. It is therefore considered that the site should be allocated in the Draft Local Plan for housing development.

Proposed amendment

In bringing forward this proposed site allocation, it is requested that the boundary of the allocation is amended to incorporate Pilgrims Wood and Prowles Gill to the south east. This area is currently shown as part of the site allocation at Land adjacent to Longfield Road (under draft Policy AL/RTW12). This area does not form part of the pending outline planning application which will deliver this site allocation. It should therefore be transferred to the Land South of Appletree and Devils Wood site allocation so it can form part of an appropriate masterplan for development in this area. Accordingly, we have prepared an updated version of the plan showing the boundary for the proposed site allocation (see Annex 1) and confirm that the new site area would be 61.54ha.

Conclusion

The Land South of Appletree and Devils Wood (north of North Farm Lane) provides an appropriate and sustainable location for future housing development that is considered viable, suitable and available for development and thus able to contribute to meeting identified local housing need. It offers an appropriate opportunity to be considered positively in terms of green belt release and landscape integration, with the prospect of beneficially being allocated for housing development in the emerging Local Plan.

We would welcome the opportunity to discuss further the real development potential of the site with TWBC. In the meantime, should you have any further questions, please do not hesitate to contact me.

[TWBC: for annex 1 see full representation].

[TWBC: this representation also entered under Appendix 6 - see Comment No. DLP_8228].

DLP_1381

Mrs Kay Williams

Object

Dear Sir,

I wish to object to the above on the grounds that it will increase the highways concerns of local residents.

The extra traffic generated will be unable to all use Nells Bridge as this is at full capacity at peak times now. A significant percentage 5%+? will have to travel along Birken Rd & Liptraps Lane. It is already difficult for pedestrians to cross this road & hazardous for young mothers with pushchairs and there is only one pedestrian crossing at the junction with Harris Road. At peaks times the traffic already has huge queques back to the shops owing to difficulty of exiting right into Sandhurst Rd.

The proposed site should not be allowed unless Nells Bridge is widened & rebuilt for 21st Century Traffic flow & several more crossing points agreed on Birken & Liptraps where this is a much used Church & school & it is already dangerous to cross. Indeed when pushing my grandaughter in her pushchair cars have to stop in both directions for us to cross

DLP_4108

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

This policy alone allocates land in excess of the OAN identified for the whole borough in the Economic Needs Study (see our response to Development Policy ED1).  This proposal for major development in the AONB and Green Belt has not been adequately justified under NPPF paragraph 172.

DLP_3827

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_2898

Chris Gow

Object

Please do not develop Green Built land.

The trees and shrubs are essential for the battle against CO2 emission, and provide amenity for residents.

DLP_2899

Chris Gow

Object

I object to all development on Green Belt land.

The trees and shrubs in the Green Belt are essential for the battle against CO2 emission, and provide amenity for residents.

DLP_1545

Tonbridge & Malling Borough Council

Object

Tonbridge and Malling welcome the contribution the proposed allocation will make towards meeting the identified needs for employment land in Tunbridge Wells.

However, the concentration of such a significant proportion of the overall need in one location, on the A21 and relatively close to the borough boundary and the Tonbridge Industrial Area raises two concerns regarding the potential impact on the local highway network and competition with businesses in Tonbridge.

Therefore, TMBC would welcome working with the Borough Council, Highways England and Kent Highways to ensure that any potential adverse impacts on the highway network both in the immediate vicinity and more widely can be satisfactorily mitigated. We would also wish to ensure that the planned investments at Longfield Road and at Tonbridge are complementary rather than competitive to ensure that positive economic growth can be delivered either side of the borough boundary.

DLP_1823

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Number:  AL/RTW 12 Land adjoining Longfield Road 

If incursion into the AONB is found to be justified by exceptional circumstances, the site would appear suitable for expansion of the business park to provide much needed replacement office/light industrial space. There is a significant topographical question mark over the northern boundaries which are higher level ground which would damage the important green backdrop to the current edge of the town. The proposed green buffer appears to mitigate these negative effects to some extent provided it can be effectively safeguarded through the policies set out in Paragraphs 4-7.

DLP_3416

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_2045

Terry Everest

Object

Stongly object

The business case for this site is much weaker than supposed, one remembers how Century Place went at least a decade before it was filled with users and has declined in use since. There are huge amounts of unused space around the town for businesses to use without needing a new site.

The site currently has significant numbers of trees, ponds and scrub vegetation  upon it and provides something of an environmental buffer for the enlarged A21, and is a habitat for wildlife. The North farm continues to be built on and expanded but this area should remain undeveloped.

DLP_1645

Tom Tugendhat MP

 

AL/RTW 12 - Land Adjacent to Longfield Road, Tunbridge Wells

I also wanted to touch on Policy AL/RTW 12 in the TWBC Draft Local Plan in light of my previous comments about industry in Tonbridge. I note that the Sevenoaks and Tunbridge Wells Economic Needs Study, produced in 2016, is used as the document to inform the decision on where to allocate sites in the Draft Local Plan. I'm aware this looks at land around the A21 as a significant opportunity for further employment growth potential. However, there are two issues with this that bring me to have concerns about this allocation.

First, since 2016 there have been two important developments which might overstate this need. The first is the completion of the A21 dual carriageway between Tonbridge and Pembury. This is something I strongly welcomed - and even opened at its completion - but we must recognise that there are some design issues which need to be resolved. At the time of writing we do not have confirmation from Highways England that any identified works will be funded following the completion of the Road Safety Audit Stage 4 that is currently being undertaken. In the event that we are unsuccessful in getting any road improvements delivered, then I have concerns about development which would increase the volume of traffic using this road at peak times. Employment sites with an additional 80,000sqm floorspace across B1, B2 and B8 uses would generate huge traffic movements during the rush hour and the impact on the A21 both here, and further north towards Morleys Roundabout, gives me cause for concern.

Second, we have had the publication and submission to the Inspectorate of the TMBC Local Plan and its plans for employment land allocations in Tonbridge. Though TMBC have had to take some difficult decisions about the sites which it selected for development, they have sought to keep Tonbridge's industrial heart in the Cannon Lane and Vale Road area by rejecting the opportunity to replace employment land here with residential units.

I am concerned that this allocation, and the sheer size of it, does not account for the development which TMBC plans to bring forward for employment land too. As TMBC are further advanced with their Local Plan it is incumbent upon TWBC to address the issues which are raised in it, rather than vice versa. I am afraid I need more reassurance about this impact and wish for a better assessment when it gets to Regulation 19 stage.

[see also full response - Comment Number DLP_1577 (entered under Foreword)].

DLP_3112

Andy Bashford

Support with conditions

Presumably all the trees will be retained (marked in green – Open Space and Landscape Buffer). Hendy could have their Multi-Garage on this site. The proximity to and types of roads to the A21 make this a no-brainer. It is adjacent to the rest of the Industrial/Business Estate, therefore not suitable for houses. The main concern is that deers are often in the open field and might end up on the A21.

DLP_3131

Teresa Stevens

Support with conditions

Presumably all the trees will be retained (marked in green – Open Space and Landscape Buffer). Hendy could have their Multi-Garage on this site. The proximity to and types of roads to the A21 make this a no-brainer. It is adjacent to the rest of the Industrial/Business Estate, therefore not suitable for houses. The main concern is that deers are often in the open field and might end up on the A21.

DLP_3196

Kent County Council (Growth, Environment and Transport)

 

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

Paragraph 2 - “non-motorised route” should amended to read non-motorised user (NMU) route.

Additional paragraph - The Transport Assessment should communicate how the development would use sustainable transport principles to minimise additional vehicular trips on the network.

Additional paragraph - The Developer will be required to consider the impact of this development on the wider road network, such as the A21 junctions at Pembury and Tonbridge.

The standard paragraph regarding contributions should also 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 County Council requests that PRoW enhancements are included in the list of expected contributions, to mitigate the impact of future development.

Heritage Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

The site has potential for prehistoric and post medieval remains. A prehistoric trackway may survive at northern end and evidence of ridge and furrow to the south. Site also may contain remnants of designed landscape associated with Colebrooke.

Archaeological and Archaeological Landscape Assessment essential with fieldwork potentially also required.

DLP_6819

Mrs Carol Richards

General Observation

Map 12 Policy AL/RTW 12 - North farm Longfield Road, para 5.28

Point 2 I note this states, ‘The northern part of this site also falls within the parish of Capel’. I mention this as I was under the understanding that a Garden Village has to have some kind of employment capability, either within the settlement or nearby. Is this site one which will be allocated to.provide the employment tick box for the Garden Village? Just an observation- but as this site lies well away from Tudeley and Capel this would and should be invalid if this is TWBC’s intention?.

DLP_7137

Ann Kelly

Object

I am writing to object to the Strategy for Capel Parish (STR/CA1), to the plans for development of Mabledon and Nightingale Farm (AL/SO3) and expansion of business, industry, storage and leisure at Longfield Road/Knights Park (AL/RTW 12, AL/RTW 13, AL/RTW14).

I am a long time resident of the region and borough, having lived in Tonbridge and Southborough as a child, and in High Brooms for the last twenty years, and am very familiar with all of the areas I am commenting on. I have watched with dismay as the Borough has become increasingly built up and congested, and the beautiful and valuable natural landscapes it contains have been pared away at by ill-considered development. The Draft Plan though, takes this to a hideous extreme, and I must raise my voice against it.

All of these developments will cause huge harm to local communities, to the environment, and to the character and beauty of the area. Additionally, all are extremely unfair to the people of Tonbridge, who will reap a large proportion of the downsides and none of the benefits, and so represent an act of extreme bad faith by Tunbridge Wells planners.

I have numerous points of objection but will restrict them to the following:

1. Climate change and ecosystem preservation: We are in a climate and nature emergency - parliament itself have declared this to be the case. We need to plant trees, we need to maintain the ecosystems that help regulate the planet's temperature, rainfall and other natural cycles.

This is not a time to be destroying countryside and natural habitat, as these plans will do. Much of this is good agricultural land - we should be using it to provide our food in a sustainable manner, not capping it off with concrete. It is also clear that areas of ancient woodland will be destroyed by these developments - this is unjustifiable, more now than ever. Once destroyed, ecosystems are almost impossible to restore on a human timescale. Your grandchildren will curse your names if you go ahead with this ecological vandalism.

2. Large parts of the Tudeley/Capel development are on a flood plain. Flooding is more likely than ever due to climate change, and assessments based on old data, such as those used by the Draft Plan, cannot be relied upon. Capping off the land with houses and roads will reduce the land's ability to soak up water and mitigate flooding, making flooding more likely both here and further downstream, e.g. Yalding. Houses that flood are difficult to sell and difficult to insure. Their value reduces, along with the tax they bring in. Looking after flooded out families is expensive. Is this something Tunbridge Wells Borough is keen to store up for itself?

2. Destruction of beauty: The visual and character effects on the area will be appalling - views across the high and low weald will be destroyed, the landscape will be scarred. The Capel development will turn a green and pleasant valley, which can be seen from numerous vantage points across South Tonbridge, Pembury, Southborough and High Brooms, to a grey built enviroment with no such visual appeal. The Mabledon development will destroy another pleasant valley, historically important as part of the South Frith forest, and affect yet more ancient woodland. The Longfield Road development will make the recent eyesore of the new A21/Longfield Road junction, viewable from Castle Hill, Southborough and various other locations, even worse.

3. Transport: The transport infrastructure will not cope with the massive new amounts of housing - traffic will pour into Tonbridge, already ridiculously congested for much of the day, and already packed communter trains will be put under further strain. Existing communities, especially in Capel, Tudeley and in South Tonbridge, will be seriously disadvantaged, and I do not believe these impacts have been considered fully. The Mabledon development will add to already excessive congestion on the A26. See below for comments on Knights Park, which will also have very negative effects on congestion. This will increase air pollution and emissions of greenhouse gasses, creating yet more negative environmental effects.

4. Bad faith: The developments are as close to the boundary between Tunbridge Wells and Tonbridge boroughs as is possible, and as such will have a disproportionately negative effect on Tonbridge. New residents use transport, medical, educational etc facilities nearby to them in Tonbridge rather than further away, so the town will suffer from increased pressure on these facilities while gaining none of the benefits, such as increased council tax receipts etc. This is unfair, unneighbourly and reflects very badly on the Council. Surely borough councillors are motivated by improving conditions for their whole communities? How can it be right that one council should advantage itself by beggaring its neighbour? I would be surprised if Tonbridge and Malling Borough Council have not made their own representations on this matter.

5. With reference to Knights Park/Longfield Road specifically -

a) Tunbridge Wells has a town centre dying on its feet, with a large underused shopping centre in it. Why, then, encourage further flight to out-of-town leisure facilities, with the accompanying emissions and congestion from car use? Encouragement of development of leisure facilies within the town would be far more sensible, and help revive the town centre. Yet by developing elsewhere, demand will be diverted from this far preferable outcome.

b) All of these developments will seriouly exacerbate the congestion that has already started to build up again on the industrial/retail estate, which was briefly alleviated by the road layout improvements finished in 2017. It will no doubt have knock on effects on the generally impassable Pembury Road as people try to find alternative routes. Development that will inevitably bring more cars, lorries and congestion to this area is ill-conceived. A few bus lanes won't cut it here, it's frequently completely gridlocked up to ASDA.

6. Flaws in the assumptions of the Draft Plan: The levels of housing need as stated in the draft plan are higher than required by government policy, and therefore should be reduced. I will quote from information provided by the Save Capel group on this:

"Housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan. TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant."

Additionally, the draft plan as it relates to Tudeley is not fit for purpose due to failure to assess the impacts on the area adequately. I quote again.

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

Tunbridge Wells Borough Council is putting a desire for development before its duty to do the right thing for the communities it serves. I urge a reconsideration of this ill-conceived plan.

Policy AL/RTW 13: Land at Colebrook House, Pembury Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_4109

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

This proposal for major development in the AONB and Green Belt has not been adequately justified under NPPF paragraph 172 (see our response to Policy ED1).

DLP_3828

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 for this area raised concern of the impacts of building heights, and this should be given careful consideration in relation to impacts to the AONB. 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_1824

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Number:  AL/RTW 13 Colebrook House 

If justified by exceptional circumstances, this site, like site AL/RTW 12, appears appropriate for business employment uses. Retaining the site within the Green Belt and AONB is a novel concept which requires further detailed appraisal, as substantial built development is intended. Given its relatively elevated location, careful landscape treatment with conservation of the parkland setting and enhancement of existing woodland cover to provide mitigation would be essential. This would seem to require a strategic landscaping scheme as an integral part of any planning application as is being required under AL/TW 12.

DLP_2900

Chris Gow

Object

I object to all development on Green Belt land.

The trees and shrubs in the Green Belt are essential for the battle against CO2 emission, and provide amenity for residents.

DLP_2901

Chris Gow

Object

I object to all development on Green Belt land.

The trees and shrubs in the Green Belt are essential for the battle against CO2 emission, and provide amenity for residents.

DLP_3417

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_2046

Terry Everest

Object

Strongly Object

This site is within a countryside setting and contains numerous trees and has a natural setting which should be maintained. The site is Green Belt and should therefore be protected from development. The potential value of the intrinsic appeal of trees and hedges in this setting should not be ignored.

DLP_2228

Dr Cameron Davies

Object

This area should be retained as a green belt buffer beween Pembury and TW.

DLP_3132

Teresa Stevens

Support with conditions

How much could the site be developed on to create business etc use (not homes), given that it is full of trees (most/all of which are Ancient Woodland or part of the Local Wildlife Site)? Deers have often been seen in the wooded area. When is the old Fairthorne garage due to be replaced on the opposite side of the A21?

DLP_3113

Andy Bashford

Support with conditions

How much could the site be developed on to create business etc use (not homes), given that it is full of trees (most/all of which are Ancient Woodland or part of the Local Wildlife Site)? Deers have often been seen in the wooded area. When is the old Fairthorne garage due to be replaced on the opposite side of the A21?

DLP_3199

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

Paragraph 2 - “non-motorised route” should amended to read non-motorised user (NMU) route

Additional paragraph - The Transport Assessment should communicate how the development would use sustainable transport principles to minimise additional vehicular trips on the network.

Additional paragraph - The developer will be required to consider the impact of this development on the wider road network, such as the A21 junctions at Pembury, North Farm and Tonbridge.

The standard paragraph regarding contributions should also 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 County Council requests that PRoW enhancements are included in the list of expected contributions, to mitigate the impact of future development

Heritage Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

There is potential for archaeology, historic structures and archaeological landscape features associated with Colebrooke, post medieval residence.

DBA is requested to better inform decisions.

DLP_6777

DHA Planning Ltd for Axiom Developments

Support with conditions

1 Introduction

1.1 Purpose of this report

1.1.1 This representation has been prepared on behalf of Axiom Developments Limited (‘Axiom’) - 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 Colebrooke House, Tunbridge Wells, which Axiom is promoting for commercial development as part of the TWBC Local Plan review.

1.1.3 Based on the current national and local planning context, we consider this site to be suitable for development and agree it should be allocated for development.

1.1.4 This representation therefore responds to the content of the draft plan (and relevant supporting documents); supports the proposed allocation of land at Colebrooke House, reinforcing why the site represents a suitable location to accommodate growth, and outlining how development could be delivered on site; and objects to the proposal to continue to include the land within the Green Belt.

2 Site context

2.1 Site overview

2.1.1 Our client is promoting land at Colebrooke House for a business park within an attractive parkland campus setting. The site was promoted via the original Call for Sites process in 2016 (site 101). The site boundary is shown in Figure 2.1.

[TWBC: for Figure 2.1 see full representation].

2.1.2 The site lies outside of the current settlement boundary for Royal Tunbridge Wells and within both the High Weald Area of Outstanding Natural Beauty (AONB) and the Green Belt.

2.1.3 As a result of the recent A21 dualling project, the site benefits from direct access onto the A21 via the Fairthorne junction. This has opened up the land to excellent access to the national road network, whilst also being well-located in relation to the existing employment areas along Longfield Road. The A21 improvements present an excellent opportunity for the site to make a substantial contribution to the local economy through development of the site.

2.1.4 The 8.5ha site comprises a large 19th century residential property set in parkland grounds. Whilst being habitable, the property is currently in need of repairs following a period of under-investment. Its value as a residential property has been substantially affected as a result of the A21 dualling works.

2.1.5 There is a unique opportunity to provide a high-quality business park set within an established parkland setting and based around the existing 19th century Colebrooke House which would be retained and converted for office use, giving the site a unique identity. Colebrooke House is an opportunity to provide an attractive business location, accessible to the A21 as well as local businesses and services. A Vision Document has been prepared which shows that the site would be capable of delivering around 11,750 sqm of office floorspace, which would be capable of supporting between 885 and 1,437 jobs depending on the intensity of their use. This Vision Document has previously been submitted on an informal basis, but is now formally submitted in support of these representations.

2.1.6 The site could be designed as an attractive standalone campus, suitable for occupation either by a single major occupier or as a premium office campus. It would be attractive to businesses within the financial and insurance industries that Tunbridge Wells specialises in, and could help to attract new businesses and/or retain existing ones looking to move or expand from poorer quality stock, or from buildings which are being converted to residential uses under permitted development rights.

2.1.7 The Council’s Economic Needs Study demonstrates the need for good quality economic development land locally. This was also backed up by responses from stakeholders identifying Tunbridge Wells as a good office and industrial location. ENS paragraph 9.66 in particular identifies demand for offices, and especially higher quality Grade A accommodation in accessible locations, which is the type of development proposed at Colebrooke House. It would score well against all of the bullet points set out in ENS paragraph 10.29, i.e. excellent accessibility; public transport and parking availability; and it being an area with a critical mass of employment use and amenities which would be attractive to investors.

2.1.8 The development would have excellent strategic transport links to the newly upgraded A21 as well as providing opportunities to create and improve existing pedestrian, cycle and public transport links to North Farm, Tunbridge Wells and Tonbridge. Facilities such as a café/clubhouse could be provided on-site to reduce the need for workers to travel during the working day. Pedestrian, cycle and emergency access links could also be provided into the land to the west, which is also proposed for development as part of the Local Plan proposals.

2.1.9 In respect of deliverability, the site has no planning history of relevance nor a history of unimplemented permissions, and there are no known impediments to the sites being phased for potential development within the 0-5 year period. The site is within the control of a single developer and a single owner. Subject to the site’s removal from the Green Belt in the Local Plan, there is an excellent opportunity to deliver a high-quality employment development scheme in the short term.

3 The Tunbridge Wells Draft Local Plan

3.1 Overview

3.1.1 The TWBC Draft Local Plan sets out the spatial vision, strategic objectives, and 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.

3.1.2 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.

3.2 Comments on Policy AL/RTW 13: Land at Colebrooke House, Pembury Road

Stance: Support with Conditions

3.2.1 Axiom supports Policy AL/RTW 13, which is generally in line with its early proposals for the commercial redevelopment of the site. We agree that the Council should be making the most of the opportunities presented by the A21 dualling improvements in terms of making Tunbridge Wells a more attractive business location and, therefore, attracting businesses currently based outside the Borough. This draft policy seeks to achieve this.

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

Site Name

3.2.3 The property is known as Colebrooke House, rather than Colebrook. There does appear to be an element of confusion, with both spellings being used in relation to different properties and addresses in the local area. However, Colebrooke is the correct spelling of the family who owned extensive land in the area in the 19th century, and both the Ordnance Survey and Royal Mail databases refer to the property as Colebrooke House. We therefore believe this to be the correct spelling and request that the property name is amended accordingly.

Quantum of development

3.2.4 We note that the site has been allocated to provide approximately 10,000sqm of B1, B2 and B8 development. As noted in section 2, we have produced a Vision Document which demonstrates that a slightly higher quantum of development – around 11,750 sqm – could be achieved on this site. We request that the draft policy is amended to reflect this.

Type of development

3.2.5 The current draft policy reflects Axiom’s vision for the site, in proposing B1, B2, B8 and ancillary uses and this is supported. However, it is conceivable that the campus nature of the proposed development site could also be attractive to other non B-class forms of employment use – for example, further/higher education. In accordance with the requirement at paragraphs 11(a) and 81(d) for Local Plans to provide flexibility, we request that the policy is worded in such a way as to allow other appropriate employment-generating uses at the site. For example, the introductory paragraph to Policy AL/RTW 13 might be amended to read:

This site, as defined on the Royal Tunbridge Wells draft Policies Map, is allocated for employment uses to provide approximately 11,750sqm of accommodation and ancillary facilities, delivered through conversion of Colebrook House, together with a modern business park in a campus layout that respects the existing parkland setting. Acceptable uses will include business (B1), general industry (B2), storage and distribution (B8), and other employment-generating uses appropriate to this location.

Green Belt Status

Comment on paragraph 5.29

3.2.6 Axiom objects to the proposal to retain the site within the Green Belt, rather than to remove it from the Green Belt as is proposed on the neighbouring allocation under policy AL/RTW 12. The proposed retention of the site within the Green Belt is unacceptable for the following reasons:

Retaining the site within the Green Belt will hinder investment.

3.2.7 The Council has identified the site as being suitable for development to help meet the Borough’s qualitative and quantitative economic development needs. As discussed further below, it is important that the market has a choice of economic development sites. Colebrooke House provides a different offer to that available on the neighbouring AL/RTW 12 allocation, in that it can provide a high-quality office park based on an existing property whilst retaining and improving an existing parkland setting.

3.2.8 However, by retaining the site within the Green Belt, the Council is making it necessary for any applicant to demonstrate very special circumstances for development in the grounds of Colebrooke House. This leads to uncertainty as to whether or not the allocation can be relied upon, which will deter investment and lead to uncertainty about its delivery. This is not a sound approach for the Local Plan to take.

3.2.9 Developers and potential occupiers will be concerned about the additional planning hurdles and the uncertainty created by having to make a very special circumstances case for development. Businesses do not like uncertainty. They are likely instead to prefer to pursue alternative sites without a Green Belt restriction, whether in Tunbridge Wells Borough, or indeed elsewhere.

This site only makes a very limited contribution to the purposes of the Green Belt

3.2.10 The site falls within parcel TW4 as considered in the Council’s Green Belt Study. This is the same parcel as the neighbouring allocation AL/RTW 12 which, unlike Colebrooke House, is proposed to be removed from the Green Belt.

3.2.11 As expanded upon in further detail in section 3.4 below, we consider that the site makes a lower contribution to the purposes of the Green Belt than suggested in the Green Belt Study. In any event, the site is in the same parcel and so scores the same as the neighbouring allocation AL/RTW 12 in this respect.

Removing the site from the Green Belt would provide a stronger and more defensible Green Belt boundary.

3.2.12 As noted in further detail in section 3.4 below, we agree with the conclusion in the Green Belt Study that the A21 would make a stronger Green Belt boundary. In contrast, the Council’s proposed Green Belt boundary does not follow any strong physical features.

3.2.13 NPPF paragraph 139(f) states that Local Plans should define Green Belt boundaries clearly, “using physical features that are readily recognisable and likely to be permanent”.

3.2.14 For these reasons, we have proposed an alternative Green Belt boundary as described in paragraph 3.5.5 and shown in Figure 3.5.

The Distribution of Development Topic Paper analysis does not provide any justification for retaining the site within the Green Belt.

3.2.15 The justification for removing AL/RTW 12 from the Green Belt, as set out on page 38 of the Distribution of Development Topic Paper, would apply equally to the Colebrooke House site.

3.2.16 Sites AL/RTW 12 and AL/RTW 13 are then considered in more specific detail in the table on p20 which purports to provide the rationale for deciding whether sites are retained in or removed from the Green Belt. The rationale specified in both cases is identical:

“Provides employment in sustainable location; A21 provides strong MGB boundary; Well Wood to north marks Green Belt edge on adjacent development.”

3.2.17 Yet AL/RTW 12 is partly removed from the Green Belt whilst AL/RTW 13 is retained within it. There is no justification whatsoever provided in the Topic Paper to justify the different stances being taken in each case, especially when doing so will hinder investment and development at Colebrooke House.

There is a clear need to release sites for economic development, and this is an appropriate site.

3.2.18 As noted above, the Green Belt designation will hinder the development of this site. Yet it is clear that there is a compelling need for employment development in Tunbridge Wells.

3.2.19 The Council’s Economic Needs Study recognises that the A21 dualling as well as other recent highway infrastructure improvements in the North Farm area could further unlock potential future allocations for employment growth. We strongly support this view and urge the Council to get best value from these infrastructure improvements by allowing well-designed development in what is a clearly attractive and accessible location for businesses, such as at Colebrooke House. Whilst the ENS summary at 6.94 refers to the infrastructure improvements being a catalyst for further investment, this will only happen if the right sites are allocated. If sites aren’t attractive to businesses, or are too slow to deliver, businesses will simply go elsewhere to the detriment of the local economy.

3.2.20 We attended the Tunbridge Wells Stakeholder Workshop referred to in the ENS and agree that the key findings included the lack of supply of land and premises acting as a disincentive to potential investors and constraining the growth of existing businesses (a point that we note has also been raised separately by Locate in Kent). The workshop identified the need to address local transport and congestion issues especially around North Farm (where significant improvements have been made) and workshop attendees identified the potential of the North Farm/A21 corridor for economic growth. The allocation for development at Colebrooke House is fully in line with the findings of the ENS and the Stakeholder Workshop. Furthermore, North Farm is already recognised as a well-established employment location. Allocating further development nearby increases the potential for business-to-business services further enhancing the local economy.

3.2.21 However, the continued inclusion of Colebrooke House within the Green Belt represents an unnecessary hurdle which will hinder investment.

The Council’s Economic Development Strategy and Economic Needs Study support these conclusions.

3.2.22 The Council’s Economic Development Strategy 2018-2021 concludes, amongst other things, that:

(1) A shortage of sites and premises is a major constraint for local businesses and is also a barrier to inward investment from outside the Borough;

(2) The shortage has been exacerbated due to the conversion of floorspace from office to residential under Permitted Development legislation, particularly in Royal Tunbridge Wells town centre;

(3) The Council’s Economic Needs Study recommends, amongst others, employment sites in areas close to main arterial roads (e.g. the A21) where accessibility to the highway network for business operations is quick;

(4) Current weaknesses in Tunbridge Wells include traffic congestion in urban areas, a shortage of sites, and ageing office stock;

(5) Current threats include limited opportunity for additional road capacity; out commuting, especially of the highly skilled; and pressure for residential development over employment uses; and

(6) Opportunities for Tunbridge Wells include the new Local Plan process, as this can provide new employment allocations, therefore improving the amount of land available for economic development and ensuring that such land is located where it is attractive to the market.

The Council’s Office Market Review also recognises serious issues with office provision in Tunbridge Wells town centre and recommends considering provision in the A21 corridor (and the Council’s decision not to proceed with the Calverley Square civic centre project has compounded the problems).

3.2.23 The Council’s Office Market Review, which is part of the evidence base to this Local Plan, notes on p.28 that:

(1) There is limited supply of office space on the A21 corridor;

(2) The majority of available space locally is in Maidstone and Kings Hill (Tonbridge & Malling) with the latter offering modern, well-specified space with excellent parking provision in a business park location;

(3) “There is a significant danger that if there is no suitable available office space in the [Tunbridge Wells town centre] Study Area, particularly for larger employers, and where MEES requirements are an issue [2 The MEES (Minimum Energy Performance Standards) Regulations have made it unlawful since April

2018 to let buildings which do not achieve minimum Energy Performance Certificate standards. Whilst this applies initially to new lettings and renewals only, from April 2023 it will apply to all existing leases.], then relocation out of Royal Tunbridge Wells will be a necessity unless sites outside the Study Area, for example on North Farm’s industrial estate, are considered.”

3.2.24 The study’s conclusions on p.33 include:

(1) The current town centre office market comprises mainly old stock, which is unlikely to become available and/or does not meet modern standards;

(2) A substantial amount of office space has been lost as a result of the office to residential permitted development rights: 22% of May 2013 office stock had already been lost at the time of publication (Feb 2018) and a permission is in place for a further 22% to be lost;

(3) Less than 8,000 sq ft of office space is available, with much of that being old, limited and/or lacking parking;

(4) The only potential opportunities to replace lost office space are the new civic centre development [which in October 2019 the Council voted not to proceed further with]; redevelopment of the Town Hall [which was dependent on the civic centre project] and new development in the Vale Avenue Area of Change [which has seen some refurbishment and extension, but also a loss of existing buildings to hotel and residential use, further compounding the problem]; and

(5) The North Farm / A21 corridor area should be considered for new office development.

3.2.25 Colebrooke House is of course in the A21 corridor and has rightly been recognised in the draft Local Plan as being appropriate for economic development. It should be noted there are no significant opportunities for office development in this location on sites which are outside the Green Belt, since this currently washes over all undeveloped land in this area. It now needs to be removed from the Green Belt to allow the appropriate re-development of the site in accordance with draft Local Plan policies.

There is a need for a choice of economic development sites to be provided.

3.2.26 NPPF paragraph 80 emphasises the need for planning policies to create conditions to allow businesses to invest, expand and adapt. This approach “should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future”.

3.2.27 Paragraph 81 then requires planning policies to set out a strategy “which positively and proactively encourages sustainable economic growth”, having regard to local economic development strategies.

3.2.28 New commercial development must meet the needs of the market by providing development opportunities in the right places to meet current and future demand. This should include the provision of commercial development around appropriate strategic road network junctions, amongst other locations.

3.2.29 If Tunbridge Wells is to reach its full economic potential, new business land and locations are required in order to meet currently unmet needs, allow existing businesses to relocate to expand, and to attract new businesses to the Borough.

3.2.30 It is currently proposed to meet the economic development needs of those businesses seeking a location near the strategic road network on a single site in Tunbridge Wells – the adjacent proposed AL/RTW 12 allocation. Whilst we agree that is a logical and appropriate site to develop for commercial floorspace, it would be unwise to rely on a single site coming forward to meet the identified need, for the following reasons:

(1) If, for whatever reason, that site doesn’t come forward in the manner envisaged, or indeed at all, there will be no other sites on which that specific need can be met;

(2) The Economic Needs Study and Office Market Review have identified that there is a need for employment floorspace close to the A21, a conclusion with which Axiom fully agree;

(3) Assuming that AL/RTW 12 is allocated, having more than one development site option in this area provides competition for the market, which assists affordability and therefore delivery. It also stops the Council’s economic strategy being frustrated by a lack of choice;

(4) NPPF paragraph 82 recognises the need for a variety of sites to be provided, noting that provision should be made to address the requirements of different sectors, including making provision “at a variety of scales and in suitably accessible locations.”; and

(5) A greater variety of allocated sites allows a greater range of employment buildings, sizes and types to be offered in a wider variety of locations. This makes it more likely that interested companies will find the space that they want within Tunbridge Wells Borough, assisting growth and boosting the local economy. As noted previously, the character of the Colebrooke House site is very different to that of the neighbouring AL/RTW 12 site, enabling a very different type of office campus to be provided. Local plans are very good at providing a wide range of housing sites and locations, providing choice in the market. By contrast, the number of options available to companies looking to expand or relocate is much smaller. This needs to be rectified.

3.2.31 To ensure the benefits of economic growth benefit everyone, new commercial provision should be well placed to serve a skilled workforce and to meet the needs of businesses. Whilst it is appropriate for some employment development to be provided in the most accessible locations such as town centres, new provision should also be made close to the strategic road network to meet the needs of businesses, discourage out commuting, reduce congestion on routes into the town centre and offer new opportunities for local people to live and work in the Borough.

3.2.32 Whilst it is recognised that there are other economic development proposals elsewhere in the Borough, including at Paddock Wood and Gills Green, these are locations which are likely to be less attractive to the office market and are less well related to the strategic road network.

3.2.33 Paragraph 11 of the Executive Summary to the ENS identifies an Objectively Assessed Need for at least 14ha of employment land and this target is referred to throughout the Local Plan and in the Distribution of Development Topic Paper. However, the ENS goes on to recommend identifying a greater quantum of land in recognition of market interest and to provide a sufficient choice of sites for prospective occupiers and investors. ENS paragraph 8.88 recommends that 20ha of new employment land should be allocated. This supports our view that a proper choice of sites must be provided. This should include Colebrooke House, as the Local Plan recognises, which means it should also be removed from the Green Belt.

Release of the site from the Green Belt is required to enable the strategy in policy STR/RTW 1 to be delivered

3.2.34 This policy, amongst other things, requires 90,000 sqm of employment floorspace to be delivered, including at Colebrooke House. The site therefore needs to be released from the Green Belt to ensure that such development is not hindered. For the reasons set out above, safeguarding the site’s Green Belt status will mean that development will not be attracted to the site, and the Council’s economic development strategy will not be fully realised, making this element of the plan unsound.

Development at Colebrooke House would make best use of a partly brownfield site and so should be prioritised over purely greenfield sites.

3.2.35 NPPF paragraph 84 notes that “the use of previously developed land, and sites that are physically well related to existing settlements, should be encouraged where suitable opportunities exist.”

3.2.36 Colebrooke House is, in part, previously developed land.

3.2.37 This provides a clear and compelling reason to remove Colebrooke House from the Green Belt and prioritise its delivery for economic development over purely greenfield locations.

3.2.38 As currently drafted, the Local Plan effectively prioritises delivery of development on the open greenfield adjacent site AL/RTW 12 over Colebrooke House since RTW 12 is to be removed from the Green Belt and Colebrooke House is not. We note that there is no analysis in the Local Plan to show why RTW 12 has been prioritised over Colebrooke House in this way.

3.2.39 If there is going to be a policy difference between the two sites (and we would argue that a differing approach is unnecessary), the Plan should instead prioritise the part-brownfield, well-screened Colebrooke House site over development of the whole of the greenfield, open site at RTW 12. As demonstrated elsewhere in these representations, and as illustrated in Figure 3.1 and Figure 3.2 below, the neighbouring site RTW 12 is a large one which is much more visible from the surrounding highway and footpath network. It also relies upon highways access onto the more congested Longfield Road, whereas Colebrooke House enjoys what is in effect almost a private, direct access onto the A21.

[TWBC: for figures 3.1, 3.2, and 3.3, see full representation].

3.2.40 As Figure 3.2 and Figure 3.3 make clear, the site is surrounded by well-established and mature trees which means there is no visibility into the site. Indeed, despite being adjacent to the busy A21, people passing the site would not even know that the existing house was there. The submitted Landscape Study (p38) confirms that if three storey buildings were developed on the site, these would not be visible from beyond the site boundaries.

3.2.41 This is a further reason why, if Green Belt and AONB land is to be released for development, priority should be given to well-located sites with the least harmful effects. Developing a site which is (and will continue to be) so well screened allows best use to be made of a prime employment location without unnecessary harm to the local landscape.

3.2.42 Unlike the adjacent AL/RTW 12 site, there are no public rights of way crossing the Colebrooke House site, and so there is no risk of walkers’ views being affected by development on this site.

Release of this site from the Green Belt is compatible with NPPF paragraph 138

3.2.43 NPPF paragraph 138 notes that where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously developed and/or is well-served by public transport. This provides another clear reason to prioritise development at Colebrooke House over wholly greenfield sites.

3.2.44 As noted above, the Colebrooke House site is, in part, previously developed. Longfield Road is already served by public transport. It would be possible to further enhance this, either through improved bus provision e.g. extending the existing bus routes, and/or by introducing innovative new services which meet the needs of office parks.

3.2.45 An example of the latter is the PickMeUp shuttle bus service which operates at the Oxford Science Park [3 https://pickmeup.oxfordbus.co.uk/]. This is an app-based on-demand ride-sharing minibus service which provides direct public transport access between any two points within a defined service area covering much of eastern and southern Oxford. The service has proved successful since being launched in 2018 and has since been expanded to cover a greater area.

Vehicular Access

3.2.46 As set out in the Vision Document, the historic main driveway has been reinstated as a result of the A21 works and provides an attractive and direct link to the new A21 Fairthorne junction, as required in the draft policy. Further improvements will be made to this access to accommodate the development.

3.2.47 This is another reason why development should be prioritised at Colebrooke House, as it enjoys its own direct access onto the little-used new Fairthorne junction on the A21. This ensures that, in contrast to site RTW 12, no new vehicular access is required onto the busy Longfield Road, minimising congestion. The Colebrooke House driveway also provides direct access to the new Non-Motorised Route between Pembury, Longfield Road and Tonbridge which was constructed as part of the A21 works to enhance pedestrian and cycle links locally.

Pedestrian and Cycle Access

3.2.48 We confirm that the development will include good pedestrian and cycle links. We note that draft policy AL/RTW13 criterion 2 should refer to Policy RTW 12, not 13, when discussing links to the neighbouring site.

Heritage

3.2.49 Axiom’s proposals for the site include the retention of Colebrooke House as suggested in the draft policy.

3.2.50 A Heritage Assessment has already been carried out and has been provided to the Council on an informal basis. We are also formally submitting this with these representations. This assesses the draft proposals set out in the Vision Document and concludes that:

* The proposed alterations to the main house will not alter the character or significance of this non-designated heritage asset;

* The proposed office campus has been designed to minimise impacts on the landscape and retained 19th century house;

* The scheme protects the historic character of Colebrooke House, enlarging or reinstating lost grounds to the south of the house and reinforcing the essence of the original park environment; and

* The new planned landscape, perhaps echoing its historic predecessor in the creation of woodland and clearings linked by a network of paths, could provide opportunities for those working within the campus to enjoy the landscape, the retained elements of the park, thus benefiting from an integration of that historic landscape into the proposed working environment.

Landscape

3.2.51 A Landscape and Visual Appraisal has been carried out and provided to the Council on an informal basis. We are also formally submitting this with these representations. This assesses the draft proposals set out in the Vision Document and concludes that:

* The area of and immediately around the site is completely enclosed by woodland blocks in the wider landscape and also by the trees within the site. Its location on a west-facing slope, with the A21 immediately to its east, means that it is visually associated with the urban edge of Tunbridge Wells to the west and does not appear as part of the wider countryside to the east;

* The area around the site has been significantly affected by the A21 improvement works, and is also affected by the visible edge of Tunbridge Wells to the west, with its large-scale commercial buildings;

* Assuming that the development would comprise well designed office buildings of no more than three stories in height, and that the mature parkland trees would be retained, the site has been assessed as of low to medium sensitivity to development of the type proposed;

* TWBC have conducted studies of landscape sensitivity and contribution to the purposes of including land within the Green Belt of the land around the town, in order to identify areas which may potentially be suitable for development and release from the Green Belt. Those studies have found that the site and the area to its west are of relatively low sensitivity and importance to Green Belt purposes in comparison with the other areas considered, and concluded that the area including the site ‘relates more strongly to the settlement than to the wider countryside’;

* Access for the development would be from the new A21 Fairthorne junction to the north, utilising the existing tree-lined drive into the site. All significant perimeter vegetation would be retained and protected during construction, as would the mature parkland trees. The proposed office buildings would be no more than three storeys in height and would therefore be lower than the trees within and around the site;

* While the area of the site itself would change significantly, from being an area of open parkland relating to the house to its north, to a high quality office campus in parkland setting, the degree of change to the local landscape around the site brought about by the proposed development would be negligible;

* The anticipated overall effects on the local landscape would be slight adverse at their greatest, in the winter soon after completion. Effects in the summer and over time as the proposed planting matures would be insignificant, as the proposals generally fit the landform and scale of the landscape, would have limited effects on views, can be mitigated to a reasonable extent and would avoid significant effects on designated landscapes. Effects after around 10 years would be expected to be neutral;

* That part of the AONB laying within the site would be affected by the development, and there would be a significant change to the landscape of the site. However, while there would be some inevitable landscape effects within the site itself, there would be no significant effects on the wider landscape of the AONB or upon the character of the AONB. The proposals would involve medium scale development within the AONB, but any harm in that respect would be offset by the enclosed nature of the site and by the proposed high-quality design and retention of perimeter woodland and parkland trees; and

* There would be some generally low level harm in terms of the purposes of including land within the Green Belt, but the TWBC study has shown that harm would be at a lower level in the case of the area including the site than for most other parcels of land around Tunbridge Wells.

Safeguarded Waste Management Facilities

3.2.52 We do not understand the purpose of criterion 9, which requires any application to demonstrate that there will be no material adverse impact on the operation of safeguarded waste management facilities. We are not aware of any safeguarded waste management facilities on or adjacent to the site and assume that this has been added in error. Criterion 9 should therefore be deleted.

3.3 Comments on Proposals Map

3.3.1 As set out in section 3.4 below, we request that the Green Belt boundary is amended to include site AL/RTW 13 for the reasons set out in these representations.

3.3.2 It is noted that the proposed Limits to Built Development have, correctly and sensibly, been drawn to include the proposed Colebrooke House allocation. We support this amendment, though we have also suggested further amendments as set out in section 3.4 below. It would make much more sense for the Limits to Built Development and Green Belt boundaries to be consistent here.

[TWBC: see also Comment Nos. DLP_6777-6779 and full representation and supporting documents attached.

  1. Colebrooke Park   Design Overview
  2. Colebrooke Park   Ecology Report
  3. Colebrooke Park   Heritage Report
  4. Colebrooke Park   Landscape and Visual Appraisal

See also Comment No. SA_118 on the Sustainability Appraisal].

DLP_7138

Ann Kelly

Object

I am writing to object to the Strategy for Capel Parish (STR/CA1), to the plans for development of Mabledon and Nightingale Farm (AL/SO3) and expansion of business, industry, storage and leisure at Longfield Road/Knights Park (AL/RTW 12, AL/RTW 13, AL/RTW14).

I am a long time resident of the region and borough, having lived in Tonbridge and Southborough as a child, and in High Brooms for the last twenty years, and am very familiar with all of the areas I am commenting on. I have watched with dismay as the Borough has become increasingly built up and congested, and the beautiful and valuable natural landscapes it contains have been pared away at by ill-considered development. The Draft Plan though, takes this to a hideous extreme, and I must raise my voice against it.

All of these developments will cause huge harm to local communities, to the environment, and to the character and beauty of the area. Additionally, all are extremely unfair to the people of Tonbridge, who will reap a large proportion of the downsides and none of the benefits, and so represent an act of extreme bad faith by Tunbridge Wells planners.

I have numerous points of objection but will restrict them to the following:

1. Climate change and ecosystem preservation: We are in a climate and nature emergency - parliament itself have declared this to be the case. We need to plant trees, we need to maintain the ecosystems that help regulate the planet's temperature, rainfall and other natural cycles.

This is not a time to be destroying countryside and natural habitat, as these plans will do. Much of this is good agricultural land - we should be using it to provide our food in a sustainable manner, not capping it off with concrete. It is also clear that areas of ancient woodland will be destroyed by these developments - this is unjustifiable, more now than ever. Once destroyed, ecosystems are almost impossible to restore on a human timescale. Your grandchildren will curse your names if you go ahead with this ecological vandalism.

2. Large parts of the Tudeley/Capel development are on a flood plain. Flooding is more likely than ever due to climate change, and assessments based on old data, such as those used by the Draft Plan, cannot be relied upon. Capping off the land with houses and roads will reduce the land's ability to soak up water and mitigate flooding, making flooding more likely both here and further downstream, e.g. Yalding. Houses that flood are difficult to sell and difficult to insure. Their value reduces, along with the tax they bring in. Looking after flooded out families is expensive. Is this something Tunbridge Wells Borough is keen to store up for itself?

2. Destruction of beauty: The visual and character effects on the area will be appalling - views across the high and low weald will be destroyed, the landscape will be scarred. The Capel development will turn a green and pleasant valley, which can be seen from numerous vantage points across South Tonbridge, Pembury, Southborough and High Brooms, to a grey built enviroment with no such visual appeal. The Mabledon development will destroy another pleasant valley, historically important as part of the South Frith forest, and affect yet more ancient woodland. The Longfield Road development will make the recent eyesore of the new A21/Longfield Road junction, viewable from Castle Hill, Southborough and various other locations, even worse.

3. Transport: The transport infrastructure will not cope with the massive new amounts of housing - traffic will pour into Tonbridge, already ridiculously congested for much of the day, and already packed communter trains will be put under further strain. Existing communities, especially in Capel, Tudeley and in South Tonbridge, will be seriously disadvantaged, and I do not believe these impacts have been considered fully. The Mabledon development will add to already excessive congestion on the A26. See below for comments on Knights Park, which will also have very negative effects on congestion. This will increase air pollution and emissions of greenhouse gasses, creating yet more negative environmental effects.

4. Bad faith: The developments are as close to the boundary between Tunbridge Wells and Tonbridge boroughs as is possible, and as such will have a disproportionately negative effect on Tonbridge. New residents use transport, medical, educational etc facilities nearby to them in Tonbridge rather than further away, so the town will suffer from increased pressure on these facilities while gaining none of the benefits, such as increased council tax receipts etc. This is unfair, unneighbourly and reflects very badly on the Council. Surely borough councillors are motivated by improving conditions for their whole communities? How can it be right that one council should advantage itself by beggaring its neighbour? I would be surprised if Tonbridge and Malling Borough Council have not made their own representations on this matter.

5. With reference to Knights Park/Longfield Road specifically -

a) Tunbridge Wells has a town centre dying on its feet, with a large underused shopping centre in it. Why, then, encourage further flight to out-of-town leisure facilities, with the accompanying emissions and congestion from car use? Encouragement of development of leisure facilies within the town would be far more sensible, and help revive the town centre. Yet by developing elsewhere, demand will be diverted from this far preferable outcome.

b) All of these developments will seriouly exacerbate the congestion that has already started to build up again on the industrial/retail estate, which was briefly alleviated by the road layout improvements finished in 2017. It will no doubt have knock on effects on the generally impassable Pembury Road as people try to find alternative routes. Development that will inevitably bring more cars, lorries and congestion to this area is ill-conceived. A few bus lanes won't cut it here, it's frequently completely gridlocked up to ASDA.

6. Flaws in the assumptions of the Draft Plan: The levels of housing need as stated in the draft plan are higher than required by government policy, and therefore should be reduced. I will quote from information provided by the Save Capel group on this:

"Housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan. TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant."

Additionally, the draft plan as it relates to Tudeley is not fit for purpose due to failure to assess the impacts on the area adequately. I quote again.

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

Tunbridge Wells Borough Council is putting a desire for development before its duty to do the right thing for the communities it serves. I urge a reconsideration of this ill-conceived plan.

Policy AL/RTW 14: Land at the former North Farm landfill site (SHELAA reference: Site 72), North Farm Lane and land at North Farm Lane, North Farm Industrial Estate

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1813

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Numbers:  AL/RTW 7,8,9,10,14,15,19, 24, 26,28,29,31,32

The above sites seem suitable for allocation subject to the proposed conditions written into the policies.

DLP_1670

TWBC Property and Estates

TWBC

Support

AL/RTW14

These are two separate sites from the call for sites.

a. Bullet 4. It should be noted that reference to the Biodiversity Opportunity Area is misleading as it should not apply to the whole of this allocation. Site 261 is a separate site and has not been included on the Kent Landscape Information Survey (KLIS) as an area of Habitat Opportunity.

b. Whilst the Sports & Leisure, Sui Generis uses for the whole allocated site is acceptable, the Policy or RJ should also make additional reference to the fact that part of the site (ie Site 261) is also within the key employment area, Policy ED1. This would therefore allow uses such as - B1 (Business), B2 (General Industrial), B8 (Storage and Distribution) etc.

DLP_2229

Dr Cameron Davies

Support

Support

DLP_3114
DLP_3133

Andy Bashford
Teresa Stevens

Support

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

Using it for Sports/Leisure activities and/or renewable energy provision is OK.

DLP_3201

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:

Additional paragraph - The Transport Assessment should communicate how the development would use sustainable transport principles to minimise additional vehicular trips on the network.

Additional paragraph - The developer will be required to consider the impact of this development on the wider road network, such as the A21 junctions at Pembury, North Farm and Tonbridge.

The standard paragraph regarding contributions should also 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 County Council requests that PRoW enhancements are included in the list of expected contributions, to mitigate the impact of future development.

Heritage Conservation

Scale 5 - No known archaeological potential on the site or part of it.

