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Section 6: Development Management Policies - Open Space, Sport, and Recreation


This response report contains comments received on Section 6: Development Management Policies – Open Space, Sport, and Recreation.

Contents

General Comments

Comment No.

Name/Organisation

Response

DLP_6073

Mr C Mackonochie

Object

Policy Number: OSSR1 and OSSR2

Policy OSSR 1 Retention of Open Space

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_603

Sport England

Support

Policy OSSR 1

Sport England has worked with officers of the council to develop the adopted playing pitch strategy and the indoor/built sports facility needs assessment. Therefore, Sport England is very supportive of this policy.

DLP_1887

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Number: OSSR 1 Retention of Open Space 

We support this policy but would want to ensure that in weighing the benefits or dis-benefits of any proposed alternative facility, the benefit of retaining a local amenity not reliant on motorised transport for access would be given significant weight.

DLP_2926

Chris Gow

Object

Retention of Open Space

Retention of existing open space should preserve the areas of green space from development.

Surely the development of sites such as these:

Land at Culverden Stadium, Culverden Down Map 21 Policy AL/RTW 21

Land at Bayham Sports Field West Map 22 Policy AL/RTW 22

Land at Cadogan Sports Field, St John's Road Map 24 Policy AL/RTW 24

Land at Colebrook Sports Field, Liptraps Lane Map 25 Policy AL/RTW 25

Land at the Memorial Field, west of Maidstone Road Map 43 Policy AL/PW 4

Big Side Playing Field, adjacent to Quaker Lane and Waterloo Road Map 45 Policy AL/CRS 2

Jaegers Field, Angley Road Map 46 Policy AL/CRS 3

should be preserved from development…

DLP_4041

Dr P Whitbourn

Object

Thee point has been made under Policy TP4 that Tunbridge Wells Common is a percious asset that needs to be firmly and unarguably protected from any new building encroachment, and this should be clearly spelled out in a site-specific policy in the Open Space section.

Such a policy might read:

Tunbridge Wells Common is a precious asset that deserves special protection from development. Thus the general open space provisions pf Policy OSSR 1 will not apply in the particular case of Tunbridge Wells Common, and now new building encroachment on Tunbridge Wells Common will be permitted.

DLP_4217

Tunbridge Wells District Committee Campaign to Protect Rural England

Support with conditions

The mapping inaccuracies (for example the non-existent golf course at Brenchley) need to be corrected.

We also question the environmental and social sustainability  of the proposed exception for the open spaces and recreational land allocated for other purposes in the draft plan: concentrating recreational provision at Hawkenbury may bring benefits in terms of upgraded quality of provision, but it could lead to a deterioration in local quality of life and an increase in vehicular traffic, where people have to travel by car to a recreation field where previously they could walk to one.  The words “unless allocated for another purpose /use/development in this Local Plan” should be deleted.

DLP_5923

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:

OSSR1 & 2 could go further particularly where there is risk of a ‘surplus to requirements’. The assessment for that should be robust and involve local communities directly with that analysis. Evidence of proper engagement should be expected for and integral to these policies.

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

DLP_6313

Susan Heather McAuley

Support with conditions

Policy Number:  OSSR 1 Retention of Open Space

This policy is couched in urban terms.  In the countryside, the available open space is often footpaths across fields including informal ways where farmers give access across their land for limited recreational purposes including fruit-picking, dog-walking, sledging and picnicking.  Rural people do not have the luxury of parks and sports fields that are provided for town dwellers.  This policy does not reflect that difference.  Many new housing estates provide small amounts of open space for their residents but these can be designated, whether formally or not, as private and for the use of only the new residents. In the countryside where a field is lost to housing that was available for public use, no alternative is provided.  It is not possible for people to start using the next available field if that has not traditionally allowed public access.  This Policy should also account for country dwellers.

The recent building at Bramling Gardens, Sissinghurst has lost such a space to the village.  It is only because the farmer has left a strip of land (as he wants to build on other adjacent fields in the future) that villagers are able to access other areas for walking and dog-walking and general recreation.  No provision was made in the planning process to provide an alternative recreation area for the village.

DLP_7166

Kay Margaret Goodsell

Support with conditions

We are losing all our open spaces – our green fields – that is what makes open space in a village, not sports fields like you have in towns.  The green fields are all going and we have nowhere to walk.

DLP_8036

Rose May McAuley

Object

Paras 6.546-6.552

In the country our open space is being taken away by new housing estates.  These are put on the fields that children used to be able to play on and adults used for exercise and dog walking.  Tun Wells has parks and sports fields but we don’t have any.

