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Section 5: Place Shaping Policies Southborough


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

Contents

Policy STR/SO 1: The Strategy for Southborough

Comment No.

Name/Organisation

Response

DLP_1992
DLP_2973
DLP_2481
DLP_2501
DLP_2946
DLP_2993
DLP_3005
DLP_3407
DLP_3412
DLP_3740
DLP_3745
DLP_3750
DLP_4061
DLP_4078
DLP_4322
DLP_4335
DLP_4344
DLP_4347
DLP_4401
DLP_4414
DLP_4418
DLP_4427
DLP_4509
DLP_4519
DLP_4533
DLP_4549
DLP_4575
DLP_4707
DLP_4710
DLP_4720
DLP_4737
DLP_4742
DLP_4745
DLP_4746
DLP_4752
DLP_4757
DLP_4763
DLP_4771
DLP_4785
DLP_4791
DLP_4798
DLP_4802
DLP_4810
DLP_4820
DLP_4830
DLP_4833
DLP_4836
DLP_4839
DLP_4842
DLP_4849
DLP_4975
DLP_5142
DLP_5859
DLP_5865
DLP_5874
DLP_5894
DLP_5992
DLP_6081
DLP_6101
DLP_6111
DLP_6236
DLP_6244
DLP_6327
DLP_6346
DLP_6354
DLP_6357
DLP_6368
DLP_6383
DLP_6393
DLP_6394
DLP_6417
DLP_6443
DLP_6448
DLP_6475
DLP_7262
DLP_7295
DLP_7692
DLP_7708
DLP_8043

Mrs Lisa Dunnett
Tim Boden
Janet Trayner
Brian Austen
Priya Enefer
Michael Lee
Elspeth Penny
Branislav Trajkovski
Terry Brisefer
Marion Harris
James Dunnett
Anthony Harris
Sophia Spickett
Sean Mullins
Gary Smith
Nicole Smith
Sara Vincent
Christopher Van't Hoff
Teresa Ann Van't Hoff
Freddie Van't Hoff
Hannah Van't Hoff
Katie Van't Hoff
Werda Hattingh
Mary Greenwood
Eric & Fiona Watkins
Bryan Greenwood
Lynn Green
Patrick North
Mark Weavis
Christina Sharpe
Kevin Kirby
Corrine Kirby
Cook Clancy and Co
Izzie Miller
Gillian Curphy
Keith Ebbels
Susan Tanner
Stephen Traveller
Susan Robertson
Amin H Rajan
Gail Armstrong
Paul Smith
Ann Norman
Tracey Gadd
Stuart Taylor
Elizabeth Dowling
Mark Windle
Alastair Dale
Christopher Beach
Maija Wilson
Rachel Waller
Mark Weller
Liz Wallace
Andrew Wallace
Sally Moesgaard-Kjeldsen
Sylvia Bourne-Moore
Pamela  Barnes
John Stephen Barnes
David & Jennifer Heyes
Andre Hattingh
Diane & Andrew Bell
Claire Penney
Chloe Daniels
Paul Sleightholme
Mark Brennan
Brian Waters
Ruth & Paul Langridge
Keith Hardwick
Saffron Bohan
Marji Whale
Neil Bohan
Laura Weller
Linda Weller
Deborah Crook
Chris Daniels
Keith Crook
Leah
Julia Prentice
Martin J Prentice

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

Object 

The strategy seems to be focussed on the urban areas of Southborough ignoring the fact that 66% of the parish is in the Green Belt and 64% is in the AONB. Paragraph 5.53 even says that all the allocations are “within the Main Urban Area”. This is incorrect. Both AL/SO 3 and AL/SO 4 are outside the Main Urban Area, and are on AONB/Green Belt sites (my comments on these site allocations are given below in comment boxes 2A and 2B)

I am also concerned that the only references to the Southborough Hub (AL/SO 1) are re:the housing (which is already built and for sale) and the Medical Centre. There’s no mention for example about a theatre being provided (to replace the much-loved Royal Victoria Hall), replacement library, or community facilities.

DLP_2060

Terry Everest

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_2253

Anya Wood

Object 

The strategy appears to ignore the fact that 66% of the parish is in the Green Belt and 64% is in the AONB. Paragraph 5.53 says that all the allocations are “within the Main Urban Area”. This is incorrect. Both AL/SO 3 and AL/SO 4 are outside the Main Urban Area, and are on AONB/Green Belt sites (my comments on these site allocations are given below in comment boxes 2A and 2B)

DLP_2630

Alistair Beeston

The strategy seems to be focused on the urban areas of Southborough ignoring the fact that 66% of the parish is in the Green Belt and 64% is in the AONB. Paragraph 5.53 even says that all the allocations are "within the Main Urban Area". This is incorrect. Both AL/SO 3 and AL/SO 4 are outside the Main Urban Area, and are on AONB/Green Belt sites (my comments on these site allocations are given below in comment boxes 2A and 2B)

If indeed the strategy is to be based on urban Southborough there appears inadequate consideration of effective use being made of potential brown field sites. Additionally the pace of technological change during the plan period is likely to render many commercial, industrial and retail activities redundant. Rather than permit unwelcome intrusions into green belt and AONB the plan should have a more dynamic approach to identify and utilise existing spaces as they become brown filed rather than sit back and await ad hoc renewal. It would also serve to revive rapidly declining areas of Southborough.

DLP_2972

Tim Boden

Mabledon

What a ridiculous location to place a major development-this area is only in Tunbridge Wells councils area by default, and as in the proposed development in the Capel area, TWBC is obviously trying to place developments away from the Tunbridge Wells area, and as close to other boroughs as possible-disgraceful behaviour!!

As an aside, this document is typical of government type forms that puts everything in legalise, that most people can’t navigate/understand, and is done to stifle debate!

DLP_3242

Kent County Council (Growth, Environment and Transport)

Highways and TransportationThe Local Highway Authority conditionally supports this policy.

Comments on sites mentioned in this policy are set out in individual policy comments.
The following changes are requested:

Paragraph - “Maintenance and enhancement of, and/or linkages to, public footway network, public rights of way and the local strategic cycle network in accordance with Policy TP 2: Transport Design and Accessibility”

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

Public Rights of Way and Access Service

KCC supports and welcomes the specific reference to PRoW in paragraph 8.

DLP_4088
DLP_4874
DLP_5814
DLP_5899
DLP_6232

Jayne Windle
Dominique Webber
Brian Wood
Tim Elliott
Martin Webber

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

Policy Number:  STR/SO 1 The Strategy for Southborough 

The strategy seems to be focussed on the urban areas of Southborough ignoring the fact that 66% of the parish is in the Green Belt and 64% is in the AONB.  Paragraph 5.53 even says that all the allocations are “within the Main Urban Area”. This is incorrect. Both AL/SO 3 and AL/SO 4 are outside the Main Urban Area, and are on AONB/Green Belt sites (my comments on these site allocations are given below in comment boxes 2A and 2B)

DLP_4112

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

CPRE objects to the Strategy for Southborough.

We  note that of the proposed 135-205 new dwellings, 85 have already been granted planning permission on sites AL/SO1 and AL/SO2.  This means that the balance of additional dwellings is to be provided solely by site AL/SO3 which is located within the Green Belt and AONB and outside the LBD.  (Paragraph 5.53 mistakenly states that all the allocations are “within the Main Urban Area”).  CPRE is concerned that up to 60% of new dwellings within Southborough are being proposed within the AONB/Green Belt and we feel this example highlights CPRE’s overarching criticism that TWBC is not seeking to maximise development within the existing urban areas by measures such as increased housing density.

Allocation AL/SO 4 is only mentioned in passing (as being included in the LBD around Southborough.)  This allocation includes the restoration of a Grade II listed house associated with Decimus Burton  (Mabledon House) and the Historic Park and Gardens.  The proposed 200-bed hotel and leisure complex in this allocation, together with on-going maintenance of the Park and Gardens would be expected to provide a high level of new employment opportunities as well as supporting an increase in tourism.  CPRE suggests that an additional point be added to the Policy to recognise the potential economic benefit of this allocation.

“A new luxury hotel and leisure complex will be delivered, together with the restoration of an Historic Park and Gardens (AL/SO 4)”

64% of the Parish of Southborough lies within the AONB and 66% lies in the Green Belt;  the policy contains only very limited provisions for conserving and enhancing these areas. CPRE is aware that Policy EN21 High Weald Area of Outstanding Natural Beauty (AONB) as currently drafted specifically excludes sites allocated in the Local Plan (see our objection concerning policy EN21).  This is a very important point for the Strategy for Southborough as the two allocations that have not yet received planning permission (AL/SO3 and AL/SO4) are in largely open countryside in the AONB.  Policy point 4, requiring proposals within the AONB to “make a positive contribution towards achieving the objectives of the AONB Management Plan”, falls far short of the provisions in Policy EN21 and the requirements of the NPPF regarding development in the AONB.  In particular the scale and extent of development within the AONB should be limited (in accordance with the NPPF).  CPRE believes that proposed allocations should be subject to the full provisions of policy EN21, including those relating to the NPPF policies for major developments in the AONB.

The final paragraph of Policy STR/SO 1 states that the site allocated under AL/SO 4 is now included within the LBD around Southborough.   This extension of the LBD is not shown in the draft Policies Maps.  The map in the Limits to Built Development Topic does not even extend to this site location, which is some distance from the current LBD.  (28.1 Royal Tunbridge Wells and Southborough LBD Boundary Amendments (NORTH:: site reference 1-12).  This site lies within the AONB/Green Belt and predominantly covers a Historic Park and Garden. CPRE believes that it is wholly inappropriate to include the whole site within the LBD as this creates a presumption of further development of the site. The wider site should remain outside the LBD to act as a check on further expansion of the site under the proposals within AL/SO 4.

DLP_4367

British Horse Society

Support with conditions

Under bullet points 8 and 9, the proposed improvements to public rights of way, the strategic cycle network and amenity/natural green space, parks and recreation gorounds should include the provision of new facilities for horse riding.  A means of linking (or at least semi-linking) the public bridleway along the new section of the A21 to the public bridleway at Southborough Common should be the aim, as well as some new circular horse riding routes in the Green Belt to help to improve accessibility to compensate for building on part of the Green Belt.

DLP_4778

Alison Spender

Policy Number:  STR/SO 1 The Strategy for Southborough 

I am particularly concerned with the traffic congestion and protecting the countryside that lies between the urban areas of Southborough and Tunbridge Wells.

We are concerned that the strategy pays little regard to the 66% of the parish that is in the Green Belt and the 64% that is in the AONB. There is no reference to requirements in the NPPF to conserve and enhance landscape and scenic beauty in Areas of Outstanding Natural Beauty and the requirements re the objectives set out in the High Weald Management Plan are very weak.  There is no mention of enhancing biodiversity or actions to address climate change.  We also note that managing air quality is not part of the strategy for Southborough, despite the continuing poor air quality in the AQMA.

Paragraph 5.53 (Allocation Policies for Southborough) states that all the allocations are “within the Main Urban Area”. This is incorrect. Both AL/SO 3 and AL/SO 4 are outside the Main Urban Area, and are on AONB/Green Belt sites.  We are not sure that the Council is aware of the actual locations of either of these sites (straddling the border with Tonbridge) as the policy also states that the LBD now includes AL/SO4 but this is not visible on the Southborough Policies Map and the map in the Limits to Built Development Topic Paper (28.1 RTW and Southborough LBD Boundary Amendments)only covers the area up to Vauxhall Lane, about a mile south of Mabledon House.

DLP_4790

Amin H Rajan

This proposed development will be hugely detrimental to the area and the communities that live in it.

First, the size of the development will totally change the character of this area of outstanding natural beauty: its scenic features, its flora and fauna, its rural charm.

Second, it will harm endangered species that inhabit on this area.

Third, it will result in a big urban sprawl, that will deprive both Tonbridge and Southborough of their clear civic identity.

Fourth, as things are, there are huge pressures on local community amenities like schools, doctors, hospitals, railway system. What will the council do to develop the necessary back up infrastructure?

Finally, worse of all, the traffic congestion currently in this area is at its all-time high. Vauxhall lane has been turned into race track – as things are. The road links will make matters worse.

Worthy Counsellors, please think hard about this scheme. The scheme truly marks the death of common sense.

Its only merit – from community point of view - is to line the pockets of developers. There are a lot of open green field sites in the vicinity of Tonbridge. Why not go to a site which causes least disruption to the local community.  

The aesthetic beauty of the new development is on the wrong side of ZERO, while the day-to-day impact on the existing residents in the area will be enormous. 

DLP_4804

Liz Hatherell

Policy Number: STR/SO 1 The Strategy for Southborough

The strategy seems to be focussed on the urban areas of Southborough ignoring the fact that 66% of the parish is in the Green Belt and 64% is in the AONB. Paragraph 5.53 even says that all the allocations are “within the Main Urban Area”. This is incorrect. Both AL/SO 3 and AL/SO 4 are outside the Main Urban Area, and are on AONB/Green Belt sites (my comments on these site allocations are given below in comment boxes 2A and 2B)

I am also concerned that the only references to the Southborough Hub (AL/SO 1) are re:the housing (which is already built and for sale) and the Medical Centre. The promised state-of-the-art theatre (to replace the much-loved Royal Victoria Hall), replacement library, or community facilities have fallen by the wayside in what seems to have become an ill thought out and very expensive (to the residents) vanity project.

DLP_4809

Ann Norman

Over all, I think this is a very ill-conceived and unethical plan.  Southborough has already been swamped by newbuild homes, and the infra-structure is totally inadequate to cover any more development.

The A26 is a very much over-used road, partly due to the misleading signage on the A.21 leading to the slip road off, which states “Southborough and Tunbridge Wells” when it SHOULD actually state “Southborough and Tonbridge”.  The vast majority of the heavy traffic (articulated lorries and large delivery vans etc.) would be much better advised to continue on the A.21 and, if delivering to Tunbridge Wells or further, to take the A.264 further on.

Therefore, even more traffic (and the inevitable surge in private cars etc. that a new development would produce) would be the end result of this ill-advised plan, and life would become intolerable throughout Southborough.

I urge the developers to think again, try to put aside the thought of all monetary gains in order to consider their fellow human beings, and find an alternative site on which to place their profit-making development, obviously one which will impact very much less on the surroundings.

DLP_4847

Christopher Beach

Significant building on AONB and Green Belt land is completely unacceptable. I left London for Tunbridge Wells on the strength of its beautiful and historic countryside setting. To see development plans like this is utterly heartbreaking.

I hope these plans can be torn up.

DLP_4855
DLP_6459
DLP_7287
DLP_7773
DLP_7987

Liza Hall, HHRA
Elle Arscott, HHRA
Hangman's Hill Residents Association
Jacqueline Arscott, HHRA
Peter Evans, HHRA

TWBC: the following standard response was submitted by the list of Hangman’s Hill Residents Association (HHRA) members on the left:

Policy Number:  STR/SO 1 The Strategy for Southborough 

The Hangman’s Hill Residents Association (HHRA) represents those living on or close to the section of London Road, Southborough  (the A26) that is between Vauxhall Lane and Mabledon.  We aim to play an active role in localism and shaping the future of Southborough and are particularly concerned with protecting the countryside that lies between the urban areas of Southborough and Tonbridge.

We are concerned that the strategy pays little regard to the 66% of the parish that is in the Green Belt and the 64% that is in the AONB.  There is no reference to requirements in the NPPF to conserve and enhance landscape and scenic beauty in Areas of Outstanding Natural Beauty and the requirements re the objectives set out in the High Weald Management Plan are very weak.  There is no mention of enhancing biodiversity or actions to address climate change.  We also note that managing air quality is not part of the strategy for Southborough, despite the continuing poor air quality in the AQMA.

We are very surprised that the proposed hotel and leisure complex and the renovated Historic Park and Gardens at Mabledon House (AL/SO4) are not mentioned in the Strategy.  These are likely to generate a significant amount of new employment opportunities and stimulate tourism for the whole of the borough.

Paragraph 5.53 (Allocation Policies for Southborough) states that all the allocations are “within the Main Urban Area”. This is incorrect.  Both AL/SO 3 and AL/SO 4 are outside the Main Urban Area, and are on AONB/Green Belt sites.  We are not sure that the Council is aware of the actual locations of either of these sites (straddling the border with Tonbridge) as the policy also states that the LBD now includes AL/SO4 but this is not visible on the Southborough Policies Map and the map in the Limits to Built Development Topic Paper (28.1 RTW and Southborough LBD Boundary Amendments)only covers the area up to Vauxhall Lane, about a mile south of Mabledon House.

DLP_5281

Michael Claxton

I am a resident in south Tonbridge (Kings Road) and regularly walk to Tudely and its environs, enjoying its historic church, its isolated position and the delightful unspoiled countryside. I also cycle to Tudeley and beyond to Paddock Wood on the narrow roads on which I presently feel safe and untroubled by heavy dangerous traffic, free to appreciate the open views on both sides.

I also use the very narrow and twisting Vauxhall Lane on my bicycle or on foot and delight in the farmland and animal grazing areas on both sides, a few minute from where we live (which would be impacted badly by the Mabledon development).

Before moving to Tonbridge many years ago, we searched long and hard for a suitable location near the green belted land and the destruction of these areas would radically degrade our quality of life.

I am writing in addition to object to the strategy for the Mabledon area STR/AL/SO3-4

As mentioned in my introduction, the environmental impact of developing those areas is also very destructive and many of the same arguments apply. Please do not make these irreversible changes to the landscape so many in the area have enjoyed and benefited from for many generations.

DLP_6167

B. M. Broadbent

Policy Number:  STR/SO 1 The Strategy for Southborough

The Proposals for AL/SO 3 and 4 are outside the main urban area of Southborough and in the Green Belt and AONB. These areas should not be developed.

The proposed development AL/SO 3 requires significant improvement of infrastructure and is not costed. But it is unlikely that the cost could be recovered from the building of the small development proposed. Further development would be required and the Green Belt eroded.

The traffic load would not fall on Tunbridge Wells but on the congested streets of Tonbridge which are already virtually gridlocked at peak times and on the transport system and parking which is in short supply.

DLP_6241

Matthias Koslowski

Policy Number:  STR/SO 1 The Strategy for Southborough 

The proposal/Strategy mentions that all allocations are within the main urban area. This is untrue. About 2/3 of the area of Southborough (AL SO3/SO4) in on the Green Belt and/or an AONB.

The proposal does not give enough consideration to the provision of additional community facilities.

DLP_6329

Simon Byerley

Policy Number:  STR/SO 1 The Strategy for Southborough 

As a local resident to the proposed development I am concerned that the strategy pays little regard to the 66% of the parish that is in the Green Belt and the 64% that is in the AONB. There is no reference to requirements in the NPPF to conserve and enhance landscape and scenic beauty in Areas of Outstanding Natural Beauty and the requirements re: the objectives set out in the High Weald Management Plan are very weak. There is no mention of enhancing biodiversity or actions to address climate change. I also see that managing air quality is not part of the strategy for Southborough, despite the continuing poor air quality in the AQMA. There is also no mention of the role that Green Infrastructure pays in terms of developing an approach to managing our natural environment to deliver multifunctional benefits.

I am very surprised that the proposed hotel and leisure complex and the renovated Historic Park and Gardens at Mabledon House (AL/SO4) are not mentioned in the Strategy.  These are likely to generate a significant amount of new employment opportunities and stimulate tourism for the whole of the borough.

Paragraph 5.53 (Allocation Policies for Southborough) states that all the allocations are “within the Main Urban Area”. This is incorrect.  Both AL/SO 3 and AL/SO 4 are outside the Main Urban Area, and are on AONB/Green Belt sites.  I am not sure that the Council is aware of the actual locations of either of these sites (straddling the border with Tonbridge) as the policy also states that the LBD now includes AL/SO4 but this is not visible on the Southborough Policies Map and the map in the Limits to Built Development Topic Paper (28.1 RTW and Southborough LBD Boundary Amendments)only covers the area up to Vauxhall Lane, about a mile south of Mabledon House.

DLP_6359

Julia and Colin Stoward

Policy Number:  STR/SO 1 The Strategy for Southborough 

The strategy seems to be focussed on the urban areas of Southborough ignoring the fact that 66% of the parish is in the Green Belt and 64% is in the AONB.  Paragraph 5.53 even says that all the allocations are “within the Main Urban Area”. This is incorrect. Both AL/SO 3 and AL/SO 4 are outside the Main Urban Area, and are on AONB/Green Belt sites (my comments on these site allocations are given below in comment boxes 2A and 2B)

My family and I are so disappointed that the Southborough Hub has not been built.  The council were very keen to pull down the existing theatre where we loved to go to pantomimes, and watch our children participate in dance shows etc.  I would love to know what has happened to the money that was allocated to this! This was a community facility; please provide us with the facilities that local residence were promised when you sold off the land for yet more housing!

DLP_6367

Ms Margaret Borland

Policy Number:  STR/SO 1 The Strategy for Southborough 

This is a strategy for the Main Urban Area of Southborough,  not for the Parish of Southborough, of which 66% is in the Green Belt and 64% is in the AONB.  Paragraph 5.53 even says that all the allocations are “within the Main Urban Area”, ignoring AL/SO3 Land at Mabledon and Nightingale and AL/SO/4 Land at Mabledon House. Both of these are on AONB/Green Belt sites at the very northern end of the parish, straddling the border with the borough of Tonbridge and Malling.  They are some distance from the current Limits to Built development so it is unclear how the LBD will be extended to encompass developments here.

The proposed hotel and leisure complex and the renovated Historic Park and Gardens at Mabledon House (AL/SO4) is not mentioned in the Strategy despite the fact this has the potential to save a valuable heritage asset that is already in need of significant renovation, to generate new employment opportunities for Southborough and to stimulate tourism for the whole of the Borough.

The cultural aspects of development in Southborough are ignored.  The Southborough Hub (AL/SO1)  provides housing (which is already built and for sale) and a replacement Medical Centre, but there’s no mention of the theatre space to replace the much-loved Royal Victoria Hall, a replacement library, or other community facilities. Surely these are of importance to maintain Southborough as a thriving community and not simply a suburb of Royal Tunbridge Wells?

There is also no mention in this Strategy of the existing traffic congestion on the A26 which will only be exacerbated by the proposed developments.  The associated poor air quality both within the AQMA and along the whole length of the A26 in Southborough through to Tonbridge is a major health hazard and a disincentive to active travel. Who would chose to walk their children to school or wait at the side of the road for a bus when it means breathing poisonous traffic fumes? I know it is a difficult problem due to lack of road widths and there are some limited measures proposed in the Transport Evidence Base that may ease congestion a little, but how dispiriting the Strategy doesn’t include a commitment to pro-actively investigate and propose additional innovative solutions to this long-standing and critical issue.

DLP_6380

Shirley Whiteley

Hello im sending this in disagreement to further homes being built on yet more of our greenbelt land, this seems to be a trend at present where developers and councils just feel its ok to continually build new homes on our green land, without enough infrastructure to support this, where will this end? The hospitals are over flowing, gp cannot cope, schools etc, you cannot build homes without money into the nhs and other services!!!!!!!, let alone our beautiful green land which is slowly getting smaller, the whole of our countryside will end looking like London, concrete jungle, with escalated crime anti-social behaviour, pretty sure its more about money and profit than anything else, especially where developers are concerned, as with the government, giving away our greenbelt !!, this is disgraceful to be honest, if we as individuals apply to buy a small piece of land to live on, its near on impossible, yet its very easy to approve hundreds and thousands of homes if suits!, its about time this country listened to the voters and people, NO more homes on greenbelt, NO further immigration, which is partly to blame for the stress on housing and services, we cannot house everyone , every other countrys or our own, I am one of thousand s that have had enough of not being listened to and concerns and common sense!

DLP_6388

Pam Hudson

Objection to the above.

What is happening to Protection of rural England Green Belt land - when the Southborough Council are giving permission for this to be further developed?

The whole area between the A26 and A21 will be adversely affected.

The volume of traffic on the A26 is already saturated and access to and from Vauxhall Lane dangerous and almost impossible.  Who is monitoring road safety, air quality and the affect on the health of current residents?

DLP_7409

Byerley Ltd

Object

As a local resident to the proposed development I am concerned that the strategy pays little regard to the 66% of the parish that is in the Green Belt and the 64% that is in the AONB. There is no reference to requirements in the NPPF to conserve and enhance landscape and scenic beauty in Areas of Outstanding Natural Beauty and the requirements re the objectives set out in the High Weald Management Plan are very weak.  There is no mention of enhancing biodiversity or actions to address climate change.  We also note that managing air quality is not part of the strategy for Southborough, despite the continuing poor air quality in the AQMA. There is also no mention of the role that Green pays in terms of developing a multifunctional approach to managing our natural environment and delivering multifunctional benefits.

We are very surprised that the proposed hotel and leisure complex and the renovated Historic Park and Gardens at Mabledon House (AL/SO4) are not mentioned in the Strategy.  These are likely to generate a significant amount of new employment opportunities and stimulate tourism for the whole of the borough.

Paragraph 5.53 (Allocation Policies for Southborough) states that all the allocations are “within the Main Urban Area”. This is incorrect.  Both AL/SO 3 and AL/SO 4 are outside the Main Urban Area, and are on AONB/Green Belt sites.  We are not sure that the Council is aware of the actual locations of either of these sites (straddling the border with Tonbridge) as the policy also states that the LBD now includes AL/SO4 but this is not visible on the Southborough Policies Map and the map in the Limits to Built Development Topic Paper (28.1 RTW and Southborough LBD Boundary Amendments)only covers the area up to Vauxhall Lane, about a mile south of Mabledon House.

DLP_7523

Leah

I am  a 10 year old girl who has recently moved to the area of Southborough. Myself, sister and Dad really love it here.

But we were very unhappy to hear that there may be a lot of new buildings in the area around near house. Please do not destroy the lovely land that surrounds my house. The family of deer, stoats, owls, badgers and foxes we see around here have a right to live in these woods too. I love playing in the woods and fields with my sister and neighbours, and my dad and I make forts and tree houses in the old oak trees.

It makes me very sad to hear that this may soon be all gone. Where will all the animals move to? I know people need a place to live too, but are there any other spaces that don’t have as many animals where you can build houses?

The road we live on is very busy and noisy, if we get more cars it will make it worse and very difficult for us to get in and out of our house. My dad doesn’t like going into Tunbridge Wells as there is too much traffic already, but we love going to the shopping centre and Creams for ice-cream. If there more cars are on London Road, I am afraid he will never go there.

My younger sister also has asthma, this would not be good for her as the dirty air will make it worse. I really am worried for her.

I am hoping to go to Tunbridge Wells Grammar next year and really look forward to riding my bike there, but if the traffic get worse no way will my dad let me as it will be too dangerous. It’s really dangerous already with big trucks and cars shooting along.

Please don’t destroy this area, we really really love it here

DLP_7897

Enplan for Mabledon Services Ltd

Support

Mabledon Services Ltd (MSL) are promoting the development of a hotel at Mabledon House. The Draft Local Plan includes draft Policy AL/SO 4 which proposes to allocate this site for a 200-bedroom hotel subject to various requirements located within the High Weald AONB. The house and grounds of Mabledon comprise together a nationally significant heritage asset and one that is closely associated and particularly important to Tunbridge Wells. The house has been in continuous sole residential use since the early 1990s, but it is considered that this is no longer tenable given the ongoing need for repair, restoration and modernisation required.

Whilst proposals for the hotel are at an early stage, they will include for the restoration and redevelopment of the Grade II Listed house together with the development of a new bedroom and services wing, linked to the main house. There are several relatively contemporary buildings that adversely affect the setting of the listed house and Grade II Registered Park & Garden. These will be removed. The Gardener’s Cottage, walled garden, the Quarry Garden, the various terraces to the west and north of the house, as well as the remaining gardens and wider parkland, will all be restored.

MSL supports Draft Policy STR/SO 1: The Strategy for Southborough. In respect of Part 4 of the Policy, MSL is committed to ensuring that forthcoming proposals will make a positive contribution towards achieving the objectives of the AONB Management Plan and guidance from the AONB Joint Advisory Committee, as well as the high standards required by other policies within the Plan for the AONB.

The AONB Management Plan 2019-2024 defines five components of the character of the High Weald, plus what is referred to as Other Qualities, and in each case sets a number of management objectives to retain and enhance these. MSL considers that the proposals will not adversely affect any of these objectives and will positively complement Objective S3 – To enhance the architectural quality of the High Weald and ensure development reflects the character of the High Weald in its scale, layout and design and Objective OQ3 -  To develop and manage access to maximise opportunities for everyone to enjoy, appreciate and understand the character of the AONB while conserving its natural beauty. 

DLP_8027

Hangman's Hill Residents Association

Object

The Hangman’s Hill Residents Association (HHRA) represents households living on or close to the section of London Road, Southborough (the A26) that is between Vauxhall Lane and Mabledon. As of 14 November 2019, HHRA has approximately 100 households – signed up as members or supporters. We aim to play an active role in localism, the community and shaping the future of Southborough and are particularly concerned with protecting the countryside that lies between the urban areas of Southborough and Tonbridge.

The strategy pays little regard to the 66% of the parish that is in the Green Belt and the 64% that is in the Area of Outstanding Natural Beauty (AONB). There is no reference to requirements stated in the NPPF to conserve and enhance landscape and scenic beauty in the AONB and the requirements re the objectives set out in the High Weald Management Plan are very weak.

Equally, there is no mention of enhancing biodiversity or proactively addressing climate change. We also note that managing air quality is not part of the strategy for Southborough, despite the continuing poor air quality in the AQMA.

The proposed hotel and leisure complex and the renovated Historic Park and Gardens at Mabledon House (AL/SO4) are not mentioned in the Strategy. These are likely to generate new employment opportunities and stimulate tourism for the whole of the Borough.

Paragraph 5.53 (Allocation Policies for Southborough) states that all the allocations are “within the Main Urban Area”. This is incorrect. Both AL/SO 3 and AL/SO 4 are outside the Main Urban Area, and are on AONB/Green Belt sites and straddle the border with Tonbridge. The policy states that the LBD now includes AL/SO4 but this is not visible on the Southborough Policies Map, nor the map in the Limits to Built Development Topic Paper (28.1 RTW and Southborough LBD Boundary Amendments) - this only covers the area up to Vauxhall Lane, about a mile south of Mabledon House.

DLP_8047

Robinson Escott Planning for Decimus (Paddock Wood) Ltd

My client submits land for consideration as a site (which has not already been submitted in previous “calls for sites”).

The land is at Baldwin’s Lane, North Fram Road Tunbridge Wells TN2 3DH - The Brickworks. I attach a red line plan to this proforma.

The land is 1.79ha in size and comprises poor quality and low employment generating commercial space. It is situated within the urban confines of Southborough, in a sustainable location close to High Brooms Train Station.

Initial concept master plans of the site confirm that the yield of the site could be up to 216 residential dwellings as well as 14,531sqft of commercial space.

The site is not situated in the Green Belt or in any landscape designation (AONB). The site is located in Flood Zone 1.

It is confirmed that the site is available, deliverable, achievable and suitable for development within the Local Plan period.

DLP_8180

Highways England

Location:

No/Type:

Distance to SRN:

Impact:

Current traffic flows:

Recommendations

Southborough

Approx 50-120 dwellings on allocated sites, plus 85 which already have planning permission.

The Southborough Hub, a mixed used scheme to include approximately 69 residential dwellings, and including retail units, flexible community floor space, including for assembly and leisure uses, Town Council Offices, medical centre, new sports pavilion with ground maintenance store and workshop, and extension to the existing Yew Tree Road public car park.

New, retail floorspace should enhance and diversify provision within Southborough, provided it is of an appropriate scale and will not have a significant adverse impact on the town.

Any residential uses fronting onto London Road shall be located above ground floor.

This site already has planning permission. Development is currently under construction

3km

A21/A26 or via Longfield Road/ A21 Bypass/

>15km

M26/M25-J5

Significant; any development along this route will need mitigation on the local network as traffic is already operating at higher levels during peak hours directly into Tonbridge (south).

Potential to provide railway station as on direct line to Tonbridge from High Brooms.

Operating between normal flows and slightly higher than normal for both AM and PM respectively.

Transport Assessment likely for this area given the relationship to the A21 and Royal Tunbridge Wells.

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

Mabledon

Approximately 300 dwellings, between 2 sites

· Additional facility for hotel with 200 rooms

<1km

A21/ A26

Adjacent to the A21/A26 junction. Will need to demonstrate that additional movements can be accommodated.

Current traffic flows indicated higher than normal movement in the AM peak period, but normal levels during the PM peak.

Safe and direct access will be provided from the A26.  Full capacity modelling would be required for the junction given its proximity.

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

Policy AL/SO 1: Southborough Hub, London Road

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_2061

Terry Everest

Object

Object

Arguing for a reduction or stop to any further development than has already been completed here other than that of the hub building on London Road itself.

The green space has already been encroached upon and reduced.

DLP_3246

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 development shall incorporate a segregated cycle route between The Ridgewaye and the A26 London Road at which point a toucan crossing shall be implemented by the developer.

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

KCC notes that the policy does not feature “Proposals must be accompanied by a Transport Assessment”. Either all large sites should state this, or none of them (in which case it would be taken for granted that a Transport Assessment is required).

Heritage Conservation

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

Very high potential for Mesolithic and Neolithic remains. Also potential for post medieval remains associated with Bell Inn PH identifiable of 1st Ed OS map. Predetermination Archaeological DBA is required.

DLP_3602

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Southborough. 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 69 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/SO 1

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 Southborough. 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/SO 1

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

DLP_5870

Ms Sally Moesgaard-Kjeldsen

Object

I am against this building proposal. Southborough is a small village which already jam packed with vehicles, it can take 1 hoursto drive through the village at times

We have huge lorries driving through our village which are far to large and our roads are awful and full of pot holes.

The hub has is being built together with a number of flats, we had a lovely village hall which was well attended, why has that not been replaced.

Whats more to the point we also have flowers and animals living in the area, some of which are becoming extinct

DLP_6440

Mr Des Joyner

Object

I am writing to add my concerns and objections to your Strategic Housing Development for the Borough of Tunbridge Wells and specifically for Southborough up to the A26/A21 junction ( STR/SO 3 )

--- You state all the allocations are " within the Main Urban Areas " -- yet Southborough Parish is 2/3rds Green Belt and nearly 2/3rds is an Area of Outstanding Natural Beauty. Both AL/SO 3 and AL/SO 4are outside the Main Urban Area.

--- Also for the Southborough Hub you have taken a major chunk of the Park behind. The flats are going up -- How well are the sales going, what's happening to the development of the hub/the medical centre and is there any plans to replace what was a wonderful and much loved all be it small  theatre Royal Victoria.

--- I strongly object to the proposed development ( AL/SO 3 ) of 50-- 120 residential dwellings on land at Mabledon and Nightingale.

--- this is not a main urban area but within an AONB.

--- I assume access is via the A26 -- a road that is already unable to cope with the high level of traffic from bicycles to major tonnage lorries. its time consuming to join and leave. High levels of pollution, difficult and dangerous to cross. Poorly maintained and many potholes.

--- Adding in excess of 400 new people and over 200 cars will just add to the previous point.

--- The doctors surgery is already struggling to cope with the current level of patients.

--- will Utilities be able to cope

--- will schools cope.

---  what impact will this proposed build have on the environment, the woodland and wildlife. Is not that part of  our responsibility of us adults to protect our environment, wildlife and woodland for future generations. Only today a report was published stating that we have lost 50% of insects --- this impacts animals further up the food chain like birds , hedgehogs, badgers, foxes etc. Although its fair to say these plans will destroy their habitat.

DLP_8288

NHS West Clinical Commissioning Group

General Observation

The build for the medical centre that forms part of the Southborough hub (as a re-location for St Andrews Medical Centre) has commenced. This development provides capacity for population growth.

Policy AL/SO 2: Speldhurst Road former allotments (land between Bright Ridge and Speldhurst Road)

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_463

Paul Bartlett

Support with conditions

Policy AL/SO 2

1. Vehicular access

Given the excessive number of private vehicles in the local area such that parking in local roads restricts just one carriageway to be available for use this site must have no impact whatsoever on the free passage of vehicles on the Speldhurst Road. At present the parked vehicles on the right side of this site are often causing a restriction which should be addressed as a planning improvement within this site application. Widening the Speldhurst Road could address that with minimal impact on the site area. That is, maintaining the two carriageway width, not more, as it is currently a pinch-point and not safe in some conditions; flood, snow, ice.

DLP_2062

Terry Everest

Object

Object

These former allotments should be turned into a local wildlife refuge or community allotment or green space.

DLP_3248

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

Paragraph 1 – “Vehicular access from Bright Ridge”

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

Heritage Conservation

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

DLP_2916

Chris Gow

Object

The loss of allotments, and any land available for cultivation, is a profound loss.

Additional local food production however small the scale of provision should be encouraged, and land preserved for this purpose.

DLP_2917

Chris Gow

Object

I object to this development.

The loss of allotments, and any land available for cultivation, is a profound loss.

Additional local food production however small the scale of provision should be encouraged, and land preserved for this purpose.

The threats of climate change should make us alert to the problems of food supply, and provision of local areas of land for cultivation should be made available.