DLP_7139

Ann Kelly

Object

I am writing to object to the Strategy for Capel Parish (STR/CA1), to the plans for development of Mabledon and Nightingale Farm (AL/SO3) and expansion of business, industry, storage and leisure at Longfield Road/Knights Park (AL/RTW 12, AL/RTW 13, AL/RTW14).

I am a long time resident of the region and borough, having lived in Tonbridge and Southborough as a child, and in High Brooms for the last twenty years, and am very familiar with all of the areas I am commenting on. I have watched with dismay as the Borough has become increasingly built up and congested, and the beautiful and valuable natural landscapes it contains have been pared away at by ill-considered development. The Draft Plan though, takes this to a hideous extreme, and I must raise my voice against it.

All of these developments will cause huge harm to local communities, to the environment, and to the character and beauty of the area. Additionally, all are extremely unfair to the people of Tonbridge, who will reap a large proportion of the downsides and none of the benefits, and so represent an act of extreme bad faith by Tunbridge Wells planners.

I have numerous points of objection but will restrict them to the following:

1. Climate change and ecosystem preservation: We are in a climate and nature emergency - parliament itself have declared this to be the case. We need to plant trees, we need to maintain the ecosystems that help regulate the planet's temperature, rainfall and other natural cycles.

This is not a time to be destroying countryside and natural habitat, as these plans will do. Much of this is good agricultural land - we should be using it to provide our food in a sustainable manner, not capping it off with concrete. It is also clear that areas of ancient woodland will be destroyed by these developments - this is unjustifiable, more now than ever. Once destroyed, ecosystems are almost impossible to restore on a human timescale. Your grandchildren will curse your names if you go ahead with this ecological vandalism.

2. Large parts of the Tudeley/Capel development are on a flood plain. Flooding is more likely than ever due to climate change, and assessments based on old data, such as those used by the Draft Plan, cannot be relied upon. Capping off the land with houses and roads will reduce the land's ability to soak up water and mitigate flooding, making flooding more likely both here and further downstream, e.g. Yalding. Houses that flood are difficult to sell and difficult to insure. Their value reduces, along with the tax they bring in. Looking after flooded out families is expensive. Is this something Tunbridge Wells Borough is keen to store up for itself?

2. Destruction of beauty: The visual and character effects on the area will be appalling - views across the high and low weald will be destroyed, the landscape will be scarred. The Capel development will turn a green and pleasant valley, which can be seen from numerous vantage points across South Tonbridge, Pembury, Southborough and High Brooms, to a grey built enviroment with no such visual appeal. The Mabledon development will destroy another pleasant valley, historically important as part of the South Frith forest, and affect yet more ancient woodland. The Longfield Road development will make the recent eyesore of the new A21/Longfield Road junction, viewable from Castle Hill, Southborough and various other locations, even worse.

3. Transport: The transport infrastructure will not cope with the massive new amounts of housing - traffic will pour into Tonbridge, already ridiculously congested for much of the day, and already packed communter trains will be put under further strain. Existing communities, especially in Capel, Tudeley and in South Tonbridge, will be seriously disadvantaged, and I do not believe these impacts have been considered fully. The Mabledon development will add to already excessive congestion on the A26. See below for comments on Knights Park, which will also have very negative effects on congestion. This will increase air pollution and emissions of greenhouse gasses, creating yet more negative environmental effects.

4. Bad faith: The developments are as close to the boundary between Tunbridge Wells and Tonbridge boroughs as is possible, and as such will have a disproportionately negative effect on Tonbridge. New residents use transport, medical, educational etc facilities nearby to them in Tonbridge rather than further away, so the town will suffer from increased pressure on these facilities while gaining none of the benefits, such as increased council tax receipts etc. This is unfair, unneighbourly and reflects very badly on the Council. Surely borough councillors are motivated by improving conditions for their whole communities? How can it be right that one council should advantage itself by beggaring its neighbour? I would be surprised if Tonbridge and Malling Borough Council have not made their own representations on this matter.

5. With reference to Knights Park/Longfield Road specifically -

a) Tunbridge Wells has a town centre dying on its feet, with a large underused shopping centre in it. Why, then, encourage further flight to out-of-town leisure facilities, with the accompanying emissions and congestion from car use? Encouragement of development of leisure facilies within the town would be far more sensible, and help revive the town centre. Yet by developing elsewhere, demand will be diverted from this far preferable outcome.

b) All of these developments will seriouly exacerbate the congestion that has already started to build up again on the industrial/retail estate, which was briefly alleviated by the road layout improvements finished in 2017. It will no doubt have knock on effects on the generally impassable Pembury Road as people try to find alternative routes. Development that will inevitably bring more cars, lorries and congestion to this area is ill-conceived. A few bus lanes won't cut it here, it's frequently completely gridlocked up to ASDA.

6. Flaws in the assumptions of the Draft Plan: The levels of housing need as stated in the draft plan are higher than required by government policy, and therefore should be reduced. I will quote from information provided by the Save Capel group on this:

"Housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan. TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant."

Additionally, the draft plan as it relates to Tudeley is not fit for purpose due to failure to assess the impacts on the area adequately. I quote again.

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

Tunbridge Wells Borough Council is putting a desire for development before its duty to do the right thing for the communities it serves. I urge a reconsideration of this ill-conceived plan.

Policy AL/RTW 15: Land at Knights Park

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1814

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Numbers:  AL/RTW 7,8,9,10,14,15,19, 24, 26,28,29,31,32

The above sites seem suitable for allocation subject to the proposed conditions written into the policies.

DLP_4299

White Young Green Planning for Standard Life Investments UK Real Estate Fund

Support with conditions

Standard Life Investments UK Real Estate Fund support the proposed allocation of land at Knights Park (under Policy AL/RTW 15) for “…compatible leisure uses that would deliver an intensification of the leisure offer currently provided within the site.”

To be deemed ‘effective’ and therefore ‘sound’, it is recommended that the reasoned justification supporting this policy should provide a definition of ‘leisure’ for the purposes of this policy. It is advised that this definition should remain consistent with the Leisure Activities identified in the Council’s evidence base – Tunbridge Wells Retail and Leisure Study (Nexus, April 2017) (See Figure 8.1) which confirms ‘Leisure’ includes:

  • Indoor Sports & Health Facilities;
  • Cinema;
  • Restaurant;
  • Pubs and Bars;
  • Ten Pin Bowling;
  • Bingo;
  • Theatre / Concert Hall;
  • Museum / Art Galleries; and
  • Outdoor Sports.

It is considered enhancing and broadening the leisure provision at Knights Park will positively improve the health and social well-being amongst residents in the surrounding area (including Knights Wood) and serve local needs within north east Tunbridge Wells.

DLP_4300

White Young Green Planning for Standard Life Investments UK Real Estate Fund

Object

Map 15 – Policy AL/RTW 15 Knights Park - Open Space & Landscape Buffer

Standard Life Investments UK Real Estate Fund strongly object to the proposed ‘Open Space & Landscape Buffer’ identified on the Knights Park allocation (Policy AL/RTW 15), which is considered illogical and unnecessary for the following reasons:

  1. The ‘Open Space & Landscape Buffer’ proposed along the eastern extent of the Knights Park site has been drawn over the existing operational service yards, car park and the roofs of existing buildings located within the Park. It is therefore illogical to define this area as an ‘Open Space & Landscape Buffer’. Furthermore, it is unclear what landscaping this area (although physically impractical) would safeguard against (discussed in further detail at Point 2, below).
  2. It is noted that Robingate Wood (comprising 28.96 ha) abuts Knights Park along its eastern boundary. The wood is already currently actively managed by Dandara (see Woodland Management Plan, Thomson Ecology, Oct 2013) in order to compensate for the loss of habitat relating to the adjacent Knights Wood residential development. As part of this, the area immediately adjoining the site is subject to ‘selective thinning’ to improve light levels to other trees, understorey and encourage growth of native shrub and wildflower species. The desire to protect Robingate Wood Ancient Woodland from adverse impacts of built development is acknowledged, however it is not considered that designating this eastern strip as an ‘Open Space & Landscape Buffer’ would in any way achieve this, given its already developed state. The safeguarding of ancient woodland from impacts associated with new development is more adequately and appropriately dealt with by virtue of Policy EN 15, assessed on a case-by-case basis, rather than proposing arbitrary buffer zones which serve no purpose.

In view of the above, the proposed ‘Open Space & Landscape Buffer’ is considered to be neither ‘justified’ nor ‘effective’ and therefore remains ‘unsound’. The buffer should be removed along the eastern extent of the Policy AL/RTW 15 designation (see Attachment 1), leaving the southern and western landscape buffer to screen between the Park and the neighbouring residential homes within Knights Wood.

DLP_4302

White Young Green Planning for Standard Life Investments UK Real Estate Fund

Object

Standard Life Investments UK Real Estate Fund object to the wording of the later part of Policy AL/RTW 15 which states; “It is expected that contributions will be required towards the following if necessary, to mitigate the impact of the development:…” and continues to list a number of potential contributions. It is considered wording of the policy is entirely unnecessary and pre-judges the impact of all future development at Knights Park, rather than allowing planning contributions to be dealt with on a case-by-case basis.

Regulation 122 of the CIL Regulations indicate that planning obligations may only constitute a reason for granting planning permission if they meet the tests:

  • Necessary to make the development acceptable in planning terms;
  • Directly related to the development; and
  • Fairly and reasonably related in scale and kind to the development.

It is considered only appropriate to list out specific planning obligations required if that particular allocation would undoubtedly otherwise be precluded without the provision being made (for example: a new highway junction necessary to allow access to a residential allocation, which would otherwise not be feasible). The current wording simply provides a ‘wish-list’ of “expected” contributions. For example, to “expect”…“if necessary”…”potential” transport mitigation (item b) is so vague as to be entirely inappropriate policy wording. Likewise, “ d. the provision of buildings and spaces to provide cultural infrastructure”, is equally vague and provides no apparent way of assessing the types of development or level of ‘impact’ which would trigger such a requirement as being necessary. This approach would clearly not meet with the relevant Regulation 122 tests.

To pre-empt contributions for each allocated site is considered to be unwarranted and leaves the Plan vulnerable to becoming promptly outdated.

In view of the above, it is considered that reference to planning contributions within Policy AL/RTW 15 (and all other similar policies where this approach has been taken) is removed and that Policy ST 5 (Essential Infrastructure and Connectivity) as the governing policy for the use of planning contributions is relied on exclusively (also see comments on updated wording of Policy ST5).

In view of the above, the current wording of Policy AL/RTW 15 Land at Knights Park is not deemed to be ‘positively prepared’, ‘justified’, ‘effective’ or ‘consistent with national policy’. As such, the policy is not deemed ‘sound’ and should be amended as outlined above to rectify the abovementioned concerns.

DLP_2047

Terry Everest

General Observation

I would query the need for this development and argue for a reduction in any proposed development, the site provides a good function currently and I would object to any development which further encroaches or endangers the remaining woodland or marginal green space around the site.

DLP_3202

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

There is concern about loss of parking on this site in order to develop further A3 uses. It is requested that something is included in the policy to ensure this is a key consideration.

The County Council as Local Highway Authority is also considering this (with Arriva) as a potential Park and Ride site owing to parking for leisure related uses being mostly during evenings and car park being relatively free during office hours.

The standard paragraph regarding contributions should also 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.

Policy AL/RTW 16: Land at Wyevale Garden Centre, Eridge Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_669

Ms Carole Freeman

Object

Re:  AL/RTW16 - This plot is on quite a dangerous bend in a very busy road and on the very edge of the Common. I do not consider this a safe place to develop for housing as lots of cars coming out on this bend could cause unnecessary extra problems for the many road users.

DLP_2902

Chris Gow

Object

More Green Belt land threatened.

No development should take place on Green Belt Land.

DLP_2903

Chris Gow

Object

I object to all development on Green Belt land.

The trees and shrubs in the Green Belt are essential for the battle against CO2 emission, and provide amenity for residents.

DLP_3763

Martin Robeson Planning Practice for Tesco Stores Ltd

Object

Policy AL/RTW16 – Land at Wyevale Garden Centre (objection)

Notwithstanding the scale of convenience goods capacity identified by the Council’s retail consultants (noting this work is now already over two years old), Tesco questions the necessity of an additional convenience store, particularly in the context of the modest growth anticipated in Royal Tunbridge Wells itself (relatively to other growth locations) and recent changes to foodstore provision in and around the town. Even if this were not the case, the Council is allocating other sites in and adjacent to the town centre for retail development, including for convenience goods retailing. The Wyevale site is ‘out-of-centre’ in policy terms and relatively remote from the bulk of the town’s population, encouraging trips away from it, to the potential detriment of the town. This isolation would not facilitate any beneficial trips to, or support of, any existing retail centre. The site itself is highly constrained. It lies partly in the Green Belt and whether exceptional circumstances for adjustment to the GB boundary is unclear. It is adjacent to important wildlife designations and falls partly in Flood Zone 3. The site access is highly constrained, and it is unclear how a satisfactory access arrangement can be delivered. The adjacent highway also displays peak-hour queuing. Tesco recommends that the draft allocation is deleted.

DLP_1825

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Number:  AL/RTW 16 Wyevale 

We previously commented that mixed use redevelopment of this site would be appropriate provided that higher parts of the site adjoining the Common, the historic setting of Hungershall Park and High Rocks Lane were safeguarded as green spaces, which is achieved in the draft policy. The access to the A26 remains a critical issue requiring improvement.

We would support the creation of an active travel route through the site linking High Rocks Lane and the A26 as this would create an excellent new route into the town centre avoiding the extremely daunting incline from the bottom of Cabbage Stalk Lane up through Hungershall Park.

DLP_4275

RTW Civic Society

 

This mentions the possibility of an A1 convenience store.  Could this be as large as a Lidl store?

DLP_2550

Ms S Daniels

Object

This is a well-used garden centre that has just changed ownership from Wyevale. Situated on a bend in the narrow Eridge Road and close to the Spa Valley's railway bridge it is a most unsuitable spot for generating yet more traffic from even more housing. Why is a convenience store required when a large Sainsbury's is a short distance away. Such ribbon development leads to the degradation of the green spaces and access to the Common that surrond the current site.

DLP_2048

Terry Everest

Object

Object

I object to any further development of this area which currently sits reasonably well in its environment but should not be developed further and nor should the garden centre be replaced with a more intense use such as residential or industrial. This is a sensitive woodland and river catchment and should therefore be protected.

DLP_3205

Kent County Council (Growth, Environment and Transport)

 

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

Paragraph 8 – “Means of access, including secondary/emergency access, to be informed by a Transport Assessment: it is likely that the scale of any development may be limited by quality of access arrangements that can be achieved within the confines of the site. There is a crash record at the access junction and the railway bridge affects visibility to the west when exiting. An emergency access is likely to be required to the north. Pedestrian and cycle access into the town requires improvement.”

Additional paragraph: Provision of pedestrian and cycle access to the north.

The standard paragraph regarding contributions should also 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

KCC supports the specific policy reference to PRoW (Statement 4), including the provision of an east-west green route and new connections with the existing PRoW network.

Heritage Conservation

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

The site lies south of Nevill Park and east of High Rocks Iron Age hillfort and is in an archaeologically sensitive area. Predetermination DBA and fieldwork is required to be carried out.

Policy AL/RTW 17: Land at 36-46 St John's Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_3593

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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/RTW 17

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 Tunbridge Wells. 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/RTW 17

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

DLP_5204

Culverden Residents Association

General Observation

If this allocation should not be built out for any reason under the present planning consent, we would advocate that the rear part of the site should be developed as a primary school to meet the existing unfulfilled need on both sides of the A26 in this area. We made representations to that effect in earlier consultations.

DLP_2904

Chris Gow

Object

This development should never have been approved.

The site is best suited for low cost housing, close to shops, amenities and bus routes.

Opportunity missed to deliver something that is suitable for lower income households in the borough.

DLP_3207

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:

Additional paragraph: All servicing and delivery activity to be contained within the site boundary.

Additional paragraph. Principal vehicular access from Woodbury Park Road.

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

Policy AL/RTW 18: Land to the west of Eridge Road at Spratsbrook Farm

Comment No.

Name/Organisation

Object/support/ support with conditions/general observation

Response

DLP_27

Mr and Mrs R Ballard

Object

Re: Proposed development on land to the rear of Ramslye Road, Tunbridge Wells

It would be an absolute travesty if the development was to be sancioned on the land behind Ramslye Road, Tunbridge Wells - our green and pleasant land - which would be lost for ever and ever. This land is enjoyed by us all, not only the walkers, but the view from our houses is spectacular. We are able to watch the wildlife and the changing seasons - God forbid if this proposal goes ahead.

When we purchased our house [TWBC redacted personal details] just over 28 years ago, we were NOT council tenants, and paid the going rate at that time, for what was to be our retirement home and which we have enjoyed during the years we have lived here - IT IS OUR HAVEN!!  At the time of purchase, we were assured that the land in question was, or is, Crown Land, and would never, ever be built upon, which was one of the reasons we made the purchase both of us being country born and living on farms.

Now, at a time when the World is talking strongly about climate change, and the fact that the A26 Eridge Road is a race track it beggars belief that such a development could even be thought of in this area; an absolute death trap for motorists and pedestrians exiting the proposed site. I dread to think what problems would be created if traffic was to be diverted through Ramslye Road. We have our fair share of problems now, with the gas guzzling vehicles which use the road to fetch and carry pupils and staff to and from St. Mark's School also the huge trucks which seem to deliver daily to the school. Some drivers park anywhere they please, blocking our driveways and the road. They just will not walk a few yards.  There is also quite a problem with parking for residents especially where in some cases they have two or three cars per house. It is also a bus route and the buses have great difficulty making there way around the estate at times.

This area does not require this kind of development, especially not adjacent to a dangerous and sometimes gridlocked road.

I do hope that the Tunbridge Wells Borough Council Planning Department will give serious thought when considering their verdict regarding this dreadful proposal and refuse the application by the development company.

DLP_98

Mr Michael Wadsworth

Object

There is another large site in TW, the golf course next to the SPA Hotel, this is Green Belt and has a Limits to Build similar to the Ramslye Farm/ Spratsbrook site, in fact it has less constraints than our site as it is previously developed and is not actively farmed.

DLP_185

Miss Noreen O'Meara

Object

I wish to register my strong objection to any development on land to the west of Eridge Road at Spratsbrook Farm (SHELAA reference site 137), and I make the following points in support of my objection.

1. The land is Ramslye Farm, not Spratsbrook Farm. Spratsbrook Farm is about a mile away in Sussex. This has caused great confusion, with the result that some local residents have been unaware of the plan to build on the site, and others not knowing how to comment on the plan.

2. The heritage significance of Ramslye Farm has been completely underestimated. There is no mention of the fact that Ramslye Farm is a historic farmstead dating back to medieval times. Other sites that were rejected did mention historic farmsteads  within their boundaries or nearby. There is also no mention of  Ramslye Old Farmhouse, a 17th century listed house with probable earlier origins, that lies directly next to the plot, and which would have its tranquil rural setting completely ruined if this development was allowed to go ahead. The proposed development overlaps with a scheduled monument, the High Rocks Prehistoric Rock Shelters and Multivallate Hillfort. The Northwest side of the plot actually covers part of the hillfort itself, and its development would result in the partial loss of a very important part of our local heritage. In addition the hilltop setting of the fort, which affords far reaching views in all direction, would be ruined, and no depth of green buffer would prevent this.

3. The site is rich in wildlife, and building on the land would result in loss of habitat and feeding opportunities for many species. Badgers, various species of bats, adders, grass snakes, slow worms and birds of prey are all known to frequent this site. The ancient woodland that lies both on and adjacent to the site and its associated wildlife would suffer significant damage if the development were to go ahead, in spite of the provision of a green buffer.

4. The SHELAA reports that this site has existing access onto the A26 Eridge Road. This is incorrect. A  lane which provides private access to Ramslye Old Farmhouse and Ramslye Farm Cottage, and which is also a public footpath, runs to the south of the site but does not provide access to the site. A farm track used to lead from the north part of the site but this was abandoned many years ago and is now completely overgrown, so the site has no access onto the A26.

5. The land is prime arable farmland, and I have been told that a very good crop was harvested from it this year. According to the government's "Best and Most Versatile" rules, highly productive farmland like this should be protected.

6. The A26 Eridge Road is already the second most congested road in Tunbridge Wells, and if this development were to go ahead it would be the busiest by far. The levels of air and noise pollution would be unsafe and intolerable for the local residents. I understand that part of the plan involves creating a roundabout at the junction with Broadwater Down, and that it is believed that this would make this stretch of road safer. I believe that it would make the road even more dangerous, and would be likely to turn the quiet  conservation area of Broadwater Down into a congested rat run.

7. The land lies within the High Weald Area of Outstanding Natural Beauty. Unlike some of the other plots that are within the AONB, this land is a particularly good example of High Weald  landscape, which has been described as, "a medieval landscape of wooded, rolling hills studded with sandstone outcrops; small, irregular-shaped fields; scattered farmsteads; and ancient routeways." This describes Ramslye Farm perfectly.

8. The land is Green belt and should not be released for development. Green belt boundaries should only be altered in wholly exceptional circumstances, which do not exist in this case.

I believe all of the above reasons make this site totally unsuitable for development, and I therefore ask that it is removed from further consideration in the Draft Local Plan.

DLP_256

Mr J Buss for Oak Tree Homes Trust

Object

Objection to Local Development Plan including Spratsbrooke Farm land. Ref Site 137 AL/RTW18 

As Trustees of Strawberry Hill House, 65 Broadwater Down, Tunbridge Wells, Kent, TN2 5FP we strongly object to any potential development on the above land. Our reasons are as follows:

  1. This land is already Green Belt and should not be released for development. A study conducted by the council in 2017 assessed that this would cause a high degree of harm if allowed to be developed. It also that this land made a strong contribution to the national criteria for Green Belt by three of the four criteria assessed.
  2. The strain on the infrastructure. The existing road network cannot support a development of the proposed nature and size. 23,496 vehicles use the Eridge Road daily going into Tunbridge Wells. This causes traffic queues from Sainsbury’s roundabout to Broadwater Down and beyond. The proposed development would add around 350 cars daily also increasing traffic by up to 25% for school runs, totalling nearly 30,000 vehicles every day. The current roads and parking simply will not cope with this extra strain. The site of any new school should be in the same location as the bulk of the new housing.

When we constructed our block of 10 retirement apartments at Strawberry Hill House, 65 Broadwater Down , around 100 metres of road was dug up to convey waster to the main sewer. A development of the proposed size would place even more strain on the facilities.

  1. The land is within an Area of Outstanding Natural Beauty. It is also high grade agricultural land and must be protected from development. The council is failing in its duties under the Countryside and Rights of Way Act 2000 which says the primary purpose of AONB’s is to conserve and enhance natural beauty. Their protection should be given a high priority by local authorities. The crops grown there include cereals, linseed oil seed rape which according to the government means it should be protected under the ‘Best and Most Versatile’ rules that ensure we keep the best farm land to produce the food we need.

In conclusion, a development of this scale will a terrible impact on AONB and high grade agricultural land as well as a negative impact on local residents in terms of traffic, noise, congestion and pollution.  We urge you to remove this site from the draft local plan.

DLP_339

Residents Against Ramslye Development

Object

[TWBC: comments made by petition signed by 669 local residents. Please note the petition has been scanned and personal details redacted. The redacted petition is attached as a supporting document. See also Comment Number DLP_335 (Policy STR1: The Development Strategy (Table 3: Scale and Distribution of Development].

We want to register our strong objection to any development on this site (the fields adjacent to Ramslye Road and beyond it/Spratsbrook Farm) and we make the following points in support of our objection:

  1. The land is within the High Weald Area of Outstanding Natural Beauty (AONB) and is high grade agricultural land and as such it must be protected from development

Approximately half of the site sits within the High Weald Area of Outstanding Natural Beauty (AONB). The whole site is visually prominent and contributes to local recreational uses through its visual landscape, walking access to Friezland woods and being farmed. The Department for Environment Farming and Rural Affairs (DEFRA) states:

“The primary purpose of AONB designation is to conserve and enhance natural beauty. Subsidiary purposes – in effect, qualifications of the primary purpose – are those defined in a Countryside Commission statement 1991, restated in 2006:

  • In pursuing the primary purpose of designation, account should be taken of the needs of agriculture, forestry, other rural industries and of the economic and social needs of local communities. Particular regard should be paid to promoting sustainable forms of social and economic development that in themselves conserve and enhance the environment.
  • Recreation is not an objective of designation, but the demand for recreation should be met so far as this is consistent with the conservation of natural beauty and the needs of agriculture, forestry and other uses.”

AONBs are designated by government to ensure that the conservation and enhancement of the landscape is given high priority. The High Weald AONB has a number of features:

  • rolling hills, dissected by steep-sided gill streams and studded by sandstone outcrops.
  • small, irregular-shaped fields and open heaths which are often the remnants of medieval hunting forests.
  • abundant, interconnected ancient woods and hedges. The dense forest which gave the Weald its name has largely vanished, but fine ancient broadleaved woodland is still abundant, particularly in the deep gills which incise the ridges. The Weald retains one of the highest levels of woodland cover in the country at over 23 per cent. Traces of the ancient Wealden iron industry, including hammer ponds, are found scattered throughout the woodlands.
  • scattered farmsteads and hamlets, largely developing from temporary dwellings in wooded areas or ‘dens’ where farmers from the Downs grazed their pigs. Buildings are characterised by distinctive stone, brick, tile and white weatherboard houses and oasthouses are common.
  • narrow, sunken lanes arising from pannage – the movement of animals from the Downs to the High Weald in the autumn to graze on mast in the area’s woodlands or dens.

The land on this site is a fine example of these characteristics and we understand it is considered to be medieval assart farmland. Given its close proximity to Tunbridge Wells, the site is currently easily accessible and available to the public for recreational purposes – its loss would clearly have a detrimental impact on the environment and the visual landscape.

In addition, the land on the whole site is designated agricultural grade 3, and given the crops grown on the fields for the past 3 decades at least include cereals, linseed and oil seed rape, it seems very likely it is grade 3a[1] which means it should be protected under the “Best and Most Versatile” (BMV) rules.

Footnote: [1] Subgrade 3a - good quality agricultural land

Land capable of consistently producing moderate to high yields of a narrow range of arable crops, especially cereals, or moderate yields of crops including: cereals; grass; oilseed rape; potatoes; sugar beet; less demanding horticultural crops.

We consider that in putting this site forward for consideration of development the council has failed in its duties under the Countryside and Rights of Way Act (CRoW) 2000 which reaffirms the primary purpose of AONBs: to conserve and enhance natural beauty. The CRoW sets out responsibilities for the management of AONBs. Specifically in identifying the site for development TWBC is not complying with:

  • Section 82 reaffirms the primary purpose of AONBs: to conserve and enhance natural beauty.
  • Section 84 confirms the powers of local authorities to take appropriate action to conserve and enhance the natural beauty of AONBs.
  • Section 85 places a duty on all public bodies and statutory undertakers to ‘have regard’ to the ‘purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty.’
  • Section 92 clarifies that conservation of natural beauty includes conservation of flora, fauna and geological and physiographical features.

Furthermore, the development of the site would not in our view meet the requirements of the National Planning Policy Framework set out in section 170. Section 170 requires that Planning policies and decisions should contribute to and enhance the natural and local environment by:

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

    In permitting development on this site we consider TWBC will be in breach of all of the clauses set out above.

    A development of the scale proposed for this site cannot comply with the requirements set out above in respect of AONB, BMV, CRoW or NPPF, and additionally TWBC’s own policy as set out in STR8 says:

    “The urban and rural landscapes of the borough, including the designated High Weald AONB, will be conserved and enhanced;

    The landscape character of the borough will be protected through retention and enhancement of the key characteristics or valued landscape features and qualities, as well as through the restoration of landscape character where it has been eroded;…

    Within the area designated as AONB and its setting, development will be managed in a way that conserves and enhances the natural beauty of the area, and developers will be expected to demonstrate (through relevant documentation submitted as part of a planning application) how proposals have had regard to the objectives of the High Weald AONB Management Plan. Proposals that would harm the natural beauty of the AONB will not be permitted unless it is clearly in the public interest to do so. In such instances, effective mitigation should form an integral part of the development proposals;

    A hierarchical approach to nature conservation and the protection of biodiversity will be applied across the sites and habitats of national, regional, and local importance within the borough. The objective is to achieve net gains for nature and protect and enhance sites of geological interest across the whole borough;….

    The designated and non-designated heritage assets of the borough, including historic field patterns, listed buildings, conservation areas, Scheduled Ancient Monuments, archaeological sites, and Historic Parks and Gardens, will be conserved and enhanced, and special regard will be had to their settings;….”

    And EN7 goes on to say “Proposals that affect a designated or non-designated heritage asset, or its setting, will only be permitted where the development conserves or enhances the character, appearance, amenity, and setting of the asset; and in the case of historic parks and gardens, provides, where possible, improvement of access to it.”

    The fine words and sentiment set out in the policy that we support will be rendered empty and worthless if development on this site is permitted. Developing the site will result in its loss as a heritage and landscape asset and no amount of mitigations will meet the policy intent set out in the Draft Local Plan.

    Under the NPPF TWBC is obliged to give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land before permitting the development of greenfield sites. TWBC has simply not demonstrated appropriate consideration of the impact of developing this site and should remove it from consideration in the local plan.

  2. recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland;
  3. minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;
  4. preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans; and
  5. remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.
  6. The land is Green Belt and it must not be released for development

    We do not consider that the case has been made to release the portion of the Green Belt which is relevant to this site.

    The decision to declassify any Green Belt must meet the criteria set out in the National Planning Policy Framework (NPPF). In addition, the decision to declassify should be subject to significant analysis and challenge given the permanence of the decision – i.e. once it’s gone it’s gone. The expectation set out by government in the NPPF is that new Green Belt will not be designated, therefore the barriers to declassifying should be as high as they are for classifying new Green Belt.

    Paragraph 136 of the NPPF says:

    “Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period.”

    Paragraphs 143 to 144 go on to say:

    “Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.

    When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations.”

    We do not consider the local plan meets the thresholds set in the NPPF to release the site from Green Belt. Beyond a superficial statement to the effect that there are special circumstances, the plan does not present detailed arguments or evidence, nor does it consider individual sites within the Green Belt which given the differently assessed impacts would be a minimum for each site.

    The Tunbridge Wells Green Belt Study Stage Two (TWGBSST) prepared in July 2017 assesses the degree of harm caused by the potential loss of this site (referenced as TW10 in the TWGGBSST) as high (the second highest rating). It also assesses that the contribution of this site to the NPPF criteria for Green Belt as relatively strong (the second highest rating) in three out of the four criteria assessed. The TWGBSST presents a strong evidence base to retain this site in the Green Belt. It is not apparent from the local plan that any other site has been proposed to be released from the Green Belt that would have the high degree of harm associated with losing this site in the RTW area.

    Further we consider the release of this site from the Green Belt is inconsistent with the policy STR8 (Conserving and enhancing the natural, built, and historic environment). In particular, it has not been demonstrated how its release would be consistent with clauses 1, 2, 4 and 5 of that policy. If we as local citizens are to be able to rely on these policies, it is of the utmost importance that the council adheres to all of its policies and manages the inevitable tensions in a transparent and robust way. We do not consider that given the high degree of harm to the Green Belt that would be caused by its release, that this site can ever be released in a way that is consistent with this policy and we therefore urge the council to withdraw this site from further consideration.

  7. The existing road network cannot support a development of the size and nature proposed

We do not consider any development on this site can be consistent with the strategic policy set out in the draft local plan relating to transport considerations (reproduced at the end of this section). The proposal to develop the site will add an unsustainable level of traffic to Eridge Road. Data from the Tunbridge Wells Park and Ride Feasibility Study shows Eridge Road supports almost the same amount of traffic as Pembury Road, which are both significantly busier than other access roads (see table 2 below reproduced).

Table 2: DfT Estimated Daily Traffic Flows, 2016

Road

Link

Cars, Taxis

All Motor Vehicles

A264 Pembury Road

B2023 to Blackhurst Lane

19,408

24,215

A267 Frant Road

B2169 to A26

11,560

14,138

A26 Eridge

LA Boundary to A267

19,746

23,496

A264 Langton Road

A264 Mount Ephraim to A26

7,855

9,034

A26 London Road

A26 Mount Ephraim to Birchwood Avenue, Southborough

15,450

19,330

The RAC reports that in the Tunbridge Wells Borough, car ownership is 560 per 1000 population. On that basis, 270 new homes with the same occupancy rate as the current TW average (2.35 people) would add 358 cars to the current traffic flow. There is no existing access road to the site (only a private driveway) - we believe the draft local plan is incorrect on this point - and a new access road would be required creating additional road safety issues on an already very busy road with poor visibility.

In addition, school runs can add significantly to the traffic - estimates vary between 20% and 25% increases. Logistically it is not at all clear why it would be sensible or feasible to place a school serving the borough at the extreme South West of the borough. Such positioning will not only lead to an unsustainable increase in traffic on Eridge Road but also London Road (and other feeder roads) towards any school. School run traffic effectively creates four journeys (there and back twice a day) so putting a school at the far end of the borough should not be considered viable.

Furthermore, Kent County Council reports that in 2016, 16,172 pupils attended secondary school in Kent, of which 803 came from out of county. Given Tunbridge Wells’s proximity to the Sussex border, it is reasonable to assume a much greater than average proportion of the 803 pupils will attend Tunbridge Wells schools than other parts of Kent. Building a school so close to the East Sussex border will only exacerbate this situation and therefore lead to even more traffic issues on Eridge Road as the key access.

Given the Draft Local Plan has identified Capel, Tudely and Paddock Wood as areas for substantial housing development, from a transport perspective there can be no logical justification for building a new secondary school so far away from those settlements. Surely if TWBC is serious in its objective to promote active travel it should seek to facilitate that by putting new settlements and new facilities (such as schools) closer together. Placing a school in this site will in our view result in decreased opportunities for active travel and we do not agree with the assessment set out at appendix E of the sustainability appraisal document.

The Draft plan says “Reducing greenhouse gas emissions such as carbon dioxide (CO2) is critical in limiting the impacts of climate change. In 2008, the Climate Change Act set a legally binding target for reducing UK CO2 emission by at least 80 per cent by 2050”. If the Council is going to give effect to these words, it must rethink building a school so close the border.

When considered against the evidence set out above, it is clear that the current road and parking infrastructure cannot support the level of intensive development proposed without some drastic form of intervention to divert existing and additional through traffic from the A26 to the A21 to the south of Tunbridge Wells.

Further consideration should also be given to the impact on the existing residents of the Ramslye estate. The estate is currently a relatively quiet, green environment. It benefits from public open spaces that are used by the community, which adds to its character and general feel. The addition of a new secondary school will likely turn the roads into a congested car park for either school run or indeed older pupils seeking to park and walk through. We would refer you to the parking situation at the Fusion sports centre on St. Johns Road where many parking spaces are regularly taken by pupils of the neighbouring school (contrary to Fusion’s parking policy). As is the case with many semi-rural and suburban areas, many people are reliant on their cars even for short journeys.

Transport and Parking

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

All sustainable modes of transport (including active travel, the use of public transport, and electric vehicles) will be facilitated to reduce dependence on emissions-producing private car use, and which will also support opportunities for improving air quality within the borough in accordance with the latest Air Quality Action Plan and the developing Kent and Medway Energy and Low Emission Strategy. This will be done through working with partners to:

1. Continue to develop and provide an integrated strategic cycle network in accordance with the latest Cycling Strategy and Local Cycling and Walking Infrastructure Plan, as well as enhance routes such as Public Rights of Way for users of non-motorised transport. This will include networks within settlements, particularly Royal Tunbridge Wells, Southborough, Langton Green, Rusthall, Pembury, Paddock Wood, Five Oak Green, and the new garden settlement at Tudeley Village, but also between these and other settlements;

2. Provide improved cycle parking and e-bike charging points;

3. Encourage improvements in public transport infrastructure and services, including in terms of rail access to Gatwick and London;

4. Support the expansion of car clubs (which allow the booking/use of vehicles kept on publicly accessible land by individuals for a number of hours at a time) and opportunities for car sharing;

5. Provide bike share opportunities;

6. Incorporate electric car charging points (or any new technology requirements) into new developments, and where possible into existing public and private car parks and street furniture;

7. Explore potential for incorporating innovative smart travel solutions resulting from emerging transport technology and initiatives, such as Demand Responsive Transport (DRT), and Mobility as a Service (MaaS), into transport planning and new developments; and

8. Pursue improvements to transport links in the rural areas of the borough, and conserve and enhance the rural lanes network to ensure that they are convenient and safe for users.

a. Provision will be made for maintaining and improving transport infrastructure at the strategic and local levels through working with partners to:

a. Improve the local and strategic cycle network;

b. Retain and improve the strategic rail network by increasing rail capacity, reliability, and punctuality, as well as reducing overall journey times by rail. The Council, as Local Planning Authority, will also aim to provide station infrastructure improvements where necessary;

c. Improve the strategic highways network, including projects on the A21 Kippings Cross to Lamberhurst, A264 bus priority measures, the Hawkhurst relief road, and the A264 junction capacity improvements (Woodsgate Corner and Halls Hole Road/Blackhurst Lane). In particular, provision will be made for the offline A228 as part of the wider strategic transport network, and to mitigate the impact of development proposed in this Plan;

d. Establish rapid bus/transport links, including from Paddock Wood to Tunbridge Wells, and Paddock Wood to Tonbridge (via Tudeley Village), and Tunbridge Wells to Tonbridge, and retain and enhance existing bus services;

e. Plan for, as appropriate, and take opportunities presented by, technological innovations in transport; and

f. Ensure that transport infrastructure development or improvement schemes (including public realm and other works to historic routes, surfaces, and street furniture) take every opportunity to improve or enhance the historic environment, green, grey, and blue infrastructure, and landscape connectivity in accordance with the guidance in Historic England’s national and regional Streets for All: Advice for Highway and Public Realm Works in Historic Places guidance.

Traffic and car parking will be carefully managed through developing innovative strategies that will both provide a sufficient level of parking in the borough as well as encourage sustainable travel. The Council, as Local Planning Authority, will be closely involved with the Council's forthcoming Parking Strategy, to ensure an integrated approach to parking, transport, and land use planning.

Development proposals that have significant transport implications will be required to be accompanied by a transport assessment and travel plan showing how car based travel can be minimised (seeTable 8).

Conclusion

A development of this scale in the High Weald AONB and on such high grade agricultural land sets a dangerous precedent for our rural environment, and it will have an unduly negative impact on the residents in the area in terms of traffic, noise, congestion and pollution.

We have set out a compelling and reasoned case to remove this site from the draft local plan and we urge you to consider how to challenge the overall requirement for new dwellings to a more realistic and justified target.

DLP_383

Mrs S Sheldrake

Object

I entirely agree with the Reisidents against Ramslye Development letter

The land is in the high Weald AONB. once built on agricultural land is lost for ever

the land is Green Belt amd should not be built on

The Eridge Road cannot cope with the present trafficand the development of houses and   a large school would need a much bigger road--- more farm loss

Are so many houses actually needed? Houses take a long time to sell in this area. and there is no actual work for people.

DLP_372

Virginia Best

Object

Comment on AL/RTW18 Site 137

Land to West of Eridge Road on Spratsbrook Farm.

The following comments are in objection to the proposal to include the above site as a potential site in the Tunbridge Wells Borough Plan for the development of c 270 dwellings and a secondary school.

The above site is in the Green Belt and some of the site is in the AONB. Development of this site would be in contravention of both policies.

The site is adjacent to the High Rocks which is an SSSI and also very close to Friezland Wood and Hargate Forest and close by to RSPB Broadwater Warren.  Any development of the scale proposed would have a harmful effect on the conservation of these areas, habitats, and wildlife contained there.

The visual  impact of the site on the top of a hill would be severe to the High Weald landscape in which it sits.

The existing road network would be severely impacted by the development, not only the dwellings but the proposal for a school would entail thousands of new traffic movements every day.

As a consequence of traffic congestion there will be an adverse impact on local residents, greater pollution and associated health risks.

There are no plans to provide a health centre -  I understand the Showfields surgery is soon to close so the pressure on health services locally will be exacerbated.

DLP_395

Craig K

Object

As a new resident to the area, I am hugely disappointed to hear about these new plans. The area suffers already greatly from bad traffic congestion and traffic pollution (along the Eridge road from the proposed site into Pantiles area) and further houses would add to this pollution and also congestion, and would be unsustainable.

The road is not safe for children crossing and further houses and thus cars can’t be good.

Furthermore, the fields the site is proposed to be built on are a really nice piece of Greenland in a busy town centre close proximity.  Please don’t build such a large site and adding to the car pollution.

DLP_411
DLP_413
DLP_415
DLP_7941
DLP_8065
DLP_8069
DLP_8081
DLP_8062
DLP_469
DLP_486
DLP_617
DLP_625
DLP_628
DLP_663

DLP_674
DLP_677
DLP_683
DLP_672
DLP_680
DLP_738
DLP_749
DLP_755
DLP_763
DLP_775
DLP_777
DLP_781
DLP_785
DLP_742
DLP_746
DLP_752
DLP_758
DLP_768
DLP_770
DLP_772
DLP_838
DLP_919
DLP_933

DLP_916

DLP_922

DLP_926

DLP_1035

DLP_1037

DLP_1053

DLP_1055

DLP_1063

DLP_1065

DLP_1081

DLP_1044

DLP_1046

DLP_1048

DLP_1058

DLP_1070

DLP_1076

DLP_1084

DLP_1090

DLP_1094

DLP_1138

DLP_1148

DLP_1154

DLP_1156

DLP_1158

DLP_1160

DLP_1127

DLP_1131

DLP_1133

DLP_1135

DLP_1141

DLP_1143

DLP_1145

DLP_1151

DLP_1168

DLP_1174

DLP_1176

DLP_1178

DLP_1190

DLP_1192

DLP_1199

DLP_1201

DLP_1171

DLP_1195

DLP_1208

DLP_1216

DLP_1330

DLP_1332

DLP_1204

DLP_1319

DLP_1323

DLP_1325

DLP_1327

DLP_1339

DLP_1341

DLP_1343

DLP_1345

DLP_1336

DLP_1348

DLP_1350

DLP_1354

DLP_1399

DLP_1403

DLP_1388

DLP_1390

DLP_1396

DLP_1416

DLP_1424

DLP_1426

DLP_1450

DLP_1456

DLP_1458

DLP_1431

DLP_1435

DLP_1439

DLP_1514

DLP_2329

DLP_2670

DLP_2715

DLP_1484

DLP_1494

DLP_1508

DLP_1510

DLP_1522

DLP_1530

DLP_1544

DLP_1548

DLP_1554

DLP_1556

DLP_1465

DLP_1467

DLP_1469

DLP_1473

DLP_1477

DLP_1487

DLP_1491

DLP_1499

DLP_1501

DLP_1519

DLP_1527

DLP_1533

DLP_1535

DLP_2172

DLP_2174

DLP_2183

DLP_2242

DLP_2244

DLP_2246

DLP_2248

DLP_2250

DLP_2252

DLP_2177

DLP_2270

DLP_2290

DLP_2306

DLP_2308

DLP_2239

DLP_2257

DLP_2259

DLP_2263

DLP_2267

DLP_2277

DLP_2287

DLP_2293

DLP_2297

DLP_2299

DLP_2301

DLP_2303

DLP_2359

DLP_2363

DLP_2323

DLP_2333

DLP_2337

DLP_2343

DLP_2396

DLP_2400

DLP_2404

DLP_2409

DLP_2681

DLP_2687

DLP_2706

DLP_2711

DLP_2664

DLP_2672

DLP_2678

DLP_2690

DLP_2694

DLP_2699

DLP_2703

DLP_2853

DLP_3088

DLP_3100

DLP_3071

DLP_3073

DLP_3079

DLP_3085

DLP_3150

DLP_3223

DLP_3229

DLP_3251

DLP_3259

DLP_3265

DLP_3273

DLP_3291

DLP_3583

DLP_3683

DLP_3214

DLP_3236

DLP_3240

DLP_3697

DLP_3278

DLP_3296

DLP_3648

DLP_3652

DLP_3668

DLP_3734

DLP_7250

W Gibson

Sheila Gibson

Mr and Mrs Hitching

R, A & A Angelis & K & N Lescure

Olive Hobday

Kelly Cooper

Chrissie Wade

Susan Cooper

Rupert Ward

Mr and Mrs D & C Carter

Laura Gonzales

Jean Moss

Dorothy Beaumont

Kathleen Dowling

Margaret Hutchison

Justine Threadgold

Ashleigh Threadgold

Mary Pepper

Robin Threadgold

Esther Clements

Valerie Murray

Isobel Creesey

Kirsty McLauchlan

Beth Dawson

Wolff

Mrs A James

Andrew Gent

Tanya

Mr and Mrs M A Bates

Richard and Ann Waterman

Peter A Smith

Mita Khamom

Vivienne Smith

P I Patterson

Lydia Sepulcre

J L Becker

GD Stewart

Michael Foreman

Robin Townshend

Keith and June Murray-Jenkins

Barrie Howells

Linda Howells

Winifred Fraser

Alfred D'Avila

Shirley and Peter Kemp

John Weller

George Damper

John and Bronwen Verrico

Phillip Gritted

Mr and Mrs Muggeridge

Stephen and Jane Brewer

Lida Willingale

Michael John Sharp

Wendy Craft

Jacqueline Duncan

Andrew Duncan

Claire Stewart

Martin and Diana Ridgley

James Rowe

Lin Gent

Louise Dunphy

T Seabrook

Shirli and Brian Edgington

Cara Goodman

Russell Smith

Gemma Joy

Jonathan & Hilary Rayner

Malcolm Bowskill

Nick Joy

Diane Moore

Martin Creasy

Marlene Virgili-Jarvis

Kathy Jones

Gwyneth Banks

David Gillmore

Patricia Dennis

B. E. Holcombe

Roy Freeman

Nazmal Miah

S Malek

Michael and Karen Clarke

Sandra Hoskins

Barbara Rowe

Beryl Sayers

Alistair Milner

Jemma Askew

Simon Holtham

Karla Martin

Ange Gent

Anna Madams

Lucinda Sparrowhawk

Molly Moynan

Leslie Moore

Tony Taylor

Mr and Mrs J Howkins

Sue Newell

Alice Holmes

Jade Frawley

Adam Kayyali

M Hawkins

Olga Malolepsza

Charlie Tampsett

Jason Puttock

Martina Zizkova

Chris Patterson

Alfie Tauprett

Alexandra Draper

Lucy Soames

Ashley Martin

Stacey Martin

James Sharp

Mr & Mrs R & M Thatcher

Ben Tully

H Lewsey-Gillmore

Margaret Gudgeon

Tristan Tully

Mike and Jean Brown

Lee Maynard

Victoria Adams

Gary Norman

Bernadette Adamson

Kirsty Green

Theo Tully

Patricia Tiltman

Emma Heasman

Anna Leppik

Debbie Tampsett-Maynard

Joe Tampsett

Nikki and Tony Howther

Ben Taylor

Daniel Holmes

Vladimira Lukowska

Jack Tampsett

Freda Holmwood

Paula Green

Karl Coomber

Dmitry Goldberg

Naddine Kayyali

James Scott Lindsay

Sarah Waldock

Sandra and Charles Neve

Philip Brewer

Eve Gabriel

S McCurry

Samantha C S Harris

Chris Heal

Gwendolyne Taylor

Jack Norton

R & V Baldock

Mr & Mrs Harvey

Clive Jones

Elena Monica Dragnescu

Donna-Louise Brewer

Nicola Cooper

Viggo Marshall

Helena Marshall

Judy & Colin Owen

Angela Jean Mullis

H Brereton & C Martinez

Carol Moorby

Lynne Brown

James H Brown

David and Linda Keen

Susie Holtham

Carole Moore

Bernard Hoskins

Chloe Newell

Ann Tully

David Jarvis

Valerie Cunningham

Mr and Mrs Vale

Donald Moorby

Trevor Piper

Cathy Waghorn

Paul Blackman

Debbie Webster

Ryan Copper

Chris Williams

C Chambers

Jeremy Cubitt

Marion Blackman

Peter Webster

Craig Cheeseman

Nihal Haddi

Megan Copper

P & J Godman

Matthew Broadbent

Andrew Howard

Ann Darby

Alice Walker

Bryan Darby

Claire Broadbent

Beth Lester

Helen Reynolds

Natasha Saville-Smith

Hugh Sinclair

Gary Easton

Emily Fisher

James Barringer

Deirdre Sinclair

Chris Walker

Dale Richards

Rosemary Porter

Holly Vos

Tracy Balcombe

Oliver Williams

William Coleman

Susan Easton

Susan Askew

Jody Williams

James Askew

Cindy Williams

Mr John Telling

Object

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

I want to register my strong objection to any development on this site (the fields adjacent to Ramslye Road and beyond it/Spratsbrook Farm) and I make the following points in support of my objection:

1. The land is within the High Weald Area of Outstanding Natural Beauty (AONB) and is high grade agricultural land and as such it must be protected from development:

Approximately half of the site is classified as AONB. It is a fine and accessible example of the High Weald and we have AONB designations to protect this type of land. additionally, all of it is high quality agricultural land. By putting the site forward for consideration of development, the council has failed in its duties under the Countryside and Rights of Way Act (CRoW) 2000 which says the primary purpose of AONBs is to conserve and enhance natural beauty and its protection should be given high priority by local authorities. The crops grown in the fields include cereals, linseed and oil seed rape, which according to the government means it should be protected under the "Best and Most Versatile" (BMV) rules that are designed to ensure we keep the best and most productive farm land available so we can continue to grow the food we need.

2. The land is Green Belt and it must not be released for development:

the councils own study of Green Belt prepared in 2017 as part of the development of the local plan assessed the degree of harm caused by the potential loss of this land as high. It also assessed the contribution of this land to the national criteria for Green Belt as relatively strong in three of the four criteria assessed. It is not apparent from the local plan that any other site has been proposed to be released from the Green Belt that would have the high degree of harm associated with losing this land.

