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Section 6: Development Management Policies – Economic Development


This response report contains comments received on Section 6: Development Management Policies - Economic Development.

Contents

General comments

Comment No.

Name/Organisation

Section or paragraph number(s)

Response

DLP_1801

Royal Tunbridge Wells Town Forum

Employment Policies Paragraphs 6.418-6.505

In Paragraph 6.418 we support the provision of the proposed new employment land. Employment in the Borough has been almost stagnant for over 20 years and there is a clear need to provide new employment opportunities for existing and additional residents to prevent Royal Tunbridge Wells in particular from becoming a dormitory town. However, the proposed extent of land take in RTW seems significantly to exceed the 14Ha identified need.

In paragraph 6.426 we strongly support the continuation of Article 4 Directions to protect existing office locations.

In paragraphs 6.429-6.430, we support priority to careful siting, mast sharing and minimisation of visual impact of new communication masts.

In paragraph 6.470, we support the retention of existing, well located and suitable tourist accommodation as well as further tourist-related development.

In paragraph 6.497 we support the retention of viable local neighbourhood facilities.

DLP_6065

Mr C Mackonochie

ED1 to ED12

Support

Policy Number: ED1 to ED12 with particular emphasis upon ED 3 to ED7

DLP_6288

Tunbridge Wells Constituency Labour Party

Section 6: Employment

There is insufficient focus in the employment section on how the Local Plan will seek to build  an inclusive economy. Development and regeneration should be assessed on the impact on wellbeing and inclusivity as well as economic growth. Growth should provide benefits to everyone and not just those profiting from property development. We need to build an inclusive economy where the contribution of all is valued and we protect the cohesion and diversity of the area. Long standing residents should not be pushed out of their communities just to make way for people . Growth should be assessed against the Social Value it is providing to the local area.

Along with many other areas in the South East, Tunbridge Wells has large numbers of families who experience in work poverty. Local earnings are below the SE regional average whilst housing costs are high. The challenge of affordability can only be addressed by providing new social rented units for those most in need. The Local Authority needs to focus on the quality of jobs being provided and work to improve the range of local jobs to enable more local people to work in the Borough. Tunbridge Wells must invest and take steps to avoid being a commuter dormitory Borough for London.

Local living wage - the Council should take the lead and pay all workers including those employed by third parties carrying out services on their behalf a living wage. This will set an example to other employers in the Borough and send a clear message that no one should be paid a wage which guarantees being in poverty.

Policy ED 1: The Key Employment Areas

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_602

Sport England

General Observation

Policy ED 1

Sport makes a huge contribution to the lives of individuals, to the economy and to society. Sport England has undertaken research to examine the economic value of sport in England.  The main conclusions are:

In 2010, sport and sport-related activity generated Gross Value Added (GVA) of £20.3 billion – 1.9% of the England total.  This placed sport within the top 15 industry sectors in England and larger than sale and repair of motor vehicles, insurance, telecoms services, legal services and accounting

Sport and sport-related activity is estimated to support over 400,000 full-time equivalent jobs – 2.3% of all jobs in England Sport also generates a range of wider benefits, both for individuals and society:

The benefits of playing sport include the well-being/happiness of individuals taking part, improved health and education, a reduction in youth crime, environmental benefits, stimulating regeneration and community development, and benefits to the individual and wider society through volunteering

Consumption of sport benefits include the well-being/happiness of spectators, and the national pride/feel good factor through sporting success/achievement

Economic Value of Sport – Local Model (updated Nov 2015)

All local authorities in England can demonstrate how sport benefits their economy using our new Economic Value of Sport – Local Model.

The model produces area based (local authority, county sport partnership and local enterprise partnership) estimates on sports’ contribution to the local economy in the form of business output (GVA) and jobs plus wider benefits like health.  I am attaching a copy of the model for Tunbridge Wells Borough Council which can be found at https://www.sportengland.org/research/benefits-of-sport/economic-value-of-sport/

Some of the key headlines for the Tunbridge Wells are:

It is estimated that there are 583 jobs created as a result of participation in sport in the Borough at GVA of £23.3m;

https://www.sportengland.org/our-work/partnering-local-government/tools-directory/economic-value-of-sport-local-model/

The total direct economic value of sport to the Borough as whole is £50.3m with a total employment of 797 people.  This is interesting because referring to nomis https://www.nomisweb.co.uk/reports/lmp/la/1946157347/report.aspx#tabempunemp they suggest that the latest figures suggest that there 800 people employed in the Arts, Entertainment and Recreation Industry (section ) in 2018.  This equates to 2.5% of the working population, which is more than employed within other services activities, real estate Electricity and Gas and Water industries respectively.

Non-participation GVA of sport (spectating, gambling etc.) is estimated to be £27m, creating 214 jobs.

Another which should be considered is Sport’s education and mentoring programs for young people which are continually highlighted for their success in engaging with low achievers at school and equipping them with jobs and qualifications, which other employment sectors have not been able to achieve:

https://www.sportengland.org/research/benefits-of-sport/social-value-of-sport/

It is Sport England’s contention that the Tunbridge Wells Borough Plan should consider D2 sports uses; fitness clubs, gyms, climbing centres and five aside centres, to be acceptable on employment sites, as they do create sustainable employment opportunities and provide work experience and qualifications in cases for the less academically inclined.

When sports facilities are designed in as part of an employment part e.g. Wolverhampton Business Park or Harwell Science Park, it creates a better and more sustainable working environment and therefore an attractive area for business to locate in or relocate to.

Also, it should not be overlooked that there are usually more employment opportunities generated through a commercial gym, e.g. David Lloyd Gyms or commercial football e.g. Football First, or a gymnastics club D2 use, than a 500,000m2 B8 use.

In conclusion, Sport England wishes the Tunbridge Wells Borough Plan to acknowledge that commercial sports (not retail) are a Bona Fide use on Industrial and Business parks creating employment as well as inputting into the local economy. Therefore, they should be treated like any other business when applying for planning permission for change of use or new development on sites covered in this Plan.

DLP_1873

Royal Tunbridge Wells Town Forum

Support

Policy Number: ED 1 Key Employment Areas

We support the retention and, where appropriate, expansion/enhancement of existing employment areas to maintain a diverse economic base and to prevent RTW from over-reliance on commuting to provide employment for an increasing population. While we support expansion of the knowledge economy, there is also a continuing need to provide work for less well qualified members of the local community in light industrial B1/B2 uses.

DLP_2402

TWBC Property and Estates

TWBC

Support

Support

DLP_3657

Lynne Bancroft

Support with conditions

More business areas should be allocated in the Cranbrook and Sissinghurst area due to the difficulty in travelling by road or public transport to the key economic hub in Tunbridge Wells. Without this, any development in this area is unsustainable.

DLP_3972

Ide Planning for Paddock Wood Town Council

Support

SUPPORT

This identifies employment sites in Paddock Wood.

It is essential that development of employment opportunities does not only extend the existing storage and distribution facilities, which employ few people. What is needed is B1 & B2 to encourage people to live and work in the town, reducing traffic and pollution.) Also, to attract major companies with office based services.

DLP_4199

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

This policy allocates sites, most of them in the AONB and/or Green Belt, with an area vastly in excess of the 14ha of additional employment space which was the minimum Objectively Assessed Need identified in the Economic Needs Study.  According to Appendices 1 and 3 (allocations in the Green Belt and AONB) of the Distribution of Development paper,

AL/RTW12, land adjacent to Longfield Road, amounts to 37ha of Green Belt and AONB (though approximately half of it will remain as open space and buffer);
AL RTW13, land at Colebrook House, amounts to 7.71ha of Green Belt and AONB;
AL/HA8, Hawkhurst Station business park amounts to 2ha of additional land in the AONB;
AL/HA9, Land at Santers Yard, Gills Green amounts to 1ha of additional land in the AONB;
AL/HA10, Site at Limes Grove, 0.55ha in the AONB safeguarded for employment use;
AL/PW1/CA3 Land at Paddock Wood and Capel, will include “expansion of key employment areas” in the Green Belt;
AL/CA1, Tudeley village, will include some “appropriate employment” in the Green Belt;
and
AL/SO3, Land at Mabledon and Nightingale, in the Green Belt and AONB, is to include “land-based economic development”.

The evidence justifying this excess over OAN and the need for the allocations to be in the AONB and Green Belt is not clear and should be thoroughly tested at Examination.

DLP_4496

Paddock Wood Neighbourhood Plan Steering Group

Support

This identifies employment sites in Paddock Wood.

It is essential that development of employment opportunities does not only extend the existing storage and distribution facilities, which employ few people.  What is needed is B1 & B2 to encourage people to live and work in the town, reducing traffic and pollution.) Also, to attract major companies with office based services.

DLP_7261

DHA Planning for Barth-Haas UK Ltd

Support with conditions

Development Management Policies

The development management policies seek to achieve the vision established by the strategic and place making policies aforementioned (Section 2.2 and 2.3). They provide more detail for decision making in relation to particular issues and assess the acceptability of development.

In this respect, policy ED 1 states that the Key Employment Areas, as defined on the draft policies map, are defined for the provision of employment uses to serve the borough for the plan period. Our client’s site is located within the Transfesa Road Area, with potentially appropriate uses being Business (B1), General Industry (B2) and Storage and Distribution (B8).

The policy states that the retention of existing floorspace and the encouragement of new floorspace in these areas - on allocated and non allocated vacant sites - and through the intensification of redevelopment of existing sites, will be supported in principle.

BarthHaas support the positive and flexible wording of the policy, which encourages the redevelopment and intensification of existing sites. Likewise, we do not object to the site being retained for employment purposes.

However, the site is potentially suitable for other complementary uses that are not permitted by policy ED 1 – including retail and leisure. Indeed, given the proximity of the site to the town centre and Paddock Wood Railway Station, such uses could assist with wider town centre regeneration objectives and/or meeting the needs of a growing population.

Whilst we fully acknowledge that the majority of the Transfesa Road Area would not be suitable for uses other than those already permitted by policy ED 1, sections of the area would be due to their relationship with the town centre. For example, our clients land is located less than a 10 minute walk from the town centre and an even shorter distance from the Paddock Wood Train Station. Within Chapter 3 of this representation we expand on the opportunities to deliver alternative uses on land within our client’s ownership.

Therefore, greater flexibility should be built into the policy wording to allow a greater range of uses in suitable locations and enable responsiveness to changes in economic circumstances.

[TWBC: see full representation. Also Comment Nos. DLP 7242 (Policy STR/PW1, and DLP_7260 (the Development Strategy)].

DLP_7659

Mr J Boxall

Support with conditions

Policy Number:   ED 1

More business areas should be allocated in the Cranbrook and Sissinghurst area due to the difficulty in travelling by road or public transport to the key economic hub in Tunbridge Wells.  Without this, any development in this area is unsustainable.