Policy AL/SO3: Land at Mabledon and Nightingale

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1541

Tonbridge & Malling Borough Council

Support with conditions

Although these are smaller proposals that do not require master planning in the way that the larger allocations at Tudeley, Capel and Paddock Wood do, the policy acknowledges that the implementation of the Mabledon House proposal will depend on the agreement of TMBC. It notes that:

“The main house is located within the borough of Tunbridge Wells and the ancillary buildings are located in the borough of Tonbridge & Malling; the Historic Park and Garden is split between the two boroughs. The above policy to be agreed with Tonbridge & Malling Borough Council to encourage a holistic and comprehensive approach to development proposals across the whole of the estate.”

TMBC welcomes the opportunity to discuss the proposed site allocation at Mabledon House with Tunbridge Wells Borough Council within the context of the emerging Local Plan, subject to a better understanding of the scale and form of the development, particularly in respect of that part of the site within Tonbridge and Malling, the very special circumstances for the development within the Metropolitan Green Belt and the impacts on High Weald AONB and its setting.

DLP_1573

Mr John Hurst

Object

Green Belt - do not develop. Would start to form a conurbation with Tonbridge.

DLP_1642

Tom Tugendhat MP

 

AL/SO 3 and AL/SO 4 - Land at Mabledon and Nightingale, and Land at Mabledon House

I feel that this should be the first site that I comment on, as the boundary of development is right up to, and including, land in Tonbridge and Malling. There are a handful of dwellings south of the A21 which fall in Tonbridge and Malling and residents there are understandably concerned about the impact of this allocation.

It is good that TWBC recognise the cross-boundary issues and accept that they will need agreement with TMBC as the local planning authority here to ensure that this site goes ahead. You will have noted from TMBC's robust response to this consultation that they have their concerns about this allocation, specifically with the outbuildings falling over the borough boundary. I would like to re-emphasise this point and make clear that no development should proceed without TMBC being fully on board with its proposals.

I am particularly intrigues by requirement 8c in the draft allocation at AL/SO 3 on this site because it states that 'Community Facilities' should be provided on this site. I would be extremely keen to learn what facilities TWBC thinks would be appropriate here? As the site falls closer to the town of Tonbridge than the town of Tunbridge Wells I am extremely keen that any facilities compliment those that are already available in Tonbridge for local residents.

[see also full response - Comment Number DLP_1577].

DLP_2065

Terry Everest

Object

Strongly Object

Farmland is not the same as building land.

Farmland retains much of the character, naturalness and intrinsic appeal of the countryside and should not be developed simple as it is easier to secure the change of use. The size of this is too big but it also represents built environment where it should not go into the countryside so cannot be supported at all.

DLP_2256
DLP_5816

Anya Wood
Brian Wood

Object

Two responders submitted the standard response with the following slight variation:

I write to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);

ii) where the housing, roads and other buildings are going to be located; and

iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

The map in the SHELAA (Site 445) shows that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and it crosses Vauxhall Lane in the south. This is a very large area – 171 hectares. Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

It is a concern that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It is also difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups.

There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is an important area of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

Allowing development on the Green Belt sets a dangerous precedent, and TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas).

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. This proposed allocation for a major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and

* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_2466

Miss Helen Tebay

Object

AL SO 3, Mabledon and Nightingale site 445

This is AONB, green belt for a reason. It is a beautiful stretch of land, full of wildlife and stunning views. The A26 is a known traffic bottleneck at all busy times every day of the week and weekends. I use it every day. I live off this road. The pollution levels along the A26 are some of the worst in the country. We had notification that parts of it are an area in need of action, with very poor air. This development would bring a huge increase in traffic. It will bring more people without having the infrastructure of schools, GPs, dentists, hospitals, roads, rubbish collections. All these services are currently creaking at best, failing at times. The area is also very green. We simply cannot afford to lose all those trees. The number of trees chopped down for the widening of the A21 and North Farm housing estates was a huge loss and will also have impacted on air quality. We cannot afford to keep concretising green space. Please consider traffic, infrastructure, the environment, pollution, beauty, and local people’s views and our health.

DLP_1993
DLP_2482
DLP_2503
DLP_2974
DLP_3008
DLP_3408
DLP_3413
DLP_3742
DLP_3746
DLP_3751
DLP_4062
DLP_4089
DLP_4345
DLP_4348
DLP_4402
DLP_4415
DLP_4419
DLP_4428
DLP_4520
DLP_4537
DLP_4551
DLP_4576
DLP_4708
DLP_4711
DLP_4721
DLP_4738
DLP_4743
DLP_4747
DLP_4748
DLP_4753
DLP_4758
DLP_4764
DLP_4772
DLP_4792
DLP_4799
DLP_4803
DLP_4806
DLP_4811
DLP_4823
DLP_4831
DLP_4834
DLP_4837
DLP_4840
DLP_4844
DLP_4850
DLP_4976
DLP_5143
DLP_5861
DLP_5866
DLP_5875
DLP_5895
DLP_5901
DLP_5994
DLP_6083
DLP_6102
DLP_6245
DLP_6341
DLP_6358
DLP_6384
DLP_6396

Mrs Lisa Dunnett
Janet Trayner
Brian Austen
Tim Boden
Elspeth Penny
Branislav Trajkovski
Terry Brisefer
Marion Harris
James Dunnett
Anthony Harris
Sophia Spickett
Jayne Windle
Sara Vincent
Christopher Van't Hoff
Teresa Ann Van't Hoff
Freddie Van't Hoff
Hannah Van't Hoff
Katie Van't Hoff
Mary Greenwood
Eric & Fiona Watkins
Bryan Greenwood
Lynn Green
Patrick North
Mark Weavis
Christina Sharpe
Kevin Kirby
Corrine Kirby
Cook Clancy and Co
Izzie Miller
Gillian Curphy
Patrick North
Susan Tanner
Stephen Traveller
Amin H Rajan
Gail Armstrong
Paul Smith
Liz Hatherell
Ann Norman
Tracey Gadd
Stuart Taylor
Elizabeth Dowling
Mark Windle
Alastair Dale
Christopher Beach
Maija Wilson (HHRA*)
Rachel Waller
Mark Weller
Liz Wallace
Andrew Wallace
Sally Moesgaard-Kjeldsen
Sylvia Bourne-Moore
Tim Elliott
Pamela Barnes
John Stephen Barnes
David & Jennifer Heyes
Claire Penney
Chloe Daniels
Brian Waters
Keith Hardwick
Marji Whale

Object

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

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the 'extended settlement' will entail (e.g. a village, a hamlet or around several farmsteads);

ii) where the housing, roads and other buildings are going to be located; and

iii) the size i.e. the extent of the development

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built one. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that "small scattered forms of development" (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area - 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed - maybe even thousands of houses. The only constraint in the Policy is that the housing development will "not exceed 120 dwellings during this plan period" (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide "safe and acceptable access arrangements from the A26" (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is - an access road from Mabledone Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by givings periods of priority to vehicles leaving/joining the A26.

It's even more difficult to imagine how "safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge" will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic - not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC's own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App.A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an 'exemplar scheme', without providing an explanation of why it is considered to be 'exemplar' and what are the "unique circumstances" that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWB's own Supporting Documents conclude that development here would be harmful, including:

  • the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
  • the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity 

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It's an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_2511

Mr Guy Dagger

Object

Major development is not appropriate in the AONB. TWBC have accepted that Mabledon and Nightingale is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met.

The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.

DLP_2594

Richard Bysouth

Object

Policy AL/SO 3:

I object to this development on several grounds:

1) It is located in a key section of Green Belt and an AONB between Southborough and Tonbridge. Building 50-120 dwellings here will set a precedent for future development. Eventually this would result in continuous built-on land between Southborough and Tonbridge. Once undeveloped land is gone, it's gone forever.

2) Increased traffic on the A26. This is already over capacity. More pollution will result.

3) Point 7 "may not exceed 120 dwellings during this plan period" suggests that there would of course be future development.

DLP_2603

Peter Clement

Object

Policy AL/SO 3

I object to the proposed development of the land at Mabledon and Nightingale on the basis that it will have an unacceptable impact on the AONB at this location. The scale of the development here will lead to unacceptable loss of green belt, despite the contention in the Plan that this site's designation as Green Belt can be retained after development. In this regard, I believe the proposed Plan is misleadingly as it is not fully counting the true loss of green belt in the Borough.

I also object on the basis that this prooposed development will lead to a joining up of the urban areas of Southborough and Tonbridge into an 'urban sprawl', removing very valuable green spaces between these two places, that serve to protect the local natural environment and character of the area.

The proposed development at Mabledon and Nighigale will also place an additional, unsustainable burden on the local road infrastructure, which is already strained at peak times.

The proposed mitigation measures are too remote from the site of development to be reasonable, or appropriate mitigations.

I would support removal of the proposed development of Mabledon and Nightingale from the updated Plan, in favour of 'infill' development within the existing urban envelopes, to concentrate development in existing urban areas, so as to retain the extent of surrounding rural areas and, hence, the character of the Borough.

DLP_2631

Mr Alistair Beeston

Object

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the 'extended settlement' will entail (e.g. a village, a hamlet or around several farmsteads);

ii) where the housing, roads and other buildings are going to be located; and

iii) the size i.e. the extent of the development

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built one. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that "small scattered forms of development" (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area - 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed - maybe even thousands of houses. The only constraint in the Policy is that the housing development will "not exceed 120 dwellings during this plan period" (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide "safe and acceptable access arrangements from the A26" (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is - an access road from Mabledone Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by givings periods of priority to vehicles leaving/joining the A26.

It's even more difficult to imagine how "safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge" will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic - not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC's own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App.A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an 'exemplar scheme', without providing an explanation of why it is considered to be 'exemplar' and what are the "unique circumstances" that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWB's own Supporting Documents conclude that development here would be harmful, including:

  • the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
  • the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity 

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It's an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

Personal Comment

I have been privileged to live in this beautiful valley for approaching 40 years during which it has changed little from its previous 40 and probably earlier apart from its inadequate roadways. In the same way that climate activists argue to sustain the environment for future generations we all have the same responsibility to protect our landscape from injudicious and unwelcome development when other options exist. Housebuilding on the scale proposed would indicate a willingness to accept more speculative development and result in the spoiling of this natural valley.

For all of the reasons detailed above I submit my strong objections. 

DLP_2775

Mr Peter Tavner

Object

This is a very large site within the AONB. However there is no detail provided as to precisely where the proposed development might take place on the site. Without further specific information as to the exact location or footprint of the development it is impossible to form a view.

The potential scale of the development footprint means this policy is likely to constitute major development. The NPPF only allows major AONB development in exceptional circumstances. These circumstances are not provided nor is an "assessment of meeting the need in some other way" (ie outside of the AONB) provided.

DLP_2949

Priya Enefer

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

  • what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);
  • where the housing, roads and other buildings are going to be located; and
  • the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion, which is already unacceptable, and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26. My son already has breathing problems. Increased congestion on this road, which this development will no doubt create, with exacerbate this problem and impact on his quality of life.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. I already use the A26 to cycle to work and it is already unsafe. Additinal congestion will exacerbate this problem.

There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge and as such was a key part of the decision for us to relocate here as a family. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

  • the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
  • the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. I use them daily going to London anytime between 0615 and 0900 and returning anytime from 4pm-9pm and the situation is the same every single day - massive overcrowding and deeply unpleasant commuting conditions. This development will further add to the overcrowding on the trains.

DLP_2996

Michael Lee

Object

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the 'extended settlement' will entail (e.g. a village, a hamlet or around several farmsteads);

ii) where the housing, roads and other buildings are going to be located; and

iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that "small scattered forms of development" (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area - 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to take advantage in the future from a much larger housing development than is currently proposed - maybe even thousands of houses. The only constraint in the Policy is that housing development will "not exceed 120 dwellings during this plan period" (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 - Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues. I can smell the petrol fumes on a summer's day.

This is already such a busy road that it will be almost impossible to provide "safe and acceptable access arrangements from the A26" (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is - an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26 and appalling road surface; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Aera of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It's even more difficult to imagine how "safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge" will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. Cyclists invariably use footpath. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups.There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic - not safe for anyone, but especially dangerous for the elderly or those with young children. Fatal accident happened nearby.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC's own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and

* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of only relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat. There is a rising consciousness, both socially and politically, that we must "save the planet" at all costs. The constant desire on the part of local authorities and developers to put up houses 'willy nilly' is directly opposing that growing ethos.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces. PLEASE, THINK of future generations!

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_3026

Jacqueline Prance

Object

Site on AONB & GREEN BELT and access onto extremely busy roads

DLP_3252

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 – “Provision of safe and acceptable access arrangements from the A26 for the proposed development with, where required, a secondary/emergency access”

Paragraph 2 – “Provision of safe and accessible pedestrian and cycle linkages including crossing points to Southborough and Tonbridge (see Policy TP 2: Transport Design and Accessibility)”

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

Heritage Conservation

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

DLP_3421

High Weald AONB Unit

Object

Major development is not appropriate in the AONB.

Paragraph 172 (NPPF) requires great weight to be given to the AONB and says “Planning permission should be refused for major development55 [in these areas] other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:

d) 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;

e) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and

f) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated”.

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

Major development of this scale is not appropriate in an AONB. The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan adopted by TWBC in March 2019. Objective S2 of the Management Plan sets a proposed action - ‘Seek to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’ – which is intended to help conserve the small scale nature of the AONB landscape which has been created by people by hand, and has changed very little in 700 years. As the draft Local Plan policy EN21 states, the High Weald AONB ‘is considered one of the best surviving Medieval landscapes in Northern Europe’.

Justification for allocating this site includes the claim that the site offers opportunity to develop an ‘exemplar scheme inspired by the underlying historical evolution of the High Weald’ (Local Plan, Para 5.56). The statement is provided as a reason for allocating Site 445 in the SHELAA, and as a justifier for major development on this site in the Distribution of Development Topic Paper (Appendix 3), but no explanation is given as why this statement should be uniquely applied to this site. This statement, exhorting development to be inspired by and reflect the distinctive character of this nationally important landscape, is pertinent to all proposed development in the AONB and should be applied as a matter of course not as a justification for development. DDTP Appendix 3 goes on to claim that development at this site ‘could offer substantial AONB benefits’. What are these?

At the core of this site lies a historic farmstead, Mabledon. The dispersed settlement pattern formed by the high density of historic farmsteads in the High Weald is a core component of the landscape’s distinctive character and beauty for which it is nationally designated. Farms in the High Weald tend to be relatively small and are surrounded by their own fields which typically separate farmsteads from neighbouring farms and the villages or towns which served them. This medieval dispersed settlement landscape pattern distinguishes the High Weald. Development of 120 dwellings at Mabledon, a farmstead site, will materially change its character and relationship with surrounding settlement.

Mabledon and Nightingale form a narrow green gap between the large settlements of Tonbridge and Southborough/ Tunbridge Wells. This green gap is protected as AONB and retains the core components of it character and beauty, as confirmed by the site Assessment (SHELAA), and AONB major sites assessment (DDTP, Appendix 3). Major development in this narrow green gap between major settlements will substantially alter its rural character and compromise achievement of AONB management objectives. It is also likely to lead to coalescence between these two major towns, both in itself and through the precedent it will create for development within this gap.

Access to the site would presumably be either from London Road or Vauxhall Lane. The latter is a narrow rural lane with no pavements which follows the ridgeline around the south and east of the site. Any ‘improvements’ to this road to facilitate access would be severely detrimental to the character and features of this historic routeway.

We object to this allocation and dispute the claim that development on this historic farmstead set in a rural location will offer ‘substantial AONB benefits’. 

DLP_3432

Sally Marsh

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingdale

Major development is not appropriate in the AONB. TWBC have accepted that Mabledon and Nightingale is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met.

The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.

Justification for allocating this site includes the claim that the site offers opportunity to develop an ‘exemplar scheme inspired by the underlying historical evolution of the High Weald’ (Local Plan, Para 5.56). The statement is provided as a reason for allocating Site 445 in the SHELAA, and as a justifier for major development on this site in the Distribution of Development Topic Paper (Appendix 3), but no explanation is given as why this statement should be uniquely applied to this site. This statement, exulting development to be inspired by and reflect the distinctive character of this nationally important landscape, is pertinent to all proposed development in the AONB and should be applied as a matter of course not as a justification for development. DDTP Appendix 3 goes on to claim that development at this site ‘could offer substantial AONB benefits’. What are these?

At the core of this site lies the historic farmstead, Mabledon. The dispersed settlement pattern formed by the high density of historic farmsteads in the High Weald is a core component of the landscape’s distinctive character and beauty for which it is nationally designated. Farms in the High Weald tend to be relatively small consisting of a farmhouse, multipurpose barn, cattle housing and perhaps an oast. They are surrounded by their own fields which typically separate farmsteads from neighbouring farms and the villages or towns which served them. This medieval dispersed settlement landscape pattern distinguishes the High Weald and development at this scale - 120 dwellings within one farmstead - will materially change this character.

Mabledon and Nightingale form a narrow green gap between the large settlements of Tonbridge and Southgborough/ Tunbridge Wells. This green gap is protected as AONB and retains the core components of it character and beauty, as confirmed by the site Assessment (SHELAA), and AONB major sites assessment (DDTP, Appendix 3). Major development in this narrow green gap between major settlements will substantially alter its rural character and compromise achievement of AONB management objectives.

DLP_3814

Ms Sally Moesgaard-Kjeldsen

Object

I'm sorry but as usual you have asked me to do something which the website will not let me do.

I am so frustrated.

Here is an email confirming that I am dead against the building of all these houses.

If this takes place we will have a 'city' on our hands.

Use your brains and thinks of what will happen if you build here, we have almost extinct flowers and animals in this field.

I cannot believe that so called 'intelligent' people will even think about building on this land

What about Crowborough

DLP_3831

Government Team
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_4054

Southborough Society

Object

Section 5.56 

‘Making strong and positive contributions to the objectives of the AONB Management Plan’ suggests not all of these objectives will be fulfilled and risks falling short of what the plan sets out to do.

The Southborough Society opposes any designated AONB to be developed for any reason. We believe these green spaces are precious and finite and thus they need to be protected and cherished. The Borough needs to find alternative sites to provide housing without making incursions into the greenbelt or adding to the already unsustainable levels of traffic on the A26.

In July 2019, TWBC  declared a ‘climate emergency’; providing a number of electric car charging points and limiting single use plastics at the Town Hall will go nowhere near compensating for the significant addition of traffic that will come from residents in the proposed dwellings. It is entirely feasible that this development could put another 200 plus cars on the road in our locality. This, bearing in mind that the stretch of A26 frequently exceeds the WHO limits for pollution according to from data collected at the St John’s site.

In order to maintain the appearance of green space along this stretch of road, the dwellings are to be located away from the main road which will encourage residents to use their cars. There are no assurances that these homes will be served by public transport. Currently, the bus services are extremely expensive – in many instances it can be cheaper to travel by taxi locally. Cycling on the A26 is dangerous. There is no designated cycle path and KCC have not supported previous requests from the Joint Transportation Board to reduce the traffic speed.

Section: 5.57 

Residents would always welcome build quality to the highest standards but this is extremely unlikely to meet the stated objective of providing affordable housing.

There appears to be no masterplanning with regards to traffic – this is one of the busiest A roads in the area and is notorious for traffic congestion. As more housing comes on line from the Southborough Hub site and the former Speldhurst Allotment site it makes no sense to consider separately each planning application in isolation from one another.

DLP_4079

Sean Mullins

Object

I unequivocally object to the development of this land. Reasons are detailed as such in the document, but to summarise:

  1. Details of the development are very vague and ambiguous. Why such a large area is need for up to 120 houses?
  2. Where precisely will this development be in this area?
  3. This is an AONB and Green belt area, designated as such to stop urban crawl. Any further development here will take away the last green space between Tunbridge Wells and Tonbridge, divided only by a motorway. A coalescing of towns will lead to one of the biggest urban areas in the south east outside of London
  4. This area is rich in natural flora and fauna, including ancient woods, ancient oak trees and families of deer, stoats, hedgehogs, foxes, badgers, owls and woodpeckers. Such beautiful landscape is what makes TW so picturesque and what brings tourists, shoppers and visitors from all over the south east and the UK.
  5. The A26 cannot take anymore traffic. In peak times it is at a standstill and on weekends the same. This is having a diverse effect on visitors to shops and businesses within the TW town centre, which is already under pressure from less footfall due to residents not wanting to face blocked roads to get into town. In off-peak times it is dangerous, with most vehicles not abiding to the speed limit. I live with my two young daughters who walk and ride to school along this road.
  6. Finally and most importantly for me - my daughter suffers from asthma, which is controllable at the moment. The air pollution along the A26 is already at dangerous levels. More cars will add to what is already a health concern for all that live along the road.  I fear my daughters health will take a turn for the worse and our ability to keep her condition in check and her developing concerning chronic breathing problems.

I trust you understand our concerns and are willing to review the development in detail and consider not to grant planning permission. This is such a beautiful borough, made up of people that care for their surroundings, these green spaces is what makes TW so unique. Please do not approve this development, it will be met with stiff resistance from the entire community.

Policy Number:  AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

  1. what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);
  2. where the housing, roads and other buildings are going to be located; and
  3. the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south.  This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed –  maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7).  It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development.  Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc).  These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic.  Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided.  There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups.

There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge.  There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley.  All of it is in the Green Belt and it typifies the openness of the Green Belt.  Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided.  At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and  what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

  • the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
  • the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity 

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge.  It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls).  The gill woodlands and shaws provide important corridors, rich in biodiversity.  There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding 

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs.  This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

This development will put further pressure on the infrastructure in Southborough.  There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_4113

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

CPRE objects to this policy.

This allocation is for a “mixed use scheme to include land-based economic development and approximately 50-120 residential (C3) dwellings”. It is defined as a major development by TWBC and is expected to be guided by a masterplan (see paragraph 4.46, Policy STR 3).

CPRE is very concerned that there is a complete lack of clarity as to the specific location or scale of the proposed development and extent of the area to be developed.  Without further details it is impossible adequately to assess the appropriateness of the proposed allocation. This lack of clarity poses a significant threat of broad and dispersed development on the entirety of the allocated site which, according to the SHELAA, is 171 hectares (Site Reference 445).  The vagueness of the policy opens wide the potential for future development on the site, and indeed this appears to be the intention of TWBC when it states that “development may not exceed 120 dwellings during this plan period”.  The allocated site includes land within Tonbridge and Malling Borough, opening up the opportunity for further development not restricted by this policy.

The policy requires an ‘overarching masterplan’ prior to any application being submitted. However very few guiding principles are provided within policy AL/SO 3 for the formulation of that masterplan.  This contrasts markedly with other allocated sites within the Local Plan which provide more definition around how the masterplans for those sites should be prepared.

Green Belt

The allocated site is wholly within the Green Belt and represents a large single greenfield site separating Southborough and Tonbridge east of the A26. It falls within Broad Area 1 in TWBC’s Green Belt Study; parcel BA1 is assessed as making a strong contribution to all Green Belt objectives. Accordingly development of the site would directly contravene some of the key purposes of Green Belt policy in the NPPF, in particular “to prevent neighbouring towns merging into one” and to “check unrestricted sprawl of urban areas”.  TWBC propose that this site should remain in the Green Belt. It is not clear how this decision has been made.  It must contribute to a misleading impression of the extent of the Green Belt that is proposed to be built over under this draft Plan.

AONB

With regard to the AONB, there is no evidence provided which suggests that the proposal would satisfy the objectives of the High Weald AONB Management Plan. CPRE also considers that the proposal would represent ‘major development’ in the AONB.  The policy does not demonstrate exceptional circumstances nor that the three associated tests within the NPPF have been considered. In particular the policy does not include “an assessment for meeting the need in some other way”.  It is obvious that the proposal for 50-120 new dwellings could be met by increasing density on other sites and/or identifying other sites that are not located within the AONB.  We dispute the suggestion that this development is justified as providing an opportunity to develop an exemplar scheme inspired by the underlying historical evolution of the High Weald: ALL development within the nationally important landscape of the High Weald should be inspired by and reflect the AONB’s distinctive character.

It is also worth noting the Inspector’s report to the draft 2006 Local Plan with regards to proposals for a Park & Ride car park on land within the site allocated within policy AL/SO 3.  The Inspector referred to the guidance on major developments within national policy PPS7 which is now been replicated within paragraph 172 of the NPPF, and concluded that:

  • In the absence of any guidance in the Local Plan as to the definition of “major”, the Inspector concluded that issues such as location, scale, context and design were relevant in determining whether a development was “major” (see paragraph 11.189 of the 2005 Inspectors Report).
  • Applying those tests to the proposed Park & Ride site in the 2006 Local Plan, the Inspector concluded that the site, being around 2 hectares in size and way beyond the existing LBD should indeed be classified as “major development”.
  • Since the proposed Park & Ride (P&R) site had not been adequately assessed against the tests for major development, the Inspector at that time recommended that the Mabledon P&R proposals be deleted from the proposed 2016 Local Plan.

This experience from the last Local Plan strongly suggests that Policy AL/SO 3 would also be classified as major development and underscores the need to comply with the associated tests in the NPPF at this location.

Heritage

The site contains Ancient Woodland, assart fields and traditional orchards.  It is not clear how these heritage assets will be protected – and general access dissuaded – particularly if the development has a scattered settlement pattern.  This situation could be exacerbated if leisure and tourist-related activities formed a significant part of the proposed land-based economic development.  The impact on the heritage properties both within the site and at the edge of it does not appear to have been taken into account.  In particular, the impact on Mabledon House,  which from its location higher up the ridge line looks down on the fields separating Mabledon Farm from the A26, does not appear to have been considered.

Light Pollution

CPRE is concerned that development of the site will increase and intensify the extent of light intrusion in this area.  This  is an oasis of darker skies between the urban areas of Southborough and Tonbridge.

NPPF paragraph 180(c) requires planning decisions to “ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on … and the natural environment.” This includes limiting “the impact of light pollution from artificial light on local amenity, intrinsically dark landscapes and nature conservation.”

A26

CPRE is very concerned about the impact of this policy on the A26.  Congestion is a major problem here and CPRE understands that queues on this stretch of road form during peak periods back towards the A21/A26/Quarry Hill interchange. Access to the A26 from a development centred on Mabledon Farm,  when combined with visitor and staff traffic for the proposed hotel, spa and conference centre (AL/SO 4) will exacerbate the congestion such that this interchange will be brought to a standstill, impacting nearby Tonbridge and possibly affecting traffic on the A21.

We envisage that a roundabout would be required at the entrance to Mabledon Farm and Mabledon House to ensure safe vehicular access to the A26 from both sites (this is consistent with previous proposals for the Park & Ride at Mabledon Farm in the draft 2006 Local Plan).  The associated lighting would lead to further light intrusion.

There are currently limited options for active travel due to the lack of width on the A26; the Transport Evidence Base confirms that there are no plans for widening this.  There are no cycle tracks and a narrow pavement on one side of the road only.  While the area is well served by buses, due to its proximity to the urban areas, there are no pedestrian crossings, and bus passengers have to navigate crossing the road through 40mph traffic.

The Policy requires an ‘overarching masterplan’ prior to any planning application being submitted, suggesting that all the queries set out above will be considered at the earliest when the masterplan is being produced.  Very few guiding principles are provided within policy AL/SO 3 for the formulation of that masterplan.  This contrasts markedly with other allocated sites within the Local Plan which provide more definition around how the masterplans for those sites should be prepared.

DLP_4323

Gary Smith

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

Please accept this document to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land based economic development and approximately 50-120 residential (C2) dwellings.

It is my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);

ii) where the housing, roads and other buildings are going to be located; and

iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed potentially thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous causing queues of sitting traffic pulling out onto the A26 as it is now for residents in the existing houses near the site, when events are held at Mabledon Farm there are staff managing the traffic during events. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and

* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_4337

Nicole Smith

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

Please accept this document to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land based economic development and approximately 50-120 residential (C2) dwellings.

It is my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);

ii) where the housing, roads and other buildings are going to be located; and

iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed potentially thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous causing queues of sitting traffic pulling out onto the A26 as it is now for residents in the existing houses near the site, when events are held at Mabledon Farm there are staff managing the traffic during events. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and

* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_4511
DLP_6112
DLP_6233
DLP_6237
DLP_6348
DLP_6355
DLP_6361

Werda Hattingh
Andre Hattingh
Martin Webber
Diane & Andrew Bell
Paul Sleightholme
Mark Brennan
Julia and Colin Stoward

Object

The following responders submitted the standard response with variations:

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I am writing to register my OBJECTION to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);

ii) where the housing, roads and other buildings are going to be located; and

iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and then crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

As things stand at the moment, it is already an extremely busy and dangerous road to live on. We often struggle to turn onto the A26 from our driveway and have witnessed a number of accidents on this stretch of the A26 over the years. It is extremely worrying to contemplate the negative health implications that reduced air quality will have on our and our children’s health with increased traffic on London Road.

As a mother I feel very concerned that both our children will be exposed to even higher levels of toxic fumes to inhale whilst waiting at the bus stop…. an essential service working parents need. Additionally, as a family we support the use of public transport where possible to reduce our own carbon footprint as much as possible. Our children’s exposure to toxic fumes directly next to the roadside whilst for extended periods of time whilst waiting for the bus would naturally be higher than taking a private car journey. It would be a shame if we felt compelled to stop using public transport if the benefits no longer outweighed the risks associated with increased levels of traffic on London Road.

This truly is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

We enjoy walking in this area for reasons of health & wellbeing – the benefits of which will be lost should housing development take place here.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation for a major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and

* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes, bats, pheasants, many bird species and owls). Our visitors always comment on the beauty of daytime birdsong & the mesmerising sound of owls during night-time. It would be such a shame to disturb the fine balance which make it possible for all these species to co-esist. We want to protect their natural habitat by preserving it in its present state. The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife. The detriment of light pollution on nocturnal animals are well documented: https://www.nps.gov/articles/nocturnal_earthnight.htm

https://britishbirds.co.uk/article/bb-eye-the-effect-of-light-pollution-at-night-on-birds/

https://www.darksky.org/light-pollution/wildlife/

http://cescos.fau.edu/observatory/lightpol-Birds.html

Every member of our household will be very sad and will feel a great sense of loss & sorrow if owls and other nocturnal animals can no longer reside / survive in our beautiful area….

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

I would feel bereft if our ancient woodland were to be lost!

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

https://www.kentonline.co.uk/kent/news/it-was-horrendous-i-ve-never-seen-the-train-so-rammed-211203/

https://www.kentonline.co.uk/kent/news/train-passengers-slam-overcrowding-213319/

many more articles available online

DLP_4585

Kate Hardy

Object

Policy Number: AL/SO 3

Land at Mabledon and Nightingale (SHELAA reference: Site 455)

object to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

Green Belt

This 171-hectare space of Green Belt land is the last buffer between Tonbridge and Tunbridge Wells. Green Belt policy was creating precisely for preventing this type of urban sprawl development which would result in the coalescence of town and city. Giving the go-ahead to a development “not to exceed 120 dwellings during this plan period” (Policy point 7) sets a dangerous precedent; a slippery slope which opens the door to even more extensive development on this site in the future. The council must draw a line in the sand NOW to honour national planning policy and give the Green Belt the respect it deserves.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

Myself and other residents disagree with the council’s conclusion that this release of Green Belt land is justified by exceptional circumstances. No exceptional circumstances have been demonstrated in the local plan. Housing need is not an exceptional circumstance. The government has been very clear that a “brownfield first” approach should be followed, consulting with neighbouring boroughs if required to satisfy housing supply needs.

AONB & Heritage Assets

The proposed allocation for a major development in the AONB goes directly against the key objectives of the High Weald AONB Management Plan agreed by the Council. It is the council’s duty to preserve AONB & their biodiversity and protect Heritage Assets. I urge councillors to read the outstanding article by the High Brooms Society on the history of the Southborough valley. They describe it as a “countryside of such loveliness that it takes your breath away; where one sees nothing but beautiful woods, green fields on slopes and wild flowers, embraced by the undulating lap of the High Weald of Kent.” This is place that we frequently take our children out walking. Indeed the Society goes on to say that “the walk from Southborough to the Vauxhall Inn through the valley has been recently named as one of the Great British Walks.” King George III came here to shoot game. While the Duke of Wellington came for foxes. We’ve seen evidence of bats in our loft and garden but their numbers are declining as feeding spaces such as this dwindle.

In fact, this is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and

* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Has TWBC consulted with the AONB Forum of the High Weald AONB in relation to the site? The narrative in the local plan is unclear and unacceptably vague on this and number of other points.

As this landscape offers a connection both to nature and our shared history, we ask the council not to allow its destruction.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

Due to the location of this site on the border of Tonbridge & Tunbridge Wells, it is simply irresponsible to progress with this development, when Tonbridge & Malling Borough Council have raised “serious concerns”. Specifically, that "the proximity of some of the major development proposals to the borough boundary and specifically, the south east of our main settlement of Tonbridge, is a matter of serious concern due to the potential impacts on the local highway network, rail services and other community infrastructure including health care and education, particularly when combined with planned developments in Tonbridge as part of our own Local Plan."

Despite the fact that Tonbridge train station, high street, supermarket, and associated car parks are closer than any TWBC alternative, none of the council tax revenue from these new homes would support infrastructure in Tonbridge, a fundamental flaw in the planning process which must be addressed.

This is snapshot of the current rush hour traffic ques in all directions on the Tonbridge side.


The fact that Highways concerns were not raised in the Mabledon/Nightingale evaluation is further evidence of the lack of due care being shown to the residents of Tonbridge and another example of flawed planning.

This development will also put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

In conclusion, while I appreciate the great challenge of meeting future housing needs, the convenience of partnering with a single landowner does not override the council’s obligations to national policy and the residents of Southborough & Tonbridge.

DLP_4716

Mr Mark Weavis

Object

The essence of my reaction to the proposed development East of the A26, South of the A21 and North of Vauxhall Lane is:

We live in  a delightful area where the existing residential properties benefit from a rural environment, which is the reason that people have purchased premium properties in the area.  An original owner of Mabledon was also a major shareholder of a bank that merged to become the Bank of England.  Many of the local residents still work in the City banking institutions and there is a happy link between our area and the economic powerhouse of the City.

It defeats me why our local council is seeking to destroy that relationship and turn our area into an over populated ghetto, driving long term residents away from the area.  Surely that cannot be the reason why our council exists?

Please do not destroy our environment and subject us to ridiculous traffic problems.

DLP_4729

Steve Dowle

Object

I am writing to object to the proposed development of the land at Mabledon and Nightingale for the following reasons:

1) The area is within green belt land and an area of natural beauty (AONB). This land is rich in wildlife and an important barrier between Tonbridge and Southborough. There seems very little point in having protected and designated areas if you are going to ignore them and build wherever you like.

2) Unclear planning – There needs to be very specific marking out of the proposed homes, and guarantees that this doesn’t become another Nights Wood development that goes way beyond its original intention.

3) Traffic – the traffic on the A26 is a major bottleneck into Tunbridge Wells, and this will make it even worse and have an adverse effect on businesses in the town. Without any provision for any services in the plan for this area, will mean that there will be more car use than developing within an already established area.

DLP_4735

Alistair Borland

Object

I object to the proposed allocation for a mixed-use scheme to include land-based economic development and approximately 50-120 residential dwellings.

A26 -Traffic Congestion, Air Quality and Safety 

I live on the A26 near Mabledon.  The traffic is already a major problem here and will only be made worse by a development of even 120 homes at this location, combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO4).

I drive to work as there are no suitable public transport options.  It’s already difficult and dangerous to pull out onto the A26 from my home, with heavy traffic and vehicle speeds often exceeding the 40mph speed limit. When the traffic is flowing freely, it’s hard to find a gap to safely pull out into.  It’s single carriageway so if there are any problems further along the A26, or simply a bus picking up/dropping of passengers or a car waiting to turn right into a driveway, tailbacks rapidly build up and block the exit from/entry to my driveway. Even slowing down to turn left into a driveway is dangerous – vehicles following me either only brake at the very last moment  or pull into the opposite carriageway to get past.

Imagine then the traffic queues that will form on an access road from a new housing development.  And those on the A26 itself, with vehicles waiting to turn right into the proposed new developments – through fast moving traffic, with no space for right-turn lanes.  A26 congestion will stretch south into the Air Quality Management Area of Southborough and Royal Tunbridge Wells, and north into Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase rather than reduce congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26 from the new development.

It wouldn’t matter where the access was – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road as well as traffic to/from the A21 slip roads and Quarry Hill; Vauxhall Lane is a narrow rural lane with appalling visibility at its junction with the A26 and is already over-used as a cut through between Southborough and the Vauxhall interchange; the track to Nightingale Farm is on a bend which restricts visibility.

“Safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be even more difficult to provide.  There are no cycle tracks on this section of the A26 and no room to provide them without widening the road (at enormous cost).  Cyclists already use the narrow pavement rather than cycling on the carriageway.  That’s understandable but as they can easily reach speeds of 30mph, they already present a serious danger to pedestrians – particularly parents with young children and elderly people.  It’s not a route to encourage schoolchildren to use for any sort of active travel from a new housing development to schools in Southborough or Tonbridge.

A number of bus routes run along the A26 but there are no pedestrian crossings near the Mabledon/Nightingale site.   How would a parent with a baby in a push chair and another child cross the road to get to a bus stop? Two small traffic islands within a 1 mile stretch of road don’t offer a safe option for crossing for anyone, but are especially dangerous for the elderly or those with young children.

And then there is the health hazard from vehicle fumes, with a constant flow of cars and HGVs passing at high speed for much of the day.