3. The existing road network cannot support a development of the size and nature proposed: 

On average 23,496 motor vehicles use Eridge Road every day going into Tunbridge Wells. Only Pembury Road is busier (by c.3%). Traffic  already queues on Eridge Road from Sainsbury's roundabout to Broadwater Down and sometimes further. The proposed development could add c.350 cars to the area and increase traffic by up to 25% for the school runs, totalling nearly 30,000 vehicles every day. The quiet green space of Ramslye could become a congestion/parking black spot due to school traffic. It is clear the current roads and parking provision cannot handle a development of this size and the site of any new school needs to correspond to the location of the bulk of the new housing.

A development of this scale in the High Weald AONB and on such high grade agricultural land sets a dangerous precedent for our rural environment, and it will have an unduly negative impact on the residents in the area in terms of traffic, noise, congestion and pollution.

I have set out a compelling and reasoned case to remove this site from the draft local plan and I urge you to consider how to challenge the overall requirement for new houses to a more realistic and justified target.

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

DLP_356

Yvonne Savage

Object

Standard comment as above, plus the following additional comment:

This area also borders the "High Rocks" AONB which will have a negative for visitors who wish to visit by foot, as there are other smaller rocks within the woods surrounding the area.

DLP_8078

Simon Edward Wade

Object

Standard comment as above, plus the following additional comment:

Ref: 18/02773/FULL. I have fought hard against the redevelopment of No. 46 Broadwater Down, my neighbour. Sadly now approved, though finances seem to be delaying, as was the case with Strawberry Hill House (06/01224/FULL).

DLP_614

Mr and Mrs Fitzgerald

Object

Standard comment as above, plus the following additional comment:

As well as the above, it will destroy the wildlife habitat for bats, deer, etc and impact on RSPB Broadwater Warren Nature Reserve and Folly Wildlife Rescue.

DLP_623

Ian and Susan McNeill

Object

Standard comment as above, plus the following additional comment:

We strongly object for all the above reasons but particularly point no. 3.

DLP_620

Jackie Ford

Object

Standard comment as above, plus the following additional comment:

I am particularly concerned with the increased traffic this proposed development will cause to the A26. At present vehicles exceed the 30mph speed when approaching the Broadwater Down. There needs to be more traffic calming measures in place i.e.either/ or flashing 30mph signs or slow down signs when approaching Tunbridge Wells. This road carries a huge amount of traffic and is dangerous for both residents and school children.

DLP_666

David and Pam Wrenn

Object

Standard comment as above, plus the following additional comment:

What environmental cost, this madness? First Calverley Grounds - now the unwanted / un-necessary intrusion into AONB / Green Belt at Ramslye.

Has T.W.B.C. planning services dept. lost all sense of reason and learned nothing from recent events!?

DLP_783

Mr William Adamson

Object

Standard comment as above, plus the following additional comment:

Other comments

Exiting Court Royal is already dangerous due to traffic approaching at speed from blind bends in both directions.

DLP_787

Mrs G Cooper

Object

Standard comment as above, plus the following additional comment:

Other comments

I agree with all that has been printed here.

DLP_929

Fiona Flower

Object

Standard comment as above, plus the following additional comment:

I was born (at home) and lived until my teens at Ramslye Farm Cottages so feel I have a right to comment on this plan. The site is green belt prime farm land and has a significant site of archeological interest. I feel there must be sites that are more suited in this area of Kent to build this many houses.

DLP_936

Patricia Groom

Object

Standard comment as above, plus the following additional comment:

Certainly we need land for housing, this is a dynamic area for families with good schools. Poor roads NOW? NHS + GPs? Not agricultural land or land for physical activity open spaces for MENTAL WELL-BEING. BROWN SITES? RETAIL SITES?

Other Comments:

Already a car park + rat run.

Parking costs are high from taxed income!

DLP_1039

David Gross

Object

Standard comment as above, plus the following additional comment:

Other Comments:

When traffic is not held up because of volume once it has cleared the traffic lights at the crossing heading towards Crowborough it is an encouragement to travel at excessive speeds making the bend dangerous to traffic leaving the flats.

DLP_1041

Patricia Gross

Object

Standard comment as above, plus the following additional comment:

Other Comments:

The bend outside Court Royal is very dangerous Cars are driving too fast we live in fear while trying to leave the site.

DLP_1073

Alison Sharp

Object

Standard comment as above, plus the following additional comment:

Other comments:

  • Declassifying an Area of Outstanding Natural Beauty is a dangerous precedent. Where will it lead in the future?
  • If the land is developed by Dandara, they will undoubtedly then apply to extend the development further by applying to Wealden District Council. Where will this stop?
  • Do we need another school when there is spare capacity at Hayesbrook School?
  • The impact on the local environment will be too great for the following reasons:
    1. The A26 is an incredibly busy road with queues banking back beyond Broadwater Down at key times most days. it cannot sustain more traffic especially the school run.
    2. Smaller roads adjoining the A26 are increasingly used as cut throughs, even by large lorries. They are used for daily free parking and cannot sustain a further increase in traffic especially for those seeking to drop off/pick up children from the secondary school.
    3. An increasing number of secondary school students drive to school. Where will these students park their cars ?
    4. Ramslye Estate has tree lined roads, grassy areas, narrow roads and many parked cars as there are few house drives. Any new development cannot be easily accessed through the estate and past an existing Primary School.
    5. The speed limit past the fields and Ramslye is not adhered to, with cars only braking to 30mph as they approach the traffic camera. Further development will only add to the risk of accidents.

I hope you will take these points into consideration.

DLP_1079

S A Leipnik

Object

Standard comment as above, plus the following additional comment:

Other comments:

Wildlife needs to be considered also. Owls, etc need to be protected

Enough is enough. Too many houses/too much land being taken - incl. woodland

Too much traffic already

No new infrastructure

Tunbridge Wells is hardly a thriving town - no shops, no jobs

DLP_1050

Delaine Langley

Object

Standard comment as above, plus the following additional comment:

Other comments: It would be such a sad shame to see this beautiful land ruined. To disrupt the beautiful wildlife we should be saving our green spaces not building on them.

DLP_1060

D Rose

Object

Standard comment as above, plus the following additional comment:

Other comments:

Make used of Brownsite, to many car at school now and Four Disable parking around play green, slow worms in field, I don't know wvye They don't concert all over Kent they would have runway for Airport, and how for big houses? No, The Queen Hms had four, each of them had too kids we breed like rats you know.

DLP_1068

Christopher and Angela Sims

Object

Standard comment as above, plus the following additional comment:

Other comments:

The impact to road congestion has not been assessed. I therefore strongly object to this draft plan going forward without such an assessment being in the public domain.

DLP_1087

Anna Avery

Object

Standard comment as above, plus the following additional comment:

Other comments:

I am also concerned that this development, if it goes ahead would dramatically affect the tranquility of the surrounding Friezland Woods through noise pollution from the site construction and the additional roads put in place. Furthermore, the planned development will likely optimise space to squeeze as many new houses into the fields as possible. I am concerned that public spaces such as squares, wider streets and communal parks would not likely be included so not only would the development aggravate current Ramslye residents, the quality of the space for potential future residents of the new site would be impinged upon. Essentially profit would be prioritised over welfare which benefits only the developers. If the development goes ahead, it would be best to create as much affordable quality housing as possible and to also create and preserve large public areas for people to engage with the community. This would be essential if young families are moving into the area.

DLP_1125

R Manwaring

Object

Standard comment as above, plus the following additional comment:

Retail space like the large supermarkets (Sainsbury's) & shopping centre (RVP) should present opportunities for housing/flats, as per other parts of the country, by making use of these large land masses.

DLP_1166

Elizabeth and John Skates

Object

Standard comment as above, plus the following additional comment:

Other comments: The traffic at peak time is often jammed up to summervale RD. now so more houses in this area is a ludicrous idea. T.Wells can't cope now. Green belt land. NO

DLP_1184

Margaret Pratt

Object

Standard comment as above, plus the following additional comment:

Other comments: Eridge Rd is always very busy with many holdups due to heavy traffic. I have lived here six years & speed is increasing.

DLP_1163

Kevin and Kathleen Hurst

Object

Standard comment as above, plus the following additional comment:

Consideration must be given to the total lack of medical facilities on the south side of Tunbridge Wells, with the closure of Rowen Tree Surgery many people face an expensive & lengthy journey to town.

DLP_1187

J and L Jenkins

Object

Standard comment as above, plus the following additional comment:

Other comments: I would like to see the fields are used to create a pinetum an area of Natural beauty that lowers poulution and people can visit bringin revenue to the town.

DLP_1210

Kirsty Farmer

Object

Standard comment as above, plus the following additional comment:

Other comments: I am extremely concerned about the volume of traffic this will attract. The majority of my residents still drive and have great difficulty now turning left and right onto the eridge road - what will this be like when the build starts? Chaos what with the utility companies setting up!!

DLP_1214

Ashley Savage

Object

Standard comment as above, plus the following additional comment:

Other comments: Bluebells grow here which are protected. To develop so near to the High Rocks would also be undermining the heritage of the site!

DLP_1220

Robert Gifford

Object

Standard comment as above, plus the following additional comment:

Also the medical facilities are not good now and the Rowan Tree Surgery is going to close in January.

DLP_1313

Rose Patterson

Object

Standard comment as above, plus the following additional comment:

Other comments: If this development was going to be truly affordable not new luxury homes for  people moving down from London spending in excess of half a million then this may be a different response from people. But this is a development about greed not local need with a terrible impact on the beautiful natural area and all the creatures and trees it supports.

DLP_1315

Ben Williams

Object

Standard comment as above, plus the following additional comment:

Other comments: It is greenbelt + an AONB - leave it alone!!

DLP_1317

Kellie Wart

Object

Standard comment as above, plus the following additional comment:

Other comments: All the above ar the reasons im against.

DLP_1321

Richard Ballard

Object

Standard comment as above, plus the following additional comment:

Other comments: The land subject to the protest is and will always be CROWN LAND and any construction on it would be contrary to GOVERNMENT ruling not TWBC 'snowflakes'

DLP_1334

Patricia Sanctuary

Object

Standard comment as above, plus the following additional comment:

Other comments: It is important to everyone to escape from the pressures of life now and again we therefore need to protect and enhance the green spaces that make escape possible. Like this site

DLP_1358

Sian Sharp

Object

Standard comment as above, plus the following additional comment:

Other comments: I cannot believe you are going to bulldoze these fields

DLP_1362

Nicholas Sharp

Object

Standard comment as above, plus the following additional comment:

Other comments: I cannot believe you are proposing to destroy one of the things that that make tunbridge wells an attractive place to live!

DLP_1385

Mrs Elizabeth Coles

Object

Standard comment as above, plus the following additional comment:

Other comments:

1) Tunbridge Wells is losing its unique charm by extensive development on the outskirts and infilling. Once such character is lost it is permanent

2) Rowan tree surgery closes Jan 2020. No GP - more traffic across town

DLP_1393

Robert Avery

Object

Standard comment as above, plus the following additional comment:

Other comments: I am concerned about the increased traffic on the A26 and the likely increased pressure on parking in Ramslye, which is already very near to capacity.

DLP_1405

Christine Malek

Object

Standard comment as above, plus the following additional comment:

Other comments: I agree with all of the above.

DLP_1419

P Brown

Object

Standard comment as above, plus the following additional comment:

Other comments: I strongly object to the natural wildlife habitat being destroyed, I've seen deer, slow worms, skylarks and many other species whilst walking over many years.

DLP_1408

Mr and Mrs Shields

Object

Standard comment as above, plus the following additional comment:

Other comments: The traffic problem referred to in item 3 cannot be stressed enough as more and more cars, heavy goods vehicles and juggernaughts use Broadmead for the school run, short cut to Broadwater Down and then to Frant Road - not only the increase in numbers, but the speed which on occasions certainly exceeds the speed limit!

DLP_1412

Stephen Barnes

Object

Standard comment as above, plus the following additional comment:

Other comments: I agree with the three statements made above.

DLP_1428

Catherine Morley

Object

Standard comment as above, plus the following additional comment:

Other comments: Hands off our green land!

DLP_1504

Rob Shepherd

Object

Standard comment as above, plus the following additional comment:

Other comments:

This is an area of outstanding natural beauty as well as the A26 being a very busy road.

DLP_1506

Rosemary Ballard

Object

Standard comment as above, plus the following additional comment:

Other comments: Should this development be given the green light, our green and pleasant land will be gone forever, not to mention the pollution and horrendous traffic problem which would be created on the A26.

DLP_1524

Adam Willingale

Object

Standard comment as above, plus the following additional comment:

Other comments: We acknowledge another secondary school is needed, we feel the road system would support this nearer to the rugby club (Frant road + Forest Road accessed), not the Eridge Road - issues would also occur under the spa valley bridge, which already causes high vehicle problems.

DLP_1461

Rhian Taylor

Object

Standard comment as above, plus the following additional comment:

Other comments: I am extremely concerned about the above issues and as a local resident already affected by the congestion on the A26 on a daily basis, I strongly object to any development which will bring extra cars and traffic to an already overcongested area.

DLP_1489

Suzie Hawkins

Object

Standard comment as above, plus the following additional comment:

Other comments: There is so much nature and amazing wildlife on this site, it would be such a massive loss of habitat to so many animals.

DLP_1497

June Gentry

Object

Standard comment as above, plus the following additional comment:

Other comments:

Please show us proof that KCC have asked for another secondary school, please give a fair reason for taking this land out of greenbelt

If? This development goes a-head what road + safety improvement do you plan for the A26 Eridge Rd

DLP_1559

Judi Best

Object

Standard comment as above, plus the following additional comment:

Other comments: Tunbridge Wells is already 'stuffed' - with ensuing traffic problems and huge waits for any Doctors or Dentists appointments. The more you build the more people will come!

DLP_1563

Jacqui Avery

Object

Standard comment as above, plus the following additional comment:

Other comments:

My main concerns are linked to the impact on the environment. At this time of climate and ecological emergency it seems extremely short-sighted to concrete over valuable agricultural land and make the land inhospitable to wildlife. Greenbelt land is irreplaceable and is of enormous benefit to people, animals + insects. We need to encourage biodiversity and also to promote sustainable agriculture. At a time when we are unsure of the impact of brexit on our country (when we do not produce enough food to feed our population) we should not be choosing locally to reduce our ability to grow food.

As a teacher who has worked in state secondary schools in Tunbridge Wells for twelve of the last sixteen years, I strongly dispute the need for a new seconday school. In my experience the schools are fighting each other for the available students and several are already expanding.

As Outlined above, I believe strongly that we should not be building on this beautiful, valuable land, but if the decision is taken to build on it I believe strongly that it should be used for high quality affordable housing rather than for expensive homes. If TWBC is truly concerned about the education of local secondary school age children they should not be worrying about building an unnecessary school, but should instead be concerned about the number of excellent young teachers who are offered jobs in local schools and then turn them down when they realise they cannot afford to live here.

The numbers of young teachers in TW schools who live in places like Hastings and are therefore unable to offer extra-curricular opportunities to young students is surprisingly large. Please don't build on this land, but if you do, learn a lesson from the RIBA award winning council development in Norwich where residents live in beautiful, passive housing with high quality outside space for young people and old people alike.

Tunbridge Wells does not need to build in precious green belt land, and it does not need to cram in hundreds of non-descript expensive houses on the High Weald countryside that makes this such a desirable place to live. Let us make use of brown / derelict land for our housing needs and keep the distinctive AONB available for all local residents and wildlife to enjoy.

DLP_2189

Alison Vos

Object

Standard comment as above, plus the following additional comment:

Other comments:

Misleading site name - it is Ramslye farm NOT Spratsbrook which is in the Wealden. Active farmland as has been all my life 65 yrs! The green belt is not to be built on it is to stop ribbon development therefore it should NOT be built on. Site of ancient monument and ancient woodland - protecting wildlife pollution levels will be very harmful with the increase in traffic levels.

Utilities such as water supply, sewage systems will be under huge strain as infrastructure has not been properly assessed. There is nowhere to enlarge the road system.

DLP_2186

Thomas Vos

Object

Standard comment as above, plus the following additional comment:

Other comments: It is absurd to choose to build on AONB / agricultural land when brown field sites exist very near to this land.

DLP_2282

Laurel Bunker

Object

Standard comment as above, plus the following additional comment:

Other comments: In addition to point 3 above, pollution on Eridge Road is already classified as high. Further congestion will only worsen this, to the detriment of residents health.

DLP_2312

Bridget Adam

Object

Standard comment as above, plus the following additional comment:

Other comments:

The proposed site is on Ramslye Farm,not Spratsbrook farm.Spratsbrook farm is in East Sussex.

The site in question contains the remains of a Roman Hill Fort.It covers about 26 acres but has only been partially excavated so could be even larger.There was a paved road and guardhouse on the southeast side,Ramslye Farm.Achaeological finds show it was occupied about 100BC and again about AD43 when the Romans invaded.

All the excavations were undertaken by James Money, an archaeological student.

The Fort is a scheduled monument and building can only take place on the site of the surrounding landscape with the permission of the Secretary of State.It is against the law to dig on the site of a scheduled monument.

There was information about the site on the K.C.C. website until very recently stating it survives well and is a good example of a Roman Hill Fort.

I would like to know why this information was removed for no apparent reason.

DLP_2326

P Smallwood

Object

Standard comment as above, plus the following additional comment:

Other comments:

As someone who has lived in the same house since 1962 and seen the increase in traffic during that time, this road CANNOT cope with a further increase of traffic with NOISE POLLUTION and CONGESTION.

PLEASE PRESERVE GREEN TUNBRIDGE WELLS.

DLP_2342

Una Perrine

Object

Standard comment as above, plus the following additional comment:

Other comments:

As a frequent visitor to England from the USA for the more than thirty years, I always look forward to my time in Tunbridge Wells, seeing friends and acquaintances. Tunbridge Wells is unique owing to its history, the central green area known as The Common and the lovely Pantiles area with its famous Chalybeate Spring. Its proximity to so much beautiful English countryside only adds to its appeal. I was shocked to learn on my last visit a few weeks ago that plans have been put forward to build on nearby Ramslye Farm (It is Ramslye Farm not Spratsbrook as has been incorrectly stated, although I am sure that this has already been pointed out).

One of the great pleasures on my trips is the walk from Eridge Road across the farm to High Rocks and back. This peaceful, tranquil walk has always been a highlight for me, especially as some of my visits in past years have coincided with the wonderful bluebell wood in bloom.

My interest in this ancient farm and the lovely centuries old (listed) farmhouse which is close to where the public footpath begins started many years ago, when i learned that there is an iron age fort on it, and the old farmhouse may possibly be on an even older site. TO say that I was horrified that there is a proposal now being put forward to build 270 homes and a school is an understatement. Does Tunbridge Wells Council really not care about preserving the history of the town?

As very few households now seem to have only one car, a possible addition of up to 500 plus cars onto an already incredibly busy Eridge Road would seem to be an enormous problem.

Even if these homes do get built will they be affordable or will they end up like the development of apartments being built at the Pantiles which have morphed into "luxury" apartments?

Finally, I would like to add that I lived some years ago in Sedona, once a lovely town in Arizona, famous for its beautiful red rocks. My husband and I watched as local planners and politicians allowed the town to grow out of hand, aided by greedy developers. It resulted in the town being ruined, and this and the truly awful traffic jams that resulted from the unrestricted growth of the town forced us to move away. Please don't let something like this happen in Tunbridge Wells, and please don't build on Ramslye Farm.

DLP_2390

John Gledhill

Object

Standard comment as above, plus the following additional comment:

Other comments:

Lived in the area all are lives. Why should they take the fields to line somebodies pockets. And all the wild life. That will suffer.

DLP_2317

J R Leipnik

Object

Standard comment as above, plus the following additional comment:

Other comments:

The increase of traffic on a very busy road will be intolerable and dangerous. Tunbridge Wells has already had a vast increase of home building and a concrete jungle is not a privilege to land in. This idea seems to be particular members of society out to make money for themselves at the detriment of our local community.

DLP_2335

Nancy Tully

Object

Standard comment as above, plus the following additional comment:

Other comments:

"Love where you live" - I do, and I hate to think of it being spoilt.

DLP_2418

Val Gledhill

Object

Standard comment as above, plus the following additional comment:

Other comments:

It'so beautiful over the fields so many wild animals I have walked these fields for at least 55 years seen all the changing seasons please don't build here your just taking all the open spaces and it's so unfair

DLP_2426

Amy Shepherd

Object

Standard comment as above, plus the following additional comment:

Other comments: This section of the A26 is so dangerous, I have witnessed 2 serious accidents in last 6 months, cars continue at National speed limit right up to the speed camera. It is tempting standing at the bus stop - additional traffic will make this worse and the idea of more school children using the road would be very risky.

DLP_2413

Sharon Atkins

Object

Standard comment as above, plus the following additional comment:

Other comments:

In addition to the above, I fully support the need for affordable social housing which should be protected from sale. Not for house building for box ticking and financial gain by council developers! at the expense of our green belt. TW is full of new developments good + bad and I am concerned that the infrastructure is not keeping up. eg. water, drains, roads, power etc.

DLP_2675

Rebecca Cubitt

Object

Standard comment as above, plus the following additional comment:

Other comments: Traffic in Tunbridge Wells is bad enough. Why add to the problem? Air quality will become terrible and ruin this beautiful area.

DLP_3076

Simon Darby

Object

Standard comment as above, plus the following additional comment:

Further comments:

AONB/Green Belt

The proposed site is part of the High Weald AONB and Green Belt and as such should be protected from development. The damage to this beautiful area will be irreversible. As it is bordered by Friezland Ancient Woodlands and The High Rocks I wonder what the impact will be on these? Not forgetting the archaeological interest in the field itself and the ancient fort below it's surface. Lastly I fear for the impact this development will have on the local wildlife. I know of slow worms being seen in the gardens bordering this proposed site as well as bats, deer and many birds regularly being seen on the fields.

Agriculture

This is good agricultural land that has been constantly farmed for as long as I can remember. The crops planted grow well. I am sure with the removal of this valuable agricultural land there would be an impact on the air quality and possible water issues locally too.

Doctors Surgery

With the imminent closure of Rowan Tree Surgery in Showfields at the end of January 2020 there are already some major problems arising. Many people are now struggling to find a surgery that is convenient with suitable parking facilities or transport links. With this development it can only be compounded

Traffic

The increased congestion on Eridge Road will cause complete chaos and building a new school here will cause traffic problems exiting TUnbridge Wells too. Traffic in & out of the town centre will be gridlocked at peak times. The only solution for the commuter will be to use Broadwater Down & Showfields Estate as a way to bypass the traffic. These roads are already very busy at times with lorries, buses, coaches and cars, regularly speeding along.

Parking 

With the idea of a secondary school being built, I have concerns about parking issues on Ramslye and Showfields. Parking space is already precious enough as it is. Come to Ramslye Rd during the school rush hour and you can see the chaos.

Secondary School

Building a secondary school here does not make sense. With most of the local schools extending their capacity, I believe we have enough space for the foreseeable future. If TWBC do have requirement for a new school it should be built where it is needed most. MAny hundreds of children travel from Staplehurst, Cranbrook, Marden Etc, to school in Tonbridge & Tunbridge Wells every day. Does this not show the requirement for a school to be built nearer them?

DLP_3082

Sharon Darby

Object

Standard comment as above, plus the following additional comment:

Other comments:

The above site is in AONB, Green Belt and is the site of an Iron Age Hillfort. It also has good grade actively farmed land which I understand produces a good yield of crops each year - I believe that on the local plan the soil may be graded incorrectly (an ALC of land at Ramslye Farm undertaken in October 2014 by Vaughan Redfern Agricultural and Rural Development on behalf of TWBC stated the site is a mix of subgrade 3a1 and 3b. Grade 3a means it should be protected under the "Best and Most Versatile" (BMV) rules). I feel that all of these grouped together should have been enough to have this site excluded from the Local Plan.It is also next to the protected Friezland Woods. There have also been sightings of protected species such as dormice, adders and great crested newts plus many birds. The site also provides wildlife corridors between Hargate Forest, Friezland Wood & Broadwater Warren. In addition, the site is only just outside the Ashdown forest 7km protection zone.

The Tunbridge Wells Green Belt Study Stage Two (TWGBSST) prepared in July 2017 assessed the degree of harm caused by the potential loss of this site (referenced as TW10 in the TWGGBSST) as high (the second highest rating). It also assessed that the contribution of this site to the NPPF criteria for Green Belt as relatively strong (the second highest rating) in three out of the four criteria assessed. The TWGBSST presented a strong evidence base to retain this site in the Green Belt. It is not apparent from the local plan that any other site has been proposed to be released from the Green Belt that would have the high degree of harm associated with losing this site in the RTW area.

I have concerns as to how all sites have been assessed. A number of other sites (sites: 30, 99, 114, 280, 411, 434, 146) state that they are in AONB however the High Weald AONB have confirmed that this is incorrect (they are writing to you directly) and I would deem that all sites are looked at again in detail to ensure this and other information is correct.

I believe that under your scoring system this site has scored low for Heritage yet it has an Iron Age Hillfort which other sites do not have and yet other sites scored more favourable!

I believe you have stated that the site is 55.79 ha, however I think that approximately only 15 ha is available in the borough. The remaining area is in the Wealden who have deemed it unsuitable for development.

The A26 next to this site has around 23,000 vehicles a day and the site is on a nasty corner which I believe you are thinking about putting a roundabout on! (The Pembury Road has only slightly more vehicles per day). You scored Site 137 favourably on 'travel' compared to other sites which have less busy roads and better public transport. Site 146, Tunbridge Wells Golf Club on the A264 has only approximately 9,000 vehicles per day and has better public transport but received a lower score. I am wondering how many other sites may have been scored incorrectly again or been excluded because of incorrect scoring.

KCC reported in 2016 that approximately 16,000 pupils attended secondary school in Kent, of which 803 came from out of county. Given Tunbridge Wells's very close proximity to the Sussex border, it is reasonable to assume a much greater than average proportion of the 803 pupils will attend Tunbridge Wells schools than other parts of Kent. Building a school so close to the East Sussex border will only exacerbate this situation and therefore lead to even more traffic issues on the A26 as the key access. Obviously this could have a negative impact on your future emission targets.

I understand that a lot of schools in Tunbridge Wells, Beacon in Crowborough and Uplands in Wadhurst are expanding now or in the very near future; so is a school required in this area? It could be argued that a school should be built 'further out' which would potentially stop a lot of children being driven into Tunbridge Wells which would ease traffic problems for the local area - which is definitely needed. Perhaps TWBC should have gone back to government disagreeing with the number of houses to be built - do we have the support services for these extra houses with the GP Surgery in Showfields closing and our hospital already at full capacity! If we continue the way we are Tunbridge Wells will just become a concrete jungle and there will be no AONB/Green Belt left for futrure generations. We need to remember that the land is only ours to look after for future generations. Should brownfield sites be an alternative to save our AONB/Green Belt land?

An alternative site close to site 137 is Site 146. It is not in AONB as you have stated and the traffic is less, as mentioned previously. It has more regular buses and it would enable children from more areas including Ramslye, Showfields, Rusthall and St Johns to have a school within a walkable distance which would benefit more children and help them exercise on a day to day basis - it would also help you meet your emissions target. It would need some thinking 'out of the box' to ensure all routes are safe but I am sure that it could be possible. You could also potentially include children from Langton and perhaps make use of the flat paths on school days for a cycle route (this pathway is normally empty at most times). The positive is then children from potentially 5 areas would be able to reach this area by walking/cycling and get exercise at the same time which can only benefit our children and future generations of children. A number of people have informed me that this site is available however perhaps there is an issue that Dandara do not have an option on it?

I have lived in Tunbridge Wells for over 50 years and am aware that changes can be hard but are needed. However I feel that this site has not been compared equally with all other sites which could/have been put forward and I am hoping that TWBC will now look at this again on a fair, open and honest basis. It could be seen as disastrous to build on a Historic, AONB/Green Belt site when others are available which do not have the same constraints and may be regretted in years to come.

DLP_3245

Katrina Coleman

Object

Standard comment as above, plus the following additional comment:

Other comments:

Whilst walking I spotted 1 roe deer and 1 muntjac deer (protected species) on the same field, opposite sides within 45 minutes! Housing built here will not be affordable for offspring of local residents trying to get on the housing ladder and stay close to families in order to share care of grandchildren/elderly parents.

DLP_3281

Lawrence Coleman

Object

Standard comment as above, plus the following additional comment:

Other comments:

As a 21 year old Im loosing faith in the future I am inherating. All you do is take over green spaces and give nothing back!

DLP_3719

G. A. Oliver

Object

Standard comment as above, plus the following additional comment:

Other comments:

My childhood home was Ramslye Old Farmhouse and I worked on the farm for many years, both as dairyman at Strawberry Hill and tractor driver and general farmhand. I feel all development should be opposed.

DLP_3743

Jennifer Ashwood

Object

Standard comment as above, plus the following additional comment:

Other comments:

I was born in 1949 at Ramslye Old Farmhouse and spent a happy childhood there until 1964 and feel very strongly that not only as a listed property but also that the field has architecture significance, should not be developed.

DLP_3749

Florence Bennet

Object

Standard comment as above, plus the following additional comment:

Other comments: This proposal does not make any sense. All these extra people and the doctors surgery on Snowfields closing in January 2020 where are all the people going to find doctors dentists etc

DLP_3757

Norman Bennet

Object

Standard comment as above, plus the following additional comment:

Other comments:

The congestion along Eridge Road at times, and would be exasperated even more if the building problem went ahead

Ramslye road at times especially school times the road is gridlocked without adding extra traffic added to it

DLP_3288

Neville Coleman

Object

Standard comment as above, plus the following additional comment:

Other comments:

It will affect the nature reserves of Friezland Wood and Hargate Forest due to the increased human activity, it is also a feeding area for deer, badgers, foxs, swallows, buzzards and numerous other species.

DLP_3738

Christopher Oliver

Object

Standard comment as above, plus the following additional comment:

Other comments:

I strongly oppose any development as it would be detrimental to the rural nature of it is part of T.W and would cause catastrophic traffic overload for the community.

DLP_440

C D Bedford

Object

While some houses must be built, I'm not saying "Not in my Back Yard". What I'm saying is that if a development is built on that field, it is so close to the Kent/Sussex border that, should East Sussex, Wealden wish to build on the edge of their border, it would make a considerable town.

Also builders have to provide Social Housing as part of the development. I would not wish for London Borough to place their people here at the expense of the local waiting list, as was done at the post office development.

It is strange that the outbreak of grafitti in the town coincided with various developments.

DLP_7895

Joe Lester

Object

I wish to submit my strong objection to the inclusion of Ramslye Farm incorrectly named Spratsbrook Farm later changed to Land West of Eridge Road at Spratsbrook Farm which is not specific enough as Eridge Road stretches from Crowborough to well into Tunbridge Wells and Spratsbrook Farm is not in Tunbridge Wells/Kent.

Please find my points for objection below

Ancient Scheduled Monument 

The site includes and is adjacent to an Ancient Scheduled Monument, much of which I imagine is yet to be unearthed, we understand the site is around 26 acres. Iron Age/Roman Multivale hill forts are extremely rare, not to mention the High Rocks prehistoric rock shelters.

According to the NPPF paragraph 190 makes a point of “Local Planning Authorities should identify and asses the significance of the asset” and “Affect the settings of a heritage asset”.  The proposed development would destroy part of and lead to future damage to the monument as well as the surrounding landscape being completely compromised.  I don't need to elaborate how important it is that this site is protected, however I would question why a site has been deemed “unsuitable” due to it having a listed WW2 pillbox in situ, I would hope an ancient scheduled monument of “significant importance” be better protected than one of 28,000 WW2 Pillboxes?

Green Belt

The site is in the Green Belt, I would also stress that it is a greenfield site. The purpose of the Green Belt is to prevent urban sprawl and keep land permanently open. According to a TWBC Green Belt report from 2017, the site is listed as being of ​HIGH​ sensitivity.  Many sites have been deemed “unsuitable” for their Green Belt status, however this site is deemed fair game as it is “sustainable” by TWBC who are attempting to get the site taken out of the Green Belt through the local plan.  According to NPPF paragraph 134 which stipulates the five main purposes of the Green Belt.

A) To check unrestricted sprawl of large built up areas (Strongly Applies)

B) To prevent neighbouring town merging to one another (This would merge two counties as well as disregarding the adjoining limits to build)

C) To assist in safeguarding the countryside from encroachment (This development would expand the town boundary and cause severe permanent damage)

D) To preserve the setting and special character of historic towns (The setting and special character would be lost also causing severe damage to the Iron Age hill fort and its setting).

E) To assist in urban regeneration, by recycling derelict and other urban land (The site is of good grade farmland and designated as a historic farmstead).

All of the above points are valid on this site therefore it should not be de classified or developed. TWBC should be protecting the green belt not encouraging its demise, especially when the Green Belt acts to protect the Ancient Scheduled Monument on the site.

AONB

The site is located in the AONB and surrounded by the wider High Wield AONB, this land is protected and development would not just harm the site in question but also affect the wider landscape and over the years keep creeping out expanding the town. Other sites have been deemed unsuitable due to its AONB status but again this site is considered fair game.

Listed Building

Our house is adjacent to the sites southern boundary. It is a listed farmhouse that dates back to the 1600`s, however we understand there was a dwelling here long before the 1600`s. In the Local Plan our house was in fact not described as being listed, a simple Historic England map search shows the houses listed status. I would argue not for a buffer zone between us and the proposed development, I would instead argue that the development would alter the surroundings of a listed building to far from its previous settings and would therefore be deemed unsuitable.

Highways

The road infrastructure would simply not put up with the new traffic from 270 dwellings and a large school. The Eridge Road is a main entry road into Tunbridge Wells and is extremely busy and dangerous with several accidents in the past.

Noise/Air Pollution

The proposed development would significantly increase noise and air pollution. As we live at the base of a small valley sound travels from the main road several hundred yards away, the construction and future noise/air pollution would have a severe impact on our quality of life.

Ecology

The site is home to a diverse range of wildlife including a sparrowhawk which has just been added to the endangered list. Our pond adjacent to the site, a report by Wealden suggests the presence of Great Crested Newts which are protected and development must give them a large buffer.

Other Constraints

-The site is adjacent to a limits to build development

-Ancient Woodland

-Site of Specific Scientific Interest

I would question why less constrained more suitable sites have been deemed “unsuitable” by TWBC and yet this highly constrained extremely sensitive ​legally​ protected site has been “pushed” forwards by TWBC planning and local councillors. The site is in fact more constranted than all of the sites deemed unsuitable. I would also point out that seven sites deemed unsuitable by TWBC for its AONB designation are actually not in the AONB. It is lazy town planning to push this site as it is on the edge of the settlement and argue sustainability whilst disregarding its severe sensitivity.

I am also unhappy that TWBC have in my view deliberately mis named the site, after admitting some fault and changing it slightly I am still disappointed that it took several months to address this issue and not fully resolve it. TWBC has not described our house as listed, again this could be due to the fact that a listed building on the edge of the site will cause them a problem. However my main disappointment is how TWBC have been so keen on the site and have no problem trying to declassify ​HIGH​ risk green belt and destroy a​ “historically significant” Scheduled Ancient Monument.

I urge that TWBC removes this site from its Draft Local Plan.

I look forward to your response and justification for putting this site forward. If this site can be built on it would set a dangerous precedent for the future development

DLP_7939

Wendy Owen

Object

Sustainability Appraisal

This submission is made primarily in respect of site 137 but its content relates additionally to sites:

  • 30 (with 100, 199 & 205) Land at Caenwood Farm & Whitegates Farm Reynolds Lane;
  • 73 Land at Pembury Road South;
  • 99 Land at Pembury Road;
  • 114 Land at Sandown Park west of A21;
  • 116 Land South of Pembury Road;
  • 146 Tunbridge Wells golf club Langton Road;
  • 280 Land at The Midway Nevill Court;
  • 384 Land at Great Bayhall;
  • 411 Land at Sandown Park between Pembury Grange & A21;
  • 434 Tutty’s Farm Hawkenbury; &
  • 459 (with 23, 111, 214, 326, 333, 341, 383 & additional land [300 & 65?]) Land at Kipping’s Cross. (see Appendix 6: Submitted sites not included in this Draft Local Plan)

We wish to challenge the ‘unsuitable’ decisions for the sites listed above, either because the sustainability scores are inconsistent (sites 30, 73, 99, 114, 116, 146, 411 and 434) or because no sustainability appraisal was even completed (sites 280, 384 and 459). At least some of these sites are suitable for a school and therefore site 137 cannot be considered exceptional.

We wish to challenge the content and conclusions contained within the Sustainability Appraisal for Draft Local Plan (Regulation 18), which as a consequence, we consider will change the ‘suitable’ conclusion contained in the SHELAA in respect of site 137 / AL/RTW 18 to ‘unsuitable’.
We consider many of the scores in the sustainability appraisal understate the negative impact of the development of site 137. In addition, we do not consider the appraisal has been consistently carried out when compared to sites in similar positions with a similar level of sensitivity. On reading the detail, some other sites appear to have been appraised as unsuitable because a developer is no longer interested in the site (e.g. 459), whereas site 137 is considered suitable because a developer is still interested. This is not an appropriate way to develop a plan of this magnitude and developer interest should not be a contributory factor to making the case for exceptional circumstances required to release Green Belt or to develop on AONB designated land.

We attach a spreadsheet (below) which compares the sustainability objective scores and issues to consider across a selection of sites which TWBC has deemed unsuitable. As you can see from the spreadsheet, there are number of unexplainable inconsistencies. In particular we would draw your attention to the scores for:

  • Air: It is not clear how this score has been arrived at for site 137. “Air quality is scored as negative overall because of the large size of the development and likelihood that new vehicles will utilise the A26 as a through route”. “There is also a need to meet nitrogen dioxide reduction targets along the A26 in Royal Tunbridge Wells, which is identified as an Air Quality Management Area.” We can see no reason why the score should not be --/--- as per site 30 (“the substantial use of private vehicles in this location causes the noise and air objectives to score very negatively”).
  • Biodiversity: It is not at all clear why site 146 has scored so much worse than site 137. Even though site 137 is technically undesignated, the presence of protected species such as bats, dormice, adders and great crested newts should increase the negative score. The draft plan makes reference to site 137 being a Biodiversity Opportunity Area. The site provides wildlife corridors between Hargate Forest, Friezland Wood & Broadwater Warren. In addition, the site is only just outside the Ashdown forest 7km protection zone and we would expect a proper impact assessment to be carried out given the negative air quality score, as to our knowledge NO2 does not respect lines drawn on maps.
  • Education/Employment/Equality: It would appear these all score very positively compared to other sites because of the proposed siting of a secondary school. Other sites in the attached spreadsheet were also assessed for schools (sites 30, 73 & 146; 384 & 459 (mixed use) were omitted from appraisal) but they have not been scored anywhere near as positively. These scores should be reviewed and made consistent. Site 146 should also be considered alongside RTW9 (Lifestyle Motor Europe) which neighbours it & could be developed together, providing more flexibility.
  • Heritage: this score is too low and does not adequately take account of the Scheduled Monument (Historic England) that is in part in the site, along with other heritage constraints (listed buildings and historic farmstead). It is not clear why site 99 scores --/---.
  • Housing: the appraisals contain errors. With the exception of site 280, all sites listed here should be scored +++ as >150 dwellings are possible.
  • Land use: the land is ALC Grade 3a and 3b and is therefore subject to the greatest level of protection under the “Best and Most Versatile” rules; as such it should be scored as - - - . Site 146 is already developed (it’s a golf course) so should score 0 or maybe - as loss of green space.
  • Landscape: Given the site is high value Green belt, in the AONB and is so visually prominent, it should be scored consistently with other sites (30, 99 & 116) at - - -.
  • Noise: Sites 137, 30 & 146 are impacted by the Gatwick flight path to a similar extent. The A26 (site 137) currently gets 23,496 motor vehicles per day; the A264 (site 146) currently gets 9,034 motor vehicles per day. No data for Reynolds Lane (site 30). Site 137 should score --- or --/---. Site 30 should score much more favourably given its likely current traffic volume. Site 146 should score somewhere in between.
  • Services and facilities: It is not clear why this has been scored more positively than sites 30 and 146; all are similar distances to the town centre and housing (with site 30 close to a school and sports centre) so they should be scored consistently.
  • Travel: It is not clear why this has been scored so positively in comparison to sites 30, 73 & 146 (& 99). The site is on the borough/county boundary. Increased traffic is acknowledged, as is the borough’s low bus usage, and the existing cycle lanes on other sites are listed as issues not positive factors in relation to active travel. Site 146 is on the A264 which gets 62% less traffic (9,034 vehicles per day) than the A26 (23,496 vehicles per day). Development here would give a fairer distribution of traffic and less congestion; this should score ++. Site 146 also has good existing access as it’s to a golf course. There is some overlap here with services and facilities.

We also challenge why sites were omitted from the sustainability appraisal – surely the purpose of the appraisal process is to fully consider the positives and negatives, in a structured and documented way. Sites 459 and 384 are noted as “within the AONB and landscape impacts were considered too severe to warrant consideration”; can the same not be said for the sites we have listed here? We can find no mention of site 280; why was there no appraisal of this site?

On further detailed examination of the sample of sites we have used for comparison purposes, we note all are listed as being in the High Weald AONB. However, based on the maps available on the High Weald AONB website and as confirmed by the HW AONB team the following sites are within the TW conurbation and are NOT in the AONB - sites: 30, 99, 114, 146, 280, 411 and 434. That being the case, these sites previously rejected must be considered ahead of site 137 / AL/RTW 18 in order to comply with the NPPF.

We would also like to make the following factual corrections to the SHELAA for site 137 / AL/RTW 18. Firstly, the size of the site is not 55.79 ha; c.15 ha is available in the borough (with the remaining area in Wealden (with no defined boundary on the site) which has deemed it unsuitable for development). The ‘issues to consider’ section incorrectly grades the land as ALC Grade 4, Urban, when in fact the land is agricultural grade 3a and 3b – an assart field which is actively farmed. The heritage matters should more accurately record that the site includes part of a Scheduled Monument with archaeological potential (which further reduces the developable area). It is also adjacent to listed buildings and a historic farmstead. The site includes and is adjacent to ancient woodland.

We consider that any objective assessment of the site with the corrections we have highlighted, coupled with the appropriate sustainability scores as set out in the attached spreadsheet, will result in the SHELAA assessment concluding the site is unsuitable.

Furthermore, the spreadsheet we have included shows a small selection of sites with reasonable scale which have been excluded. While all of these sites appear to have been excluded at least in part because they are in the AONB/Greenbelt (which we are querying), they appear to be no more sensitive to development than site 137 / AL/RTW 18 and in some cases, as we have demonstrated, have fewer constraints. That being the case we consider that TWBC has failed in its duty to carry out an objective and thorough assessment and failed to demonstrate that all other sites have been exhausted before including site 137 / AL/RTW 18 in the Draft Local Plan (Regulation 18) and as such has not met the requirements of the NPPF.

Site 137 does not meet the sustainability requirements and is therefore unsuitable for development.
General comment

The Sustainability Appraisal of the Draft Local Plan states “To make meaningful progress towards a more sustainable way of living, it is essential that Local Plans are developed with a detailed consideration of sustainability issues from the outset. This is the purpose of a Sustainability Appraisal (SA). The process is a legal requirement under the Planning and Compulsory Purchase Act 2004…”

Table 8. Compatibility testing of Local Plan objectives with Sustainability Appraisal objectives. [TWBC: see full representationattached].

This table gives a misleadingly positive view of the compatibility of the local plan objectives with the sustainability appraisal objectives. For example, development needs will almost certainly be incompatible with heritage, landscape and noise; it is not obvious why climate change would have a positive relationship with employment and business growth. The compatibility test should be revisited.

Given the significant deficiencies in preparing this compatibility test, we consider the sustainability appraisal does not meet the legal requirements.

SHELAA issues to consider

We want to register our strong objection to any development on site 137 and we make the following points in support of our objection:

1. Green Belt designation: The land is Green Belt and it must not be released for development

We do not consider that the case has been made to release the portion of the Green Belt which is relevant to this site.

The decision to declassify any Green Belt must meet the criteria set out in the National Planning Policy Framework (NPPF). In addition, the decision to declassify should be subject to significant analysis and challenge given the permanence of the decision – i.e. once it’s gone it’s gone. The expectation set out by government in the NPPF is that new Green Belt will not be designated, therefore the barriers to declassifying should be as high as they are for classifying new Green Belt.

Paragraph 136 of the NPPF says: “Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period.” Paragraphs 143 to 144 go on to say: “Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations.”

We do not consider the local plan meets the thresholds set in the NPPF to release the site from Green Belt. Beyond a superficial statement to the effect that there are special circumstances, the plan does not present detailed arguments or evidence, nor does it consider individual sites within the Green Belt which given the differently assessed impacts would be a minimum for each site.
The Tunbridge Wells Green Belt Study Stage Two (TWGBSST) prepared in July 2017 assesses the degree of harm caused by the potential loss of this site (referenced as TW10 in the TWGGBSST) as high (the second highest rating). It also assesses that the contribution of this site to the NPPF criteria for Green Belt as relatively strong (the second highest rating) in three out of the four criteria assessed. The TWGBSST presents a strong evidence base to retain this site in the Green Belt. It is not apparent from the local plan that any other site has been proposed to be released from the Green Belt that would have the high degree of harm associated with losing this site in the RTW area.

In any case, we consider the assessment of the site in the Green Belt Study Stage 2 is incorrect. Using the published methodology, we consider site 137’s (TW10 in the Green Belt study) contribution to purposes 3 and 4 should be reassessed to “Strong”. The site’s contribution to purpose 3 “Assist in safeguarding the countryside from encroachment” is strong because it is undeveloped and is selfevidently separate from urban development. Its contribution to purpose 4 “Preserve the setting and special character of historic towns” should be changed to strong given its visual prominence and is characteristic of the AONB in being assart; the current assessment is incorrect in noting the site is adjacent to a scheduled monument when your own map clearly shows the scheduled monument is in part in the site.

Further we consider the release of this site from the Green Belt is inconsistent with the policy STR8 (Conserving and enhancing the natural, built, and historic environment). In particular, it has not been demonstrated how its release would be consistent with clauses 1, 2, 4 and 5 of that policy. If we as local citizens are to be able to rely on these policies, it is of the utmost importance that the council adheres to all of its policies and manages the inevitable tensions in a transparent and robust way. We do not consider that given the high degree of harm to the Green Belt that would be caused by its release, that this site can ever be released in a way that is consistent with this policy and we therefore urge the council to withdraw this site from further consideration.

2. AONB (2 component parts): The land is within the High Weald Area of Outstanding Natural Beauty (AONB) and is high grade agricultural land and as such it must be protected from development

Approximately half of the site sits within the High Weald Area of Outstanding Natural Beauty (AONB). The whole site is visually prominent and contributes to local recreational uses through its visual landscape, walking access to Friezland woods and being farmed. The Department for Environment Farming and Rural Affairs (DEFRA) states:

The primary purpose of AONB designation is to conserve and enhance natural beauty. Subsidiary purposes – in effect, qualifications of the primary purpose – are those defined in a Countryside Commission statement 1991, restated in 2006:

  • In pursuing the primary purpose of designation, account should be taken of the needs of agriculture, forestry, other rural industries and of the economic and social needs of local communities. Particular regard should be paid to promoting sustainable forms of social and economic development that in themselves conserve and enhance the environment.
  • Recreation is not an objective of designation, but the demand for recreation should be met so far as this is consistent with the conservation of natural beauty and the needs of agriculture, forestry and other uses.”

AONBs are designated by government to ensure that the conservation and enhancement of the landscape is given high priority. The High Weald AONB has a number of features:

  • rolling hills, dissected by steep-sided gill streams and studded by sandstone outcrops.
  • small, irregular-shaped fields and open heaths which are often the remnants of medieval hunting forests.
  • abundant, interconnected ancient woods and hedges. The dense forest which gave the Weald its name has largely vanished, but fine ancient broadleaved woodland is still abundant, particularly in the deep gills which incise the ridges. The Weald retains one of the highest levels of woodland cover in the country at over 23 per cent. Traces of the ancient Wealden iron industry, including hammer ponds, are found scattered throughout the woodlands.
  • scattered farmsteads and hamlets, largely developing from temporary dwellings in wooded areas or ‘dens’ where farmers from the Downs grazed their pigs. Buildings are characterised by distinctive stone, brick, tile and white weatherboard houses and oasthouses are common.
  • narrow, sunken lanes arising from pannage – the movement of animals from the Downs to the High Weald in the autumn to graze on mast in the area’s woodlands or dens.

The land on this site is a fine example of these characteristics and we understand it is considered to be medieval assart farmland. Given its close proximity to Tunbridge Wells, the site is currently easily accessible and available to the public for recreational purposes – its loss would clearly have a detrimental impact on the environment and the visual landscape.

We consider that in putting this site forward for consideration of development the council has failed in its duties under the Countryside and Rights of Way Act (CRoW) 2000 which reaffirms the primary purpose of AONBs: to conserve and enhance natural beauty. The CRoW sets out responsibilities for the management of AONBs. Specifically in identifying the site for development TWBC is not complying with:

  • Section 82 reaffirms the primary purpose of AONBs: to conserve and enhance natural beauty.
  • Section 84 confirms the powers of local authorities to take appropriate action to conserve and enhance the natural beauty of AONBs.
  • Section 85 places a duty on all public bodies and statutory undertakers to ‘have regard’ to the ‘purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty.’
  • Section 92 clarifies that conservation of natural beauty includes conservation of flora, fauna and geological and physiographical features.

    Furthermore, the development of the site would not in our view meet the requirements of the National Planning Policy Framework set out in section 170. Section 170 requires that Planning policies and decisions should contribute to and enhance the natural and local environment by:

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

b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland;

d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;

e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans; and

f) remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.

In permitting development on this site we consider TWBC will be in breach of all of the clauses set out above.