DLP_8172

Highways England

 

Any new employment area is likely to generate trips on the network and should be located in areas where sustainable transport and active transport options are the primary mode choice.

However, large number of employment sites, specifically within the B8 category can be predominantly vehicle based.  Therefore, as well as providing a full transport assessment, a route distribution assessment will be required. This requirement should  included in policy/text as appropriate.

It should also be noted that parcel delivery companies have been found to generate up to 6 to 8 times as much traffic (staff/ deliveries) as other B8 uses. Consequently, until such time as the full impacts and appropriate mitigations of this particular sector are more widely understood and agreed, Highways England recommends that policy and text explicitly states that any applications for this type of use will be dealt with on their own merits and are not considered automatically to be in accordance with the local plan.

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

DLP_8417

Paddock Wood Labour Party

Object

Policy ED1 & ED4. OBJECT.

Employment

There is insufficient focus in the employment section on how the Local Plan will seek to build an inclusive economy in Paddock Wood. Development and regeneration should be assessed on the impact on wellbeing and inclusivity as well as economic growth. Growth should provide benefits to everyone and not just those profiting from property development. Long standing residents should not be pushed out of their communities just to make way for wealthier people moving in. Growth should be assessed against the Social Value it is providing to the local area.

In work poverty is a problem where local earnings are below the SE regional average whilst housing costs are high. The challenge of affordability can only be addressing by providing new social rented units for those most in need. The TWBC needs to focus on the quality of jobs being provided and work to improve the range of local jobs to enable more local people to work in the Borough including PW. TWBC must invest and take steps to avoid being a commuter dormitory Borough for London.

Policy ED 2: Retention of existing employment sites and buildings

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1874

Royal Tunbridge Wells Town Forum

Support

Policy Number ED 2 Retention of Employment Sites 

We strongly support this policy and the use of Article 4 Directions to ensure that well located and suitable office buildings should be retained in office use within RTW.

DLP_3658

Lynne Bancroft

Support with conditions

Employment needs to be retained and encouraged in Cranbrook and Sissinghurst and other small villages in the Borough. Currently the development proposed by the TWBC Local Plan in Sissinghurst is unsustainable due to lack of employment opportunities and facilities.

DLP_4200

Tunbridge Wells District Committee Campaign to Protect Rural England

Support

CPRE supports this policy

DLP_5219

Culverden Residents Association

Support

We support this policy which should prevent any further loss of office accommodation in the town centre.

DLP_7660

Mr J Boxall

Support with conditions

Employment needs to be retained and encouraged in Cranbrook and Sissinghurst and other small villages in the Borough.  Currently the development proposed by the TWBC Local Plan in Sissinghurst is unsustainable due to lack of employment opportunities and facilities.

DLP_7718

Stephen Ward Town Planning and Development Consultations Ltd for Anglo Beef Processors

Object

Paragraph Number(s): 6.422 & 6.423 

Paragraph 6.422 states “In addition to the provision of new sites and allocations to meet the employment needs of the borough, it is also important that the stock of existing employment sites is maintained across the whole borough (not just within the Key Employment Areas)”. According to the Draft Local Plan, this approach is based on justification from the Economic Needs Study (p.462).

It is submitted that a blanket approach to the preservation of employment sites across the borough was not the intention of the Economic Needs Study (August 2016) (ENS). The analysis undertaken by the ENS highlighted the significant loss of office (B1a) floorspace which has been exacerbated by Permitted Development Rights for office to residential conversions. Due to the continued significant threat of the change of use from office accommodation to residential, it has been recommended that the Council should seek to protect the remaining well located, suitable office stock through the use of Article 4 Directions, alongside criteria-based development management policy within the new Local Plan (para. 6.424).

However, the following trends were also identified-

  • Industrial premises occupy the greatest amount of floorspace in Tunbridge Wells and stock of industrial floorspace experienced a modest increase over the period to 2012 (para. 5.29 ENS).
  • The largest share of new employment floorpsace was in Tunbridge Wells (para. 5.29 ENS).
  • Tunbridge Wells is characterised by an ageing stock of employment floorspace with a large number of commercial properties built before 1950(para. 5.29 ENS).
  • Professional services are expected to see the strongest growth in Tunbridge Wells, representing approximately one in five new jobs forecast in the borough (para. 8.22, ENS).
  • Significant advances made in manufacturing technologies and business practices have resulted in declining demand for industrial land in many areas (para. 8.69).
  • Table 10.4 of Section 10 outlines the Recommended Land Requirements 20132033/35 states that B1c/B2 Industrial as negative (-1.4ha/1.8ha). The need for 14ha of employment land relates to B1a/b Office and B8 Warehouse uses.

It is submitted that the type of employment facilities on site at WA Turner site are unsuitable for the projected employment needs of the area.

Paragraph 6.423 states that it is important “that good quality existing sites and buildings are not permanently lost to alternative uses as a result of short terms trends and changes in demand, while recognising that the permanent protection of sites and buildings that have no prospect of coming forward for its permitted/designated use is counter-productive for the local economy”.

It is submitted that the WA Turner site (Ref 145) is one such site. The removal of this site from the allocations policy of the Local Plan would not be to the benefit to the local economy. The employment use on the site did not arise from a plan-led approach. Rather it is a historical use that emerged on a piecemeal and ad hoc basis and now appears as a land use anomaly when considered against the predominance surrounding uses that are residential.

DLP_7720

Stephen Ward Town Planning and Development Consultations Ltd for Anglo Beef Processors

General Observation

ED 2 relates to the retention of existing employment sites and buildings with the target of “no loss of business Floorspace” stated at Appendix 3 of the draft Local Plan. Justification for not allocated the WA Turner Factory Site has been linked to this policy. Policy ED 2 includes three criteria to retain existing employment sites in their existing use or an alternative employment generating use as follows-

1. Are well located to a main road and public transport networks; and

2. Provide, or are physically and viably capable of providing, through redevelopment, good quality modern accommodation attractive to the market; and

3. Are capable of meeting a range of employment uses to support the local economy.

It is submitted that the WA Turner site does not comply with any of the above criteria. The existing factory is unsustainable due to the dated technology and facilities it offers. The cost of redeveloping this site for a manufacturing use is unviable.

It is clear from the Economic Needs Study that manufacturing is in decline and that professional employment uses are required into the future and the protection of Office B1a accommodation. The WA turner site is restricted in size and shape and would not be attractive to the market for high quality accommodation for a series of reasons including market demand which is for buildings with large floor plates and other very specific requirements such as minimum floor to ceiling heights. Access to the site is also restricted because of the adjacent bridge structure and the restricted space for manoeuvring of large vehicles.

Policy ED 3: Digital communications and fibre to the premises (FTTP)

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1763

Horsmonden Parish Council

 

Policy ED3- Digital Communications and Fibre to the Premises (FTTP): We support this policy in promoting FTTP in larger scale developments proposed in the draft Local Plan. The quality of digital communications is currently a big issue for local businesses in Horsmonden. However, we are disappointed to see that the ambition to provide the highest level of connection to all properties - which applies to the towns and the proposed new settlement at Tudeley - falls short of Horsmonden (but not Pembury, which is being asked to accommodate a similar level of new development to Horsmonden).

DLP_1875

Royal Tunbridge Wells Town Forum

Support

Policy Number: ED 3 Digital Communications 

We support this policy in a Borough that has a particularly high and still growing level of home working. It is important that digital infrastructure should be provided both to private and public sector housing.

DLP_1967

Ms Jacqueline Stanton

Support with conditions

Policy ED3

Horsmonden parish is not supported by suitable digital communications and if the level of development, as set out in this Plan, happens in the parish, the level of provision will not be adequate.

DLP_3380

Kent County Council (Growth, Environment and Transport)

 

Broadband

KCC welcomes the inclusion of policy ED 3 (Digital Communications and Fibre to the Premises) as there is a need to ensure that new development has either full fibre (FTTP) or gigabit capable connections.

Given the recent shift in Government policy (set out in the Future Telecoms Infrastructure Review) from superfast speeds (in excess of 24mbps) to ‘gigabit-capable’ speeds (delivered either via wired i.e. FTTP or wireless solutions) KCC would request that the references to 24mbps, high speed and ‘next generation-access’ are replaced with the term ‘gigabit-capable’. This will help ensure that the plan is in keeping with current and emerging national digital infrastructure policy.

KCC also believes, given the increasing importance of mobile connectivity, that developers should be strongly encouraged, at an early stage, to discuss mobile coverage and capacity with mobile network operators to ensure that new development has the mobile connectivity that businesses and residents would expect.

DLP_3659

Lynne Bancroft

Support with conditions

Employment needs to be retained and encouraged in Cranbrook and Sissinghurst and other small villages in the Borough. Currently the development proposed by the TWBC Local Plan in Sissinghurst is unsustainable due to lack of employment opportunities and facilities.

DLP_4010

Lamberhurst Parish Council

Support

ED3 – Digital Communications & Fibre to the premises (FTTP)

Supports in general the proposal to improve digital communications network throughout the borough.

DLP_4201

Tunbridge Wells District Committee Campaign to Protect Rural England

Support

CPRE supports this policy

DLP_7661

Mr J Boxall

Support with conditions

Employment needs to be retained and encouraged in Cranbrook and Sissinghurst and other small villages in the Borough. Currently the development proposed by the TWBC Local Plan in Sissinghurst is unsustainable due to lack of employment opportunities and facilities.

Policy ED 4: Rural Diversification

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_3660

Lynne Bancroft

Support with conditions

Employment needs to be retained and encouraged in Cranbrook and Sissinghurst and other small villages in the Borough. Currently the development proposed by the TWBC Local Plan in Sissinghurst is unsustainable due to lack of employment opportunities and facilities.

DLP_4202

Tunbridge Wells District Committee Campaign to Protect Rural England

Support

CPRE supports this policy

DLP_7662

Mr J Boxall

Support with conditions

Employment needs to be retained and encouraged in Cranbrook and Sissinghurst and other small villages in the Borough. Currently the development proposed by the TWBC Local Plan in Sissinghurst is unsustainable due to lack of employment opportunities and facilities.

DLP_8418

Paddock Wood Labour Party

Object

Policy ED1 & ED4. OBJECT.

Employment

There is insufficient focus in the employment section on how the Local Plan will seek to build an inclusive economy in Paddock Wood. Development and regeneration should be assessed on the impact on wellbeing and inclusivity as well as economic growth. Growth should provide benefits to everyone and not just those profiting from property development. Long standing residents should not be pushed out of their communities just to make way for wealthier people moving in. Growth should be assessed against the Social Value it is providing to the local area.