The serious impact on the safety, health and wellbeing of existing residents over a wide area must be taken into account by the Council when considering whether to take this proposal forward

Impact on the Countryside and the Environment 

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge.  There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley.  I know it’s Green Belt and AONB and so has “legal” protection from inappropriate development, but it’s the sheer beauty and the tranquillity that make me want to keep it safe from development.  Away from the road, even in a back garden, it’s very easy to forget that Southborough and Tonbridge are only a mile away.  Watching birds of prey swooping above the open fields,  bats catching insects at dusk and a variety of birds – crows, robins, thrushes, wrens, sparrows, blackbirds, nuthatches, green and spotted woodpeckers, blue tits, great tits, coal tits -  the list seems endless.  We even have pheasants as regular visitors, and of course can listen to the owls hooting at night. Wildlife that strays into our garden or can be seen in the nearby fields includes deer, badgers, foxes, weasels and stoats, hedgehogs.

It’s not developed land so it’s the perfect habitat for all of the above – yes, there are oast houses and barns now converted to homes, but these add to the sense of place,  and don’t intrude on the landscape as a new development would.  At night I can clearly see the stars, and have watched meteor showers. I’ve lived all my life in the Kent countryside and want to continue to do so.  The mental health benefits for are incalculable.

DLP_4779

Alison Spender

Object

Policy Number:  AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455) 

I am concerned with protecting the countryside that lies between the Southborough and Tunbridge Wells.

I strongly object to the proposed allocation of AL/SO 3 Land at Mabledon and Nightingale for a mixed use scheme to include land-based economic development and approximately 50-120 residential dwellings on the basis of

  • the lack of clarity in the Draft Local Plan documentation set regarding the proposal;
  • the potential for inappropriate development in the AONB and the Green Belt;
  • increased traffic congestion on the A26, including in the Southborough AQMA and
  • environmental impacts.

1. Lack of Clarity regarding the Proposal

I am surprised that TWBC have seen fit to include as a proposed allocation where there appears to be

a) confusion as to where the site is :

Draft Local Plan para 5.53 incorrectly states that it is the Main Urban Area, and this is error is repeated or implied in a number of the Supporting Documents

(b) lack of clarity as to the extent of development proposed apart from housing:

Buildings for land based economic development (policy point 8b) – what and how many?

Community facilities including buildings (policy point 8c) – what and how many?

utility cycle tracks within the site to link to Southborough and Tonbridge, which will be tarmacked and lit for safety reasons

roads within the site to link “scattered forms of development”

buildings and spaces to provide cultural infrastructure (Exhibition Board 19)

c) a need for additional studies to determine where developments (housing and other) could be located while still avoiding the multitude of constraints;

much of the allocated area was put forward in the 2016 Call for Sites (Sites: 179 - Mabledon Farm,  180 - Nightingale Farm and 181 – Moatenden)

the environmental and landscape constraints are well covered in the relevant Environment & Landscape Supporting Documents on the Local Plan website.

d) no calculation of what land take will be required for the developments.

The site boundaries are not shown on the policy maps however we note from the SHELAA (Site reference 445 – 16. Southborough Sites) that the site is approximately 171 hectares.

the 50-120 dwelling proposed for the current plan period in Policy AL/SO3 would only require 8 hectares using a density of 15 dwellings per hectare for a mixed use development or 3 hectares using a density of 40 dwellings per hectare on a greenfield site.

We consider that the vagueness of this proposed allocation simply establishes that development in this area is acceptable to TWBC, setting a dangerous precedent for the future.   Our very serious concern it the landowners (the Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed.  The “Potential yield if residential” in the SHELAA should reflect that the stated developable area is 125 hectares giving a potential yield of 1,875 dwellings using a  density 15 dwellings per hectare for a mixed-use development,  or 5,000 dwellings using a density of 40 dwellings per hectare on a greenfield site.

A planning application has recently (August 2019) been submitted by the landowner for one small part of the site (19/02361 Moatenden - 1.14 hectares) which cites the lack of a 5-year housing supply.  What is to stop further applications for other areas at any point in the future when Tunbridge Wells cannot demonstrate a 5-year housing supply?  Additionally, approximately a quarter of the site is in the borough of Tonbridge and Malling, and includes direct access from Vauxhall Lane within that borough, giving further options for development.

Until the location(s) and extent of development are confirmed it is premature to propose allocating this site in the Draft Local Plan.

2. High Weald AONB

I am concerned that the reasons for allocating this site for housing development are not clearly set out in the Draft Local Plan documentation set.  From the information provided this allocation is likely to cause significant harm to the character of the AONB and there are no “exceptional circumstances” as defined in the NPPF paragraph 172.

Additionally we have found no evidence to support the Council’s view that it will provide “an exemplar scheme inspired by the underlying historical character of the High Weald” (although we have noticed that “exemplar” appears to be the buzzword for developments proposed by this landowner,  who also owns the site at Tudeley which is proposed for the “Garden Village).

a) Assessment of harm to AONB Character

From a landscape perspective this site is rural in nature and forms a strategic gap between Tonbridge and Southborough.  It lies within sub areas SP5 and SP6 in the 2017 Landscape Sensitivity Assessment of Countryside around Tunbridge Wells and this report highlights the many landscape features typical of the High Weald AONB.  Both areas are assessed as having a high sensitivity to any scale of development.  The report does suggest that, within sub area SP5 “there may be pockets of land associated with existing development where sensitivity to small-scale development could be relatively contained in the wider landscape” but does not specify where these pockets might be. Mabledon Farm is the only existing development that is both within the allocated site and sub-area SP5, suggesting that a scattered development would not satisfy this requirement.

The Southborough section of the Historic Landscape Characterisation gives further evidence of the historic importance of this site.  The main report highlights that “whilst dispersed plans may offer opportunities for additional dwellings, the very process can easily destroy the historic layout and character of the farmstead” (para 4.1, Section 1 – User Guide  & Interpretation).  Mabledon Farm is a historic farmstead, with assart fields and traditional orchards close to it.

The conclusions in these reports are reflected in the assessment of High Impact on the AONB in the Distribution of Development Topic Paper (App. 3: Assessment of AONB Sites - Site Policy Ref SO 3).

In the light of the above,  we question why the Council chose to support the development proposal for Mabledon/Nightingale and include an allocation for this site in the Draft Local Plan.   Paragraph 6.85 of the Distribution of Development Topic Paper states that “where development is considered likely to cause significant harm to the defining character of the AONB (also having regard to potential mitigation) or cause harm disproportionate to likely benefits of the scheme, then that development will be very unlikely to be supported”.  

The mitigation proposed for this development appears to be the “farmstead approach” which is nowhere defined nor expanded upon.  The suggestion in the Distribution of Development Topic Paper  (App 3) that there is “a very restrictive policy requiring positive landscape outcomes” is simply untrue.   The only restriction in the Policy for AL/SO 3 is that housing development will be limited to 120 dwellings in this plan period.  As the Council specifically exclude sites allocated in the local plan from the provisions of Policy EN21,  and the AONB Joint Advisory Committee’s role in the development will only be to provide “input to the vision and design process”, there appear to be no restrictions in Policy AL/SO 3 to protect the landscape from inappropriate development.

b) Major development in AONB

The Distribution of Development Topic Paper highlights the provisions of the NPPF with regard to AONBs (para 3.8 – 3.11)  and suggests that TWBC believe that the proposed development is likely to be classed as major development in the AONB, highlighting that its scale is “very substantial” relative to the existing settlement.(App. 3: Assessment of AONB Sites - Site Policy Ref SO 3,  Distribution of Development Topic Paper)

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. Consideration of such applications should include an assessment of:

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”. 

It is nonsensical for the Council to present an assessment of major developments within the AONB against the NPPF requirements as a single entity,  as is done in the table under para 6.101 in the Distribution of Development Topic Paper.  The individual site level assessments are not described in in the Distribution of Development Topic Paper or the SHELAA.  We are concerned therefore that no evidence is given of the “exceptional circumstances” specific to the proposed AL/SO3 allocation;  in particular we cannot see that the need for up to 120 dwellings could not be met in some other way within the borough as a whole, with the council already proposing to allocate 9% more housing than required by the OAN calculations.

We also question the Council’s reliance on “unique circumstances” as justification referenced throughout the Draft Local Plan document set.  These appear to be that a farmstead (Mabledon Farm) and its surrounding land are in a single ownership.  It is a very disturbing statement on the state of a predominantly rural borough if this is true!

In conclusion we can see no justification for the proposed allocation for development of this large site in the AONB.  The Distribution of Development Topic Paper para 6.89 supports the view that this proposal should have been rejected by the Council as not being a “reasonable option”.

Green Belt

AL/SO3 provides the one-mile wide Green Belt separation east of the A26 between the built-up areas of Southborough and Tonbridge. Housing development here would be contrary to the purposes of the Green Belt as set out in paragraphs 133-134 of the NPPF:

“The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

Green Belt serves five purposes:

a) to check the unrestricted sprawl of large built-up areas;

b) to prevent neighbouring towns merging into one another;

c) to assist in safeguarding the countryside from encroachment;

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

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

In the Stage 2 TWBC Green Belt Study this site falls within Broad Area 1, we assume due to its rural nature. BA1 is assessed as making a STRONG contribution to each of the Green Belt purposes a) through d).

It is unclear what assessments of the potential for harm to this area of Green Belt the Council have carried out in proposing this allocation.  The Green Belt designation is not included in the “Issues to consider” section of the SHELAA (Site ref 445 – Section 16. Southborough Site) and we cannot find any discussion of the reasons behind the decision that this site should remain in the Green Belt.  The Assessment of Green Belt Sites (App 1 Distribution of Development Topic Paper) has N/A for

  • Allocation Area within MGB
  • Hectares to remove from MGB
  • Site Size
  • Site % in MGB
  • Housing Min as % of site in MGB
  • Housing Max as % of site in MGB

As this table also has the housing numbers and masterplanning for AL/SO3 shown under SO4 (the hotel/leisure development, we can only assume that no consideration at all has been given to Green Belt purposes in allocating this site. We suggest that the intent in the NPPF is to protect the Green Belt from inappropriate development, not to allow unconstrained development simply by the Council declaring that a developed site will remain in the Green Belt. In this instance it seems as if the Council has simply avoided the need to demonstrate “exceptional circumstances” by ignoring the sites contribution to the Green Belt purposes.

Without knowing the location and extent of development it is impossible to say what impact the proposed developments would have on the openness of this area of the Green Belt.  There are views into the site from a variety of locations - the A26, a PROW to Haysden (higher up the ridge) or the footpath near the Cottage Hospital (lower down the valley).  Any development at the southern end of the site would be visible from Vauxhall Lane (a designated Rural Lane) and the Tunbridge Wells Circular Walk.

3. Transport and Active Travel 

a) Congestion and Air Quality

We are very concerned that additional traffic from this new development  will simply exacerbate the existing congestion and air quality on the section of the A26 near the site and in the nearby AGMA in Southborough.  The situation will be made even worse by the volume of traffic likely to be generated by the proposed hotel and leisure complex at Mabledon House (AL/SO3).  We are unsure how the smart traffic management system proposed in the Transport Evidence Base, synchronising traffic lights, will improve the traffic flows on the A26 past the Mabledon/Nightingale site when there are no traffic lights here and the speed limit is 40mph, 10mph higher than the speed limit in the urban area of Southborough.  Additionally, this is a single-carriageway road with traffic halted by buses picking up/dropping off passengers and vehicles slowing or stopping to turn into private driveways.

b) Safety

The Policy for AL/SO3 requires “safe and acceptable access arrangements from the A26 for the proposed development with, where required, a secondary emergency access”. (policy point 1).

We note that the junction performance assessment for AL/SO3 allocation in the Transport Evidence Base was carried out based upon 100 dwellings accessing the A26 via Vauxhall Lane.  We are confused by this approach as Vauxhall Lane is at the opposite end of the site to Mabledon Farm on which the development would be centred. Vauxhall Lane is a narrow lane with complex topography and a “blind” junction with the A26; it is totally unsuited to such an increase in traffic.

The more obvious access to the A26 would be through upgrading the current PROW from Mabledon Farm to the A26.  Unfortunately this would result in traffic leaving/joining the A26 in close proximity to the access to the proposed hotel and leisure complex at Mabledon House (AL/SO4).  This stretch of road has a 40mph speed limit and this limit is frequently exceeded as vehicles approach the slip road to the A21.  It is unclear how traffic from the new development could safely pull out onto the A26. We believe that traffic lights would only serve to increase congestion and air pollution, by halting the flow of traffic on the A26 while construction of a roundabout would have a material impact on the character of the AONB landscape (as would any widening of the A26).

Safe and acceptable pedestrian and cycle linkages to Southborough are also required(policy point 2).   At this stage we feel that there is too little information available re Scheme 404 (Cycling corridor and rights of way between Tunbridge Wells and Tonbridge) which appears to be the route that would serve the development at AL/SO 3, and will comment when the Walking and Cycling Strategy is published.

Pedestrian access to Southborough and Tonbridge via the A26 is not safe and we see no indications  that any improvements are proposed in the Draft Local Plan. There is a narrow pavement on only one side of the road and there are no controlled pedestrian crossings.  Traffic speeds make walking here both unpleasant and unsafe.  Getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but impossible for the elderly or those with young children.  Cars will continue to be used for the majority of journeys.

4. Land-based economic development and rural life

The proposed housing development is neither connected to, nor essential for, land based economic development on this site and it is unclear why the housing element has been included in the allocation.

We believe that the majority of the land within the site is leased to two tenant farmers and has been used in recent years as grazing for cattle, sheep, and horses stabled at the Honnigton Equestrian Centre (south of Vauxhall Lane, and not itself included within this site).  The informal tracks within the site have also been used for exercising horses from the Honnigton Equestrian Centre. The landowners already have an obligation to improve (for the 25 years) some of the agricultural land on this site under an S106 agreement in November 2014 in relation to the planning application 14/00870 for a Solar Park on other land which they own.

Obviously we cannot comment on the current economic viability of the agricultural uses on this site.  However we have not seen any evidence in the DLP document set that there is a need for affordable housing (and other infrastructure and amenities) for rural communities on this site to meet Objective LBE2 in the High Weald AONB Management Plan nor that erection of rural workers dwellings here would be essential under the provisions of Policy H10 in the Draft Local Plan.

In relation to the proposed land-based economic development per se, in addition to the Development Management Policies already referenced in point 8f of Policy AL/SO 3 as a minimum the following should also apply: EN22, ED4, ED5, ED6 and ED7.  We also surprised that there is no requirement for supporting woodland management and rural crafts as set out in the “Statement of Significance” in the High Weald AONB Management Plan (and quoted in the Distribution of Development Paper)

5. Ecology and Biodiversity

We believe that the potential impact of the proposed development on ecology and biodiversity has been seriously underestimated in the Draft Local Plan. The site includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a wide variety of species. The gill woodlands and shaws provide important corridors for wildlife and are rich in biodiversity.  There are traditional orchards, now a rare habitat.  In addition the site is on a green corridor of Ancient Woodland (Coxon Wood, Beeches Wood, Nightingale Wood and Minepit Wood )which provides a natural habitat for plants, animals and birds.  The Dark Skies provide an essential haven for nocturnal wildlife; at night owls can be heard hooting, foxes calling and badgers foragaing.

It is unclear how development here would protect and enhance biodiversity and geodiversity

6. Heritage Assets

The impact of the proposed development on listed buildings and other heritage assets within or bordering the site does not appear to have been assessed.

7. Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain with run-off from the A26 and higher ground. There is network of underground streams and springs in addition to the visible stream and ponds within the site.  This is not ideal land for development and will be made worse by the creation of additional impermeable surfaces for housing, roadways etc.

We are also aware that the mains sewer is located at the rear of the gardens of the strip of houses beside the A26 and there is a Southern Water pumping station near this (within the site).  As there are steep slopes in this area, falling away from the A26, we would like to be assured that appropriate measures are planned for connection of new properties to the mains sewage pipes has been considered.

8. Infrastructure

This development will put further pressure on the infrastructure in Southborough.  There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_4787

Susan Robertson

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);

ii) where the housing, roads and other buildings are going to be located; and

iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc despite a petition by local residents in 2016 for a speed reduction to 30mph along this stretch of the A26). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. This was a point raised by the Speed Reduction Petition in 2016. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. Again, a point raised by the speed reduction campaign in 2016.

There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children. Again, another point raised by the speed reduction campaign.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and

* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_4858

Liza Hall
Hangman’s Hill Residents Association

Object

Policy Number:  AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455) 

The Hangman’s Hill Residents Association (HHRA)represents those living on or close to the section of London Road, Southborough (the A26) that is between Vauxhall Lane and Mabledon.  We aim to play an active role in localism and shaping the future of Southborough and are particularly concerned with protecting the countryside that lies between the urban areas of Southborough and Tonbridge.  This response from the HHRA Committee is based upon discussions with our membership and our analysis of the wider set of Draft Local Plan documentation.

The HHRA Committee strongly objects to the proposed allocation of AL/SO 3 Land at Mabledon and Nightingale for a mixed use scheme to include land-based economic development and approximately 50-120 residential dwellings on the basis of

  • the lack of clarity in the Draft Local Plan documentation set regarding the proposal;
  • the potential for inappropriate development in the AONB and the Green Belt;
  • increased traffic congestion on the A26, including in the Southborough AQMA and
  • environmental impacts.

1. Lack of Clarity regarding the Proposal

HHRA is surprised that TWBC have seen fit to include as a proposed allocation where there appears to be

a) confusion as to where the site is :

Draft Local Plan para 5.53 incorrectly states that it is the Main Urban Area, and this is error is repeated or implied in a number of the Supporting Documents

b) lack of clarity as to the extent of development proposed apart from housing:

Buildings for land based economic development (policy point 8b) – what and how many?

Community facilities including buildings (policy point 8c) – what and how many?

utility cycle tracks within the site to link to Southborough and Tonbridge, hich will be tarmacked and lit for safety reasons

roads within the site to link “scattered forms of development”

buildings and spaces to provide cultural infrastructure (Exhibition Board 19)

c) a need for additional studies to determine where developments (housing and other) could be located while still avoiding the multitude of constraints;

much of the allocated area was put forward in the 2016 Call for Sites (Sites: 179 - Mabledon Farm,  180 - Nightingale Farm and 181 – Moatenden)

the environmental and landscape constraints are well covered in the relevant Environment & Landscape Supporting Documents on the Local Plan website.

d) no calculation of what land take will be required for the developments.

The site boundaries are not shown on the policy maps however ee note from the SHELAA (Site reference 445 – 16. Southborough Sites) that the site is approximately 171 hectares.

the 50-120 dwelling proposed for the current plan period in Policy AL/SO3 would only require 8 hectares using a density of 15 dwellings per hectare for a mixed use development or 3 hectares using a density of 40 dwellings per hectare on a greenfield site.

We consider that the vagueness of this proposed allocation simply establishes that development in this area is acceptable to TWBC, setting a dangerous precedent for the future.   Our very serious concern it the landowners (the Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed.  The “Potential yield if residential” in the SHELAA should reflect that the stated developable area is 125 hectares giving a potential yield of 1,875 dwellings using a  density 15 dwellings per hectare for a mixed-use development, or 5,000 dwellings using a density of 40 dwellings per hectare on a greenfield site.

A planning application has recently (August 2019) been submitted by the landowner for one small part of the site (19/02361 Moatenden - 1.14 hectares) which cites the lack of a 5-year housing supply.  What is to stop further applications for other areas at any point in the future when Tunbridge Wells cannot demonstrate a 5-year housing supply? Additionally, approximately a quarter of the site is in the borough of Tonbridge and Malling, and includes direct access from Vauxhall Lane within that borough, giving further options for development.

Until the location(s) and extent of development are confirmed it is premature to propose allocating this site in the Draft Local Plan.

2. High Weald AONB

HHRA is very concerned that the reasons for allocating this site for housing development are not clearly set out in the Draft Local Plan documentation set.  From the information provided this allocation is likely to cause significant harm to the character of the AONB and there are no “exceptional circumstances” as defined in the NPPF paragraph 172.

Additionally we have found no evidence to support the Council’s view that it will provide “an exemplar scheme inspired by the underlying historical character of the High Weald” (although we have noticed that “exemplar” appears to be the buzzword for developments proposed by this landowner,  who also owns the site at Tudeley which is proposed for the “Garden Village).

  1. Assessment of harm to AONB Character

From a landscape perspective this site is rural in nature and forms a strategic gap between Tonbridge and Southborough.  It lies within sub areas SP5 and SP6 in the 2017 Landscape Sensitivity Assessment of Countryside around Tunbridge Wells and this report highlights the many landscape features typical of the High Weald AONB.  Both areas are assessed as having a high sensitivity to any scale of development.  The report does suggest that, within sub area SP5 “there may be pockets of land associated with existing development where sensitivity to small-scale development could be relatively contained in the wider landscape” but does not specify where these pockets might be. Mabledon Farm is the only existing development that is both within the allocated site and sub-area SP5, suggesting that a scattered development would not satisfy this requirement.

The Southborough section of the Historic Landscape Characterisation gives further evidence of the historic importance of this site.  The main report highlights that “whilst dispersed plans may offer opportunities for additional dwellings, the very process can easily destroy the historic layout and character of the farmstead” (para 4.1, Section 1 – User Guide  & Interpretation).  Mabledon Farm is a historic farmstead, with assart fields and traditional orchards close to it.

The conclusions in these reports are reflected in the assessment of High Impact on the AONB in the Distribution of Development Topic Paper (App. 3: Assessment of AONB Sites - Site Policy Ref SO 3).

In the light of the above,  we question why the Council chose to support the development proposal for Mabledon/Nightingale and include an allocation for this site in the Draft Local Plan.   Paragraph 6.85 of the Distribution of Development Topic Paper states that “where development is considered likely to cause significant harm to the defining character of the AONB (also having regard to potential mitigation) or cause harm disproportionate to likely benefits of the scheme, then that development will be very unlikely to be supported”.  

The mitigation proposed for this development appears to be the “farmstead approach” which is nowhere defined nor expanded upon.  The suggestion in the Distribution of Development Topic Paper  (App 3) that there is “a very restrictive policy requiring positive landscape outcomes” is simply untrue.   The only restriction in the Policy for AL/SO 3 is that housing development will be limited to 120 dwellings in this plan period.  As the Council specifically exclude sites allocated in the local plan from the provisions of Policy EN21,  and the AONB Joint Advisory Committee’s role in the development will only be to provide “input to the vision and design process”, there appear to be no restrictions in Policy AL/SO 3 to protect the landscape from inappropriate development.

  1. Major development in AONB

The Distribution of Development Topic Paper highlights the provisions of the NPPF with regard to AONBs (para 3.8 – 3.11)  and suggests that TWBC believe that the proposed development is likely to be classed as major development in theAONB, highlighting that its scale is “very substantial” relative to the existing settlement.(App. 3: Assessment of AONB Sites - Site Policy Ref SO 3,  Distribution of Development Topic Paper)

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. Consideration of such applications should include an assessment of:

  1. 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;
  2. b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and
  3. c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated”. 

It is nonsensical for the Council to present an assessement of major developments within the AONB against the NPPF requirements as a single entity,  as is done in the table under para 6.101 in the Distribution of Development Topic Paper.  The individual site level assessments are not described in in the Distribution of Development Topic Paper or the SHELAA.  We are concerned therefore that no evidence is given of the “exceptional circumstances” specific to the proposed AL/SO3 allocation;  in particular we cannot see that the need for up to 120 dwellings could not be met in some other way within the borough as a whole, with the council already proposing to allocate 9% more housing than required by the OAN calculations.

We also question the Council’s reliance on “unique circumstances” as justification referenced throughout the Draft Local Plan document set.  These appear to be that a farmstead (Mabledon Farm) and its surrounding land are in a single ownership.  It is a very disturbing statement on the state of a predominantly rural borough if this is true!

In conclusion we can see no justification for the proposed allocation for development of this large site in the AONB.  The Distribution of Development Topic Paper para 6.89 supports the view that this proposal should have been rejected by the Council as not being a “reasonable option”.

Green Belt

AL/SO3 provides the one-mile wide Green Belt separation east of the A26 between the built-up areas of Southborough and Tonbridge. Housing development here would be contrary to the purposes of the Green Belt as set out in paragraphs 133-134 of the NPPF:

“The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

Green Belt serves five purposes:

  1. a) to check the unrestricted sprawl of large built-up areas;
  2. b) to prevent neighbouring towns merging into one another;
  3. c) to assist in safeguarding the countryside from encroachment;
  4. d) to preserve the setting and special character of historic towns; and
  5. e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 

In the Stage 2 TWBC Green Belt Study this site falls within Broad Area 1, we assume due to its rural nature. BA1 is assessed as making a STRONG contribution to each of the Green Belt purposes a) through d).

It is unclear what assessments of the potential for harm to this area of Green Belt the Council have carried out in proposing this allocation.  The Green Belt designation is not included in the “Issues to consider” section of the SHELAA (Site ref 445 – Section 16. Southborough Site) and we cannot find any discussion of the reasons behind the decision that this site should remain in the Green Belt.  The Assessment of Green Belt Sites (App 1 Distribution of Development Topic Paper) has N/A for

  • Allocation Area within MGB
  • Hectares to remove from MGB
  • Site Size
  • Site % in MGB
  • Housing Min as % of site in MGB
  • Housing Max as % of site in MGB

As this table also has the housing numbers and masterplanning for AL/SO3 shown under SO4 (the hotel/leisure development, we can only assume that no consideration at all has been given to Green Belt purposes in allocating this site. We suggest that the intent in the NPPF is to protect the Green Belt from inappropriate development, not to allow unconstrained development simply by the Council declaring that a developed site will remain in the Green Belt. In this instance it seems as if the Council has simply avoided the need to demonstrate “exceptional circumstances” by ignoring the sites contribution to the Green Belt purposes.

Without knowing the location and extent of development it is impossible to say what impact the proposed developments would have on the openness of this area of the Green Belt.  There are views into the site from a variety of locations - the A26, a PROW to Haysden (higher up the ridge) or the footpath near the Cottage Hospital (lower down the valley).  Any development at the southern end of the site would be visible from Vauxhall Lane (a designated Rural Lane) and the Tunbridge Wells Circular Walk.

3. Transport and Active Travel 

a) Congestion and Air Quality

We are very concerned that additional traffic from this new development  will simply exacerbate the existing congestion and air quality on the section of the A26 near the site and in the nearby AGMA in Southborough.  The situation will be made even worse by the volume of traffic likely to be generated by the proposed hotel and leisure complex at Mabledon House (AL/SO3).  We are unsure how the smart traffic management system proposed in the Transport Evidence Base, synchronising traffic lights, will improve the traffic flows on the A26 past the Mabledon/Nightingale site when there are no traffic lights here and the speed limit is 40mph, 10mph higher than the speed limit in the urban area of Southborough.  Additionally, this is a single-carriageway road with traffic halted by buses picking up/dropping off passengers and vehicles slowing or stopping to turn into private driveways.

  1. Safety

The Policy for AL/SO3 requires “safe and acceptable access arrangements from the A26 for the proposed development with, where required, a secondary emergency access”. (policy point 1).

We note that the junction performance assessment for AL/SO3 allocation in the Transport Evidence Base was carried out based upon 100 dwellings accessing the A26 via Vauxhall Lane.  We are confused by this approach as Vauxhall Lane is at the opposite end of the site to Mabledon Farm on which the development would be centred. Vauxhall Lane is a narrow lane with complex topography and a “blind” junction with the A26; it is totally unsuited to such an increase in traffic.

The more obvious access to the A26 would be through upgrading the current PROW from Mabledon Farm to the A26.  Unfortunately this would result in traffic leaving/joining the A26 in close proximity to the access to the proposed hotel and leisure complex at Mabledon House (AL/SO4).  This stretch of road has a 40mph speed limit and this limit is frequently exceeded as vehicles approach the slip road to the A21.  It is unclear how traffic from the new development could safely pull out onto the A26. We believe that traffic lights would only serve to increase congestion and air pollution, by halting the flow of traffic on the A26 while construction of a roundabout would have a material impact on the character of the AONB landscape (as would any widening of the A26).

Safe and acceptable pedestrian and cycle linkages to Southborough are also required(policy point 2).   At this stage we feel that there is too little information available re Scheme 404 (Cycling corridor and rights of way between Tunbridge Wells and Tonbridge) which appears to be the route that would serve the development at AL/SO 3, and will comment when the Walking and Cycling Strategy is published.

Pedestrian access to Southborough and Tonbridge via the A26 is not safe and we see no indications  that any improvements are proposed in the Draft Local Plan.  There is a narrow pavement on only one side of the road and there are no controlled pedestrian crossings.  Traffic speeds make walking here both unpleasant and unsafe.  Getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but impossible for the elderly or those with young children. Cars will continue to be used for the majority of journeys.

  1. Land-based economic development and rural life

    The proposed housing development is neither connected to, nor essential for, land based economic development on this site and it is unclear why the housing element has been included in the allocation.

    We believe that the majority of the land within the site is leased to two tenant farmers and has been used in recent years as grazing for cattle, sheep, and horses stabled at the Honnigton Equestrian Centre (south of Vauxhall Lane, and not itself included within this site).  The informal tracks within the site have also been used for exercising horses from the Honnigton Equestrian Centre. The landowners already have an obligation to improve (for the 25 years) some of the agricultural land on this site under an S106 agreement in November 2014 in relation to the planning application 14/00870 for a Solar Park on other land which they own.

    Obviously we cannot comment on the current economic viability of the agricultural uses on this site.  However we have not seen any evidence in the DLP document set that there is a need for affordable housing (and other infrastructure and amenities) for rural communities on this site to meet Objective LBE2 in the High Weald AONB Management Plan nor that erection of rural workers dwellings here would be essential under the provisions of Policy H10 in the Draft Local Plan.

    In relation to the proposed land-based economic development per se, in addition to the Development Management Policies already referenced in point 8f of Policy AL/SO 3 as a minimum the following should also apply: EN22, ED4, ED5, ED6 and ED7.  We also surprised that there is no requirement for supporting woodland management and rural crafts as set out in the “Statement of Significance” in the High Weald AONB Management Plan (and quoted in the Distribution of Development Paper)

  2. Ecology and Biodiversity

    We believe that the potential impact of the proposed development on ecology and biodiversity has been seriously underestimated in the Draft Local Plan. The site includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a wide variety of species. The gill woodlands and shaws provide important corridors for wildlife and are rich in biodiversity.  There are traditional orchards, now a rare habitat.  In addition the site is on a green corridor of Ancient Woodland (Coxon Wood, Beeches Wood, Nightingale Wood and Minepit Wood )which provides a natural habitat for plants, animals and birds.  The Dark Skies provide an essential haven for nocturnal wildlife; at night owls can be heard hooting, foxes calling and badgers foragaing.

    It is unclear how development here would protect and enhance biodiversity and geodiversity

  3. Heritage Assets

    The impact of the proposed development on listed buildings and other heritage assets within or bordering the site does not appear to have been assessed.

  4. Flooding

    Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain with run-off from the A26 and higher ground. There is network of underground streams and springs in addition to the visible stream and ponds within the site.  This is not ideal land for development and will be made worse by the creation of additional impermeable surfaces for housing, roadways etc.

    We are also aware that the mains sewer is located at the rear of the gardens of the strip of houses beside the A26 and there is a Southern Water pumping station near this (within the site).  As there are steep slopes in this area, falling away from the A26, we would like to be assured that appropriate measures are planned for connection of new properties to the mains sewage pipes has been considered.

  5. Infrastructure

This development will put further pressure on the infrastructure in Southborough.  There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_4875

Dominique Webber

Object

Policy Number:  AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455) 

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the  conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

I moved here to benefit from the green space which was disappearing from where we lived in London due to building. Now building is happening here on any available piece of land without any regard to our rich environment of trees, plants, wild animals and birds.

It seems strange that this draft plan for so much housing goes against what we know about people needing more green space for their mental health.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

  1. what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);
  2. where the housing, roads and other buildings are going to be located; and
  3. the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and it crosses Vauxhall Lane in the south.  This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed –  maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7).  It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality 

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development.  Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc).  These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic.  Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided.  There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups.

There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt 

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge.  There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley.  All of it is in the Green Belt and it typifies the openness of the Green Belt.  Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided.  At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and  what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

  • the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
  • the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity 

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge.  It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls).  The gill woodlands and shaws provide important corridors, rich in biodiversity.  There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding 

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs.  This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

This development will put further pressure on the infrastructure in Southborough.  There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_4900

Sue Claxton

Object

I wish also to object to the late submitted plans for Mabledon AL/SO3 & AL/SO4.

Again this will affect Tonbridge more than other area, with increases in traffic and pollution and a loss of wildlife habitat. This is part of the Green Belt land that separates Tonbridge from Southborough and I can see no exception circumstances that require it to no longer be protected.  The A21 is a natural boundary for the town.  There are already several schools in the immediate vicinity and the consequent demands for public transport in south Tonbridge will put further strain on the towns resources.

As more land is concreted over the greater the threat of flooding to the area long term.  This cannot be sustainable and once done cannot be undone.  The A21 widening has already increased land use in this area, as well as increasing pollution in all it’s forms.  I implore TWBC to reconsider their plans.

DLP_4977

Planning and Transportation Committee
Southborough Town Council

 

Thank you for the opportunity to comment on the draft Tunbridge Wells Local Plan. This letter sets out the comments made by the Town Council as its Full Council Meeting held on 31 October 2019.

The Town Council would like to make comments on two polices being ALSO3 and ALSO4. Mention was also made that under section 5.53 this would appear to be technically incorrect.

POLICY ALSO3 Comments are as follows:

1. Councillors expressed concern that the proposed developments at Mabledon Farm were moving outside of the urban area of Southborough and into an area of AONB. This would mean no clear definition between Tonbridge/ Southborough/ Tunbridge Wells. With a general Urban sprawl being developed.

2. Councillors expressed concern over the additional serious traffic implications for both pedestrians and cyclists on an already extremely busy A26.

Where will the access points be onto and off of an already dangerous highway? And how will this affect the road use for pedestrians and cyclists. There are further concerns for other road users trying to access onto and off of an already busy highway.

3. Councillors expressed concerns over the potential increase in Air Pollution in An area that is already of concern with the levels of air pollution.

4. Councillors are concerned that there is no clear definition of where the proposed development is supposed to be placed the site is in an area of some 171 hectares. The vagueness of the policy means that they are unable to truly determine the effect the proposed 50 properties would have. The policy needs to be more direct so the full impact can be assessed.

Thank you again for the opportunity to comment and I trust that this Council will be kept fully appraised of any alterations or further comment opportunities.

DLP_5041

Mr A Richards

Object

I object to the proposal to develop house on the Site (AL/S03) Mabledon & Nightingale

On the following grounds:

It is on the Green Belt.

It is an AONB & heritage site.

It will increase traffic volumes.

It will have an adverse environmental impact & air quality.

It has fauna and flora that should be protected.

DLP_5267

Tunbridge Wells Friends of the Earth

Object

Policy Number:  AL/SO 3

Object to new development in the Green Belt.

DLP_5434

Susan Killick

Object

It has been brought to my attention that Mabledon and farms in the area of the A26 have been included in the Tunbridge Wells Plan.

I wish to lodge the strongest possible objection to the use of farming land for housing development, the increase in housing provision without thought of basic needs in life - doctors, schools etc.   More housing will only drag more people into an already overcrowded area depleting green belt country.

At a time when this country may have to stand alone then farming becomes more than important if we are to feed everyone.

The only gainers in the proposals will be  a) greedy landowners and b) even more greedier developers who have no connection or understanding of the area.

If this proposal was to be advanced then Tonbridge would be considered by some as simply a suburb of  Tunbridge Wells.  If Tunbridge Wells wants to expand then there is a vast area of common within the town plus various parks.

DLP_5718

Joe Hale

Object

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

Additionally, I am writing to object to the Mabledon & Nightingale Proposals.

I strongly object to the plans for additional housing in the Capel, Tudeley and Hangman's Hill.

There is no local appetite to build on the Green Belt land in the Borough of Tunbridge Wells. The Mabledon and Nightingale Proposals are advocating the construction of 120 dwellings in the 'Protected' High Weald Area of Outstanding Natural Beauty. This land should be protected, as it acts as a buffer zone between the Tunbridge Wells and Tonbridge Connurbations and is a Beautiful, Uninterupted site, following the local valley like landscape.

If the plans go ahead, these connurbations will be joined, effectively creating one single huge Borough. The plans of the Tunbridge Wells Borough contradict the message and theory behind Green Belt Laws

The Proposals to create effectively a Tudeley New Town is absolutely Ludicrus, they do not respect the Local wishes, neither do they respect the AONB's, Green Belt Land and Flood Plains as advertised in the Borough's Local Plan. The area for the Proposed new Garden Village regularly floods, and lanes nearby would be totally stretched to capacity, when a flood would occur with the 2800 new homes, as the developments would be cut off completely in the event of the Medway bursting it's banks near Tudeley. The Fields nearby where the development is planned are mainly agricultural, and can become unusable when flooding occurs. Tonbridge town Centre is already overstretched, with the surrounding roads operating at Capacity regularly, A brand new secondary school would be proposed near Somerhill Estate, however this wouldnt succumb to the demand for school/GP Places nearby, pushing nearby already overstretched facilities to the maximum.

I wouldnt be objected to additional development's on the Matfield and Brenchley side of Paddock Wood, as additional infrastructure including an A228 Bypass and an A21 Improvement near Kipping's Cross.