DLP_8042

Rose May McAuley

Support with conditions

Our open space in Sissinghurst is being lost to new housing estates and we get nothing to replace it, young people get bored and we have started to get vandalism and graffiti here which we never used to get.

I used to go blackberrying with my grandmother on the field that is now Bramling Gardens Sissinghurst – what replacement area has been provided for the village?  None.

DLP_8253

Brenchley War Memorial Hall and Recreation Ground Charity

 

Thank you for the opportunity to comment on the draft Tunbridge Wells Borough Local Plan.  The Brenchley War Memorial Hall and Recreation Ground Charity would like to comment upon the proposed designation of part of its land as both a Local Green Space and an Open Space.  It would also like to make some general comments about the provision of sports, leisure and recreation facilities in Brenchley and Matfield Parish, of which it is a major provider.

The Charity’s comments on policies OSSR1, OSSR2, EN17 and STR/BM 1 are included on the following pages.

Policy OSSR1 and Policy EN17

Brenchley War Memorial and Recreation Ground Charity welcomes policies EN17 and OSSR1 in the Draft Local Plan, which propose to protect part of its land from development by designating it as both a Local Green Space and an Open Space.  The Charity provides a major contribution to the leisure and recreation facilities in the parish, with a football pitch, cricket field (also providing two junior soccer pitches and a croquet lawn), tennis courts, bowls green and squash court.  The Charity’s premises also include a village hall, meeting room (hosting the Parish Archive), snooker room, popular community café and day nursery.  The Charity’s facilities are available to a wide range of ages and interests, making an enormous contribution to the health and well-being of the community.  The cricket field has been landscaped and furnished, improving the biodiversity and creating a welcoming open space that enjoys far-reaching views across the High Weald.

Throughout the borough the towns have attracted financial support from Town and Borough councils to provide a recreation and leisure infrastructure.  In the rural parishes most facilities and activities appear to be privately funded, as is the case in Brenchley and Matfield Parish.  As a self-funding organisation, Brenchley Memorial Hall Charity has needed to develop diverse income streams to fulfil its charitable purpose of providing recreation and leisure-time occupation for the neighbourhood.

The current sports and recreation facilities should be able to meet the needs of the community for the foreseeable future. There is an increasing demand for activities based within the buildings and the Charity wishes to retain the possibility of an extension to these facilities.  There is an area of land adjacent to the squash court which cannot be used for recreational activities and is difficult to maintain.  The Charity would like to reduce the area designated as Local Green Space and Open Space in the Draft Local Plan to allow the possibility of expansion.  The proposed new boundary is shown in the plan below.  The Charity would like TWBC to consider a reduction in the area of the Charity’s land currently shown in the DLP as a Local Green Space and Open Space.

[TWBC: for map see full representation].

DLP_8366

Peter Lidstone

Support with conditions

1 OSSR 1: Retention of Open Space

An Open Space, Sport and Recreation Study (2018)(101) has been undertaken to assess the current level of open space, sport, and recreation provision within the borough.

I agree with the overall study conclusions are that the existing open space, sport, and recreation provision within the borough should be retained (unless alternative suitable provision is re-provided), quality should be improved, and provision for new facilities should be sought and supported. In the case of Cadogan Fields, I do not feel there is a need to move the facilities to a different site in accordance with the Playing Pitch Strategy because the land is used by residents and it does contribute to health and wellbeing of the children nearby. This is even more urgent as adult and children obesity is on the increase.

I agree with Policy OSSR 2 for locally accessible public space for neighbourhoods to prevent unnecessary travel by car to other sports pitches on the other side of the town.

Policy OSSR 2 The provision of publicly accessible open space and recreation

Comment No.

Name/Organisation

Object/support/support with conditions/general observation

Response

DLP_1888

Royal Tunbridge Wells Town Forum

 

Policy Number: OSSR 2 Provision of Publicly accessible Open Space

Support + General Observation

We strongly support this policy and the intention to prepare an Open Space SPD. We support the explanatory note contained in Paragraph 6.547 to the effect that additional open spaces should normally be provided within new major developments. We feel that the reference to alternative provision mentioned in Paragraph 6.548 should clarify what could be considered “conveniently and safely accessible”. Only in exceptional circumstances should an alternative open space be considered conveniently and safely accessible if it cannot be realistically accessed by active travel.

DLP_2398

TWBC Property and Estates

Support

OSSR2

It is hoped that the LPA will will be able to bring forward the Open Space SPD and its adoption at a similar time to the adoption of the Local Plan

DLP_3395

Kent County Council (Growth, Environment and Transport)

 

Public Rights of Way and Access Service

Additional wording should be included within this policy text to ensure that publicly accessibly open space and recreation opportunities are easily accessible to everyone. There should be sustainable transport connections available, so that visitors are not dependant on private vehicle use to access these sites.