In work poverty is a problem where local earnings are below the SE regional average whilst housing costs are high. The challenge of affordability can only be addressing by providing new social rented units for those most in need. The TWBC needs to focus on the quality of jobs being provided and work to improve the range of local jobs to enable more local people to work in the Borough including PW. TWBC must invest and take steps to avoid being a commuter dormitory Borough for London.

Policy ED 5: Conversion of Rural Buildings outside the Limits to Built Development

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_2682

Jeremy Elsom

Object

Policy ED5

Policy ED5 is not “Sound” in terms of Para 35 of the revised NPPF in that it is inconsistent with National Planning Policy contained in the revised NPPF and in the T&CP(General Permitted Development)(England) Order 2015(as amended). Criteria d in the Policy with regard to giving preference to employment uses over residential use is not justifiable in planning terms, is contrary to National Planning Policy and could result in a negative impact on housing supply.

The NPPF seeks a ‘significant boost to housing delivery’ and contains lengthy and specific requirements to measure and meet housing targets . While it also acknowledges the importance of employment development it is clear that housing delivery is the most significant issue. As part of this provision Para 68 of the NPPF supports the development of windfall sites as does Para 4.11 of the Draft Local Plan and Para 79 of the NPPF supports the re use of redundant buildings in the countryside for residential use. Furthermore Government Policy in Part 3 of the T& CP(General Permitted Development Order)(England)Order 2015(as amended) specifically allows redundant farm buildings to go to residential use without any requirement that they first be tested for an alternative economic use. Thus National Planning Policy is to support the use of redundant rural buildings for residential use. Furthermore it gives permitted development rights for changing business and storage uses to residential use.

Thus the thrust of National Planning Policy is to prioritise residential over employment uses and specifically with regard to the use of redundant agricultural buildings for residential use. In contrast draft Policy ED5 supports economic use for such buildings and only permits residential use in exceptional circumstances which includes the requirement for a lengthy 2 year marketing period which will be highly onerous to the applicant and goes against the principle of rapid decision making. Thus the approach in Policy ED5 is clearly at odds with that in the revised NPPF and other National Policy with regard to this matter.

Policy ED5 provides very onerous tests with regard to demonstrating that rural buildings should first be considered for employment uses. Policies should only be adopted if they can be justified in terms of meeting specific planning objectives and safeguarding against specific planning harm. As stated above the need for residential units should have priority or at least be on par with the need for economic units and therefore there is no justification for the onerous tests in the Policy with regard to economic use of rural buildings and therefore no material harm can be shown for giving residential use as a priority for the conversion of rural buildings or at least to put it on par with economic uses. This would be in line with recent National Planning Policy.

There is also an objection to criteria (a) in Policy ED5 which states that buildings for conversion should have historic or architectural value or be part of a whole farm plan and no other use is viable. This criteria confuses the need to preserve buildings of historic or architectural merit which is covered by other policies in the plan and making the best use of redundant agricultural buildings. In para 6.443 in explanation of Policy ED5 it acknowledges the importance of rural buildings generally and states;-

“Many of the existing buildings are of historic or architectural interest…others are not of historic or architectural interest but rather of a more functional appearance, however they are still reflective of the rural character and landscape”.

Para 79(c) of the NPPF only refers to “the development would re-use redundant or disused buildings…” there is no requirement for them to be of historic or architectural interest. Similarly there is no justification for having to put forward a whole farm plan or show no other use is viable This again implies contrary to National Policy that residential use is in some way onerous and needs special justification which is not the case.

There are two other ammendments which need to be made for clarification purposes. With regard to criteria b it could be open to a wide interpretation as could the word 'Modifications' in criteria 2 as any conversion could be argued to include some form of modification.

In order to meet these objections the following changes should be made:-

Proposed changes to Policy ED5:- Criteria (a) should be modified to refer only to all substantial rural buildings, and the reference to historic buildings and ones of architectural value as well as whole farm plans and viability should be deleted. Criteria (d) should be deleted .Criteria (b) should be replaced with the words"Should have accessibility to a range of services in a nearby settlement". Criteria 2 should have the word "modification" deleted.

DLP_3662

Lynne Bancroft

Support with conditions

Too many rural farm buildings have been converted into homes restricting the opportunities of turning them into employment sites or ongoing farm buildings for others to use. TWBC should be a lot more restrictive on the conversion of such buildings to ensure farmers and businesses have places to trade from in the rural countryside

DLP_4203

Tunbridge Wells District Committee Campaign to Protect Rural England

Support

CPRE supports this policy

DLP_4257

Rother District Council

Support

Support

The priority to the employment use of rural buildings is consistent with the policy approach of this Council, having regard to the need to support economic activity in rural areas, especially in the AONB and the pressure on such opportunities to be lost to housing.

DLP_4376

British Horse Society

Support

Too many stables are being converted to residential use or use as holiday accommodation, resulting in the loss of places to keep horses or in applications for new stabling in the area.  This policy should help to prevent this in future.

DLP_5161

Cushman Wakefield for Ministry of Justice

Object

Policy ED 5

This is the key policy in respect of development outside of the Limits to Built Development but relates only to the conversion of ‘rural buildings’, referring to “agricultural or other rural buildings” and is predicated on the basis that the type of building to which it applies needs to be broadened. Furthermore, the policy is also focussed on conversion to business, recreation and tourism rather than residential, requiring a minimum marketing period of two years. We consider this approach is unjustified and unreasonable as it does not allow a balanced planning assessment of the most appropriate use of individual sites, especially those which do not fit with the preconceptions of the policy. We also consider that there is no justification for the blanket imposition of a requirement to undertake marketing as a balanced planning assessment will often demonstrate that a residential solution is the best. We consequently request that the approach of this policy be amended to recognise that some sites do not fit with the preconceptions inherent in its stance and that where it is agreed that residential use is appropriate the marketing requirement is waived.

Finally, we consider that in any event a two-year marketing period is too long and that a 6month period is sufficient to test the market provided that a full marketing exercise is undertaken. The marketing requirement should not be imposed simply as a time bar to discourage a particular form of development and so should only be of a length of time necessary to investigate the market appetite and not any longer as this would simply defer the delivery of much needed housing without justification.

[TWBC: see Comment Numbers DLP_5154, 5157-5159, 5161, and 5163-5164. See also full representation].

DLP_7663

Mr J Boxall

Support with conditions

Too many rural farm buildings have been converted into homes restricting the opportunities of turning them into employment sites or ongoing farm buildings for others to use.  TWBC should be a lot more restrictive on the conversion of such buildings to ensure farmers and businesses have places to trade from in the rural countryside

Policy ED 6: Commercial and private recreational (including equestrian) uses in the countryside

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_4204

Tunbridge Wells District Committee Campaign to Protect Rural England

Support with conditions

CPRE supports this policy.  We would like to see point 12 extended to make clear that importing soil to the site to create bunds or dams, or to raise the overall level of the site, will also be controlled.

DLP_4258

Rother District Council

Support

Support

Accords with this Council’s policies for equestrian development in the countryside, with a requirement for proposals within the AONB to conserve its special landscape character and features.

DLP_4377

British Horse Society

General Observation

The policy seems reasonable.  Equestrians value the countryside and want to see it protected from unnecessarily damaging development.  Horses can help to preserve the High Weald landscape and biodiversity by grazing its small fields and providing a market for locally grown hay.  The rich grazing resulting from the application of fertilisers can lead to the serious and sometimes fatal condition of laminitis in horses, so fields used by horses, and the hay and haylage grown to feed horses, will need far lower fertiliser applications, if any, and hence will be more biodiverse than fields used for cattle or arable land.

Policy ED 7: Retention of, and promotion of new, tourist accommodation and attractions

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_358

Jeremy Skene

Object

Comment on Policy ED 7

1. Preface

Whilst the need to ensure adequate tourist accommodation and facilities through planning policy is fully supported, we contend that any measures should be equitable upon all operators and without disadvantage to any sector or group.

Moreover we contend that such planning should be successful in providing not only sufficient accommodation but also facilities commensurate with modern visitor needs. Recent technological innovations have provided a sudden growth in visitor aspirations that must be met in order to maintain and promote RTW as a premier choice not only for tourists and short term visitors but also for commercial customers who increasingly demand updated facilities.

This development, together with growing economic pressure from declining demand, increased fixed and employment costs and tightened regulatory pressure, has placed mounting difficulties upon the general hotel sector (evidenced by the recent Premier Inn profits warnings for example) and specific problems upon smaller businesses and those in out-dated buildings in particular.

This submission examines the severe difficulties imposed upon small budget hotel businesses that the proposed policy will enact and they are respectfully drawn to the attention of Council members and planners so that an informed decision may be taken.

2. Submission

The current Local Plan Policy T2 allows change of use upon proof either that the hotel is no longer economically viable or that its location is no longer suitable. This has been the critical justification; if the business cannot be sustained through valid circumstances the Council has properly authorized a change of building use not only to avoid pointless dilapidation but also to contribute to the ever growing need for residential accommodation or other business use.

However the new Draft Local Plan Policy ED 7 assesses applications against five different criteria, ALL of which must be met. We contend this places draconian restrictions upon current hotel owners, particularly those in old rambling buildings that are not cost effective to update or even operate.

Criterion 1 requires proof that the hotel location is no longer suitable for tourist accommodation. We contend that very few if any hotel businesses in RTW are situated outside suitable tourist areas and that very few, if any, will therefore qualify for conversion.

Criterion1 thereby appears to be a ‘catch all’ measure that automatically dismisses any chance of conversion for most hotels within the borough regardless of other circumstances. It is completely unfair on applicants in genuine business difficulties and should therefore be excluded in its entirety.

Criterion 2 requires evidence that the hotel has been marketed through several, including some specific, channels over a relevant period. However no distinction is made between small businesses, where marketing must be limited to sustain effective profitability, and larger chain hotels, where the group marketing is more comprehensive and costs are negligible to each outlet.

It seems this criterion is aimed to ensure that a reasonable and earnest attempt was made to market and operate the hotel. As such it is perfectly in order but without realistic measures of that marketing effort, and without regard to the difference between types of hotel, it could be easily misconstrued and thereby erroneously applied.

In the budget sector, virtually all business today is derived through website marketing, online agency sales and guest entries in Trip Advisor or similar. Guests are keen to rate their experiences on line so hotels are forced to work in order to maintain good enough scores. In consequence no other marketing is either necessary or effective.

However Luxury hotels will require more sophisticated marketing, selling facilities for weddings, events, conferences and high end catering. Boutique hotels will have yet different marketing needs for their niche approach.

Accordingly we feel that criterion2 should not include any specific marketing channels but establish merely that suitable marketing was exercised.

Criterion 3 requires the hotel to be for sale at a ‘market price’ reflecting its use and condition for at least two years and to provide reasons for rejecting any offers received.

We contend this measure is entirely draconian and will provide substantial and unfair opportunities for large chain operators or financial speculators at the expense of small private hoteliers.