Nearby to the Tunbridge Wells Town Centre, more dwellings should be alternatively built near the Existing Developments of Showfields, Ramslye and Hawkenbury, as there is sufficient space to regenerate the Southern Side of the Town Centre. These Communities would most benefit the additional homes, as there is an existing community there. Dwellings here wouldn't effect the local landscape of the town, Green Belt and the AONB. I would be very, very supportive of New Homes in this area of the town and Borough, compared to the Tudeley and Hangman's Hill proposals.

Nearby existing towns such as Maidstone and Hastings have engulfed previously quiet tranquil villages on the outskirts of town, making the Town Centre's a less appealing space to visit. I would not be pleased if more visitors decided to avoid the Tunbridge Wells area, due to an apparent short sited development programme that focussed on Housebuilding, making the developer's richer and the Town Centre and Beautiful Scenic spots nearby a less appealing space to live, work and visit!

DLP_5881

Ms Sally Moesgaard-Kjeldsen

Object

the prosed building between Mabeldon and Vauxhal Lane

I have already said that this proposal must not go through, why Southborough? we don't want to live in a concrete jungle. What about Crowborough, Hildenborough, etc.

DLP_6168

B. M. Broadbent

Object

Policy Number:  AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455) 

OBJECT to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings and support the views expressed by other residents involved with the ‘Hangman’s Hill’ Residents Association with respect to the environment. Notably with respect to the environment.

The AONB and Green Belt should be respected for once development starts Southborough and Tonbridge will become joined. This is highly undesirable and the changes to infrastructure would ruin the rest.

The proposed development would merely be the ‘thin end of the wedge’ for a much larger development eroding the Green Belt and AONB – both designations intended to prevent the sort of development being proposed.

The traffic load generated would clearly fall largely on the already congested Tonbridge ring road and Pembury Road in Tonbridge. And increase the demand for parking in Tonbridge by commuters. TWBC is attempting to meet its targets by putting the burden on a neighbouring borough.

The A26 already carries traffic at greater than normally acceptable levels of traffic and minor interruptions causes huge tailbacks very quickly onto the A21 and down Quarry Hill into Tonbridge. On such occasions the one mile up Quarry Hill to my home (< 1 mile) can take 15 minutes or more as an example. At the Public Enquiry into the proposal for a Park and Ride site at Mabledon Farm the KCC engineers and TWBC staff described the A26 as saturated. That was 13 years ago and peak flows then at rush hour are now being experienced outside rush hour. Peak period flows have noticeably increased substantially. Back then peak flow was around one vehicle every 2.5 seconds, now it seems that vehicles are virtually nose to tail without adequate stopping distance between vehicles.

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues. This cannot be a sensible plan.

DLP_6223

Amy Togher

Object

Policy Number:  AL/SO 3

Land at Mabledon and Nightingale (SHELAA reference: Site 455)

object to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

Green Belt

This 171-hectare space of Green Belt land is the last buffer between Tonbridge and Tunbridge Wells. Green Belt policy was created precisely for preventing this type of urban sprawl development which would result in the coalescence of town and city. Giving the go-ahead to a development “not to exceed 120 dwellings during this plan period” (Policy point 7) sets a dangerous precedent; a slippery slope which opens the door to even more extensive development on this site in the future. The council must draw a line in the sand now to honour national planning policy and give the Green Belt the respect it deserves.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

Myself and other residents disagree with the council’s conclusion that this release of Green Belt land is justified by exceptional circumstances. No exceptional circumstances have been demonstrated in the local plan. Housing need is not an exceptional circumstance. The government has been very clear that a “brownfield first” approach should be followed, consulting with neighbouring boroughs if required to satisfy housing supply needs. Stating that “the release of Green Belt land” is a strategic objective for the Local Plan demonstrates that the council is not taking the right approach.

AONB & Heritage Assets

The proposed allocation for a major development in the AONB goes directly against the key objectives of the High Weald AONB Management Plan agreed by the Council. It is the council’s duty to preserve AONB & their biodiversity and protect Heritage Assets. I urge councillors to read the outstanding article by the High Brooms Society on the history of the Southborough valley. They describe it as a “countryside of such loveliness that it takes your breath away; where one sees nothing but beautiful woods, green fields on slopes and wild flowers, embraced by the undulating lap of the High Weald of Kent.”  The Society goes on to say that “the walk from Southborough to the Vauxhall Inn through the valley has been recently named as one of the Great British Walks.” King George III came here to shoot game. While the Duke of Wellington came for foxes.

In fact, this is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge.  It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls).  The gill woodlands and shaws provide important corridors, rich in biodiversity.  There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

  • the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
  • the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Has TWBC consulted with the AONB Forum of the High Weald AONB in relation to the site? The narrative in the local plan is unclear and unacceptably vague on this and number of other points.

As this landscape offers a connection both to nature and our shared history, I ask the council not to allow its destruction.

Flooding 

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs.  This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

The location of this site is on the borough boundary of Tonbridge & Tunbridge Wells, and Tonbridge & Malling Borough Council have raised “serious concerns” about the TWBC Local Plan. Specifically, that "the proximity of some of the major development proposals to the borough boundary and specifically, the south east of our main settlement of Tonbridge, is a matter of serious concern due to the potential impacts on the local highway network, rail services and other community infrastructure including health care and education, particularly when combined with planned developments in Tonbridge as part of our own Local Plan."

Despite the fact that Tonbridge train station, high street, supermarket, and associated car parks are closer than any TWBC alternative, none of the council tax revenue from these new homes would support infrastructure in Tonbridge, a fundamental flaw in the planning process which must be addressed.

This is snapshot of the current rush hour traffic ques in all directions on the Tonbridge side.

The fact that Highways concerns were not raised in the Mabledon/Nightingale evaluation is further evidence of the lack of due care being shown to the residents of Tonbridge and another example of flawed planning.

This development will also put further pressure on the infrastructure in Southborough.  There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

A26 -Traffic and Air Quality 

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development.  Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc).  These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic.  Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided.  There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups.

There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

In conclusion, while I appreciate the great challenge of meeting future housing needs, the convenience of partnering with a single landowner does not override the council’s obligations to national policy and the residents of Southborough & Tonbridge.

DLP_6242

Matthias Koslowski

Object

Policy Number:  AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455) 

I am objecting to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential dwellings.

I am having several concerns:

  1. Lack of clarity in the Draft Local Plan

    The Draft local Plan is vague and unclear on several aspects, including the size and the scheme of the development, and the actual locations of the dwellings, the roads and the community facilities.

    The boundaries of the site are unclear on the Policy map (Map 35, p148) as is the question of how much of the development would involve the Green Belt and/or AONB.

    The proposed allocated area for the development is very big, 171 hectares, which is far too big for 120 houses. Much of the space would be unused for the currently proposed development but would be an open invitation for further developments in the future.

  2. A26 -Traffic and Air Quality 

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

The A26 is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development.  Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. An access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

It is already dangerous to cycle on the A26. There are no cycle tracks. There is only a narrow pavement for pedestrians on one side of the road; and there are very few opportunities for pedestrians to cross the road. Vehicles regularly exceed the 40mph speed limit on the Tonbridge bound side just before joining the A21. Any increase in traffic on the A26, combined with additional access roads for the proposed development and the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House, would endanger the health and the life of cyclists and pedestrians even further. The Draft local Plan has not given enough consideration to how to combat the impact of an increase in traffic on cyclists and pedestrians.

Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

3. Green Belt 

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge.  There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley.  All of it is in the Green. The strip is less than a mile wide but conversion of the small number of heritage farm buildings into homes has already taken place within the site. It is therefore very important that the Green Belt continues to be protected from inappropriate development.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

4. AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB). Its spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options. As already mentioned, the proposed allocated area for the development is very big, 171 hectares, which is far too big for 120 houses.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and  what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

  • the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
  • the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

5. Ecology and Biodiversity 

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge.  It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls).

The gill woodlands provide important corridors of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), and provide natural habitat for plants and animals.  There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat for animals and plants.

6. Flooding 

The proposed area becomes already rapidly waterlogged in periods of heavy. It is likely that a new development at that site would reduce the size of permeable surface. That would increase the risk of serious flooding of the proposed development area.

7. Infrastructure

This development will put further pressure on the infrastructure in Southborough.  There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

DLP_6315

Emma Stroud

Object

Policy Number: AL/SO 3

Land at Mabledon and Nightingale (SHELAA reference: Site 455)

object to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

Green Belt

This 171-hectare space of Green Belt land is the last buffer between Tonbridge and Tunbridge Wells. Green Belt policy was created precisely for preventing this type of urban sprawl development which would result in the coalescence of town and city. Giving the go-ahead to a development “not to exceed 120 dwellings during this plan period” (Policy point 7) sets a dangerous precedent; a slippery slope which opens the door to even more extensive development on this site in the future. The council must draw a line in the sand now to honour national planning policy and give the Green Belt the respect it deserves.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

Myself and other residents disagree with the council’s conclusion that this release of Green Belt land is justified by exceptional circumstances. No exceptional circumstances have been demonstrated in the local plan. Housing need is not an exceptional circumstance. The government has been very clear that a “brownfield first” approach should be followed, consulting with neighbouring boroughs if required to satisfy housing supply needs. Stating that “the release of Green Belt land” is a strategic objective for the Local Plan demonstrates that the council is not taking the right approach.

AONB & Heritage Assets

The proposed allocation for a major development in the AONB goes directly against the key objectives of the High Weald AONB Management Plan agreed by the CouncilIt is the council’s duty to preserve AONB & their biodiversity and protect Heritage Assets. I urge councillors to read the outstanding article by the High Brooms Society on the history of the Southborough valley. They describe it as a “countryside of such loveliness that it takes your breath away; where one sees nothing but beautiful woods, green fields on slopes and wild flowers, embraced by the undulating lap of the High Weald of Kent.” The Society goes on to say that “the walk from Southborough to the Vauxhall Inn through the valley has been recently named as one of the Great British Walks.” King George III came here to shoot game. While the Duke of Wellington came for foxes.

In fact, this is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and

* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Has TWBC consulted with the AONB Forum of the High Weald AONB in relation to the site? The narrative in the local plan is unclear and unacceptably vague on this and number of other points.

As this landscape offers a connection both to nature and our shared history, I ask the council not to allow its destruction.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces. The news from Sheffield this weekend of unprecedented rainfall should give us pause to consider how climate change will increase flooding risk in the future.

Infrastructure

The location of this site is on the borough boundary of Tonbridge & Tunbridge Wells, and Tonbridge & Malling Borough Council have raised “serious concerns” about the TWBC Local Plan. Specifically, that "the proximity of some of the major development proposals to the borough boundary and specifically, the south east of our main settlement of Tonbridge, is a matter of serious concern due to the potential impacts on the local highway network, rail services and other community infrastructure including health care and education, particularly when combined with planned developments in Tonbridge as part of our own Local Plan."

Despite the fact that Tonbridge train station, high street, supermarket, and associated car parks are closer than any TWBC alternative, none of the council tax revenue from these new homes would support infrastructure in Tonbridge, a fundamental flaw in the planning process which must be addressed.

This is snapshot of the current rush hour traffic ques in all directions on the Tonbridge side.

(see image for map)

The fact that Highways concerns were not raised in the Mabledon/Nightingale evaluation is further evidence of the lack of due care being shown to the residents of Tonbridge and another example of flawed planning.

This development will also put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

In conclusion, while I appreciate the great challenge of meeting future housing needs, the convenience of partnering with a single landowner does not override the council’s obligations to national policy and the residents of Southborough & Tonbridge.

DLP_6343

Simon Byerley

Object

Policy Number:  AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I strongly object to the proposed allocation of AL/SO 3 Land at Mabledon and Nightingale for a mixed use scheme to include land-based economic development and approximately 50-120 residential dwellings on the basis of

  • the lack of clarity in the Draft Local Plan documentation set regarding the proposal;
  • the potential for inappropriate development in the AONB and the Green Belt;
  • increased traffic congestion on the A26, including in the Southborough AQMA and
  • environmental impacts.

1. Lack of Clarity regarding the Proposal

I am surprised that TWBC have seen fit to include as a proposed allocation where there appears to be

a) confusion as to where the site is :

* Draft Local Plan para 5.53 incorrectly states that it is the Main Urban Area, and this is error is repeated or implied in a number of the Supporting Documents

b) lack of clarity as to the extent of development proposed apart from housing:

* Buildings for land based economic development (policy point 8b) – what and how many?

* Community facilities including buildings (policy point 8c) – what and how many?

* Utility cycle tracks within the site to link to Southborough and Tonbridge, which will be tarmacked and lit for safety reasons

* roads within the site to link “scattered forms of development”

* buildings and spaces to provide cultural infrastructure (Exhibition Board 19)

c) a need for additional studies to determine where developments (housing and other) could be located while still avoiding the multitude of constraints;

* much of the allocated area was put forward in the 2016 Call for Sites (Sites: 179 - Mabledon Farm, 180 - Nightingale Farm and 181 – Moatenden)

* the environmental and landscape constraints are well covered in the relevant Environment & Landscape Supporting Documents on the Local Plan website.

d) no calculation of what land take will be required for the developments.

* The site boundaries are not shown on the policy maps however ee note from the SHELAA (Site reference 445 – 16. Southborough Sites) that the site is approximately 171 hectares.

* the 50-120 dwelling proposed for the current plan period in Policy AL/SO3 would only require 8 hectares using a density of 15 dwellings per hectare for a mixed use development or 3 hectares using a density of 40 dwellings per hectare on a greenfield site.

e) Valuing our natural assets as part of the national ecosystem services approach is key to truly determining the environmental economic value of these sites. I urge you, as part of the options process, to undertake a valuation assessment on all the green belt options. Then you will be truly informed of the environmental cost to the Borough that would occur if these important green assets were subject to development.

I consider that the vagueness of this proposed allocation simply establishes that development in this area is acceptable to TWBC, setting a dangerous precedent for the future.   Our very serious concern it the landowners (the Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed.  The “Potential yield if residential” in the SHELAA should reflect that the stated developable area is 125 hectares giving a potential yield of 1,875 dwellings using a  density 15 dwellings per hectare for a mixed-use development,  or 5,000 dwellings using a density of 40 dwellings per hectare on a greenfield site.

A planning application has recently (August 2019) been submitted by the landowner for one small part of the site (19/02361 Moatenden - 1.14 hectares) which cites the lack of a 5-year housing supply.  What is to stop further applications for other areas at any point in the future when Tunbridge Wells cannot demonstrate a 5-year housing supply? Additionally, approximately a quarter of the site is in the borough of Tonbridge and Malling, and includes direct access from Vauxhall Lane within that borough, giving further options for development.

Until the location(s) and extent of development are confirmed it is premature to propose allocating this site in the Draft Local Plan.

2. High Weald AONB

I am very concerned that the reasons for allocating this site for housing development are not clearly set out in the Draft Local Plan documentation set.  From the information provided this allocation is likely to cause significant harm to the character of the AONB and there are no “exceptional circumstances” as defined in the NPPF paragraph 172.

a) Assessment of harm to AONB Character

From a landscape perspective this site is rural in nature and forms a strategic gap between Tonbridge and Southborough.  It lies within sub areas SP5 and SP6 in the 2017 Landscape Sensitivity Assessment of Countryside around Tunbridge Wells and this report highlights the many landscape features typical of the High Weald AONB.  Both areas are assessed as having a high sensitivity to any scale of development.  The report does suggest that, within sub area SP5 “there may be pockets of land associated with existing development where sensitivity to small-scale development could be relatively contained in the wider landscape” but does not specify where these pockets might be. Mabledon Farm is the only existing development that is both within the allocated site and sub-area SP5, suggesting that a scattered development would not satisfy this requirement.

The Southborough section of the Historic Landscape Characterisation gives further evidence of the historic importance of this site.  The main report highlights that “whilst dispersed plans may offer opportunities for additional dwellings, the very process can easily destroy the historic layout and character of the farmstead” (para 4.1, Section 1 – User Guide  & Interpretation).  Mabledon Farm is a historic farmstead, with fields and traditional orchards close to it.

The conclusions in these reports are reflected in the assessment of High Impact on the AONB in the Distribution of Development Topic Paper (App. 3: Assessment of AONB Sites - Site Policy Ref SO 3).

In the light of the above, I question why the Council chose to support the development proposal for Mabledon/Nightingale and include an allocation for this site in the Draft Local Plan.   Paragraph 6.85 of the Distribution of Development Topic Paper states that “where development is considered likely to cause significant harm to the defining character of the AONB (also having regard to potential mitigation) or cause harm disproportionate to likely benefits of the scheme, then that development will be very unlikely to be supported”.  

The mitigation proposed for this development appears to be the “farmstead approach” which is nowhere defined nor expanded upon.  The suggestion in the Distribution of Development Topic Paper  (App 3) that there is “a very restrictive policy requiring positive landscape outcomes” is simply untrue.   The only restriction in the Policy for AL/SO 3 is that housing development will be limited to 120 dwellings in this plan period.  As the Council specifically exclude sites allocated in the local plan from the provisions of Policy EN21,  and the AONB Joint Advisory Committee’s role in the development will only be to provide “input to the vision and design process”, there appear to be no restrictions in Policy AL/SO 3 to protect the landscape from inappropriate development.

b) Major development in AONB

The Distribution of Development Topic Paper highlights the provisions of the NPPF with regard to AONBs (para 3.8 – 3.11)  and suggests that TWBC believe that the proposed development is likely to be classed as major development in the AONB, highlighting that its scale is “very substantial” relative to the existing settlement. (App. 3: Assessment of AONB Sites - Site Policy Ref SO 3,  Distribution of Development Topic Paper)

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. Consideration of such applications should include an assessment of:

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”.

It is nonsensical for the Council to present an assessment of major developments within the AONB against the NPPF requirements as a single entity, as is done in the table under Para 6.101 in the Distribution of Development Topic Paper. The individual site level assessments are not described in in the Distribution of Development Topic Paper or the SHELAA.  We are concerned therefore that no evidence is given of the “exceptional circumstances” specific to the proposed AL/SO3 allocation;  in particular we cannot see that the need for up to 120 dwellings could not be met in some other way within the borough as a whole, with the council already proposing to allocate 9% more housing than required by the OAN calculations.

I also question the Council’s reliance on “unique circumstances” as justification referenced throughout the Draft Local Plan document set.  These appear to be that a farmstead (Mabledon Farm) and its surrounding land are in a single ownership.  It is a very disturbing statement on the state of a predominantly rural borough if this is true!

In conclusion I can see no justification for the proposed allocation for development of this large site in the AONB.  The Distribution of Development Topic Paper para 6.89 supports the view that this proposal should have been rejected by the Council as not being a “reasonable option”.

Green Belt

AL/SO3 provides the one-mile wide Green Belt separation east of the A26 between the built-up areas of Southborough and Tonbridge. Housing development here would be contrary to the purposes of the Green Belt as set out in paragraphs 133-134 of the NPPF:

“The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

Green Belt serves five purposes:

a) to check the unrestricted sprawl of large built-up areas;

b) to prevent neighbouring towns merging into one another;

c) to assist in safeguarding the countryside from encroachment;

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

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

In the Stage 2 TWBC Green Belt Study this site falls within Broad Area 1, I assume due to its rural nature. BA1 is assessed as making a STRONG contribution to each of the Green Belt purposes a) through d).

It is unclear what assessments of the potential for harm to this area of Green Belt the Council have carried out in proposing this allocation. The Green Belt designation is not included in the “Issues to consider” section of the SHELAA (Site ref 445 – Section 16. Southborough Site) and we cannot find any discussion of the reasons behind the decision that this site should remain in the Green Belt.  The Assessment of Green Belt Sites (App 1 Distribution of Development Topic Paper) has N/A for

  • Allocation Area within MGB
  • Hectares to remove from MGB
  • Site Size
  • Site % in MGB
  • Housing Min as % of site in MGB
  • Housing Max as % of site in MGB

As this table also has the housing numbers and masterplanning for AL/SO3 shown under SO4 (the hotel/leisure development, we can only assume that no consideration at all has been given to Green Belt purposes in allocating this site.  I suggest that the intent in the NPPF is to protect the Green Belt from inappropriate development, not to allow unconstrained development simply by the Council declaring that a developed site will remain in the Green Belt. In this instance it seems as if the Council has simply avoided the need to demonstrate “exceptional circumstances” by ignoring the sites contribution to the Green Belt purposes.

Without knowing the location and extent of development it is impossible to say what impact the proposed developments would have on the openness of this area of the Green Belt.  There are views into the site from a variety of locations - the A26, a PROW to Haysden (higher up the ridge) or the footpath near the Cottage Hospital (lower down the valley).  Any development at the southern end of the site would be visible from Vauxhall Lane (a designated Rural Lane) and the Tunbridge Wells Circular Walk.

3. Transport and Active Travel

a) Congestion and Air Quality

I am very concerned that additional traffic from this new development will simply exacerbate the existing congestion and air quality on the section of the A26 near the site and in the nearby AGMA in Southborough.  The situation will be made even worse by the volume of traffic likely to be generated by the proposed hotel and leisure complex at Mabledon House (AL/SO3).  We are unsure how the smart traffic management system proposed in the Transport Evidence Base, synchronising traffic lights, will improve the traffic flows on the A26 past the Mabledon/Nightingale site when there are no traffic lights here and the speed limit is 40mph, 10mph higher than the speed limit in the urban area of Southborough.  Additionally, this is a single-carriageway road with traffic halted by buses picking up/dropping off passengers and vehicles slowing or stopping to turn into private driveways.

b) Safety

The Policy for AL/SO3 requires “safe and acceptable access arrangements from the A26 for the proposed development with, where required, a secondary emergency access”. (policy point 1).

We note that the junction performance assessment for AL/SO3 allocation in the Transport Evidence Base was carried out based upon 100 dwellings accessing the A26 via Vauxhall Lane.  I am confused by this approach as Vauxhall Lane is at the opposite end of the site to Mabledon Farm on which the development would be centred. Vauxhall Lane is a narrow lane with complex topography and a “blind” junction with the A26; it is totally unsuited to such an increase in traffic.

The more obvious access to the A26 would be through upgrading the current PROW from Mabledon Farm to the A26.  Unfortunately this would result in traffic leaving/joining the A26 in close proximity to the access to the proposed hotel and leisure complex at Mabledon House (AL/SO4).  This stretch of road has a 40mph speed limit and this limit is frequently exceeded as vehicles approach the slip road to the A21.  It is unclear how traffic from the new development could safely pull out onto the A26. We believe that traffic lights would only serve to increase congestion and air pollution, by halting the flow of traffic on the A26 while construction of a roundabout would have a material impact on the character of the AONB landscape (as would any widening of the A26).

Safe and acceptable pedestrian and cycle linkages to Southborough are also required (policy point 2).   At this stage we feel that there is too little information available re Scheme 404 (Cycling corridor and rights of way between Tunbridge Wells and Tonbridge) which appears to be the route that would serve the development at AL/SO 3, and will comment when the Walking and Cycling Strategy is published.

Pedestrian access to Southborough and Tonbridge via the A26 is not safe and I see no indications that any improvements are proposed in the Draft Local Plan. There is a narrow pavement on only one side of the road and there are no controlled pedestrian crossings.  Traffic speeds make walking here both unpleasant and unsafe.  Getting to a bus stop on the other side of the road involves jaywalking through 40mph traffic – not safe for anyone, but impossible for the elderly or those with young children.  Cars will continue to be used for the majority of journeys.

4. Land-based economic development and rural life

The proposed housing development is neither connected to, nor essential for, land based economic development on this site and it is unclear why the housing element has been included in the allocation.

I believe that the majority of the land within the site is leased to two tenant farmers and has been used in recent years as grazing for cattle, sheep, and horses stabled at the Honiton Equestrian Centre (south of Vauxhall Lane, and not itself included within this site).  The informal tracks within the site have also been used for exercising horses from the Honiton Equestrian Centre. The landowners already have an obligation to improve (for the 25 years) some of the agricultural land on this site under an S106 agreement in November 2014 in relation to the planning application 14/00870 for a Solar Park on other land which they own.

Obviously I cannot comment on the current economic viability of the agricultural uses on this site.  However I have not seen any evidence in the DLP document set that there is a need for affordable housing (and other infrastructure and amenities) for rural communities on this site to meet Objective LBE2 in the High Weald AONB Management Plan nor that erection of rural workers dwellings here would be essential under the provisions of Policy H10 in the Draft Local Plan.

In relation to the proposed land-based economic development per se, in addition to the Development Management Policies already referenced in point 8f of Policy AL/SO 3 as a minimum the following should also apply: EN22, ED4, ED5, ED6 and ED7.  I am also surprised that there is no requirement for supporting woodland management and rural crafts as set out in the “Statement of Significance” in the High Weald AONB Management Plan (and quoted in the Distribution of Development Paper)

5. Ecology and Biodiversity

I believe that the potential impact of the proposed development on ecology and biodiversity has been seriously underestimated in the Draft Local Plan. The site includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a wide variety of species. The gill woodlands and shaws provide important corridors for wildlife and are rich in biodiversity.  There are traditional orchards, now a rare habitat.  In addition the site is on a green corridor of Ancient Woodland (Coxon Wood, Beeches Wood, Nightingale Wood and Minepit Wood ) which provides a natural habitat for plants, animals and birds.  The Dark Skies provide an essential haven for nocturnal wildlife; at night owls can be heard hooting, foxes calling and badgers foraging.

It is unclear how development here would protect and enhance biodiversity and geodiversity.

6. Heritage Assets

The impact of the proposed development on listed buildings and other heritage assets within or bordering the site does not appear to have been assessed.

7. Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain with run-off from the A26 and higher ground. There is network of underground streams and springs in addition to the visible stream and ponds within the site.  This is not ideal land for development and will be made worse by the creation of additional impermeable surfaces for housing, roadways etc.

8. Infrastructure 

This development will put further pressure on the infrastructure in Southborough.  There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_6370

Ms Margaret Borland

Object

Policy Number:  AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455) 

I strongly object to the proposed allocation for a mixed-use scheme to include land-based economic development and approximately 50-120 residential dwellings.

Even after reading many of the Topic Papers and Supporting Documents the proposal still appears to be very immature.  It is not clear to me

i) what the proposed extended settlement will ultimately be - a new hamlet, a new village or several new “farmsteads” scattered around the site;

ii) where within the site the housing and other buildings are going to be located – “centred on Mabledon farm” is a very vague description for locations in a very large site; and

iii) how much land take is expected to be required for the proposed developments, taking into account community buildings, buildings for land-based economic development and roads and cycleways within the overall site.

The size of the site is effectively hidden as its boundaries are not shown on the Policy map (Map 35, p148 and the DLP Policies Maps document).   I raised this point at the Council Cabinet meeting on 15th August and so am disappointed that the only change made has been to increase the size of star marking an apparently random location within the site.  Why was the map in the SHELAA (Site 445) or the one in the SA not used not used? I can’t find any other allocations for developments that are only marked like this in the Draft Local Plan.   Looking at the Draft Local Plan itself and the Exhibition Boards who would know that the proposed allocation is for a very large area – 171 hectares (roughly equivalent to 250 football pitches) stretching from the A21 to the  northmost corner the Southborough LBD,  between the A26 and the railway line? Certainly, very few of the nearby residents knew until it was highlighted by the local Residents Association.

I feel it’s unacceptable to include such a vague proposal in the Regulation 18 Draft Local Plan  The site was put forward in the 2017 Call for Sites, and is an amalgamation and extension of 3 sites included in the Issues and Options Consultation.  If possible location(s) and extent of development have not been assessed in the intervening 2 years, I don’t see how the Council can credibly claim that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will not impact the AONB landscape,  the openness of the Green Belt,  the Ancient Woodland, the Heritage Assets and the designated Local Wildlife Site (to name but a few of the constraints).

Including this allocation in the Draft Local Plan just establishes that development on this protected and environmentally important land is acceptable to TWBC, and sets a dangerous precedent for future development.  The landowners of the site (The Hadlow Estate) or developers could look to profit from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7).  It is unclear as to whether even this time-limited constraint will apply if TWBC continues to be unable to show a five-year housing supply and whether any restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

There is little information as to what the proposed masterplanning would involve,  unlike other site allocations in this Draft Local Plan, once again highlighting the lack of clarity in this proposed Allocation Policy.

A26 -Traffic Congestion, Air Quality and Safety 

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and increasing unacceptably high air pollution.

This is already such a busy road that I’m struggling to envisage how “safe and acceptable access arrangements from the A26” (Policy point 1) could be provided for the proposed development.  Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in homes near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21.  Even slowing down to turn left into a driveway is dangerous – vehicles following either only brake at the very last moment (flashing their lights in complaint) or pull into the opposite carriageway to get past, risking collision with on-coming traffic.  There are no speed safety measures (cameras / speed registers etc), and no traffic lights or pedestrian crossings to act as informal constraints on speed.

These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road as well as traffic to/from the A21 slip roads and Quarry Hill; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26 and already over-used as a cut through between Southborough and the Vauxhall interchange to avoid traffic jams in Tonbridge; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into a new development - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the A26 carriageway waiting for a gap in high-volume fast-moving traffic.  Traffic queues will stretch back into the Air Quality Management Area of Southborough and Royal Tunbridge Wells and into Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26 from the new developments.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided.

There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. The new cycle route between Southborough and Tonbridge that is proposed in the Transport Evidence Base (roughly following the railway line)  appears to include a section of Vauxhall Lane which is single track with passing places and already has a high volume of cars using it as a cut through at peak times

There are no pedestrian crossings on the A26 near the proposed development site. Two small traffic islands in a 1 mile stretch of road do not allow safe crossing for anyone but groups of school children, the elderly and those with young children are particularly disadvantaged.  There is a narrow pavement on only one side of the road which is poorly maintained and unsafe, with cars and HGVs passing at high speed, and is unpleasant due to noise and exhaust fumes.  Add this to steep gradients within the site and it is clear that cars will inevitably be the preferred mode of travel for new residents.

The serious impact on the safety, health and wellbeing of residents over a wide area must be taken into account by the Council when considering whether to take this proposal forward.

Green Belt 

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge.  There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley.  All of it is in the Green Belt and it typifies the openness of the Green Belt.  Conversion of a small number of heritage farm buildings into homes took place a number of years ago and the homes alongside the A26, which are not within the site, pre-date the Green Belt designation.

The strip is less than a mile wide and is the Green Belt separation between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow band of green, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas).    However Green Belt designation does not appear as one of the “Issues to Consider” in the SHEELA.

Surely it is premature for the Council to conclude that this proposed development is not in conflict with the purposes of the Green Belt and therefore will not require a change to the Green Belt boundaries?   Without knowing location(s) and extent of development this is a leap of faith rather than an evidence-based assessment.

AONB

The site is wholly within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on this site will mean irreversible loss of historic landscapes and will totally change the character of the area.

The various Supporting Documents conclude that development here would be harmful, highlighting that:

  • the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
  • the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper)

The Council suggest that this is a major development within the AONB, but them make no attempt to explain what are the “exceptional circumstances” (NPPF para. 172) that would support development on this site and how the associated tests have been applied.

Instead there are various references in the Draft Local Plan document set to “unique circumstances” and a “farmstead approach”, apparently as justification for a major development in the AONB, but what exactly these are is nowhere explained nor expanded upon.  There is no evidence provided of the capacity for change of the two farmsteads within the site based upon their character, their significance or their sensitivity (Farmsteads Assessment Guidance Summary and SPD) in relation to the proposed developments.

With such high sensitivity to development and in the absence of an assessment of how this proposed development would meet the objectives set out in the High Weald AONB Management Plan, I feel that it is debateable whether this could be  “an exemplar scheme  inspired by the character of the High Weald” as suggested in the Draft Local Plan.

Heritage Assets

The impact of the proposed development on listed buildings within or near the site and their setting does not appear to have been assessed.  These include

  • Mabledon House on the opposite side of the A26, the home of and enlarged by Decimus Burton together with an Historic Park and Garden;
  • The Nightingales, an early 19th century farmhouse, adjoining the proposed site;
  • the Lodge of the former Great Bounds, and the Walls and Gate piers of the Entrance on the opposite side of the A26; and
  • the 17th Century Moat Farmhouse and its 19th century Barn, within the site to the south of Vauxhall Lane

Mabledon Farm (within the site) and Nightingale Farm and Oast (surrounded by the site but in separate private ownership) are also heritage assets. Vauxhall Lane is a designated Rural Lane and an historic routeway.   There are medieval field patterns and assart fields close to Mabledon Farm and extensive areas of Ancient Woodland.

How will development on this site ensure that these are “conserved and enhanced, and special regard will be had to their settings”?  (Policy STR8, point 8).  Policy AL/SO3 doesn’t even include the word heritage let alone a reference to this policy or policy EN7 Heritage Assets.

Ecology and Biodiversity 

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge.  It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of wildlife (deer, hedgehogs, badgers, foxes, stoats, weasels and voles) and birds (woodpeckers, owls, birds of prey, crows, robins, sparrows, wrens, blackbirds, thrushes, blue tits, coal tits, great tits, long-tailed tits). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

It is worrying that the Policy for AL/SO 3 does not include a reference to Development Management Policy EN11 Net Gains for Biodiversity.  Surely this should be an essential part of development management for proposed development on a greenfield site such as this one?

Flooding 

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs.  This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

This development will put further pressure on the infrastructure in Southborough.  There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_6371

Ruth & Paul Langridge

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);

ii) where the housing, roads and other buildings are going to be located; and

iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Vauxhall Lane

This 2-mile long road links the A26 with the A21 and consequently attracts an already absurdly high volume of rush hour traffic, with school traffic using it as a rat-run to reach all the Tonbridge schools. In the event of road works or accidents on either of these main roads, it quickly becomes even more congested. It is a pretty, leafy, narrow winding lane, completely unsuited to so much traffic, being poorly maintained, with disintegrating edges, ever-increasing potholes, and a semi-permanent flood on the dangerous bend opposite Honnington Farm due to a drain that is seldom cleared, with a concrete surround that is constantly smashed by traffic trying to avoid on-coming vehicles. Should the Mabledon Farm development go ahead, cars in and out of the access road into Vauxhall Lane would increase traffic enormously. The Vauxhall Lane railway bridge below the Cottage Hospital is very narrow, and would need to be rebuilt to take lorries and extra traffic.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and

* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_6398

Saffron Bohan

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);
ii) where the housing, roads and other buildings are going to be located; and
iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children. My son has to cross this road when returning from school. It is already extremely concerning as there is no safe crossing place.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and

* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

My property has already flooded in December 2013 and this is something that concerns me.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_6418

Neil Bohan

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);
ii) where the housing, roads and other buildings are going to be located; and
iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children. My son has to cross this road when returning from school. It is already extremely concerning as there is no safe crossing place.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

My property has already flooded in December 2013 and this is something that concerns me.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_6444

Laura Weller

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);
ii) where the housing, roads and other buildings are going to be located; and
iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children. My son has to cross this road when returning from school. It is already extremely concerning as there is no safe crossing place.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

My property has already flooded in December 2013 and this is something that concerns me.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_6449

Linda Weller

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);
ii) where the housing, roads and other buildings are going to be located; and
iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children. My son has to cross this road when returning from school. It is already extremely concerning as there is no safe crossing place.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

My property has already flooded in December 2013 and this is something that concerns me.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_6460

Hangman's Hill Residents Association

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

The Hangman’s Hill Residents Association (HHRA)represents those living on or close to the section of London Road, Southborough (the A26) that is between Vauxhall Lane and Mabledon. We aim to play an active role in localism and shaping the future of Southborough and are particularly concerned with protecting the countryside that lies between the urban areas of Southborough and Tonbridge. This response from the HHRA Committee is based upon discussions with our membership and our analysis of the wider set of Draft Local Plan documentation.

The HHRA Committee strongly objects to the proposed allocation of AL/SO 3 Land at Mabledon and Nightingale for a mixed use scheme to include land-based economic development and approximately 50-120 residential dwellings on the basis of

  • the lack of clarity in the Draft Local Plan documentation set regarding the proposal;
  • the potential for inappropriate development in the AONB and the Green Belt;
  • increased traffic congestion on the A26, including in the Southborough AQMA and
  • environmental impacts.

1. Lack of Clarity regarding the Proposal

HHRA is surprised that TWBC have seen fit to include as a proposed allocation where there appears to be

a) confusion as to where the site is :

- Draft Local Plan para 5.53 incorrectly states that it is the Main Urban Area, and this

is error is repeated or implied in a number of the Supporting Documents

b) lack of clarity as to the extent of development proposed apart from housing:

- Buildings for land based economic development (policy point 8b) – what and how many?

- Community facilities including buildings (policy point 8c) – what and how many?

- utility cycle tracks within the site to link to Southborough and Tonbridge, hich will

be tarmacked and lit for safety reasons

- roads within the site to link “scattered forms of development”

- buildings and spaces to provide cultural infrastructure (Exhibition Board 19)

c) a need for additional studies to determine where developments (housing and other) could be located while still avoiding the multitude of constraints;

- much of the allocated area was put forward in the 2016 Call for Sites (Sites: 179 -

Mabledon Farm, 180 - Nightingale Farm and 181 – Moatenden)

- the environmental and landscape constraints are well covered in the relevant

Environment & Landscape Supporting Documents on the Local Plan website

d) no calculation of what land take will be required for the developments.

- The site boundaries are not shown on the policy maps however ee note from the

SHELAA (Site reference 445 – 16. Southborough Sites) that the site is approximately 171 hectares.