A development of the scale proposed for this site cannot comply with the requirements set out above in respect of AONB, BMV, CRoW or NPPF, and additionally TWBC’s own policy as set out in STR8 says:

“The urban and rural landscapes of the borough, including the designated High Weald AONB, will be conserved and enhanced;

The landscape character of the borough will be protected through retention and enhancement of the key characteristics or valued landscape features and qualities, as well as through the restoration of landscape character where it has been eroded;…

Within the area designated as AONB and its setting, development will be managed in a way that conserves and enhances the natural beauty of the area, and developers will be expected to demonstrate (through relevant documentation submitted as part of a planning application) how proposals have had regard to the objectives of the High Weald AONB Management Plan. Proposals that would harm the natural beauty of the AONB will not be permitted unless it is clearly in the public interest to do so. In such instances, effective mitigation should form an integral part of the development proposals;

A hierarchical approach to nature conservation and the protection of biodiversity will be applied across the sites and habitats of national, regional, and local importance within the borough. The objective is to achieve net gains for nature and protect and enhance sites of geological interest across the whole borough;….

The designated and non-designated heritage assets of the borough, including historic field patterns, listed buildings, conservation areas, Scheduled Ancient Monuments, archaeological sites, and Historic Parks and Gardens, will be conserved and enhanced, and special regard will be had to their settings;….”

And EN7 goes on to say “Proposals that affect a designated or non-designated heritage asset, or its setting, will only be permitted where the development conserves or enhances the character, appearance, amenity, and setting of the asset; and in the case of historic parks and gardens, provides, where possible, improvement of access to it.”

The fine words and sentiment set out in the policy that we support will be rendered empty and worthless if development on this site is permitted. Developing the site will result in its loss as a heritage and landscape asset and no amount of mitigations will meet the policy intent set out in the Draft Local Plan.

Under the NPPF TWBC is obliged to give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land before permitting the development of greenfield sites. TWBC has simply not demonstrated appropriate consideration of the impact of developing this site and should remove it from consideration in the local plan.

3. Heritage matters (adjacent to Conservation Area): additionally, the site includes a Scheduled Monument (with archaeological potential), and is adjacent to listed buildings and a historic farmstead.

The SHELAA (issues to consider and sustainability assessment) did not accurately reflect the heritage matters relevant to the site. Had all the matters been clearly listed at this stage of TWBC’s process (not later in Place Shaping Policy AL/RTW 18), we consider the site would have been deemed unsuitable, particularly when compared with the sites we have listed above. The Sustainability Assessment section says “Finally heritage score negatively due to the compromised setting of the Hill Fort (a Scheduled Ancient Monument)”, almost as if it was an afterthought instead of that status being recognised as the highest in the country. Indeed neither the SHELAA map nor the Policy map even show the Scheduled Monument.

Historic England lists Scheduled Monument references 1002280 (prehistoric rock shelters and a multivallate hillfort at High Rocks, 309m ESE of High Rocks Inn) and 1003816 (prehistoric rock shelters and a multivallate hillfort at High Rocks, 309m ESE of High Rocks Inn) and consequently the prescribed processes must be followed in relation to any development which might affect it. The Schedule of Monuments has only 19,854 entries (2016) and TWBC is urged to continue to support the protection of this site.

The draft local plan as it stands does not adequately address the requirements set out in sections 189202 of the National Planning Policy Framework regarding heritage assets. In particular, the requirements to take account of the contribution made by their setting and that any adverse impact on a scheduled monument should only be sanctioned in “wholly exceptional circumstances”. We do not accept that any case has been effectively made for wholly exceptional circumstances.

In addition, section 187 b requires authorities to “predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.” It seems clear given the overall scale of the Hill Fort it would be very likely that there lies a wealth of so far unidentified historically significant archaeology in the fields surrounding the Hill Fort and they should all therefore be conserved in accordance with section 187 b.

Organisations such as RESCUE (British Archaeological Trust) and the Council for British Archaeology have confirmed our understanding and TWBC might be in receipt of separate objections from them.

[TWBC: for map, see full representation].

A scheduled monument is an historic building or site that is included in the Schedule of Monuments kept by the Secretary of State for Digital, Culture, Media and Sport. The regime is set out in the Ancient Monuments and Archaeological Areas Act 1979 (1). Applications to schedule or deschedule a monument are administered by Historic England, who will carry out an assessment and make a recommendation to the Secretary of State.

The protected site of a monument may also include any land adjoining it essential for its support and preservation. Once a monument is scheduled any works to it, and flooding and tipping operations that might affect it, with few exceptions require scheduled monument consent from the Secretary of State, (not the local planning authority). Historic England manages the process of scheduled monument consent on behalf of the Secretary of State. Metal detecting on a Scheduled Monument is also illegal without a licence from Historic England.

Historic England has written to us stating “it should be consulted on any planning applications which is likely to affect the site of a scheduled monument. We would expect to be consulted at pre-application stage for any large development which involved work on or adjacent to a scheduled monument. Our archaeological specialists would provide advice and recommendations to the local authority.”

Additionally, the site is adjacent to two listed buildings (Ramslye Old Farmhouse and Ramslye Farmhouse), and Ramslye Old Farmhouse is a historic farmstead.
4. Highway matters: The existing road network cannot support a development of the size and nature proposed

We do not consider any development on this site can be consistent with Policy STR 6 Transport and Parking. The proposal to develop the site will add an unsustainable level of traffic to Eridge Road. Data from the Tunbridge Wells Park and Ride Feasibility Study shows Eridge Road supports almost the same amount of traffic as Pembury Road, which are both significantly busier than other access roads (see table 2 below reproduced).

Table 2: DfT Estimated Daily Traffic Flows, 2016

Road

Link

Cars, Taxis

All Motor Vehicles

A264 Pembury Road

B2023 to Blackhurst Lane 

19,408 

24,215 

A267 Frant Road

B2169 to A26

11,560

14,138

A26 Eridge 

LA Boundary to A267 

19,746 

23,496 

A264 Langton Road

A264 Mount Ephraim to A26

7,855

9,034

A26 London Road

A26 Mount Ephraim to Birchwood Avenue, Southborough

15,450

19,330

The RAC reports that in the Tunbridge Wells Borough, car ownership is 560 per 1000 population. On that basis, 270 new homes with the same occupancy rate as the current TW average (2.35 people) would add 358 cars to the current traffic flow.

There is no existing road access to the site, only a private driveway to two houses, which is in fact in Wealden - we believe the draft local plan is incorrect on this point - and a new access road would be required creating additional road safety issues on an already very busy road with poor visibility. The introduction of a roundabout for example, would adversely affect the flow of traffic on the A26, creating the sorts of tailbacks already experienced on Pembury Road. The proposal to add signals (traffic lights) on the A26 at the junction of Broadwater Forest Lane/Bunny Lane simply moves the problem of volume back down the road rather than solving it. It would be easier/safer to pull out onto the A26, but that is likely to increase the overall volume further.

In addition, school runs can add significantly to the traffic - estimates vary between 20% and 25% increases. Logistically it is not at all clear why it would be sensible or feasible to place a school serving the borough at the extreme South West of the borough. Such positioning will not only lead to an unsustainable increase in traffic on Eridge Road but also London Road (and other feeder roads) towards any school. School run traffic effectively creates four journeys (there and back twice a day) so putting a school at the far end of the borough should not be considered viable.

Furthermore, Kent County Council reports that in 2016, 16,172 pupils attended secondary school in Kent, of which 803 came from out of county. Given Tunbridge Wells’s proximity to the Sussex border, it is reasonable to assume a much greater than average proportion of the 803 pupils will attend Tunbridge Wells schools than other parts of Kent. Building a school so close to the East Sussex border will only exacerbate this situation and therefore lead to even more traffic issues on Eridge Road as the key access.

Given the Draft Local Plan has identified Capel, Tudely and Paddock Wood as areas for substantial housing development, from a transport perspective there can be no logical justification for building a new secondary school so far away from those settlements. Surely if TWBC is serious in its objective to promote active travel it should seek to facilitate that by putting new settlements and new facilities (such as schools) closer together. Placing a school in this site will in our view result in decreased opportunities for active travel and we do not agree with the assessment set out at appendix E of the sustainability appraisal document.

The Draft plan says “Reducing greenhouse gas emissions such as carbon dioxide (CO2) is critical in limiting the impacts of climate change. In 2008, the Climate Change Act set a legally binding target for reducing UK CO2 emission by at least 80 per cent by 2050”. If the Council is going to give effect to these words, it must rethink building a school so close the border.

When considered against the evidence set out above, it is clear that the current road and parking infrastructure cannot support the level of intensive development proposed without some drastic form of intervention to divert existing and additional through traffic from the A26 to the A21 to the south of Tunbridge Wells.

Further consideration should also be given to the impact on the existing residents of the Ramslye estate. The estate is currently a relatively quiet, green environment. It benefits from public open spaces that are used by the community, which adds to its character and general feel. The addition of a new secondary school will likely turn the roads into a congested car park for either school run or indeed older pupils seeking to park and walk through. We would refer you to the parking situation at the Fusion sports centre on St. Johns Road where many parking spaces are regularly taken by pupils of the neighbouring school (contrary to Fusion’s parking policy). As is the case with many semi-rural and suburban areas, many people are reliant on their cars even for short journeys.

5. Agricultural Land Classification: Grade 4, Urban

The SHELAA (issues to consider) incorrectly graded the land. Had the site been correctly graded at this stage of TWBC’s process (not later in Place Shaping Policy AL/RTW 18), we consider the site would have been deemed unsuitable, particularly when compared with the sites we have listed above.

Policy AL/RTW 18 confirms the site consists of managed agricultural land and the site is an assart field.

An ALC of land at Ramslye Farm undertaken in October 2014 by Vaughan Redfern Agricultural and Rural Development on behalf of TWBC stated the site is a mix of subgrade 3a1 and 3b. Grade 3a means it should be protected under the “Best and Most Versatile” (BMV) rules.

Note, this plan covering an area of 24.5 hectares extends beyond site 137, across the county border into Wealden.

[TWBC: for plan, see full representation].

The National Farmers Union is calling on the government to make a strong commitment to British farming to ensure a secure supply of home-grown food for shoppers after new figures put the UK’s self-sufficiency at 61%. It says “Our self-sufficiency has declined over recent years and our political leaders need to take this seriously. While we will never be completely self-sufficient as a country it is vital that Britain takes its role as a food producer for its growing population seriously and does not rely on the rest of the world. When people buy British food they are buying into standards that protect and enhance our natural resources and iconic landscapes. They are buying into world-leading standards of animal welfare, and they are buying into the role farmers are playing in combatting the climate change challenge that is facing us all. We are ready and able to drive productivity while using less inputs and in smarter ways, we are ready and able to plant bigger hedgerows, more woodland, and secure more carbon rich soils, and we are ready and able to contribute more to renewable energy combined with carbon capture and storage in our grasslands used for grazing. British farming is the backbone of the country’s largest manufacturing industry; food and drink. It contributes more than £120 billion to the UK economy and employs almost four million people.”

We should not be building on this actively farmed land, which has again provided a very good crop in this last year. In the light of declaring a climate emergency, farmland and green spaces should not be destroyed.

6. Cross boundary

The sustainability appraisal concluded there are no cross boundary issues with Wealden District Council. We dispute this conclusion. In the TWBC FOI (ref: FO08223) response supplied in respect of site AL/RTW 18 it makes reference to “likely cross boundary issues” and we understand discussions with Wealden have taken place although conveniently it would appear no notes were taken.

7. Noise – road and air

The SHELAA (issues to consider) did not list road noise as a problem. Had the site been correctly evaluated at this stage of TWBC’s process (not later in Place Shaping Policy AL/RTW 18), we consider the site would have been deemed unsuitable, particularly when compared with the sites we have listed above.

Road noise was mentioned in the SHELAAs (issues to consider) for sites 99, 114 and 116 (Pembury Road), but not for site 137. The A26 (site 137) currently gets 23,496 motor vehicles per day, and is only 3% less busy than Pembury Road. The A26 already experiences high levels of road noise.

Noise from road traffic is the second most harmful environmental pollutant in Europe behind air pollution according to the World Health Organisation.

Noise and disturbance from flights arriving at and leaving from Gatwick is a known problem affecting the local area. Organisations such as Gatwick Area Conservation Campaign (GACC), Tunbridge Wells Anti-Aircraft Noise Group (TWAANG), Communities Against Gatwick Noise Emissions (CAGNE), Gatwick Obviously NOT (GON) and Plane Wrong have been working for many years to try to minimise Gatwick’s impact. Flight paths were changed in 2014 (without consultation) and complaint numbers have risen significantly and consequently new groups have been established. Gatwick plans to substantially increase traffic by bringing its standby runway into daily use.

TWBC must fully consider the current problem as seen by residents and the scale of the problem if Gatwick is allowed to grow as planned.

From 24 hour Webtrak videos of planes crossing within audible distance of Ramslye (3km), it is calculated any new houses and a school would be exposed to an average of 221 overflights a day, half of Gatwick traffic. From DOT calculations, World Health Organisation night noise limits would be exceeded for those living there. It would be dishonest to offer houses for sale in a location which is severely impacted by Gatwick, and will be even more so if Gatwick traffic increases by 40% as per the airport’s plan.

[TWBC: for image, see full representation].

8. Ancient woodland

The SHELAA (issues to consider) did not acknowledge the ancient woodland on part of site 137 and the ancient woodland which is adjacent to the site. Had the site been correctly evaluated at this stage of TWBC’s process (not later in Place Shaping Policy AL/RTW 18), we consider the site would have been deemed unsuitable, particularly when compared with the sites we have listed above.

Site 384 is less impacted by ancient woodland yet its SHELAA (issues to consider) says “ancient woodland considerations related to access (outside of the site)”.

Landscape and Biodiversity Officer’s assessment

Set out below is an excerpt from an email from your Landscape and Biodiversity Officer, obtained via TWBC FOI ref: FO08223. This email dated April 2019 details far more issues than the SHELAA for site 137 dated July 2019. Examples: “High Rocks to the north west is a Scheduled Ancient Monument and a SSSI (Site of Special Scientific Interest) [see Draft Local Plan Appendix 1: Biodiversity/ geodiversity sites within TW borough]]. A Public Right of Way extends east west just south of the site and Friezland Wood [see Appendix 1: Biodiversity/ geodiversity sites, Local Wildlife Sites (LWS) TW23] to the north is used for informal recreation…”.

As the SHELAA was incomplete, either the site must be rejected as not suitable or it must be compared again to the SHELAAs for the sites listed above. Place Shaping Policy AL/RTW 18 makes reference to many of the issues, but this cannot be relied upon as other sites had already been discounted based on the information documented on the SHELAA and therefore an accurate comparison had not been made.

The above site, as you know is on the border with Wealden DC and Sussex, with the political boundary unusually splitting the fields in half rather than following a feature on the ground. As such information we hold on the land may be incomplete. In addition there are likely to be cross boundary issues with a number of interest and disciplines such as heritage, landscape and drainage requiring consultation with Wealden DC and/or East Sussex County Council. As part of the evidence for their Local Plan Wealden DC have produced landscape and ecological studies for land immediately adjacent in the same ownership. I have referred to this where relevant as WDC LS (Landscape Study or WDC ES (Ecology Study).

  • High Rocks to the north west is a Scheduled Ancient Monument and a SSSI.
  • An area wider that the SAM is recognised as an area of archaeological potential which may expand over a wider area
  • Ramslye Ramslye Farm is an historical farmstead and so the Farmstead SPd is relevant and should be consulted
  • Ramslye Farmhouse is listed
  • The most northerly field is surrounded by Ancient Woodland
  • The whole site has been identified in our Historic Landscape Characterisation Study as medieval and possibly an assart.

As you know a large part is within the AONB and the remainder immediately adjacent. Taking account of the location of the whole site and its immediate landscape context the AONB Management Plan and supporting guidance is considered relevant. A Public Right of way extends east west just south of the site and Friezland Wood to the north is used for informal recreation and has well used trackway connecting to the PROW network including the Tunbridge Wells Circular and land owned by the Woodland Trust. The Landscape Sensitivity Assessment places the site into ES1 generally an area of High Sensitivity but notes that immediately adjacent to the existing edge of settlement there is medium sensitivity. This broadly corresponds with the WDC LS which also concluded that the land is highly sensitive. Much of the Outline Landscape Mitigation in the Wealden report would be pertinent to this site.

The Ancient Woodland would of course require a buffer. The Council is assuming that such buffers would be 25m unless a smaller buffer is justified through detailed assessment. Despite the intensive arable use the site lies within an ecologically rich landscape of woodland, shaws, ponds and streams with significant protected areas nearby including two woodland trust sites and Broadwater Down RSPB site and Eridge Park SSSI. Protected species likely to be present include, GCN, Dormice, badgers, reptiles, breeding birds and bats. Beyond the woodland botanical interest may be significant in boundary features. The WDC ES provides some further detailed lists of species and adjacent sites.

The site fall outside the 7km zone of influence for Ashdown Forest SPA but its particular location and potential size suggest that the site would be subject to its own Habitat Regulation Assessment and that it is likely that SAMMs and possibly SANGs will be required.

Clearly this is a sensitive and challenging site. A smaller portion, outside the AONB and hard up against existing development, is a relatively straightforward proposition but any proposal for wider land use will need to be informed by suitable studies that address the above issues. Of these heritage is perhaps the most important but this in itself if linked to landscape and historic landscape features and noting the presence of the AONB makes landscape studies equally important. Studies in relation to ecology need to be developed to the point where it is clear that mitigation can be achieved and that the proposal can achieve net gain. The HRA for the Local Plan will cover the general spatial approach to Ashdown Forest but this site is likely to require its own HRA with regards to SAMMs and SANGs.

It appears from provisional mapping that the area is most likely to be grade 3 agricultural land but it is now known whether it is grade 3a or 3b and hence Best and Most Versatile or not. Either way it is in active agricultural use as arable land and has been so for many years. It is possible that he has been pasture in the past but I have no evidence of this. Landscape heritage on and adjacent the site is significant:

Name of site

It is not clear why this site is named Spratsbrook Farm, as when an Ordnance Survey map is consulted, the name Spratsbrook Farm appears on the east of the A26, on the south side of Strawberry Hill Farm. There are buildings on the west of the A26, opposite the name Spratsbrook Farm, but site 137 borders Ramslye and can much more accurately be described as Ramslye Farm. The absence of ‘Ramslye’ from the site name means local people might have overlooked it when considering the draft local plan.

Planning Portal

A number of respondents have tried to submit comments via the portal but many seem to have lost them when returning to the system later. [TWBC: Officer Name redacted] has very kindly assisted by offering to upload letters and emails etc, but inevitably doing an offline response means some aspects of the plan e.g. topic papers will have been overlooked.

Conclusion

Site 137 was concluded to be suitable because “it lies adjacent to the main urban area and is likely to be sustainable in this context. It is also adjacent to the A26 Eridge Road a key distributor road”. We have provided much evidence to challenge the sustainability assessment which is too positive and TWBC’s own study shows the A26 is already a very busy road with only 3% less traffic than Pembury Road.

Several sites large enough to accommodate a school and/or housing were concluded to be unsuitable because they are in the High Weald AONB/Green Belt/there is a landscape impact, there is heritage impact and there is high traffic. Some of these sites have been incorrectly classified as AONB and rated too highly in terms of Green Belt value. Site 137 has an Ancient Monument, yet other sites were dismissed for less significant heritage reasons. Traffic is already a major issue for the A26.

Site 137 has been scored inconsistently and more favourably than other development sites. By failing to include sites not in the AONB, TWBC’s Draft Local Plan does not comply with the NPPF requirements to demonstrate the exceptional circumstances required to develop site 137.

We have set out a compelling and reasoned case to remove this site from the Draft Local Plan.

TWBC: see supporting document – AONB site comparison

DLP_468

Corinna Woods

Object

I write to comment on the proposed development of the fields adjoining Ramslye Estate on the Eridge Road, at Spratsbrook Farm.

I have for years (20 years resident in Broadwater Down) enjoyed the walks across the fields and Ramslye Woods to High Rocks and back via Friezeland Woods.

I am concerned that this beautiful land right on the edge of Tunbridge Wells should be considered for such an extensive development. It is not only green belt and an AONB but is much enjoyed by many local people, a 'lung' for the health of the community.

  1. I am surprised that it is considered that a seven form entry secondary school is needed as there is such a proliferation of schools available . Inevitably there will be traffic issues associated with a school.
  2. While I recognise the need for social housing and some affordable housing I fear that what we will get is more expensive large properties with occupants owning numbers of cars,  again increasing the already dreadful traffic congestion.

I would support a modest development of social housing extending no further back than the rear boundary of the existing estate.

  1. Traffic has , in the years I have been resident in Tunbridge Wells, become intolerable. However the new development is planned it will only increase this problem and if land is sacrificed I would prefer to see a park and ride scheme next to Ramslye .
  2. The peaceful environment of High Rocks will be seriously altered if such a development goes ahead.

I wish, on these grounds, to object to the plan .

DLP_670

Ms Carole Freeman

Object

Re: AL/RTW18 - This is an area of outstanding natural beauty and as such should not be built on - agricultural land should not be built on - we are more than ever going to need to be more self-sufficient in this country and as such agricultural land should be closely guarded - we also need to use it in the future to maintain good air quality and natural wildlife habitat.  The Eridge Road is already used by many vehicles all day and night and 270 houses and a secondary school will promote even more traffic and pollution around the area which is not a sensible thing for council to be pushing forward and not good for the people living in the area - we do not need more polluting traffic in the area!!

DLP_819

Tim Dowling

Object

I want to register my strong objection to any development on this site (the fields adjacent to Ramslye Road and beyond it/Spratsbrook Farm) and I make the following points in support of my objection:

1) The land is within the High Weald Area of Outstanding Natural Beauty and is high grade agricultural land. As such, it must be protected from development.

2) The land is Green Belt and it must not be released for development.

3) The existing road network cannot support a development of the size and nature proposed.

4) Increased levels of noise, particulate and gas pollution, generated by significantly increased traffic levels present a serious health concern to local (and future) residents.

5) There remain a number of large, unused brownfield sites within central Tunbridge Wells which should take priority over protected Green Belt land, in terms of (re)development.

DLP_833

Jill and Graham Cowing

Object

Wish to object to Ramslye development due to impact on traffic in Broadmead

DLP_4110

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

CPRE objects to the proposed new secondary school and major residential allocation at Spratsbrook Farm.

This site is located on the East Sussex boundary within the green belt and AONB and is allocated for 270 dwellings and a seven form entry secondary school. CPRE is concerned about the impact of this development on the AONB and green belt, as well as its impact on heritage assets and its potential impact on the Ashdown Forest SPA through the traffic generated by it.

It is not clear from policy AL/RTW18 where the requirement for such a large school comes from and whether, with it being on the Kent/Sussex border, its purpose is to meet need arising from the adjoining County, rather than from Tunbridge Wells. No evidence appears to have been provided as to consideration of alternative sites and solutions for expansion of secondary education in Tunbridge Wells that would be less damaging to the AONB and Green Belt.

AONB

With regard to the AONB, paragraph 172 of the NPPF states:

“Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest”.

Planning Practice Guidance, July 2019, states:

“The National Planning Policy Framework makes clear that the scale and extent of development in these areas should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty. Its policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas. [CPRE Kent emphasis]

Paragraph: 041 Reference ID: 8-041-20190721.

AONBs together with National Parks have the highest status of protection in relation to landscape and scenic beauty.  For National Parks “the Government recognises that the Parks are not suitable locations for unrestricted housing and does not therefore provide general housing targets for them. The expectation is that new housing will be focused on meeting affordable housing requirements, supporting local employment opportunities and key services”

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

On this point the Glover Review (Landscapes Review 2019) sets out how important it is that the “needs and requirements of the local community will be met within the broader context of achieving sustainable development appropriate to these nationally important landscapes” and how  AONBs “should not be the place for major intrusive development” (pages 62/63). Building homes in the AONB isn’t ruled out completely, with the report acknowledging that “we need more homes in the countryside, including in national landscapes, but in small numbers, built beautifully and made affordable” (page 105).

Green Belt

This site falls within Broad Area 7 in the Green Belt Study Stage 2.  Stage 2 figure 1.1 indicates that there would be very high level of harm caused by the release of this broad area.

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

DLP_3594

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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 270 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/RTW 18

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

DLP_2905

Chris Gow

Object

Green Belt land and AONB and a small area of Ancient Woodland on part of the site, with the site adjacent to Ancient Woodland to the north...

There is no way this land should be considered for any development.

DLP_2906

Chris Gow

Object

I object to this development.

It is Green Belt, ANOB, and comprises small areas of Ancient Woodland on part of the site so there is no way this should be developed.

DLP_4547

Historic England

 

Policy AL/RTW 18 – this site, Land West of Eridge Road at Spratsbrook Farm, includes part of a Scheduled Monument (High Rocks), a hill fort which straddles the Kent and East Sussex boundary (Kent 399 & ES 196 or NHLE 1003816). Although a green buffer to the schedue=led are is suggested within the policy we are concerned that this, in itself, will not provide adequate protection to the mounumnet or its setting. The council should consider including more detailed protection or mitigation requirements into the policy, including a prerequisite to prepare a conservation plan for safeguarding and the ongoing mangement of the monument.

DLP_3829

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_1826

Royal Tunbridge Wells Town Forum

General Observation

Policy Number:  AL/RTW 18 Spratsbrook Farm 

This is a more difficult site than appears at first glance as is shown in the SHELAA assessment, particularly as the landowner is understood to have acquired other adjacent land in Wealden District for potential development. This site is Green Belt and AONB and should only be developed upon evidence of exceptional circumstances.

There are some particularly significant landscape issues with regard to the rising ground furthest from Eridge Road to the west of the site as the grassland there appears to be highly visible from the Beacon Hotel and Rusthall Common and any urban development here would destroy the apparent continuity of undeveloped AONB landscape stretching to the horizon and Crowborough Beacon. If the site is developed, this area should be retained as a protected open green space as playing fields (in conjunction with the proposed secondary school which should therefore be adjacent) and/or recreational land, without any encroaching buildings. This would also allow mitigation to the setting of the adjacent Ancient Monument hill fort further to the west.

The remainder of the site appears to have potential for the local secondary school which will be required in the southern quarter of the town given the significant residential expansion taking place at Hawkenbury, the proposed residential development adjacent to Ramslye also on the Spratsbrook site, the proposed remodelling of part of Showfields and other long term development potential in the south of the town.

If exceptional circumstances should be made out, any housing development on the site should seek to ensure a much greater housing density than has been achieved on the Berkeley Homes development at Hawkenbury in order to justify incursion into the Green Belt/AONB. Also the proportion of affordable housing should be increased, at least to the new general level of 40%, with some significant social rented housing adjoining the Ramslye estate. We welcome the draft housing policies that seek to achieve this objective.

Adjustment of the 30mph limit zone would be required, the more so if the idea of a secondary school is pursued, with new active travel routes into the town as proposed. It should be noted that, if the West Station were to be re-opened to public rail services, it would be particularly useful as a public transport hub for this site, being within walking/cycling distance and mostly under one mile distant.

DLP_4276

RTW Civic Society

 

Point 2.  Please explain the purpose of the cycle link to the Ramslye estate.  We are not aware of a cycle path from Ramslye to the town centre.  Will one be developed?

DLP_3418

High Weald AONB Unit

Object

The proposal is major development partly within the AONB which has not been adequately justified under paragraph 172 of the NPPF. The part of the site within the AONB is a medieval aggregate assart field (1066-1499) and adjacent to Friezland Wood which is ancient woodland and a local wildlife site. Ramslye Farm is likely to have been a historic farmstead, so there could be important archaeological remains.

DLP_4684

CBRE Ltd for Dandara Ltd

 

Land to the west edge of Eridge Road at Spratsbrook Farm

4.71 The site comprises undeveloped, managed agricultural land, that is located adjacent to Royal Tunbridge Wells. It is bound to the north and east by a mix of residential, commercial and educational uses. The southern allocation boundary forms the TWBC/Wealden District Council administrative boundary. The boundary forms an arbitrary line through the large field it runs through and is not recognisable by a hedgerow, Public Right of Way, etc.

4.72 Dandara controls further land to the south of the allocation boundary within Wealden DC and has promoted (and continues to do so) these land parcels through the emerging Wealden Local Plan. These further land parcels are considered by Dandara to be suitable and available for development and, whilst supporting the TWBC allocation for the site, Dandara considers that the allocation should recognise the potential for future development (including infrastructure linkages) within the Wealden DC parcels. A Site Location Plan is included in Figure 4 below.

[TWBC: for Figure 4, see page 24 of full representation].

4.73 The site (site ref. RTW18) is allocated for release from the Green Belt in the Draft Local Plan to facilitate the development of approximately 270 dwellings and a seven-form entry secondary school. The implementation of this development will require associated infrastructure and transport works.

4.74 Land to the west of Eridge Road at Spratsbrook Farm was assessed as part of the Strategic Housing and Economic Land Availability Assessment in July 2019. The assessment concluded that the site is a sustainable location for development, given the adjacent urban area and its close proximity to the A26 Eridge Road. In addition, the assessment noted the availability of the site, the benefit of it being in single ownership and that it is deliverable within the Plan period. Dandara supports this assessment, the allocation of the site and the vision for its development.

4.75 In order to ensure that the site allocation is in accordance with the NPPF (paragraph 35) tests of soundness; positively prepared, justified, effective and consistent with national policy Dandara provides the following comments in relation to this site:

Policy AL/RTW18 ‘Land to the west of Eridge Road at Spratsbrook Farm’- Dandara notes the following:

4.76 In the adopted Development Plan for TWBC, the Land to the west of Eridge Road site is within the Green Belt. The western portion of the site is within the High Weald Area of Outstanding Natural Beauty (AONB).

4.77 The site is adjacent to the current Limits to Built Development of Royal Tunbridge Wells, to the north and east. There is a Schedule Ancient Monument abutting and within the western part of the site.  Close to the north-western and northern boundary of the site is the Eridge Railway Line. There is a listed building (Ramslye Old Farmhouse) adjacent to the site, to the south which connects to the A26 Eridge Road via a track.

4.78 The site is well situated close to the Ramslye neighbourhood to the south west of Tunbridge Wells and is an ideal location for a sustainable urban extension. The site itself is suitable for residential development (as concluded by TWBC in their SHELAA (July 2019), factoring in its relatively flat topography, sustainable location and good access from the A26 Eridge Road. Furthermore, the site is located in a Flood Zone 1.

4.79 The site is located in a sustainable location on the edge of Royal Tunbridge Wells and is accessible by range of sustainable transport modes including approximately a 15/20 minute walk, 7 minute cycle or 5 minute bus journey Sainsbury’s and The Pantiles beyond. By car, the site is approximately a 4 minute drive to The Pantiles (1.1 miles), 4 minute drive to Royal Tunbridge Wells Railway Station (1.3 miles). The site is served by a number of bus stops along Eridge Road.

4.80 TWBC has undertaken a Green Belt review: ‘Tunbridge Well Green Belt Study Stage 1 (November 2016) and Stage Two (July 2017) as key evidence base to support the emerging Local Plan. As part of this review and as set out in paragraph 4.49 of the Draft Local Plan and TWBC’s Distribution of Development Topic Paper (September 2019) TWBC considers that there are exceptional circumstances for the release of Green Belt land associated with the delivery of a secondary school and new homes in a sustainable location in accordance with paragraph 135 of the NPPF. Dandara supports this.

4.81 Identified growth at Spratsbrook Farm will therefore benefit further from the site’s existing accessibility and good public transport connections to Royal Tunbridge Wells. The site also does not require significant infrastructure investment to facilitate the delivery of new homes. The site is available now and can be delivered early as there are no barriers to delivery.

4.82 Under Policy AL/RTW18 the site is allocated for approximately 270 dwellings and a sevenform entry secondary school. Dandara supports this allocation.

4.83 The site has capacity for circa 250 – 300 new homes and a new school based on initial feasibility work undertaken by Dandara and consideration for the site’s constraints, particularly its landscape sensitivity and surrounding heritage sensitivity.

4.84 Dandara has commissioned Turley Associates to provide initial heritage advice which will help ensure any scheme will protect the appearance and setting of the existing heritage assets which surround the site.

4.85 Initial engagement has been undertaken with Kent County Council Highways and Transportation regarding the access strategy for the site, which has been accepted in principle.  4.86 Dandara supports the objective of promoting non-car access between the site and the town centre, including through the incorporation and enhancement of the existing Public Rights of Way network and contributions to a holistic package of sustainable transport mitigation measures for the urban area.

4.87 Dandara has also commissioned DHA to provide an assessment of transport and flood risk issues to ensure these matters are considered early, inform the design and scheme layout and are not a constraint to development.

4.88 In respect of the final paragraph, point B of Policy AL/RTW18, we note that the list of contributions that may be required includes secondary school contributions. As the site allocation includes the provision of a seven-form entry secondary school, Dandara proposes that this be amended to primary school contributions only.

4.89 All such contributions should be necessary to make the development acceptable in planning terms, be directly related, and fairly and reasonably related in scale and kind. All infrastructure requirements will need to be viability tested and provision justified in order to meet the relevant tests.

4.90 Dandara welcomes the need for new school places and to seek investment in local schools in response to the anticipated level of housing growth, and to ensure its delivery as part of a holistic new community.

4.91 Point 7 of the policy requires investigation of the provision of soft landscaping buffer along the south-western boundary with(in) Wealden District Council. As addressed earlier, we consider that the policy (and appropriate clause) should be amended to recognise the ability for future development within Wealden DC as well as associated infrastructure. This is considered to be important having regard to a potential uplift in housing needs/securing a higher buffer in the Local Plan, as well as to ensure appropriate delivery in the Housing Market Area through Duty to Cooperate. This is particularly important given Tunbridge Wells’ status as the regional town serving the needs of a number of authority areas. We would therefore propose the following clause be inserted: “Provision for appropriate linkages including development and associated infrastructure within land to the south (within Wealden District Council) is recognised and to allow for potential future development”.  Housing Trajectory

4.92 In TWBC’s Draft Local Plan housing trajectory, the first phase of parcel RTW18 for the delivery of 70 homes is due to commence in 2024/25. 70 homes per annum will be delivered between 2024/25 – 2026/27 with 60 homes to be delivered in the final phase in 2027/28.

4.93 In transport terms, the site benefits from ready access to the A26 Eridge Road and the wider Tunbridge Wells urban area, with strong opportunities to promote non-car travel amongst residents, staff and pupils. As such, it does not require significant enabling highways infrastructure which could allow delivery of this site to come forward sooner.

4.94 The site is suitable for housing, available and deliverable within the first 5 years of the Plan period. Dandara suggests TWBC’s trajectory should be adjusted slightly to facilitate the earlier delivery of Spratsbrook Farm, commencing in 2023/2024.

[TWBC: see full representation].

DLP_4915

Woodland Trust

Object

AL/RTW 18 Land to the west of Eridge Road at Spratsbrook Farm, Royal Tunbridge Wells

We have particular concern about the allocation of site AL/RTW 18 Land to the west of Eridge Road at Spratsbrook Farm, Royal Tunbridge Wells, which is adjacent to the Woodland Trust site at Friezland Wood.

Without appropriate site layout, substantial buffering, and sensitive management both during construction and operation, any development risks harmful impact on Friezland Wood and failure to comply with the requirement to deliver net gain for biodiversity, in line with draft Policy EN 11.

Friezland Wood is an ancient woodland, a woodland significantly affected by ash dieback, with potential tree safety concerns for any neighbouring houses, a SSSI, and contains a scheduled ancient monument.

We provide free public access to woods for quiet, informal recreation and our woods are managed to make them accessible, welcoming and safe. The site allows for quiet informal recreation as a contrast to the more active pursuits taking place on and around the privately owned High Rocks. The Trust supports low-key public access to Friezland Wood by maintaining entrances and infrastructure as necessary. There is very limited parking on site.

We are concerned that adjacent development could harm the tranquillity of the site, and that encroachment on its edge could adversely affect its environmental quality and its value as a natural habitat. The proposal for a school on site is likely to generate larger volumes of noise and traffic than residential development alone.

If this site allocation does go ahead, despite our concerns, then as a minimum we would ask for strengthened conditions to include:

  • Locating built elements at the areas of the site away from the ancient woodland
  • Ensuring that construction site access is away from the ancient woodland
  • Ensuring that traffic access to any future development is away from the ancient woodland
  • Reserving a proportion of S106 and/or CIL monies from the site for enhancing the protection of Friezland Wood
  • Where appropriate seeking to improve pedestrian access to Friezland Wood for low key leisure, in line with the Woodland Trust’s management plan for the site.

DLP_2468

Mrs Emma Lester

Object

Draft Local Plan Site; AL/RTW18 Land West of Eridge Road at Spratsbrook (Ramslye) Farm Site 137 

Comment

We object to the proposed inclusion of site AL/RTW18 Land West of Eridge Road at Spratsbrook (Ramslye) Farm Site 137 in the Draft Local Plan.  Firstly, as you are aware the incorrect naming of this site as Spratsbrook has caused confusion and initially any contact we had with TW Planning Dept regarding this was ignored, Spratsbrook Farm is in Wealden, not adjacent to the site or a well-known farm in the area, we feel this has knowingly misled people as to the exact position of this very sensitive and highly constrained site. ‘Land to the West of Eridge Road’ does not define Ramslye Farm (could be the Garden Centre site) and you can’t expect people to scroll through 518 pages of the Draft Local Plan to find a site map on page 108 which is not identified correctly in the Contents page.

Landscape

The site is Green Belt, around half the site ANOB, adjacent to Limits to Build, adjacent to 18 acres of Ancient Woodland, (Friezland Wood and Ramslye Wood), a County Wildlife Site, listed buildings, a Historic Farmstead, Historic Landscape and an Ancient Scheduled Monument (all reasons other sites were found to be unsuitable).

The fields are high quality 3a/3b Grade activity farmed land (see attached Land Classification filenot‘Grade 4 Urban’ as stated in the SHELAA. The National Farmers Union have requested a commitment from the Government to not build on actively farmed land, as a country we are only 61% self-sufficient and with leaving the EU this level should not fall, a ‘very good’ crop was harvested this year as it has been for centuries.

These fields are some of the only, if not the only, actively farmed fields left in central Tunbridge Wells, they have been enjoyed for generations by people walking the footpaths to the Woods and High Rocks we are lucky to have such beautiful open fields readily accessible to the people of Tunbridge Wells to exercise in and enjoy the countryside.

Green Belt– In the Tunbridge Wells Green Belt Study July 2017 the site TW10 was shown as having the following level of harm if removed from the Green Belt;

Purpose 1 – Check the unrestricted sprawl of large built up areas - relatively strong

Purpose 3 – Assist in safeguarding the countryside from encroachment – relatively strong

Purpose 4 – Preserve the setting and special character of historic town – relatively strong

Overall level of harm from removing site from the Green Belt –High

Therefore, there is no good reason to remove it from the Green Belt. The Green Belt also protects the Ancient Scheduled Monument.

Wealden rejected their part of these fields for development as it would have an ‘unjustified impact on the character and appearance of the landscape’. It also stated, ‘the part of the site adjacent to the Scheduled Ancient Monument has extensive tree coverage and ancient woodland making this area unsuitable for development’.  How can TWBC find the site suitable and Wealden find the same fields unsuitable?

This site would cause Urban Sprawl by joining Kent and Sussex, other sites in the SHELAA were deemed ‘unsuitable’ for joining villages to Tunbridge Wells, this would merge two Counties – one of the purposes of Green Belt.  Green Belt should only be built on as a last resort, there are plenty of sites available not in the Green Belt.

Highways

The A26 Eridge Road is a major route into Tunbridge Wells from Newhaven, Brighton, Uckfield, Crowborough, a very busy road with c. 23,496 motor vehicles using it every day, only Pembury Rd is busier by c. 3%.  The junctions of Bunny Land and Broadwater Down are hazardous with large lorries turning up Broadwater Down to avoid the low railway bridge or to reach A21. Broadwater Down, Broadmead and Bunny Lane, all residential roads with on street parking, would become rat runs at school time.  The roundabout at the base of Broadwater Down mentioned by Cllr Woodward would need to be a significant size for the large lorries that use the junction (often getting stuck or causing accidents) along with traffic accessing the Cemetery, it would cause a bottle neck for traffic coming into Tunbridge Wells which is already nose to tail at rush hour.

The vehicle access to the site mentioned is not a public highway, it is a private single track to access the properties adjacent to the site and is in Wealden, it is also a hugely popular Public Footpath leading to the High Rocks one of Tunbridge Wells best known Landmark and Heritage Asset.

The proposed ‘link’ for cyclists and pedestrians in Ramslye Road would inevitably become a ‘drop off’ point for parents, Ramslye Road is already congested with residents on road parking and an existing Primary School which has recently been extended and has a capacity for 330 children – the added traffic would put those children in danger and increase pollution – Ramslye Road is already chaos at school time, many of the properties are maisonettes/flats which increased the number of cars per property.

When Dandara’s development of Union House also on Eridge Road is completed the 127 apartments will generate even more traffic on this part of the A26.

Secondary School

We challenge the need for another Secondary School in Tunbridge Wells, many children are bussed into Tunbridge Wells to attend school from Kings Hill, Maidstone, Sevenoaks etc a study of where most children come from should take place and a new school built there.  Both Huntleys and Ridgeway Schools were closed, and the sites developed for housing and now KCC want another school! At present Bennett, St Gregory’s, TW Boys Grammar and Skinners are all expanding in size and struggling to recruit teaching staff.

A school at this site on the very edge of town would require most pupils to be driven/bussed in, the Tunbridge Wells Golf Club site on Langton Road would allow pupils to walk from Rusthall, Langton, Ramslye, Showfields, St John’s reducing pollution from cars by allowing children to walk to school, Langton Road is a much quieter road than Eridge Road and the site is previously developed and easily accessed.

Historic Issues

Ramslye Farm is a Historic Farmstead, with Listed Buildings dating from 1600 and 1700, there is a belief the Old Farmhouse site dates back to Saxon times.  The same Mesolithic and Neolithic rock formations are on the farm as found at the High Rocks Shelters – the proposed development would cause ‘substantial harm’ to this Historic Farmstead, destroy its setting and damage the adjacent heritage assets.

(see attached historical article - Ramslye Ancient Homestead)

Ancient Scheduled Monument – Iron Age Multivallate Hillfort

The fields are home to a 26 Acre Iron Age Multivallate Hillfort which is an Ancient Scheduled Monument, it was partially excavated in the 1950’s.  It is an unusual site as the Hillfort was built c. 100BC on the site of earlier Mesolithic and Neolithic Rock shelters (The High Rocks) and later occupied by the Romans after their invasion in 43AD - this means the site is Pre-historic, Iron Age and Roman.  Many Iron Age and Roman artefacts have been found in the fields and further Ramparts discovered by the pinch-point in the fields where we understand the paved access road and guardhouse once stood.

An article on the Kent County Council Website states …..

It (the Hillfort) survives well and is a good example.  Partial excavation has indicated that the earthwork defences will retain evidence for construction techniques employed during the Iron Age whilst the interior will retain evidence for the occupation of the Hillfort, the economy of its inhabitants and subsequent Romano-British Occupation.  The prehistoric occupation site within the bounds of the later Hillfort is an unusual occurrence and will retain archaeological information and environmental evidence in relation to the rock shelters and the surrounding landscape at the time of occupation.

The Hill Fort is an Ancient Scheduled Monument and therefore it and its setting are protected and according to the 2019 NPPF para 194 ‘Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting) should require clear and convincing justification’. Substantial harm to or loss of a Grade II listed building, or Grade II registered parks and gardens should be exceptional; and assets of the highest significance, notably Scheduled Monuments, should be wholly exceptional. This policy alone is enough to argue the case against this development.  The historic setting of the Hillfort and a Grade II Listed building would be greatly harmed with no convincing justification, the council has not demonstrated that no alternative site can be found for this development.  The site has only been partially excavated therefore the landscape surrounding the Hillfort with its multi-period connections still awaits further detailed research and survey. Development of these fields will damage part of the fort and completely destroy its setting, which is at present uncompromised, it will also mean any further parts of the Hillfort which may lie undiscovered will be lost forever.

Heritage assets such as these must be preserved for future generations, we are custodians of this earth and must not destroy such sensitive sites.  The High Rock Shelters are also protected and adjacent to the site so the proposed development would affect their setting.  These are Designated SSSI sites because ‘it is a key geomorphological site for sandstone weathering features developed on the highest cliffs in the Weald’  (Source – Ecology Report 2016)

Wildlife

The Farm is home to an abundance of wildlife, deer roam the fields, dormice, bats, snakes and many species of birds live here including Buzzards, Sparrow Hawk, Kingfishers, Swifts, Lapwings, Herons, Pheasants and Ducks wander the footpath, a colony of slow worms live in the fields and the ponds adjacent to the site are home to newts and other reptiles.  An Ecology Report carried out by Wealden in 2016 by Chris Blandford Associates states ……the sites location, adjacent and close to several areas of Ancient Woodland and High Rocks SSSI increases its value and sensitivity.  The site has potential to support notable/protected species.

Conclusion

This site is totally unsuitable for development, to lose this food producing farmland and damage a Scheduled Monument and its setting is not justified, this is a very sensitive site and its assets should be protected.   Many other sites deemed ‘unsuitable’ in the SHELAA had far fewer constraints than this site.  With all these constraints if you can build on this site you can build anywhere – and that sets a dangerous precedent.

We feel during dealings with the Planning Department and our local Councillors there has been a bias towards the site, we understand Cllr Woodward voted in favour of the site going into the Draft Local Plan on the understanding there would be 40% affordable housing, yet we were told at the RVP exhibition there will be no affordable housing as Dandara are building a school for free. There are other more suitable site which we feel have been over-looked, the SHELAA played down the constraints and contained many errors regarding this site and gave other sites incorrect ANOB status which have been laid out in the Residents Against Ramslye Development’s official response.

We understand the school will be built for free by Dandara if they can build 270 houses – is the site big enough for such a large development and does it justify losing such a Historic Farmstead where the fields have been enjoyed by the people of Tunbridge Wells for generations and causing irreperable damage to a significant Ancient Scheduled Monument – how many Iron Age Hillforts or join Pre-Histroic, Iron Age and Roman Archaeological sites are there in Tunbridge Wells?

The local Doctors Surgery has recently closed, can the Tunbridge Wells sewage and water system sustain such a development.  The SHELAA states the site is ‘sustainable’ but doesn’t explain how.

I would also like to point out accessing the portal to object has been problematic – so many people have had difficulties and I am sure it has proved too much for some people - so they have given up!  However, Kate Jelly has been a great help to us, and we are very grateful to her.

We would ask that you reconsider the inclusion of this site due to the highly sensitive nature of this much loved and productive ancient part of Tunbridge Wells.

Paul and Emma Lester

DLP_1572

Mr John Hurst

Object

Green Belt - do not develop

DLP_2049

Terry Everest

Object

Strongly Object

This is Green Belt land within the AONB and contains ancient woodland.

None of this is replaceable and this site should be protected not developed.

The fragility of Ancient Woodland means that it really needs a buffer between it and development - usually any attempt to move ancient woodland is ultimately unsuccessful as the setting, soil and position is too alien for this form of mitigation / remediation to succeed long term.

DLP_1552

Cllr Keith Obbard

Object

AL / RTW 18             Land West of Eridge Road at Ramslye / Spratsbrook Farm

I wish to register my objection to any development on this site, and make the following comment in support of my objection.

This submission is made as a personal comment, in my capacity as Wealden District Council (WDC) Member for Withyham, and does not represent the position of WDC, Withyham Parish Council, or the Wealden Green Party.

The Tunbridge Wells Borough Council (TWBC) Draft Local Plan identifies this site as Green Belt land, within the High Weald Area of Outstanding Natural Beauty (HW AONB), with areas of ancient woodland, a scheduled ancient monument, and listed buildings nearby.

The proposed development sites consist of good agricultural land, and make an effective buffer between the existing edge of the Tunbridge Wells built up area and the open Countryside of East Sussex. [National Planning Policy Framework (NPPF) para 134 ]

Green Belt land can only be released for development in exceptional circumstances [ NPPF para 136, 137] and Local Authorities have a duty to protect the AONB. [Countryside & Rights of Way Act 2000]  TWBC has not demonstrated any exceptional circumstances.

The National Planning guidance requires great weight to be given to conserving and enhancing the landscape and scenic beauty of AONB’s and planning permission for major developments should be refused. [NPPF para 170, 172]

The High Weald AONB Management Plan has been adopted by all the relevant local authorities, including TWBC. One of it’s objectives is to “seek to prioritise the delivery of new housing primarily through small scale development and a mix of housing sizes that responds to local needs” [ Settlements; S2] This would be a major development that changes the character of the area completely, and will swamp the locality with extra traffic from all across the Borough and from across the County Border.

The site is visually prominent within the wider landscape of the AONB.

When the adjacent area was assessed by the Wealden District Council (WDC) as part of their Strategic Housing and Economic Land Availability Assessment (SHELAA) in 2017/18 it was assessed as having very high landscape sensitivity and very high landscape capacity, and therefore unsuitable for development. [ WDC SHELAA  729/1610]

The site borders the Ashdown Forest Special Protection Area and Special Area of Conservation (SPA & SAC) 7 km zone of influence and any development will have an adverse effect on the SPA & SAC due to the increased traffic emissions, and the increased recreational pressure arising from the population increase.

The proposed development of 270 houses and the approx 1,000 pupil secondary school will result in an increase of cars, buses & commercial vehicles in excess of 1000 extra traffic movements per day, on to a road system that is already suffering congestion and blockage at peak times.

In the light of declaring a climate emergency, the Green Belt and AONB   should be enhanced by more tree planting and enriching natural habitats, not destruction.

This development will not make a positive contribution to biodiversity, or a Net Gain for Nature.[TWBC Policy EN11]

The total number of new houses put forward in the draft plan has been called into question by the 2016 revision of the Office for National Statistics method for calculating housing need, which reduces the calculated housing need for the Borough by about 30%,  so for this reason also, the TWBC has not demonstrated there are exceptional circumstance sufficient to harm this site.