I shall explain. Hotels are generally valued as a function of their turnover, profitability and sustainability of the business. For example the Tunbridge Wells Retreat Hotel was given a 2m valuation on a 175k profit in the 2019 Hotel Viability Report (see Financial Information Summary, Section 11.2) This illustrates that investors normally require the operational profit to be 6-10% of valuation in order to sustain capital costs, periodic renovations and any business fluctuations.

Consequently any drop in profitability will have significant effects upon market valuation and, as profitability only occurs beyond a break-even turnover, even a 10% drop in turnover can eradicate most, if not all, profit. This can occur without any mismanagement by the operator and is often inflicted by newly built or upgraded competition that draws away customers and reduces sustainability. Where budget hotels are entirely unsuitable to the cost effective upgrades needed to match their new competitors, profitability may even be reversed into loss and the valuation must then fall to scrap value.

This situation would be distinctly attractive to the very hotel chains that initiated the drop in turnover in the first place. Criterion3 will even encourage them to undercut room rates in order to close down small hotels and acquire their premises as profitable annexes to their central operation at well below real value prices.

Alternatively such low valuations will also attract speculators able to withstand long periods of shut down and dereliction before the Council is obliged to permit the much needed residential conversion. Most private small hoteliers are unable to withstand such loss for so long and this criterion thereby effectively forces them to either ‘sell for a song’ or face years of hardship. Indeed many might even be forced into bankruptcy (where the valuation does not cover their capital loans) despite having perhaps served the community for many decades and are now facing retirement age.

Moreover, where viability is deemed negligible by reputable estate agents, no effective sales marketing is even possible except towards speculators and the chain hotels as described (See letter from Fleurets agents in the Tunbridge Wells Retreat Viability Report)

Furthermore it is impossible to market a hotel without the knowledge of staff. This is likely to reduce motivation and the ability to function the business effectively, thereby compounding the pressure on profitability and further reducing the consequent market value.

We contend that the free market in this instance cannot be taken as a fair measure of viability as market valuations can be easily manipulated by larger chain operators. Hence criterion3 does not appear to meet common standards of social justice (and thereby public endorsement) and should therefore be excluded in its entirety.

Criterion 4 is ambiguous in so far as all hotels require business planning to operate in the first place and the performance against targets cannot be measured without specification of what those targets should be and the differentiation in targets between individual businesses.

However, if criterion4 is aimed to simply ensure that the business has been professionally and efficiently run despite the difficulties that have led to the application, it is accepted to be in order providing that such is clearly stated within it.

Criterion 5 is again ambiguous. It requires the applicant to evidence any property upgrading aimed to ‘increase attractiveness to the market’. But whether that ‘market’ lies within the operational or sales sphere is not specified. Moreover it implies (but does not state) an obligation upon the applicant to invest in such upgrades even though neither the property nor its business would necessarily benefit from them. Hence this criterion again could easily be misconstrued and thereby erroneously applied.

We accept that the Council should ensure that reasonable investment was made throughout the applicant’s tenure to provide proper maintenance and suitable guest standards. Normally this would involve expending 5% of turnover on maintenance and such can easily be verified through historic business accounts. This would prevent applicant owners choosing to run down their hotels in order to cynically claim unviability and thereby qualification for conversion.

However criterion5 refers to upgrading in order to increase property attractiveness rather than maintaining it. This involves capital investment additional to that required for the original premises and which may, in many circumstances, be entirely imprudent or even ruinous to the business.

I shall explain. Any hotel business must analyse all capital expenditure against current and predicted market conditions, structural realities and estimated costs per letting bedroom in order to ensure a sustainable return on investment. Hence there can be many perfectly fair reasons not to upgrade, as several older or budget sector businesses in RTW have already experienced:

(i) The Chain Hotel effect. The RTW budget hotel market is significantly evolving in jeopardy to the prospects for small independent operators. Two large budget chain hotels (87 bed Travel Lodge and the 110 bed Premier Inn) will be operating in 2020 with considerable economic advantage over their smaller private competitors:

A. Their rooms are mostly sold directly through their own centralised systems. (Premier Inn report 97% direct sales) Independents must use online sales agents as most customers search through that medium. (brochures, advertisements and guides as specified in criterion 2 are now obsolete in the budget market) Most agents demand 20% commission thereby immediately removing that profit from the bottom line.

B. The considerably larger scale of chain hotel operations allows much greater economy of scale in every sector: staff requirements, supply purchasing and maintenance costs. Hence an additional 20% (estimated) is removed from the bottom line of their smaller independent competitors.

C. Newly built hotels (such as the Premier Inn) will also have important features such as air conditioning and thermal insulation already built in. Older buildings (and especially old conversions of Victorian terraced houses) cannot offer equivalent attractions to their customers or energy saving features to their operators. The capital investment per bedroom to provide them is many times greater than the cost for modern buildings and were the small independents to do so, an estimated additional 20% (estimated) would also be removed from their bottom line.

D. As the budget market is (by definition) price sensitive, the chain hotels need only price below their small independent competitors to attract the vast bulk of business in that sector and smother them. Only if all 197 chain hotel rooms are occupied will the market be fully open to competition. Hence significant additional pressure is put upon small business turnover and the bottom line is yet further reduced.

(ii) Building limitations. Any form of upgrading is entirely dependent upon property size, structure and type. No distinction is made in the criterion for these factors. A larger business can absorb upgrades more easily than smaller rivals as their ratio of revenue generating space against unproductive space is much higher. Newer and compact buildings can also be upgraded with considerable cost effectiveness. Victorian town centre budget hotels (and terraced house conversions in particular) with failing structures, out-dated facilities and rambling layouts simply cannot achieve comparable cost effective modernisation for contemporary hotel usage.

Evidence of this may be found in the recent Tunbridge Wells Retreat viability report. In the Financial Information Summary, the capital expenditure requirements for its modernisation are analysed. The costs of upgrading the hotel within the Budget or 5 star market provide a return on that investment of less than 4% despite the considerable risks involved. Such prospect will prohibit normal bank funding and thereby render the upgrade unviable.

Moreover some older budget hotels stand in designated Conservation Zones that significantly restrict the upgrades needed to meet modern demands and maintain profitability. Complete rebuilding with additional floors for example, a possible solution for some old hotels, is prohibited in these zones without impossible architectural and size limitations.

(iii) Hotel sector restrictions. Particular problems exist in RTW for small budget sector hotels aiming to alleviate turnover decline through a change in target market. The 2017 RTW Hotel Capacity report recommends increasing the supply of serviced accommodation, affordable hotels and 5star hotels. There are apparently enough mid-price and boutique hotels in town and any further supply would denude their operating abilities.

However a small independent budget hotel cannot upgrade to 5star hotel as they require certain facilities, plot size, room layouts and locations not normally available for them. An old town centre budget hotel, for example, cannot find space to build a luxury swimming pool and sauna complex together with banqueting facilities and adequate car parking. There are consequently considerable limits to what can be done to make a failing Victorian budget hotel more profitable.

Criterion5 is thereby also draconian in its ambiguity and failure to recognise many specific problems that will exist for individual applicants. In some cases the sustainability of business through market reality is insufficient to merit renewal of facilities let alone additional investment for upgrades and improvements. Hence this criterion does not appear equitable and should be excluded in its entirety or redrawn to reflect the circumstances described above.

3. Conclusion

It is important for any legislation to be clear in definition, effective in its aims and straightforward to enact. We feel that Policy ED7 does not meet these criteria.

The existing Policy T2 appears already clear and straightforward but might be impeded in effectiveness through abuse and malpractice by unscrupulous landlords. I suspect that this factor has influenced the new policy which now attempts to neutralise that.

But the longer term prospects for the borough are not served by the enforced retention of old hotel stock entirely unsuited to modern needs and without sufficient business potential to meet them. By example we should consider the situation 100 years ago when several completely out-dated 18th century inns still existed in many towns and cities. Modern needs were met with their demolition and redevelopment either as new hotels, new accommodation or even public buildings. There was no sense in keeping them then and there seems little sense in maintaining 19th century house conversions as hotels today, now that their popularity and effectiveness has waned.

Consequently we contend that the borough is best served by encouraging new build hotels on brown sites rather than maintaining old inappropriate properties better suited to other use.

4. Alternative Proposal

We have considered the new town planning measures taken in Eastbourne, where similar issues have been encountered, and drawn illumination from them.

To satisfy the Council requirements for suitable tourist accommodation and the prevention of landlord malpractice, to prevent inequity upon genuine applications in unviable situations and to prevent unscrupulous speculation by investors and large chain operators we respectfully suggest the following reforms:

Policy T2 should be retained in principle (economic viability as the principal criterion) but strengthened to include the clarified essence of Criteria 2 and 4 in Policy ED7 as described above. In short any substantive claim for unviability must include evidence that proper and sufficient marketing has been applied and that the property has been properly maintained and professionally managed with adequate plans, targets and comprehensive accounts. An assessment of all these factors is a fairly clear and straightforward process which may be verified by a certified hotel valuer/consultant at the applicant’s cost should the Council feel the initial application does not bear sufficient evidence, detail or clarity. Criteria 1,3 and 5 appear inappropriate and unnecessary complications that could well worsen the hotel supply and lead to an uncompetitive market or even a near monopoly in the budget sector, besides an open field for speculators to exploit the misfortune of those genuine hoteliers heavily disadvantaged by changing times and circumstances.

DLP_1876

Royal Tunbridge Wells Town Forum

Support

Policy Number: ED 7 Retention/Promotion of Tourist Accommodation 

We support this policy as it is required to facilitate an economic policy supported by the Town Forum for developing Royal Tunbridge Wells as a destination town based on its historical, cultural, leisure and natural heritage. As climate change mitigation develops, there will be an increase in local tourism from the near continent and other parts of the UK and an increase in tourist accommodation will therefore be required.

DLP_3138

Concept Town Planning Ltd

 

I have some  comments I would like to make in relation to the section of the plan entitled ‘Retention of, and promotion of new, tourist accommodation and attractions’

Firstly, in relation to paragraph 6.469 the text says there is support for “small-scale initiatives that support the rural economy.”  This is very limiting in nature.   Small scale is not subsequently defined in the text, so this is an ambiguous term and is inappropriate as the scale of development needs to considered in the context of its location and the text should be altered to reflect this.

Secondly, in relation to the part of policy ED7 entitled ‘New tourism accommodation and visitor attractions’ we would argue that support for such should also be given to accommodation which will help to diversify the tourist provision, extend the tourist season and increase the number of visitors staying overnight, especially sustainable tourism opportunities that can capitalising on assets such as the county’s landscape and natural assets

We note that the policy then makes reference to “outdoor accommodation”.  However, it is unclear what this entails and examples of such should be included in the supporting text to the policy.  We assume this type of accommodation would include the following: tents, caravans, yurts, glamping pods and cabins.