- the 50-120 dwelling proposed for the current plan period in Policy AL/SO3 would only require 8 hectares using a density of 15 dwellings per hectare for a mixed use development or 3 hectares using a density of 40 dwellings per hectare on a greenfield site.

We consider that the vagueness of this proposed allocation simply establishes that development in this area is acceptable to TWBC, setting a dangerous precedent for the future. Our very serious concern it the landowners (the Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed. The “Potential yield if residential” in the SHELAA should reflect that the stated developable area is 125 hectares giving a potential yield of 1,875 dwellings using a density 15 dwellings per hectare for a mixed-use development, or 5,000 dwellings using a density of 40 dwellings per hectare on a greenfield site.

A planning application has recently (August 2019) been submitted by the landowner for one small part of the site (19/02361 Moatenden - 1.14 hectares) which cites the lack of a 5-year housing supply. What is to stop further applications for other areas at any point in the future when Tunbridge Wells cannot demonstrate a 5-year housing supply? Additionally, approximately a quarter of the site is in the borough of Tonbridge and Malling, and includes direct access from Vauxhall Lane within that borough, giving further options for development.

Until the location(s) and extent of development are confirmed it is premature to propose allocating this site in the Draft Local Plan.

2. High Weald AONB

HHRA is very concerned that the reasons for allocating this site for housing development are not clearly set out in the Draft Local Plan documentation set. From the information provided this allocation is likely to cause significant harm to the character of the AONB and there are no “exceptional circumstances” as defined in the NPPF paragraph 172.

Additionally we have found no evidence to support the Council’s view that it will provide “an exemplar scheme inspired by the underlying historical character of the High Weald ” (although we have noticed that “exemplar” appears to be the buzzword for developments proposed by this landowner, who also owns the site at Tudeley which is proposed for the “Garden Village).

a) Assessment of harm to AONB Character

From a landscape perspective this site is rural in nature and forms a strategic gap between Tonbridge and Southborough. It lies within sub areas SP5 and SP6 in the 2017 Landscape Sensitivity Assessment of Countryside around Tunbridge Wells and this report highlights the many landscape features typical of the High Weald AONB. Both areas are assessed as having a high sensitivity to any scale of development. The report does suggest that, within sub area SP5 “there may be pockets of land associated with existing development where sensitivity to small-scale development could be relatively contained in the wider landscape” but does not specify where these pockets might be. Mabledon Farm is the only existing development that is both within the allocated site and sub-area SP5, suggesting that a scattered development would not satisfy this requirement.

The Southborough section of the Historic Landscape Characterisation gives further evidence of the historic importance of this site. The main report highlights that “whilst dispersed plans may offer opportunities for additional dwellings, the very process can easily destroy the historic layout and character of the farmstead” (para 4.1, Section 1 – User Guide & Interpretation). Mabledon Farm is a historic farmstead, with assart fields and traditional orchards close to it.

The conclusions in these reports are reflected in the assessment of High Impact on the AONB in the Distribution of Development Topic Paper (App. 3: Assessment of AONB Sites - Site Policy Ref SO 3).

In the light of the above, we question why the Council chose to support the development proposal for Mabledon/Nightingale and include an allocation for this site in the Draft Local Plan. Paragraph

6.85 of the Distribution of Development Topic Paper states that “where development is considered likely to cause significant harm to the defining character of the AONB (also having regard to potential  mitigation) or cause harm disproportionate to likely benefits of the scheme, then that development will be very unlikely to be supported”.

The mitigation proposed for this development appears to be the “farmstead approach” which is nowhere defined nor expanded upon. The suggestion in the Distribution of Development Topic Paper (App 3) that there is “ a very restrictive policy requiring positive landscape outcomes ” is simply untrue. The only restriction in the Policy for AL/SO 3 is that housing development will be limited to 120 dwellings in this plan period. As the Council specifically exclude sites allocated in

the local plan from the provisions of Policy EN21, and the AONB Joint Advisory Committee’s role in the development will only be to provide “ input to the vision and design process” , there appear to be no restrictions in Policy AL/SO 3 to protect the landscape from  inappropriate development.

b) Major development in AONB

The Distribution of Development Topic Paper highlights the provisions of the NPPF with regard to AONBs (para 3.8 – 3.11) and suggests that TWBC believe that the proposed development is likely to be classed as major development in theAONB, highlighting that its scale is “very substantial” relative to the existing settlement.(App. 3: Assessment of AONB Sites - Site Policy Ref SO 3, Distribution of Development Topic Paper)

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. Consideration of such applications should include an assessment of:

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”.

It is nonsensical for the Council to present an assessement of major developments within the AONB against the NPPF requirements as a single entity, as is done in the table under para 6.101 in the Distribution of Development Topic Paper. The individual site level assessments are not described in in the Distribution of Development Topic Paper or the SHELAA. We are concerned therefore that no

evidence is given of the “exceptional circumstances” specific to the proposed AL/SO3 allocation; in particular we cannot see that the need for up to 120 dwellings could not be met in some other way within the borough as a whole, with the council already proposing to allocate 9% more housing than required by the OAN calculations.

We also question the Council’s reliance on “unique circumstances” as justification referenced throughout the Draft Local Plan document set. These appear to be that a farmstead (Mabledon Farm) and its surrounding land are in a single ownership. It is a very disturbing statement on the state of a predominantly rural borough if this is true!

In conclusion we can see no justification for the proposed allocation for development of this large site in the AONB. The Distribution of Development Topic Paper para 6.89 supports the view that this proposal should have been rejected by the Council as not being a “reasonable option”.

Green Belt

AL/SO3 provides the one-mile wide Green Belt separation east of the A26 between the built-up areas of Southborough and Tonbridge. Housing development here would be contrary to the purposes of the Green Belt as set out in paragraphs 133-134 of the NPPF:

“The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

Green Belt serves five purposes:

a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

In the Stage 2 TWBC Green Belt Study this site falls within Broad Area 1, we assume due to its rural nature. BA1 is assessed as making a STRONG contribution to each of the Green Belt purposes a) through d).

It is unclear what assessments of the potential for harm to this area of Green Belt the Council have carried out in proposing this allocation. The Green Belt designation is not included in the “Issues to consider” section of the SHELAA (Site ref 445 – Section 16. Southborough Site) and we cannot find any discussion of the reasons behind the decision that this site should remain in the Green Belt. The Assessment of Green Belt Sites (App 1 Distribution of Development Topic Paper) has N/A for

● Allocation Area within MGB
● Hectares to remove from MGB
● Site Size
● Site % in MGB
● Housing Min as % of site in MGB

● Housing Max as % of site in MGB

As this table also has the housing numbers and masterplanning for AL/SO3 shown under SO4 (the hotel/leisure development, we can only assume that no consideration at all has been given to Green Belt purposes in allocating this site. We suggest that the intent in the NPPF is to protect the Green Belt from inappropriate development, not to allow unconstrained development simply by the Council declaring that a developed site will remain in the Green Belt. In this instance it seems as if the Council has simply avoided the need to demonstrate “exceptional circumstances” by ignoring the sites contribution to the Green Belt purposes.

Without knowing the location and extent of development it is impossible to say what impact the proposed developments would have on the openness of this area of the Green Belt. There are views into the site from a variety of locations - the A26, a PROW to Haysden (higher up the ridge) or the footpath near the Cottage Hospital (lower down the valley). Any development at the southern end of the site would be visible from Vauxhall Lane (a designated Rural Lane) and the Tunbridge Wells Circular Walk.

3. Transport and Active Travel

a) Congestion and Air Quality

We are very concerned that additional traffic from this new  development will simply exacerbate the existing congestion and air quality on the section of the A26 near the site and in the nearby AGMA in Southborough. The situation will be made even worse by the volume of traffic likely to be generated by the proposed hotel and leisure complex at Mabledon House (AL/SO3). We are unsure how the smart traffic management system proposed in the Transport Evidence Base, synchronising traffic lights, will improve the traffic flows on the A26 past the Mabledon/Nightingale site when there are no traffic lights here and the speed limit is 40mph, 10mph higher than the speed limit in the urban area of Southborough. Additionally, this is a single-carriageway road with traffic halted by buses picking up/dropping off passengers and vehicles slowing or stopping to turn into private driveways.

b) Safety

The Policy for AL/SO3 requires “safe and acceptable access arrangements from the A26 for the proposed development with, where required, a secondary emergency access” . (policy point 1). We note that the junction performance assessment for AL/SO3 allocation in the Transport Evidence Base was carried out based upon 100 dwellings accessing the A26 via Vauxhall Lane. We are confused by this approach as Vauxhall Lane is at the opposite end of the site to Mabledon Farm on which the development would be centred. Vauxhall Lane is a narrow lane with complex topography and a “blind” junction with the A26; it is totally unsuited to such an increase in traffic.

The more obvious access to the A26 would be through upgrading the current PROW from Mabledon Farm to the A26. Unfortunately this would result in traffic leaving/joining the A26 in close proximity to the access to the proposed hotel and leisure complex at Mabledon House (AL/SO4). This stretch of road has a 40mph speed limit and this limit is frequently exceeded as vehicles approach the slip road to the A21. It is unclear how traffic from the new development could safely pull out onto the A26. We believe that traffic lights would only serve to increase congestion and air pollution, by halting the flow of traffic on the A26 while construction of a roundabout would have a material impact on the character of the AONB landscape (as would any widening of the A26).

Safe and acceptable pedestrian and cycle linkages to Southborough are also required(policy point 2). At this stage we feel that there is too little information available re Scheme 404 (Cycling corridor and rights of way between Tunbridge Wells and Tonbridge) which appears to be the route that would serve the development at AL/SO 3, and will comment when the Walking and Cycling Strategy is published.

Pedestrian access to Southborough and Tonbridge via the A26 is not safe and we see no indications that any improvements are proposed in the Draft Local Plan. There is a narrow pavement on only one side of the road and there are no controlled pedestrian crossings. Traffic speeds make walking here both unpleasant and unsafe. Getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but impossible for the elderly or those with young children. Cars will continue to be used for the majority of journeys.

4. Land-based economic development and rural life

The proposed housing development is neither connected to, nor essential for, land based economic development on this site and it is unclear why the housing element has been included in the allocation.

We believe that the majority of the land within the site is leased to two tenant farmers and has been used in recent years as grazing for cattle, sheep, and horses stabled at the Honnigton Equestrian Centre (south of Vauxhall Lane, and not itself included within this site). The informal

tracks within the site have also been used for exercising horses from the Honnigton Equestrian Centre. The landowners already have an obligation to improve (for the 25 years) some of the agricultural land on this site under an S106 agreement in November 2014 in relation to the planning application 14/00870 for a Solar Park on other land which they own.

Obviously we cannot comment on the current economic viability of the agricultural uses on this site. However we have not seen any evidence in the DLP document set that there is a need for affordable housing (and other infrastructure and amenities) for rural communities on this site to meet Objective LBE2 in the High Weald AONB Management Plan nor that erection of rural workers dwellings here would be essential under the provisions of Policy H10 in the Draft Local Plan.

In relation to the proposed land-based economic development per se, in addition to the Development Management Policies already referenced in point 8f of Policy AL/SO 3 as a minimum the following should also apply: EN22, ED4, ED5, ED6 and ED7. We also surprised that there is no requirement for supporting woodland management and rural crafts as set out in the “Statement of Significance” in the High Weald AONB Management Plan (and quoted in the Distribution of

Development Paper)

5. Ecology and Biodiversity

We believe that the potential impact of the proposed development on ecology and biodiversity has been seriously underestimated in the Draft Local Plan. The site includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a wide variety of species. The gill woodlands and shaws provide important corridors for wildlife and are rich in biodiversity. There are traditional orchards, now a rare habitat. In addition the site is on a green corridor of Ancient Woodland (Coxon Wood, Beeches Wood, Nightingale Wood and Minepit Wood )which provides a natural habitat for plants, animals and birds. The Dark Skies provide an essential haven for nocturnal wildlife; at night owls can be heard hooting, foxes calling and badgers foragaing.

It is unclear how development here would protect and enhance biodiversity and geodiversity

6. Heritage Assets

The impact of the proposed development on listed buildings and other heritage assets within or bordering the site does not appear to have been assessed.

7. Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain with run-off from the A26 and higher ground. There is network of underground streams and springs in addition to the visible stream and ponds within the site. This is not ideal land for development and will be made worse by the creation of additional impermeable surfaces for housing, roadways etc.

We are also aware that the mains sewer is located at the rear of the gardens of the strip of houses beside the A26 and there is a Southern Water pumping station near this (within the site). As there are steep slopes in this area, falling away from the A26, we would like to be assured that appropriate measures are planned for connection of new properties to the mains sewage pipes has been considered.

8. Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_6476

Deborah Crook

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);
ii) where the housing, roads and other buildings are going to be located; and
iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children. My son has to cross this road when returning from school. It is already extremely concerning as there is no safe crossing place.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

My property has already flooded in December 2013 and this is something that concerns me.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

Tonbridge itself is a traffic nightmare with absolute chaos at peak times, reducing to a miserable crawl at off peak times. It simply cannot sustain more traffic coming from the Southborough side.

DLP_7018

Turnberry for Hadlow Estate

Support with conditions

1. Introduction

1.1. This representation is submitted on behalf of the Hadlow Estate concerning Tunbridge Wells Borough Council’s spatial strategy and specifically, the allocation of a new hamlet at Mabledon under Policy AL/SO 3.

1.2. The Estate recognises the acute housing shortage facing the Borough, indeed the country, and has supported the principle of a new community at Mabledon on the basis that it will be seen in the same historical tradition of model villages such as those at Blaise Hamlet, Milton Abbas and Benenden, but with an emphasis on the organic character of the High Weald. The development can therefore serve as a model for future sensitive and sustainable development within the High Weald AONB with lessons which can be exported to other sensitive locations in the UK and beyond.

1.3. The proposed hamlet requires a long-term commitment and involvement throughout the planning and construction process. At the conclusion of the project, the new community will be regarded as significant in terms of UK town planning: that is the standard that will be delivered. This is consistent with the values and tradition of the Hadlow Estate which has a 170 year connection to the history and stewardship of the land and will continue to be maintained and managed alongside Mabledon, once the project completes.

1.4. Freed from the burden of purchasing land or retuning dividends to shareholders, the Hadlow Estate can invest in placemaking and create an exceptional development with high quality housing that showcases UK town planning. The community is therefore distinct from any other proposals in the Draft Plan.

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

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

1.7. Our representation is structured as follows: In Section 2 we set out the case for the new community with particular emphasis on ensuring the supporting evidence base is clearly expressed i.e. justified and effective in accordance with the tests of Soundness.

1.8. We then discuss the additional evidence Hadlow Estate has prepared in respect of development within the High Weald AONB and the Green Belt within Section 3. This includes the proposed boundaries of the development.

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

2. The Case for Mabledon

2.1. We have reviewed the Draft Plan and its supporting material to assist the Council in ensuring the evidential basis for the Plan is both robust and justified, particularly in its identification of Mabledon as a new hamlet of between 50 and 120 dwellings. We begin with the macro issues which drive the need for the new Local Plan i.e. Housing Need, before moving to the response to that need, the Spatial Strategy and the clear justification for selecting the site.

2.2. We conclude with some commentary on what it actually means in terms of Mabledon becoming an exemplar development in the tradition of model hamlet planning.

Housing Need

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

2.4. These matters include:

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

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

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

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

e. Finally, the Council needs to update its economic evidence which is not in step with its housing evidence and may point towards additional housing need. This needs to be resolved now in advance of Submission.

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

Spatial Strategy

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

a. The Borough constraints have been mapped:

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

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

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

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

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

2.7. The Distribution of Development Topic Paper helpfully brings these matters together to explain the steps that led to the proposed Development Strategy within the Draft Plan. It is clear from the responses in the Issues and Options Consultation Statement that the preservation of the AONB is important and therefore directly aligns with paragraph 172 of the NPPF demanding ‘great weight’ is attached to conserving their landscape and scenic beauty.

2.8. The Distribution of Development Topic Paper comprehensively assesses the impact of proposed development in the AONB, relating it to the special characteristics that define the designation. In the case of Mabledon, we have undertaken additional evidence which is set out in Section 3. However, we note that one of the reasons for designating the proposed community is to establish a sensitive exemplar development that can capture the qualities of the High Weald and serve as a model for future, sustainable growth: this objective should be included in the main policy and we have added suggested wording in Section 4 below. This change would ensure the Development Strategy is situated on a firm, evidential and justified basis. This is not the case at present.

2.9. We have undertaken an independent analysis of the Council’s evidence base in respect of the review of the Green Belt and this work is set out in Section 3 below. It reaffirms the findings of the Council in this respect, but we do consider that the Exceptional Circumstances should be elevated into the Draft Plan, at the end of Section 2 so they provide a link between Challenges and Opportunities and the response, i.e. the Vision, Objectives and Development Strategy. This would clearly evidence and justify the spatial strategy in response to the survey of the Borough.

2.10. Therefore, whilst we have objected to how portions of the evidence base need to be corrected or enhanced to make the proposed spatial strategy Sound, we are in support of the principle that Mabledon comes forward as a new exemplar community, sustainably located and an effective response to accommodating housing need in the Borough as well as informing how future need can be met in a constrained Borough.

3. Supporting evidence

Landscape and Visual Appraisal

3.1. The proposed site is located within the High Weald AONB and potential development on it would be visible from various local publicly accessible locations within the AONB, mainly the Public Right of Way that runs along the drive from the A26 through Mabledon Farm, down to Vauxhall Lane. Longer distance views from the AONB would be highly limited, primarily due to the relatively dense character of the woodland, trees and hedgerows. The amount of new development that would be visible would be small. The appraisal concludes that the visual change to the character of the High Weald AONB, would be limited.

3.2. The High Weald AONB Management Plan 20192024 defines five components of character (sometimes referred to as ‘Special Qualities’) that make the High Weald a recognisable, distinct and homogenous area. These include the following; (1) Geology, Landform, Water Systems and Climate, (2) Settlement, (3) Routeways, (4) Woodland and (5) Field and Heath. A further category of Other Qualities is also highlighted, which include ‘People value the wonderful views and scenic beauty of the High Weald with its relative tranquillity’. It is considered that these components are only capable of being directly affected by the proposals to a very limited degree.

3.3. The draft policy requires an exemplar design approach that makes a positive contribution to the objectives of the AONB Management Plan. At this stage, without a scheme devised, the assessment takes a precautionary approach to the assessment of effects. But, in accordance with the objectives of the draft policy, it would be an objective for the design of the scheme to not only minimise landscape and visual effects on the AONB but to deliver a scheme that, overall, would be in-keeping with and enhance the character and appearance of the High Weald. Development proposals based on such an approach would have the potential to be perceived as having a positive and beneficial landscape and visual effect on the AONB.

3.4. The draft Mabledon Farm allocation is unlike any of the other draft AONB allocations because at its heart is a vision for the creation of a new community, centred on an historic farmstead, based on the settlement typologies and evolution of farmstead, hamlets and small villages in the High Weald. This contrasts with the other draft proposals to expand existing larger village and towns in the High Weald. Mabledon Farm is particularly appropriate for this because it has at its centre an especially suitable traditional farmstead, has an elevated, ridge top location, which is typical of the most characteristic smaller scale High Weald settlements and has, through the wider landholding, the ability for the settlement to be connected to its landscape setting through land management commitments.

3.5. In support of this, and as noted in Section 5 of this document, we have proposed the deletion of the word ‘amenity’ from Policy EN 20 Rural Landscape as it is too broad a term, and renders the policy ineffective.

Heritage Appraisal

3.6. Mabledon is typical of the scattered farmsteads and dwellings that are predominant in this part of the Weald. The footprint of a good proportion of the working buildings survives, and the farmstead contains a range of buildings built in locally characteristic materials including brick and weatherboarding.

3.7. The layout of the farmstead has, however, changed significantly since its construction in the early nineteenth century, and key buildings have been significantly altered including the main house and oast house. Others have been largely rebuilt on their original footprint.

3.8. Some of the buildings, particularly the farmhouse, oast house and Kent Barn, could make an important contribution to a new rural community, particularly when some of the most recent, unsympathetic modern buildings have been removed, allowing appreciation of the original farm layout. This core of historic buildings has the potential to become the focal point of an exemplary new development, whilst retaining their original farmstead character.

3.9. The reuse and restoration of the historic buildings provide an opportunity to reveal historic elements and ensure their long term conservation. Therefore on balance, it is likely that the proposed development would result in an overall neutral effect to their significance, with potential for their enhancement depending on the detailed design of the proposed development.

Archaeological Appraisal

3.10. An initial review of the archaeological potential has confirmed that the site has a moderate potential to contain prehistoric evidence and known heritage assets from the Post-Medieval period. Although the presence of an ancient routeway along the western boundary of the site has been identified, there is a low potential for any occupation evidence from these periods.

3.11. The significance of the potential archaeological resources has been assessed and it has been concluded that the heritage assets within the study site are likely to be of no more than local interest, and not such that would preclude development provided adequate steps are taken to identify remains present and mitigate for their loss if necessary.

Green Belt Review

3.12. The NPPF envisages that plan-making authorities may move Green Belt boundaries in order to deliver sustainable and objectively assessed development needs, where there are fully justified exceptional circumstances. However, Policy AL/SO 3 for Mabledon indicates that the development proposals for Mabledon Farm would remain in the Green Belt.

3.13. Accordingly, post-allocation at the planning application stage, the applicant would need to make the case for ‘very special circumstances’ that would clearly outweigh the harm to the Green Belt, in accordance with Paragraph 144 of the NPPF. Such a case would need to be based on the raft of overarching very special circumstances identified by the Council in the Plan and supporting evidence, but also on very special circumstances that would be, at the time of the planning application, specific to this site. These would include (1) that this site has an allocation in the Local Plan, (2) that there was a specific need for the delivery of this site, for the numbers proposed, at that particular time, and (3) that the vision for the site required and the scheme proposed would deliver an enlarged settlement ‘that reflects the evolution of farmsteads, hamlets, and small villages, and which remains connected to the surrounding land and its management, has the potential to demonstrate a new sustainable approach to development in the High Weald, making strong and positive contributions to the objectives of the AONB Management Plan’ (paragraph 5.56 of the supporting text to Policy AL/SO 3).

3.14. Evidently, the expanded farmstead development at Mabledon Farm would have a direct effect on the existing Green Belt and would impact to some degree on the four of the five purposes. However, this is considered to be limited in degree. The draft policy requirement for the scheme to be exemplar and of modest scale, would mean that the development would have limited visual impact and would retain an overall rural character, being perceived to be part of the countryside, rather than as urban development. Furthermore, the presence of retained Green Belt and AONB across the area between Tunbridge Wells and Tonbridge would mean that future residential development proposals, including in and around the expanded farmstead development, would be capable of being resisted at the application stage.

4. Sustainability Appraisal

4.1. We have reviewed Table 23 within the SA to ensure consistency with other sites and to ensure all relevant considerations are factored in.

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

  • The proximity of the site to strategic urban and employment areas leads to higher scores in terms of Employment, Services & Facilities, and Travel;
  • The wider Hadlow Estate can leveraged in support of biodiversity improvements.

4.3. The site therefore moves from scoring positively across nine Sustainability Objectives to scoring eleven, whilst negative indicators fall from seven to two, which brings it in to line with other allocations.

Revised SA Appraisal for AL/SO 3 - Table 23, SA of the Spatial Strategy

Sustainability Objective

AL/SO 3

Commentary

Air

-

No change

Biodiversity

+

The ecological constraints will be mitigated through sensitive masterplanning. On the basis the Hadlow Estate extends beyond the allocation, there is opportunity to create net improvements in biodiversity.

Business Growth

++ / +++

No change

Climate Change

0

The draft Policy insists on a comprehensive climate change strategy

Deprivation

++

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

Education

+

No change

Employment

+++

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

Equality

0

Adjusted to align with other allocations

Health

+

No change

Heritage

++

No change

Housing

+ / ++

No change

Land Use

0 / +

No change

Landscape

++

No change

Noise

0

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

Resources

?

No change

Services & Facilities

0 / -

No change

Travel

+

No change

Waste

0

No change

Water

0

The site is not at risk of flooding from watercourses, but the site will be masterplanned in accordance with the principles of directing development to those areas of the site with the lowest risk of other forms of flooding, e.g. ground water or managing overland flow appropriately

[TWBC: for SA Appraisal showing full colour table, see full representation].

5. Amendments to Policy AL/SO3

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

5.2. We have also included the approach to Green Belt within the draft Policy on the basis that when an application comes forward in accordance with the Policy, the site will still be subject to Green Belt policy.

5.3. In response to a request from Tonbridge and Malling Borough Council for collaboration around this allocation, we have also added this clarification to the Policy.

5.4. The section related to contributions has been altered to ensure the policy complies with the legal tests related to S106 agreements.

Policy AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 445)

This area, indicated by a star on the Southborough draft Policies Map, is allocated for a mixed use scheme to include land-based economic development and approximately 50-120 residential (C3) dwellings. Development brought forward in accordance with the terms of this Policy shall be considered appropriate development in the Green Belt.

Development on this site shall accord with the following requirements:

1. Provision of safe and acceptable access arrangements from the A26 for the proposed development with, where required, a secondary emergency access (see criterion 5 of Policy EN1: Design and other development management criteria);

2. Measures to enhance or provide Provision of safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge (see Policy TP 2: Transport Design and Accessibility);

3. A vision for the site and an agreed design process to be developed in collaboration with the Council and with input from stakeholders, particularly Tonbridge and Malling Borough Council and the AONB Joint Advisory Committee, with a final version to be submitted and agreed by the Council prior to any planning application being submitted;

4. An overarching masterplan and supporting information on delivery to be agreed with the Council prior to any planning application being submitted;

5. The design and layout to be informed by a comprehensive energy and climate change strategy (Policies EN 4: Energy reduction in new buildings and EN 5: Climate Change Adaptation);

6. Provision of public electric charging points and car share facilities in line with Policy TP 2: Transport Design and Accessibility;

7. Development above 50 dwellings will need to be justified through the design process and may not exceed 120 dwellings during this plan period ;

8. The scheme shall include provision for the following:

a. Affordable housing (see Policy H 5: Affordable Housing);

b. Buildings for land based economic development;

c. Community facilities, including buildings, allotments, orchards, and recreation (see Policy OSSR 2: Provision of publicly accessible open space and recreation);

d. High quality sustainable forms of housing development with provision for log and bicycle storage using local materials wherever possible (see Policies EN 1: Design and other development management criteria and EN 2: Sustainable Design and Construction);

e. Live/work units and broadband or high speed mobile connectivity to facilitate homeworking (see Policy ED 3: Digital communications and fibre to the premises);

f. A scheme of landscape restoration and management for green space and the wider agricultural holding, with opportunities and provision for community involvement (see Policy EN 1: Design and other development management criteria - criterion 3, Policy EN 17: Local Green Space, Policy EN20: Rural Landscape and EN21: High Weald Area of Outstanding Natural Beauty (AONB));

9. The proposed development shall be an exemplar of sustainable design within the High Weald AONB and Tt he developer will enter into an agreement with the Council to facilitate using the site as an exemplar project through site visits and talks during and post construction, and to produce a publication to explain the scheme and processes adopted to be made freely available in an electronic format.

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

a. Improvements to public realm;

b. The provision of sustainable and active transport mitigation measures , town centre wide or town wide transport mitigation measures ; and orwhere necessary, highway works in the vicinity of the site, including the provision of pedestrian crossings (see Policies TP 1: Transport Assessments, Travel Plans, and Mitigation and TP 2: Transport Design and Accessibility);

c. Primary and secondary education;

d. Health and medical facilities;

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

f. 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 The provision of appropriate and proportionate contributions to sport and recreation (see Policy OSSR 2: The provision of publicly accessible open space and recreation);

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

[TWBC: see full representation. Also see Comment Numbers DLP_7018, 7020 and SA_129].

DLP_7136

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.

DLP_7263

Chris Daniels

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);

ii) where the housing, roads and other buildings are going to be located; and

iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a fiveyear housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

DLP_7288

Hangman's Hill Residents Association

Object

The Hangman’s Hill Residents Association (HHRA)represents those living on or close to the section of London Road, Southborough (the A26) that is between Vauxhall Lane and Mabledon.  We aim to play an active role in localism and shaping the future of Southborough and are particularly concerned with protecting the countryside that lies between the urban areas of Southborough and Tonbridge.  This response from the HHRA Committee is based upon discussions with our membership and our analysis of the wider set of Draft Local Plan documentation.

The HHRA Committee strongly objects to the proposed allocation of AL/SO 3 Land at Mabledon and Nightingale for a mixed use scheme to include land-based economic development and approximately 50-120 residential dwellings on the basis of

  • the lack of clarity in the Draft Local Plan documentation set regarding the proposal;
  • the potential for inappropriate development in the AONB and the Green Belt;
  • increased traffic congestion on the A26, including in the Southborough AQMA and
  • environmental impacts.

1. Lack of Clarity regarding the Proposal

HHRA is surprised that TWBC have seen fit to include as a proposed allocation where there appears to be

a) confusion as to where the site is :

  • Draft Local Plan para 5.53 incorrectly states that it is the Main Urban Area, and this is error is repeated or implied in a number of the Supporting Documents

b) lack of clarity as to the extent of development proposed apart from housing:

  • Buildings for land based economic development (policy point 8b) – what and how many?
  • Community facilities including buildings (policy point 8c) – what and how many?
  • utility cycle tracks within the site to link to Southborough and Tonbridge, hich will be tarmacked and lit for safety reasons
  • roads within the site to link “scattered forms of development”
  • buildings and spaces to provide cultural infrastructure (Exhibition Board 19)

c) a need for additional studies to determine where developments (housing and other) could be located while still avoiding the multitude of constraints;

  • much of the allocated area was put forward in the 2016 Call for Sites (Sites: 179 - Mabledon Farm, 180 - Nightingale Farm and 181 – Moatenden)
  • the environmental and landscape constraints are well covered in the relevant Environment & Landscape Supporting Documents on the Local Plan website.

d) no calculation of what land take will be required for the developments.

  • The site boundaries are not shown on the policy maps however ee note from the SHELAA (Site reference 445 – 16. Southborough Sites) that the site is approximately 171 hectares.
  • the 50-120 dwelling proposed for the current plan period in Policy AL/SO3 would only require 8 hectares using a density of 15 dwellings per hectare for a mixed use development or 3 hectares using a density of 40 dwellings per hectare on a greenfield site.

We consider that the vagueness of this proposed allocation simply establishes that development in this area is acceptable to TWBC, setting a dangerous precedent for the future.   Our very serious concern it the landowners (the Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed.  The “Potential yield if residential” in the SHELAA should reflect that the stated developable area is 125 hectares giving a potential yield of 1,875 dwellings using a  density 15 dwellings per hectare for a mixed-use development,  or 5,000 dwellings using a density of 40 dwellings per hectare on a greenfield site.

A planning application has recently (August 2019) been submitted by the landowner for one small part of the site (19/02361 Moatenden - 1.14 hectares) which cites the lack of a 5-year housing supply.  What is to stop further applications for other areas at any point in the future when Tunbridge Wells cannot demonstrate a 5-year housing supply? Additionally, approximately a quarter of the site is in the borough of Tonbridge and Malling, and includes direct access from Vauxhall Lane within that borough, giving further options for development.

Until the location(s) and extent of development are confirmed it is premature to propose allocating this site in the Draft Local Plan.

2. High Weald AONB

HHRA is very concerned that the reasons for allocating this site for housing development are not clearly set out in the Draft Local Plan documentation set.  From the information provided this allocation is likely to cause significant harm to the character of the AONB and there are no “exceptional circumstances” as defined in the NPPF paragraph 172.

Additionally we have found no evidence to support the Council’s view that it will provide “an exemplar scheme inspired by the underlying historical character of the High Weald” (although we have noticed that “exemplar” appears to be the buzzword for developments proposed by this landowner,  who also owns the site at Tudeley which is proposed for the “Garden Village).

a) Assessment of harm to AONB Character

From a landscape perspective this site is rural in nature and forms a strategic gap between Tonbridge and Southborough.  It lies within sub areas SP5 and SP6 in the 2017 Landscape Sensitivity Assessment of Countryside around Tunbridge Wells and this report highlights the many landscape features typical of the High Weald AONB.  Both areas are assessed as having a high sensitivity to any scale of development.  The report does suggest that, within sub area SP5 “there may be pockets of land associated with existing development where sensitivity to small-scale development could be relatively contained in the wider landscape” but does not specify where these pockets might be. Mabledon Farm is the only existing development that is both within the allocated site and sub-area SP5, suggesting that a scattered development would not satisfy this requirement.

The Southborough section of the Historic Landscape Characterisation gives further evidence of the historic importance of this site.  The main report highlights that “whilst dispersed plans may offer opportunities for additional dwellings, the very process can easily destroy the historic layout and character of the farmstead” (para 4.1, Section 1 – User Guide  & Interpretation).  Mabledon Farm is a historic farmstead, with assart fields and traditional orchards close to it.

The conclusions in these reports are reflected in the assessment of High Impact on the AONB in the Distribution of Development Topic Paper (App. 3: Assessment of AONB Sites - Site Policy Ref SO 3).

In the light of the above,  we question why the Council chose to support the development proposal for Mabledon/Nightingale and include an allocation for this site in the Draft Local Plan.   Paragraph 6.85 of the Distribution of Development Topic Paper states that “where development is considered likely to cause significant harm to the defining character of the AONB (also having regard to potential mitigation) or cause harm disproportionate to likely benefits of the scheme, then that development will be very unlikely to be supported”.  

The mitigation proposed for this development appears to be the “farmstead approach” which is nowhere defined nor expanded upon.  The suggestion in the Distribution of Development Topic Paper  (App 3) that there is “a very restrictive policy requiring positive landscape outcomes” is simply untrue.   The only restriction in the Policy for AL/SO 3 is that housing development will be limited to 120 dwellings in this plan period.  As the Council specifically exclude sites allocated in the local plan from the provisions of Policy EN21,  and the AONB Joint Advisory Committee’s role in the development will only be to provide “input to the vision and design process”, there appear to be no restrictions in Policy AL/SO 3 to protect the landscape from inappropriate development.

b) Major development in AONB

The Distribution of Development Topic Paper highlights the provisions of the NPPF with regard to AONBs (para 3.8 – 3.11)  and suggests that TWBC believe that the proposed development is likely to be classed as major development in theAONB, highlighting that its scale is “very substantial” relative to the existing settlement.(App. 3: Assessment of AONB Sites - Site Policy Ref SO 3,  Distribution of Development Topic Paper)

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. Consideration of such applications should include an assessment of:

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”.

It is nonsensical for the Council to present an assessement of major developments within the AONB against the NPPF requirements as a single entity,  as is done in the table under para 6.101 in the Distribution of Development Topic Paper.  The individual site level assessments are not described in in the Distribution of Development Topic Paper or the SHELAA.  We are concerned therefore that no evidence is given of the “exceptional circumstances” specific to the proposed AL/SO3 allocation;  in particular we cannot see that the need for up to 120 dwellings could not be met in some other way within the borough as a whole, with the council already proposing to allocate 9% more housing than required by the OAN calculations.

We also question the Council’s reliance on “unique circumstances” as justification referenced throughout the Draft Local Plan document set.  These appear to be that a farmstead (Mabledon Farm) and its surrounding land are in a single ownership.  It is a very disturbing statement on the state of a predominantly rural borough if this is true!

In conclusion we can see no justification for the proposed allocation for development of this large site in the AONB.  The Distribution of Development Topic Paper para 6.89 supports the view that this proposal should have been rejected by the Council as not being a “reasonable option”.

Green Belt

AL/SO3 provides the one-mile wide Green Belt separation east of the A26 between the built-up areas of Southborough and Tonbridge. Housing development here would be contrary to the purposes of the Green Belt as set out in paragraphs 133-134 of the NPPF:

“The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

Green Belt serves five purposes:

  1. a) to check the unrestricted sprawl of large built-up areas;
  2. b) to prevent neighbouring towns merging into one another;
  3. c) to assist in safeguarding the countryside from encroachment;
  4. d) to preserve the setting and special character of historic towns; and
  5. e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 

In the Stage 2 TWBC Green Belt Study this site falls within Broad Area 1, we assume due to its rural nature. BA1 is assessed as making a STRONG contribution to each of the Green Belt purposes a) through d).

It is unclear what assessments of the potential for harm to this area of Green Belt the Council have carried out in proposing this allocation.  The Green Belt designation is not included in the “Issues to consider” section of the SHELAA (Site ref 445 – Section 16. Southborough Site) and we cannot find any discussion of the reasons behind the decision that this site should remain in the Green Belt.  The Assessment of Green Belt Sites (App 1 Distribution of Development Topic Paper) has N/A for

  • Allocation Area within MGB
  • Hectares to remove from MGB
  • Site Size
  • Site % in MGB
  • Housing Min as % of site in MGB
  • Housing Max as % of site in MGB

As this table also has the housing numbers and masterplanning for AL/SO3 shown under SO4 (the hotel/leisure development, we can only assume that no consideration at all has been given to Green Belt purposes in allocating this site. We suggest that the intent in the NPPF is to protect the Green 

Belt from inappropriate development, not to allow unconstrained development simply by the Council declaring that a developed site will remain in the Green Belt. In this instance it seems as if the Council has simply avoided the need to demonstrate “exceptional circumstances” by ignoring the sites contribution to the Green Belt purposes.