ENDS

DLP_2369

J Jenner

Object

Ramslye Development AL/RTW 18 Site No 137

I should like to register my objection to the above planning proposals.

The area concerned is Green Belt, AONB and productive agricultural land, with 2019 also producing a good rapeseed harvest, which encourages the abundant wildlife here.

There are obvious access and traffic problems in the area, including many continental Heavy Goods Vehicles using this main route to and from Newhaven.

According to KCC Education and TWBC Infrastructure Plans there is no foreseeable requirement for a new secondary school or the proposed number of houses, and should the need arise a better site would be the north side of Tunbridge Wells.

The protection, preservation and improvement of the environment for the future and welfare of the next generation is an exhortation to which we should all pay heed.

DLP_2364

P C Jenner

Object

AL/RTW 18 Site No 137

I wish to register my objection to the proposed development at Spratsbrook Farm (Ramslye Farm).

It is impossible to overstate either the environmental importance of this Green Belt site designated as an AONB or the impact the additional traffic created by such a large development would have on an already very busy and frequently congested main road into Tunbridge Wells.

At a time when all the predictions point to climate change and the increasing importance for everyone of food production and conservation, a decision allowing a development of this size here would not only be irresponsible but also an act of rural vandalism.

The area casually marked on an Ordnance Survey Map is not just some low grade semi-agricultural site of secondary importance, but totally irreplaceable highly productive farmland, as well as a major habitat for abundant and varied wildlife. There can be no question regarding the quality of this farmland. I have lived on it for almost 50 years and knew the last tenant farmer very well, and know these fields are capable of producing very high yields. Now, with the potential effects of global warming we should all be alarmed at the loss of any perfectly productive farmland.

Also, because this site has been designated an AONB it qualifies as being protected, but this is now at risk of being disregarded on the grounds that it has become 'available'. If this flexible approach were applied to designated listed buildings simply by becoming available, many would certainly have been snapped up by developers and would have disappeared under bulldozers.

Objectors cannot be accused of 'nimbyism' as this proposal is not about building a few dwellings here and there around the borough to allow the local authority to achieve its house building obligations, and to which few people would object. This amounts to massive land grab to build a new settlement on precious farmland.

DLP_3134

Teresa Stevens

Support with conditions

Would access be via the existing Ramslye estate or directly onto the A26? Would the Secondary school be on the A26 side of the site and the 270 homes be towards the High Rocks in? Given the proximity to the A26, wouldn’t a Park & Ride facility be a good idea? Still create a new school (assuming it is necessary) but less homes.

DLP_3115

Andy Bashford

Support with conditions

Would access be via the existing Ramslye estate or directly onto the A26? Would the Secondary school be on the A26 side of the site and the 270 homes be towards the High Rocks in? Given the proximity to the A26, wouldn’t a Park & Ride facility be a good idea? Still create a new school (assuming it is necessary) but less homes.

DLP_3208

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

Paragraph 2 – “Links from the site to be provided to the existing public footway network in the vicinity of the site and cycle and pedestrian links between the site, the adjacent Ramslye estate and into the town centre and train station.”

Additional paragraph: Improved public transport links are required to serve the residential aspect and the secondary school. Provision of a bus only link between the school site and Ramslye Road.

The standard paragraph regarding contributions should also 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

KCC supports the specific policy reference to PRoW in paragraph 2, as new path links would be a valuable addition to the existing PRoW network. However, attention is drawn to the railway line along the northern boundary of the site, which currently acts as a barrier to north-south movements. Consideration should be given to policy measures that can address this barrier and improve connectivity with the surrounding PRoW network.

Heritage Conservation

Scale 1 - Development of this site (or part of) should be avoided

Site contains designated heritage asset of High Rocks hillfort and Scheduled Monument of Iron Age date. Associated remains are likely to survive on this site and there is potential for early prehistoric remains.

The County Council from a heritage perspective would prefer that this site is removed from allocations.

Archaeological DBA essential. The County Council considers that safeguarding measures are needed to ensure no impact on the Scheduled Ancient Monument. Historic England must be consulted and predetermination works essential.

DLP_3501

R Fitzpatrick

Object

1. All Policies (Apply to AL/RTW 18)

A Council should not harm the interests of its electorate by determining property developer margins more important than its electorate's environmental interests. A Council's green field sites should not be delivered for building development while any brown field sites remain undeveloped in its area. If central Government takes over the development authority of a Council in order to accelerate its building developments it should not harm the interests of the local population by determining property developer margins more important than the local population's environmental interests.

(Breaching the protections of the Green Belt site of farm land and AONB AL/RTW 18 should be removed from development candidature while brown field sites such as AL/RTW 11 and others half a mile away lie derelict.)

2. Transport

The plan is deficient in respect of not citing possible consequences within its plan period of changes to the national/international transport model giving rise potentially to fundamental alterations in street scene and town and logistics planning:- fuel changes causing land use changes; the end of vehicle ownership ending garage use and street parking; automated vehicles ending the provision of buses and imposing new traffic flow and mass taxi storage requirements; new uses for car parks.

(While none is yet plan-worthy the absence of citation is akin to planning for horse-troughs, stabling and pastures in 1905. The only reference is Para 8.3.3 of Draft Residential Parking Standards Topic Paper August 2019 that the Plan relies on "the....expectation that residents in the borough will remain using their private car as the primary mode of transport which is likely to increase within the Plan period as based on current trends....")

DLP_4043

HOOOH (Hands Off Old Oswestry Hillfort)

Object

OBJECTION - Draft Local Plan, Site AL/RTW18, Land West of Eridge Road at Spratsbrook (Ramslye). Farm Site 137

This representation is made on behalf of the HOOOH community group. We are working to protect the scheduled monument of Old Oswestry, a 3,000-year-old Iron Age hillfort (located north of Oswestry in Shropshire), from development in its setting.

As a group we are concerned about the wider preservation of the nation’s precious and envied footprint of Iron Age hillforts and prehistoric landscapes, and ensuring their rightful protection as provided for under the current NPPF. We were alarmed to hear of the proposals to allocate development land within the setting of the scheduled High Rocks Iron Age multivallate hillfort and co-located prehistoric rock shelters.

The proposed allocation would be extremely harmful to the heritage significance and experience of this especially interesting, atmospheric and rare combination of hillfort and rock shelters, the setting of which are afforded protection under the NPPF. Not only does the proposed allocation extend right up to the heritage promontory, it would also destroy a significant area of the heritage setting that provides vital evidence and context for archaeological understanding and ‘reading’ of the site; it should be protected under fair application of the NPPF and Historic England guidelines on heritage setting. The landscape east of High Rocks also provides all-important green/rural separation from Ramslye and Tunbridge Wells, retaining the hillfort’s sense of place and statement within the landscape as intended by our ancestors.

The ‘Hillfort Atlas’ of Great Britain and Ireland has raised the national and international profile of our Iron Age hillforts, leveraging their tourism value and the accessibility of our Celtic history. At the same time, it has reinforced the stature of scheduled hillforts like High Rocks, which have long been recognised and designated as ‘extra special’. The aesthetic and heritage appeal of the hillfort and rock shelters, and scope to attract and engage visitors with their stories, would be devastated by the proposed development.

While the heritage importance of the site is a compelling reason in itself against development, we also note that the proposed allocation lies wholly within Greenbelt and substantially within the High Weald Area of Outstanding Natural Beauty (AONB) with loss of Ancient Woodland and also of high grade agricultural land. These significantly compound the argument against the viability of the land for development.

We would ask that you reconsider and remove the above proposed site and prioritise finding an alternative and less contentious location; we believe the heritage and environmental protections/constraints alone would weigh heavily against the justification for any development.

DLP_5266

Tunbridge Wells Friends of the Earth

Object

Policy Number:  AL/RTW 18 

Object to new development in the Green Belt.

DLP_5382

Mr and Mrs R & S Coyle

Object

We wish to object to the proposed Ramslye development of housing and secondary school on the Land to the West of Eridge Road at Spratsbrook Farm (AL/RTW18) site number 137

DLP_5647

Michael Vos

 

Specific Observations Re RTW18 / Site 137 Land to the West of Eridge Road at Spratsbrook Farm

3

3.1 Incorrect Site Name. It is misleading to refer to Spratsbrook Farm which is not even in Tunbridge Wells or indeed in Kent. Ramslye Farm is the correct name for the location of the land specified and is what local people know it by.

3.2 Green Belt. I can see no valid reason given for justifying release of land from the Green Belt. The designation of Green Belt to this edge of town location was made for a perfectly sound reason and that purpose still applies to this site today. Serious harm would result from losing this area of land from the Green Belt.

3.3 AONB. I can likewise see no valid for justifying building in the area of AONB within the site. The purpose of such designation (conserving, protecting and enhancing natural beauty) was made with good reason and ought to be maintained as such.

3.4 Wildlife. The site is full of wildlife with a great variety of mammals, birds, insects and amphibians. Building on the land would destroy such wildlife.

3.5 Ancient Monument The area is adjacent to an ancient Hill Fort and any building within the site would be adverse to it’s preservation and setting.

3.6 Ancient Woodland The site is surrounded by ancient woodland which helps sustain the wildlife referred to above. The woods should be left well alone and kept in their rural setting.

3.7 Listed Buildings. There are some listed buildings adjoining the site and these should be left in their same context which is currently provided for through the Green Belt and AONB designations.

3.8 Agriculture. The fields comprising the site have been farmed for centuries. The land is of a very good grade for agriculture and should be protected as being Best and Most Versatile and continue to contribute to our economy as such.

3.9 Roads and Transport. The A26 Eridge Road which runs past the site into Tunbridge Wells from Crowborough already carries a high volume of traffic causing tail backs, delays, congestion, and pollution. The self-evident huge increase in traffic which would be generated by the proposed building of a school and 270 houses would be enormous and make what is already a serious problem into a deadly one for both those on the roads and in particular for local residents. The proposed location of a school makes no sense as the danger from the roads means parents and teachers are not going to allow cycling to school so most people attending the school will have to do so by private or public transport. It should be noted also that as it would contain sixth formers many of who will want to drive themselves to school and some point.

3.10 Access. Following on from 3.8 above there is no safe place to access the site from Eridge Road. The speed of traffic combined with hills and bends would cause accidents to both drivers and pedestrians. Indeed in the years I have lived at the above address I have witnessed vehicles striking the kerbstones and mounting the pavement. A recent example attended by the police and KCC involved a lorry mounting the pavement and crashing into one my tree’s ( Oak ) in the verge which first necessitated KCC remaining boughs that as a result were dragged into the road and me having subsequently having to have the tree removed being no longer in a safe condition. Access through the Ramslye Estate is also not practical not only for the same reasons as above but also because in term time in the interests of the current primary school. In either case parking on local roads blocking residents is an issue too.

3.11 Utilities. The proposed development will inevitably put pressure on the supply of utilities and in particular water supply. This may necessitate new infrastructure causing more environmental damage than just that by the development itself and disruption to residents and visitors to Tunbridge Wells by road.

3.12 Air Quality and Noise. The air quality in the area concerned is already poor. Noise is already at a high level from the existing level traffic. The proposed development would have a serious impact on both these factors causing damage to the environment, the local residents and the children attending St Marks Primary School.

3.13 Site Ownership. It is said that because the site is in single ownership this is a factor in selection. It should not be so. The Council possesses the powers of compulsory purchase so this should be ignored. Those that own and promote the site have no interests in the local community. The land owner would simply make money from unearned inherited wealth. The promoter is of course only interested in profit nothing more. That is of course why they are in business. The latter should look to other sites to promote that do not have the overwhelming factors against development that this one does. The Council should not be swayed by the carrot of a new school being built for “free” as after all a developer is not going to build one alone out of a philanthropic motive without making a profit out of what else it can get out of the local authority and probably by asking for more than originally allowed for in stages.

3.14 Rights of Way. It should be noted and taken into account that there are both public and private rights of way not only around the fields but also across them in several places. These may be adversely affected and there is no legal right to undo at least the private rights of way currently exercised over the land.

3.15 Housing and School. The observations above as to the need for the housing and new school apply here too. There is no justification in planning terms for linking the two together and each element should be considered on their own merits.

3.16 Local Democracy. The purpose of local government is to represent local communities and look after both their interest and to preserve the character of the environment in which they live and thus provide quality of life, In this case the vast majority of the local residents are firmly against development of this site and it is the duty of local councillors to represent them. It is course those people nearest to a site that know it and it’s merits best so they should be heard and their position acted upon.

3.17 Conclusion. For the reasons stated above I strongly object to the inclusion of this site as being designated for development in the new local plan. Once concreted over and developed we would lose forever a beautiful area which has quite rightly hitherto been properly protected as designated Green Belt on the edge of town and as an AONB providing huge benefit to local people , the environment , wildlife and

DLP_7355

Wealden District Council

General Observation

Policy AL/RTW 18 (Pages 108 to 110) relates to land to the west of Eridge Road at Spratsbrook Farm that has been allocated for 270 (net) dwellings and lies immediately west of the A26 Eridge Road, where there is existing access into the site. The site shares an administrative border with Wealden District that lies to the south. In addition, land directly adjacent to the allocation within Wealden District has been submitted for consideration as part of Wealden District Council’s SHELAA. This is considered further below.

The site allocation in the Tunbridge Wells Local Plan is located within Green Belt, partially within the High Weald AONB and includes a small area of Ancient Woodland and an Ancient Monument in the western corner of the site that has archaeological potential. The policy confirms under policy AL/RTW 18 that as well as the provision of 270 (net) dwellings, the allocation will also provide a seven form entry secondary school on site. It is anticipated that contributions towards primary and secondary education, health and medical facilities, a new sports hub at Hawkenbury Recreation Ground will be brought forward as part of the development proposals.

Paragraph 172 of the NPPF (February, 2019) confirms that great weight should be given to conserving and enhancing landscape and scenic beauty in Areas of Outstanding Natural Beauty (AONB), which have the highest status of protection in relation to these issues. It notes that the scale and extent of development within these designated areas should be limited and that planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. The remaining part of the paragraph confirms that consideration to be given to following issues that includes:

(a) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy; (b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and (c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.

Tunbridge Wells Borough Council has published a supporting document named the ‘Distribution of Development Topic Paper’ that includes consideration of development potential in the High Weald AONB under Section 6(G), amongst other matters. This document notes under paragraph 6.93 of the document that of the 49 site allocations in the High Weald AONB that are being put forward for inclusion in the Draft Local Plan, around 17 are considered to be ‘major’ development in their local context. The document provides a commentary for the borough as a whole on how the strategy meets the exceptions test laid out in paragraph 172 of the NPPF on pages 51 to 53.

Appendix 3 of the ‘Distribution of Development Topic Paper’ outlines each site allocation within the High Weald AONB in terms of whether the site allocation is indeed ‘major’ development in the context of paragraph 172 of the NPPF and if so, whether its meets the exceptions and public interest test. The aforementioned site above was considered to be ‘major’ development of a very substantial scale and high impact on the High Weald AONB. In terms of justification for the development, it has been stated that this is the only site that has come forward that is suitable to deliver a new secondary school in this part of the Borough and would provide good connectivity to the town and wider landscape.

Given the scale of the development and its impact on the High Weald AONB, it is agreed by Wealden District Council that the development would be ‘major’ development in the context of paragraph 172 of the NPPF. However, the assessment for this site does not provide specific justification for the development against the aforementioned criteria in paragraph 172 of the NPPF. It is considered that it may be better to assess each ‘major’ development site in the High Weald AONB against each of the criteria and then to reach a conclusion as to whether the site is justified on this basis.

In July 2017, Wealden District Council commissioned Chris Blandford Associates to undertake the Wealden Local Plan Sites Landscape and Ecological Assessment Study and this details the ecological and landscape information to inform the process of identifying suitable sites for future development within those areas of the District outside of the South Wealden Growth Area (SWGA).

As part of this process, Wealden District Council undertook a landscape assessment for the southern part of this site (the area of land located within Wealden District) in support of the Submission Wealden Local Plan (January, 2019). As part of this study the site was considered to have high visibility, very high landscape sensitivity and value, and a very low landscape capacity. This information was shared and discussed with Tunbridge Wells on the completion of this study. It also noted that whilst the whole site is highly sensitive, the north-western part of the site is most sensitive (nearest to the proposed allocation site) as it lies within and adjacent to a nationally Scheduled Monument providing a characteristic landscape setting to a prehistoric site.

Criteria 7 of policy AL/RTW 18 in the draft Tunbridge Wells Local Plan confirms that the provision of a soft landscaping buffer along the south-western boundary within the Wealden District administrative area should be investigated. Such joint working is supported, however it is considered that the evidence base above should be taken into account and the landscape protected accordingly. It is considered that the policy wording should therefore be strengthened to ensure the protection of the landscape as part of any development coming forward. In this regard, further discussions are welcomed. In addition, it is not clear how any cross boundary impacts on transport infrastructure or the setting of the High Weald AONB have been assessed, for example, and whether consideration of the secondary school included within this policy has included discussions with East Sussex County Council (ESCC), given its proximity to Wealden District and settlements such as Frant, Bells Yew Green and Eridge. Wealden District Council would welcome discussions involving East Sussex County Council in relation to education and highways matters to ensure that such an allocation, if not removed in the next iteration of the Plan, is both agreeable and where necessary the policy strengthened.

It would be helpful for the allocation plan associated with this site to show the District boundary for Wealden District. It would also be helpful to show the green belt and AONB designations.

Spratsbrook Farm – Area of land within Wealden District (SHELAA ref: 729/1610)

Wealden District Council considered the allocation of land in the AONB adjacent to the Tunbridge Wells allocation as part of its Local Plan preparation.

The Wealden District Council Strategic Housing and Economic Land Availability Assessment (SHELAA) was published in January 2019. This document along with other evidence base documents including the Sustainability Appraisal informed plan preparation.

As part of the Wealden Local Plan preparation, key considerations included major development in the AONB and the national planning policy test whereby land outside the AONB serving Wealden District would need to be considered as well as the other necessary tests. The nature of Wealden District, as well as other factors including landscape considerations (as set out above), resulted in the land in the AONB surrounding Tunbridge Wells not being selected.

It is considered that the above matters would need to be duly considered should this area of land be promoted in the future.

DLP_6122

Mr Neal Hunt

Object

Land to the West of Eridge Road at Spratsbrook Farm

AL/RTW 18 Site no. 137

This site is wholly inappropriate for development and the description of the site contained in the Draft Local plan reads like a list of a planning officers reasons for refusal to a planning committee. ( I speak as a professional Development Manager)

The site is

- Designated green belt

- Within an AONB

- Contains and is adjacent to ancient woodland

- Contains an ancient monument

- Biodiversity opportunity area

With reference to the NPPF, I do not believe that the draft plan demonstrates exceptional circumstances for the inclusion of this site (Clause 136). Nor does it demonstrate that all other reasonable options have been explored (Clause 137). Indeed it classifies as inappropriate development ( Clause 143 and 144) and the harm caused by development on this site would outweigh any benefits.

Finally I would refer you to Section 15 of the NPPF and in particular Clause 170. This policy would go against all the recommendations set out in the Clause and would have a massive negative impact on the local natural environment.

I would urge you to withdraw this site immediately.

DLP_6970

Siobhan O'Connell

Object

I want to register my strong objection to any development on this site (the fields adjacent to Ramslye Road and beyond it/Spratsbrook Farm) and I make the following points in support of my objection: 1. The land is within the High Weald Area of Outstanding Natural Beauty (AONB) and is high grade agricultural land and as such it must be protected from development: Approximately half of the site is classified as AONB. It is a fine and accessible example of the High Weald and we have AONB designations to protect this type of land. Additionally, all of it is high quality agricultural land. By putting this site forward for consideration of development, the council has failed in its duties under the Countryside and Rights of Way Act (CRoW) 2000 which says the primary purpose of AONBs is to conserve and enhance natural beauty and its protection should be given a high priority by local authorities. The crops grown in the fields include cereals, linseed and oil seed rape, which according to the government means it should be protected under the “Best and Most Versatile” (BMV) rules that are designed to ensure we keep the best and most productive farm land available so we can continue to grow the food we need. 2. The land is Green Belt and it must not be released for development: The council’s own study of Green Belt prepared in 2017 as part of the development of the local plan assessed the degree of harm caused by the potential loss of this land as high. It also assessed the contribution of this land to the national criteria for Green Belt as relatively strong in three of the four criteria assessed. It is not apparent from the local plan that any other site has been proposed to be released from the Green Belt that would have the high degree of harm associated with losing this land. 3. The existing road network cannot support a development of the size and nature proposed: On average 23,496 motor vehicles use Eridge Road every day going into Tunbridge Wells. Only Pembury Road is busier (by c.3%). Traffic already queues on Eridge Road from Sainsbury’s roundabout to Broadwater Down and sometimes further. The proposed development could add c.350 cars to the area and increase traffic by up to 25% for the school runs, totalling nearly 30,000 vehicles every day. The quiet green space of Ramslye could become a congestion/parking black spot due to school traffic. It is clear the current roads and parking provision cannot handle a development of this size and the site of any new school needs to correspond to the location of the bulk of the new housing. A development of this scale in the High Weald AONB and on such high grade agricultural land sets a dangerous precedent for our rural environment, and it will have an unduly negative impact on the residents in the area in terms of traffic, noise, congestion and pollution. I have set out a compelling and reasoned case to remove this site from the draft local plan and I urge you to consider how to challenge the overall requirement for new houses to a more realistic and justified target.

DLP_5406

Andrew Best

Object

I am writing to object to the inclusion of the above site in the TW Local Plan.

It is an unsuitable site for a number of reasons:

  1. Part of proposed site is within the High Weald AONB  and so should be ruled out on this ground alone, but also this section and the other part outside the AONB would adversely affect the wider AONB landscape as  the site is in a prominent location on the ridge and will impact the rural approach to Tunbridge Wells
  2. The site is greenfield and will impact the SSSIs at High Rocks, Eridge Rocks and Eridge Park.
  3. It will add to traffic movements across the Ashdown Forest which is a continuing planning issue to this area of special protection and is within the Ashdown 15km zone an area of special protection and is not far outside the 7km zone.
  4. It will impact the RSPB nature reserve at Broadwater Warren less than one mile away which has rare flora and fauna and in value would rate alongside Ashdown Forest for nature conservation in terms of species
  5. In terms of Highways the Eridge Road is at capacity on 23,000 vehicles per day and adding local traffic with cause delays and a build up of traffic entering the town. Access will be a problem whether through Ramslye or by way of a new roundabout on A26 as both will slow the processing of Tunbridge Wells bound traffic. There is no easy solution to this problem as the majority of the traffic on the A26 is bound for Tunbridge Wells  itself rather than through traffic. In particular the proposal for a school will increase the traffic movements far more than simply a residential development. As there is currently spare capacity in Tunbridge Wells secondary schools this proposal is not need but developer driven, using education as a cloak to sweeten an unacceptable proposal.

I urge Tunbridge Wells Borough Council to reject what is a speculative proposal for inclusion in the Local Plan and instead look towards regeneration of existing buildings and land rather than allow an extension of the town’s perimeter to the south and west into the countryside to the long term detriment of the town and surrounding villages.

Policy AL/RTW 19: Land at 77 Mount Ephraim (Sturge House, Brockbourne House)

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1815

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Numbers:  AL/RTW 7,8,9,10,14,15,19, 24, 26,28,29,31,32

The above sites seem suitable for allocation subject to the proposed conditions written into the policies.

DLP_3209

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following change is requested:

The standard paragraph regarding contributions should also 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 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

The site is within the grounds of Oakhurst, post medieval residence including designed formal gardens. Assessment of remaining historic landscape required.

DLP_2907

Chris Gow

Object

This site should be the place for exclusive housing to satisfy larger households.

The use for business should be overturned, the site is better suited for exclusive housing.

DLP_2908

Chris Gow

Object

Site should be developed for exclusive housing.

The use for business should be overturned; the site is better suited for exclusive housing.

Policy AL/RTW 20: Land at Tunbridge Wells Telephone Engineering Centre, Broadwater Down

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_177

Hobbs Parker for British Telecom Plc & Telereal Trillium

Support with conditions

Telereal Trillium, support the proposed allocation of the Telephone Engineering Centre, Broadwater Down, Tunbridge Wells, policy AL/RTW20.

1. It is confirmed that the site is available for development and deliverable within the plan period. It is considered that the site is suitable for the approximately 50 dwellings identified, to achieve this it is considered the site is most suitable for a mix of houses and flats.

Given the nature of the site it is questioned whether on-site development requirement 2, should identify such an extensive range of requirements, particularly given that criterion f of the off-site requirements contained within the allocation duplicate many of these requirements. In the light of this it is suggested that the size of the site makes it most suitable for the provision on –site of some open space and small scale recreational areas but that more expansive open space and recreational requirements would be better provided off-site in conjunction with other developments and schemes. It is therefore suggested that criterion 2 of the policy AL/RW20 is amended as follows;

2. Provision of on-site amenity / natural green space and small scale local play area.

And that the wider range of open space and recreational requirements (in accordance with policy OSSR2) are dealt with by contribution towards off site provision, with criterion f of the policy amended as follows;

f. Provision of off-site amenity / natural green space, and improvements to existing allotments, parks and recreation grounds, children’s play space and youth play space (see policy OSSR 2:The provision of publicly accessible open space and recreation).

DLP_376

Mr Clifford Sheppard

Object

"Potential to provide pedestrian linkages between Broadwater Lane and Linden Garden;"

This will result in a significant increase in pedestrians using Linden Gardens as users from across the Showfields Estate will use this as a shortcut.

There is no footpath for much of Linden Gardens, so more pedestrians will have to walk in the road, posing a danger to themselves and a hazard to traffic.

Pedestrian access to the new development from Linden Gardens will result in increased traffic, and residents may choose to park in Linden Gardens. Parking is already severely limited. The end of Linden Gardens is used as a turning area by larger vehicles and this must not be removed or blocked.

Increased traffic will result in more wear and tear to a private road, at the expense of residents.

More pedestrians will inevitably result in more litter etc - the road is not cleaned or maintained by the council, so this will result in additional cost and maintenance to residents.

The pedestrian access would reduce walking times only marginally, but would have a significant effect on the residents of Linden Gardens.

DLP_3595

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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 50 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/RTW 20

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 Tunbridge Wells. 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/RTW 20

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

DLP_1827

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Number:  AL/RTW 20 Telephone Engineering Centre 

Development for residential use is appropriate given the housing need and the benefit of using a brownfield site but, given its relatively central location and proximity to existing green space, development should be of a much higher density than is proposed.

DLP_3144

Penny Kift

Object

Re AL/RTW20 of the Draft Plan.

In the Site Allocations Plan 2016 the BT site and WA Turners were to be developed together to provide 170 dwellings. The 2016 Plan was most specific about the sites being seen as a whole and not developed separately. I am disappointed that under the draft plan the WA Turner site has now been taken out and the BT site will only provide 50 dwellings.

The reasons given are that WA Turners provides local employment.

My concerns are:

  1. Most of the employees at Turners are agency staff, bussed in by mini buses from outside the area – very few employees are from the immediate area.
  2. The original factory has changed its practices over the years and has become more of a distribution depot. Broadwater Lane is not suitable to provide access needed by modern day articulated lorries. It certainly is not wide enough for turning and many times a week there is a Health and Safety issue caused by lorries reversing over the mini-roundabout by the entrance to Broadwater Down Primary School and the Ark Children’s Centre.
  3. The reduced number of dwellings will provide less affordable homes because of the percentage factor – this type of accommodation is much needed in the Broadwater Ward. It will also produce less money for infrastructure contributions for schools and leisure facilities, again, much needed in this ward.

In conclusion: With the development of The Goodwins, School Rise and, more recently, Underwood Rise, this area has become a quiet residential area. It is no longer appropriate to have a factory in this location. There is ample room for this on the North Farms Estate with its road infrastructure and links to the improved A21.

DLP_3211

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The address should be Underwood Rise, not Broadwater Down.

The following changes are requested:

Paragraph 1 - “Provision of pedestrian link between Broadwater Lane and Linden Garden;”

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

The County Council notes that the site does not appear to abut the public highway: access section of Underwood Rise and Linden Gardens are private roads.

Heritage Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

Some archaeological potential for post medieval railway/industrial heritage remains requires further archaeological assessment.

DLP_7719

Stephen Ward Town Planning and Development Consultants for Anglo Beef Processors

Support with conditions

Paragraph Number(s): 5.36 

As noted by the Draft Local Plan at paragraph 5.36, “Land at Tunbridge Wells Telephone Engineering Centre is allocated in the Site Allocations Local Plan 2016 (Policy AL/RTW 13) as part of a wider allocation including the WA Turner Factory for residential development (C3) providing approximately 170 dwellings”.

According to the draft Local Plan “The WA Turner site is not proposed to be allocated in this Draft Local Plan. Although it was submitted in the Call for Sites exercise, it is a site which is in existing employment use, which is of economic and employment benefit: it is therefore not proposed to allocate this for residential development” (para. 5.26, p.112).

Our client strongly objects to the omission of their lands, the WA Turner Factory from the allocation policies for Royal Tunbridge Wells. As acknowledged by the draft Local Plan, this site was submitted in the Call for Sites exercise. The submission in response to the Call for Sites in 2016 clearly stated that the site would be become available for development within the next 5-10 years. Our client has engaged at all stages of the process to promote the redevelopment of their lands including the submission on Site Allocations Development Plan Document Consultation Draft (Ref AL_1168) in 2013 informed the Planning Authority that the plant was nearing the end of its lifecycle and further capital investment is unsustainable. A proposal has been developed for the redevelopment of this site that would provide residential dwellings types including apartments and town houses. It is submitted that AL/RTW 20 should include the WA Turner Factory site to allow for a comprehensive development of this area.

Site Allocation Policy - AL/RTW 20 

Lands at Tunbridge Wells Telephone Engineering Centre to the immediate east of the WA Turner Factory site is identified in the Allocation Policies for Royal Tunbridge Wells Town Centre as AL/RTW 20. These lands have been carried forward from the Site Allocations Local Plan 2016 under Policy AL/RTW 13 which covered a wider allocation including the WA Turner Factory for residential development (C3) providing approximately 170 dwellings. Under Policy AL/RTW 13 the WA Turner Factory site was also considered suitable for a mix of market and retirement housing.

According to the draft Local Plan “The WA Turner site is not proposed to be allocated in this Draft Local Plan. Although it was submitted in the Call for Sites exercise, it is a site which is in existing employment use, which is of economic and employment benefit: it is therefore not proposed to allocate this for residential development” (para. 5.26, p.112).

A proposal has been developed for the redevelopment of this site that would provide a residential development. It is submitted that AL/RTW 20 should include the WA Turner Factory site to allow for a comprehensive development of this area. It is further submitted the proposal to retain the Telephone Exchange site for residential use and change the WA Turner Factory allocation to employment is a conflicting policy approach. Both sites should be used for residential development.

Policy AL/RTW 21: Land at Culverden Stadium, Culverden Down

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_38

David Hodgkinson

Object

Being next to a secondary school that has some 10 busses and other traffic causing major congestion twice a day during termtime what do you propose to do with a potential of another 60 cars using the same roads. Secondly how can you create the infrastructure to provide a way for all existing weeekend traffic crossing the town to the proposed new hub in Hawkenbury. The stadium creates little air pollution and being a grass pitch will reduce the carbon dioxide in the air. being next to a school that many students walk to and past surely must be a more important consideration than putting thirty homes in an already conjested area.

DLP_7852

Robert Belton

Object

I am writing to object to the following policy within the Local Plan.

Paragraph 5.37 : The Sports Strategy for Royal Tunbridge Wells

Policy AL/RTW 23 : Land at Cadogan Sports Field , St John’s

I strongly object to this land being used for future housing on the following grounds.

  1. This land is currently being used mainly by both junior male and female local football teams who play their organised matches on Saturdays and Sundays. Supported by their family and friends .   I have major concerns that the proposed new sports hub in Hawkenbury  would not be able to cater for the loss of these football pitches should the land be sold for future housing development.
  2. The impact of the additional traffic flow of a potential 70 + vehicles onto the A26 St John’s Road , (which is already one of the most polluted roads in the Borough) , would only add to the pollution and potential danger to existing residents, road users and pedestrians, should this land be sold for future housing development and access to any such development was off of St John’s Road.
  3. The additional vehicle movements would increase the danger to the school pupils who exit and access their school buses on St John’s Road . Also it would increase the danger to them trying to cross St John’s  to get to three of the Boroughs Secondary schools.
  4. This green space with its large number of trees is currently playing a very important part in helping to provide better air quality to this highly polluted area due to the 24/7 volume of traffic using the immediate adjacent A26 St John’s Road. Should this be green space be lost it would have a massive impact on the quality of life in the area.
  5. Concerns over the impact of any future housing development could have on Saint Augustine’s school which boundaries run along one side of this site.

I appreciate the need for more housing to be built in the Borough . However I believe that this land should be retained and made available to the schools in the area for full sports usage.

DLP_1828

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Number:  AL/RTW 21 Culverden Stadium 

As a former Rural Fringe site adjoining the LBD, this site appears appropriate for residential development subject to the preservation and enhancement of tree cover to the north and on the boundaries. The northern edge of the site sits on a prominent escarpment and the maintenance of the Ancient Woodland buffer is vital all along the escarpment abutting Smockham Farm as is provided for in Paragraphs 2 and 4.

Because there are existing acute traffic problems on Culverden Down caused by the “school run” to a number of nearby schools, together with additional commuter rat-running, a further pre-condition for any planning permission on the site should be the prior introduction of a 20mph zone in the whole of the Culverden area together with filtered permeability and safe walking and cycling routes to local schools to make local active travel a reality.

DLP_5205

Culverden Residents Association

General Observation

Any kind of development should not take place prior to introduction of a 20mph zone in the whole of the Culverden area, together with filtered permeability and safe walking and cycling routes to local schools to make local active travel a reality and to eliminate rat-running.

DLP_2909

Chris Gow

Support with conditions

This development should only be approved of NO trees are felled in the build.

Tree preservation orders should be placed on ALL the trees on the site, and assurance demanded that no trees will be felled, or lopped, or pruned.

DLP_2910

Chris Gow

Support with conditions

Development should be conditional on the following:

This development should only be approved of NO trees are felled in the build.

Tree preservation orders should be placed on ALL the trees on the site, and assurance demanded that no trees will be felled, or lopped, or pruned.

DLP_1672

TWBC Property and Estates

TWBC

Support

a. Bullet 4. The site is not officially part of a Biodiversity Opportunity Area (BOA) and not statutorily designated, - see para 6.146. The plan in the High Weald Kent Biodiversity Strategy is also not clear but seems to exclude a significant part of the land including the current football pitch and areas to the south and west. Furthermore, the Habitat Opportunity Plan on Kent Landscape Information Service (KLIS), only defines a discreet area to the north of the football pitch as a minor acid woodland or acid grassland opportunity. Any compliance with bullet 4, should therefore only be applicable to any properly designated areas rather applying a blanket approach.

b. Bullet 5. The gate piers referred to, are on a different site. This requirement is therefore Ultra Vires and would be difficult to implement.

DLP_2050

Terry Everest

Object

Strongly Object

This area is covered in trees and wildlife and the stadium protects its surroundings so should be retained. The character of the fringe woodland  here is very special has a high degree of naturalness and intrinsic appeal. It is possible to sense the age of the trees and there are pleasant footpaths through here which should be retained. Ths site should not be developed.

DLP_2377

Mr and Mrs Jose

Object

REF. SECTION 5-37 OF THE DRAFT LOCAL PLAN

With reference to the above proposal we, as residents of Cleeve Ave, strongly object to the idea of a Football Stadium being created in close proximity to our property and have several queries and concerns.

1) Who would be responsible for maintaining the stream that currently run along two sides of the field, as part of the drainage system runs through our property and any debris blocking the stream could in turn cause flooding in our property.

2) WHEN ANY FUTURE SITE INSPECTIONS OR SURVEYS ARE CARRIED OUT, COULD THE INSPECTORS/SURVEYERS PLEASE ALSO INSPECT OUR PROPERTY SO THAT THEY CAN APPRECIATE OUR CONCERNS AND THE POSSIBLE FLOODING TO OUR PROPERTY THAT COULD ENSUE

3) When the house to the rear of our property, in Sherborne Close was demolished and rebuilt a few years ago, the land flooded after demolition, causing a deluge of thick orange sludge to flood our garden, which resulted in the builders having to dig out channels to divert the flood water into the stream to prevent our property being overwhelmed and completely flooded.

4) Has any consideration been taken into account that this is a quiet residential area consisting of two roads of bungalows to one side of the field, mainly occupied by retired and elderly people who, like us have specifically chosen to retire here to enjoy the peace and quiet, plus the fact that Sherborne Close - a sheltered accommodation complex runs along side another side of the field.

5) As Pembury Road is already a major traffic bottleneck, how can it possibly cope with a huge increase in traffic as it currently stands.

6) Will we be compensated for the devaluation of our property, as we would probably find it very difficult to sell and relocate to another suitable property and location, so instead of continuing to enjoy our retirement, we will spend our last years suffering noise, disruption and misery.

7) Please find enclosed a copy of the plan showing the close proximity of our property to the proposed Football Stadium site, also showing the said streams, marked as 'DRAINS' on the plan

DLP_3216

Kent County Council (Growth, Environment and Transport)

Object

Highways and Transportation

The Local Highway Authority objects to this policy.

The existing vehicular and pedestrian access to site inadequate (Note re paragraph 5: Pillars are at entrance to adjacent site)

Heritage Conservation

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

DLP_5015

R P Dann

 

Paragraph Number 5.37

I am concerned about the impact of increased traffic, parking, a large number of people, noise, floodlights and the threat of anti-social behaviour. This is a very quiet area overlooking farmland at the moment and I wish this to remain quiet and peaceful.  We know Tunbridge Wells Football Club already have had recent problems with anti-social behaviour.

In addition I have been advised, first hand, that the pumping station in Cleeve Avenue is working at full capacity.  Even if a new pumping station was built the infrastructure (drainage) will not cope with increased numbers of people - Tunbridge Wells football club currently have total capacity for 3,750 so would presumably be looking for this not to be reduced.

DLP_5095

Carol Lawrence

Object

I am messaging on behalf of my parents whom live in Cleeve Avenue Hawkenbury TW they are NOT in favour with the plans regards relocation of TW football club.

DLP_7251

Mr John Telling

Object

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected.

My reasons for wishing to retain these sites include the following:

1. To reduce our carbon footprint we have to reduce the need for all travel, including that to accessible open space. This policy is at odds with the imperative need to cut CO2 emissions and pollution. A policy which promotes more driving about is irresponsible. It will force more people into cars on our already congested roads, increasing traffic congestion and pollution simply to access recreational open space.

2. We need to develop and protect local green spaces for children/families to be able to play, relax and socialise. Many individuals and families have no or only small gardens. Families with children need open spaces near their homes to play with a ball, cycle on their bikes, and meet with friends and family without having to drive or be driven across the borough.

3. People need open space to walk, run and socialise with others in their community.

4. Green spaces are increasingly recognised as necessary for good mental health and physical wellbeing. They bring natural features into an urban area and help people feel better about their local environment.

5. Trees and vegetation help improve air quality and absorb CO2.

Removing local playing fields will be detrimental to the borough and people's quality of life. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable without access to private transport. Public transport to Hawkenbury is limited. And why should people have to use transport, public or private to access social open space? People should be able to access open space on foot.

Other sites and approaches that do not involve building on playing fields and informal open space should be considered.

This proposal is environmentally and socially retrogressive and contrary to residents' wellbeing needs.

DLP_6123

Angela Funnell

Object

Paragraph 5.37: The Sports Strategy for Royal Tunbridge Wells

This includes:

  • Policy AL/RTW 21 Land at Culverden Stadium, Culverden Down
  • Policy AL/RTW 22: Land at Bayham Sports Field West
  • Policy AL/RTW 23: Land to the north of Hawkenbury Recreation Ground
  • Policy AL/RTW 24: Land at Cadogan Sports Field, St John’s Road
  • Policy AL/RTW 25: Land at Colebrook Sports Field, Liptraps Lane

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected. My reasons for wishing to retain these sites include the following:

  1. We need green spaces for children/families to be able to play. Some families don’t have gardens, or only small ones. They need places near their homes to play with a ball, cycle on their bikes, and play with friends and family without having to be driven across the borough.
  2. People need them to walk, run and socialise with others in their community.
  3. They are good for our mental health and physical wellbeing. They beautify an urban area and make people feel better about the environment they live in.
  4. The trees and plants help provide good air quality.

Removing the local playing fields will do much harm to the borough. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable. It will also force more people into cars on our already congested roads, increasing traffic congestion and pollution. Other sites should be considered that do not involve building on playing fields.

DLP_5756

Sally Antram

Object

Paragraph 5.37: The Sports Strategy for Royal Tunbridge Wells

This includes:

  • Policy AL/RTW 21   Land at Culverden Stadium, Culverden Down
  • Policy AL/RTW 22:   Land at Bayham Sports Field West
  • Policy AL/RTW 23:   Land to the north of Hawkenbury Recreation Ground
  • Policy AL/RTW 24:   Land at Cadogan Sports Field, St John’s Road
  • Policy AL/RTW 25:   Land at Colebrook Sports Field, Liptraps Lane

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected. My reasons for wishing to retain these sites include the following:

1. We need green spaces for children/families to be able to play. Some families don’t have gardens, or only small ones. They need places near their homes to play with a ball, cycle on their bikes, and play with friends and family without having to be driven across the borough.

2. People need them to walk, run and socialise with others in their community.

3. They are good for our mental health and physical wellbeing. They beautify an urban area and make people feel better about the environment they live in.

4. The trees and plants help provide good air quality.

Removing the local playing fields will do much harm to the borough. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable. It will also force more people into cars on our already congested roads, increasing traffic congestion and pollution. Other sites should be considered that do not involve building on playing fields.

In addition, focusing all the town’s main sports facilities in one hub in Hawkenbury will inevitably cause problems for that area of the town, including increased traffic and congestion.

Policy AL/RTW 22: Land at Bayham Sports Field West

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_7750

Skinners’ School

General Observation

The designation of Southfields Park as Local Green Space is understandable if the Council wishes to maintain a clear boundary between Southborough and Tunbridge Wells.

However, I would be very concerned if the implication was that the school’s ability to develop the site, eg a small car park, development of our pavilion, laying down a MUGA pitch or new cricket nets were hindered.

Skinners’ School plays a significant role in the development of talented sportsmen in Tunbridge and has contributed hugely to the sporting profile of the town (eg by founding the town’s rugby club).

We have already discussed with the Council the school’s desire to develop its sporting provision and at the same time to support the development of sport in the town. Whilst our ability to sell Southfields is significantly hindered by designation as a Local Green Space, I could accept that were it not for the fact that the Council proposes to build housing on Cadogan Sports Field (Site 237), thus effectively closing the door on our ability to develop provision elsewhere.

As said above, I would appreciate a conversation with the Council about Cadogan in order to investigate our ability to purchase or lease the site and to use it for our use but also for the use of the community. I would also like to discuss the extent to which Local Green Space designation inhibits our ability to develop Southfields Park for sport.

DLP_2553

Ms S Daniels

 

Do not over-develop this site. It will add to the number of cars using the Bayham Road/Forest Road junction which is already dangerous and in need of a mini-roundabout or similar traffic management scheme.

Pedestrianisation should include a continuous footpath between the site and Forest Road.

With so much development along Forest Road (here, Hollyfields at Hawkenbury, Regent's Place) there is a pressing need for a bus route to run on a circular route from town up the Frant Road, along Forest Road, Bayhall Road and to the town centre with similar frequency to the Rusthall 281 route.

DLP_1673

TWBC Property and Estates

TWBC

Support

AL/RTW22

a. Bullet 3. The site is not officially part of Biodiversity Opportunity Area BOA- not statutorily designated see para 6.146. The site is currently a football pitch and noted as improved grassland. On the Kent Landscape Information Survey (KLIS) it is seen as habitat opportunity- Acid Grassland and Heath. If applied to the whole site this would potentially conflict with the allocation and the delivery of valuable housing. Any enhancement opportunity should be regarded as being part of any development.

b. Bullet 6. Groundwater source protection zone - these are non-statutory Safeguard Zones. Reference to Magic mapping only shows the southernmost part of the site being included.

DLP_2051

Terry Everest

Object

Strongly Object

It is important that sports fields are protected and retained throughout the environs of Tunbridge Wells and the borough. It is not correct that this amenity can be reprovided at Hawkenbury or elsewhere - as it is the local amenity and value both as a functional used space and a part of the green space network which is important to retain.

DLP_3217

Kent County Council (Growth, Environment and Transport)

Object

Highways and Transportation

The Local Highway Authority objects to this policy.

There is no footway either side of Bayham Road. KCC as the Local Highway Authority cannot support allocation without significant work to provide footway along Bayham Road or to provide alternative footway link to highway network.

Heritage Conservation

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

DLP_7356

Wealden District Council

General Observation

Policy AL/RTW 22 (Pages 116 to 117) relates to Land at Bayham Sports Field West that has been allocated for between 20 and 25 (net) dwellings and lies immediately to the north of Bayham Road, beside the Kent and Sussex Crematorium.

It is noted that the constraints to the site are less on the basis that the site is not located within the Green Belt or High Weald AONB. The vehicular and pedestrian access for the site would need to be taken from Bayham Road, B2169.

Nonetheless, it not clear how Tunbridge Wells Borough Council has taken into account the sites proximity to the administrative boundary of Wealden District and its potential cross boundary impacts on infrastructure (transport, open space and recreation and green infrastructure / biodiversity and education particularly) and the setting of the High Weald AONB within Wealden District.

It would be helpful for the allocation plan associated with this site to show the District boundary for Wealden.

DLP_7252

Mr John Telling

Object

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected.

My reasons for wishing to retain these sites include the following:

1. To reduce our carbon footprint we have to reduce the need for all travel, including that to accessible open space. This policy is at odds with the imperative need to cut CO2 emissions and pollution. A policy which promotes more driving about is irresponsible. It will force more people into cars on our already congested roads, increasing traffic congestion and pollution simply to access recreational open space.

2. We need to develop and protect local green spaces for children/families to be able to play, relax and socialise. Many individuals and families have no or only small gardens. Families with children need open spaces near their homes to play with a ball, cycle on their bikes, and meet with friends and family without having to drive or be driven across the borough.

3. People need open space to walk, run and socialise with others in their community.

4. Green spaces are increasingly recognised as necessary for good mental health and physical wellbeing. They bring natural features into an urban area and help people feel better about their local environment.

5. Trees and vegetation help improve air quality and absorb CO2.

Removing local playing fields will be detrimental to the borough and people's quality of life. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable without access to private transport. Public transport to Hawkenbury is limited. And why should people have to use transport, public or private to access social open space? People should be able to access open space on foot.

Other sites and approaches that do not involve building on playing fields and informal open space should be considered.

This proposal is environmentally and socially retrogressive and contrary to residents' wellbeing needs.

DLP_8358

Angela Funnell

Object

Paragraph 5.37: The Sports Strategy for Royal Tunbridge Wells

This includes:

  • Policy AL/RTW 21 Land at Culverden Stadium, Culverden Down
  • Policy AL/RTW 22: Land at Bayham Sports Field West
  • Policy AL/RTW 23: Land to the north of Hawkenbury Recreation Ground
  • Policy AL/RTW 24: Land at Cadogan Sports Field, St John’s Road
  • Policy AL/RTW 25: Land at Colebrook Sports Field, Liptraps Lane

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected. My reasons for wishing to retain these sites include the following:

  1. We need green spaces for children/families to be able to play. Some families don’t have gardens, or only small ones. They need places near their homes to play with a ball, cycle on their bikes, and play with friends and family without having to be driven across the borough.
  2. People need them to walk, run and socialise with others in their community.
  3. They are good for our mental health and physical wellbeing. They beautify an urban area and make people feel better about the environment they live in.
  4. The trees and plants help provide good air quality.

Removing the local playing fields will do much harm to the borough. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable. It will also force more people into cars on our already congested roads, increasing traffic congestion and pollution. Other sites should be considered that do not involve building on playing fields.

DLP_8362

Sally Antram

Object

Paragraph 5.37: The Sports Strategy for Royal Tunbridge Wells

This includes:

* Policy AL/RTW 21 Land at Culverden Stadium, Culverden Down

* Policy AL/RTW 22: Land at Bayham Sports Field West

* Policy AL/RTW 23: Land to the north of Hawkenbury Recreation Ground

* Policy AL/RTW 24: Land at Cadogan Sports Field, St John’s Road

* Policy AL/RTW 25: Land at Colebrook Sports Field, Liptraps Lane

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected. My reasons for wishing to retain these sites include the following:

1. We need green spaces for children/families to be able to play. Some families don’t have gardens, or only small ones. They need places near their homes to play with a ball, cycle on their bikes, and play with friends and family without having to be driven across the borough.

2. People need them to walk, run and socialise with others in their community.

3. They are good for our mental health and physical wellbeing. They beautify an urban area and make people feel better about the environment they live in.

4. The trees and plants help provide good air quality.

Removing the local playing fields will do much harm to the borough. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable. It will also force more people into cars on our already congested roads, increasing traffic congestion and pollution. Other sites should be considered that do not involve building on playing fields.

In addition, focusing all the town’s main sports facilities in one hub in Hawkenbury will inevitably cause problems for that area of the town, including increased traffic and congestion.

Policy AL/RTW 23: Land to the north of Hawkenbury Recreation Ground

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_7851

Robert Belton

Object

I am writing to object to the following policy within the Local Plan.

Paragraph 5.37 : The Sports Strategy for Royal Tunbridge Wells

Policy AL/RTW 23 : Land at Cadogan Sports Field , St John’s

I strongly object to this land being used for future housing on the following grounds.