DLP_3571

Kent & East Sussex Regional Office
National Trust

Object

Policy ED 7 supports the retention of existing tourism accommodation and supports new visitor accommodation and new visitor attractions but fails to adequately support existing visitor attractions. The policy should also support the sustainable growth of existing tourism within the Borough through the provision of new facilities in appropriate locations and where it would not harm the character of the environment.

DLP_4039

Dr P Whitbourn

Object

Paragraph 6.469 makes the point that the tourist industry is significant to the Borough and is considered to be an important contributer to the economy of Tunbridge Wells.

However, although the historic town of Royal Tunbridge Wells continues to be thought of by some as a tourist destination town, such as it once was, in reality the town is now almost devoid of visitor attractions. The "Day at the Wells" experience in the Corn Exchange is no longer a feature of The Pantiles, and neither are the interesting antique shops for which the place was one well-known. The town's museum and art gallery will be closed for some time, and heritage trains on the Spa Valley Railway only run intermittently while, in the longer term, it remains to be seen whether the heritage line has a future, if main line services to London Victoria and to Brighton come to be reinstated.

It is disappointing therefore, to see that Policy ED7 makes no actual proposals for remedying the present deteriorating situation, but only offers rather vague "support" for unspecified visitor attractions, and that subject to several potentially less than encouraging conditions. Yet this historic town of Royal Tunbridge Wells has so much potential that might be unlocked, if the will and determination to do so existed. Thus it would be good to see a more positive and aspirational approach in the Plan.

The Cultural Hub is a good starting point, and worth a mention in this section, especially as it is an example of the Council giving a lead. Nevertheless, it has to be said that the new Hub will be too cramped and ought to spread into the adjacent over-large Town Hall, through which it could link with a refurbished Art Deco Assembly Hall, the historic Court House, and Decimus Burton's Calverley Terrace, as indicated in the diagram on page 18 of this response. No 9 Crescent Road, in particular, might be sympathetically refurbished, suitably furnished, and well presented as an introduction to Decimus Burton's seminal Georgian Calverley New Town, and related to nearby Trinity Theatre, and other features of the Georgian new town.

Immediately to the north of the Cultural Hub is the spectacular Edwardian Baroque Opera House, the upper floors of which are at present closed to the public, but which might well make an interesting heritage attraction, associated with the popular place of refreshment below.

At the southern end of the town centre, the obvious focal point of The Pantiles should be at the Georgian Bath House, which is the one building in this key heritage ensemble that is the work of a noteworthy architect of the period, as well as containing the chalybeate spring that gave rise to the birth of this spa town. Currently, the premises are occupied by a chemist's shop, which provides a useful and valued local facility.

However, two sizable shops nearby became vacant recently, and it may not be impossible that at sometime in the future a managed relocation could take place that would allow the Bath House to become once again a visitor attraction and the focal point of the Pantiles. Baths that are at present concealed beneath the shop floor could be opened up, and the story of thee Pantiles and Tunbridge Wells explained in engaging displays.

As parts of the Bath House now interconnect with Framptons premises next door, it may be that a heritage attraction and refreshment facilities could be combined to their mutual advantage. Tourist information, attractions and facilities are needed both at the top and bottom ends of theof the town centre, and the Bath House would be a good location for a proper replacement of the disgracefully poor TIC currently situated in the Corn Exchange.

Clearly, some ideas for visitor attractions would involve various parties, including the Council's Museum Service, and private property interests. Nevertheless, I feel strongly that greater efforts need to be made, and that Policy ED7 is in need of a more proactive approach.

DLP_4205

Tunbridge Wells District Committee Campaign to Protect Rural England

Support with conditions

CPRE supports this policy, but suggests adding to point b “or on the Green Belt”.

DLP_4259

Rother District Council

Support

Support

The general approach taken to the promotion of new and retention of existing tourist accommodation is consistent with this Council's policies.

DLP_4312

White Young Green Planning for Standard Life Investments UK Real Estate Fund

Support

Policy EN 7 – Retention of, and promotion of new, tourist accommodation and attractions 

Standard Life Investments UK Real Estate Fund support the current wording of Policy EN 7 (Retention of, and promotion of new, tourist accommodation and attractions), particularly in relation to its support for new tourism accommodation and visitor attractions.

DLP_5917

Sarah Hamilton

 

I have now seen submissions from the Parishes and Town in my Division and have just sent you a contribution from Lamberhurst residents.

As you are aware I am triple hatted (Paddock Wood East) and  have discussed my position with the TWBC Monitoring officer.

You will have received many detailed responses which I don’t need to add to. We have already discussed many topics. They include flood risk, roads, rural transport and distribution networks as well as future demands in terms of the nature and  location of employment and uncertainty of retail.

As you know I  have raised these issues with you and your team concerning the whole Division and would not wish to add to that in terms of repetition but  would like to emphasise the following:

ED7 and ED8 : The rural economy is fragile and opportunities for tourism / visitors essential. As one example Heritage Open Days, a yearly festival encourages this by creative events reflecting local heritage which in turn supports local business. Paddock Wood is at the heart of a unique rural heritage and is well placed to attract visitors to the area. The Wesley Centre (built in 1888 non-designated EN7) which includes a small grassed area is well placed to support a local archive as well as events to support arts and culture. Again its land, currently used by those who use its hall, should be protected as open space and against development other than anything that would be integral to future community use of the whole site and building.

The lack of protection in terms of heritage value of traditional rural cottages as well as Victorian / Edwardian buildings, pubs and community buildings is a great concern. Protection should, I believe, be strengthened (EN6) and broadened in terms of conserving areas and preventing unnecessary demolition. Focus on listed buildings, although of great importance, should not be the only consideration for adverse impact and quality of relationships within an area.

Lucks Lane in Paddock Wood is an example of an area that would benefit from protection of what is left to reflect its special rural heritage and the same could apply to other areas that will not have the advantage of master-planning.

[TWBC: see Comment Nos. DLP_5913-5925].

Policy ED 8: Town, Rural Service, Neighbourhood, and Village Centres Hierarchy

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1608

Maggie Fenton

 

Policy ED8 Towns Rural services, neighbourhood & village centres

6.479 The distinctive characteristics of each centre will be promoted in the place shaping policies with defined neighbourhood & village centres.

Recognises FOG exists within this policy BUT with no detail how it will be “promoted”. Throughout the DLP are details of improvements to other rural communities from 20mph speed zones, traffic calming measures and new facilities. There is absolutely no vision for the exisiting communities of FOG and  Capel apart from “betterment” from flood risk, which needs addressing now and an influx of thousands of new residents and cars.

The NPPF emphasizes the importance of creating healthy, inclusive & safe places for people to live & work. It seeks …..in the interest of securing sustainability well functioning centres to be retained or enhanced for the benefit of the local community.

The DLP is unsound in this respect.

DLP_2438

J Coleman

Object

The development in the TWBC Local Plan puts proportionately more housing into villages rather than larger towns and regional centres. The proposed numbers of housing developments in Sissinghurst outweighs the size of the village and is not sustainable development. Development should be closer to existing urban sites in larger towns and regional centres with employment, facilities and transport to prevent the destruction of the rural nature of the villages.

DLP_3663

Lynne Bancroft

Support with conditions

I agree with this policy but the development proposed by TWBC Local Plan puts proportionately more housing into villages rather than larger towns and regional centres, especially Tunbridge Wells itself. Sissinghurst’s proposed numbers of housing developments outweighs the size of the village and is unsustainable development. Development can only be sustainable if it is done close to existing urban sites due to lack of employment, facilities, transport and the destruction of the rural nature of the villages.

DLP_3713

Capel Parish Council

Object

Capel Parish Council objects to this Policy and to the following paragraphs of the accompanying commentary, for the reasons stated.

Paragraph 6.479 states that “The distinctive characteristics of each centre will be promoted in the place shaping policies.

Policy ED 8 identifies Five Oak Green as a ‘Village Centre’ which falls in the hierarchy after the defined primary regional town centre (RTW), town centres, rural service centres and neighbourhood centres.

Whilst the policy recognises Five Oak Green, there is no detail how it will be promoted to ensure its long term ‘vitality and viability’. Throughout the dLP are details of improvements to other rural communities from 20mph speed zones, traffic calming measures and new facilities. There is absolutely no vision for the existing communities of Five Oak Green and Capel apart from ‘betterment’ from flood risk, which already needs addressing pre-development, and an influx of thousands of new residents and cars.

The NPPF clearly states in paras 91-92 that planning policies and decisions should “should aim to achieve healthy, inclusive and safe places” and “ensure that established shops, facilities and services are able to develop and modernise, and are retained for the benefit of the community;

The DLP does not fulfil this requirement in terms of the existing settlements within Capel Parish and is therefore unsound.

DLP_3883

Mrs June Bell

Object

Policy Number: ED 8

Reasons for objection:

The DLP considers Cranbrook town centre on the same scale and capacity as Paddock Wood (population > 8,000, has a mainline train service, 7.7miles from employment, health, financial and retail hub in Tunbridge Wells) and Southborough (population of > 12,000, 2.2 miles from employment, health, financial and retail hub in Tunbridge Wells). This is not accurate and will not achieve sustainable development.

Cranbrook is described in section 2 as an attractive, vibrant rural town located within the High Weald AONB, with 2 distinct and designated conservation areas, limited impractical (to accommodate modern working commitments and drop off at nurseries) bus service to employment, health, financial and retail hub in Tunbridge Wells and ALL the 9 sites allocated in the DLP are within the designated AONB.

DLP_3973

IDE Planning for Paddock Wood Town Council

Object

OBJECT

This proposes to move Paddock Wood out of the rural service centre bracket to be designated a Town Centre alongside Cranbrook and Southborough. Whether this policy can be accepted will depend upon what is, in turn, accepted in terms of the scale of development at Paddock Wood/east Capel, its distribution, how sustainable it would be and phasing.

DLP_4206

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

CPRE’s opposition to “Tudeley Village” should be noted.  If “Tudeley Village” is built it should be shown as a town, not a neighbourhood centre, since it will be the size of a town and should be equipped with the services that a well-designed town of that size requires.

We also dispute the grouping of Cranbrook with Southborough and the proposed expanded Paddock Wood.

DLP_4497

Paddock Wood Neighbourhood Plan Steering Group

 

This proposes to move Paddock Wood out of the rural service centre bracket to be designated a Town Centre alongside Cranbrook and Southborough. This policy may be accepted overall – the point is made elsewhere concerning the scale of development at Paddock Wood/east Capel, its distribution, how sustainable it would be and the pace of change

The town centre does not offer sufficient facilities for the existing population, requiring people to travel out of town for most aspects of their social life.  Redevelopment of the town centre is essential prior to any further housing allocations – this is a project which cannot be delayed until the latter end of the plan period, but needs to come at the beginning.  The existing developments of 1,100 houses will put pressure on town centre facilities and should trigger the town centre development as laid out in the previous site allocations local plan. More information is also required on the definition of a “medium sized” foodstore and where it might be located.