Without knowing the location and extent of development it is impossible to say what impact the proposed developments would have on the openness of this area of the Green Belt.  There are views into the site from a variety of locations - the A26, a PROW to Haysden (higher up the ridge) or the footpath near the Cottage Hospital (lower down the valley).  Any development at the southern end of the site would be visible from Vauxhall Lane (a designated Rural Lane) and the Tunbridge Wells Circular Walk.

3. Transport and Active Travel 

a) Congestion and Air Quality

We are very concerned that additional traffic from this new development  will simply exacerbate the existing congestion and air quality on the section of the A26 near the site and in the nearby AGMA in Southborough.  The situation will be made even worse by the volume of traffic likely to be generated by the proposed hotel and leisure complex at Mabledon House (AL/SO3).  We are unsure how the smart traffic management system proposed in the Transport Evidence Base, synchronising traffic lights, will improve the traffic flows on the A26 past the Mabledon/Nightingale site when there are no traffic lights here and the speed limit is 40mph, 10mph higher than the speed limit in the urban area of Southborough.  Additionally, this is a single-carriageway road with traffic halted by buses picking up/dropping off passengers and vehicles slowing or stopping to turn into private driveways.

b) Safety

The Policy for AL/SO3 requires “safe and acceptable access arrangements from the A26 for the proposed development with, where required, a secondary emergency access”. (policy point 1).

We note that the junction performance assessment for AL/SO3 allocation in the Transport Evidence Base was carried out based upon 100 dwellings accessing the A26 via Vauxhall Lane.  We are confused by this approach as Vauxhall Lane is at the opposite end of the site to Mabledon Farm on which the development would be centred. Vauxhall Lane is a narrow lane with complex topography and a “blind” junction with the A26; it is totally unsuited to such an increase in traffic.

The more obvious access to the A26 would be through upgrading the current PROW from Mabledon Farm to the A26.  Unfortunately this would result in traffic leaving/joining the A26 in close proximity to the access to the proposed hotel and leisure complex at Mabledon House (AL/SO4).  This stretch of road has a 40mph speed limit and this limit is frequently exceeded as vehicles approach the slip road to the A21.  It is unclear how traffic from the new development could safely pull out onto the A26. We believe that traffic lights would only serve to increase congestion and air pollution, by halting the flow of traffic on the A26 while construction of a roundabout would have a material impact on the character of the AONB landscape (as would any widening of the A26).

Safe and acceptable pedestrian and cycle linkages to Southborough are also required(policy point 2).   At this stage we feel that there is too little information available re Scheme 404 (Cycling corridor and rights of way between Tunbridge Wells and Tonbridge) which appears to be the route that would serve the development at AL/SO 3, and will comment when the Walking and Cycling Strategy is published.

Pedestrian access to Southborough and Tonbridge via the A26 is not safe and we see no indications  that any improvements are proposed in the Draft Local Plan.  There is a narrow pavement on only one side of the road and there are no controlled pedestrian crossings.  Traffic speeds make walking here both unpleasant and unsafe.  Getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but impossible for the elderly or those with young children. Cars will continue to be used for the majority of journeys.

4. Land-based economic development and rural life

The proposed housing development is neither connected to, nor essential for, land based economic development on this site and it is unclear why the housing element has been included in the allocation.

We believe that the majority of the land within the site is leased to two tenant farmers and has been used in recent years as grazing for cattle, sheep, and horses stabled at the Honnigton Equestrian Centre (south of Vauxhall Lane, and not itself included within this site).  The informal tracks within the site have also been used for exercising horses from the Honnigton Equestrian Centre. The landowners already have an obligation to improve (for the 25 years) some of the agricultural land on this site under an S106 agreement in November 2014 in relation to the planning application 14/00870 for a Solar Park on other land which they own.

Obviously we cannot comment on the current economic viability of the agricultural uses on this site.  However we have not seen any evidence in the DLP document set that there is a need for affordable housing (and other infrastructure and amenities) for rural communities on this site to meet Objective LBE2 in the High Weald AONB Management Plan nor that erection of rural workers dwellings here would be essential under the provisions of Policy H10 in the Draft Local Plan.

In relation to the proposed land-based economic development per se, in addition to the Development Management Policies already referenced in point 8f of Policy AL/SO 3 as a minimum the following should also apply: EN22, ED4, ED5, ED6 and ED7.  We also surprised that there is no requirement for supporting woodland management and rural crafts as set out in the “Statement of Significance” in the High Weald AONB Management Plan (and quoted in the Distribution of Development Paper)

5. Ecology and Biodiversity

We believe that the potential impact of the proposed development on ecology and biodiversity has been seriously underestimated in the Draft Local Plan. The site includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a wide variety of species. The gill woodlands and shaws provide important corridors for wildlife and are rich in biodiversity.  There are traditional orchards, now a rare habitat.  In addition the site is on a green corridor of Ancient Woodland (Coxon Wood, Beeches Wood, Nightingale Wood and Minepit Wood )which provides a natural habitat for plants, animals and birds.  The Dark Skies provide an essential haven for nocturnal wildlife; at night owls can be heard hooting, foxes calling and badgers foragaing.

It is unclear how development here would protect and enhance biodiversity and geodiversity

6. Heritage Assets

The impact of the proposed development on listed buildings and other heritage assets within or bordering the site does not appear to have been assessed.

7. Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain with run-off from the A26 and higher ground. There is network of underground streams and springs in addition to the visible stream and ponds within the site.  This is not ideal land for development and will be made worse by the creation of additional impermeable surfaces for housing, roadways etc.

We are also aware that the mains sewer is located at the rear of the gardens of the strip of houses beside the A26 and there is a Southern Water pumping station near this (within the site).  As there are steep slopes in this area, falling away from the A26, we would like to be assured that appropriate measures are planned for connection of new properties to the mains sewage pipes has been considered.

8. Infrastructure

This development will put further pressure on the infrastructure in Southborough.  There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_7296

Keith Crook

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);
ii) where the housing, roads and other buildings are going to be located; and
iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children. My son has to cross this road when returning from school. It is already extremely concerning as there is no safe crossing place.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

My property has already flooded in December 2013 and this is something that concerns me.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

Tonbridge itself is a traffic nightmare with absolute chaos at peak times, reducing to a miserable crawl at off peak times. It simply cannot sustain more traffic coming from the Southborough side.

DLP_7406

Mr John Telling

Object

I cannot see any justification for this speculative housing development proposal in contradiction of proper conservation intentions of the Green Belt and High Weald AONB protection policies. The proposal is hedged about by planning verbiage which will prove elastic over time. This is the narrow end of what could easily become a very large wedge. This is a blatant money making proposal. Once started expansion of this development intrusion into an agricultural area of significant landscape value will prove irresistible. Why here?

DLP_7410

Byerley Ltd

Object

I strongly objects to the proposed allocation of AL/SO 3 Land at Mabledon and Nightingale for a mixed use scheme to include land-based economic development and approximately 50-120 residential dwellings on the basis of

  • the lack of clarity in the Draft Local Plan documentation set regarding the proposal;
  • the potential for inappropriate development in the AONB and the Green Belt;
  • increased traffic congestion on the A26, including in the Southborough AQMA and
  • environmental impacts.

1. Lack of Clarity regarding the Proposal

I am surprised that TWBC have seen fit to include as a proposed allocation where there appears to be

a) confusion as to where the site is :

  • Draft Local Plan para 5.53 incorrectly states that it is the Main Urban Area, and this is error is repeated or implied in a number of the Supporting Documents

b) lack of clarity as to the extent of development proposed apart from housing:

  • Buildings for land based economic development (policy point 8b) – what and how many?
  • Community facilities including buildings (policy point 8c) – what and how many?
  • utility cycle tracks within the site to link to Southborough and Tonbridge, which will be tarmacked and lit for safety reasons
  • roads within the site to link “scattered forms of development”
  • buildings and spaces to provide cultural infrastructure (Exhibition Board 19)

c) a need for additional studies to determine where developments (housing and other) could be located while still avoiding the multitude of constraints;

  • much of the allocated area was put forward in the 2016 Call for Sites (Sites: 179 - Mabledon Farm, 180 - Nightingale Farm and 181 – Moatenden)
  • the environmental and landscape constraints are well covered in the relevant Environment & Landscape Supporting Documents on the Local Plan website.

d) no calculation of what land take will be required for the developments.

  • The site boundaries are not shown on the policy maps however ee note from the SHELAA (Site reference 445 – 16. Southborough Sites) that the site is approximately 171 hectares.
  • the 50-120 dwelling proposed for the current plan period in Policy AL/SO3 would only require 8 hectares using a density of 15 dwellings per hectare for a mixed use development or 3 hectares using a density of 40 dwellings per hectare on a greenfield site.

e) Valuing our natural assets as part of the national ecosystem services approach is key to truly determining the environmental economic value of these sites. I urge you, as part of the options process, to undertake a valuation assessment on all the green belt options. Then you will be truly informed of the environmental cost to the Borough that would occur if these important green assets were subject to development.

I consider that the vagueness of this proposed allocation simply establishes that development in this area is acceptable to TWBC, setting a dangerous precedent for the future.   Our very serious concern it the landowners (the Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed.  The “Potential yield if residential” in the SHELAA should reflect that the stated developable area is 125 hectares giving a potential yield of 1,875 dwellings using a  density 15 dwellings per hectare for a mixed-use development,  or 5,000 dwellings using a density of 40 dwellings per hectare on a greenfield site.

A planning application has recently (August 2019) been submitted by the landowner for one small part of the site (19/02361 Moatenden - 1.14 hectares) which cites the lack of a 5-year housing supply.  What is to stop further applications for other areas at any point in the future when Tunbridge Wells cannot demonstrate a 5-year housing supply? Additionally, approximately a quarter of the site is in the borough of Tonbridge and Malling, and includes direct access from Vauxhall Lane within that borough, giving further options for development.

Until the location(s) and extent of development are confirmed it is premature to propose allocating this site in the Draft Local Plan.

2. High Weald AONB

I am very concerned that the reasons for allocating this site for housing development are not clearly set out in the Draft Local Plan documentation set.  From the information provided this allocation is likely to cause significant harm to the character of the AONB and there are no “exceptional circumstances” as defined in the NPPF paragraph 172.

a) Assessment of harm to AONB Character

From a landscape perspective this site is rural in nature and forms a strategic gap between Tonbridge and Southborough.  It lies within sub areas SP5 and SP6 in the 2017 Landscape Sensitivity Assessment of Countryside around Tunbridge Wells and this report highlights the many landscape features typical of the High Weald AONB.  Both areas are assessed as having a high sensitivity to any scale of development.  The report does suggest that, within sub area SP5 “there may be pockets of land associated with existing development where sensitivity to small-scale development could be relatively contained in the wider landscape” but does not specify where these pockets might be. Mabledon Farm is the only existing development that is both within the allocated site and sub-area SP5, suggesting that a scattered development would not satisfy this requirement.

The Southborough section of the Historic Landscape Characterisation gives further evidence of the historic importance of this site.  The main report highlights that “whilst dispersed plans may offer opportunities for additional dwellings, the very process can easily destroy the historic layout and character of the farmstead” (para 4.1, Section 1 – User Guide  & Interpretation).  Mabledon Farm is a historic farmstead, with fields and traditional orchards close to it.

The conclusions in these reports are reflected in the assessment of High Impact on the AONB in the

Distribution of Development Topic Paper (App. 3: Assessment of AONB Sites - Site Policy Ref SO 3).

In the light of the above, I question why the Council chose to support the development proposal for Mabledon/Nightingale and include an allocation for this site in the Draft Local Plan.   Paragraph 6.85 of the Distribution of Development Topic Paper states that “where development is considered likely to cause significant harm to the defining character of the AONB (also having regard to potential mitigation) or cause harm disproportionate to likely benefits of the scheme, then that development will be very unlikely to be supported”.  

The mitigation proposed for this development appears to be the “farmstead approach” which is nowhere defined nor expanded upon.  The suggestion in the Distribution of Development Topic Paper  (App 3) that there is “a very restrictive policy requiring positive landscape outcomes” is simply untrue.   The only restriction in the Policy for AL/SO 3 is that housing development will be limited to 120 dwellings in this plan period.  As the Council specifically exclude sites allocated in the local plan from the provisions of Policy EN21,  and the AONB Joint Advisory Committee’s role in the development will only be to provide “input to the vision and design process”, there appear to be no restrictions in Policy AL/SO 3 to protect the landscape from inappropriate development.

b) Major development in AONB

The Distribution of Development Topic Paper highlights the provisions of the NPPF with regard to AONBs (para 3.8 – 3.11)  and suggests that TWBC believe that the proposed development is likely to be classed as major development in the AONB, highlighting that its scale is “very substantial” relative to the existing settlement. (App. 3: Assessment of AONB Sites - Site Policy Ref SO 3,  Distribution of Development Topic Paper)

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. Consideration of such applications should include an assessment of:

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”. 

It is nonsensical for the Council to present an assessment of major developments within the AONB against the NPPF requirements as a single entity, as is done in the table under Para 6.101 in the Distribution of Development Topic Paper.  The individual site level assessments are not described in in the Distribution of Development Topic Paper or the SHELAA.  We are concerned therefore that no evidence is given of the “exceptional circumstances” specific to the proposed AL/SO3 allocation;  in particular we cannot see that the need for up to 120 dwellings could not be met in some other way within the borough as a whole, with the council already proposing to allocate 9% more housing than required by the OAN calculations.

I also question the Council’s reliance on “unique circumstances” as justification referenced throughout the Draft Local Plan document set.  These appear to be that a farmstead (Mabledon Farm) and its surrounding land are in a single ownership.  It is a very disturbing statement on the state of a predominantly rural borough if this is true!

In conclusion I can see no justification for the proposed allocation for development of this large site in the AONB.  The Distribution of Development Topic Paper para 6.89 supports the view that this proposal should have been rejected by the Council as not being a “reasonable option”.

Green Belt

AL/SO3 provides the one-mile wide Green Belt separation east of the A26 between the built-up areas of Southborough and Tonbridge. Housing development here would be contrary to the purposes of the Green Belt as set out in paragraphs 133-134 of the NPPF:

“The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

Green Belt serves five purposes:

  1. a) to check the unrestricted sprawl of large built-up areas;
  2. b) to prevent neighbouring towns merging into one another;
  3. c) to assist in safeguarding the countryside from encroachment;
  4. d) to preserve the setting and special character of historic towns; and
  5. e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 

In the Stage 2 TWBC Green Belt Study this site falls within Broad Area 1, I assume due to its rural nature. BA1 is assessed as making a STRONG contribution to each of the Green Belt purposes a) through d).

It is unclear what assessments of the potential for harm to this area of Green Belt the Council have carried out in proposing this allocation.  The Green Belt designation is not included in the “Issues to consider” section of the SHELAA (Site ref 445 – Section 16. Southborough Site) and we cannot find any discussion of the reasons behind the decision that this site should remain in the Green Belt.  The Assessment of Green Belt Sites (App 1 Distribution of Development Topic Paper) has N/A for

  • Allocation Area within MGB
  • Hectares to remove from MGB
  • Site Size
  • Site % in MGB
  • Housing Min as % of site in MGB
  • Housing Max as % of site in MGB

As this table also has the housing numbers and masterplanning for AL/SO3 shown under SO4 (the hotel/leisure development, we can only assume that no consideration at all has been given to Green Belt purposes in allocating this site.  I suggest that the intent in the NPPF is to protect the Green Belt from inappropriate development, not to allow unconstrained development simply by the Council declaring that a developed site will remain in the Green Belt. In this instance it seems as if the Council has simply avoided the need to demonstrate “exceptional circumstances” by ignoring the sites contribution to the Green Belt purposes.

Without knowing the location and extent of development it is impossible to say what impact the proposed developments would have on the openness of this area of the Green Belt.  There are views into the site from a variety of locations - the A26, a PROW to Haysden (higher up the ridge) or the footpath near the Cottage Hospital (lower down the valley).  Any development at the southern end of the site would be visible from Vauxhall Lane (a designated Rural Lane) and the Tunbridge Wells Circular Walk.

3. Transport and Active Travel 

a) Congestion and Air Quality

I am very concerned that additional traffic from this new development will simply exacerbate the existing congestion and air quality on the section of the A26 near the site and in the nearby AGMA in Southborough.  The situation will be made even worse by the volume of traffic likely to be generated by the proposed hotel and leisure complex at Mabledon House (AL/SO3).  We are unsure how the smart traffic management system proposed in the Transport Evidence Base, synchronising traffic lights, will improve the traffic flows on the A26 past the Mabledon/Nightingale site when there are no traffic lights here and the speed limit is 40mph, 10mph higher than the speed limit in the urban area of Southborough.  Additionally, this is a single-carriageway road with traffic halted by buses picking up/dropping off passengers and vehicles slowing or stopping to turn into private driveways.

b) Safety

The Policy for AL/SO3 requires “safe and acceptable access arrangements from the A26 for the proposed development with, where required, a secondary emergency access”. (policy point 1).

We note that the junction performance assessment for AL/SO3 allocation in the Transport Evidence Base was carried out based upon 100 dwellings accessing the A26 via Vauxhall Lane.  I am confused by this approach as Vauxhall Lane is at the opposite end of the site to Mabledon Farm on which the development would be centred. Vauxhall Lane is a narrow lane with complex topography and a “blind” junction with the A26; it is totally unsuited to such an increase in traffic.

The more obvious access to the A26 would be through upgrading the current PROW from Mabledon Farm to the A26.  Unfortunately this would result in traffic leaving/joining the A26 in close proximity to the access to the proposed hotel and leisure complex at Mabledon House (AL/SO4).  This stretch of road has a 40mph speed limit and this limit is frequently exceeded as vehicles approach the slip road to the A21.  It is unclear how traffic from the new development could safely pull out onto the A26. We believe that traffic lights would only serve to increase congestion and air pollution, by halting the flow of traffic on the A26 while construction of a roundabout would have a material impact on the character of the AONB landscape (as would any widening of the A26).

Safe and acceptable pedestrian and cycle linkages to Southborough are also required (policy point 2).   At this stage we feel that there is too little information available re Scheme 404 (Cycling corridor and rights of way between Tunbridge Wells and Tonbridge) which appears to be the route that would serve the development at AL/SO 3, and will comment when the Walking and Cycling Strategy is published.

Pedestrian access to Southborough and Tonbridge via the A26 is not safe and I see no indications that any improvements are proposed in the Draft Local Plan. There is a narrow pavement on only one side of the road and there are no controlled pedestrian crossings.  Traffic speeds make walking here both unpleasant and unsafe.  Getting to a bus stop on the other side of the road involves jaywalking through 40mph traffic – not safe for anyone, but impossible for the elderly or those with young children.  Cars will continue to be used for the majority of journeys.

4. Land-based economic development and rural life

The proposed housing development is neither connected to, nor essential for, land based economic development on this site and it is unclear why the housing element has been included in the allocation.

I believe that the majority of the land within the site is leased to two tenant farmers and has been used in recent years as grazing for cattle, sheep, and horses stabled at the Honiton Equestrian Centre (south of Vauxhall Lane, and not itself included within this site).  The informal tracks within the site have also been used for exercising horses from the Honiton Equestrian Centre. The landowners already have an obligation to improve (for the 25 years) some of the agricultural land on this site under an S106 agreement in November 2014 in relation to the planning application 14/00870 for a Solar Park on other land which they own.

Obviously I cannot comment on the current economic viability of the agricultural uses on this site.  However I have not seen any evidence in the DLP document set that there is a need for affordable housing (and other infrastructure and amenities) for rural communities on this site to meet Objective LBE2 in the High Weald AONB Management Plan nor that erection of rural workers dwellings here would be essential under the provisions of Policy H10 in the Draft Local Plan.

In relation to the proposed land-based economic development per se, in addition to the Development Management Policies already referenced in point 8f of Policy AL/SO 3 as a minimum the following should also apply: EN22, ED4, ED5, ED6 and ED7.  I am also surprised that there is no requirement for supporting woodland management and rural crafts as set out in the “Statement of Significance” in the High Weald AONB Management Plan (and quoted in the Distribution of Development Paper)

5. Ecology and Biodiversity

I believe that the potential impact of the proposed development on ecology and biodiversity has been seriously underestimated in the Draft Local Plan. The site includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a wide variety of species. The gill woodlands and shaws provide important corridors for wildlife and are rich in biodiversity.  There are traditional orchards, now a rare habitat.  In addition the site is on a green corridor of Ancient Woodland (Coxon Wood, Beeches Wood, Nightingale Wood and Minepit Wood ) which provides a natural habitat for plants, animals and birds.  The Dark Skies provide an essential haven for nocturnal wildlife; at night owls can be heard hooting, foxes calling and badgers foraging.

It is unclear how development here would protect and enhance biodiversity and geodiversity.

6. Heritage Assets

The impact of the proposed development on listed buildings and other heritage assets within or bordering the site does not appear to have been assessed.

7. Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain with run-off from the A26 and higher ground. There is network of underground streams and springs in addition to the visible stream and ponds within the site.  This is not ideal land for development and will be made worse by the creation of additional impermeable surfaces for housing, roadways etc.

8. Infrastructure

This development will put further pressure on the infrastructure in Southborough.  There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_7496

Manor Fields Management Committee

 

I refer to the Plan with specific reference to the area adjacent to the A21/A26 junction around Mabledon Farm towards Vauxhall Lane.and wish to add my support to the various objecting submissions made by the residents around Hangmans Hill and also my neighbour here in Manor Fields, namely Des Joyner.

Manor Fields' sole road access is via the A26 London Road and the volume of traffic is considerable as no doubt the recent survey and assessment of vehicle numbers will reveal. The pollution is aggravated by frequent traffic queues caused by a whole myriad of reasons such as road works for the service needs of the many connections along the full length of the A26 between the A21 and Tunbridge Wells and road, traffic lights and road marking alterations. I know of near neighbours that have moved away from the area because of the pollution levels, which they measured.

In addition to all the valid points raised by those persons I referred to in my first paragraph I would like to remind all those at TWBC of the Council's recent adoption of the High Weald AONB Management Plan 2019-2024 as required by Section 89 of the Countryside and Rights of Way Act 2000. It is difficult to find the final text of the Plan from the Council's website but the draft contained the following:

'Permitted Development Rights

The status of an AONB is equivalent to that of the National Parks and together they share the highest level of protection in relation to landscape and scenic beauty. 

Designation demands that planning policies and decisions should focus on the conservation and enhancement of the landscape. The conservation of wildlife and cultural heritage are also important considerations.

We recognise the importance of this area and will only permit development if it protects or enhances the natural beauty and special characteristics of the area. 

Major developments should not take place in these designated areas except in exceptional circumstances.' 

On the face of it, the Council's development plan for the area in question will potentially be in conflict with its own AONB Management Plan as the land is very much in the designated protected area and by no means part of the Tunbridge Wells urban area.

I hope my comments will be given due and responsible consideration.

DLP_7537

Colin Clarke

Object

object to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

Green Belt

This 171-hectare space of Green Belt land is the last buffer between Tonbridge and Tunbridge Wells. Green Belt policy was created precisely for preventing this type of urban sprawl development which would result in the coalescence of town and city. Giving the go-ahead to a development “not to exceed 120 dwellings during this plan period” (Policy point 7) sets a dangerous precedent; a slippery slope which opens the door to even more extensive development on this site in the future. The council must draw a line in the sand now to honour national planning policy and give the Green Belt the respect it deserves.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

Myself and other residents disagree with the council’s conclusion that this release of Green Belt land is justified by exceptional circumstances. No exceptional circumstances have been demonstrated in the local plan. Housing need is not an exceptional circumstance. The government has been very clear that a “brownfield first” approach should be followed, consulting with neighbouring boroughs if required to satisfy housing supply needs. Stating that “the release of Green Belt land” is a strategic objective for the Local Plan demonstrates that the council is not taking the right approach.

AONB & Heritage Assets

The proposed allocation for a major development in the AONB goes directly against the key objectives of the High Weald AONB Management Plan agreed by the Council. It is the council’s duty to preserve AONB & their biodiversity and protect Heritage Assets. I urge councillors to read the outstanding article by the High Brooms Society on the history of the Southborough valley. They describe it as a “countryside of such loveliness that it takes your breath away; where one sees nothing but beautiful woods, green fields on slopes and wild flowers, embraced by the undulating lap of the High Weald of Kent.”  The Society goes on to say that “the walk from Southborough to the Vauxhall Inn through the valley has been recently named as one of the Great British Walks.” King George III came here to shoot game. While the Duke of Wellington came for foxes.

In fact, this is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge.  It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls).  The gill woodlands and shaws provide important corridors, rich in biodiversity.  There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

  • the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
  • the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Has TWBC consulted with the AONB Forum of the High Weald AONB in relation to the site? The narrative in the local plan is unclear and unacceptably vague on this and number of other points.

As this landscape offers a connection both to nature and our shared history, I ask the council not to allow its destruction.

Flooding 

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs.  This is not ideal land for development and will be made worse by additional impermeable surfaces. The news from Sheffield this weekend of unprecedented rainfall should give us pause to consider how climate change will increase flooding risk in the future.

Infrastructure

The location of this site is on the borough boundary of Tonbridge & Tunbridge Wells, and Tonbridge & Malling Borough Council have raised “serious concerns” about the TWBC Local Plan. Specifically, that "the proximity of some of the major development proposals to the borough boundary and specifically, the south east of our main settlement of Tonbridge, is a matter of serious concern due to the potential impacts on the local highway network, rail services and other community infrastructure including health care and education, particularly when combined with planned developments in Tonbridge as part of our own Local Plan."

Despite the fact that Tonbridge train station, high street, supermarket, and associated car parks are closer than any TWBC alternative, none of the council tax revenue from these new homes would support infrastructure in Tonbridge, a fundamental flaw in the planning process which must be addressed.

This is snapshot of the current rush hour traffic ques in all directions on the Tonbridge side.

[TWBC: see image]

The fact that Highways concerns were not raised in the Mabledon/Nightingale evaluation is further evidence of the lack of due care being shown to the residents of Tonbridge and another example of flawed planning.

This development will also put further pressure on the infrastructure in Southborough.  There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

A26 -Traffic and Air Quality 

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development.  Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc).  These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic.  Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided.  There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups.

There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

In conclusion, while I appreciate the great challenge of meeting future housing needs, the convenience of partnering with a single landowner does not override the council’s obligations to national policy and the residents of Southborough & Tonbridge.

DLP_7618

Christine and Michael Gambles

Object

My husband and I are writing to object in the strongest possible terms about the proposal to build houses on the land adjacent to Mabledon farm and Nightingale Farm off Vauxhall Lane.

We object for the following reasons:-

  1. This is an area of outstanding natural beauty and incorporates an historic farmstead.
  2. Both the A26 (which is accessible from either end of Vauxhall Lane) and Vauxhall Lane roads and surrounding areas already have unacceptably high levels of pollution.
  3. Both the A26 and Vauxhall Lane roads are already heavily congested.
  4. The A26 is generally acknowledged to be the busiest "A" road in Kent.  Even now travelling in rush hour is to be avoided.
  5. The recent granting of a licence for a drive-in cinema throughout the year at Honnington has already increased the volume of traffic on Vauxhall Lane.
  6. Vauxhall Lane itself is a narrow country road, which is already heavily congested on account of it being used as a cut-through for the school run.  At points, the road is virtually single track and actually becomes that at Tonbridge Cottage hospital, where there is a one way bridge over the railway.
  7. There are more suitable areas of brown field land available for building (albeit at a higher cost) such as the Colas site in Tonbridge.
  8. This is the thin edge of the wedge and, if permitted, will no doubt allow sprawling urbanisation to continue in the beautiful countryside.

We respectfully ask that the above points are taken into consideration.

DLP_7693

Leah

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);
ii) where the housing, roads and other buildings are going to be located; and
iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Vauxhall Lane

This 2-mile long road links the A26 with the A21 and consequently attracts an already absurdly high volume of rush hour traffic, with school traffic using it as a rat-run to reach all the Tonbridge schools. In the event of road works or accidents on either of these main roads, it quickly becomes even more congested. It is a pretty, leafy, narrow winding lane, completely unsuited to so much traffic, being poorly maintained, with disintegrating edges, ever-increasing potholes, and a semi-permanent flood on the dangerous bend opposite Honnington Farm due to a drain that is seldom cleared, with a concrete surround that is constantly smashed by traffic trying to avoid on-coming vehicles. Should the Mabledon Farm development go ahead, cars in and out of the access road into Vauxhall Lane would increase traffic enormously. The Vauxhall Lane railway bridge below the Cottage Hospital is very narrow, and would need to be rebuilt to take lorries and extra traffic.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_7709

Julia Prentice

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);
ii) where the housing, roads and other buildings are going to be located; and
iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children. My son has to cross this road when returning from school. It is already extremely concerning as there is no safe crossing place.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

My property has already flooded in December 2013 and this is something that concerns me.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_7775

Jacqueline Arscott
Hangman's Hill Residents Association

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

The Hangman’s Hill Residents Association (HHRA)represents those living on or close to the section of London Road, Southborough (the A26) that is between Vauxhall Lane and Mabledon. We aim to play an active role in localism and shaping the future of Southborough and are particularly concerned with protecting the countryside that lies between the urban areas of Southborough and Tonbridge. This response from the HHRA Committee is based upon discussions with our membership and our analysis of the wider set of Draft Local Plan documentation.

The HHRA Committee strongly objects to the proposed allocation of AL/SO 3 Land at Mabledon and Nightingale for a mixed use scheme to include land-based economic development and approximately 50-120 residential dwellings on the basis of

  • the lack of clarity in the Draft Local Plan documentation set regarding the proposal;
  • the potential for inappropriate development in the AONB and the Green Belt;
  • increased traffic congestion on the A26, including in the Southborough AQMA and
  • environmental impacts.

1. Lack of Clarity regarding the Proposal

HHRA is surprised that TWBC have seen fit to include as a proposed allocation where there appears to be

a) confusion as to where the site is :

- Draft Local Plan para 5.53 incorrectly states that it is the Main Urban Area, and this is error is repeated or implied in a number of the Supporting Documents

b) lack of clarity as to the extent of development proposed apart from housing:

- Buildings for land based economic development (policy point 8b) – what and how many?

- Community facilities including buildings (policy point 8c) – what and how many?

- utility cycle tracks within the site to link to Southborough and Tonbridge, hich will be tarmacked and lit for safety reasons

- roads within the site to link “scattered forms of development”

- buildings and spaces to provide cultural infrastructure (Exhibition Board 19)

c) a need for additional studies to determine where developments (housing and other) could be located while still avoiding the multitude of constraints;

- much of the allocated area was put forward in the 2016 Call for Sites (Sites: 179 -

Mabledon Farm, 180 - Nightingale Farm and 181 – Moatenden)

- the environmental and landscape constraints are well covered in the relevant Environment & Landscape Supporting Documents on the Local Plan website

d) no calculation of what land take will be required for the developments.

- The site boundaries are not shown on the policy maps however ee note from the SHELAA (Site reference 445 – 16. Southborough Sites) that the site is approximately 171 hectares.

- the 50-120 dwelling proposed for the current plan period in Policy AL/SO3 would only require 8 hectares using a density of 15 dwellings per hectare for a mixed use development or 3 hectares using a density of 40 dwellings per hectare on a greenfield site.

We consider that the vagueness of this proposed allocation simply establishes that development in this area is acceptable to TWBC, setting a dangerous precedent for the future. Our very serious concern it the landowners (the Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed. The “Potential yield if residential” in the SHELAA should reflect that the stated developable area is 125 hectares giving a potential yield of 1,875 dwellings using a density 15 dwellings per hectare for a mixed-use development, or 5,000 dwellings using a density of 40 dwellings per hectare on a greenfield site.

A planning application has recently (August 2019) been submitted by the landowner for one small part of the site (19/02361 Moatenden - 1.14 hectares) which cites the lack of a 5-year housing supply. What is to stop further applications for other areas at any point in the future when Tunbridge Wells cannot demonstrate a 5-year housing supply? Additionally, approximately a quarter of the site is in the borough of Tonbridge and Malling, and includes direct access from Vauxhall Lane within that borough, giving further options for development.

Until the location(s) and extent of development are confirmed it is premature to propose allocating this site in the Draft Local Plan.

2. High Weald AONB

HHRA is very concerned that the reasons for allocating this site for housing development are not clearly set out in the Draft Local Plan documentation set. From the information provided this allocation is likely to cause significant harm to the character of the AONB and there are no “exceptional circumstances” as defined in the NPPF paragraph 172.

Additionally we have found no evidence to support the Council’s view that it will provide “an exemplar scheme inspired by the underlying historical character of the High Weald ” (although we have noticed that “exemplar” appears to be the buzzword for developments proposed by this landowner, who also owns the site at Tudeley which is proposed for the “Garden Village).

a) Assessment of harm to AONB Character

From a landscape perspective this site is rural in nature and forms a strategic gap between Tonbridge and Southborough. It lies within sub areas SP5 and SP6 in the 2017 Landscape Sensitivity Assessment of Countryside around Tunbridge Wells and this report highlights the many landscape features typical of the High Weald AONB. Both areas are assessed as having a high sensitivity to any scale of development. The report does suggest that, within sub area SP5 “there may be pockets of land associated with existing development where sensitivity to small-scale development could be relatively contained in the wider landscape” but does not specify where these pockets might be. Mabledon Farm is the only existing development that is both within the allocated site and sub-area SP5, suggesting that a scattered development would not satisfy this requirement.

The Southborough section of the Historic Landscape Characterisation gives further evidence of the historic importance of this site. The main report highlights that “whilst dispersed plans may offer opportunities for additional dwellings, the very process can easily destroy the historic layout and character of the farmstead” (para 4.1, Section 1 – User Guide & Interpretation). Mabledon Farm is a historic farmstead, with assart fields and traditional orchards close to it.

The conclusions in these reports are reflected in the assessment of High Impact on the AONB in the Distribution of Development Topic Paper (App. 3: Assessment of AONB Sites - Site Policy Ref SO 3).

In the light of the above, we question why the Council chose to support the development proposal for Mabledon/Nightingale and include an allocation for this site in the Draft Local Plan. Paragraph

6.85 of the Distribution of Development Topic Paper states that “where development is considered likely to cause significant harm to the defining character of the AONB (also having regard to potential  mitigation) or cause harm disproportionate to likely benefits of the scheme, then that development will be very unlikely to be supported”.

The mitigation proposed for this development appears to be the “farmstead approach” which is nowhere defined nor expanded upon. The suggestion in the Distribution of Development Topic Paper (App 3) that there is “ a very restrictive policy requiring positive landscape outcomes ” is simply untrue. The only restriction in the Policy for AL/SO 3 is that housing development will be limited to 120 dwellings in this plan period. As the Council specifically exclude sites allocated in

the local plan from the provisions of Policy EN21, and the AONB Joint Advisory Committee’s role in the development will only be to provide “ input to the vision and design process” , there appear to be no restrictions in Policy AL/SO 3 to protect the landscape from  inappropriate development.

b) Major development in AONB

The Distribution of Development Topic Paper highlights the provisions of the NPPF with regard to AONBs (para 3.8 – 3.11) and suggests that TWBC believe that the proposed development is likely to be classed as major development in theAONB, highlighting that its scale is “very substantial” relative to the existing settlement.(App. 3: Assessment of AONB Sites - Site Policy Ref SO 3, Distribution of Development Topic Paper)

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. Consideration of such applications should include an assessment of:

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”.

It is nonsensical for the Council to present an assessement of major developments within the AONB against the NPPF requirements as a single entity, as is done in the table under para 6.101 in the Distribution of Development Topic Paper. The individual site level assessments are not described in in the Distribution of Development Topic Paper or the SHELAA. We are concerned therefore that no

evidence is given of the “exceptional circumstances” specific to the proposed AL/SO3 allocation; in particular we cannot see that the need for up to 120 dwellings could not be met in some other way within the borough as a whole, with the council already proposing to allocate 9% more housing than required by the OAN calculations.

We also question the Council’s reliance on “unique circumstances” as justification referenced throughout the Draft Local Plan document set. These appear to be that a farmstead (Mabledon Farm) and its surrounding land are in a single ownership. It is a very disturbing statement on the state of a predominantly rural borough if this is true!

In conclusion we can see no justification for the proposed allocation for development of this large site in the AONB. The Distribution of Development Topic Paper para 6.89 supports the view that this proposal should have been rejected by the Council as not being a “reasonable option”.

Green Belt

AL/SO3 provides the one-mile wide Green Belt separation east of the A26 between the built-up areas of Southborough and Tonbridge. Housing development here would be contrary to the purposes of the Green Belt as set out in paragraphs 133-134 of the NPPF:

“The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

Green Belt serves five purposes:

a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

In the Stage 2 TWBC Green Belt Study this site falls within Broad Area 1, we assume due to its rural nature. BA1 is assessed as making a STRONG contribution to each of the Green Belt purposes a) through d).

It is unclear what assessments of the potential for harm to this area of Green Belt the Council have carried out in proposing this allocation. The Green Belt designation is not included in the “Issues to consider” section of the SHELAA (Site ref 445 – Section 16. Southborough Site) and we cannot find any discussion of the reasons behind the decision that this site should remain in the Green Belt. The Assessment of Green Belt Sites (App 1 Distribution of Development Topic Paper) has N/A for

● Allocation Area within MGB
● Hectares to remove from MGB
● Site Size
● Site % in MGB
● Housing Min as % of site in MGB

● Housing Max as % of site in MGB

As this table also has the housing numbers and masterplanning for AL/SO3 shown under SO4 (the hotel/leisure development, we can only assume that no consideration at all has been given to Green Belt purposes in allocating this site. We suggest that the intent in the NPPF is to protect the Green Belt from inappropriate development, not to allow unconstrained development simply by the Council declaring that a developed site will remain in the Green Belt. In this instance it seems as if the Council has simply avoided the need to demonstrate “exceptional circumstances” by ignoring the sites contribution to the Green Belt purposes.