  1. This land is currently being used mainly by both junior male and female local football teams who play their organised matches on Saturdays and Sundays. Supported by their family and friends .   I have major concerns that the proposed new sports hub in Hawkenbury  would not be able to cater for the loss of these football pitches should the land be sold for future housing development.
  2. The impact of the additional traffic flow of a potential 70 + vehicles onto the A26 St John’s Road , (which is already one of the most polluted roads in the Borough) , would only add to the pollution and potential danger to existing residents, road users and pedestrians, should this land be sold for future housing development and access to any such development was off of St John’s Road.
  3. The additional vehicle movements would increase the danger to the school pupils who exit and access their school buses on St John’s Road . Also it would increase the danger to them trying to cross St John’s  to get to three of the Boroughs Secondary schools.
  4. This green space with its large number of trees is currently playing a very important part in helping to provide better air quality to this highly polluted area due to the 24/7 volume of traffic using the immediate adjacent A26 St John’s Road. Should this be green space be lost it would have a massive impact on the quality of life in the area.
  5. Concerns over the impact of any future housing development could have on Saint Augustine’s school which boundaries run along one side of this site.

I appreciate the need for more housing to be built in the Borough . However I believe that this land should be retained and made available to the schools in the area for full sports usage.

DLP_4111

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

CPRE objects to this proposal for a new sports hub which appears to be major development in the AONB and has not been adequately justified under NPPF paragraph 172.

DLP_3596

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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/RTW 23

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

DLP_3830

Natural England

 

It is acknowledged that this site is located within the AONB. The Landscape Sensitivity Assessment identifies this site to have high-medium high sensitivity to development, therefore any development in this location should be given careful consideration, taking into account the requirements of the NPPF and the High Weald Management Plan. Policy wording for this allocation should reflect requirements of the above policies, and include reference to appropriate lighting requirements, which will be of concern in this location.

DLP_1829

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Number:  AL/RTW 23 Land north of Hawkenbury Recreation Ground 

The creation of the new sports hub  is welcome and the use of the site appropriate in preference to additional residential development so close to the AONB.

Access to the site should be via Hawkenbury Recreation Ground as the access via High Woods Lane is unsuitable for motor vehicles because of the rather dangerous junction with Halls Hole Road, itself far too close to the junction with Hawkenbury Road. But an active travel route to a secondary entrance on High Woods Lane would be of significant benefit as would the closure to through traffic of Halls Hole Road itself.

DLP_2911

Chris Gow

Object

I object to this development.

It is Green Belt land and lies within the AONB, and should not be developed.

DLP_4277

RTW Civic Society

 

a) The concept of the proposed hub will undoubtedly help the organised sports. What isn’t clear is whether there will be sufficient spaces within the town for kids to kick balls about.

b) No mention is made of what parking for cars will be provided, nor whether restrictions will be imposed on surrounding streets. Have you looked at what happens when St. Marks rugby ground holds a junior tournament? The surrounding roads are packed with parked cars.  If the new sports hub is going to be bigger than the rugby club……  Also, how much parking will be provided on the site?

c) the plan only talks about improving junctions and crossings.  We would venture to suggest that at the very least, some road widening would be required.

DLP_2820

Mr Nicholas Pope

General Observation

The provision of additional football fields, including a football stadium to replace the Culverden Stadium, north of the Hawkenbury Recreation Ground creates a number of challenges that must be addressed if this is to proceed.

Transport provision: Sustainalble travel must be a priority if this is to proceed with well designed cycle routes and pedestrian access from the town centre to reduce the number of motor vehicles travelling through town to access the new playing fields. Hawkenbury is further from the other parts of town than the Culverden Stadium and, therefore, is likely to create more journeys and longer journeys across town. There are also major concerns about Halls Hole Road and the additional traffic on this narrow road creating increased danger to residents on the road, pedestrians, and people in motor vehicles. It is not a suitable road for large amounts of traffic.

Parking: Sufficient parking needs to be provided to ensure visitors do not fill up all the residential roads and park on verges along main roads. There are already parking problems on weekdays with workers parking badly.

Noise and light pollution: The location and design of floodlit pitches needs to minimise the disturbance to residents who live close to the fields.

Creating additional sports fields is preferable to building houses on this site.

There are also concerns with losing the playing fields at Culverden Stadium (AL/RTW 21), Cadogan Sports Field (AL/RTW 24), and Colebrook Sports Field (AL/RTW 25) for development, making sports fields less accessible to residents and younger people across town.

DLP_3420

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_1675

TWBC Property and Estates

TWBC

Support

a.      Paragraph 5.39. Bullet 4. There are 2 field gates off High Woods Lane. Bullet 6 should more clearly say that it is the ‘Land to the north of the existing Hawkenbury recreation ground’. Bullet 7 referring to ‘part of the land’ description is misleading. The planning consent 17/03232 was for all of the land.

b.      It is considered unreasonable to seek substantial transport contributions to a junction that is not yet designed nor costed, as well as being some distance from the allocation site.

c. Paragraph 6.540 and TP6. Reference to this proposal is unclear. There are no details at all on the Halls Hole Road alignment on the proposals map. Nor any implications that it may have on nearby land including this allocation.

DLP_2052

Terry Everest

General Observation

Query

Will this site retain natural grass and other elements such as plants hedges and trees - that is a vital must !, I would not like to see anything similar to the unnatural built and fenced approach which has occurred at the Tunbridge Wells Grammar Schools fields - these now look horrible, are overly artificial and are totally restricted from the people.

This one site cannot replace many other local green spaces - that is clearly wrong both in fact of likely usage and in sustainability terms - this policy is ill though out in general. This site is supportable but not at the loss of other playing fields and sports pitches.

DLP_2373

Malcolm Wimshurst

Object

Having played bowls, outdoor in the Hawkenbury Recreation Ground from 1965 until 2000 and as a founder member indoors since 1986 and still playing at the Royals at the bottom of High Woods Lane I am all for sport in Hawkenbury but DEFINITELY NOT FOR FOOTBALL ON THIS SITE.

Living in Chester Avenue like others we would be overlooking the proposed football pitches. In time, if not all at the beginning, this would mean high fencing, flood lighting, stands, changing rooms, toilets and a large parking area all bringing an increase in traffic and it would completely ruin our final years in an area we have been so happy in after moving here 12 years ago.

The language from the players on all the weather pitch can at times be intolerable, as is the flood lighting but that would be nothing compared to the football pitches on the new proposed site together with the extra parking needed and all much, much nearer. Parking is already a big problem in this area. Vandalism would surely also increase over such a large site.

Sherborne Residential Home for elderly people, Cleeve Avenue, Chester Avenue and High Woods Lane resident's lives would all be drastically changed for the worse in what would be seen by the majority as our peaceful retirement years.

PLEASE DO NOT GO AHEAD WITH THIS PROPOSAL BUT THINK OF PEOPLES LIVES FOR ONCE AND NOT THE POUNDS, SHILLINGS AND PENCE MADE FROM SELLING OTHER COUNCIL OWNED GREEN SPACES FOR HOUSING WHERE FOOTBALL PITCHES WOULD BE FAR BETTER SUITED.

Thank you for reading my objections.

DLP_3218

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 – “Development shall implement schemes/contribute to schemes to make substantial improvements to local road junctions and crossings within the immediate area, and to other traffic or sustainable transport measures; to include the access junction with High Woods Lane, High Woods Lane/Halls Hole Road, Halls Hole Road/Forest Road, Halls Hole Road/ A264 Pembury Road (and/or contribution to junction improvement investigation/implementation on A264 Pembury Road) (see Policies TP1: Transport Assessments, Travel Plans and Mitigation and TP2: Transport Design and Accessibility)”

Additional paragraph - Widening of High Woods Lane to the west of the site access from single-way working to cater for additional trips.

Additional paragraph - Provision of overspill parking area.

The standard paragraph regarding contributions should also 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.

DLP_5044

Hawkenbury Village Association

Object

We strongly object to the new sports hub at Hawkenbury Recreation Ground, to include standing/seating for supporters and other ancillary structures, other sports and recreation grounds and built facilities (Policy OSSR 2: The provision of publicly accessible open space and recreation), specifically offering two senior pitches (one of which to be 3G/stadium quality), three youth pitches, and one mini pitch.

Hawkenbury Recreation (Rec) ground already has the astro turf , which is a Borough wide facility that attracts a lot of traffic and creates a lot of noise and light pollution (including in the evenings) and to put another Borough wide facility in close proximity would stretch local facilities too far.

We strongly object to the relocation of Tunbridge Wells football club (TWFC) to Hawkenbury Rec and the standing/seating stadium provision proposed. TWFC currently have seating for 250 supporters and a total capacity of 3,750 people. Attendance at games is typically 300 supporters. We strongly object to the scale of this development in Hawkenbury, which does not have the utilities, parking or transport provision for the footfall of supporters, as well as all the other users of the new sports hub and those enjoying the park and children’s playground. There is also no provision for if TWFC are promoted to a higher league and then the number of supporters increases. The current proposed space and infrastructure would not be able to withstand the increased supporters.

The proposed sports hub and stadium will negatively impact the lives of Hawkenbury residents, particularly those living adjacent the pitches/stadium – in Hollyfields, Hawkenbury Rd, Sherborne Close, High Wood Lane, Chester Ave and Cleeve Ave. There will be increased traffic, parking on driveways and pavements, earthworks, noise and air pollution, floodlights and anti-social behaviour. We do not have transport links serving Hawkenbury, with 1 bus service serving the area. Hawkenbury Rec is adjacent to AONB, and there is a stream running alongside the proposed site, which is part of the river and not a culvert as believed by the council.

The anti-social behaviour (i.e. shouting and swearing from the sidelines) that comes with such facilities is not in keeping with the Hawkenbury Recreation Ground, it’s very close proximity to residential property and the children’s play area. We draw your attention to an article written in KentLive, 15th Oct 2019, https://www.kentlive.news/sport/football/children-left-traumatised-afterhuge-3431513 about children left traumatised after a huge brawl at TWFC ‘sparked by a racist comment’ on October 5th when they were playing Beckenham Town FC.

It is also reported in Kent Live that Chairman Scott Barlett stated ‘If we moved we would want to control our own destiny and we would want to manage the stadium, we’d want the revenue from the gate and the clubhouse and we would rent out the 3 or 4G pitch and get the revenue’. This will not be possible or feasible for a site owned and managed by TWBC, and within a local Recreation ground.

We strongly object to relocating TWFC and a proposed “stadium” to Hawkenbury Recreation ground. It clearly has not been thought through. We suggest that a sustainable, state-of-theart stadium with provision for increased supporters, traffic is built elsewhere and closer to main transport links and not adjacent to residential properties, a recreation ground and children’s play area.

DLP_7253

Mr John Telling

Object

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected.

My reasons for wishing to retain these sites include the following:

1. To reduce our carbon footprint we have to reduce the need for all travel, including that to accessible open space. This policy is at odds with the imperative need to cut CO2 emissions and pollution. A policy which promotes more driving about is irresponsible. It will force more people into cars on our already congested roads, increasing traffic congestion and pollution simply to access recreational open space.

2. We need to develop and protect local green spaces for children/families to be able to play, relax and socialise. Many individuals and families have no or only small gardens. Families with children need open spaces near their homes to play with a ball, cycle on their bikes, and meet with friends and family without having to drive or be driven across the borough.

3. People need open space to walk, run and socialise with others in their community.

4. Green spaces are increasingly recognised as necessary for good mental health and physical wellbeing. They bring natural features into an urban area and help people feel better about their local environment.

5. Trees and vegetation help improve air quality and absorb CO2.

Removing local playing fields will be detrimental to the borough and people's quality of life. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable without access to private transport. Public transport to Hawkenbury is limited. And why should people have to use transport, public or private to access social open space? People should be able to access open space on foot.

Other sites and approaches that do not involve building on playing fields and informal open space should be considered.

This proposal is environmentally and socially retrogressive and contrary to residents' wellbeing needs.

DLP_6097

Mark Cowen

Object

I am opposed to the proposed relocation of Tunbridge Wells Football Club to the area in High Woods Lane Hawkenbury for the following reasons:-

The scale of this proposed development will completely ruin the village atmosphere of Hawkenbury. I can already hear the shouting and language from the existing astro turf/football pitch near the recreation ground which is a concern for the families which live within this area; the proposed size with numerous pitches would subject this village to an unacceptable level of noise and congestion. There will be flood lighting which will cause light pollution and have a huge impact on those residents surrounding this proposed development. The existing road infrastructure cannot cope with the volume of traffic especially Bayhall Road and Halls Hole Road which are already grid locked at various times of the day and the influx of additional vehicles to Hawkenbury will cause the roads to become even more congested increasing the traffic pollution. There will be vehicles parked carelessly wherever the occupants choose to dump them as well as little regard for the residents of this village. It will create the potential for anti social behaviour and the residents will be subjected to unwelcome noise, littering and disruption of an unprecedented level. The proposed decimation of the land around the Bowls Club is unwelcome and will cause damage to the existing wildlife and serenity of this area. The proposed football hub with a total capacity (at the moment) of 3750 people will turn Hawkenbury into a no go area and cause untold misery for its residents. The proposed substantial road improvements within this immediate area will have little impact and the existing road network, Bayhall Road and Halls Hole Road will be unable to cope with the potential influx of a few thousand vehicles at one time if full match capacity is reached. The road network around Hawkenbury and many parts of Tunbridge Wells are continuously at a standstill during busy periods and this will cause chaos to the already congested roads. A foolish proposal that will completely ruin Hawkenbury and change it forever. I’m finding it difficult to even understand how this is even being proposed!

DLP_6189

Turley for Bellway Homes Strategic

 

We write on behalf of our client, Bellway Homes Strategic, in relation to the Regulation 18 draft Local Plan for Tunbridge Wells Borough which is currently subject to public consultation. This letter provides the background to Bellway’s interest in the Borough and sets out representations on their behalf.

BACKGROUND

Bellway has a legal interest in the land to the north and south of High Woods Lane (Mouseden Farm) on the eastern edge of the built up area of Tunbridge Wells/Hawkenbury which it is promoting for residential led development. The land promoted by Bellway is identified on the plan at Appendix 1 of these representations. The site is separated by High Woods Lane. The area south of High Woods Lane is currently in agricultural use and bordered to the east by woodland, to the south by existing sports uses and to the west by existing residential development. The area north of High Woods Lane is also within agricultural use, with further agricultural uses/woodland to the east and an indoor bowls club and allotments to the west.

The adopted Proposals Map indicates that both parts of the site are within the Green Belt and AONB.

On the basis of the Proposals Map published as part of this consultation indicates that the southern part of the land (south of High Woods Lane) is to be designated under Policy RTW23 with that area to adjoin the ‘Proposed Limited to Built Development’. The northern part of the land promoted by Bellway is not subject to any other proposed designations. The draft Proposals Map appears to indicates that both parts of the site will continue to be located within the Green Belt and AONB (although the resolution of the Proposals Map published as part of the consultation is very low quality).

In 2017 Tunbridge Wells Borough Council itself submitted an application in relation to the land south of High Woods Lane. This application (17/03232/FULL) proposed the following development:

“Change of use of part of land to expand existing recreational facilities through provision of additional sports pitches, together with associated access, car parking provision, 'ball stop' fencing, changing room facilities and other works”

Application 17/03232/FULL was granted on 20th December 2017 and the permission is subject to a standard condition that development shall be begun before the expiration of 3 years from the date of the decision. The permission is also subject to a number of conditions which require details to be approved prior to the commencement of development.

It is clear from the application form that the Borough Council, as applicant, did not control the land required to deliver the abovementioned development.

In the period since permission was granted, we understand that the Borough Council has made no attempts (through any procedural mechanism) to acquire the land. Furthermore, the Borough Council’s website does not indicate that any submissions have been made to discharge pre-commencement conditions.

These representations are also accompanied by an Outline Landscape, Visual and Green Belt Advice Note prepared by Turley on behalf of Bellway. This demonstrates that the contribution made by the site to the Green Belt purposes has been overstated. This note also demonstrates that views of the Site from the surrounding landscape to the east, including the wider extent of the High Weald AONB are limited by the mature vegetation within High Wood and the ridgetop topography;

MASTERPLAN

In order to demonstrate that this site can accommodate development, an illustrative masterplan has been prepared. This demonstrates that residential development would be located to the north of High Woods Lane, with this area also accommodating a network of open spaces and planting. To the south of High Woods Lane the masterplan demonstrates how sports pitches can be accommodated in this area.

Bellway is capable of facilitating the delivery of the sports pitches within the wider site promoted via these representation in conjunction with residential development at the site. Bellway would be willing to enter into dialogue with the Council as to how this site could be delivered whilst providing the sports pitches. Bellway would be willing to then transfer the recreation and sports facilities to the Borough Council. The application for the sports pitches (made by the Borough Council) explained that the additional provision would help to remedy shortfalls present in the area in youth pitch provision.

As these representations advocate, the emerging Local Plan should be revised to include a policy which seeks to facilitate the recreation and sports facilities at this site, provided in conjunction with and facilitated by, residential development at the wider site. Bellway would be willing to engage with the LPA regarding the wording of any such policy.

[TWBC: see full representation and Comment Numbers DLP_6189-6198].

SUMMARY

These representations set out significant concerns regarding the draft Local Plan for Tunbridge Wells Borough. In summary, the level of housing required to address issues of affordability and does not provide any realistic opportunities to make a meaningful contribution to meeting affordable housing needs. Whilst the Council claims that the housing supply represents a buffer over the planned requirement, this is based on extremely optimistic assumptions and short lead in times before the key sites deliver. In the case of Paddock Wood the Plan then relies upon very high delivery rates.

A more diverse and greater range of sites are required to address affordability, provide affordable housing and to help ensure that the housing requirement is achievable.

The Plan also provides a disproportionally low level of new housing at Tunbridge Wells despite the sustainability of this settlement, in comparison to other, less sustainable locations. This is borne out by the selection of the Tudeley Village site as a location for a new garden village in a remote location. Alternative options are available which would direct development to the most sustainable settlement (i.e. Tunbridge Wells) and which are in sustainable locations.

This conclusion is supported by the Council’s own evidence which demonstrates the availability and suitability, sustainability and logic of alternative sites on the edge of Tunbridge Wells (including the land promoted by Bellway which is subject to these representations).

The Council’s own evidence has overstated the contribution that certain sites, including the land promoted by Bellway which is subject to these representations) makes to the Green Belt. When the land is assessed in a more robust manner (and when assessed independently rather than as part of wider Broad Areas), the contribution is significantly reduced.

The southern part of the land promoted by Bellway (i.e. the land south of High Woods Lane) is subject to a planning permission for recreational uses. That application was submitted by the Borough Council, however the Council has no interest in the land and has not taken any steps to discharge pre-commencement conditions. In contrast, Bellway has a legal interest in the land and is promoting this area, as part of a wider site, for residential development. Bellway would be willing to work with the Borough Council to explore opportunities for bringing forward the approved recreational facilities in the area, which residential development on the site could help deliver.

As it is currently drafted the Local Plan is unsound. These fundamental issues of unsoundness are compounded by a lack of documentary evidence to explain why the Council has selected the approaches and proposed allocations in the emerging Local Plan.

Bellway would be willing to enter in to dialogue regarding the land north and south of High Wood Lane and the extent to which this site could deliver housing (delivering the greater range and diversity of sites) in a sustainable location. Bellway would be willing to discuss the manner in which such housing could assist in delivering additional recreational facilities in the area.

DLP_6197

Turley for Bellway Homes Strategic

 

This proposed allocation relates to the southern part of the land promoted by Bellway. As the draft Local Plan acknowledges, this area does benefit from planning permission granted in 2017 for recreational facilities. No submissions have been made to discharge the conditions of that permission. Moreover, the land is subject to an option in favour of Bellway for a number of years. The fact that this site and land to the north is subject to an agreement with a national housebuilder (who is promoting the site for residential development and recreation use) is clear indication that the allocation of this site for solely recreational purposes (as envisaged in Policy AL/RTW 23) is undeliverable without being facilitated through a comprehensive site development policy including an element of housing to the north.

In addition, as we explain elsewhere, the Council’s own evidence, namely that undertaken by LUC overstates the contribution (and therefore harm) that releasing the are proposed for recreational purposes under allocation AL/RTW 23 makes to the Green Belt. This area forms part of parcel TW6a. The contribution of Parcel TW6a as a whole has been overstated, however as the Turley Outline Landscape, Visual and Green Belt Advice Note demonstrates, the southern part of the land promoted by Bellway makes a lesser contribution in its own right.

Furthermore, we refer to the SHELAA analysis of site 53 which found that it was (in part) a suitable, sustainable and logical site for development. Those specific references were to the southern part of the site promoted by Bellway and so relate to the area proposed for designation under Policy AL/RTW 23. Those conclusions were made in a document which considers the suitability of sites for housing and economic purposes and so must be read as relating to such forms of development, rather than recreational uses.

Although the Council has published a number of documents in support of the draft Local Plan in relation to open space and sports facilities, as far as we can establish, none of those refer to the necessity or appropriateness of allocating the site AL/RTW 23 for recreational purposes.

It appears as though this site is proposed for allocation simply because of a planning permission granted in 2017 yet no thought has been given as to how it will actually be delivered. In contrast the Council’s own evidence (in the SHELAA) refers to its suitability, sustainability and logic for housing/economic purposes.

The allocation under Policy AL/RTW 23 is therefore fundamentally unsound and undeliverable.

Bellway is capable of facilitating the delivery of the sports pitches within the wider site promoted via these representation in conjunction with residential development at the site. Bellway would be willing to enter into dialogue with the Council as to how this site could be delivered whilst providing the sports pitches. Bellway would be willing to then transfer the recreation and sports facilities to the Borough Council.

As these representations advocate, the emerging Local Plan should be revised to include a policy which seeks to facilitate the recreation and sports facilities at this site, provided in conjunction with and facilitated by, residential development at the wider site. Bellway would be willing to engage with the LPA regarding the wording of any such policy.

[TWBC: see full representation and Comment Numbers DLP_6189-6198].

DLP_6231

Sylvia Joyce

Object

I am writing to strongly object to the proposed building of a football club in this location.

This is a quiet residential area and not the place for a huge football pitch etc. The lane you intend to lead to the location is already blocked by cars parked down one side, and the lane it leads from (Halls Hole Road) is already a nightmare, also the exit to Bayhall Road is almost impossible sometimes. The infrastructure is not in place for a huge project like this.

You may think you can improve this but there is no way these roads can be made wider, bigger or good enough to maintain the amount of traffic expected.

At the moment the recreation ground is just right and used by many people, including children. Also for picnics etc. There is cricket and hockey played and also a very nice children's playground. Many local people use it and this would all be lost if you went ahead with your plan.

Why is it necessary to move the football club when they already have one in Tunbridge Wells?

I am also worried about anti social behaviour which normally comes with football supporters, and the safety of the local people near the stadium.

Please leave the football club where it is.

PS Why have I had to find out about this from a friend? Do you not think to ask the locals what they think?

DLP_7704

Elizabeth Ugarow

Object

I am appalled at the shock announcement of a Major sized Stadium being planned WITHOUT Hawkenbury Residents knowledge/last minute! Via a leaflet through the door of my vision impaired brain damaged son.

Tom (my son) moved to the quiet and peaceful village of Hawkenbury-green in October/November 2014 to be near his siblings and their families who live in Tunbridge Wells & Sevenoaks. I immediately saw the dangerous 3 way junction Bayhall Rd/Hall’s Hole Rd/Highwoods Lane. I rang the council to ask for a pedestrian crossing to be installed & was told “not until a major Road Traffic Accident occurs there.” Well, my son has already suffered a near death traffic accident - having him at aged 22, in May 1996 with severe life changing injuries internal & cortical brain damage. His sister found xxxx for sale [TWBC note: postal address has been redacted]. It has been adapted for his needs & with ten hours care he is determinately pushing forward with his life despite near misses with huge farm vehicles, speeding car drivers on Highwoods Lane, Hall’s Hole & Bayhall roads. Plus verbal & dog attacks in the local parks. No police presence/community officers are ever seen.

We have asked & asked for pavements to be resurfaced, potholes are everywhere. Tom’s brain shakes in his head when driven in a car particularly in town & Culverden Down which is in my area with bumpy speed bumps & deep potholes. He constantly trips on uneven pavements attaining even more head injuries (very smooth pavements around the Town Hall). Cleeve Avenue itself needs resurfacing & repairing. Also Tom has teams of carers that must park in front of his house as he needs assistance getting in & out of a car & with walking plus carrying shopping & equipment.

WE ARE ALSO SPEAKING on behalf of Tom’s neighbours, many of whom are in their eighties & nineties & need peace & quiet & NOT to be invaded by noisy football crowds & THEIR VEHICLES day & night. With risks of crimes & brawling that has already happened at HawkenburyRec & abusive language. Another one on my sons has an allotment near the Indoor Bowling Club. It is the only place in the week where he can spend quality peace & quiet with his AUTISTIC, EPILEPTIC, DIABETIC son gardening...

What a thoughtless, insensitive, ruthless attitude to the community this invasive “plan” is. SECTION 5-37 DRAFT LOCAL PLAN a NO! NO! from the Residents & Allotment holders of Cleeve Avenue, Chesterh Avenue & High Woods Lane. This quiet peaceful backwater has already changed in the last five years due to speeding traffic & commuters using it as a car park! All the wildlife will suffer - woodpeckers, owls, squirrels, birds nests, foxes, & wild fowl.

Do come and visit Tom and see what I mean - fresh air, vistas, sky expanse, hedgegrows, WILL VANISH...NO!

DLP_7493

Ian Kirkham & Lianne May-Kirkham

Object

We strongly object to the relocation of TWFC as part of the Sports Hub proposal. The area will not support this kind of development and the lighting, noise, earthworks, proximity to housing, ancient hedgerows and woodland, flooding issues, interruption of the flow of the river tributary, anti-social behaviour, parking and traffic, likelihood of TWFC using the site for large social gatherings of up to 3.750 people and the development of current facilities at Culverden, Cadogan, Bayham and Colebrook for housing is short sighted and not in the best interests of the town nor the elderly residents who live on the boundary of the proposed Sports Hub who are still unaware of the true nature of this development as TWBC has not engaged in a meaningful way with them as part of the consultation. We wholeheartedly object!

DLP_5864

Beverley Norman

Object

I am writing in this form because your website is not user friendly unless you are a regular computer user.

I am a resident of Hawkenbury and have been for all my life. I was appalled  to learn of your proposed Sports Hub you wish to build at the bottom of High Woods Lane.

How on earth is this ever going to enhance any ones lives or the countryside in and around the area.

High Woods lane is narrow with allotments and Bungalows either side, also small housing just at the top of Dunorland field, just over the field is Sherbourne Close an old peoples retirement estate. Having football matches and the noise pollution on the scale mentioned would be horrific  for the surrounding area. Sherbourne would eventually close because no one will want to live there.

Halls Hole lane leading from Pembury road would be constantly grid locked with the volume of traffic trying to converge onto a small country road. Yet again your desire to cut down trees and destroy the countryside outweighs your logical thinking in this time of horrendous climate change and wild life being destroyed.

To have over 3000 people trying to get to Hawkenbury from all over Kent on Match days or a number of events running simultaneously in a Sports Hub will cause chaos on the A21, Pembury Junction,  Pembury Road (witch is already congested on daily basses. ) as well as Forest road, Halls Hole Lane junction which again does not work efficiently on rush hours with the volume of traffic.

It appears once again you fail to show any thought or consideration for you constituencies’ in your determination to line your own benefits. You again are loosing valuable voters in this area.

DLP_8359

Angela Funnell

Object

Paragraph 5.37: The Sports Strategy for Royal Tunbridge Wells

This includes:

  • Policy AL/RTW 21 Land at Culverden Stadium, Culverden Down
  • Policy AL/RTW 22: Land at Bayham Sports Field West
  • Policy AL/RTW 23: Land to the north of Hawkenbury Recreation Ground
  • Policy AL/RTW 24: Land at Cadogan Sports Field, St John’s Road
  • Policy AL/RTW 25: Land at Colebrook Sports Field, Liptraps Lane

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected. My reasons for wishing to retain these sites include the following:

  1. We need green spaces for children/families to be able to play. Some families don’t have gardens, or only small ones. They need places near their homes to play with a ball, cycle on their bikes, and play with friends and family without having to be driven across the borough.
  2. People need them to walk, run and socialise with others in their community.
  3. They are good for our mental health and physical wellbeing. They beautify an urban area and make people feel better about the environment they live in.
  4. The trees and plants help provide good air quality.

Removing the local playing fields will do much harm to the borough. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable. It will also force more people into cars on our already congested roads, increasing traffic congestion and pollution. Other sites should be considered that do not involve building on playing fields.

DLP_8363

Sally Antram

Object

Paragraph 5.37: The Sports Strategy for Royal Tunbridge Wells

This includes:

* Policy AL/RTW 21 Land at Culverden Stadium, Culverden Down
* Policy AL/RTW 22: Land at Bayham Sports Field West
* Policy AL/RTW 23: Land to the north of Hawkenbury Recreation Ground
* Policy AL/RTW 24: Land at Cadogan Sports Field, St John’s Road
* Policy AL/RTW 25: Land at Colebrook Sports Field, Liptraps Lane

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected. My reasons for wishing to retain these sites include the following:

1. We need green spaces for children/families to be able to play. Some families don’t have gardens, or only small ones. They need places near their homes to play with a ball, cycle on their bikes, and play with friends and family without having to be driven across the borough.

2. People need them to walk, run and socialise with others in their community.

3. They are good for our mental health and physical wellbeing. They beautify an urban area and make people feel better about the environment they live in.

4. The trees and plants help provide good air quality.

Removing the local playing fields will do much harm to the borough. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable. It will also force more people into cars on our already congested roads, increasing traffic congestion and pollution. Other sites should be considered that do not involve building on playing fields.

In addition, focusing all the town’s main sports facilities in one hub in Hawkenbury will inevitably cause problems for that area of the town, including increased traffic and congestion.

DLP_3406

D Haffenden

Object

Ref Response to TWBC Draft Local Plan (Regulation 18) Section 5.37 HAWKENBURY SPORTS HUB

Find below my comments for consideration regarding the proposed sports hub in Hawkenbury.

1. In general the ideas of a sports hub, whilst far from ideal for the area, would be acceptable without the Tunbridge Wells football club (TWBC) and all that it would attract ie crowding, transport chaos, anti social behaviour, little, noise.

2. Road infrastructure is not suitable for the increased volume of traffic expected. Halls Hole road and Highwoods Lane are not suitable for modification and would be difficult to implement.

3. Pollution increase due to cars and larger transport.

4. Insufficient information about the precise location of the TWBC stadium and its main entrance route has been given. Highwoods lane is not suitable for this and due to the ancient hedge rows it would unacceptable for widening.

5. As there is steep slope on the proposed site it will take considerable expense and upheaval to level it suitable for playing pitches.

6. There are many elderly people in close proximity to these proposals who are already disturbed by the existing sports activities in the Hawkenbury recreational ground.

7. As far as Highwoods Lane is concerned it already has problems due to AXA, Nuffield Hospital Hospital staff & commuters using this area as a free car park, making it impossible for the Hawkenbury Allotment Holders to park so that they can access their plots during the week. Heavy (enormous) agriculture vehicle movement from the farms further down the Lane, and not inconsiderable traffic movement including buses going to the indoor bowls club.

8. Adequate parking facilities must be provided for cars, coaches, mini buses and motor bikes etc. It is far from clear t

hat this has been sensibly addressed.

9. There is a genuine fear that will be used for alternative activities activities such as fund raising for TWFC should it be located here. We are in the area already have to tolerate the activity site in Dunorland park and the associated parking and noise problems..

10. Finally how will the policing be undertaken and who is responsible for it.

I hope you find these comments both constructive and informative

DLP_3047

Barry and Susan Richardson

Object

Response to TWBC Draft Local Plan - Section 5.37

We are generally supportive of improved sports facilities for this area. However, we do have concerns expressed below, which we hope will be taken into account for the Final Local Plan.:

1.) The original PP granted (TW/17/03232/Full) appeared to be for a fairly modest scheme involving a few football pitches. The proposed Sports Hub Scheme in the DLP far exceeds this and the scale will have astronomic overloading effects on the local community and the environment.

Claims in the 'MONSON' transport statement 28/11/2017 (that supported 17/03232) that there will be 'insignificant' effects are flawed. One has only to visit the TWRFC at Forest Road/Frant Road at weekends to see the effects of traffic and parking in the surrounding roads relevant to that site. Similar effects could well be seen as the result of this development if the wrong assumptions are made and they will be worse due to very narrow lanes. The High Woods Lane already suffers from the effects of 'free' parking by employees from local agencies and commuters to Tunbridge Wells, London etc, albeit this is mainly on weekdays. In addition, the lane carries large numbers of cars and coaches to/from the Royal Bowls Centre as well as many massive vehicles serving the farms and commercial enterprises beyond the Centre. Putting it simply, modifications to the current infrastructure will not be able to sustain the true impact of the Sports Hub scheme, i.e. the High Woods Lane access route will be hugely overloaded and cause significant problems for the largely very elderly residents and the very valuable Hawkenbury Allotment Holder's Association (HAHA) community facility.

The Hub Scheme will ahve the potential to be an all-day/night facility for schools and clubs as well as the more established sports association such as the TWFC. In addition, the latter has stated they would want autonomy to run their club, which will have a stadium. This could lead to events such as music and other concerts, which would add to disturbance, noise and lighting pollution, litter and anti-social behaviour.

The existing controlled-access gate to the Royals Bowls Centre and beyond, limits anti-social behaviour such as theft from the Centre and the farms and fly tipping in the High Woods. This measure would need to be suitably replaced or upgraded.

PP 17/03232 showed inadequate parking facilities i.e. only 65 car spaces and no provision for coaches, buses or mini buses. In addition, the proposed access and parking faciliteis suggest woefully inadequate provision to prevent congestion and blockages to adjacent roads and residential housing. The health and safety of the largely very elderly population is an important issue.

Pedestrian and bicycle access to the site from the existing recreation ground and the new housing and school developments at the 'Hawkenbury Farm Site' might help with traffic/parking problems. This would be truly indicative of a good sports facility and the modern emphasis on encouraging less motor traffic and promoting healthier lifestyles.

The Hub Scheme would need to demonstrate adequate provision for changing and toilet facilities, which was not he case in PP 17/03232 and fell short of Sport England standards. Use of ancient  hedgerows and woodland would not be a healthy option.

2.) The area features an AONB, a Local Wildlife Site (TW21), an MGB1 Sensitive Area, Agricultural Land Grade 3, Ancient Woodland Hedgerows, a Public Right of Way (WB43) and Public Access Land High Wood. These features provide an important social amenity. They also provide important environmental corridors for wildlife such as bats, dormice, reptiles and insects, particularly butterflies. Thus, the effects of the Sports Hubs Scheme development are very likely to have a significant negative impact on the ecology of the nearby ancient woodland and hedgerows though huge disturbance and fragmentation, both during massage excavation works and the on-going human activities.

3.) The scale of the Sports Hub Scheme will have significant negative effects relating to noise and lighting pollution and potential anti-social behaviour, as witness recently at the existing TWFC Stadium. Light pollution from any flood lighting would adversely affect both the local population and wildlife and add to the 'Dark Skies Issue'. The overall effects would be hugely unfair on the elderly Sherborn Close residents, who already suffer from those associated with the all-weather pitches in the Recreation Grounds to some degree. They would become almost surrounded by those adverse effects.

4.) The area forms part of the Wealden Clay Ridge and this feature might well add to the already significant problems relating to drainage and local flooding. The 'ditch' referred to in the MONSON report LGL/8550O is a stream system in the area that is fed by many natural springs and is an important part of drainage in the area. It flows to the Dunorlan Park and then eventually to the River Medway. It has been known to burst its banks in tiems of heavy and or protracted periods of rainfall especially in winter months, when the Medway backs up in times of flooding. Hence the earth mounds constructed to prevent flooding of the carpark to the Royals Bowls Centre.

5.) It is understood that Southern Water has stated their sewage pumping station at Cleeve Avenue is already running at full capacity and would not be able to sustain any further loading.

We hope you find these comments helpful.

Policy AL/RTW 24: Land at Cadogan Sports Field, St John's Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_39

David Hodgkinson

Object

Building on an aready very conjested road with dangerously high air pollution levels leading on to st johns road across a designated cycle lane surely must be a very poor planning decision that will impact on residents health. Secondly how can you compensate for all the families and sports clubs that operate at weekends that parents and children can walk to. How do you propose to transport these families across the town with no impact on the traffic and pollution levels already experienced. Surely it is time to open up the Sports centre on St Johns road to provide as bigger facility on the north side of Town as the proposed Hawkenbury development.

DLP_28

Peter Castle

Object

Object

DLP_198

Laura Partridge

Object

  • First and foremost, objecting on grounds of pollution. St. John’s Road has one of the highest readings of emissions from the Hand and Sceptre pub in Southborough and the old Kent and Sussex Hospital site. Extremely harmful levels of carbon and nitrogen dioxide. This is particularly concerning considering the amount of schools and therefore children along the road and that these chemicals lead to chronic lung diseases.
  • 30-40 houses, with households these days having an average of 2 cars per household = potentially 80 more cars mobile in the area. Traffic is already at a standstill on St. John’s Road with a large percentage of that traffic being HGVs, particularly large emitters of pollution.
  • Utterly irresponsible to add additional housing into this already congested area in view of the number of schools in the area and the threat to children’s health and ultimately their lives. A significant danger exists to young pedestrians throughout the day, travelling to and from school and to access sporting facilities in the case of The Skinners’ School boys walking to Southfields in Southborough for Games. Primary school children walking and on scooters and bikes are at risk and there will be accidents if not fatalities.
  • I refute the Council’s declaration that there is vehicular access and a main distributor road from A26 St. John’s Road. This is in fact a single lane access shared by pedestrians and several established trees mitigating the high levels of pollution from the A26. Presence of a nearby speed camera would also indicate that there is recurrent speeding at this juncture of the road. The allocation of parking spaces in the car park at the end of this lane are for use by members of the Masons and the Tennis Club and are also deployed as parking for participants in the Half Marathon in February.
  • These activities and events contribute to a sense of community. Customer’s enjoyment of these events would be diminished by the level of traffic encountered to enable access. There is a loss to existing community of provision of recreational space which is NOT replaced by driving over to Hawkenbury for their weekend sporting events. Locals compelled to drive to Hawkenbury defeats the objective of keeping fit and again contributes to emissions.
  • Ultimately, there is a tragic loss of green space here. We are already losing the bowling green which was a welcome green space in a highly residential area. There is a nationwide epidemic of obesity and call for recreational space and amenities to encourage residents to engage in more exercise. Not every family can afford to subscribe their children to expensive sporting clubs.
  • Why could Cadogan Field not be open to the public during the week and continue to support local sporting teams and events at the weekends?
  • Finally, I have consulted the Headmaster of a local school that has little to no green space on its site and hope that discussions could be had about the possibility of a school cricket pavilion for the enjoyment of hundreds of local school children.

DLP_248

Jane Walters

Object

In my view it is wrong for the council to sell the green space they own to build housing on.  I appreciate that selling land for development brings money in, but the council has a responsibility to take the long-term view and maintain the town as a good place to live.  People need houses, but they also need infrastructure - schools, public transport (that isn't stuck on congested roads), cycle paths, medical centres, sports fields, libraries.  In a world where people are already finding it harder to keep fit and active, bringing problems for their health, it is vital that the council looks to the future and provides a way for its residents to exercise and enjoy being outside rather than closing off options in the pursuit of short-term profit.

DLP_242

Joanne Stephens

Object

7) Suggestion - rather than develop every square inch of green space, the council have an opportunity to invest in the future of the physical and mental wellbeing of the local residents and utilise this space to create a lifestyle hub incorporating a community cafe & allotments as well as a sports field (eg for families and schools to use for rounders in the summer, football in the winter) and outdoor recreation equipment (perhaps an outdoor gym), keeping and adding to the existing trees would create a much needed oasis of nature within a growing built-up community.

DLP_247

Chris Walters

Object

Object

DLP_393

Nicholas Prideaux

Object

Policy AL/RTW 24

My main objections to development are:

  • Traffic. Traffic on St John’s road is of high density and building houses would add further to the chronic situation.
  • Safety. Related to the above point. With many schools in the area and a road already with a speed camera, indicating the risk of speeding, more traffic increases safety risk to children and the general public. Also access would cross over a cycle path, making it more dangerous to use.
  • Pollution. Related to the above point. With many schools in the area and high pollution on the road, the addition of further traffic will add further to the issue.
  • Sewerage. There is often smells from the drains at the entrance to the Masonic Hall and significant improvement would be required if the sewers are to cope with additional dwellings.
  • Drainage. The fields are low lying and covering over the grass will add to run off and cause potential flooding issues.
  • Green space. In an increasingly congested town, let’s keep open some green space so that we can all breathe and have open areas.

May I suggest that instead of developing the playing fields for housing we instead open them up for local schools to use during the week – Boys Grammar, Skinners, & St Gregory’s. This would keep the open space and provide for more sports and recreation in a built up area. The fields are already in use at weekends.

Thank you for the chance to comment.

DLP_7749

Skinners’ School

Object

The development of housing on Cadogan Sports Field will add to traffic congestion on St John’s Road and remove a useful sporting amenity in the locality.

Skinners’ School would be keen to purchase or lease the land in order to use it as a sports field and would do so virtually every day of the school year. We would also be pleased to maintain the sports field and to allow it to be used regularly by the local community.

I am disappointed to see that, whilst it is proposed to designate the whole of Southfields Park (the school’s current sports ground which is proving to be inadequate in terms of size for the range of sports players at the school) as a Local Green Space Site (thus diminishing our ability to develop facilties), an opportunity to expand our provision as a school (and a leading sports provider in the borough) would be denied by building over Cadogan.

I would therefore encourage the Council to reconsider any plan to build housing on Cadogan and to consider how an organisation like Skinners’ School could take it off the Council’s hands, look after it and keep it in the heart of the community.

DLP_725

Gemma C

Object

The main issue is that the main road (A26, St Johns Road) is already overly congested and building more houses on Cadogan Sports Field will increase congestion and pollution in an area that is already an air pollution management area (I understand that St Johns Road is the most polluted road in West Kent). It is also likely that more cars will use the nearby residential roads as rat runs to try to avoid the even more congested main road. The residential roads are narrower with cars parked on both sides, and it can be dangerous with cars weaving in and out of parked cars at speed, with young children walking along the pavements to get to/from the two local primary schools. Further houses and more traffic will have an impact on pedestrain safety and children's health, on both the main road (which is used by many secondary school children) and the nearby residential roads, with so many schools in the St Johns area. All of the greenery and established trees at Cadogan helps to mitigate the unacceptable levels of pollution in St Johns.

There should be green space and local sports fields in every community in Tunbridge Wells, not just Hawkenbury. The proposed sports hub at Hawkenbury is not a reasonable re-provision because:

- it's the other side of town, so will only increase traffic and pollution further, with increased numbers of people having to get in the car to play sport. It can be a nightmare travelling from one side of town to the other because the roads are so congested already and this will only exacerbate it.

- it will reduce the number of teams that can play Sunday league football as it’s not a 1:1 replacement in terms of total number of football pitches.

The are a number of potential issues with the site itself, including:

- only single carriageway access – this could lead to a tail back on the main road if there are drivers trying to get out of the development whilst others are waiting to get in

- localised flooding – there is often flooding in our back garden after heavy rainfall, and this will only get worse in this area if more houses are built, as the field helps to drain the gardens. I also understand that there is an issue with the drains serving the houses on St John’s road.

- houses will overlook the primary school and leave no room for the primary school to expand to service the growing population.

Also, we do not experience high levels of antisocial behaviour and vandalism, as suggested by TWBC. We have lived here for over 3.5 years (our house backs on to the playing field) and have never experienced any antisocial behaviour or vandalism of any kind (apart from the traveller community, which was an isolated incident and is nothing to do with the normal use of the playing field).

If the use of the site must change, please consider the following alternatives:

- keeping the field open during the daytime, so that the local community can use it when it’s not in use by the local football teams.

- makes the pitches available for use by the local schools - there are many schools very close by.

- make it a nature reserve area with benches etc – this would help with the unacceptable levels of pollution in St Johns

- putting a café there and outdoor play area for young children. A baby café, similar to the one in Langton Green (Langton Green Pavilion), would be a brilliant asset to the local community, with many young families living in the area. As well being used by families with very young children during the daytime, it is likely to be used by parents with primary school aged children after school pick up, with it being adjacent to the local primary school and very close to another local primary school. It could also be enjoyed by users of the bowling green and tennis courts etc.

DLP_872

Linda Davies

Support with conditions

Policy AR/RTW 24  Comment  from L Davies

I am the owner occupier of xx [TWBC: house number redacted] Powder Mill Lane TW, and have been for the past 36 years. The rear of my long garden abuts the northern boundary of the site in question.

1. Any reference to vandalism on this site is erroneous. I have accessed Cadogan Field regularly (unchallenged) during my ownership with only one occasion of abuse evident relatively recently when the field was occupied briefly by travellers. Any use by neighbours- albeit unauthorised - has been wholly respectful.

2. I support the conditional development of the site - in a sensitive manner - as it is currently an underused asset. Conditions are that the existing mature trees all around the periphery are protected, replacement facilities for football are provided, and the character of the whole area is respected, in terms of density, height and visual appeal and character of the detached and semi detached properties that surround it.

3. The number of houses provided on the site could be enhanced if all or part of my garden were included in the site for development. You will see that the rear section of my garden is identified on your plan as the only 2 adjacent blocks which have trees. The land is currently secondary woodland and orchard, as part of my garden and lies immediately to the west of St Augustine's school hard playground area, its field, and school buildings.

4. I would be happy to discuss opportunites for development of part or all of my garden in connection with this policy.

DLP_1172

Neil Stephens

Object

I would like to object on the following basis.

1 - TRaffic - the St Johns road area is already significantly congested as it is. Adding further housing that woudl feed out onto that road will just increase congetstion.

2 - Air pollution - Based on the increased traffic there will be a negaive impact on the quality of air in the St Johns Road area - an area hat already has very poor air quality. THis has been proven to have a negaive impact on childrens health.

3 - Pedestrian safety - The site is accessed by a single road bordered closely on both sides. there are schools either side of the site meaning that kids walk these streets with phones in hand and headphones on paying little to no attention to the fact that there will now ne an increased volume of traffic coming onto the road from an unexpected source.

4 - localised flooding - our gardens already get very wet - if we remove the trees bvordering the fields this is likely to get worse.

5 - The field is regularly used for sporting events (football every saturday and sunday in season. Removiung their accesss just means that they drive further afield to play increasing air pollution and traffic elsewhere.

6 - you say that there is a high degree of antisocial behavior and a large number of complaits - please share the data that backs this up as his is definitely not my experience.

Finally - the access to local facilities and green space is paramount and shoehorning everyone into one site just does not work for a community. This is a site that could be used for so much more than the few houses you are proposing. Examples of this are the utilisation of the pitches for other schools, allotments, wildflower meadows and eneral walking space all of which can enhance the community and air quality.

DLP_2913

Chris Gow

Object

I object to this development.

A development on this site removes a green space used for recreation, and the relocation of the sports facility to the Sports Hub adds to traffic movements, and looses the community aspect of a local sports field.

The development will likely result in the felling of mature trees, something that should always be avoided on developments.

The additional traffic movements onto St Johns from the proposed development is increasing the traffic movements onto an already congested route.

The green space is am amenity for local use that should be preserved.

DLP_1182

Joe C

Object

Policy AL RTW24 – Cadogan Playing fields

The main grounds for the objection are highlighted below:

Pollution and Congestion

-   St Johns (A26) is already one of the worst roads in Kent for pollution, adding further traffic would only increase dangerous levels.

-   Further congestion with cars trying to merge from the proposed development, will mean there are even more pollutants released given the undoubtable increase in stationery traffic.

-   There are 3 schools adjourning the A26 and the increase in traffic will further impact their health and increase safety concerns with the traffic volumes rising.

-   Given that the residential roads running parallel to A26 are used as a cut through to avoid the traffic currently, this will likely increase, again adding more pollutants and danger to the surrounding area. St Augustine’s is on one of the roads and high level of pollution can only have a detrimental effect on the primary school children.

-   Parking is already a problem on the surrounding roads and the proposed 40 new houses will likely make this worse, again increasing the dangers for the school children when crossing the local roads.

Schools

-   Local schools are already suffering from overcrowding and the further demand following the development could lead to greater travel times and further pollution for the area.

-   The development would prevent St Augustine’s from growing any larger and again would increase pressure on pupil numbers.

-   The development would directly overlook the school and intrude on the children’s privacy during school hours.

Reduced green space/sports facilities

-   The addition of the sports hub would reduce the amount of playing pitches available to Saturday/Sunday league teams, as only 2 teams would be able to use the new pitches at one time.

-   It would increase travel around Tunbridge Wells as sports teams have to travel to Hawkenbury rather than being able to play at the local grounds

-   With limited green spaces in Tunbridge Wells as it is it would be a real loss to the community to urbanise further, which brings with it further pollution.

-   There is currently localised flooding and this will no doubt increase if the development proceeds

n.b reference to anti-social behaviour is unfounded in recent years, I have been living on Wilman road for 3.5years and haven’t seen or experienced any anti-social  behaviour in Cadogan when in proper use.

Alternative/increased usage would be agreeable and some suggestions below:

-   Schools could utilise the pitches during the week, there are 5 schools in the close vicinity which could benefit from some extra sports/playing facilities.

-   Open up the space during day time hours to allow the community to use the space when the football pitches are not in use.

-   Create a park area with a café, these are very popular in the local area with the Langton Green café doing very well.

-   Nature reserve with benches and ponds to offset some of the A26 pollution

DLP_3597

Southern Water Services Plc

 

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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/RTW 24

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

DLP_2700

St John’s Road Residents Association

Object

AL/RTW 24, Site No. 237 Land at Cadogan Sports Field

The proposed development for 30-40 houses is on a sports field accessible only by way of a shared driveway off the A26 which is the most congested and polluted road into Tunbridge Wells. For a development of this size, developer must provide fully equipped childrens’ play space

The St. John’s Road area is also host to seven schools and the ones most affected will be St. Augustines Catholic Primary School, St. John’s Church of England Primary School, Tunbridge Wells Grammar School for Boys, Tunbridge Wells Girls Grammar School and Skinners Boys School.