A master plan is proposed; development is intended to revitalise and regenerate the town. Elsewhere in the Plan, reference is made to the town centre being reconfigured and expanded but it is not apparent from the policy as drafted what is meant by this. Neither is it clear what is meant under clause ‘4’ where reference is made to residential development in the town centre as ‘contributing’ to the 4000 unit allocation. Reference is made below under ED11 on the overriding need to protect the primary shopping area as a commercial area. Also, any high density housing in the centre of Paddock Wood should not exceed the height of existing buildings in order to retain the character of the town centre.

With reference to the map on page 191, which shows the area proposed for the Town Centre, the NP Group would support the extension of the town centre to include the whole of Commercial Road to prevent the current retail premises outside the proposed Town Centre from being converted into residential /other uses.  The shops currently “outside” the designated Town Centre are an integral part of the centre of Paddock Wood.

With the planned expansion of Paddock Wood the provision of additional public car parking is essential.  The NP group supports the idea of double storey car park at the Station and that  the railway station area should be made into a transport hub. The Group supports the idea of an additional large car park north of  the railway bridge to prevent people coming to the town centre just to park.

DLP_5918

Sarah Hamilton

 

I have now seen submissions from the Parishes and Town in my Division and have just sent you a contribution from Lamberhurst residents.

As you are aware I am triple hatted (Paddock Wood East) and  have discussed my position with the TWBC Monitoring officer.

You will have received many detailed responses which I don’t need to add to. We have already discussed many topics. They include flood risk, roads, rural transport and distribution networks as well as future demands in terms of the nature and  location of employment and uncertainty of retail.

As you know I  have raised these issues with you and your team concerning the whole Division and would not wish to add to that in terms of repetition but  would like to emphasise the following:

ED7 and ED8 : The rural economy is fragile and opportunities for tourism / visitors essential. As one example Heritage Open Days, a yearly festival encourages this by creative events reflecting local heritage which in turn supports local business. Paddock Wood is at the heart of a unique rural heritage and is well placed to attract visitors to the area. The Wesley Centre (built in 1888 non-designated EN7) which includes a small grassed area is well placed to support a local archive as well as events to support arts and culture. Again its land, currently used by those who use its hall, should be protected as open space and against development other than anything that would be integral to future community use of the whole site and building.

The lack of protection in terms of heritage value of traditional rural cottages as well as Victorian / Edwardian buildings, pubs and community buildings is a great concern. Protection should, I believe, be strengthened (EN6) and broadened in terms of conserving areas and preventing unnecessary demolition. Focus on listed buildings, although of great importance, should not be the only consideration for adverse impact and quality of relationships within an area.

Lucks Lane in Paddock Wood is an example of an area that would benefit from protection of what is left to reflect its special rural heritage and the same could apply to other areas that will not have the advantage of master-planning.

[TWBC: see Comment Nos. DLP_5913-5925].

DLP_7013

Turnberry for Hadlow Estate

Object

[TWBC: this comment relates to representations on AL/CA 1: Tudeley Village].

Policy ED8 - Town, Rural Service, Neighbourhood, and Village Centres Hierarchy


The objective of this policy is not clear. The purpose of the hierarchy appears to restrict the location of retail and other services, but it is not clear how that policy is to be operated. This leads to confusion, particularly as the words ‘Neighbourhood Centre’ in everyday meaning is very limited in scope and function. For example, on the basis Tudeley will grow to between 2,500-2,800 dwellings, we consider the status of the settlement to be similar to Hawkhurst (population of circa 5,000 residents) which is a Rural Service Centre. On the basis the Hadlow Estate are seeking to establish Tudeley as a genuinely mixed use community with a good range of employment opportunities, we are concerned that the hierarchy as expressed will limit the ambition to create a commercial heart that can support employment and a community of that size.

[TWBC: see full representation attached].

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

DLP_7664

Mr J Boxall

Support with conditions

I agree with this policy but the development proposed by TWBC Local Plan puts proportionately more housing into villages rather than larger towns and regional centres, especially Tunbridge Wells itself.  Sissinghurst’s proposed numbers of housing developments outweighs the size of the village and is unsustainable development. Development can only be sustainable if it is done close to existing urban sites due to lack of employment, facilities, transport and the destruction of the rural nature of the villages.

DLP_8136

Ashley Saunders

Object

I objects to this Policy and to the following paragraphs of the accompanying commentary, for the reasons stated.

Paragraph 6.479 states that “The distinctive characteristics of each centre will be promoted in the place shaping policies.

Policy ED 8 identifies Five Oak Green as a ‘Village Centre’ which falls in the hierarchy after the defined primary regional town centre (RTW), town centres, rural service centres and neighbourhood centres.

Whilst the policy recognises Five Oak Green, there is no detail how it will be promoted to ensure its long term ‘vitality and viability’. Throughout the dLP are details of improvements to other rural communities from 20mph speed zones, traffic calming measures and new facilities. There is absolutely no vision for the existing communities of Five Oak Green and Capel apart from ‘betterment’ from flood risk, which already needs addressing pre-development, and an influx of thousands of new residents and cars.

The NPPF clearly states in paras 91-92 that planning policies and decisions should “should aim to achieve healthy, inclusive and safe places” and “ensure that established shops, facilities and services are able to develop and modernise, and are retained for the benefit of the community;

The DLP does not fulfil this requirement in terms of the existing settlements within Capel Parish and is therefore unsound.

Policy ED 9: Town and Rural Service Centres

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1877

Royal Tunbridge Wells Town Forum

Support

Policy Number: ED 9 Town Service Centres 

We support this policy, particularly to prevent the over-concentration of particular uses such as fast food outlets in close proximity to one another.

DLP_3974

IDE Planning for Paddock Wood Town Council

Object

OBJECT

This proposes to move Paddock Wood out of the rural service centre bracket to be designated a Town Centre alongside Cranbrook and Southborough. Whether this policy can be accepted will depend upon what is, in turn, accepted in terms of the scale of development at Paddock Wood/east Capel, its distribution, how sustainable it would be and phasing.

DLP_4207

Tunbridge Wells District Committee Campaign to Protect Rural England

Support with conditions

CPRE supports this policy, but it may need to be qualified to take account of heritage issues in Conservation Areas

DLP_4498

Paddock Wood Neighbourhood Plan Steering Group

 

This proposes to move Paddock Wood out of the rural service centre bracket to be designated a Town Centre alongside Cranbrook and Southborough. This policy may be accepted overall – the point is made elsewhere concerning the scale of development at Paddock Wood/east Capel, its distribution, how sustainable it would be and the pace of change

The town centre does not offer sufficient facilities for the existing population, requiring people to travel out of town for most aspects of their social life.  Redevelopment of the town centre is essential prior to any further housing allocations – this is a project which cannot be delayed until the latter end of the plan period, but needs to come at the beginning.  The existing developments of 1,100 houses will put pressure on town centre facilities and should trigger the town centre development as laid out in the previous site allocations local plan.  More information is also required on the definition of a “medium sized” foodstore and where it might be located.

A master plan is proposed; development is intended to revitalise and regenerate the town. Elsewhere in the Plan, reference is made to the town centre being reconfigured and expanded but it is not apparent from the policy as drafted what is meant by this. Neither is it clear what is meant under clause ‘4’ where reference is made to residential development in the town centre as ‘contributing’ to the 4000 unit allocation. Reference is made below under ED11 on the overriding need to protect the primary shopping area as a commercial area. Also, any high density housing in the centre of Paddock Wood should not exceed the height of existing buildings in order to retain the character of the town centre.

With reference to the map on page 191, which shows the area proposed for the Town Centre, the NP Group would support the extension of the town centre to include the whole of Commercial Road to prevent the current retail premises outside the proposed Town Centre from being converted into residential /other uses.  The shops currently “outside” the designated Town Centre are an integral part of the centre of Paddock Wood.

With the planned expansion of Paddock Wood the provision of additional public car parking is essential.  The NP group supports the idea of double storey car park at the Station and that  the railway station area should be made into a transport hub. The Group supports the idea of an additional large car park north of  the railway bridge to prevent people coming to the town centre just to park.

DLP_5919

Sarah Hamilton

 

I have now seen submissions from the Parishes and Town in my Division and have just sent you a contribution from Lamberhurst residents.

As you are aware I am triple hatted (Paddock Wood East) and  have discussed my position with the TWBC Monitoring officer.

You will have received many detailed responses which I don’t need to add to. We have already discussed many topics. They include flood risk, roads, rural transport and distribution networks as well as future demands in terms of the nature and  location of employment and uncertainty of retail.

As you know I  have raised these issues with you and your team concerning the whole Division and would not wish to add to that in terms of repetition but  would like to emphasise the following:

Regarding ED9-12 I would like to suggest overall more detailed and broad analysis is required to assess future needs in a climate of changing patterns of retail and technology as well as leisure demands, transport and travel. Studies may need to be updated to ensure local knowledge and opinion is properly reflected particularly in terms of value of local facilities and assets. Potential loss of Police premises in Paddock Wood is one example where importance to the community has not been considered in any depth by engaging directly with local people who are affected.

Facilities for youth and younger generations as well as the older generations could feature more throughout the Plan I think. Although behaviour patterns and needs constantly change open space again is of particular and enduring value. Space which is safe and free to use, where people of all generations can find peace and tranquillity within a pleasant landscape.

[TWBC: see Comment Nos. DLP_5913-5925].

DLP_8402

Mr Raymond Moon

Object

Policy ED 9 OBJECT.

Defined Town and Rural Service Centres

6.484 The Town Centre of Paddock Wood. Parts of the centre of PW behind “Barsleys” has remained derelict and overgrown for many years and its redevelopment should be part of the Draft Local Plan and the Masterplan. The development of this land should be instigated by TWBC without the need for Compulsory Purchase Orders but through negotiation and goodwill with the local landowners. The pedestrianisation of the Commercial Road should be implemented as part of the redevelopment of PW Town Centre.

DLP_8419

Paddock Wood Labour Party

Object

Policy ED 9 OBJECT.

Defined Town and Rural Service Centres

6.484 The Town Centre of Paddock Wood. Parts of the centre of PW behind “Barsleys” has remained derelict and overgrown for many years and its redevelopment should be part of the Draft Local Plan and the Masterplan. The development of this land should be instigated by TWBC without the need for Compulsory Purchase Orders but through negotiation and goodwill with the local landowners. The pedestrianisation of the Commercial Road should be implemented as part of the redevelopment of PW Town Centre.