To encourage active travel, there should be good walking and cycling connections with open spaces. Alternatively, good public transport links with open spaces should be made available, so that the public are not dependent on private vehicle use for visiting these sites. Development should be expected to provide or contribute towards the creation of new sustainable transport links if necessary.

Studies have shown that green spaces provide considerable health and well-being benefits for the public, but these spaces will face increasing pressures from new developments and a growing population. There is a risk that the attractive qualities of green spaces will deteriorate, unless appropriate steps are put in place to protect the sites and manage access. To cope with the increasing demands of a growing population, it is recommended that the Local Plan seeks an increase in open space provision above that currently sought.

Research has also identified a correlation between deprivation, access to greenspace and good health, where less deprived areas have good access to green space and better health. Local populations with a relatively high level of physical inactivity have limited access to natural greenspace that is ‘close to home’. The Local Plan for Tunbridge Wells should therefore aim to increase the provision of accessible green spaces and improve opportunities to access this resource in relatively deprived areas.

Kent Sport and Physical Activity

It is important to ensure that these strategies and any subsequent developments take account of the Sport England Guidance that is available as follows:

> https://www.sportengland.org/facilities-planning/planning-for-sport/playing-fields-policy/
> https://www.sportengland.org/facilities-planning/planning-for-sport/aims-and-objectives/
> https://www.sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/playing-pitch-strategy-guidance/
> https://www.sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/facilities-planning-model/
> https://www.sportengland.org/facilities-planning/active-design/

All are relevant, but of particular interest may be the final two regarding Sport England's Facilities Planning model and Active Design guidance. It is also worth raising that Government's and Sport England's strategies for sport are very much focussed on tackling inactivity and supporting/encouraging underrepresented groups to be active. Through the national Active Lives Survey, latest figures from April 2019 show that, 25.1% of people nationally are inactive. In Tunbridge Wells this figure is 18.1% and this contributes to significant impact on physical and mental health, as well as individual and social/community development. Therefore, any development needs to consider this and seek to provide a mix of formal and informal areas/spaces (indoor and out) where people can be active, including walking and cycling routes, open spaces and water based activity.

DLP_4218

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

While the proposed standards for allotments, parks and recreation grounds, and play spaces may be suitable for large and urban developments, they are inadequate for villages and the rural area, where residents of new developments of up to 49 dwellings may have no access to such facilities within walking distance. For development in the villages to be sustainable, a contribution (preferably provision of land or else a financial contribution to the provision of these facilities within the village) needs to be required for all developments of more than 10 dwellings, unless they are for housing for elderly people.

DLP_4380

British Horse Society

General Observation

This should include provision of equestrian facilities and routes.

DLP_4719

CBRE Ltd for Dandara Ltd

Support with conditions

Dandara Comment 

Dandara support the policy and that the standard requirements are set out clearly however there needs to be flexibility in the policy wording, to ensure that development is not unduly restricted.

Suggested Policy Amendment(s) 

No revised wording proposed.

DLP_5924

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:

OSSR1 & 2 could go further particularly where there is risk of a ‘surplus to requirements’. The assessment for that should be robust and involve local communities directly with that analysis. Evidence of proper engagement should be expected for and integral to these policies.

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

DLP_6286

Susan Heather McAuley

Object

Provision of publicly accessible open space  Policy OSSR 1 and Paras 6.546-6.552

This policy is couched in urban terms.  In the countryside, the available open space is often footpaths across fields including informal ways where farmers give access across their land for limited recreational purposes including fruit-picking, dog-walking, sledging and picnicking.  Rural people do not have the luxury of parks and sports fields that are provided for town dwellers.  This policy does not reflect that difference.

Many new housing estates provide small amounts of open space for their residents but these can be designated, whether formally or not, as private and for the use of only the new residents.  In the countryside where a field is lost to housing that was available for public use, no alternative is provided.  It is not possible for people to start using the next available field if that has not traditionally allowed public access.  This Policy should also account for country dwellers.

The recent building at Bramling Gardens, Sissinghurst has resulted in the loss of such a space to the village. It is only because the farmer has left a strip of land (as he wants to build on other adjacent fields in the future) that villagers are able to access other areas for walking and dog-walking and general recreation.  No provision was made in the planning process to provide an alternative recreation area for the village. I doubt the planners even realised this loss would happen.