OSSR 1: Retention of Open Space
An Open Space, Sport and Recreation Study (2018)(101) has been undertaken to assess the current level of open space, sport, and recreation provision within the borough.

We agree with the overall study conclusions are that the existing open space, sport, and recreation provision within the borough should be retained (unless alternative suitable provision is re-provided), quality should be improved, and provision for new facilities should be sought and supported. In the case of Cadogan Fields, we do not feel there is a need to move the facilities to a different site in accordance with the Playing Pitch Strategy because the land is used by residents and it does contribute to health and wellbeing of the children nearby. This is even more urgent as health problems are becoming acute as both adults and children suffer from obesity.

We agree with Policy OSSR 2 for locally accessible public space for neighbourhoods to prevent unnecessary travel by car to other sports pitches on the other side of the town.

DLP_1816

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Numbers:  AL/RTW 7,8,9,10,14,15,19, 24, 26,28,29,31,32

The above sites seem suitable for allocation subject to the proposed conditions written into the policies.

DLP_1676

TWBC Property and Estates

TWBC

Support

Para 5.40 should refer to 5.39 not 5.43

DLP_2035

Mrs Susan Tovey

Object

I would like to object to the plans to turn Cadogan Playing Fields into housing for the following reasons:

1 - St John's Road already suffers from very high levels of pollution. Adding more housing to the area will only contribute to raising this further. I am concerned of the health effects on not only my own children living here, but also the vast amount of children commuting to and from the large number of schools in the local area.

2 - St John's Road suffers from extremely high levels of congestion, particularly at peak times. More cars turning onto the road will only make this worse.

3 - Green space helps to naturally reduce air pollution. By taking this away you are not helping the area, which is already identified as an Air Quality Management Area.

4- Adding another junction onto St John’s road will make it even more hazardous for children commuting to school, they already have to navigate the extremely busy roads in the area. At peak times the pavements are very crowded with children walking and I often see near misses where cars simply do not slow down or even see the child. Cars park dangerously on the roads adjoining the A26 waiting to collect children, another turning will add to this problem.

5 – You propose moving the 2 playing pitches to Hawkenbury. This will mean local people will have to travel across town, creating even more traffic and pollution.

6 – I do not have any issues with anti-social behaviour in the field. I moved here 13 years ago and accepted that there would be vocal noise from football matches. I have never needed to complain and find it hard to believe that there have been ‘a large number of complaints’ and a ‘high degree of anti-social behaviour and vandalism’. I would like to see evidence to back this up by the council.

7– There is a problem with the wastewater drainage situated in the turning to the tennis club/masonic hall, which I believe frequently smells and blocks.  How will this be affected by adding up to 40 houses?

8- My garden has very poor surface water drainage in heavy rain conditions, along with many others along St John’s Road. It often floods, taking days, sometimes weeks for the water to disappear. If you take away the pitches and build, how will this affect the drainage going forwards for all the current residents?

9 – Why does the council not promote the field to be used more during the week? Schools in the area are constantly expanding and developing their sites to accommodate the vast amounts of children wanting to attend schools here. The playing field could be offered for school sporting use, rather than keep it locked up all week.

10 – As a local resident backing on to the field, we will be affected by a potential development. We will lose the privacy we currently have, and will no doubt be overlooked. Trees may be cut down in the field by a developer, which would also contribute to an environmental effect on the area. We may also be affected by noise to the rear, when we already have to deal with loud traffic, sirens etc to the front of our property.

DLP_2947

Peter Lidstone

Object

The proposed development for 30-40 houses is on a sports field is not suitable because;

- access to the site is restriced by way of a single carriageway driveway not suitable for a housing development.

- the A26 is one of the most congested and polluted roads in Tunbridge Wells. Outside this development is an Air Quality Management Area. To replace grass and trees with houses and cars will only exacerbate the problem. Additional vehicle movements will worsen the pollution in the area. The area hosts seven schools with St. Augustines, St. John’s Primary, Tunbridge Wells Grammar School for Boys and Tunbridge Wells Girls Grammar School and Skinners School all less than half a mile away.

- The field provides amenity to local residents, drainage for surface water and is used regularly by sports teams such as Hildenborough FC. Requiring these teams to all travel to a site miles away in Hawkenbury would generate additional vehicle journeys and discourage young people from participating in sport - particularly those whose parents are unable to drive them.

1 OSSR 1: Retention of Open Space

An Open Space, Sport and Recreation Study (2018)(101) has been undertaken to assess the current level of open space, sport, and recreation provision within the borough.

I agree with the overall study conclusions are that the existing open space, sport, and recreation provision within the borough should be retained (unless alternative suitable provision is re-provided), quality should be improved, and provision for new facilities should be sought and supported. In the case of Cadogan Fields, I do not feel there is a need to move the facilities to a different site in accordance with the Playing Pitch Strategy because the land is used by residents and it does contribute to health and wellbeing of the children nearby. This is even more urgent as adult and children obesity is on the increase.

I agree with Policy OSSR 2 for locally accessible public space for neighbourhoods to prevent unnecessary travel by car to other sports pitches on the other side of the town.

DLP_2770

Kate Whitehead

Object

I object to this proposal. I am concerned about access to the Cadogan Field - at the moment this is single lane, with no pavement, and directly onto St John's Road (A26).  This raises two critical issues: pollution and safety. The road is already congested and is identified as an Air Quality Management Area due to the already high pollution.  Hundreds of children walk up and down St John's Road every week day on their way to and from the many primary and secondary schools very close by - so safety of having to cross another road would potentially be an issue (as well as breathing in more fumes from cars waiting to enter/exit the new housing development).

The field is used regularly at the weekend and we understand that Skinner's School is interested in using the field during the week.  Your report says that there is a high degree of vandalism and anti-social behaviour and a large number of complaints - however, I think this is vastly exaggerated as, having requested further information from the council, we have been told there have been no complaints in 2019 (and I suspect that all previous complaints have been made by just one or two people), and no record of vandalism in 2019 either.

DLP_2053

Terry Everest

Object

Strongly Object

Prime example of a local sports pitch - which must be retained as such.

Usage and amenity are predominantly local and would be lost almost entirely, the amenity cannot be reprovided at Hawkenbury which is too far away for most users and ignores the local environmental value of the grren space and its important role as part of a patchwork of remnant green spaces.

DLP_1927

Rachel Gritt

Object

I object because I care about our environment.

We dont want more houses and cars in town, we want green spaces with trees, more busses and cycle tracks.

The traffic is bad and it is scary walking to school.

I think children need to exercise more and the playing fields here are wasted and should be open for us to use. Its not much use to local kids if the playing fields are moved far away.

I would like my town to be healthy and green. We could have solar panels put up on the changing rooms there too.

DLP_2193

Hannah Gritt

Object

This land with 2 playing fields is very important for use now and in the future by the schools and teenagers of Tunbridge Wells. There arent enough areas for playing matches at the moment, and it seems a very bad idea to get rid of what we do have. It should be made available and improved so that people can exercise and keep fit and healthy.

Also the development will have a bad effect on the environment. Id like the council to do things to improve the local environment (the air pollution and the traffic) and not make it worse with even more building here.

DLP_2593

Andy Eeles

Object

Policy AL/RTW 24 Land at Cadogan Sports Field (SHEELA Ref; Site 237)

As a local resident I have a number of concerns regarding the proposed development of the Cadogan Sports Field.

1. LOSS OF AMENITY

My family and I have lived adjacent to the Cadogan Field for 19+ years.The entire family regularly use the wide open green space for both sport and recreation (as per the origianl intention of the Scheme of 1966).  The description of the property/land on the Charity Commission website states that the Cadogan Fields provides "buildings/facilities/open space, amateur sport, the General Public/mankind".  There are sports clubs and schools as well as members of the public who will miss out on this vital green space if it is developed for housing. We would certainly consider this a significant loss of amenity for us as we rely on it for exercise and valuable open space.

2.  AIR QUALITY

The Cadogan Fields are centred in the Tunbridge Wells Borough Council Air Quality Management Plan of 2005 where the air quality is currently described as being "Poor". Monitoring of the air quality on St. John's Road (A26) (near to the junction with Powder Mill Lane) confirms the very high levels of airborne NO2 & PM2.5/PM10 particulates, especially during peak times.  The concentrations are likely to be highest near to the road where children routinely congreagate and walk to school.   I do have serious concerns about any increase in local vehicle pollution, especially from an unnecessary housing development.

St. John's road is a bottle neck especially around school opening and closing times.  Traffic is often stationary for long periods of time during peak hours when children are walking along the pavement in the most concentrated air.

The development must be rejected on this single factor alone.

3.TRAFFIC CONGESTION

Cars which are either exiting or entering the new development are likely to cause considerable delays thereby slowing down traffic volumes and therefore causing further pollution.

4. SAFETY

The proposed entrance exits onto the A26 adjacent to a speed camera.  This implies that there is a higher risk here and any additional traffic burdon (especially turning traffic) may increase overall risk factors.  A further risk is presented by the bus lane; turning cars will be required to navigate across it.

5. ENVIRONMENT

The current site is surrounded by Oak and Silver Birch trees and concomitant wildlife. I am concerned that any development may negatively impact these.

6. MAXIMISING USEAGE

It is my view that the Cadogan Field is best retained in its current guise as per the original scheme.  It may be preferable to increase its utilisation by offering it to the (many) local schools that are within walking distance.  Space is a premium for many schools now.  As the ground is relatively level then it may benefit from the building of an all-weather pitch if necessary to optimise its use. Alternative uses could be considered such as the developement of  a wildlife centre (pond/wetland), community allotments etc. for educational and well being reasons.

DLP_1569

Tunbridge Wells Masonic Hall Ltd

Object

  1. The existing entrance is too narrow with no room for a safe separate pedestrian access.
  2. The existing vision splay on exiting across the pavement on to the A26, St.John's Road, prevents seeing pedestrians and cyclists.
  3. Extra traffic on the A26, which is already one of the busiest roads in Kent, will increase the traffic jams and toxicity levels which are already dangerously high at peak times.
  4. The narrow entrance prevents vehicles passing each other at that point thus leading to a dangerous wait on the A26 for traffic wishing to enter from the South and having to cross one lane of traffic and then the bus lane.
  5. Heavy goods lorries waiting to access the site during the construction period would cause major traffic problems.
  6. Tradesmen with their vehicles would have no choice but to park in the adjoining residential streets.

DLP_2168

Alan Finn

Object

Cadogan field Policy AL/RTW24

The development site plan outlining the area to be developed in red shows and area that is greater than the current site plan shown on title plan K924591 as attached so the development is not possible without obtaining land from the Masonic Hall.

The additional traffic flow from this development onto St. John's Road will slow traffic, increase congestion and worsen the air quality which is already above recomended levels.

The loss of the green space will also contribute to worsening of air pollution in the area.

Members of sports clubs that currently use Cadogan field will have to drive further to use alternative venues and so further increase pollution and traffic congestion.

DLP_1985

Julie Hughes

Object

Policy AL/RTW24 - Site 237

My objections to the Council selling the Cadogan Playing Fields (Field) for development are as follows:

Pollution: the Field is a large unspoilt green space with a large number of mature trees and hedges making it unique in this very built up part of RTW. The A26/St Johns Road is often cited to be the most polluted road in the area. And yet more buildings go up alongside it (eg in the last couple of years: houses backing onto Mereworth Rd, the Old Dairy, the old bus depot to name but a few) - the proposed development of the Field is different to these other new developments though as it would require removing one of the only green spaces in the area and replacing it with yet more homes and potentially double the amount of cars. The Field is also in close proximity to a primary school - St Augustine's playground backs onto the Field. I note that an air quality assessment will be conducted, however it seems obvious that the poposed development of the Field would have a very negative impact on the quality of the air along St Johns Road and on the health and wellbeing of all of the children who go to school nearby (and there are many schools along St Johns Road) and who live near it. Drainage would also be a problem given how sodden neighbouring gardens get after heavy rainfall.

Congestion / Overcrowding: Access onto the A26 from the Field if it is developed will be terrible. It is already painful getting onto the road from some of the side roads (eg Powdermill, East Cliff or even the Sports Centre) and traffic is often at  standstill at both work and school rush hours and at many other times of the day too. Adding more people and traffic will only make this worse. The Council should also consider the number of children who walk to and from school along this part of St Johns Road (soon to be more given the planned expansion of some of the secondary schools). It is simply not safe to add more cars to this. More accidents will happen (there was a particularly bad one by the speed camera just before the summer). I cycle to work sometimes along St Johns Road and it feels very unsafe: there are simply too many cars and buses, the cycle lane stops & starts (as does the bus lane), people park in the cycle lane and block it. If the Council want to reduce congestion and pollution they need to do more to encourage bus and cycle usage rather than adding to the number of people and cars with yet more development along this road.

Current use of the Field: the Field was gifted (nearly 100 years ago) to the town to provide a playing field and recreation ground for local inhabitants. However it is true that it seems to be currently under-used and its potential is not well publicised. Football teams play there on a Sunday and sometimes on a Saturday. It is mainly used by the local TW teams (Forresters and Ridgeway) - it is nice to see local children walking to the Field rather than being driven there and we would like to see more of this. I noticed the comments in the Local Plan citing foul language and anti social behaviour on the Field: this is a complete overexaggeration. In the 6 years I have lived alongside the Field (on Wilman Road) i have never noticed any foul language and the only "complaint" i made was to call the Council (as owner/trustee of the Field) to let them know that travellers had moved onto the Field and this was a few years ago. This should not be cited as a reason for selling the site as it is simply not true.

Sports Pitches: The Council's strategy paper on this is informative. Whilst I like the idea of a sports hub in Hawkenbury, I do not agree that most of the town's pitches need to be concentrated in one area. Hawkenbury/Forest Road on a Sunday morning by the rugby ground is already gridlocked, with cars parked in unsafe places. Is it really a good idea to add to this? Surely it would be more sensible to keep individual sites available for local teams/schools to use, which they can walk to?

Future use of the Field: it should be used more often by the local football teams - local residents are contacting these teams to make this happen. It could also be used by local schools as additional safe and easy to access playing fields for them during the week. Skinners has expressed an interest (the Field is closer to Skinners then their own playing fields further up the road). The Free School do not have their own playing fields and could walk their older classes to the Field for games.  In fact St Augustine's would find the Field easier to play on (better quality) than their own fields along Powdermill Lane which are badly drained and slope up to the road). This should be explored before the site is sold.

DLP_2230

Dr Cameron Davies

Object

Sports fields within walking distance of schools should not be sold off to developers.

DLP_2443

Natalie Candy

Object

I object to this development (site 237 cadogan sports field) for the following reasons:

Increased traffic in all of the surrounding roads.

Air pollution from more cars - not just as a resident with a family but also for all the children at St Augustines school.

Losing important green space in an already heavily populated area, which should be used more effectively for children and adults. Schools should have access, more sports clubs, a playground would be incredibly popular as the only nearest one is St Johns park. Developing the pavillion like Langton Green which is now so successful. There is nowhere like this in the nearby areas for young families to go to.

Water logged gardens - already a huge issue on Wilman Road, which will only get worse with building work.

More residents will stretch the already over stretched facilities - school applications, doctors surgeries.

Many thanks,

Natalie Candy

DLP_2445

Nick Candy

Object

I object to this development (site 237, policy AL/RTW24 cadogan sports field) for the following reasons:

Increased traffic in all of the surrounding roads.

Air pollution from more cars - not just as a resident with a family but also for all the children at St Augustines school.

Losing important green space in an already heavily populated area, which should be used more effectively for children and adults. Schools should have access, more sports clubs, a playground would be incredibly popular as the only nearest one is St Johns park. Developing the pavillion like Langton Green which is now so successful. There is nowhere like this in the nearby areas for young families to go to.

Water logged gardens - already a huge issue on Wilman Road, which will only get worse with building work.

More residents will stretch the already over stretched facilities - school applications, doctors surgeries.

DLP_2817

Ben Phillips

Object

AL / RTW 24 Codogan Fields

Cadogan fields is currently underused as a green space, and I can, at a stretch, understand the thinking that has led to it being identified as a potential development site given the intention to centralise sports facilities (which I do not agree with)

However the reason for it being underused is the fact that it is locked and not open to the general public, and is used only by football teams at weekends. It would be far preferable to everyone if the facility was enhanced (perhaps with S106 and CIL funds) to make it more accessible as part of the Local Plan, rather than to take it away.

Green space is at a premium in Tunbridge Wells. Most open space is privately owned (e.g. by schools) and not accessible by the public. Losing this space for ever would be a big loss to Tunbridge Wells residents, now and in the future.

Despite the space being underused currently, it has equally had great value to locals over a number of years. Friends have used the facilities for sports over the years and it has had great health and wellbeing impact.  To lose the facilities would be a great loss, and would seem counter productive to society’s aims of providing more open space and more sports facilities in order to promote healthy living and healthy people.  The link between sports and outdoor activities with mental health and physical health has been clearly established, and removing such facilities will only add pressure on health and care services in the future.

By removing a local green space which could be accessed in a sustainable manner (walking, cycling), and instead requiring residents to travel further afield for formal and non-formal sports and recreation will just add to the already congested and polluted road network, and is counter to the council’s declared climate emergency – if this declaration is to be of any purpose any decision such as this should be focused on reducing road trips, not increasing them.

It seems strange in this regard that the Local Plan has identified that and development on the land will require open space and play areas, so the need of new residents for open space has been addressed, but yet for existing residents such facilities are not seemed important? Removing this green space therefore seems somewhat counter to the very policies of the Local Plan?

My final point to make is with regard to the loss of land with bio-diversity benefits to the local area - it is my understanding that we should be seeking bio-diversity net gain from development, I would enquire as to how this would be achieved in this locality given the loss of nearly 4 acres of green land.

There are many ways that this space could be promoted and used to ensure enhanced and well used local public realm provision.  The local community could come together and work with TWBC to formulate ideas for this, bearing in mind budgets and upkeep, and it could be an amazing community resource. Ideas that spring to mind include:

·   Facilities left in their current form, but open all hours (day time) with both informal or formal sports provision, providing for a wider user group than just football teams

·   Play area / skateboard park / pump track

·   Allotments

·   Wild flower relaxation area, benches etc – usable by all generations

·   Educational extension for schools (allotments / ecology etc)

·   Mixture of all the above to cater for the needs of the whole local population

If however the council is determined to allocate this site, I would like to provide the following comments:

-    Any additional development should come with significant green space provision, for the use of both new and existing residents

-    There should be significant tree planting and landscape buffering at the edging to ensure minimal noise impact and to help offset the negative environmental impact of the development

-    The site should show bio-diversity net gain.  Any development should show bio-diversity net gain onsite and this is no exception, especially given the context of the residential development nearby and the benefits this has on health and wellbeing of local residents (new and existing).  Trees and hedgerows should be maintained and enhanced in their existing form.

-    Any development should be in keeping with the character zone of the area

-    Safe routes (not car based) to school will need to be developed, and indeed bike / bus / pedestrian usage promoted.

-    A pedestrian crossing across the A26 should be considered for access to schools, leisure centres etc

-    The pedestrian footpath across the access road should be clearly highlighted and prioritised over the junction road traffic

In summary, I oppose the allocation of these sports fields for housing.  I do not believe that the allocation of housing should be placed as a priority over and above the needs of existing residents to have sports and open space provision. This is especially in the context of other sites having new open space provision provided, thus showing the very importance of this provision.

I believe that the health and mental wellbeing benefits of local open space and playing fields should be recognised by the council and valued, and, the loss of this land would have a resultant detriment to future and existing residents.  The argument that other facilities are available is not fair for those who use (or ould use) and value these local facilities, cannot make the journey to more distant centralised space, who do not partake in formal sports but do want informal recreational space, not to mention the fact that having to drive to do be able to use open space mitigates many of the very benefits of using the open space.

If the development does have to come forward on this site, I would like to ensure that the site provides safe means of pedestrian access, a development that is in keeping with the character of the area (density) and is respectful to adjoining residential properties whose character is that of large gardens with quiet community focus, rather than of small gardens in a high density area.

DLP_2444

Carolyn Lane

Object

Regarding Policy AL/RTW 24

I object to the proposed plans for housing to replace the current playing fields on Cadogan Sports Fields.

Traffic along St John's Road is already congested for much of the day and extra housing would place further strain on this. This section of the road is extremely busy during school times and increased traffic would obviously put students in the area under extra risk of accidents. There would be ramifications on air quality in the area. This is already elevated due to vehicle emmissions as shown by the ongoing air quality monitoring. I am also skeptical as to how traffic for the development is going to fit through the existing narrow entrance way off the A26.

My main objection is the loss of sporting fields. There is a recognised need to provide enough suitable venues for sporting activities within the community. To change use of established sporting facilities for housing seems to be looking at short term needs not long term. If anything the fields need to be more accessible for general and school recreational use. The proposed idea of developing a football hub at Hawkenbury should be in addition to, not instead of, current fields. The new hub would service the expanding community in new housing at Hawkenbury and the need for more fields. There would obviously be a benefit in distributing facilities across Tunbridge Wells so more people can access these areas without the need for transport. The plan itself recognises the need for recreation grounds and play areas - why not allow use  of some of Cadogan Fields for these purposes.

DLP_2502

John  Partridge

Object

I have lived on St. John's Road, Tunbridge Wells for 16 years.  I have three children who have grown up here. 3 out of 5 members of my family suffer from asthma.  The road has got progressively busier and at open/close of school day, the traffic is at a standstill.  The green space that is Cadogan Field is an essential environmental buffer to this.

New housing would lead to potentially more vehicles, creating more traffic and most significantly more emissions, which the St.John's area cannot sustain. 60 houses could mean in excess of 120 more cars based on the average of two cars per household these days.

St. John's Road is regularly congested with HGVs emitting huge amounts of pollutants and this is particularly dangerous to the amount of young children that populate this road, attending the high number of schools here.

My eldest, who has Crohns disease now lives in London.  She often comes home on Sundays, the one day, the traffic is not an issue in St. John's, and enjoys the relative calm of the location of our house, a peaceful haven after the smog and grime of the big City. We have a number of photographs of the trees in the Masonic drive adjacent to our house to evidence this.  However, I am not able to upload them to this site, no matter how small I made the images. These trees are important mitigators to the dangerously high levels of pollution currently in St. John's.

Cadogan Field is also a sponge for the increased rainfall we currently endure and will continue to play a vital defence against future high rains.  Each house on the descent from the Cross Keys pub at the top of the hill (junction of St. John's Rd with Powdermill Lane) suffers from flooding in their garden.  My neighbour at 206, had a clay-pipe irrigation system and 14 tons of earth deposited to his garden to alleviate flooding issues at great personal cost.  In our own garden, we have had wire cages full of sand installed beneath the borders to treat the issue and our immediate neighbour still has significant problems during autumn/winter.  We both have Willow trees which are renoun for their ability to soak up high volumes of water and their original planting was not a coincidence. The field is a vital flood defence.

There have also been issues with drains and sewage and we have had correspondence with Southern Water over the years.  When prolonged, heavy rainfall occurs, the drain in the Mason's Drive struggles to cope and we have witnessed the man-hole cover blow off in the past due to the pressure from beneath.  The drain on the main road in front of our house floods regularly, creating a huge well of water which is a hazard for the buses in the bus lane. splashing and drenching the passing pedestrians. This well of water is particularly dangerous in icy conditions when it beomes a sheet of ice. Southern Water say that this St. John's Rd drain is the responsibility of the Highways/Council.  At the same time of this heavy rainfall, our downstairs toilet loses its water and will not flush.  Southern Water says this is not their responsibility but a private surveyor told us that the problem is very much linked to the insufficient sewage/drainage system installed in Victorian times and that the local infrastructure cannot cope with the strain of additional housing and increased heavy rainfall.  Without private call-out to Dyno-Rod, we would not have a functioning toilet during wet periods.  Again, at cost to us.

Cadogan Field also provides a community hub for local football teams.  Our own son (16) plays Sunday football there at weekends and the location has a real community vibe because it is a valuable green space in a densely populated neighbourhood.  Our son learned to ride a bike here as a child and many children have played here over the years. Local recreational space should be a must in theses times when obesity in the U.K. has beccome an epidemic. Not all local families can afford exensive sports club memberships or cars to transport their children to various sporting hubs/gyms. In 2009, our son had a football birthday party here, hosted by First Class Football, with the hire of the clubhouse included on permission from the Council.

Our local schools, in particular, The Skinners School have no green space at all for their pupils.  Their games field, Southfields, is a long walk for their students and is now proposed as green belt land for the future.  I am sure that on consultation with Skinners, the school would be delighted to use Cadogan on a daily basis, given the opportunity.  Our son attends Skinners and I am sure that they would be able to utilise this valuable green space.  The school is under increasing pressure to increase its pupil quota but their site cannot accommodate this.  Mr. Edward Wesson is the Headteacher there.  He is a big cricket fan and am sure would love nothing more than to see Cadogan as a cricket/sports ground for regular use by the school.

We all acknowledge there is a need for housing throughout the U.K. and particularly in the south-east but the proposal to build further housing in St. John's that would most certainly bring more pollution, more traffic and ultimately more health hazards for thousands of young school children cannot be a policy that could ever consciously be endorsed by Tunbridge Wells' Council.  It is quite simply, an environmental health hazard.

DLP_2599

Stuart Fearon

Object

Congestion : Increased traffic caused by building new houses in an already densely populated area will compound the already appalling traffic issues on St John’s Road.

Pollution : St John's Road suffer from unacceptable levels of pollution, to which building work, more housing and related traffic will only make worse. The council should not be considering this in an area with the major part of the town's schools in.

Road Safety : Speeding, misuse of bus lanes and side roads being used as 'rat runs' is already a problem issue - more traffic just makes the issue worse.

Green Spaces : This part of town needs green spaces and lacks accessible ones. The council should be looking to improve the area for all residents by using this asset to ensure it remains as open green land and is made available to more tax paying residents for their use.

Finally, regarding the reference to anti-social behaviour in the Cadogan, this seems to be a false flag. We have lived next to the Cadogan for 8 years and the only issue of ‘anti-social behaviour’ we have encountered was when travellers made their way on to the land and remained there for 3 or 4 days, and even in this case the disturbance to ourselves was very minor.

DLP_2941

Elliott Hughes

Object

I am completely against the idea that further green space in an already overly populated area should be concreted over. The St Johns area has precious little green space as is, why is it a good idea to exacerbate the problem?  I played on these playing fields when I was at Skinners as a pupil; it has since been allowed to be underused by the council. The solution for this shouldn't be to build more houses, rather the local schools should be encouraged to use the playing fields and the council should ensure the grounds are properly looked after and the third party maintainance contract properly enforced. I have seen at first hand how small and limited many school playing fields are, notably St Johns, Southborough and St Augustines. They should be given the opportunity to use these, and then local amateur clubs approached. It is shameful that the council have not tried to promote the use of this idylic space. The idea that it is subject to misuse and vandalism is absurd and only serves as further evidence that the council is not looking after it's natural environment properly.

The area is already congested and I am concerned about the safety and well being for the thousands of school childred who use the area. Adding a housing estate to this environment will only create further risk, increase pollution levels and congestion. Please could the council at the highest levels actually come and see the situation on St Johns road and how bad it is.

The fields themselves were gifted for charitable use and I consider the proposed redevelopment a complete dereliction of the fiduciary duties entrusted to the council. These playing fields should be available for the wider community and persons of all ages to exercise and promote healthy living.

The A26 cannot support another large development, especially in conjunction with all the development in the area over the last 5 years. The pollution levels are very worrying and the council has a wider duty to future generations to preserve the clean air the fields and trees produce.

DLP_2932

Oliver Eeles

 

I have grown up and continue to use the field regularly for fitness training and enjoyment. To see the community stripped of such a valuable space would be a travesty; plenty of alterate sites are available for development. The youth of Tunbridge Wells require a continued access to this green space-compromise or encroachment by a development scheme would be indefensibly unjust and reckless.  This field belongs to the youth of Tunbridge Wells and as such it is an asset which is NOT for sale.

DLP_2600

Martin Powell

Object

Land at Cadogan Sports Field, St John's Road (SHELAA reference: Site 237)

I object to Policy AL/RTW 24 as I strongly feel that this relatively small area of land could be better used then potentially 30-40 dwellings as proposed. Surely in an already heavily crowded and populated area this land could be used by one or more of the local schools such as Skinners for example that are in need of pitches/ green spaces for children to play on. Even turning this into a children’s play area that the local community and surrounding locals could use would be a better alternative than to building more dwellings in the area.

As a fellow sportsman who uses the facilities at Hawkenbury, I am excited about the potential sports hub at Hawkenbury, but not at the expense of building on every small bit of green land elsewhere as its already a nightmare with traffic/ parking etc getting to the current Hawkenbury facilities. Directing local football clubs and all sportsman to the other side of town at Hawkenbury, will only make traffic, congestion and pollution worse. I am sure the new hub facilities will be amazing, but they won’t be sufficient to support every local sports club on weekends when typically matches are played. Most of the local teams that I have spoken with that currently using Cadogen are very keen and want to continue to use the pitches there and feel that number of teams would not be around in the future should smaller pitches like Cadogen be lost.

The biggest impact of squeezing another 30-40 dwellings onto this small plot that has very restricted vehicle access via the A26 is the adding of additional traffic, vehicles and congestion on one, if not the worst, roads in and out of Tunbridge Wells already. Additional housing will only add to air population that is already in existence along that road which runs alongside numerous schools in the area. This is also a busy road used by many school children to walk to school, the additional dwellings will only increase the impact to these children’s health and safety.

Having lived in the area now for a number of years, I personally have not experienced, seen or heard from any neighbours of any antisocial behaviour or vandalism which has been suggest by TWBC as one of the reasons for turning this site into additional dwellings.

As I mentioned in the beginning, surely this land, Cadogen could be used for something better than for additional dwellings that will only cause more issues in the future such as flooding, air pollution, traffic and congestion in an already heavily polluted and congested area. The local schools, will only grow in size, teaching more children overtime and therefore requiring additional green space for them to use and Cadogen is perfect for one or many of the local schools in the area to use, some of which currently can’t provide this facility, or have to travel to be able to do so.

Thanks for reading my objections.

DLP_2847

Simon Tovey

Object

I object to the plans for the following reasons:

Adding another junction onto St John’s road will make it more conjested. At peak times the pavements are very crowded with children making it even more dangerous for them. St John's Road suffers from high levels of pollution, more housing will only contribute to raising this further.  This is an Air Quality Management Area. Taking away green space will worsen the area, we know this helps to naturally reduce air pollution.

Moving the 2 playing pitches to Hawkenbury will only create more traffic and pollution as more commuting will be involved.

My family will be affected by a potential development. We will lose privacy, be affected by noise, trees may be cut down (negative environmental effect on the area)

Why can the field not be used during the week? Schools in the area are constantly looking for more space. The playing field could be offered for sporting use, why keep it locked up.

I do not have any issues with anti-social behaviour in the field in all the time I have lived here. I would like to see evidence to back this up by the council, where are these so called reports?

DLP_2774

Robert Whitehead

Object

Policy Number: AL / RTW 24

I object to this proposal on the following grounds:

1. The A26 is one of the busiest A-roads in the county and for much of its length is single lane carriageway - this includes the entire length of St John's Road, where the entrance is proposed, and which is already heavily congested.

2. As a result of traffic pollution “The A26 between Southborough and Royal Tunbridge Wells is designated an Air Quality Management Area (AQMA), and is congested at peak periods.” (Tunbridge Wells Borough Development Plan 2015 - 2026, dated July 2015 point 4.17, page 17). The use of this land for residential housing will exacerbate this existing problem.

3. The existing entrance from St John's Road to the Cadogan Sports Field is 3.80m wide. This is insufficient width for two lanes of traffic and larger construction vehicles (see photograph file).

4. The location of a fixed traffic camera on the northbound carriageway on St John’s Road by Leighton Close, already indicates this area has already been identified as an area at higher risk of accident.

5. The route is well-used by pedestrians to attend pre, primary and secondary schools concentrated on or just off St John’s Road many of which are expanding their form entry. An additional entrance cutting across pavements, a cycle lane and a bus lane will heighten the risks to both pedestrains and road-users alike.

6. The exisiting entrance to the Cadogan Sports Field is located at the lowest point on St John's Road and is prone to localised flooding at times (see photograph file).

I feel that this policy is very general in nature and does not take account of the complexities of the road and pedestrian use and access to the Field from St John's Road i.e. local context is absent.

DLP_2793

Emma C Bennett

Object

Policy AL/RTW 24 Land at Cadogan Playing Fields

Serious concerns over safe access to the actual site in accordance with Regulation 18.

Serious concerns as to increased traffic. The road is horrendously busy as it is and absolutely cannot cope with more traffic. We often struggle to get on and off our drive way on St Johns Road due to the build up of traffic.

Serious concerns as to the dangerous levels of air pollution that more traffic will produce. The pollution levels are already crtical and creating more air pollution is not in line with the councils obligations to address pollution levels.

Serious concerns as to light and noise pollution from increased traffic.

We would absolutely support the field being used more for local sports clubs or schools. St Augustines and Skinners School have expressed an interest in using the field for additional playing fields.

Developing this site does not comply with the Council's own Green Infastructure Framework.

Developing this site has significant transport implications and therefore any proposal miust be accompanied by a transport assessment and travel plan showing how car based travel can be minimised. I cannot see how this is feasible.

DLP_2846

John Francis

Object

The change of use for the Cadogan site will diminish the sports facilities for children and young adults in Southborough and North Tunbridge Wells.  Currently children can play organised football and other sports at the Cadogan, Ridgewaye and Colbrook.  Part of the area of Ridgewaye has sold off and been built over in 2019. If the Cadogan is lost to sport the council's option is to use a site at Hawkenbury.  This is not in walking distance for Southborough and St John's residents.  The parents will have to drive their children to matches and training rather than walking with them, or for the older children, letting them walk on their own.  This will add to the weekend traffic congestion in Tunbridge Wells.  The pitches at Ridgewaye are very heavily used and will not be able to host more matches.

I am the president of Tunbridge Wells Youth Football Club, and I organise pitch use on Sundays for the club.  Most Sundays we hire at least one pitch at the Cadogan.  We already have to hire pitches at Hawkenbury, Bayham Road and Brenchley.  The loss of the Cadogan will discourage parents from sending their children to play football.

DLP_3219

Kent County Council (Growth, Environment and Transport)

Object

Highways and Transportation

The Local Highway Authority objects to this policy.

The existing vehicular and pedestrian access to site are inadequate.

Heritage Conservation

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

DLP_4045

Melinda Moss

Object

As a local resident to Cadogan fields I would like to express my objections to the plans of building 30-40 dwellings, based on the following points :

  • Impact of traffic on an already congested road ( bus lane will be blocked by traffic leaving the new development)
  • Worsening pollution of an area which is already identified as an Air Quality Management Area
  • The impact of this air pollution on children’s health
  • Concern over pedestrian safety – the road is used by many children attending the numerous primary and secondary schools in the immediate vicinity
  • Access is single carriageway
  • Localised flooding
  • The field is regularly used on Saturdays and Sundays during the football season, particularly by local teams such as Tunbridge Wells Youth.  Losing local pitches will add further traffic and congestion along the St Johns road area as players and spectators will have to drive to alternative locations. Local Secondary schools expressed interest in using Cadogan Fields in the future , if they are made available to them. Secondary schools nearby are expanding and losing green space, they would be interested in using teh facility.
  • Contrary to the TWBC Playing Pitch Strategy, we do not experience the suggested “high degree of anti-social behaviour and vandalism”.

Alternative use could include:

  • Pitches to be used by schools in the area during the week (daytime)
  • Allotments
  • As is but with variety of sports facility / pitch sizes / types, or more informal sports provision (jumpers for goalposts etc)
  • Play area
  • Skateboard park
  • Bike pump track
  • Allotments
  • Solar panels
  • Nature reserve, wildflowers, benches etc
  • Community building and gardens
  • Something for all ages – café, meeting place for older residents

DLP_4077

Laura Philips

Object

  • This is a valuable piece of green space in a residential area, which will be lost forever. There is very little public green space in the vicinity - most of it is private and inaccessible
  • Losing green space is illogical in an era of physical and mental health crises, and with a climate emergency
  • Condensing all formal sport into 1 location does not make sense – it will purely either force everyone into cars or act as a barrier to doing sport
  • Informal green space is just as important as formal. Where do kids go to have a quick kick about, fly a kite, mix with the community?
  • This space could be used to the benefit of the whole community if it was used to its full potential

DLP_5973

Kayte Alexander

Object

AL/RTW 24 Site Number 237

Cadogan fields- object

I am very much opposed to the development of this land by the building of houses on the playing fields at Cadogan.

1. A great deal of building has taken place along this road during the last few years. The traffic on the A26 is already very bad at peak times. Adding extra houses each with perhaps 1 or 2 cars trying to access onto the same road is going to make the congestion on the road and for all the buses even worse.

2. The A26 is already dangerously busy for the schoolchildren travelling to and from the many local schools.

3. The resultant increase in pollution (already at high levels) on the A26 from the extra traffic which would ensue is a big concern. PLUS the impact of increase in emissions from the idling engines of all the current traffic which would be forced to drive even slower if the extra housing is added.

4. We now know the impact on human, and especially children’s, health from more pollution.

5. Loss of these local playing fields will mean more people forced to use cars to drive to and from Hawkenbury to access those playing fields increasing traffic and congestion throughout the local area.

6. Risk of increased flooding (it is already very waterlogged here) if the field is built upon.

In contrast, it would be such a good use of the fields by the council if they were made available for greater use in the week rather than just at the weekend (as originally envisaged by the donor when the fields were willed to the town)

7. There are not enough playing fields for local use, for clubs and especially for the local schools. The Ridgeway has recently been reduced in size.

8. The fields are sited in the centre of a number of schools each of which is less than 10 minutes’ walk away. Many of these schools are being forced by the council to increase admission numbers and consequently need to build more facilities on their own sites. It is sensible for the council therefore to think and plan that the schools will eventually need to use these playing fields as they be will be short of their own space.

9. The headteacher at Skinner’s school has confirmed they would even now gladly make use of Cadogan fields. They currently walk boys much further up to Southfields playing fields which wastes valuable exercise and class time and there is insufficient space available to them there for all their current needs.

The council should be forward thinking and prioritising the needs of our young people while focussing on the overall impact to the area in broad environmental terms, rather than on making short term profit from selling more land along this road to another developer.

DLP_7254

Mr John Telling

 

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected.

My reasons for wishing to retain these sites include the following:

1. To reduce our carbon footprint we have to reduce the need for all travel, including that to accessible open space. This policy is at odds with the imperative need to cut CO2 emissions and pollution. A policy which promotes more driving about is irresponsible. It will force more people into cars on our already congested roads, increasing traffic congestion and pollution simply to access recreational open space.

2. We need to develop and protect local green spaces for children/families to be able to play, relax and socialise. Many individuals and families have no or only small gardens. Families with children need open spaces near their homes to play with a ball, cycle on their bikes, and meet with friends and family without having to drive or be driven across the borough.

3. People need open space to walk, run and socialise with others in their community.

4. Green spaces are increasingly recognised as necessary for good mental health and physical wellbeing. They bring natural features into an urban area and help people feel better about their local environment.

5. Trees and vegetation help improve air quality and absorb CO2.

Removing local playing fields will be detrimental to the borough and people's quality of life. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable without access to private transport. Public transport to Hawkenbury is limited. And why should people have to use transport, public or private to access social open space? People should be able to access open space on foot.

Other sites and approaches that do not involve building on playing fields and informal open space should be considered.

This proposal is environmentally and socially retrogressive and contrary to residents' wellbeing needs.

DLP_5978

Edmund Gritt

Object

Schools and other usage

1. I believe that Cadogan Field’s present use as a sports field should be enhanced for the local benefit of the St John’s area, and in particular for the present and future use of the 8 state schools in the vicinity – each of them no more than 10 minutes walk from this open space. I attach a map which shows the location of the 8 schools relative to Cadogan Field: 4 primaries (St Augustine’s; St. John’s; St. Matthew’s; Southborough) and 4 secondaries (St. Gregory’s; Tunbridge Wells Boys’ Grammar; Tunbridge Wells Girls’ Grammar; Skinners – of these: St. Greg’s is non-selective but only Skinners is super selective, and therefore 3 of them have relatively local catchment areas).

2. I know that Skinners is positively interested in making use of Cadogan Field as nearer site for sport than its present site on Chestnut Avenue. Some of the schools which I have identified are not in present need of additional/alternative sports field land. However:

(1) the Draft Local Plan is intended to run till 2036 and must therefore rationally account for possible future need;

(2) once Cadogan Field is removed as sports field for the purpose of housing development, it is lost forever;

(3) all local schools are under pressure to expand intake which is likely to result in building new facilities on their own sites which may cause them to look for alternative off-site sports field provision.

3. Consequently, St John’s schools which may say that they do not presently need additional/alternative sports field provision may revise their positions within the next 17 years of the Draft Local Plan.

4. TWBC should therefore conduct a full assessment in directed consultation with the 8 identified state schools to ascertain whether Cadogan Field may be required for continued use as sports field provision within the duration of the Draft Local Plan. Given the configuration and proximity of 8 local schools (as shown on my attached map – marking the St John’s as an area of exceptionally intensive educational provision – unique within the Borough), it would be irrational not to undertake that assessment. The Playing Pitch Strategy (PPS) does not indicate that it has undertaken such a directed consultation or assessment.

5. Furthermore, it would be irrational to impose extra strain on the local schools by reason of the building of 30-40 new houses under this policy which itself directly removes the availability of a possible overspill in terms of alternative/additional sports field provision to meet that easily foreseeable strain.

6. Transferring usage/management of Cadogan Field to one or more local schools would enable the improvement of the on-site facilities (such as the introduction of flood-lighting) which itself could enable an intensification of the local use of the field by non-school local teams (which might in turn be expected to provide some income stream for the proper management of the field). Winter evening use and summer use (for sports other than football) would be enhanced.

7. The critical fact is that all of this is within walking distance for local school children and other players who live locally. Displacing the available pitches to a ‘sports hub’ in the backstreets of Hawkenbury corrodes the amenity for children and other residents in St John’s. At best, it would only encourage car use to reach the ‘hub’ as well as congestion in Hawkenbury – both aggravating pollution.

8. Any rational policy with a 17-year horizon must be directed to minimising carbon emissions. A centralising plan which encourages car use to a single ‘sports hub’ on the edge of town by sacrificing sub-local provision accessible by walking is irrational. It is plainly foreseeable that such a plan will soon conflict with central government policy to reduce car use and carbon emissions.

Development lock

9. The proposed development of Culverden Stadium (Policy AL/RTW 21) is subject to a development lock in the following terms:

1. Planning permission shall be granted on this allocation site subject to planning permission having been granted for a suitable alternative sporting facility at another site;

2. Implementation of planning permission granted for the development of this allocation site shall occur only once the provision of the alternative sporting facility is operational, or will be operational in time for the start of the following football season;

10. As presently drafted, AL/RTW 24 provides no such protection for the use of Cadogan Field which could – unless a development lock is added – be developed without any alternative provision (even at Hawkenbury) being put in place.

11. If AL/RTW 24 is approved with the objective housing development then it should include a development as in AL/RTW 21.

Anti-social behaviour

12. AL/RTW 24 is predicated on the Playing Pitch Strategy (PPS). The PPS states at pages 7 and 24 in respect of Cadogan Field: The site has a high degree of antisocial behaviour and vandalism. … there are a large number of complaints regarding foul language when the pitches are used at the weekend.

13. Neither of those statements is true. At the very least they are misleading. For example, there may have been repeated complaints but from a very small number of residents.

14. I have lived adjacent to the field for 10 years and close to the clubhouse which has on occasion been the object of vandalism.

15. However, the number of incidents has been few over the years and no more than to be expected from any public park – and indeed probably far less than that.

16. Occasionally/rarely some teenagers drink in the field but that is just modern life.

17. The footballers are almost always polite and walk round the roads to knock on my front door to retrieve their lost balls. Only perhaps twice have any of them (the younger players) climbed into my garden to recover a ball. That is hardly something to get excited about.

18. The PPS appears deliberately to exaggerate these occurrences to justify the elimination of Cadogan Field. A false fact is an irrelevant consideration and reliance upon it would render the policy AL/RTW 24 irrational.

DLP_8360

Angela Funnell

Object

Paragraph 5.37: The Sports Strategy for Royal Tunbridge Wells

This includes:

  • Policy AL/RTW 21 Land at Culverden Stadium, Culverden Down
  • Policy AL/RTW 22: Land at Bayham Sports Field West
  • Policy AL/RTW 23: Land to the north of Hawkenbury Recreation Ground
  • Policy AL/RTW 24: Land at Cadogan Sports Field, St John’s Road
  • Policy AL/RTW 25: Land at Colebrook Sports Field, Liptraps Lane

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected. My reasons for wishing to retain these sites include the following:

  1. We need green spaces for children/families to be able to play. Some families don’t have gardens, or only small ones. They need places near their homes to play with a ball, cycle on their bikes, and play with friends and family without having to be driven across the borough.
  2. People need them to walk, run and socialise with others in their community.
  3. They are good for our mental health and physical wellbeing. They beautify an urban area and make people feel better about the environment they live in.
  4. The trees and plants help provide good air quality.

Removing the local playing fields will do much harm to the borough. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable. It will also force more people into cars on our already congested roads, increasing traffic congestion and pollution. Other sites should be considered that do not involve building on playing fields.

DLP_8364

Sally Antram

Object

Paragraph 5.37: The Sports Strategy for Royal Tunbridge Wells

This includes:

* Policy AL/RTW 21 Land at Culverden Stadium, Culverden Down
* Policy AL/RTW 22: Land at Bayham Sports Field West
* Policy AL/RTW 23: Land to the north of Hawkenbury Recreation Ground
* Policy AL/RTW 24: Land at Cadogan Sports Field, St John’s Road
* Policy AL/RTW 25: Land at Colebrook Sports Field, Liptraps Lane

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected. My reasons for wishing to retain these sites include the following:

1. We need green spaces for children/families to be able to play. Some families don’t have gardens, or only small ones. They need places near their homes to play with a ball, cycle on their bikes, and play with friends and family without having to be driven across the borough.

2. People need them to walk, run and socialise with others in their community.

3. They are good for our mental health and physical wellbeing. They beautify an urban area and make people feel better about the environment they live in.

4. The trees and plants help provide good air quality.

Removing the local playing fields will do much harm to the borough. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable. It will also force more people into cars on our already congested roads, increasing traffic congestion and pollution. Other sites should be considered that do not involve building on playing fields.

In addition, focusing all the town’s main sports facilities in one hub in Hawkenbury will inevitably cause problems for that area of the town, including increased traffic and congestion.

Policy AL/RTW 25: Land at Colebrook Sports Field, Liptraps Lane

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_535

Councillor Frank Williams

 

It is unclear how vehicles will access this  proposed site. If they attempt to use the access via Longview Way they will not only cause a nuisance to residents who have no drives or garages to avoid on-street parking, but also they will have to travel across the football pitches.

 

DLP_3598

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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/RTW 25

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

 

DLP_1830

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Number:  AL/RTW 25 Land at Colebrook Sports Field 

While some residential development here may be appropriate, the draft policy does not show clearly enough the extent of green space that would be retained. The surrounding residential areas are densely populated and access to alternative green spaces is not particularly good. The policy should clarify the green space that would be retained and how it would be enhanced.

 

DLP_2914

Chris Gow

Object

I object to this development.

This development removes green space amenity space from an area that is heavily populated, and the availability of an area of green open space is essential for the well being if local residents.

The proposed replacement of the open space and play area is a poor substitute for what is existing for amenity.

Existing trees are at risk of being felled, something to be avoided with all development, and in this case certainly to be avoided.

The risk of flooding is present in this location, and flood defence work is expensive and unlikely to be delivered.

 

DLP_1677

TWBC Property and Estates

TWBC

 

AL/RTW25

a. Policy currently indicates provision of approximately 60 dwellings. This site is capable of delivering 80+ dwellings. It is recommended that including a figure of approximately 70 dwellings would be a better guide to the site’s potential.

b. Para 5.41 should refer to 5.39 not 5.43

c. Bullet 5. It should be noted that the flood risk is to the western strip of the allocation. This would have no implications on the build area which is intended to the higher, eastern portion of the allocation.

 

DLP_2054

Terry Everest

Object

Strongest Objection Possible

This green space is well used locally and is an important part of a green corridor strecthing almost to the centre of Tunbridge Wells. Hundreds of people choose to pass through this corridor avoiding pollution and enjoying the amenity of trees and green spaces on the way. Most users are local children, dog walkers and parents plus adults and elderly users. This is a vital green space in the patchwork of T Wells and must not be developed.

It cannot and would not be replaced by any site elsewhere.

 

DLP_2231

Dr Cameron Davies

Object

Sports Fields within walking distance of schools should not be sold to developers.

 

DLP_3222

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:
Paragraph 2 – “Opportunities to be explored for improving pedestrian and cycle access onto Dowding Way and creating a new vehicular link between Dowding Way and Clifton Road”

Additional paragraph - Safeguard land to the west of the site for possible future pedestrian/cyclist/vehicular link between Dowding Way to Clifton Road

The standard paragraph regarding contributions should also 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.

 

DLP_7255

Mr John Telling

Object

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected.

My reasons for wishing to retain these sites include the following:

1. To reduce our carbon footprint we have to reduce the need for all travel, including that to accessible open space. This policy is at odds with the imperative need to cut CO2 emissions and pollution. A policy which promotes more driving about is irresponsible. It will force more people into cars on our already congested roads, increasing traffic congestion and pollution simply to access recreational open space.

2. We need to develop and protect local green spaces for children/families to be able to play, relax and socialise. Many individuals and families have no or only small gardens. Families with children need open spaces near their homes to play with a ball, cycle on their bikes, and meet with friends and family without having to drive or be driven across the borough.