Policy ED 10: Sequential Test and Local Impact Test

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1878

Royal Tunbridge Wells Town Forum

Support

Policy Number: ED 10 Local Impact Thresholds 

We support this Policy.

DLP_3775

Martin Robeson Planning Practice for Tesco Stores Ltd

Support

Policy ED10 – Sequential and Local Impact Test (support)

Tesco has reviewed this policy and confirms its support, particularly in respect of local impact test thresholds for Royal Tunbridge Wells (1,000m2) and Paddock Wood (280m2), and for confirming that this should be applied to proposed net floorspace.

DLP_4208

Tunbridge Wells District Committee Campaign to Protect Rural England

Support

CPRE supports this policy

DLP_4304

White Young Green Planning for Standard Life Investments UK Real Estate Fund

Object

Policy ED 10 – Sequential Test and Local Impact Test

Standard Life Investments UK Real Estate Fund object to the current wording of Policy ED 10 – ‘Sequential Test and Local Impact Test’ as it fails to provide a suitably worded over-arching retail / leisure policy to direct such proposals in Tunbridge Wells Borough Council. The policy as currently drafted is fundamentally unclear and ambiguous and fails to accord with paragraph 16(d) of the NPPF.

Although it is acknowledged policy wording need not repeat national planning policy, it is suggested that in this instance, the policy wording needs to be re-drafted to more clearly and concisely accord with national policy. The policy should first support retail proposals in designated centres within the retail hierarchy and then outline the relevant retail tests/associated considerations for retail proposals in edge/out of centre locations to comply with. The policy should require retail proposals in such locations to demonstrate that:

  1. The sequential approach to site selection has been satisfied
  2. The proposal complies with national policy in respect of the assessment of retail impact for proposals of 2,500 sqm gross floorspace and above

In view of the above, the following re-worded Policy ED 10 – Sequential Test and Local Impact Test is suggested:

“Retail and leisure development should first be located within the boundaries of the centres identified in the Retail Hierarchy and on the proposals map.

Proposals for new retail and leisure development in out of centre locations will only be accepted where:

  1. the proposal is on a site allocated for that purpose; or
  2. the proposal is of a small scale and designed to serve a local need; or
  3. in all other cases, where the following sequential approach to site selection and the impact test can be demonstrated, as outlined below:

Sequential Test

i. There are no suitable sites to meet the requirements for such uses at in or edge of centre locations

Impact Test

i. For applications above 2,500 sqm gross floorspace, a Retail Imp act Assessment will be required to demonstrate that there would be no significant adverse impact on any defined centre within the Retail Hierarchy, in accordance with national planning policy.

There may be exceptional circumstances where the Local Planning Authority deem it necessary to request the assessment of the potential for impact on a town centre or rural service centre below this threshold, if there are reasonable grounds to consider that the proposals would have significant adverse impact on such centres”.

The key issues with the current wording and justification for the re-wording is outlined below:

Sequential Test –

The current ‘Sequential Test’ section is currently deemed to be unnecessarily wordy and refers to other tests under the sequential heading (e.g. point b. relates to the impact test). In view of the need to be ‘effective’ and ‘consistent with national policy’ it is deemed appropriate to consolidate this wording (as outlined above).

Local Impact Test –

Paragraph 89 of the NPPF states that; “When assessing applications for retail and leisure development outside town centres, which are not in accordance with an up-to-date plan, local planning authorities should require an impact assessment if the development is over a proportionate, locally set floorspace threshold (if there is no locally set th reshold, the default threshold is 2,500m2 of gross floorspace)”.

Paragraphs 9.50 to 9.65 of the Tunbridge Wells Borough Retail and Leisure Study (Nexus, April 2017) relate to the setting of Local Retail Impact Thresholds. It is however considered that the evidence base fails to appropriately and conclusively meet with the criteria set out at Paragraph 0151 (Town Centres and Retail chapter) of the National Planning Practice Guidance (NPPG) required to the set a local threshold. The Study nonetheless continues to advise in favour of adopting:

  • a local impact threshold of 1,000 sqm net – proposals within the catchments of Royal Tunbridge.
  • a local impact threshold of 280 sqm net for – proposals within the catchments of Southborough, Paddock Wood, Cranbrook and Hawkhurst Town Centre.

Confusingly the policy wording itself states: “3. Applications for development above the following thresholds should be accompanied by an impact assessment: a. Royal Tunbridge Wells Town Centre: 1,000 sqm (net) b. Southborough, Paddock Wood, Cranbrook and Hawkhurst: 280 sqm (net)”. Inexplicably, the Draft Local Plan presents policy wording which would, contrary to national policy, require an impact assessment for in-centre development within the above identified centres and not in out of centre locations. It is anticipated that this is an error in the wording of the policy, however there are a number of issues with the intended approach. Our principal concerns relate to (1) the methodology utilised to determine the abovementioned local thresholds and (2) the need / ability to define of a geographical catchment of a town centre when setting varying local thresholds.

Threshold

To be deemed to be appropriately ‘justified’ and ‘consistent with national policy’ the threshold proposed would need to assess reasonable scenarios and be based on a proportionate evidence base, in line with the requirements of Paragraph 015 (Town Centres and Retail chapter) of the National Planning Practice Guidance (NPPG). It is considered that the justification provided at Paragraphs 9.50 to 9.65 of the Retail and Leisure Study is inadequate and the threshold floorspace figures appear to have been arbitrarily selected, without suitable testing. The stance furthermore overlooks the fairly substantial retail capacity estimated for the Borough over the plan period (up to 2035) in the Retail and Leisure Study (Nexus, April 2017) of between 7,700 and 9,800 sqm net floorspace for convenience goods and between 25,000 and 39,200 sqm net floorspace for comparison.

The Retail and Leisure Study (Nexus, April 2017) itself confirms at paragraph 9.58: “ … taking account of the significant retail capacity in the Borough (and in particular Royal Tunbridge Wells), we would caution against imposing too low a threshold that would result in an overly onerous requirement, whereby an applicant needs to invest significant time and resource to promote relatively straightforward and uncontentious proposals”. It is argued that the proposed floorspace thresholds would, in fact, have this exact consequence, negatively impacting on investment and stifling retail and leisure growth within the Authority.

It is considered therefore that the Draft Local Plan is not ‘sound’ on the basis of its inadequately justified local impact threshold and should therefore revert back to the national default of 2,500 sqm gross.

Catchment

To ensure simplicity, clarity and transparency within this Plan, as mentioned above it is considered that a Borough wide approach of 2,500 sqm threshold should be utilised. Although the policy itself currently doesn’t refer to catchments, we would caution against merely opting to utilise the wording used in the Retail and Leisure Study “… proposals within the catchments of…” the various town centres for the following reasons.

The definition of a catchment is a subjective process and must be proportionate to the development proposed. The catchment for one form of town centre development will be quite different from another. Rather than imposing a catchment approach, the Authority has the ability to safeguard the opportunity to request an impact assessment in instances below the 2,500 sqm gross threshold, where it is deemed there is potential for the proposals to impact on a designated centre by the inclusion of the following wording:

There may be exceptional circumstances where the Local Planning Authority deem it necessary to request the assessment of the potential for impact on a town centre or rural service centre below this threshold, if there are reasonable grounds to consider that the proposals would have significant adverse impact on such centres”.

To conclude, the Draft Local Plan as currently drafted is not deemed to be ‘sound’ and therefore should be re-drafted as suggested above.

DLP_5920

Sarah Hamilton

 

I have now seen submissions from the Parishes and Town in my Division and have just sent you a contribution from Lamberhurst residents.

As you are aware I am triple hatted (Paddock Wood East) and  have discussed my position with the TWBC Monitoring officer.

You will have received many detailed responses which I don’t need to add to. We have already discussed many topics. They include flood risk, roads, rural transport and distribution networks as well as future demands in terms of the nature and  location of employment and uncertainty of retail.

As you know I  have raised these issues with you and your team concerning the whole Division and would not wish to add to that in terms of repetition but  would like to emphasise the following:

Regarding ED9-12 I would like to suggest overall more detailed and broad analysis is required to assess future needs in a climate of changing patterns of retail and technology as well as leisure demands, transport and travel. Studies may need to be updated to ensure local knowledge and opinion is properly reflected particularly in terms of value of local facilities and assets. Potential loss of Police premises in Paddock Wood is one example where importance to the community has not been considered in any depth by engaging directly with local people who are affected.

Facilities for youth and younger generations as well as the older generations could feature more throughout the Plan I think. Although behaviour patterns and needs constantly change open space again is of particular and enduring value. Space which is safe and free to use, where people of all generations can find peace and tranquillity within a pleasant landscape.

[TWBC: see Comment Nos. DLP_5913-5925].

DLP_7115

Williams Gallagher for Canada Life Ltd

 

Policy ED10 Sequential Test and Local Impact Test

The provision for impact assessment requirement should be consistent with the requirements of the NPPF para 89 which does not require impacts assessments for development  within a centre. The policy clause 3a should therefore refer only to developments above the defined and which are outside of the centre.

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

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

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

Policy ED 11: Primary Shopping Areas and retail frontages

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_764

Dr P Whitbourn

Object

Shopping areas and frontages Policy ED11 applies in Royal Tunbrudge Wells to the Primary Shopping Areas and primary retail frontages, as defined on the draft Proposals Map.

Thus the proper application of Policy ED 11 clearly depends upon the proper and consistent definition of the area and frontages on the map which, in the case of Royal Tunbridge Wells, is for the now well-established town centre, shown by a red outline on the map, and which includes the whole length of Camden Road.

Paragraph 5.10 of the Plan draws attention to the importance of Royal Tunbridge Wells Town Centre as a regional centre, and mentions specifically "specialist shopping areas such as the Pantiles, the High Street and Camden Road".

Moreover, section 6 of Policy EN8 particularly names Camden Road as one in which proposals will only be permitted where they will not result in the loss of a traditional shop front.

Practically the whole length of Camden Road, including that to the north of Garden Road, has a "primary retail frontage" notation on the the map, and it seems utterly illogical and inconsistent for that part of to the north of Garden Road not to have the hatched shopping area notation to go with the indicated retail frontage notation.

Nowhere else on the Plan is this the case, so far as I can see, although it does happen the other way round, with a so-called primary shopping area included that has no shops in it at all. An example of this is the valued town centre residential enclave of locally listed buildings in Cadogan Gardens, where there are rightly no shops, nor should there be.

Such anomalies may simply be hang-overs from a previous and outdated plan, and care needs to be taken to review and revise the shopping area notation on the map, to ensure that is is both realistic and consistent in current circumstances. Camden Road north has many specialists independent shops and services that are important to the town's distinctive offer, and it lends itself much more appropriately to inclusion within the town's shopping area than some other streets and areas that are already included.