DLP_6295

Tunbridge Wells Constituency Labour Party

 

We are supportive of the provision of new sport and recreation facilities. There are however concerns with the Hawkenbury sports hub. It is a provision for many people over a wide area and is not located in an area with good public transport provision for residents it will serve.   It is contrary to other local plan principles in seeking to promote the use of sustainable transport options.

DLP_6937

Barton Willmore for Crest Nicholson

General Observation

7.42 Policy OSSR2 sets the requirement for open space in new developments, requiring minimum provision but also including some flexibility to take into account local circumstances, this accords with the NPPF (paras 95-101). We note that the Tunbridge Wells Borough Council Open Space Study published in June 2018 indicates that Paddock Wood is currently well served by a mix of outdoor open space with the exception of youth play provision.

[TWBC: see full representation and supporting documents Appendix 1, Appendix 2 Part 1 , Appendix 2 Part 2 and Appendix 3]. See also Comment Numbers DLP_6836, 6844, 6847, 6843, 6855, 6859, 6860, 6863, 6865, 6866, 6869-6870, 6872, 6877, 6883, 6890, 6897, 6909-6911, 6926, 6928, 6931, 6933-6937].

DLP_7088

Brown & Co Planning Ltd for The Hendy Group

Object

Policy Number: Policy OSSR 2 - The provision of publicly accessible open space and recreation

Comments; Object

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

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

1.109 The wording of this policy risk overburdening development which will impact the viability of delivering the allocations in the local plan.

1.110 Our Client recognises that some form of green space should be provided with developments, however, there is a limit to what can be realistically and viably provided on some urban sites.

UNSOUND: This policy is not positively prepared or effective and should be reworded in order not to prejudice the delivery of allocated sites.

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

DLP_8254

Brenchley War Memorial Hall and Recreation Ground Charity

 

Policy OSSR2

In 2011 the population of the parish was 2863 in 1164 households, with approximately half of the population dispersed in the rural areas outside the main settlements of Brenchley and Matfield.  The Fields in Trust publication ‘Beyond the Six Acre Standard’ (October 2016) recommends the following guidelines for formal outdoor space: 1.6 hectares of all outdoor space; 1.2 hectares of  pitches; 0.3 hectares of Multi-use Game Area (MUGA) or Skateboard park.; 0.25 hectares of equipped or designated play areas.

In line with these guidelines the minimum areas in Brenchley and Matfield Parish should be: 4.58 hectares of outdoor space; 3.44 hectares of pitches; 0.86 hectares of MUGA; 0.72 hectares of play area. With around half of the outdoor space being provided by Brenchley Memorial Hall Charity and with additional space in other areas, mostly owned by Brenchley Parish Council, the parish appears to have sufficient outdoor space.  However, there is only one equipped playground in the parish, at Brenchley Recreation Ground, with a small area of 0.026 hectares.  The Parish is highly deficient in play areas and equipped play spaces, which was highlighted in the Core Strategy documents in 2006.

Policy OSSR2 deals with the provision of publicly accessible open space and recreation provision for new housing sites. The Open Spaces Society ‘believes strongly in the value of open spaces, however small, close to where people live, for quiet relaxation and refreshment, health and well-being’.

[TWBC: for Table 2 see full representation attached].

Fields in Trust guidelines recommend the following: new developments of greater than 5 dwellings should provide a Local Area for Play (LAP); developments of 10 to 200 dwellings should provide a LAP, a Locally Equipped Area of Play (LEAP) and a contribution towards a MUGA. In contrast, the Draft Local Plan makes no on-site provision for developments less than 20 dwellings and only an Amenity/Natural green space on-site for developments of 20-49 dwellings.  For 50 – 99 dwellings the DLP only requires an on-site Amenity/Green space and a play space for children. Play areas for young children should be in close proximity to homes and the DLP requirements are well below the recommendations of Fields in Trust for on-site provision in new housing developments.

DLP_8367

Peter Lidstone

Support with conditions

1 OSSR 1: Retention of Open Space

An Open Space, Sport and Recreation Study (2018)(101) has been undertaken to assess the current level of open space, sport, and recreation provision within the borough.

I agree with the overall study conclusions are that the existing open space, sport, and recreation provision within the borough should be retained (unless alternative suitable provision is re-provided), quality should be improved, and provision for new facilities should be sought and supported. In the case of Cadogan Fields, I do not feel there is a need to move the facilities to a different site in accordance with the Playing Pitch Strategy because the land is used by residents and it does contribute to health and wellbeing of the children nearby. This is even more urgent as adult and children obesity is on the increase.

I agree with Policy OSSR 2 for locally accessible public space for neighbourhoods to prevent unnecessary travel by car to other sports pitches on the other side of the town.