Without knowing the location and extent of development it is impossible to say what impact the proposed developments would have on the openness of this area of the Green Belt. There are views into the site from a variety of locations - the A26, a PROW to Haysden (higher up the ridge) or the footpath near the Cottage Hospital (lower down the valley). Any development at the southern end of the site would be visible from Vauxhall Lane (a designated Rural Lane) and the Tunbridge Wells Circular Walk.

3. Transport and Active Travel

a) Congestion and Air Quality

We are very concerned that additional traffic from this new  development will simply exacerbate the existing congestion and air quality on the section of the A26 near the site and in the nearby AGMA in Southborough. The situation will be made even worse by the volume of traffic likely to be generated by the proposed hotel and leisure complex at Mabledon House (AL/SO3). We are unsure how the smart traffic management system proposed in the Transport Evidence Base, synchronising traffic lights, will improve the traffic flows on the A26 past the Mabledon/Nightingale site when there are no traffic lights here and the speed limit is 40mph, 10mph higher than the speed limit in the urban area of Southborough. Additionally, this is a single-carriageway road with traffic halted by buses picking up/dropping off passengers and vehicles slowing or stopping to turn into private driveways.

b) Safety

The Policy for AL/SO3 requires “safe and acceptable access arrangements from the A26 for the proposed development with, where required, a secondary emergency access” . (policy point 1). We note that the junction performance assessment for AL/SO3 allocation in the Transport Evidence Base was carried out based upon 100 dwellings accessing the A26 via Vauxhall Lane. We are confused by this approach as Vauxhall Lane is at the opposite end of the site to Mabledon Farm on which the development would be centred. Vauxhall Lane is a narrow lane with complex topography and a “blind” junction with the A26; it is totally unsuited to such an increase in traffic.

The more obvious access to the A26 would be through upgrading the current PROW from Mabledon Farm to the A26. Unfortunately this would result in traffic leaving/joining the A26 in close proximity to the access to the proposed hotel and leisure complex at Mabledon House (AL/SO4). This stretch of road has a 40mph speed limit and this limit is frequently exceeded as vehicles approach the slip road to the A21. It is unclear how traffic from the new development could safely pull out onto the A26. We believe that traffic lights would only serve to increase congestion and air pollution, by halting the flow of traffic on the A26 while construction of a roundabout would have a material impact on the character of the AONB landscape (as would any widening of the A26).

Safe and acceptable pedestrian and cycle linkages to Southborough are also required(policy point 2). At this stage we feel that there is too little information available re Scheme 404 (Cycling corridor and rights of way between Tunbridge Wells and Tonbridge) which appears to be the route that would serve the development at AL/SO 3, and will comment when the Walking and Cycling Strategy is published.

Pedestrian access to Southborough and Tonbridge via the A26 is not safe and we see no indications that any improvements are proposed in the Draft Local Plan. There is a narrow pavement on only one side of the road and there are no controlled pedestrian crossings. Traffic speeds make walking here both unpleasant and unsafe. Getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but impossible for the elderly or those with young children. Cars will continue to be used for the majority of journeys.

4. Land-based economic development and rural life

The proposed housing development is neither connected to, nor essential for, land based economic development on this site and it is unclear why the housing element has been included in the allocation.

We believe that the majority of the land within the site is leased to two tenant farmers and has been used in recent years as grazing for cattle, sheep, and horses stabled at the Honnigton Equestrian Centre (south of Vauxhall Lane, and not itself included within this site). The informal

tracks within the site have also been used for exercising horses from the Honnigton Equestrian Centre. The landowners already have an obligation to improve (for the 25 years) some of the agricultural land on this site under an S106 agreement in November 2014 in relation to the planning application 14/00870 for a Solar Park on other land which they own.

Obviously we cannot comment on the current economic viability of the agricultural uses on this site. However we have not seen any evidence in the DLP document set that there is a need for affordable housing (and other infrastructure and amenities) for rural communities on this site to meet Objective LBE2 in the High Weald AONB Management Plan nor that erection of rural workers dwellings here would be essential under the provisions of Policy H10 in the Draft Local Plan.

In relation to the proposed land-based economic development per se, in addition to the Development Management Policies already referenced in point 8f of Policy AL/SO 3 as a minimum the following should also apply: EN22, ED4, ED5, ED6 and ED7. We also surprised that there is no requirement for supporting woodland management and rural crafts as set out in the “Statement of Significance” in the High Weald AONB Management Plan (and quoted in the Distribution of

Development Paper)

5. Ecology and Biodiversity

We believe that the potential impact of the proposed development on ecology and biodiversity has been seriously underestimated in the Draft Local Plan. The site includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a wide variety of species. The gill woodlands and shaws provide important corridors for wildlife and are rich in biodiversity. There are traditional orchards, now a rare habitat. In addition the site is on a green corridor of Ancient Woodland (Coxon Wood, Beeches Wood, Nightingale Wood and Minepit Wood )which provides a natural habitat for plants, animals and birds. The Dark Skies provide an essential haven for nocturnal wildlife; at night owls can be heard hooting, foxes calling and badgers foragaing.

It is unclear how development here would protect and enhance biodiversity and geodiversity

6. Heritage Assets

The impact of the proposed development on listed buildings and other heritage assets within or bordering the site does not appear to have been assessed.

7. Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain with run-off from the A26 and higher ground. There is network of underground streams and springs in addition to the visible stream and ponds within the site. This is not ideal land for development and will be made worse by the creation of additional impermeable surfaces for housing, roadways etc.

We are also aware that the mains sewer is located at the rear of the gardens of the strip of houses beside the A26 and there is a Southern Water pumping station near this (within the site). As there are steep slopes in this area, falling away from the A26, we would like to be assured that appropriate measures are planned for connection of new properties to the mains sewage pipes has been considered.

8. Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_7904

Fiona Dagger

Object

Major development is not appropriate in the AONB. TWBC have accepted that Mabledon and Nightingale is major development but have not explained how the sequential tests required by NPPF, para. 172 have been met.

The draft Local Plan’s own policy on the AONB (EN21) recognises that development sites in the AONB need to be limited in size. This approach reflects agreed policy in the AONB Management Plan which seeks ‘to prioritise the delivery of new housing primarily through small-scale development and a mix of housing sizes that responds to local needs’.

DLP_7988

Peter Evans
Hangman's Hill Residents Association

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

The Hangman’s Hill Residents Association (HHRA)represents those living on or close to the section of London Road, Southborough (the A26) that is between Vauxhall Lane and Mabledon. We aim to play an active role in localism and shaping the future of Southborough and are particularly concerned with protecting the countryside that lies between the urban areas of Southborough and Tonbridge. This response from the HHRA Committee is based upon discussions with our membership and our analysis of the wider set of Draft Local Plan documentation.

The HHRA Committee strongly objects to the proposed allocation of AL/SO 3 Land at Mabledon and Nightingale for a mixed use scheme to include land-based economic development and approximately 50-120 residential dwellings on the basis of

  • the lack of clarity in the Draft Local Plan documentation set regarding the proposal;
  • the potential for inappropriate development in the AONB and the Green Belt;
  • increased traffic congestion on the A26, including in the Southborough AQMA and
  • environmental impacts.

1. Lack of Clarity regarding the Proposal

HHRA is surprised that TWBC have seen fit to include as a proposed allocation where there appears to be

a) confusion as to where the site is :

- Draft Local Plan para 5.53 incorrectly states that it is the Main Urban Area, and this is error is repeated or implied in a number of the Supporting Documents

b) lack of clarity as to the extent of development proposed apart from housing:

- Buildings for land based economic development (policy point 8b) – what and how many?

- Community facilities including buildings (policy point 8c) – what and how many?

- utility cycle tracks within the site to link to Southborough and Tonbridge, hich will be tarmacked and lit for safety reasons

- roads within the site to link “scattered forms of development”

- buildings and spaces to provide cultural infrastructure (Exhibition Board 19)

c) a need for additional studies to determine where developments (housing and other) could be located while still avoiding the multitude of constraints;

- much of the allocated area was put forward in the 2016 Call for Sites (Sites: 179 -

Mabledon Farm, 180 - Nightingale Farm and 181 – Moatenden)

- the environmental and landscape constraints are well covered in the relevant Environment & Landscape Supporting Documents on the Local Plan website

d) no calculation of what land take will be required for the developments.

- The site boundaries are not shown on the policy maps however ee note from the SHELAA (Site reference 445 – 16. Southborough Sites) that the site is approximately 171 hectares.

- the 50-120 dwelling proposed for the current plan period in Policy AL/SO3 would only require 8 hectares using a density of 15 dwellings per hectare for a mixed use development or 3 hectares using a density of 40 dwellings per hectare on a greenfield site.

We consider that the vagueness of this proposed allocation simply establishes that development in this area is acceptable to TWBC, setting a dangerous precedent for the future. Our very serious concern it the landowners (the Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed. The “Potential yield if residential” in the SHELAA should reflect that the stated developable area is 125 hectares giving a potential yield of 1,875 dwellings using a density 15 dwellings per hectare for a mixed-use development, or 5,000 dwellings using a density of 40 dwellings per hectare on a greenfield site.

A planning application has recently (August 2019) been submitted by the landowner for one small part of the site (19/02361 Moatenden - 1.14 hectares) which cites the lack of a 5-year housing supply. What is to stop further applications for other areas at any point in the future when Tunbridge Wells cannot demonstrate a 5-year housing supply? Additionally, approximately a quarter of the site is in the borough of Tonbridge and Malling, and includes direct access from Vauxhall Lane within that borough, giving further options for development.

Until the location(s) and extent of development are confirmed it is premature to propose allocating this site in the Draft Local Plan.

2. High Weald AONB

HHRA is very concerned that the reasons for allocating this site for housing development are not clearly set out in the Draft Local Plan documentation set. From the information provided this allocation is likely to cause significant harm to the character of the AONB and there are no “exceptional circumstances” as defined in the NPPF paragraph 172.

Additionally we have found no evidence to support the Council’s view that it will provide “an exemplar scheme inspired by the underlying historical character of the High Weald ” (although we have noticed that “exemplar” appears to be the buzzword for developments proposed by this landowner, who also owns the site at Tudeley which is proposed for the “Garden Village).

a) Assessment of harm to AONB Character

From a landscape perspective this site is rural in nature and forms a strategic gap between Tonbridge and Southborough. It lies within sub areas SP5 and SP6 in the 2017 Landscape Sensitivity Assessment of Countryside around Tunbridge Wells and this report highlights the many landscape features typical of the High Weald AONB. Both areas are assessed as having a high sensitivity to any scale of development. The report does suggest that, within sub area SP5 “there may be pockets of land associated with existing development where sensitivity to small-scale development could be relatively contained in the wider landscape” but does not specify where these pockets might be. Mabledon Farm is the only existing development that is both within the allocated site and sub-area SP5, suggesting that a scattered development would not satisfy this requirement.

The Southborough section of the Historic Landscape Characterisation gives further evidence of the historic importance of this site. The main report highlights that “whilst dispersed plans may offer opportunities for additional dwellings, the very process can easily destroy the historic layout and character of the farmstead” (para 4.1, Section 1 – User Guide & Interpretation). Mabledon Farm is a historic farmstead, with assart fields and traditional orchards close to it.

The conclusions in these reports are reflected in the assessment of High Impact on the AONB in the Distribution of Development Topic Paper (App. 3: Assessment of AONB Sites - Site Policy Ref SO 3).

In the light of the above, we question why the Council chose to support the development proposal for Mabledon/Nightingale and include an allocation for this site in the Draft Local Plan. Paragraph

6.85 of the Distribution of Development Topic Paper states that “where development is considered likely to cause significant harm to the defining character of the AONB (also having regard to potential  mitigation) or cause harm disproportionate to likely benefits of the scheme, then that development will be very unlikely to be supported”.

The mitigation proposed for this development appears to be the “farmstead approach” which is nowhere defined nor expanded upon. The suggestion in the Distribution of Development Topic Paper (App 3) that there is “ a very restrictive policy requiring positive landscape outcomes ” is simply untrue. The only restriction in the Policy for AL/SO 3 is that housing development will be limited to 120 dwellings in this plan period. As the Council specifically exclude sites allocated in

the local plan from the provisions of Policy EN21, and the AONB Joint Advisory Committee’s role in the development will only be to provide “ input to the vision and design process” , there appear to be no restrictions in Policy AL/SO 3 to protect the landscape from  inappropriate development.

b) Major development in AONB

The Distribution of Development Topic Paper highlights the provisions of the NPPF with regard to AONBs (para 3.8 – 3.11) and suggests that TWBC believe that the proposed development is likely to be classed as major development in theAONB, highlighting that its scale is “very substantial” relative to the existing settlement.(App. 3: Assessment of AONB Sites - Site Policy Ref SO 3, Distribution of Development Topic Paper)

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. Consideration of such applications should include an assessment of:

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”.

It is nonsensical for the Council to present an assessement of major developments within the AONB against the NPPF requirements as a single entity, as is done in the table under para 6.101 in the Distribution of Development Topic Paper. The individual site level assessments are not described in in the Distribution of Development Topic Paper or the SHELAA. We are concerned therefore that no

evidence is given of the “exceptional circumstances” specific to the proposed AL/SO3 allocation; in particular we cannot see that the need for up to 120 dwellings could not be met in some other way within the borough as a whole, with the council already proposing to allocate 9% more housing than required by the OAN calculations.

We also question the Council’s reliance on “unique circumstances” as justification referenced throughout the Draft Local Plan document set. These appear to be that a farmstead (Mabledon Farm) and its surrounding land are in a single ownership. It is a very disturbing statement on the state of a predominantly rural borough if this is true!

In conclusion we can see no justification for the proposed allocation for development of this large site in the AONB. The Distribution of Development Topic Paper para 6.89 supports the view that this proposal should have been rejected by the Council as not being a “reasonable option”.

Green Belt

AL/SO3 provides the one-mile wide Green Belt separation east of the A26 between the built-up areas of Southborough and Tonbridge. Housing development here would be contrary to the purposes of the Green Belt as set out in paragraphs 133-134 of the NPPF:

“The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

Green Belt serves five purposes:

a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

In the Stage 2 TWBC Green Belt Study this site falls within Broad Area 1, we assume due to its rural nature. BA1 is assessed as making a STRONG contribution to each of the Green Belt purposes a) through d).

It is unclear what assessments of the potential for harm to this area of Green Belt the Council have carried out in proposing this allocation. The Green Belt designation is not included in the “Issues to consider” section of the SHELAA (Site ref 445 – Section 16. Southborough Site) and we cannot find any discussion of the reasons behind the decision that this site should remain in the Green Belt. The Assessment of Green Belt Sites (App 1 Distribution of Development Topic Paper) has N/A for

● Allocation Area within MGB
● Hectares to remove from MGB
● Site Size
● Site % in MGB
● Housing Min as % of site in MGB

● Housing Max as % of site in MGB

As this table also has the housing numbers and masterplanning for AL/SO3 shown under SO4 (the hotel/leisure development, we can only assume that no consideration at all has been given to Green Belt purposes in allocating this site. We suggest that the intent in the NPPF is to protect the Green Belt from inappropriate development, not to allow unconstrained development simply by the Council declaring that a developed site will remain in the Green Belt. In this instance it seems as if the Council has simply avoided the need to demonstrate “exceptional circumstances” by ignoring the sites contribution to the Green Belt purposes.

Without knowing the location and extent of development it is impossible to say what impact the proposed developments would have on the openness of this area of the Green Belt. There are views into the site from a variety of locations - the A26, a PROW to Haysden (higher up the ridge) or the footpath near the Cottage Hospital (lower down the valley). Any development at the southern end of the site would be visible from Vauxhall Lane (a designated Rural Lane) and the Tunbridge Wells Circular Walk.

3. Transport and Active Travel

a) Congestion and Air Quality

We are very concerned that additional traffic from this new  development will simply exacerbate the existing congestion and air quality on the section of the A26 near the site and in the nearby AGMA in Southborough. The situation will be made even worse by the volume of traffic likely to be generated by the proposed hotel and leisure complex at Mabledon House (AL/SO3). We are unsure how the smart traffic management system proposed in the Transport Evidence Base, synchronising traffic lights, will improve the traffic flows on the A26 past the Mabledon/Nightingale site when there are no traffic lights here and the speed limit is 40mph, 10mph higher than the speed limit in the urban area of Southborough. Additionally, this is a single-carriageway road with traffic halted by buses picking up/dropping off passengers and vehicles slowing or stopping to turn into private driveways.

b) Safety

The Policy for AL/SO3 requires “safe and acceptable access arrangements from the A26 for the proposed development with, where required, a secondary emergency access” . (policy point 1). We note that the junction performance assessment for AL/SO3 allocation in the Transport Evidence Base was carried out based upon 100 dwellings accessing the A26 via Vauxhall Lane. We are confused by this approach as Vauxhall Lane is at the opposite end of the site to Mabledon Farm on which the development would be centred. Vauxhall Lane is a narrow lane with complex topography and a “blind” junction with the A26; it is totally unsuited to such an increase in traffic.

The more obvious access to the A26 would be through upgrading the current PROW from Mabledon Farm to the A26. Unfortunately this would result in traffic leaving/joining the A26 in close proximity to the access to the proposed hotel and leisure complex at Mabledon House (AL/SO4). This stretch of road has a 40mph speed limit and this limit is frequently exceeded as vehicles approach the slip road to the A21. It is unclear how traffic from the new development could safely pull out onto the A26. We believe that traffic lights would only serve to increase congestion and air pollution, by halting the flow of traffic on the A26 while construction of a roundabout would have a material impact on the character of the AONB landscape (as would any widening of the A26).

Safe and acceptable pedestrian and cycle linkages to Southborough are also required(policy point 2). At this stage we feel that there is too little information available re Scheme 404 (Cycling corridor and rights of way between Tunbridge Wells and Tonbridge) which appears to be the route that would serve the development at AL/SO 3, and will comment when the Walking and Cycling Strategy is published.

Pedestrian access to Southborough and Tonbridge via the A26 is not safe and we see no indications that any improvements are proposed in the Draft Local Plan. There is a narrow pavement on only one side of the road and there are no controlled pedestrian crossings. Traffic speeds make walking here both unpleasant and unsafe. Getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but impossible for the elderly or those with young children. Cars will continue to be used for the majority of journeys.

4. Land-based economic development and rural life

The proposed housing development is neither connected to, nor essential for, land based economic development on this site and it is unclear why the housing element has been included in the allocation.

We believe that the majority of the land within the site is leased to two tenant farmers and has been used in recent years as grazing for cattle, sheep, and horses stabled at the Honnigton Equestrian Centre (south of Vauxhall Lane, and not itself included within this site). The informal

tracks within the site have also been used for exercising horses from the Honnigton Equestrian Centre. The landowners already have an obligation to improve (for the 25 years) some of the agricultural land on this site under an S106 agreement in November 2014 in relation to the planning application 14/00870 for a Solar Park on other land which they own.

Obviously we cannot comment on the current economic viability of the agricultural uses on this site. However we have not seen any evidence in the DLP document set that there is a need for affordable housing (and other infrastructure and amenities) for rural communities on this site to meet Objective LBE2 in the High Weald AONB Management Plan nor that erection of rural workers dwellings here would be essential under the provisions of Policy H10 in the Draft Local Plan.

In relation to the proposed land-based economic development per se, in addition to the Development Management Policies already referenced in point 8f of Policy AL/SO 3 as a minimum the following should also apply: EN22, ED4, ED5, ED6 and ED7. We also surprised that there is no requirement for supporting woodland management and rural crafts as set out in the “Statement of Significance” in the High Weald AONB Management Plan (and quoted in the Distribution of Development Paper)

5. Ecology and Biodiversity

We believe that the potential impact of the proposed development on ecology and biodiversity has been seriously underestimated in the Draft Local Plan. The site includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a wide variety of species. The gill woodlands and shaws provide important corridors for wildlife and are rich in biodiversity. There are traditional orchards, now a rare habitat. In addition the site is on a green corridor of Ancient Woodland (Coxon Wood, Beeches Wood, Nightingale Wood and Minepit Wood )which provides a natural habitat for plants, animals and birds. The Dark Skies provide an essential haven for nocturnal wildlife; at night owls can be heard hooting, foxes calling and badgers foragaing.

It is unclear how development here would protect and enhance biodiversity and geodiversity

6. Heritage Assets

The impact of the proposed development on listed buildings and other heritage assets within or bordering the site does not appear to have been assessed.

7. Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain with run-off from the A26 and higher ground. There is network of underground streams and springs in addition to the visible stream and ponds within the site. This is not ideal land for development and will be made worse by the creation of additional impermeable surfaces for housing, roadways etc.

We are also aware that the mains sewer is located at the rear of the gardens of the strip of houses beside the A26 and there is a Southern Water pumping station near this (within the site). As there are steep slopes in this area, falling away from the A26, we would like to be assured that appropriate measures are planned for connection of new properties to the mains sewage pipes has been considered.

8. Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_8028

Hangman's Hill Residents Association

Object

The Hangman’s Hill Residents Association (HHRA) represents households living on or close to the section of London Road, Southborough (the A26) that is between Vauxhall Lane and Mabledon. As of 14 November 2019, HHRA has approximately 100 households – signed up as members or supporters. We aim to play an active role in localism and shaping the future of Southborough and are particularly concerned with protecting the countryside that lies between the urban areas of Southborough and Tonbridge. This response from the HHRA Committee is based upon discussions with our membership and our analysis of the wider set of Draft Local Plan documentation.

The HHRA Committee strongly objects to the proposed allocation of AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential dwellings on the basis of:

1. the lack of clarity in the Draft Local Plan documentation set regarding the proposal;
2. the potential for inappropriate development in the AONB and the Green Belt;
3. increased traffic congestion on the A26, including in the Southborough AQMA;
4. environmental impacts; and
5. social impacts.

1. The lack of clarity in the Draft Local Plan documentation set regarding the proposal;

TWBC have opted to include the AL/SO 3 site as a proposed allocation. However, there appears to be:

a) confusion and lack of clarity as to where the site is:

* Draft Local Plan para 5.53 incorrectly states that it is the Main Urban Area, and this is error is repeated or implied in a number of the Supporting Documents

b) lack of clarity as to the extent of development proposed apart from housing:

* Buildings for land based economic development (policy point 8b) – unclear as to what this entails and how many

* Community facilities including buildings (policy point 8c) – unclear as to what this entails and the number of proposed facilities

* utility cycle tracks within the site to link to Southborough and Tonbridge, which will be tarmacked and lit for safety reasons * roads within the site to link “scattered forms of development”

* buildings and spaces to provide cultural infrastructure (Exhibition Board 19)

c) a need for additional studies to determine where developments (housing and other) could be located while still avoiding the multitude of constraints;

* much of the allocated area was put forward in the 2016 Call for Sites (Sites: 179 - Mabledon Farm, 180 - Nightingale Farm and 181 – Moatenden)

* the environmental and landscape constraints are well covered in the relevant Environment & Landscape Supporting Documents on the Local Plan website.

d) no calculation of what land take will be required for the developments

* The site boundaries are not shown on the policy maps, however we note from the SHELAA (Site reference 445 – 16. Southborough Sites) that the site is approximately 171 hectares.

* the 50-120 dwelling proposed for the current plan period in Policy AL/SO3 would only require 8 hectares using a density of 15 dwellings per hectare for a mixed-use development or 3 hectares using a density of 40 dwellings per hectare on a greenfield site.

We consider that the ambiguity together with the lack of clarity of this proposed allocation simply establishes that development in this area is, without due diligence or consideration, acceptable to TWBC, setting a dangerous precedent for the future.

Our very serious concern is that the landowners (the Hadlow Estate) or a developer could look to profit in the future from a much larger housing development than is currently proposed.

To highlight this risk the “Potential yield if residential” in the SHELAA should reflect that the stated developable area is 125 hectares giving a potential yield of 1,875 dwellings using a density 15 dwellings per hectare for a mixed-use development, or 5,000 dwellings using a density of 40 dwellings per hectare on a greenfield site.

A planning application has recently (August 2019) been submitted by the landowners (the Hadlow Estate) for one small part of the site (19/02361 Moatenden - 1.14 hectares) which cites the lack of a 5-year housing supply.

It is unclear what is to prevent further applications for other areas in the future when Tunbridge Wells cannot demonstrate a 5-year housing supply. Additionally, approximately a quarter of the site is in the borough of Tonbridge and Malling, and includes direct access from Vauxhall Lane within that borough, giving further options for development outside any constraints set in a Tunbridge Wells Local Plan.

Until the location(s) and extent of development are confirmed it is premature to propose allocating this site in the Draft Local Plan.

2. The potential for inappropriate development in the AONB and the Green Belt

2.1 High Weald AONB

The reasons for allocating this site for housing development are not clearly set out in the Draft Local Plan documentation set. From the information provided this allocation is likely to cause significant harm to the character of the AONB. Additionally, there are no “exceptional circumstances” as defined in the NPPF paragraph 172.

We have found no evidence to support the Council’s view that it will provide “an exemplar scheme inspired by the underlying historical character of the High Weald” (although we have noticed that “exemplar” appears to be the buzzword for developments proposed by this landowner (Hadlow Estate), which also owns the site at Tudeley which is proposed for the “Garden Village”).

a) Assessment of harm to AONB Character

From a landscape perspective this site is rural in nature and forms a strategic gap between Tonbridge and Southborough. It lies within sub areas SP5 and SP6 in the 2017 “Landscape Sensitivity Assessment of Countryside around Tunbridge Wells” report which highlights the many landscape features typical of the High Weald AONB in these sub-areas. Both areas are assessed as having a high sensitivity to any scale of development.

The report does suggest that, within sub area SP5 “there may be pockets of land associated with existing development where sensitivity to small-scale development could be relatively contained in the wider landscape” but does not specify where these pockets might be. Mabledon Farm is the only existing development that is both within the allocated site and sub-area SP5, suggesting that neither 120 dwellings centred on Mabledon Farm nor a scattered development would satisfy this condition.

The Southborough section of the “Historic Landscape Characterisation” report gives further evidence of the historic importance of this site. The main report highlights that “whilst dispersed plans may offer opportunities for additional dwellings, the very process can easily destroy the historic layout and character of the farmstead” (para 4.1, Section 1 – User Guide & Interpretation). Mabledon Farm is a historic farmstead, with assart fields and traditional orchards close to it.
The conclusions in these reports are reflected in the assessment of High Impact on the AONB in the Distribution of Development Topic Paper (App. 3: Assessment of AONB Sites - Site Policy Ref SO 3). In light of the above, we question why the Council chose to support the development proposal for Mabledon/Nightingale and include an allocation for this site in the Draft Local Plan. Paragraph 6.85 of the Distribution of Development Topic Paper states that “where development is considered likely to cause significant harm to the defining character of the AONB (also having regard to potential mitigation) or cause harm disproportionate to likely benefits of the scheme, then that development will be very unlikely to be supported”.

The mitigation proposed for this development appears to be the “farmstead approach” which is not defined nor expanded upon.

The suggestion in the Distribution of Development Topic Paper (App 3) that there is “a very restrictive policy requiring positive landscape outcomes” is untrue.

The only restriction in the Policy for AL/SO 3 is that housing development will be limited to 120 dwellings in this plan period. As the Council specifically excludes sites allocated in the Draft Local Plan from the provisions of Policy EN21, and the AONB Joint Advisory Committee’s role in the development will only be to provide “input to the vision and design process”, there appear to be no additional restrictions in Policy AL/SO 3 to protect the landscape from inappropriate development in the future.

b) Major development in AONB

The Distribution of Development Topic Paper highlights the provisions of the NPPF with regard to AONBs (para 3.8 – 3.11) and suggests that TWBC believe that the proposed development is likely to be classed as major development in the AONB, highlighting that its scale is “very substantial” relative to the existing settlement (App. 3: Assessment of AONB Sites - Site Policy Ref SO 3, Distribution of Development Topic Paper).

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. Consideration of such applications should include an assessment of:

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”.

It is nonsensical for the Council to present an assessment of major developments within the AONB against the NPPF requirements as a single entity, as outlined in the table under para 6.101 in the Distribution of Development Topic Paper. The individual site level assessments are not described in the Distribution of Development Topic Paper or the SHELAA.
No adequate evidence or explanations are given of the “exceptional circumstances” specific to the proposed AL/SO3 allocation. In particular we cannot see that the need for up to 120 dwellings could not be met in some other way within the borough, with the council already proposing to allocate 9% more housing than required by the OAN calculations.

In our view, no such “exceptional circumstances” exist, nor have been adequately articulated by the Council, to justify major development in the AONB.

We also question the Council’s reliance on “unique circumstances” as justification referenced throughout the Draft Local Plan document set. These appear to be that a farmstead (Mabledon Farm) and its surrounding land are in a single ownership. It is a very disturbing statement on the state of a predominantly rural borough if this is the case.

In conclusion, we can see no adequate justification for the proposed allocation for development of this site in the AONB. The Distribution of Development Topic Paper para 6.89 supports the view that this proposal should have been rejected by the Council as not being a “reasonable option”.

2.2. Green Belt

AL/SO3 site is not only in the Green Belt, but is the Green Belts separating east of the A26 between the built-up areas of Southborough and Tonbridge. It is now only a narrow strip – around one mile wide. Housing development here would be contrary to the purposes of the Green Belt as set out in paragraphs 133-134 of the NPPF: “The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

Green Belt serves five purposes:

a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

We assume due to its rural nature, in the Stage 2 TWBC Green Belt Study, this site falls within Broad Area 1, BA1 is assessed as making a STRONG contribution to each of the Green Belt purposes a) through d).

It is unclear what assessments of the potential for harm to this area of Green Belt the Council have carried out in proposing this allocation. The Green Belt designation is not included in the “Issues to consider” section of the SHELAA (Site ref 445 – Section 16. Southborough Site) and we cannot find any discussion of the reasons behind the decision that this site should remain in the Green Belt.

The Assessment of Green Belt Sites (App 1 Distribution of Development Topic Paper) has N/A for:

* Allocation Area within MGB

* Hectares to remove from MGB

* Site Size * Site % in MGB

* Housing Min as % of site in MGB

* Housing Max as % of site in MGB

As this table also has the housing numbers and masterplanning for AL/SO3 shown under SO4 (the hotel/leisure development, we can only assume that no consideration has been given to Green Belt purposes in allocating this site.

We contend that the intent in the NPPF is to protect the Green Belt from inappropriate development, not to allow unconstrained development simply by the Council declaring that a developed site will remain in the Green Belt.

In this instance it seems as if the Council has avoided the need to demonstrate “exceptional circumstances” by ignoring the site’s contribution to the Green Belt purposes.

Without knowing the location and extent of development it is impossible to say what impact the proposed developments would have on the openness of this area of the Green Belt. There are views into the site from a variety of locations - the A26, a PROW to Haysden (higher up the ridge) or the footpath near the Cottage Hospital (lower down the valley). Any development at the southern end of the site would be visible from Vauxhall Lane (a designated Rural Lane) and the Tunbridge Wells Circular Walk.

3. Increased traffic congestion on the A26, including in the Southborough AQMA

3.1 Congestion and Air Quality

The additional traffic from this proposed development will simply exacerbate the existing congestion and air quality issues on the section of the A26 near the site and in the nearby AGMA in Southborough.

The situation will be compounded by the volume of traffic generated by the proposed hotel and leisure complex at Mabledon House (AL/SO4).

We are unsure how the smart traffic management system proposed in the Transport Evidence Base, synchronising traffic lights, will improve the traffic flows on the A26 past the Mabledon/Nightingale site, when there are no traffic lights here and the speed limit is 40mph, 10mph higher than the speed limit in the urban area of Southborough.

Additionally, this is a single-carriageway road with traffic halted by buses picking up/dropping off passengers and vehicles slowing or stopping to turn into private driveways.

3.2 Safety

The Policy for AL/SO3 requires “safe and acceptable access arrangements from the A26 for the proposed development with, where required, a secondary emergency access” (Policy Point 1).

We note that the junction performance assessment for AL/SO3 allocation in the Transport Evidence Base was carried out based upon 100 dwellings accessing the A26 via Vauxhall Lane.
We require an explanation for this approach as Vauxhall Lane is at the opposite end of the site to Mabledon Farm on which the development would be centred. Vauxhall Lane is a narrow lane with complex topography and a “blind” junction with the A26; it is totally unsuited to such an increase in traffic.

The more obvious access to the A26 would be through upgrading the current PROW from Mabledon Farm to the A26. Unfortunately, this would result in traffic leaving/joining the A26 in close proximity to the access to the proposed hotel and leisure complex at Mabledon House (AL/SO4).

This stretch of road has a 40mph speed limit and this limit is frequently exceeded as vehicles gain downhill momentum and accelerate to approach the slip road to the A21. It is unclear how traffic from the new proposed development could safely pull out onto the A26.

We believe that traffic lights would only serve to increase congestion and air pollution, by halting the flow of traffic on the A26 while construction of a roundabout would have a material impact on the character of the AONB landscape (as would any widening of the A26).

Safe and acceptable pedestrian and cycle linkages to Southborough are also required (Policy Point 2). At this stage we feel that there is too little information available re Scheme 404 (Cycling corridor and rights of way between Tunbridge Wells and Tonbridge) which appears to be the route that would serve the development at AL/SO 3, and will comment when the Walking and Cycling Strategy is published.

Pedestrian access to Southborough and Tonbridge via the A26 is not safe and we see no indications that any improvements are proposed in the Draft Local Plan. There is a narrow pavement on only one side of the road and there are no controlled pedestrian crossings. Traffic speeds make walking here both unpleasant and unsafe. Getting to a bus stop on the other side of the road involves jaywalking through 40mph traffic – not safe for anyone, but impossible for the elderly or those with young children. Cars will continue to be used for the majority of journeys.

4. Environmental impacts

4.1 Land-based economic development and rural life

The proposed housing development is neither connected to, nor essential for, land based economic development on this site, and it is unclear why the housing element has been included in the allocation. We believe that the majority of the land within the site is leased to two tenant farmers and has been used in recent years as grazing for cattle, sheep, and horses stabled at the Honnigton Equestrian Centre (south of Vauxhall Lane, and not itself included within this site).

The informal tracks within the site have been used for exercising horses from the Honnigton Equestrian Centre. The landowners already have an obligation to improve (for the 25 years) some of the agricultural land on this site under an S106 agreement in November 2014 in relation to the planning application 14/00870 for a Solar Park on other land which they own.

We cannot comment on the current economic viability of the agricultural uses on this site per se. However, we have not seen any evidence in the Draft Local Plan document set that there is a need for affordable housing (and other infrastructure and amenities) for rural communities on this site to meet Objective LBE2 in the High Weald AONB Management Plan nor that erection of rural workers dwellings here would be essential under the provisions of Policy H10.

In relation to the proposed land-based economic development per se, in addition to the Development Management Policies already referenced in point 8f of Policy AL/SO 3 as a minimum the following should also apply: EN22, ED4, ED5, ED6 and ED7. We also surprised that there is no requirement for supporting woodland management and rural crafts as set out in the “Statement of Significance” in the High Weald AONB Management Plan (and quoted in the Distribution of Development Paper).

4.2 Ecology and Biodiversity

The potential impact of the proposed development on ecology and biodiversity has been materially underestimated in the Draft Local Plan. The site includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a wide variety of species. The gill woodlands and shaws provide important corridors for wildlife and are rich in biodiversity.

There are traditional orchards, now a rare habitat. In addition, the site is on a green corridor of Ancient Woodland (Coxon Wood, Beeches Wood, Nightingale Wood and Minepit Wood) which provides a natural habitat for plants, animals and birds. The Dark Skies provide an essential haven for nocturnal wildlife; at night owls can be heard hooting, bats clicking, foxes calling and badgers foraging. It is not evident that a proper wildlife assessment has been carried out in this Proposed Plan.

It is unclear how development here would protect and enhance biodiversity and geodiversity.

4.3 Heritage Assets

The impact of the proposed development on listed buildings and other heritage assets within or bordering the site does not appear to have been assessed.

4.4 Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain with run-off from the A26 and higher ground. There is network of underground streams and springs in addition to the visible stream and ponds within the site. This is not ideal land for development and will be made worse by the creation of additional impermeable surfaces for housing, roadways etc.

We are also aware that the mains sewer is located at the rear of the gardens of the strip of houses beside the A26 and there is a Southern Water pumping station near this (within the site). As there are steep slopes in this area, falling away from the A26, we would like to be assured that appropriate measures are planned for connection of new properties to the mains sewage pipes has been considered.

5. Social impacts

5.1 Infrastructure This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with the existing resident population.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_8044

Mr Martin J Prentice

Object

Policy Number: AL/SO 3 Land at Mabledon and Nightingale (SHELAA reference: Site 455)

I am writing to register my objection to the proposed allocation AL/SO 3 Land at Mabledon and Nightingale for a mixed-use scheme to include land-based economic development and approximately 50-120 residential (C2) dwellings.