I therefore object to the hatched defined shopping notation on the draft proposals map, as it stands, and urge that a thorough review and revision be undertaken, to ensure realism and consistency, and that the whole of Camden Road should have a shopping area notation to go with its retail frontage notation.

DLP_1879

Royal Tunbridge Wells Town Forum

Support

Policy Number: ED 11 Primary Shopping Areas 

We support this Policy and support the encouragement of conversion of first floor accommodation within primary shopping areas which is not required for retail/storage purposes to residential accommodation. Such conversions will tend to increase the vitality and night time safety of shopping areas and provide useful windfalls towards the housing targets.

DLP_3975

Ide Planning for Paddock Wood Town Council

Support

SUPPORT

Supporting text proposes a flexible approach to development within town centres and primary shopping areas against the background of the difficulties faced by the High Street. Comment should be made that every effort must be made to retain the commercial core of the town in view of recent residential development and prospective schemes, so reducing the need for residents to have to travel elsewhere for retail and complementary services and facilities.

DLP_4209

Tunbridge Wells District Committee Campaign to Protect Rural England

Support

CPRE supports this policy

DLP_4499

Paddock Wood Neighbourhood Plan Steering Group

 

This proposes to move Paddock Wood out of the rural service centre bracket to be designated a Town Centre alongside Cranbrook and Southborough. This policy may be accepted overall – the point is made elsewhere concerning the scale of development at Paddock Wood/east Capel, its distribution, how sustainable it would be and the pace of change

The town centre does not offer sufficient facilities for the existing population, requiring people to travel out of town for most aspects of their social life.  Redevelopment of the town centre is essential prior to any further housing allocations – this is a project which cannot be delayed until the latter end of the plan period, but needs to come at the beginning.  The existing developments of 1,100 houses will put pressure on town centre facilities and should trigger the town centre development as laid out in the previous site allocations local plan.  More information is also required on the definition of a “medium sized” foodstore and where it might be located.

A master plan is proposed; development is intended to revitalise and regenerate the town. Elsewhere in the Plan, reference is made to the town centre being reconfigured and expanded but it is not apparent from the policy as drafted what is meant by this. Neither is it clear what is meant under clause ‘4’ where reference is made to residential development in the town centre as ‘contributing’ to the 4000 unit allocation. Reference is made below under ED11 on the overriding need to protect the primary shopping area as a commercial area. Also, any high density housing in the centre of Paddock Wood should not exceed the height of existing buildings in order to retain the character of the town centre.

With reference to the map on page 191, which shows the area proposed for the Town Centre, the NP Group would support the extension of the town centre to include the whole of Commercial Road to prevent the current retail premises outside the proposed Town Centre from being converted into residential /other uses.  The shops currently “outside” the designated Town Centre are an integral part of the centre of Paddock Wood.

With the planned expansion of Paddock Wood the provision of additional public car parking is essential.  The NP group supports the idea of double storey car park at the Station and that  the railway station area should be made into a transport hub. The Group supports the idea of an additional large car park north of  the railway bridge to prevent people coming to the town centre just to park.

DLP_4816

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

Support

We are supportive of draft Policy ED11, as it encourages a flexible approach to ensuring the vitality of primary shopping frontages, in-line with NPPF policy. As worded, ED11 permits the provision of range of uses including A3/A4/D1/D2 and certain Sui Generis uses, alongside traditional A1 retail, within primary shopping areas and retail frontages.

This flexible approach is welcomed within the current climate of the retail market, as it affords a greater degree of flexibility in creating active frontages, through permitting a range of town centre uses. Additionally, it encourages the provision of other uses that ultimately support the function of the town centre, as A1 retail no longer functions on its own, and more experiential approaches to town centre uses are the prevailing market trend, hence the incorporation of a range of town centre uses facilitate this experiential retail environment. As such, Policy ED11 strongly accords with paragraph 85 of the NPPF, which encourages flexible town centre uses to promote their diversity and ensure their vitality.

DLP_5921

Sarah Hamilton

 

I have now seen submissions from the Parishes and Town in my Division and have just sent you a contribution from Lamberhurst residents.

As you are aware I am triple hatted (Paddock Wood East) and  have discussed my position with the TWBC Monitoring officer.

You will have received many detailed responses which I don’t need to add to. We have already discussed many topics. They include flood risk, roads, rural transport and distribution networks as well as future demands in terms of the nature and  location of employment and uncertainty of retail.

As you know I  have raised these issues with you and your team concerning the whole Division and would not wish to add to that in terms of repetition but  would like to emphasise the following:

Regarding ED9-12 I would like to suggest overall more detailed and broad analysis is required to assess future needs in a climate of changing patterns of retail and technology as well as leisure demands, transport and travel. Studies may need to be updated to ensure local knowledge and opinion is properly reflected particularly in terms of value of local facilities and assets. Potential loss of Police premises in Paddock Wood is one example where importance to the community has not been considered in any depth by engaging directly with local people who are affected.

Facilities for youth and younger generations as well as the older generations could feature more throughout the Plan I think. Although behaviour patterns and needs constantly change open space again is of particular and enduring value. Space which is safe and free to use, where people of all generations can find peace and tranquillity within a pleasant landscape.

[TWBC: see Comment Nos. DLP_5913-5925].

DLP_6289

Tunbridge Wells Constituency Labour Party

 

We welcome provisions in the plan to revitalise town centres by allowing greater concentration of residential accommodation alongside a retail offer which is protected from conversion to non-retail. We support the use of Article 4 Direction (A4D) as part of planning legislation which allows the Council to remove permitted development rights to protect and enhance the integrity of the retail offer in the Borough.

Development should be default mixed tenure with social rent and intermediate housing alongside full market priced housing. Affordable housing should not be diverted to off site locations wherever possible delivery of affordable housing provided within the same large scale developments.

DLP_7116

Williams Gallagher for Canada Life Ltd

 

Policy ED11 – Primary Shopping Areas and Retail Frontage 

The objective of retaining the retail character of primary shopping areas and retail use is recognised as are the policy provisions for non-A1 retail uses and uses within classes D1 and D2. However no provision is made in the policy, or any other policy within the plan, for the consideration of use class A5 which can help contribute to enhanced consumer choice, vitality and viability. An appropriate policy provision should be introduced.

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

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

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

Policy ED 12: Retention of local services and facilities within defined Neighbourhood and Village Centres

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1609

Maggie Fenton

 

Policy ED12 Retention of local services & & facilities within defined neighbourhood & village centres

6.500 A new Neighbourhood centre is planned as part of the proposed development at PW/including land in the East of Capel Parish

6.501 The provision of a new village centre will be made at Tudeley as part of the proposed Tudeley village

FOG is missing from this core policy. There is no detail on how TWBC intend to help retain local services and facilities.

DLP_1880

Royal Tunbridge Wells Town Forum

 

Policy Number: ED 12 Retention of Local Services

Support + General Observation

We strongly support this Policy which should help to ensure the vitality of Neighbourhood Centres within Royal Tunbridge Wells. Vibrant Neighbourhood Centres will be important in promoting active travel and reducing car journeys within the urban fabric of Royal Tunbridge Wells. We again make the case for aiming to provide primary education facilities within half a mile of target populations in densely developed parts of the town so as to eliminate car journeys for educational purposes. KCC should now face up to its responsibilities to deal effectively with the climate emergency in this respect.

DLP_2405

TWBC Property and Estates

TWBC

General Observation

Policy ED12

A marketing period of 2 years is excessive. This fetters the owners ability to move a property forward, and steralizes /blights the area.

DLP_3665

Lynne Bancroft

Support

I agree with this policy as small villages need services to remain viable and to prevent large numbers of car journeys to other towns

DLP_3714

Capel Parish Council

Object

Capel Parish Council objects to this Policy and to the following paragraphs of the accompanying commentary, for the reasons stated.

Paragraph 6.500 (p.484) states that “A new Neighbourhood Centre is planned to be designated as part of the proposed development at Paddock Wood/including on land in the east of Capel parish

Paragraph 6.501 (p.484) states that “The provision of a new Village Centre will be made at Tudeley as part of the proposed Tudeley Village

Why is Five Oak Green missing from this core policy? There is no detail on how TWBC intend to help retain local services and facilities.

DLP_4210

Tunbridge Wells District Committee Campaign to Protect Rural England

Support

CPRE strongly supports this policy, which will help to preserve the facilities and services that residents in the rural parts of the borough rely on.

DLP_5220

Culverden Residents Association

Support

Support + General Observation

We strongly support this Policy which should help to ensure the vitality of Neighbourhood Centres such as our local one at St John’s. This is important to encourage more people to walk or cycle for shopping and other services without having to travel into the town centre every day by car. “Local Services” should include local primary education sites which are realistically accessible by active travel and do not require a car journey.

DLP_5922

Sarah Hamilton

 

I have now seen submissions from the Parishes and Town in my Division and have just sent you a contribution from Lamberhurst residents.

As you are aware I am triple hatted (Paddock Wood East) and  have discussed my position with the TWBC Monitoring officer.

You will have received many detailed responses which I don’t need to add to. We have already discussed many topics. They include flood risk, roads, rural transport and distribution networks as well as future demands in terms of the nature and  location of employment and uncertainty of retail.

As you know I  have raised these issues with you and your team concerning the whole Division and would not wish to add to that in terms of repetition but  would like to emphasise the following:

Regarding ED9-12 I would like to suggest overall more detailed and broad analysis is required to assess future needs in a climate of changing patterns of retail and technology as well as leisure demands, transport and travel. Studies may need to be updated to ensure local knowledge and opinion is properly reflected particularly in terms of value of local facilities and assets. Potential loss of Police premises in Paddock Wood is one example where importance to the community has not been considered in any depth by engaging directly with local people who are affected.

Facilities for youth and younger generations as well as the older generations could feature more throughout the Plan I think. Although behaviour patterns and needs constantly change open space again is of particular and enduring value. Space which is safe and free to use, where people of all generations can find peace and tranquillity within a pleasant landscape.

[TWBC: see Comment Nos. DLP_5913-5925].

DLP_7665

Mr J Boxall

Support

I agree with this policy as small villages need services to remain viable and to prevent large numbers of car journeys to other towns

DLP_8138

Ashley Saunders

Object

I objects to this Policy and to the following paragraphs of the accompanying commentary, for the reasons stated.

Paragraph 6.500 (p.484) states that “A new Neighbourhood Centre is planned to be designated as part of the proposed development at Paddock Wood/including on land in the east of Capel parish

Paragraph 6.501 (p.484) states that “The provision of a new Village Centre will be made at Tudeley as part of the proposed Tudeley Village

Why is Five Oak Green missing from this core policy? There is no detail on how TWBC intend to help retain local services and facilities.