3. People need open space to walk, run and socialise with others in their community.

4. Green spaces are increasingly recognised as necessary for good mental health and physical wellbeing. They bring natural features into an urban area and help people feel better about their local environment.

5. Trees and vegetation help improve air quality and absorb CO2.

Removing local playing fields will be detrimental to the borough and people's quality of life. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable without access to private transport. Public transport to Hawkenbury is limited. And why should people have to use transport, public or private to access social open space? People should be able to access open space on foot.

Other sites and approaches that do not involve building on playing fields and informal open space should be considered.

This proposal is environmentally and socially retrogressive and contrary to residents' wellbeing needs.

 

DLP_8361

Angela Funnell

Object

Paragraph 5.37: The Sports Strategy for Royal Tunbridge Wells

This includes:

  • Policy AL/RTW 21 Land at Culverden Stadium, Culverden Down
  • Policy AL/RTW 22: Land at Bayham Sports Field West
  • Policy AL/RTW 23: Land to the north of Hawkenbury Recreation Ground
  • Policy AL/RTW 24: Land at Cadogan Sports Field, St John’s Road
  • Policy AL/RTW 25: Land at Colebrook Sports Field, Liptraps Lane

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected. My reasons for wishing to retain these sites include the following:

  1. We need green spaces for children/families to be able to play. Some families don’t have gardens, or only small ones. They need places near their homes to play with a ball, cycle on their bikes, and play with friends and family without having to be driven across the borough.
  2. People need them to walk, run and socialise with others in their community.
  3. They are good for our mental health and physical wellbeing. They beautify an urban area and make people feel better about the environment they live in.
  4. The trees and plants help provide good air quality.

Removing the local playing fields will do much harm to the borough. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable. It will also force more people into cars on our already congested roads, increasing traffic congestion and pollution. Other sites should be considered that do not involve building on playing fields.

 

DLP_8365

Sally Antram

Object

Paragraph 5.37: The Sports Strategy for Royal Tunbridge Wells

This includes:

* Policy AL/RTW 21 Land at Culverden Stadium, Culverden Down

* Policy AL/RTW 22: Land at Bayham Sports Field West

* Policy AL/RTW 23: Land to the north of Hawkenbury Recreation Ground

* Policy AL/RTW 24: Land at Cadogan Sports Field, St John’s Road

* Policy AL/RTW 25: Land at Colebrook Sports Field, Liptraps Lane

I object to the proposed sports strategy, which involves the development of four of the above sites, with facilities being moved to a “sports hub” at the site in Hawkenbury. These green spaces in areas of high-density building should be protected. My reasons for wishing to retain these sites include the following:

1. We need green spaces for children/families to be able to play. Some families don’t have gardens, or only small ones. They need places near their homes to play with a ball, cycle on their bikes, and play with friends and family without having to be driven across the borough.

2. People need them to walk, run and socialise with others in their community.

3. They are good for our mental health and physical wellbeing. They beautify an urban area and make people feel better about the environment they live in.

4. The trees and plants help provide good air quality.

Removing the local playing fields will do much harm to the borough. It will have a significant impact on the borough’s ability to provide recreational facilities for all, especially the poorest and most vulnerable. It will also force more people into cars on our already congested roads, increasing traffic congestion and pollution. Other sites should be considered that do not involve building on playing fields.

In addition, focusing all the town’s main sports facilities in one hub in Hawkenbury will inevitably cause problems for that area of the town, including increased traffic and congestion.

Policy AL/RTW 26: Land at Cemetery Depot, Benhall Mill Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1817

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Numbers:  AL/RTW 7,8,9,10,14,15,19, 24, 26,28,29,31,32

The above sites seem suitable for allocation subject to the proposed conditions written into the policies.

DLP_1680

TWBC Property and Estates

TWBC

Support with conditions

AL/RTW26

a. The call for sites submission was for a split of uses, namely a replacement Borough Council cemetery depot and residential use on the remaining site for c15 C3 dwelling houses. This is still the proposed use of this site. Attached is a plan showing the potential split of the site for the intended uses. It is considered that the policy and RJ should properly reflect the 2 proposed uses - RTW 26 A and B, or otherwise treat it as separate allocations.

b. Bullet 2. There is no indication of the non-designated heritage assets referred to, nor any analysis to justify them. The adopted Local Heritage Assets SPD seems to indicate that their formal identification should be by the local authority usually in tandem with developing the evidence base for plan making. The National Planning Policy Guidance (NPPG) indicates that ’Irrespective of how they are identified, it is important that the decisions to identify them as non-designated heritage assets are based on sound evidence.’ Furthermore ‘It is important that all non-designated heritage assets are clearly identified as such’ It is suggested that this has not been done and that bullet 2 should be removed from the policy.

c. Question the relevance of the adjacent Biodiversity Opportunity Area (BOA). This site is classed as built up, on Kent Landscape Information Survey map

DLP_2055

Terry Everest

Object

Object

This space should not be developed upon. It should remain a peaceful buffer zone in view of the cemetery it is close to.

DLP_3225

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:

Additional paragraph - Position of new vehicular and pedestrian access points to be determined through a Transport Assessment.

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

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

DLP_7357

Wealden District Council

General Observation

Policy AL/RTW 26 (Pages 124 to 125) relates to Land at Cemetery Depot, Benhall Mill Road that has been allocated for 20 (net) dwellings. The site comprises a depot site associated with the adjacent cemetery, with the site fronting onto Benhall Mill Road.

The constraints to this site are more limited, since it is not located within the Green Belt or High Weald AONB. The vehicular and pedestrian access for the site would need to be taken from Benhall Mill Road.
Nonetheless, it not clear how Tunbridge Wells Borough Council has taken into account the sites proximity to the administrative boundary of Wealden District and its potential cross boundary impacts on infrastructure (transport and education particularly) and the setting of the High Weald AONB within Wealden District.

It would be helpful for the allocation plan associated with this site to show the District boundary for Wealden.

Policy AL/RTW 27: Land at Hawkenbury, off Hawkenbury Road/Maryland Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_3599

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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 250 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/RTW 27

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

This site incorporates a Private Pumping Station (WPS). In order to mitigate any noise and/or vibration generated by its essential operation, a 15 metre gap between the pumping station and any residential dwelling would be required.

In consideration of the above, we recommend the following criterion is added to Policy AL/RTW 27

A 15 metre gap between the pumping station and any sensitive development (such as housing) should be taken into consideration in the site layout.

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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/RTW 27

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

DLP_2056

Terry Everest

Object

Strongly Object

This site is too large, and too much development is proposed. It not only is suburban sprawl but threatens the AONB which should be protected. This site goes against at least two of the principal positive guiding strategies.

DLP_3226

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:

Additional paragraph - Development shall deliver/contribute to substantial improvements to local road junctions and crossings within the immediate area, and to other traffic or sustainable transport measures; to include contribution to junction improvement investigation/implementation on A264 Pembury Road (see Policies TP1: Transport Assessments, Travel Plans, and Mitigation and TP2: Transport Design and Accessibility.

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

Heritage and Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

Site has high potential for remains associated with a late 19th to early 20th century community associated with the brickworks. Some of brickworks survive at depth. Previous archaeological works undertaken should be consulted for reference

DLP_5043

Hawkenbury Village Association

Support with conditions

This site is allocated for residential development (C3) providing approximately 220-250 dwellings and a primary school. Prior to the existing draft plan the Strategic Housing development for the Borough was focussed on the town of Tunbridge Wells. Over 80% of all new development took place in and around the town. The Hollyfields site is a visible manifestation of this.

We have endured a complete change to Hawkenbury from the Hollyfields development and we do not have the infrastructure, roads and transport, and amenities in place for any more housing to be built in Hawkenbury. We are adjacent to AONB and would like assurance that no further housing developments will be built in Hawkenbury.

DLP_7358

Wealden District Council

General Observation

Policy AL/RTW 27 (Pages 126 to 128) relates to Land at Hawkenbury, off Hawkenbury Road/Maryland Road that has been allocated for between 220 and 250 dwellings and a primary school (two form entry). The site lies to the south of Hawkenbury Road, a short distance from the boundary of Wealden District to the south.

This site already has planning permission for residential development (of 247 (net) dwellings) and the provision of a new primary school and is under construction. It has been suggested by TWBC that if planning permission has been substantially completed by the publication of the Regulation 19 Pre-Submission Local Plan stage, then this policy will be deleted. It is likely that this will be the case so Wealden District Council has no further comment to make.

It would be helpful for the allocation plan associated with this site to show the District boundary for Wealden.

DLP_7256

Mr John Telling

Object

I take this to be the 'Hollyfields' site already under development. It is difficult to understand how this was allowed to go ahead with no provision of truly affordable homes for young people resident in the town, nor without any social housing. What 'provision of sustainable and active transport mitigation measures' is being made?

DLP_8373

Ms Nicola Gooch

Support

AL/RTW 27

I wholeheartedly support this allocation, which is progressing well. It might be worth considering increasing the number of allocated dwellings, given the recent planning application for additional units. Please can you push KCC to provide a two form entry school as part of this allocation - there is a strong demand for primary school places in this part of Tunbridge Wells and it would be helpful to have expanded provision at St Peters - particularly as Claremont is oversubscribed.

Policy AL/RTW 28: Land at Rowan Tree Road, Showfields Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_8286

NHS West Clinical Commissioning Group

General Observation

It is noted that the site is allocated for a mixed use development to include an improved and enhanced medical centre, enhanced residential development, as well as improvements to community facilities that could be delivered through a wider hub development.

As per policy Policy STR/RTW 1 the CCG has identified that one or more new medical centres may be required to support relocation of existing surgeries. Specific sites have not been explored or confirmed. The statement regarding an improved and enhanced medical centre in Policy AL/RTW 28 is not therefore a requirement confirmed by the CCG but the opportunity that this policy may provide is noted.

DLP_914

Evolution Town Planning for The Number One Community Trust

Object

Please find attached our representations on behalf of the Number One Community Trust in relation to the Local Plan policy of the Number One Community Centre and surrounding land on Showfield’s Estate.  The Number One Trust is a major land owner and interested party and has major concerns about the principle of the allocation and indeed the wording of the policy.  As a landowner and operator, they are unable to support the allocation or suggested redevelopment for the reasons set out in the attached report. Without the Trust, as a significant landowner onboard, we consider this to be undeliverable and will not meet NPPFs deliverability tests.  As such, we suggest that the proposed policy should be withdrawn altogether.

Contents

1.0 Introduction and current situation

2.0 Policy AL/RTW 28

3.0 Conclusions

Appendix A: Plan of Village Green allocation

Appendix B: Sample of supporting letters from users of Number One

  • Introduction & Current Situation 

1.1 These representations are submitted by Evolution Town Planning Ltd on behalf of our client and site owners, The Number One Community Trust in response to consultation on the Draft Tunbridge Wells Local Plan Consultation (Regulation 18) 2019.

1.2 The representations relate to our client’s facilities on the Showfield’s Estate, which have been allocated for redevelopment under policy AL/RTW 28. As a significant landowner and provider of the community facilities designated for redevelopment, the Trust are surprised to discover that their facilities have been allocated for redevelopment, without consultation.

1.3 These representations set out that we:

  • Object to the allocation of site AL/RTW 28, since this is undeliverable without the consent of all landowners (of which the trust is a major landowner) and no consensus has been sought.
  • Moreover, we also object to the wording of the policy, since we are not convinced that the policy currently adequately protects the Trust’s facilities and land from quantitative or qualitative losses in terms of flexibility, visibility and freedom of use.

Land in the Trusts Ownership and Control 

1.4 The Number One community trust currently owns significant facilities on the Showfield’s Estate.

The Trust owns a large D1 meeting room, known as the library. This room has high ceilings and high street visibility. It has no residential uses above it, which means that it can and does accommodate D1 uses which may not be compatible with residential uses. This large D1 room is used 7 days a week by a range of community groups. The County Council uses it as a library several days a week. When the library is closed, the room is transformed to allow other D1 occupiers to use the space. On Mondays it is occupied by ‘First Steps’ toddler group and on Sundays it is occupied all day by an Anglican Church. Other users include an art group.

1.5 The trust also owns a smaller D1 room occupied by a Pre-School. This is open 5 days a week and is a valuable resource to the local community. The preschool also makes use of the outside playground, for which the Trust have recently secured a central government grant to refurbish. This is soon to commence. One of our offices us used during the week by the pre-school for office work, and is regularly used by the local MP for consultations with constituents.

1.6 In addition, the Trust owns one of the most successful community cafés in town. The community café is open 9-3 on weekdays but the space is also available for private hire (for events such as birthday parties and private functions) and is used for children’s work on Sunday by the Church. The Council will be aware that Christ Church’s community café recently closed in the centre of the town, and this facility is one of the only (if not THE only) not-for-profit community café’s remaining in the town. It is certainly the only such facility on the Showfields Estate. We recently began to participate in a programme of acquiring good value food that cannot only be used in our café, but is also passed on to residents at very affordable prices.

1.7 Further, the Trust owns two maisonettes above the Number One Community Centre, which are rented out to meet local need for reasonably priced market-rented housing and which provide important revenues for the Trust.

1.8 The Showfields Hall has implicitly become regarded by the community as belonging to the Trust and the Trust currently lease it and have made significant financial investment in it. It is a crucial component of the Trust’s services to its local communities, and some extended ones. After many years of being leased by TWBC to commercial enterprises, the Hall began to be leased by the Trust near the end of 2015 and came into operational use in the middle of 2016. The developer of the Showfields estate built the Hall in the early 1970s, at their cost, and donated it for community use, the community at that time being represented by the local borough council. The then Royal TW Borough Council managed the Hall and its hirings, but in order to maximise income from its assets the 1976-formed TWBC subsequently decided to lease the Hall on a five-year basis to commercial enterprise, thereby limiting its use by the local community. Since 2016 the Trust has been able to make the Hall genuinely available for community use. Those who regularly hire the hall include Parkinsons-heath, Tai Chi, boxing, beavers/cubs, tango-dancing, salsadancing, and ballet-dancing groups, as well as its regular Sunday use by the Emmanuel church, and individuals/families for private events. The Trust organises and funds events such as a Christmas pantomime. Insofar as funds have allowed, the Trust has tried to improve the hall, including renovating the floor, decorating internally, and installing some sound-proofing aids. Air conditioning, fully effective sound proofing, and a CCTV system to provide safety for users, remain unfulfilled aspirations. The Hall is currently owned by TWBC, not by the Trust – but its value to the community is dependent upon the staff (manager, cleaner, caretaker) employed by the Trust, and the programme of community groups and events organised by the Trust. Thus the Hall is designated an Asset of Community Value – but its practical use relies on the work of the Trust, and is to some degree limited by not being in the Trust’s ownership. (We are limited in terms of security of tenure and ability to apply for grants to improve the facility.)

1.9 Village Green status has been granted to a significant proportion of the proposed allocation area (Local plan ref: AL/RTW 28). The precise area can be seen in the map which forms Appendix A. It can be seen that of the proposed allocation, it breaks down as follows:

Trust ownership 15%

Lease hold by Trust (Hall) 10%

Other ownership 5%

Village Green 70%

A key reason Number One is able to operate as such a successful Community Trust, is the size of village green that the Trust has adjacent to the centre. Every day the playground on that village green and the surrounding grass areas are used by visitors to Number One Community Centre. In addition, the Trust’s regular community occupiers (including the Preschool, Church and Toddler Group who support these representations) all use the village green in association with their occupation of the ‘indoor’ spaces rented from the Trust. The playground in particular is not overlooked by houses on three sides and is used daily by the Pre-School that is a permanent tenant of Number One facilities. The trustees of Number One – and they believe the wider local community – would oppose not only any reduction in the size of the village green, but also any efforts to relocate it to a different place. Relocation would sever a vital link between the Number One Trust’s resources and the village green that is used by the community on Fun Days and as part of regular daily activities of the Trust. Below is a picture of recent Fun Day that utilised the village green (The grass area behind was also used).

1.10 All of the Trust’s facilities are rented out to community groups as much as possible and the trust enjoys no planning constraints on its facilities in terms of hours of use and noise restrictions, both indoor and outdoor. Separation of potentially noisy uses without noise sensitivity concerns above is an important part of the Trust’s success and the Trust would resist any intensification of residential uses on the site of proposed allocation AL/RTW 28.

1.11 The Number One Community Trust is a local employer, paying a full-time staff person to manage the bookings and facilities of the Hall and Centre, a caretaker and staff in the café. All of the Trust’s facilities are well used and highly valued by the community.

1.12 The trustees are therefore extremely concerned that the Trust’s sites have been allocated for redevelopment without prior consultation. As currently worded the Trust is not satisfied that the policy would provide adequate qualitative and quantitative protection of the Trust’s existing facilities; the format of their operation; the trust’s excellent street visibility; the trust’s freedom of unrestricted use/noise/hours of operation; or safeguarding from intensification of noise sensitive occupiers. The trust is also concerned to ensure safeguarding of the quantum of Village Green space and its relationship to the Trust’s facilities. We set out in greater detail the objections to the proposed policy in the proceeding chapter.

  • POLICY AL/RTW 28 

2.1 Policy AL/RTW 28 allocates land and facilities within the ownership of the Number One Community Trust for development, without any consultation and without clarity as to what the policy actually means. The Trust therefore objects to the policy. The reasons for the objection are set out below.

Potential for loss in flexibility, amplification and freedoms of uses

2.2 Whilst we note that the proposed policy states that the development sought is to be ‘a mixed use development to include an improved and enhanced medical centre, enhanced residential development, as well as improvements to community facilities that could be delivered through a wider hub development’, these terms are considered vague and unclear. Whilst a developer may consider that replacing the Trust’s facilities with newer facilities may be an improvement, the Trust is not convinced.

2.3 Inevitably such a development would seek to intensify residential use, so as to make the proposal viable. Whilst there are residences above part of the Trust’s Centre, those elements of the Trust’s landholding which have the potential for greatest noise (the hall and large D2 space occupied by a library, toddler group and church) have the benefit of being completely free from residential uses above. These spaces have high ceilings, a flexible format operate without any noise or hours of operational restrictions. Both spaces are used flexibly by the community and have the potential to accommodate a range of noisy uses, free from conflict with noise sensitive uses.

2.4 The Trust would not consider a replacement of these facilities, with intensified residential uses above to be an improvement, even if the replacement facilities were more modern. Such a redevelopment would risk imposing on the Trust (and its varied users) a loss of flexibility in use (stemming from noise-restrictions / hours of operation). At present the Trust’s uses are entirely unrestricted which gives the Trust freedom to decide who to let to. A new development, especially one with residential uses above the Trust’s facilities would undoubtedly seek to regulate and restrict hours of operation/types of users/amplification of music. The Trustees would strongly oppose such restrictions, since the community centre (and the hall especially) currently enjoy freedom from noise sensitive uses and any restrictions on their operations. This freedom has been crucial to the Trust’s success over the last 30 years.

Potential for loss in quality and flexibility in spaces

2.5 Policy AL/RTW 28 states ‘Development on the site shall accord with the following requirements: (1.) A comprehensive development for the site to include the possible re-provision and enhancement of the existing residential dwellings and improved and enhanced community facilities, to include a medical centre’. There is an anomaly in that the allocation in the draft plan includes one – and only one – of the social housing blocks which are on the estate.

2.6 We have concern that this policy, as drafted, does not adequately protect the Trust from what it would consider to be an erosion of its facilities. Whilst the policy states that any development would be required to provide ‘enhanced community facilities’, these would need to be quantified and qualified for the Trustees to consider offering support to this policy.

2.7 The Trust currently owns/leases/uses the following facilities:

 

Square meter of main room

Storage available (m2)

Height of building (m2)

Ancillary facilities (WCs)

Restrictions on hours of operation / uses

Residential uses Above?

On-street visibility

Library

225

32

5m

No

None

No

High visibility

Cafe

85

20

3m

Yes

None

Yes

Medium visibility

Preschool

90

20

3m

Yes

None

Yes

Medium visibility

Lobby & office space

45

NA

3m

Yes

None

Yes

Low visibility

Hall

375

90

9m

Yes

None

No

High visibility

Community

garden

40

NA

outside

No

None

No

High visibility

Playground area

1,100

NA

outside

No

None

No

Medium visibility

2.8 The Trust would need to be satisfied that every element of both qualitative and quantitative provision would be protected and significantly enhanced in order to support this policy. The policy certainly needs to be much more specific with regard to what enhancements will look like, without encroaching on or eroding the Trust’s existing facilities and freedoms.

2.9 Naturally, as landowners, the Trust will also want to ensure continued ownership of their facilities.

Residential Ownership

2.10 In addition to the community facilities which the Trust owns, the Trust also owns a number of flats in the residential offer at the site. These let very well, and are an attractive offer on the housing market. The Trustees would be unwilling to lose any ownership of their flats, and would need to be satisfied that any replacement provision was an enhancement on their existing flats. It is important to the Trust that they own the income-earning flats within the complex, and as such, they would be unwilling to accept a purchase of their flats to enable development, without such guarantees.

Mitigation of Impacts

2.11 We note that the policy includes some suggested ‘mitigation of impacts’ payments, in order to mitigate against the impact of the development. With regard to the facilities that the Trust currently offers, the Trustees wish to be clear that they would strongly oppose any offer of financial mitigation for the impact of development upon them. We assume that this relates to off site provision of services such as school places and waste collection. It needs to be noted that no financial mitigation for loss of volume, quality, freedom, flexibility, format or offer of alternative facilities to the Number One Community Trust will be acceptable. It is important to our operation that we retain our premises on our current site. We believe the visibility arising from our location and distance from immediate housing due to the village green is key to our operation. 

Disruption during construction / loss of street frontage location

2.12 Finally, we object to this policy on the grounds that we are not convinced that a redevelopment could be accommodated without the Trust losing either access to their facilities for significant lengths of time, or being permanently located in a nonstreet frontage location: both would be entirely unacceptable to the Trustees.

2.13 The success of this Trust’s Centre, compared with any other community centre run by a charitable trust within Tunbridge Wells, is based on its visibility on the street and the continued availability of its facilities to the community, without disruption.

2.14 Temporarily sending occupiers and groups to other locations may mean that they never return. Likewise, inadequately housing occupiers in portacabins may mean that the Trust (and the community) loses valuable groups and community assets. Similarly, providing a permanent replacement building, whilst the existing buildings are remaining in use would lead to the community buildings relinquishing their street frontage, which will undermine their long-term viability. We do not see how any temporary relocation could enable us to keep employing all the local staff that we offer work to. As such neither development option is supported by the Trustees. We therefore have strong reservations that such a major redevelopment could be accommodated without potentially fatal implications for this valuable community resource and as such, we oppose the redevelopment and the allocation of the trusts buildings in policy AL/RTW 28. As trustees we have agreed that a better way forward for us as a significant land owner in this site would be to begin improving and investing in the properties we own. We are now beginning to research that, in order to improve our offering to the local community. Below is photo of café area in use by a local community group.

  • Conclusions

3.1 The Trust seeks to serve and represent the local community. We are an integral part of community life on the Showfield’s estate.

3.2 We are aware that some of the residential flats on the estate would benefit from refreshing. We would support efforts to do that.

3.3 We do not think it sensible to allocate policy AL/RTW 28 in which there is a significant village green, and in which we are a significant land owner, prior to refreshing the flats, or in isolation from consideration of the entire estate.

3.4 We think that there should have been consultation before allocation was made.

3.5 We do not see how our assets and value to the community could be guarded through a transitional period of construction.

3.6 The policy as it stands does not offer adequate detailed protection of our assets - as such it does not indicate to potential developers the sorts of challenges they would face, were they to try and develop the site – particularly the matter of safeguarding the Trust’s activities during any possible transition and construction period.

3.7 For these reasons the trustees believe it is in the long term interests of not just the Trust, but the community we serve, that the Council remove policy AL/RTW 28 from the Local Plan.

3.8 The Appendix includes a sample of letters from some of our local community users supporting our representations. [TWBC: See Appendix in full representation]

DLP_3600

Southern Water Services Plc

Support with conditions

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/RTW 27

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

DLP_1818

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Numbers:  AL/RTW 7,8,9,10,14,15,19, 24, 26,28,29,31,32

The above sites seem suitable for allocation subject to the proposed conditions written into the policies.

DLP_4278

RTW Civic Society

 

We specifically endorse the provision of a medical centre in Showfields.

DLP_2478

TWBC Property and Estates

TWBC

Support

AL/RTW28

Bullet 4. Not sure that this is a designated Village Green under the Commons Registration Act 1965 or the Commons Act 2006. It is though an Area of Important Open Space

DLP_1837

Plan-Tecture UK for Clanricarde Medical Group: Patient Participation Group

Support with conditions

Policy AL/RTW 28 - Support on condition that a medical centre/general practice provision is included in the development of this allocated site. 

Introduction

PLAN-tecture (www.plan-tecture.co.uk) have been instructed by Clanricarde Medical Group Patients Participation Group (CMG PPG) to submit a representation to  support the provision of a new medical centre on the allocated site at Rowan Tree Road, Showfields Road, Tunbridge Wells, (map 28, SHELAA site 267), referred in Policy AL/RTW 28 of the TWBC draft Local Plan Reg18.   

Clanricarde Medical Centre took over Rowan Tree medical surgery in 2016 when a decision was made to merge Rowan Tree and Clanricarde Medical Centre patient participation groups to form Clanricarde Medical Group Patient Participation Group (CMG PPG).   

CMG PPG is a voluntary group of patients legally bound to the practice contract.  The group act as a “critical friend” for the practice, liaising with patients and doctors to ensure that any changes or improvement of medical primary care services are communicated to patients and expectations are met.  CMG PPG therefore have an interest in representing patients who see the need for a medical centre/general practice to be provided in the development of allocated SHELAA site 267, referred to in Policy AL/RTW 28.  

There is concern that the recent decision of the Clinical Commissioning Group (CCG) to close Rowan Tree surgery in January 2020 may have the effect of removing this essential medical provision from draft Policy AL/RTW 28.   Point 1 of draft Policy AL/RTW 28, uses the word “possible” which gives limited assurance that a medical centre would indeed be provided on this site.  The omission of this essential provision in a proposed development on this site would not meet local community and public expectations of this draft policy.  There should be more positive/certainty in the wording of the policy for the medical centre provision on this development site. 

The absence of a medical centre/general practice on this site would have detrimental impact on the health and wellbeing of local communities especially within the Broadwater ward, identified as one of the pocket deprivation areas across Tunbridge Wells borough falling within the -40% most deprived category (Index of Multiple Deprivation (IMD 2015), Table 2 of TWBC Equality Impact Assessment (EqIA) Reg 18).   It is essential that Policy AL/RTW 28 provides certainty for a new medical centre at this allocated site for the following reasons:     

Spatial need for a medical centre in the south of Tunbridge Wells town

The impending closure of Rowan Tree surgery means that there will be no medical general practice located in the south of Tunbridge Wells town. The existing Rowan Tree surgery is within the site allocated in Policy AL/RTW 28 which is part of Showfields neighbourhood centre.  The possible long-term loss of a medical centre/general practice provision within draft Policy AL/RTW 28 would disadvantage not only the local community served by the Showfields neighbourhood centre but also to the wider residential population in the south of Tunbridge Wells.  Existing medical practice premises located in the centre of Tunbridge Wells, such as Clanricarde Medical Centre, have very limited parking provision for visiting patients which is stressful for unwell patients who want the comfort of their own cars as a mode of transport.    

The TWBC Infrastructure Delivery Plan Reg 18 (IDP) explains that the CCG have identified the need for a general practice premises to be located possibly in the south of Tunbridge Wells town to respond to growth during the new Local Plan period (3.93, 3.94 IDP).  Policy AL/RTW 28 identifies an opportunity site in terms of location that meets the suggested location for delivering a medical centre through a wider hub.  The medical centre provision on this allocated site would serve a diverse neighbourhood resident population of protected characteristic group status, as defined in the Equalities Act 2010 and further explained in paragraphs 1.8 and 1.9 of the EqIA Reg 18.   

At this site, the medical centre will not only encourage patients living in the south side of town to use active modes of travel such as walking, but also be cost effective and improve the wellbeing of many young families and elderly residents living in the adjacent residential estates in Broadwater, Pantiles and St Marks wards which are within easy reach of this site. This will promote long term net gains in social equality for a diverse range of local residents to access medical service at this site while increasing footfall, vibrancy and economic wellbeing to the other facilities within the development site.

It is noted (TWBC IDP Reg 18) that general practice premises plans will be kept under regular review by the CCG, since priorities are subject to change to ensure appropriate general medical service capacity is available as part of their commissioning responsibilities and subject to available funding, affordability and value for money.  In this respect, CMG PPG request that TWBC engages closely with CMG PPG on any changes in priorities for the provision of a new medical centre practice under Policy AL/RTW 28.  The CMG PPG would like to participate in collaborative stakeholders’ discussion to help find solutions to overcome barriers encountered to realise a medical centre on this site. 

The statistics from Kent County Council's policy-based demographic projections (2018) predict that there will be 20% increase in the population and 55.1% increase (12,3000) people aged 65+ between 2017-2037 in the borough of Tunbridge Wells.  An aging population justify the priority to establish a new medical centre, that would be accessible to patients using all modes of transport including the car with adequate provision for parking.

As the planned delivery of a new medical practice has been identified possibly in the south of Tunbridge Wells town as medium term (p91 IDP), between 5 to 10 years of the new local plan period, CMG PPG request that in the meantime the TWBC IDP is updated to address the urgent priority to commence short term delivery (from January 2020 when Rowan Tree surgery closes) of more direct, regular and frequent bus routes and connections from Showfields Road to St Johns Road, Tunbridge Wells.  This will ease the uphill struggle for many existing patients from Showfields and Ramslye estates to access medical services at Clanricarde Medical Centre given the very limited available parking provision at Clanricarde Medical Centre.  There is also the need to have bus stop shelters at each end of this identified bus route.   

Community engagement, participation and collaboration to evolve development brief, design and a sense of place

The allocated site is part of Showfields neighbourhood centre with occupied buildings providing facilities to an existing community and clientele. Early engagement with the land owners, community, end users and stakeholders including CMG PPG would be essential to weigh the options available in developing the site to ensure a collaborative shared vision for the development proposal.  This engagement process should be mentioned positively in Policy AL/RTW 28, given that the success of the development will be dependent on the pride of end users being involved in creating their own sense of community place. 

The engagement process needs to be positively planned.  It should include building confidence in the local community to collaborate with stakeholders in identifying shared priorities to formulate a development brief and design with options of how a comprehensive development of the allocated site, currently occupied, could be carried out.   

Conditions

CMG PPG supports the Policy AL/RTW 28 provided that there is certainty for the provision of a medical centre/general practice premises included within the comprehensive development.  The following are conditions that should be applied on the allocated site: 

* Evidence of an implemented programme of early and continued engagement to build knowledge capacity and collaboration with stakeholders (including land and building owners, local community, occupiers, users of the existing facilities) and CMG PPG to ensure shared decisions are made to formulate and realise the development brief and design. 

* If the development requires contributions to health and medical facilities, these should be ring-fenced for on-site health and medical provision. 

Conclusion

Policy AL/RTW 28 should be positively worded to ensure the medical centre will be provided on the allocated site because this provision will secure net gains in economic, social, and environmental objectives compliant to the sustainable principles of the National Planning Policy Framework and for the reasons explained in this representation.

DLP_3230

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:

Additional paragraph- Development needs to address operational parking and servicing.

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

DLP_7257

Mr John Telling

Object

Regarding Policy point 1: the medical centre is scheduled to close. Furthermore the library hours have reduced significantly.

The loss of the medical surgery is appalling. People, including the elderly, the disabled and those with young children will have to travel into town, with all the ramifications for road congestion and parking, or lugging children and buggies on buses, for basic medical consultations. The facilities on this site are crucial to the personal and community wellbeing of people in Showfields, Ramslye and beyond.

Social contact is increasingly recognised as important for mental health, and the No1 Trust is instrumental in providing activities and facilities for all, but especially children and the elderly in this area, and for supporting the community café, which provides a meeting place for individuals, families and social groups, as well as a stop off point for trades people and those in mobile service occupations. The pre school is a hugely valued service in this area, well sited to benefit from the outdoor public children's play facilities.

This is an absolutely crucial community resource for the Showfields, Ramslye and adjacent areas, which the Council should be supporting far more actively. Have proposals been consulted on, or discussed with the Community Trust trustees?

A proposal for 'redevelopment' is astonishing without a full discussion with those actually committed to, and involved in providing the existing services.

Policy AL/RTW 29: Land at former Gas Works, Sandhurst Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_536

Councillor Frank Williams

 

Development here will raise vehicle access issues as Sandhurst Road is increasingly busy; raise traffic issues for the same reason; and raise pedestrian safety issues. A pedestrian crossing, ideally pelican/light-controlled, is needed on Sandhurst Road to facilitate access particularly for parents of children attending Temple Grove ie. in the vicinity of the Robin Hood P.H.

DLP_3601

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Tunbridge Wells. 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 170 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/RTW 29

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 Tunbridge Wells. 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/RTW 29

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

DLP_1819

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Numbers:  AL/RTW 7,8,9,10,14,15,19, 24, 26,28,29,31,32

The above sites seem suitable for allocation subject to the proposed conditions written into the policies.

DLP_2057

Terry Everest

General Observation

Query

Has this site been fully remediated ? Is further development here totally necessary. The current intense level of housing around here would not surely be appropriate so close to the highway and on previously contaminated land. I have personally studied this site in my Merit level thesis so perhaps you would like further guidance in detail on this proposal.

DLP_3116

Andy Bashford

Support with conditions

Presumably fitting 170 homes into the site means tall blocks of flats. If they are be for social housing, that would be good. Given that this site was an Industrial site before, why not use it for new Industrial developments, such for Multi-Garages like that of Hendy? In which case “Landscape buffers to railway line and electricity installations” presumably wouldn’t relevant?

DLP_3136

Teresa Stevens

Support with conditions

Presumably fitting 170 homes into the site means tall blocks of flats. If they are be for social housing, that would be good. Given that this site was an Industrial site before, why not use it for new Industrial developments, such for Multi-Garages like that of Hendy? In which case “Landscape buffers to railway line and electricity installations” presumably wouldn’t relevant?

DLP_3231

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

Paragraph 2 –“Transport improvements: development shall deliver/contribute to transport improvements, to include improvements to road junctions and crossings adjacent to the site and within the surrounding area, as informed by Transport Assessments (see Policies TP 1: Transport Assessments, Travel Plans, and Mitigation and TP 2: Transport Design and Accessibility)”

Paragraph 4 - Improvements to vehicular, cycle, and pedestrian links under the railway line at Sandhurst Road/Upper Grosvenor Road junction

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

Heritage and Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

Potential for post medieval industrial heritage. Some assessment of archaeology needed.

DLP_7101

Carter Jonas for SGN

Support with conditions

I am writing on behalf of our Client, Southern Gas Networks (‘SGN’) in respect of their landholding at the Former Gasworks, Sandhurst Road, Tunbridge Wells, Kent. Their Site is proposed for allocation in the Draft

Local Plan under draft Policy AL/RTW 29.
SGN manages a gas network that distributes natural and green gas to approximately 5.8 million homes and businesses across Scotland and the South of England. Advances in technology and changes in gas provision across the country enables gas to be stored within the underground pipes, which makes the existing gasholder structures redundant. In 2013, SGN commenced a programme of decommissioning all of its gas holders, dismantling the existing gas infrastructure and redeveloping sites. The Site above has been included within this programme.

The Site is currently allocated for residential development (C3) in the adopted Site Allocations Local Plan under Policy AL/RTW 10. The site is expected to achieve approximately 170 dwellings.

SGN welcomes the continuation of this allocation within the draft Local Plan for residential use, but wishes to clarify site details and provide comment on the proposed wording of draft Policy AL/RTW 29.

Site Details

The Council’s information for this site is derived from the Strategic Housing and Economic Land Availability Assessment (SHELAA) (July  2019) that forms part of the evidence base of the draft Local Plan. SGN would like to clarify the Council’s records:

  • SGN can confirm that they have full ownership of the site outlined by the red line boundary within the policy;
  • SGN can confirm that the gross area (1.78 ha) of this site is accurate;
  • SGN can confirm that approximately 170 residential units can be successfully delivered on this site. As the site is brownfield land, it complies with Paragraphs 117 and 118 of the National Planning

    Policy Framework (NPPF) – promoting an effective use of land in meeting the need for new homes, through which substantial weight should be attributed to the value of brownfield land; and
  • SGN can confirm that the site is both available and achievable. The three gasholders that were previously on this site have been cut off from the gas network, decommissioned and dismantled –

    alongside the complete clearance of supporting equipment. The site has also been successfully remediated from any land contamination. As a result, the whole site is currently vacant and available in the short term for development. We therefore suggest that the site could be delivered within the first five years of the plan period. The incorporation of this site within the Local Plan will make a considerable and immediate impact on housing delivery within TWBC.

Site Allocation Policy

Draft Policy AL/RTW 29 presents a series of requirements that development shall accord to at the proposed allocation. However, SGN believe that the wording of this policy is needlessly cumbersome. NPPF

Paragraph 16 (d and f) respectively state that plans should contain policies that are “clearly written and unambiguous” and “serve a clear purpose, avoiding unnecessary duplication of policies”.

The wording frequently reiterates policies already listed throughout the draft Local Plan, namely Criteria 1, 2, 3, 6, 7, 8, 9, 10, a, e and f. Many of these requirements would also be necessary to validate a subsequent planning application and should therefore be removed from the proposed policy. SGN recognise that the inclusion of site-specific requirements are necessary and that Borough-wide circumstances change over time. However, given that the site allocation was only adopted in July 2016, and does not propose an

amendment to the site uses or capacity, SGN request that the Council carry forward much of the existing allocation rather than amending it unnecessarily.

In light of the above, we believe the policy should be drafted as follows (overleaf).

AL/RTW 29

Land at former Gas Works, Sandhurst Road (SHELAA reference: SALP AL/RTW 10)

This site, as defined on the Royal Tunbridge Wells Policies Map, is allocated for residential development (C3) providing approximately 170 dwellings.

Development on the site shall accord with the following requirements:

1) An appropriate scheme will outline access into, and through, the site, including vehicular, cycle, and pedestrian links;

2) Development shall be of a range of heights to take advantage of the topography of the site;

3) The development shall provide a connection to the sewerage system at the nearest point of adequate capacity;

4) Development shall take advantage of the existing watercourses through the site and open up culverts;

5) An appropriate scheme will ensure that landscape buffers to the railway line and electricity installations are included;

6) An appropriate scheme will subject to a financial contribution to improving vehicular, cycle and pedestrian links across the railway line at Sandhurst Road/Upper Grosvenor Road junction.

It is expected that further contributions will be required towards the following if necessary, to mitigate the impact of the development:

a) Highways improvement works in the vicinity of the site;

b) Primary and secondary education;

c) Health and medical facilities;

d) The provision of buildings and spaces to provide cultural infrastructure; and

e) Open Space, Sports and Recreation Grounds and built facilities, and children’s play space.

We also wish to add that NPPF Paragraph 56 sets out the following tests for the justification of planning obligations on sites:

1) Necessary to make the development acceptable in planning terms;

2) Directly related to the development; and

3) Fairly and reasonably related in scale and kind to the development.

This further supports the argument that the current wording of policy can be simplified and made specific to the development itself.

In the event that TWBC decide to adopt a CIL charging schedule (with a decision expected by the end of 2019 in line with the Draft Local Plan) the second paragraph in the proposed revised version of the policy (ae) may require removing or rewording.

Conclusion

SGN supports the inclusion of their site as a site allocation for approximately 170 residential dwellings within the emerging TWBC Local Plan. SGN would like to reiterate that the size and development potential of their site is accurately recorded and emphasise the deliverability of their site within the first five years of the plan period. However, SGN propose necessary amendments to the wording and emphasis of draft Policy AL/RTW 29 to make it clearer and more site-specific, in line with national policy.

DLP_7098

Richard Hopkinson Architects for J Murphy & Sons and SGN

Support with conditions

Policy Number: Policy AL/RTW29 – Land at Former Gas Works, Sandhurst Road

Principle of allocation

J Murphy & Sons (JMS) and SGN welcome the allocation of the former Gas Works Site for housing. The Gas Works was decommissioned some years ago and now lies largely vacant, with the exception of a small compound area. The disposal and redevelopment of the former Gas Works is part of SGNs rolling programme of decommissioning gas holder sites across the country and replacing these with underground gas infrastructure. SGN is working in partnership with JMS to progress the delivery of housing on this site; it is currently at the pre-planning stage.

The former Gas Works comprises an approximately 1.8 ha redundant previously developed ‘brownfield’ site lying within the Tunbridge Wells urban area. It is surrounded by existing residential streets and is in close proximity to public transport links (including High Brooms rail station, less than 150m walk, and bus routes) and within easy reach of Tunbridge Wells Town Centre and North Farm / Knights Park retail and industrial estates. It has excellent access to jobs, shops and services.

The former Gas Works is, therefore, a highly sustainable location to accommodate new housing. Moreover, it is available and deliverable in the early part of the Plan period and able to provide an important contribution to meeting housing needs in Tunbridge Wells Borough.

The proposed allocation of the site for housing, which carries forward the allocation in the Site Allocations Local Plan 2016, is strongly supported by JMS and SGN.

Efficient Use of Site

The draft policy identifies the site’s potential to deliver “approximately 170 dwellings”. Based on up to date design work taking into account the detailed characteristics of the site and its context, JMS and SGN consider that the site provides the opportunity to deliver a higher density housing development on the site, of approximately 200 dwellings.

The site allocation is carried forward from the adopted Site Allocations Local Plan 2016, within which Policy AL/RTW 10 similarly identifies the Gas Works to deliver approximately 170 dwellings based on “initial feasibility studies” (within the document, Capacity Assessments of Potential Allocation Sites, TWBC 2015).

The 2015 TWBC Capacity Assessment recognised that the site could comfortably achieve 170 units, but that a worked-up scheme could potentially achieve more. Since the site’s allocation within the adopted Local Plan, JMS and SGN have carried out further feasibility studies, contextual analysis and site modelling, which has identified the potential to deliver a larger number of dwellings on the site, based in particular on:

* The proximity to High Brooms mainline station and bus links, and the overall ease of access to Tunbridge Wells Town Centre, Southborough and Knights Park / North Farm retail and industrial parks.

* Local market assessment of housing need in the site’s vicinity, which suggests that a bias towards greater numbers of smaller units, within an overall balanced mix, would be appropriate.

* Maximising the opportunities created by the significant changes in levels across the site, which lends itself to an interesting design and offers the opportunity to develop at higher density, with taller buildings able to sit comfortably within the townscape [NB. the 2015 TWBC Capacity Assessment recognised that taller buildings could be achieved on the site].

* The separation of the site from its neighbours by Sandhurst Road.

* The incorporation of appropriate amenity and landscape open space, including areas of flood attenuation.

The outcome of this feasibility work demonstrates how approximately 200 units could be delivered on the site in such a way that provides a high-quality environment, with substantial areas of green infrastructure and open space. An open space network would create connections with existing areas of open space and landscape to the north and south and secure flood risk attenuation by opening up the watercourse and creating flood attenuation zones and deliver biodiversity benefits. A balanced mix of units that would include both larger family dwellings and apartment blocks could be accommodated, responding to local need and the site’s location. Taller buildings would be located on the northern and eastern perimeters of the site, responding to changes in topography and adding to the richness of the urban environment.

While recognising that the design is at an early stage and evolving, it is evident that a higher number of dwellings than is proposed in the draft Policy could be achieved on the site. Given the importance of delivering development that makes efficient use of previously developed land, as highlighted in the National Planning Policy Framework, it is imperative that the Site Allocation Policy recognises this potential.

JMS and SGN therefore request that the policy be amended to allocate the site for “approximately 200 dwellings”.

JMS and SGN would be happy to share early concept plans with TWBC to demonstrate how this number of dwellings could be accommodated on site.

Development requirements and contributions

JMS and SGN are working to secure a balanced, sustainable development on the Gas Works site that will meet local development needs and secure a good quality environment for existing and future residents. Viability and deliverability will be vital to the successful regeneration of this site, as there are significant abnormal costs associated with its redevelopment.

Gas Works sites typically present a number of challenges that need to be addressed to facilitate development relating, for example, to decontamination works and the requirements for removal and diversion of existing gas and other service infrastructure. In addition to this, the delivery of the former Gas Works site at Sandhurst Road is likely to require major ground works and potentially complex structural solutions to tackle the site’s topography. The existing watercourses through the site present further challenges, as does the need to ensure an appropriate flood-risk and drainage strategy.

The list of site requirements and contributions set out within the Policy are untested against the site circumstances and appear to be potentially onerous. It is therefore requested that flexibility be applied to these requirements within the wording of the Policy, through the incorporation of the following wording; … “The requirements of this Policy may be applied flexibly, where it is demonstrated that such requirements would make the development unviable.

The scope of green space requirements also appears to be unduly onerous. The draft Policy requires the: “10. Provision of on-site allotments, amenity/natural green space, parks and recreation grounds, children’s play space and youth play space in accordance with the requirements of Policy OSSR 2: Provision of publicly accessible open space and recreation.”

The Gas Works site lies between two important areas of open space, comprising the extensive Grosvenor and Hilbert Park to the south (with an access point less than 100m from the site) and the Oak Road Open Space approximately 200m to the north. These spaces provide access to established children’s and youth play areas, sports pitches, recreational open space, amenity and natural green space and allotments within easy reach of the site (as demonstrated in the Open Space Study access zones). There is a further allotment area 250m south east of the site on Sandhurst Road.

Quality open space is expected to be at the heart of a future development on the Gas Works site and JMS/SGN are committed to achieving this. The open space provided should not, however, be required to replicate the existing, good quality provision in the locality and any requirements must be balanced against the need to make optimal use of brownfield land. Most importantly, the scheme should deliver meaningful open spaces that provide a high-quality environment for existing and future residents, create amenity green space and landscaping, develop connectivity with existing open spaces and pedestrian/cycle networks, maximise the potential of the water courses and provide flood attenuation and deliver biodiversity/landscape enhancements.

It is noted that the paragraph 10 requirements link with Policy OSSR2. The inclusion within the site allocation policy of a full list of open space typologies to be provided on site, however, suggests that all forms of open space should be delivered within the Gas Works development. As worded, it is not clear that the requirement would meet the relevant tests for planning obligations and, moreover, it would create a false expectation about the potential range of spaces that should be delivered on the site.

It is therefore requested that the policy should more explicitly link the requirement for open space within a development to the need/deficiency in the vicinity of the site. As such, paragraph 10 should be simplified to require the: … “10. Provision of on-site open spaces in accordance with need in the vicinity and with the requirements of Policy OSSR 2: Provision of publicly accessible open space and recreation.

In connection with the above, it is also requested that paragraph f. of the policy (relating to required contributions) be deleted as it replicates paragraph 10. 

Parking

As explained in the response to Policy TP3 - Parking Standards, JMS and SGN have concerns regarding the implications of the draft parking policy on the ability to deliver quality housing at high-density in appropriately accessible locations.

This is particularly relevant to the former Gas Works site, the location and accessibility of which lends itself to delivering a high-density housing scheme, being so close to High Brooms Station and to other sustainable transport links and shops, facilities and employment opportunities. The site is uniquely located to benefit from sustainable transport modes and, as noted in the Residential Parking Standards Background Paper, is in an area of relatively low car ownership and a higher proportion of train travel.

The draft Local Plan rightly states that a single approach to the provision of car parking across all developments in the Borough is not appropriate (para. 6.514). In the case of the Gas Works site, the imposition of the proposed minimum standards would fail to take full account of the accessibility of the site (in line with NPPF paras. 105 and 106). Further, it would not support the delivery of the mix of units that would be appropriate for the site, comprising a higher proportion of smaller units to respond to the location and local market need. The requirement to deliver the minimum parking standards could undermine the ability to achieve an appropriate density of development alongside the suitable provision of amenity space.

In order to reflect the unique site specific circumstances, it is therefore requested that, in accordance with the exceptional circumstances requirement of Parking Policy TP 3, Policy AL/RTW29 be amended to require that: … “a bespoke approach to the provision of residential car parking be adopted that balances parking provision with the accessibility of the site and the delivery of a package of sustainable transport measures to be agreed with the Local Planning Authority.

Policy AL/RTW 30: Land at Medway Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_3232

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:

Additional paragraph - Parking, deliveries and drop off to be accommodated from Medway Road.

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

Policy AL/RTW 31: Land at 123-129 Silverdale Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1820

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Numbers:  AL/RTW 7,8,9,10,14,15,19, 24, 26,28,29,31,32

The above sites seem suitable for allocation subject to the proposed conditions written into the policies.

DLP_2956

Peter Lidstone

Object

I object to the proposed scale of the development at this site. The parking and traffic situation are already at breaking point. It is unlikely that sufficient parking spaces would be allocated for the site, so cars will need to park on Silverdale Road, at the junction with Silverdale Lane, which is would present a danger to pedestrians and cylists.

There are also concerns around overdevelopment and necessary overlooking of neighbouring properties, as well as properties on Merrion Way and Lakeman Way.

Reasonable development in keeping with the local area (6 - 8 semi-detached properties) would be far more suitable on this site, and ensure adequate parking provision

DLP_3234

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following change is requested

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

Policy AL/RTW 32: Land at Beechwood Sacred Heart School

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1821

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Numbers:  AL/RTW 7,8,9,10,14,15,19, 24, 26,28,29,31,32

The above sites seem suitable for allocation subject to the proposed conditions written into the policies.

DLP_2058

Terry Everest

Object

Object

This site is currently quite well populated with trees and is next to a significant highway within the town. This development would remove the important buffering value of the trees and the parkland style surrounds.

DLP_3237

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following change is requested

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 and Conservation

Scale 3 - Significant archaeology could be dealt with through suitable conditions on a planning approval

Potential for remains associated with post medieval residence and designed landscape. Some archaeological assessment needed.

DLP_2915

Chris Gow

Object

I object to this development.

The development is on Green Belt land, and should not be granted.