In my opinion, Tunbridge Wells Borough Council (TWBC or the Council) has not adequately thought through and explained the rationale behind the proposed site allocation, and I disagree with the conclusions that they have reached. For the reasons outlined below, this site is not suitable for the proposed development.

Lack of clarity in the Draft Local Plan

In describing the proposal for this site, the Draft Local Plan is unacceptably vague and unclear on several aspects, including:

i) what the ‘extended settlement’ will entail (e.g. a village, a hamlet or around several farmsteads);
ii) where the housing, roads and other buildings are going to be located; and
iii) the size i.e. the extent of the development.

The boundaries of the site are not shown on the Policy map (Map 35, p148) and there is no indication of how much Green Belt and AONB land will be built on. It is unacceptable to include such a vague proposal in the Draft Local Plan at Regulation 18 planning stage. As such, the Council cannot credibly claim to know that “small scattered forms of development” (p.77 Distribution of Development Topic Paper) will enable them to find a suitable location for the proposed development.

I have looked at the map in the SHELAA (Site 445) and see that the allocation is for the whole of the area between the A26, the A21 (including some land in the borough of Tonbridge and Malling) the railway line, and t crosses Vauxhall Lane in the south. This is a very large area – 171 hectares (roughly equivalent to 250 football pitches). Including this in the Draft Local Plan just establishes that development in this protected landscape is acceptable to TWBC, and sets a dangerous precedent for the future.

I am worried that the landowners of the site (The Hadlow Estate) are looking to profit in the future from a much larger housing development than is currently proposed – maybe even thousands of houses. The only constraint in the Policy is that housing development will “not exceed 120 dwellings during this plan period” (Policy point 7). It is unclear as to whether this time-limited constraint will still apply if TWBC is unable to show a five-year housing supply or as to what restrictions will apply to the northern portion of the site which is in the borough of Tonbridge and Malling.

A26 -Traffic and Air Quality

A development of up to 120 homes at this location combined with the proposed hotel complex and renovated Historic Park and Gardens at Mabledon House (AL/SO 4) will result in a significant increase in traffic on the A26, adding to current congestion and poor air quality issues.

This is already such a busy road that it will be almost impossible to provide “safe and acceptable access arrangements from the A26” (Policy point 1) for the proposed development. Pulling out onto the A26 from an access road for the new housing would be difficult and dangerous - as it is now for residents in the existing houses near the site. Vehicles regularly exceed the 40mph speed limit as they build downhill momentum preparing to join the A21; there are no speed safety measures (cameras / speed registers etc). These points stand irrespective of where the access is – an access road from Mabledon Farm will be competing with traffic from the new hotel on the other side of the road; Vauxhall Lane is a narrow roadway with appalling visibility at its junction with the A26; the track to Nightingale Farm is on a bend which restricts visibility.

Vauxhall Lane

This 2-mile long road links the A26 with the A21 and consequently attracts an already absurdly high volume of rush hour traffic, with school traffic using it as a rat-run to reach all the Tonbridge schools. In the event of road works or accidents on either of these main roads, it quickly becomes even more congested. It is a pretty, leafy, narrow winding lane, completely unsuited to so much traffic, being poorly maintained, with disintegrating edges, ever-increasing potholes, and a semi-permanent flood on the dangerous bend opposite Honnington Farm due to a drain that is seldom cleared, with a concrete surround that is constantly smashed by traffic trying to avoid on-coming vehicles. Should the Mabledon Farm development go ahead, cars in and out of the access road into Vauxhall Lane would increase traffic enormously. The Vauxhall Lane railway bridge below the Cottage Hospital is very narrow, and would need to be rebuilt to take lorries and extra traffic.

Still more congestion will be created by vehicles waiting to turn right into the new developments - the roadway is too narrow for right-turn lanes to be created, so vehicles will block the carriageways while they wait to turn right through high-volume fast-moving traffic. Traffic queues will stretch back into the Air Quality Management Area of Southborough, Royal Tunbridge Wells, Tonbridge and the slip road from the A21. Installing traffic lights is likely to increase congestion on the A26 by giving periods of priority to vehicles leaving/joining the A26.

It’s even more difficult to imagine how “safe and accessible pedestrian and cycle linkages to Southborough and Tonbridge” will be provided. There are no cycle tracks on this section of the A26 and no room to provide them without widening the road. In addition, there are no pedestrian crossings. The existing traffic island does not allow safe crossing for individuals or small groups. There is a narrow pavement on only one side of the road which is both unpleasant and unsafe, with cars and HGVs passing at high speed; getting to a bus stop on the other side of the road involves jay-walking through 40mph traffic – not safe for anyone, but especially dangerous for the elderly or those with young children.

The serious impact on the safety, health and wellbeing of families using the A26 will stretch over a very wide area.

Green Belt

This site is a glorious strip of green space between the built-up areas of Southborough and Tonbridge. There are views into the site from the A26, Vauxhall Lane, the Tunbridge Wells Circular Walk and public footpaths higher up the valley. All of it is in the Green Belt and it typifies the openness of the Green Belt. Conversion of the small number of heritage farm buildings into homes has already taken place within the site.

The strip is less than a mile wide and is the Green Belt between Southborough and Tonbridge, so it is incredibly important that it continues to be protected from inappropriate development, as set out in the NPPF. It would be all too easy for development to sprawl across this narrow green strip, resulting in the urban areas Southborough and Tonbridge coalescing.

TWBC’s own study concludes that development here would be harmful: the contribution to all of the Green Belt purposes is Strong (Parcel BA 1 - Green Belt Study Stage 2, App. A Broad Areas)

AONB

The site is within the High Weald Area of Outstanding Natural Beauty (AONB), whose spectacular and far reaching views and woodland are enjoyed by the local residents as well as those from visitors to Southborough, as they approach Southborough Common and the Conservation Area. Any development on these sites will mean irreversible loss of historic landscapes, in circumstances where there must be better options / sites for development where this can be avoided. At a density of 30 homes per hectare it would only need 4 hectares.

Considering the location of the site in High Weald AONB, the Draft Local Plan makes unacceptably vague and inadequate references about the developments on the site being an ‘exemplar scheme’, without providing an explanation of why it is considered to be ‘exemplar’ and what are the “unique circumstances” that justify this proposed development. In my opinion the proposed allocation fora major development in the AONB goes directly against some of the key objectives of the High Weald AONB Management Plan agreed by the Council.

The studies in TWBC’s own Supporting Documents conclude that development here would be harmful, including:

* the landscape has high sensitivity to development (Sub-areas SP5 and SP-6 Landscape Sensitivity Assessment); and
* the development would be very substantial in scale in relation to the existing settlement, poorly related to its setting and have a high impact on the AONB (App 3: Assessment of AONB sites - Distribution of Development Topic Paper).

Ecology and Biodiversity

This is a very important area of biodiversity between the built-up areas of Southborough and Tonbridge. It includes a designated Local Wildlife Site (TW50 Vauxhall Lane Woods), which provides a vital habitat for a variety of species (e.g. great crested newts (protected species), rare dormice, deer, hedgehogs, badgers, foxes and owls). The gill woodlands and shaws provide important corridors, rich in biodiversity. There are traditional orchards, now a rare habitat, and rare early purple orchids.

It’s an area of relatively Dark Skies, only 2 and 3 levels higher than the darkest skies (CPRE Light Pollution and Dark Skies interactive map), an essential haven for nocturnal wildlife.

In addition, the site is on a green corridor of ancient woodland (Coxon Wood, Beeches Wood, Nightingale Wood, Annise Wood and Minepit Wood), which provides natural habitat for plants and animals. Any development on these sites could mean destruction of the ancient woodland and elimination of the natural habitat.

Flooding

Away from the flood zones in the west of the site (near the railway line), the topography and clay soil mean that the ground rapidly becomes waterlogged in periods of heavy rain due to run-off from the A26 and the network of underground streams and springs. This is not ideal land for development and will be made worse by additional impermeable surfaces.

Infrastructure

This development will put further pressure on the infrastructure in Southborough. There are already concerns that the new medical centre at the Southborough Hub will not cope with existing residents.

Commuter train services from Tonbridge Station (just over a mile away) to London are already overcrowded and unpleasant. This development will further add to the overcrowding on the trains.

DLP_8388

Jessica Gordon

Object

Map 35 Policy AL/SO 3 Mabledon and Nightingale

The site AL/S03 should not be developed. It is Green Belt land, and is in an AONB and heritage site. It would increase traffic volumes and would have a negative impact on the environment and air quality. It would also negatively affect the wildlife and biodiversity in the area, and would place a burden on local services and facilities.

DLP_2919

Chris Gow

Object

I object to this development.

The development is on Green Belt land, and should not be granted.

Mature trees are threatened, and the Tree Preservation Orders should extend to cover all trees in Green Belt areas.

Policy AL/SO4: Land at Mabledon House

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1543

Tonbridge & Malling Borough Council

Support with conditions

Although these are smaller proposals that do not require master planning in the way that the larger allocations at Tudeley, Capel and Paddock Wood do, the policy acknowledges that the implementation of the Mabledon House proposal will depend on the agreement of TMBC. It notes that:

“The main house is located within the borough of Tunbridge Wells and the ancillary buildings are located in the borough of Tonbridge & Malling; the Historic Park and Garden is split between the two boroughs. The above policy to be agreed with Tonbridge & Malling Borough Council to encourage a holistic and comprehensive approach to development proposals across the whole of the estate.”

TMBC welcomes the opportunity to discuss the proposed site allocation at Mabledon House with Tunbridge Wells Borough Council within the context of the emerging Local Plan, subject to a better understanding of the scale and form of the development, particularly in respect of that part of the site within Tonbridge and Malling, the very special circumstances for the development within the Metropolitan Green Belt and the impacts on High Weald AONB and its setting.

DLP_1574

Mr John Hurst

Object

Green Belt - do not develop. Would start to form a conurbation with Tonbridge.

DLP_1643

Tom Tugendhat MP

 

AL/SO 3 and AL/SO 4 - Land at Mabledon and Nightingale, and Land at Mabledon House

I feel that this should be the first site that I comment on, as the boundary of development is right up to, and including, land in Tonbridge and Malling. There are a handful of dwellings south of the A21 which fall in Tonbridge and Malling and residents there are understandably concerned about the impact of this allocation.

It is good that TWBC recognise the cross-boundary issues and accept that they will need agreement with TMBC as the local planning authority here to ensure that this site goes ahead. You will have noted from TMBC's robust response to this consultation that they have their concerns about this allocation, specifically with the outbuildings falling over the borough boundary. I would like to re-emphasise this point and make clear that no development should proceed without TMBC being fully on board with its proposals.

I am particularly intrigues by requirement 8c in the draft allocation at AL/SO 3 on this site because it states that 'Community Facilities' should be provided on this site. I would be extremely keen to learn what facilities TWBC thinks would be appropriate here? As the site falls closer to the town of Tonbridge than the town of Tunbridge Wells I am extremely keen that any facilities compliment those that are already available in Tonbridge for local residents.

[see also full response - Comment Number DLP_1577].

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Mrs Lisa Dunnett
Anya Wood
Janet Trayner
Brian Austen
Priya Enefer
Tim Boden
Michael Lee
Elspeth Penny
Branislav Trajkovski
Terry Brisefer
Marion Harris
James Dunnett
Anthony Harris
Sophia Spickett
Sean Mullins
Jayne Windle
Gary Smith
Nicole Smith
Sara Vincent
Christopher Van't Hoff
Teresa Ann Van't Hoff
Hannah Van't Hoff
Katie Van't Hoff
Freddie Van't Hoff
Werda Hattingh
Mary Greenwood
Eric & Fiona Watkins
Bryan Greenwood
Lynn Green
Kate Hardy
Patrick North
Mark Weavis
Christina Sharpe
Kevin Kirby
Corrine Kirby
Izzie Miller
Cook Clancy and Co
Gillian Curphy
Keith Ebbels
Susan Tanner
Stephen Traveller
Susan Robertson
Amin H Rajan
Gail Armstrong
Paul Smith
Liz Hatherell
Ann Norman
Tracey Gadd
Stuart Taylor
Elizabeth Dowling
Mark Windle
Alastair Dale
Christopher Beach
Maija Wilson, HHRA
Dominique Webber
Liza Hall, HHRA
Rachel Waller
Mark Weller
Brian Wood
Liz Wallace
Andrew Wallace
Sally Moesgaard-Kjeldsen
Sylvia Bourne-Moore
Tim Elliott
Pamela Barnes
John Stephen Barnes
David & Jennifer Heyes
Andre Hattingh
Martin Webber
Diane & Andrew Bell
Matthias Koslowski
Claire Penney
Chloe Daniels
Simon Byerley
Paul Sleightholme
Mark Brennan
Brian Waters
Julia and Colin Stoward
Ruth & Paul Langridge
Keith Hardwick
Saffron Bohan
Neil Bohan
Laura Weller
Linda Weller
Deborah Crook
Chris Daniels
Keith Crook
Byerley Ltd
Leah
Julia Prentice
Martin J Prentice

Support with conditions

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

In principle, I support the proposal to develop a luxury hotel and leisure complex and the restoration of the Historic Park and Garden at Mabledon House as it will increase tourism in the borough as a whole and will generate new employment opportunities. I would also anticipate any developer will provide fibre link internet to the site. An extension of this to local residents would be beneficial, and I suggest that this should be included as a requirement in the Policy.

I am however worried that this development will have a major impact on the A26 traffic, making an already bad situation worse. It’s not only visitors but also staff for both the hotel and leisure complex and the maintenance of the Historic Park and Garden.

[Additionally]Mabledon House must be protected to maintain its status as a listed building and valuable heritage asset. It would be helpful if the policy could be clear that any scope for demolition within the scheme of redevelopment would not apply to the existing fabric of Mabledon House and that new build is in keeping with the house so as to ensure that the setting of this heritage asset is not damaged

DLP_2776

Mr Peter Tavner

Object

I do not object to the principle of the site being used as a hotel, however:

I object to the entirety of the Mabledon Historic Park & Garden being allocated for development and recommend that the Local Plan clearly limits development to a much smaller footprint on the site.

The proposal for up to 200 hotel rooms, and leisure development with spa and conference facilities, will undoubtedly transform the setting of this historic building, of special importance to Tunbrisge Wells. I am highly sceptical the scale of this transformation will not significantly damage the character of the existing building.  I recommend that the Local Plan should apply a lower maximum to the number of hotel rooms permitted on the Mabledon site in order to limit the need to make material additions to the existing building and to contain the need for additional buildings on the site. A maximum figure of say 75 rooms is more appropriate (similar to the Spa Hotel in Tunbridge Wells)

DLP_3253

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

8. “Provision of safe and accessible pedestrian and cycle linkages and crossing points to Southborough and Tonbridge…”

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

Public Rights of Way and Access Service

KCC supports and welcomes the specific reference to PRoW in paragraphs 6 and 7

Heritage Conservation

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

Potential for late post medieval remains associated with Mabeldon House and park

DLP_3422

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_3603

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Southborough. 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 200 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/SO 4

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

DLP_3832

Government Team
Natural England

 

Policy wording for this allocation states that 'the scheme of redevelopment […] is to be determined though appropriate studies...' which would indicate that further details are required. The site is located within the AONB however as details of the allocation (such as whether development will be limited to redevelopment of existing buildings) are not specified in policy wording, it is not clear if this allocation will constitute major development. Natural England advises that further information is required in order to determine whether this allocation would constitute major development. For the avoidance of doubt, should this allocation be considered major development, the same advice would apply as for other major development sites in the AONB.

DLP_4114

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

This allocation is a proposal for a major development in the AONB and Green Belt which does not appear justified under NPPF paragraph 172.  The Council does not propose to release the site from the Green Belt, which gives a misleading impression of the amount of Green Belt land that will be built over under this Plan, especially as it appears the Council intends to extend the LBD to include this site.

In principle CPRE does not object to the concept of Mabledon House being converted to a hotel.  However CPRE objects to the scale of the proposals and believes this scale of development will damage the historic nature of the site.

Mabledon House is of important historical interest to the Tunbridge Wells area, as it is the childhood home of Decimus Burton who designed many buildings in and around Tunbridge Wells (most famously the Calverley Estate) in addition to buildings at Regents Park & Kew Gardens. Mabledon was built in 1804 by his father John Burton. Having been his childhood home Decimus Burton went on to make substantial alterations to Mabledon House and drastically changed the appearance of the building. Decimus Burton is locally acclaimed as the man who effectively transformed Tunbridge Wells architecturally into the town that it is today.  With this in mind great care must be taken in developing the site.

The proposal for up to 200 hotel rooms, and a leisure development with spa and conference facilities, will undoubtedly transform the setting of this historic building.  For example 200 rooms is likely to require an additional wing to be added to the building or a whole new block altogether, and CPRE is highly sceptical this can be achieved without damaging the character of the existing building.  As an indication of the scale, Appendix A of the Tunbridge Wells Hotel Capacity study indicates that the largest existing hotel in the town (in terms of rooms) is Travelodge with 86 rooms (however we note that a new 110-bedroom Premier Inn Hotel is also currently proposed in Royal Tunbridge Wells Town Centre). The largest hotel within a more traditional building is the Spa Hotel with 69 rooms.

CPRE recommends that the Local Plan should apply a lower maximum to the number of hotel rooms permitted on the Mabledon House site in order to limit the need to make material additions to the existing building and to contain the need for additional buildings on the site.

CPRE also objects to the entirety of the Mabledon Historic Park & Garden being allocated for development and recommends that the Local Plan clearly limits development to a much smaller footprint on the site. CPRE believes that it is completely inappropriate to include the whole site (12.43 hectares – see SHELAA Site Reference  90)  within the LBD as this creates a presumption of further development of the site.

DLP_4548

Historic England

 

Policy AL/SO 4 - we note this site includes a grade II listed building, Mabledon House by Decimus Burton, and iswithin a grade II Registered Park and Garden; particulalry sensitive development to protect and enhance the character and appearnce of the heritage assets would be required, and should be more forcefully expressed in the policy wording.

DLP_4901

Sue Claxton

Object

I wish also to object to the late submitted plans for Mabledon AL/SO3 & AL/SO4.

Again this will affect Tonbridge more than other area, with increases in traffic and pollution and a loss of wildlife habitat. This is part of the Green Belt land that separates Tonbridge from Southborough and I can see no exception circumstances that require it to no longer be protected.  The A21 is a natural boundary for the town.  There are already several schools in the immediate vicinity and the consequent demands for public transport in south Tonbridge will put further strain on the towns resources.

As more land is concreted over the greater the threat of flooding to the area long term.  This cannot be sustainable and once done cannot be undone.  The A21 widening has already increased land use in this area, as well as increasing pollution in all it’s forms.  I implore TWBC to reconsider their plans.

DLP_4979

Southborough Town Council

 

POLICY ALSO4 Comments are as follows:

1. Councillors raised concerns over what demolition works were to be proposed on a grade 2 listed building.

2. Councillors again raised concerns over the access issues on to and off of the A26 to access the site.

Thank you again for the opportunity to comment and I trust that this Council will be kept fully appraised of any alterations or further comment opportunities.

DLP_2920

Chris Gow

Object

I object to this development.

The development is on Green Belt land, and should not be granted.

Mature trees are threatened, and the Tree Preservation Orders should extend to cover all trees in Green Belt areas.

DLP_5268

Tunbridge Wells Friends of the Earth

Object

Policy Number:  AL/SO 4

Object to new development in the Green Belt.

DLP_5388

Gary Evans

Object

I have read through my MP's concern's regarding the extraordinary amount of housing and new school in Tudeley, Woodgate Way and Mabledon House.

I absolutely agree with my MP's concerns and would urge the Council to give consideration to those who will be detrimentally affected by this tsunami of build.

Where is the capacity on our roads, our local hospitals, GP services to meet the demand for more human expansion? We must protect our environment, reduce our carbon emissions and live sustainably. We must have green spaces for our mental and physical health, not just a few trees planted to offset the significant environmental impact.

Your proposals demonstrate disrespect, not only for the residents of Tunbridge Wells but also your neighbours in Tonbridge.

We cannot go on like this. You need to say to central government enough is enough and we as a society need to change our way of life in order to provide a sustainable future for our children. That means amongst other things that each and every one of us should not have more than 2 children, as we have chosen to do.

These proposals should not go ahead.
Thank you for your time

[TWBC: accompanying email from Tom Tugendhat MP copied here for information]:

Dear Gary,

As you may be aware Tunbridge Wells Borough Council are proposing to develop land in Tudeley for over 2,000 homes. In addition to this, they are also considering building a Secondary School off Woodgate Way, here in Tonbridge, and more housing at Mabledon House, just south of the A21.  

Though each of these areas are close to Tonbridge, they technically fall outside our council area. I am keen for Tunbridge Wells Borough Council to hear the comments of those of us who live in Tonbridge about the proposals. 

Up until 15 November 2019 they will be consulting. It is open to anyone, including people living in Tonbridge and surrounding villages, to respond. I am keen that they understand the concerns that many have raised with me. 

You can see my response here, but if you haven’t yet done so please consider responding too. You can do so by e-mail to localplan@tunbridgewells.gov.uk or by following the link here.

With our own housing needs to meet, Tonbridge and Malling Borough Council are understandably hugely concerned about the proposals too. They have agreed a robust response too and I know your councillors Dennis King (dennis.king@tmbc.gov.uk) and Frixos Tombolis (frixos.tombolis@tmbc.gov.uk) would be interested to hear your thoughts as well.

If you share these concerns please do respond before 15 November, and encourage your friends and neighbours to do so as well. 

Best wishes

Tom 

Tom Tugendhat MP
Member of Parliament for Tonbridge and Malling
130 Vale Road
Tonbridge
Kent
TN9 1SP
01732 441563

DLP_6169

B M Broadbent

Object

I OBJECT to the proposed development of Land in general and Mabledon House in particular into a very large hotel for the following reasons.

1) At the Public Enquiry into the proposed TWBC Park & Ride site at Mabledon Farm the KCC traffic engineers and TWBC staff described the A26 as saturated. Volumes of traffic have increased significantly since then. What were only peaks back in 2006 are now regular flows at other times of the day and the peak flow seems to have increased by more than 50%. Traffic is still increasing. Planning to increase this by hundreds of journeys per day is unacceptable.

2) We are downwind of the pollution being generated by vehicles accelerating along both sides of the dual carriageway and adding to this is unacceptable to us.

3) There is no justification for such a hotel and no obvious benefit for Tunbridge Wells. If it seen as a draw for tourists, why would they stay in a hotel with no easy access to the town other than via the congested A26 and put further pressure on parking in the town centre.

4) Such a hotel would inevitably become a wedding venue with pop/dance music blaring out of open doors and windows until midnight and perhaps beyond. From its strategic position the sound would be heard in Bidborough but more seriously, since the prevailing wind carries the sound, over the A26 and down the dense housing on Quarry Hill in Tonbridge. This would be so during the Spring, Summer and early Autumn months when residents too would want their windows open. To impose such noise on other residents at least once per week over these months – and possibly more given that weddings seem to happen more often on Fridays (or other days) too is unacceptable. Whatever restrictions are agreed at the planning stage, commercial imperative will prevail afterwards and the restrictions will not be worth the paper on which they are written.

5) This is another example of TWBC trying to meet its objectives by development along the border with Tonbridge. Mabledon House may be in the TW Borough, but it is only just over a mile from the centre of Tonbridge and all transport and support services would place additional load on a very congested Tonbridge.

DLP_6374

Ms Margaret Borland

Support with conditions

Policy Number:  AL/ SO 4 Land at Mabledon House (SHELAA reference : Site 90 and additional land) 

In principle I support the proposal to develop a luxury hotel and leisure complex and the restoration of the Historic Park and Garden at Mabledon House as it will increase tourism in the borough as a whole and will generate new employment opportunities. The restoration of the house becomes more essential as every year passes and hopefully this would see it and the Historic Park and Gardens returned to their former glory.

I do however have some serious concerns:

  • this development would have a major impact on the A26 traffic, making an already bad situation worse. It’s not only visitors but also staff for both the hotel and leisure complex and the on-going maintenance of the Historic Park and Garden;
  • the impact on the AONB and Green Belt has not been adequately assessed; and
  • there is a risk that events held at the proposed hotel, such as weddings and private parties, could result in significant noise disturbance  to local residents over a wide area

I would like to see some proposed “betterment” for local residents in this policy in view of the unavoidable impacts of such a development – perhaps provision of fibre broadband (FTTP) to our homes (as it will surely be provided to the hotel complex) as this area currently suffers from extremely low broadband speeds due to distance from the BT cabinet.

Finally Mabledon House must be protected to maintain its status as a listed building and a valuable heritage asset.  It would be helpful if the policy could be clear that any scope for demolition within the scheme of redevelopment would not apply to the existing fabric of Mabledon House and that new build is in keeping with the  house so as to ensure that the setting of this heritage asset is not damaged.

DLP_6473
DLP_7290
DLP_7777
DLP_7989

Elle Arscott, HHRA
Hangman's Hill Residents Assoc
Jacqueline Arscott, HHRA
Peter Evans, HHRA

Support with conditions

TWBC: the following comment was submitted by the list of members of Hangman’s Hill Residents Association (HHRA) on the left:

Policy Number: AL/ SO 4 Land at Mabledon House (SHELAA reference : Site 90 and additional land)

The Hangman’s Hill Residents Association supports in principle the proposal to develop a luxury hotel and leisure complex and the restoration of the Historic Park and Garden at Mabledon House as it will increase tourism in the borough as a whole and will generate new employment opportunities.

We are however concerned that this development will have a major impact on the A26 traffic, making an already bad situation worse. There is likely to be high car usage for both visitors travelling from out of the area and for staff working unsocial hours.

Additionally, Mabledon House must be protected to maintain its status as a listed building and valuable heritage asset. It would be helpful if the policy could be clear that any scope for demolition within the scheme of redevelopment would not apply to the existing fabric of Mabledon House and that the extent of new build is limited and in keeping with the house so as to ensure that the setting of this heritage asset is not damaged.

DLP_7407

Mr John Telling

Object

The main impact of this policy on Green Belt land within the High Weald AONB will, if implemented, fall on Tonbridge & Malling BC. It is odd that one of the mitigations is the development of a sports hub at Hawkenbury.

DLP_7900

Enplan for Mabledon Services Ltd

Support with conditions

Mabledon Services Ltd (MSL) are promoting the development of a hotel at Mabledon House and supports, with conditions, Draft Policy AL/SO 4: Land at Mabledon House.

The Draft Local Plan includes draft Policy AL/SO 4 which proposes to allocate this site for a 200-bedroom hotel, subject to various requirements, located within the Green Belt and High Weald AONB. The house and grounds of Mabledon comprise together a nationally significant heritage asset and one that is closely associated and particularly important to Tunbridge Wells. The house has been in continuous sole residential use since the early 1990s, but it is considered that this is no longer tenable given the ongoing need for repair, restoration and modernisation required.

Whilst proposals for the hotel are at an early stage, the main benefits of the proposal can be summarised as:

  • The provision of a well-located luxury 5-star graded country house hotel for Tunbridge Wells, serving the higher end of the market, would be of considerable economic and social value for the town and borough and would be a facility of regional economic importance. Whilst Tunbridge Wells is not without good quality 4-star hotels, Mabledon would provide for a scale and quality of accommodation and a model of service of an exceptional standard, all within a heritage setting, that would clearly define it as the area’s premier hotel. These proposals are fully in line with TWBC’s Hotel Capacity Study, which supports the need for a 5-star hotel within the borough;
  • The provision of a high quality and substantial conferencing facilities, including the largest purpose-built conference hall in the town. This would be a facility for regional importance attracting organisations, businesses and delegates from across the south-east;
  • The repair, restoration and appropriate reuse of a heritage asset of national significance (the Grade II Listed Building and Grade II Registered Historic Park and Garden) and which is of particular relevance and importance to Tunbridge Wells, though the association with James Burton and, particularly, Decimus Burton, together with the potential to have the value re-assessed on restoration of the gardens and parkland on Historic England’s Register of Historic Parks and Gardens. Securing the future of this nationally significant heritage asset is crucial;
  • The provision of public access to part of the parkland (the area to the south of the main house and garden), in the form of a low-key country park, together with the potential provision of an outdoor grassed amphitheatre for occasional events.

The draft policy sets out that “Development shall accord with the following requirements”. MSL are concerned that this wording is ambiguous and does not specifically tie the process of determination directly to satisfying the requirements. MSL suggest the following alternative wording – ‘Development proposals will be approved that comply with the following criteria:’

In respect of the requirements, MSL has the following comments:

  1. Provision of safe and acceptable access arrangements from the A26 – MSL support this requirement and have commissioned an accessibility and highway access study by WSP (submitted separately to TWBC). This concludes that based on peak-period traffic forecasts, with around one vehicle every 2 minutes arriving or departing, that it is reasonable to conclude that it is unlikely that there will be capacity issues. As the daily forecast would exceed 500 vehicles per day, a right-turning provision should be considered and WSP have defined a suitable and safe turning arrangement. They also identify the need to slightly widen the existing access.
  2. A Conservation Plan and detailed scheme of restoration for the built heritage assets and the Historic Park and Garden – MSL support this requirement.
  3. The proposal is located within the Green Belt and will remain so on completion of the development, and so all proposed development will need to demonstrate exceptional circumstances supported by evidence of need within this location – MSL accept that this site will remain in the Green Belt. Accordingly, Paragraph 144 of the NPPF will be engaged with any planning application and “very special circumstances” will have to exist that clearly outweigh potential harm by way of inappropriateness and other harms to the Green Belt for an application to be approved. MSL propose that the current policy wording “exceptional circumstances” be amended to very special circumstances, as this properly reflects the Paragraph 144 requirement.
  4. A schedule of landscape maintenance – MSL support this requirement.
  5. A Landscape and Ecological Management Plan – MSL support this requirement. MSL recognises that should the development be deemed to be “major” (a matter for the decision maker to determine (Footnote 55)) in order to meet the tests of Paragraph 172 of the NPPF, then “exceptional circumstances” would need to be proven and it would need to be demonstrated that the development would be in the public interest (refer to draft Policy EN 21: High Weald Area of Outstanding Natural Beauty). MSL believes that the considerable benefits to the nationally significant heritage asset, an increase in public accessibility to the heritage asset, together with the considerable local and regional economic and social benefits of the new hotel use, that these would represent a strong case that would meet these tests.
  6. Provision being made for public access to heritage assets and the Historic Park and Garden under an agreed scheme of site management, to include connections to, and improvements of, existing Public Rights of Way – MSL will promote public access to part the parkland (the area to the south of the main house and garden), in the form of a low-key country park, together with the potential provision of an outdoor grassed amphitheatre for occasional events and will also support managed public access to the remaining Historic Park and Garden and heritage assets, under an agreed management scheme. As MSL is not aware of existing Public Rights of Way through or adjoining the site, other than footways along the A26 (which are not considered relevant to this requirement), it will not support this and will seek its deletion from the draft policy wording.
  7. Explore opportunities and a scheme of implementation for providing increased public permeability through the site by providing pedestrian/cycle links with wider Public Right of Way and cycle network – As for requirement point 6, MSL will promote and support public access, under an agreed management scheme, but it will not support connections to and improvements of existing Public Rights of Way, as MSL is not aware that these exist within or adjoining the site. Given that requirement 6 delivers that same as requirement 7, MSL will seek the deletion of requirement 7.
  8. Opportunities for the provision of a cycle link to Royal Tunbridge Wells, Southborough, and Tonbridge to be explored and, if feasible, to be provided – MSL would be prepared to make a reasonable and commensurate contribution to this requirement should it be considered feasible. MSL will seek the wording of the policy to be changed accordingly.
  9. Any proposal to be supported by detailed landscape, arboricultural, and ecological studies – MSL support this requirement.

In respect of contributions, MSL does not currently agree to the suggested contributions listed (a) to (g), noting that in the absence of CIL, any Section 106 requirements would need to be related to the development proposals. At this stage with draft CIL pending, MSL will not seek the deletion of this part of the policy wording, at least not and until the position of the council with CIL is clear. But it wishes to clarify that as set out contributions (c) to (f) are not considered to relate to the hotel development proposals and not “necessary”.

MSL recognises that the site straddles the administrative boundary with Tonbridge & Malling Borough Council, with the main house and most significant part of the garden and parkland within Tunbridge Wells. MSL appreciates that TWBC would wish to gain T&MBC’s agreement to Policy AL/SO 4. However, MSL does not accept that having secured that agreement through the Local Plan process, that TWBC should, for the purposes of determination, be “dependent upon the support and cooperation” of T&MBC. Evidently T&MBC would be a key consultee to any development application but the primary determining authority, utilising their own policy, would be TWBC. MSL will seek to amend this reference in the first paragraph of the draft policy.

MSL propose the following wording amendments to draft Policy AL/SO 4 (text struck through represents a proposed deletion. Text underlined represents proposed additional/replacement text):

Policy AL/SO 4

Land at Mabledon House


This site, as shown on the Southborough draft Policies Map, straddles the borough boundary with Tonbridge & Malling Borough Council and as such, while the policy encompasses a vision for the whole site, it is restricted to that land which lies within Tunbridge Wells borough (this draft policy is to be agreed with Tonbridge & Malling Borough Council to encourage a holistic and comprehensive approach to development proposals across the whole of the estate). Successful implementation of this policy is dependent upon the support and cooperation of Tonbridge & Malling Borough Council.

The proposal for the whole site, which this policy supports, is for the development of a luxury hotel up to a maximum of 200 rooms and leisure development with spa and conference facilities, set within a restored historic park and garden and wider attractive landscape. The scheme of redevelopment and any scope for demolition and/or new build and/or conversion is to be determined through appropriate studies covering highways, heritage, landscape, climate change, ecology, and viability.

Development will be approved that complies with the following criteria shall accord with the following requirements :

  1. Provision of safe and acceptable access arrangements from the A26 for the proposed development (see criterion 5 of Policy EN 1: design and other development management criteria);
  2. A Conservation Plan and detailed scheme of restoration for the built heritage assets and the Historic Park and Garden (see Policy EN 7: Heritage Assets);
  3. The proposal is located within the Green Belt and will remain so on completion of the development, and so all proposed development will need to demonstrate exceptional circumstances very special circumstances supported by evidence of need within this location;
  4. A schedule of landscape maintenance for the restored landscape features;
  5. A Landscape and Ecological Management Plan for ongoing protection and management of the identified landscape and ecological features of the site (see criterion 3 of Policy EN 1: Design and other development management criteria, EN 11: Net Gains for Nature: biodiversity, EN 20: Rural Landscape and EN 21: High Weald Area of Outstanding Natural Beauty (AONB));
  6. Provision being made for public access to heritage assets and the Historic Park and Garden under an agreed scheme of site management, to include connections to, and improvements of, existing Public Rights of Way (see Policies EN 7: Heritage assets and TP 2: Transport Design and Accessibility) ;
  7. Explore opportunities and a scheme of implementation for providing increased public permeability through the site by providing pedestrian/cycle links with wider Public Right of Way and cycle network.

7. Opportunities for the provision of a cycle link to Royal Tunbridge Wells, Southborough, and Tonbridge to be explored and, if feasible, to be provided commensurate with the need generated by the development;

8. Any proposal to be supported by detailed landscape, arboricultural, and ecological studies (see Policy EN1: Design and other development management criteria).

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

a. Improvements to public realm;

b. The provision of sustainable and active transport mitigation measures, town centre wide or town wide transport mitigation measures; and or highways works in the vicinity of the site, including the provision of pedestrian crossings (see Policies TP 1: Transport Assessments, Travel Plans, and Mitigation and TP 2: Transport Design and Accessibility;

c. Primary and secondary education;

d. Health and medical facilities;

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

f. 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);

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

NOTE: The main house is located within the borough of Tunbridge Wells and the ancillary buildings are located in the borough of Tonbridge & Malling; the Historic Park and Garden is split between the two boroughs. The above policy to be agreed with Tonbridge & Malling Borough Council to encourage a holistic and comprehensive approach to development proposals across the whole of the estate.

DLP_8029

Vice Chair
Hangman's Hill Residents Association

Support with conditions

Whereas the views of the Committee of HHRA expressed here strive to represent the majority of the members and supporters on its list, some members and supporters may have different individual views on some of the allocated sites (e.g. in relation to AL/SO 4 Land at Mabledon House). The Committee has acknowledged these different views and has encouraged members and supporters to express those individual views in their responses to the Council.

The Hangman’s Hill Residents Association supports in principle the proposal to develop a luxury hotel and leisure complex and the restoration of the Historic Park and Garden at Mabledon House as it will increase tourism in the borough as a whole and will generate new employment opportunities.

We are however concerned that this development will have a major impact on A26 traffic, making an already bad situation worse. There is likely to be high car usage for both visitors travelling from out of the area and for staff working unsocial hours.

The potential for noise disruption from events such as weddings and private parties at this location also requires further investigation, and we would expect strict controls to be put in place to prevent this adversely impacting residential amenity in the surrounding area. Due to location and topography, noise from the proposed hotel development and its grounds will travel widely both up and down the valley.

Additionally, Mabledon House must be protected to maintain its status as a listed building and valuable heritage asset. It would be helpful if the policy could be clear that any scope for demolition within the scheme of redevelopment would not apply to the existing fabric of Mabledon House unless that demolition is required for safety reasons e.g. the conservatory. In this case, that part of the building must be replaced to its original heritage condition. The extent of any new build is limited and in keeping with the house so as to ensure that the setting of this heritage asset is not damaged. The site should not be included in an LBD, as this would open up the potential for further development.