Appendix 5: Topic papers and other supporting documents
This response report contains comments received on Appendix 5: Topic papers and other supporting documents.
Contents
General
Comment No. | Name/Organisation | Response |
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DLP_7959 | Wendy Owen | The list of Topic Papers and supporting documents does not match the documents available via the link – there are vastly more than are listed, i.e. 9 Housing documents, 6 Employment/leisure/retail documents, 15 Environment/landscape, 9 Transport/infrastructure. |
DLP_442 | Don Kent | All my supporting paper documents will be presented at planning application stage and at the next time to comment which I believe is August 2020. |
DLP_4315 | White Young Green Planning for Standard Life Investments UK Real Estate Fund | See comments on:
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DLP_4650 | Ann & John Furminger | There are a number of items that have not been consulted on with the local NDP group eg community centre and use of library site, amalgamation of GP practices etc |
DLP_6076 | Mr C Mackonochie | Borough of Royal Tunbridge Wells Revised Kent HLC (2000) Parish of Capel' I am surprised that the paper ‘Borough of Royal Tunbridge Wells Revised Kent HLC (2000) Parish of Capel dated October 2016 has not been used as a supporting documents – this may omission may explain various omissions concerning the historic legacy of Capel Parish |
Distribution of Development Topic Paper
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_8214 | Mrs Suzi Rich | Topic Paper or supporting document title:· Distribution of Development Topic Paper· Green Belt Study· Infrastructure Delivery Plan· Transport Strategy Review: Context and Way Forward including Appendix C: Local Plan Transport Assessment Report 2019 (prepared by Sweco) Comments on the Distribution of Development Topic Paper Chapter 3: Development Constraints (p.4) Chapter 5: Issues and Options consultation (p.11) Paragraph 5.6 summarises the main outcomes of the consultation for the question relating to the five strategic options for delivery presented in the Issues and Options document. Only 18% ranked Option 5 (new freestanding settlement) as their most preferred approach. It is submitted that this would have been even less if the site/sites now proposed at AL/CA 1 and AL/CA 3 & AL/PW 1 had been identified at that time. Appendix 1 to The Issues and Options Consultation Statement, available on the Tunbridge Wells Borough Council website at https://beta.tunbridgewells.gov.uk/local-plan/issues-and-options, lists the Strategy Considerations at Section 5 (p.26-39). It is clear from p.33, that by far the largest level of support was 60% for Option 4 (Growth Corridor led approach). However, p.39 of the same document states that “A level of support was indicated in the Issues and Options responses for a new settlement.” This is misleading. The Consultation Statement goes on to consider the responses to question 10 and 10a relating to preferences for a combination of Options (p.35). The first bullet point states that the responses indicate that it is worth “Exploring further the potential for ‘new settlement growth’, as this was the most commonly preferred (alone or in combination) of all the options”. The statement is blatantly not true! Paragraphs 5.7-5.8 cover question 11/11a, which asked for views about the possibility of a new settlement somewhere in the borough and suggestions for possible locations. It lists the key issues referred to across the response groups, which include:
These views have been completely ignored by TWBC! They should carry weight and should have informed the decision on the strategic site proposals. Paragraphs 5.9-5.10 cover question 12/12a, which asked whether all reasonable options for accommodating future development growth within the borough have been considered and identified and if not, what other options should be considered. Respondents suggested that the following options should be considered:
Where have these responses been acknowledged in the dLP? Have these options been considered at all? Chapter 6: Formulating the development strategy (p.14) Paragraph 6.2 states “For the second Call for Sites, officers contacted the promotors of sites submitted to the first Call for Sites and identified and then contacted owners of land around settlements (on a ‘without prejudice’ basis) that had not been submitted through the first Call for Sites to enable them to submit sites if they wished. This proactive approach encouraged owners of land that could be suitable for development to submit sites for consideration”. Why were we told by Stephen Baughan at the Capel Annual Parish Meeting that TWBC had no influence on what sites were submitted and that the officers just had to work with what appeared in the Call for Sites! Paragraph 6.2 also expressly states that the second 'Call for Sites' was undertaken between May and June 2017. In the Interim New Local Plan Strategic Housing & Economic Land Availability Assessment 2017. It was stated “although the call for sites remains open, it will no longer be possible to include any new sites within the site assessment process that is informing the Draft Local Plan (being prepared under Regulation 18) AS THERE IS INSUFFICIENT TIME TO ADEQUATELY ASSESS SUCH SITES. (TWBC will continue to accept in order that they may be assessed & potentially included at Reg 19)”. The evidence base persuaded TWBC to opt for Growth Strategy Option 3 (existing urban distribution plus villages) and Option 4 (A21 growth corridor). There was a possibility of Option 5 (new settlement) in the longer term (8 possible sites but 5 not shortlisted including AL/ CA 1). Presumably this underwent a robust process based on robust evidence? This was still the preferred stance March 2018, however in April 2018, there appeared to be a complete change of direction which resulted in the allocation of 60% of the proposed development in the Parish of Capel. Where in the DLP is this new evidence base? When was site 448 (Land at Tudeley) first considered (p.24-30)? Table 2 details TWBC’s Conclusions of the SHELAA and SA on garden settlement options but gives no credible explanation as to why the Tudeley site is considered to be ‘well located’ as required by para 72 of the NPPF. Neither does Table 3 which details the outcome of TWBC’s Consideration of proposed strategic allocation sites against para 72 of the NPPF. This table is misleading and inaccurate. The site is NOT well located. Comments on the Green Belt Study The site at Tudeley (AL/CA 1) falls within Broad Areas BA3 and BA4. The ‘Potential Level of Harm to the Green Belt Associated with Release of Broad Areas BA3 and BA4 is ‘VERY HIGH’ (Figure 1.1 (p.8)) Comments on the Infrastructure Delivery Plan Education Health Under the heading ‘Additional future requirements needed to deliver growth proposed in the Draft Local Plan’ at paragraph 3.104 (p.40) it states that “The Council has not been made aware of any specific requirements over the plan period; however, discussions with the Maidstone and Tunbridge Wells NHS Trust have highlighted potential need for extension of either the Tunbridge Wells Hospital or Maidstone Hospital to serve the West Kent Area over the Plan period” Please also see my comments in COMMENT BOX 2 under the heading ‘Strategic Objective 5: Essential Infrastructure and Connectivity’ Comments on the SWECO Local Plan Transport Evidence Base Figure 9-2 shows the ‘Mitigation Interventions Mapped’ (p.142) which shows the proposed routes for the following ‘highway measures’ detailed in Table 9-2 (p.138): It is suggested building the Colts Hill strategic link is vital to delivery of the proposed new developments in Capel. How will this improve connectivity? It will be a faster, polluting road to nowhere unless the congestion on the A264 and the two roundabouts at Pembury can be dealt with (there are no proposals to do so in the dLP and the Hendys development will make this worse). Traffic to the A21 from Paddock Wood will continue to use the B2017. The A228 strategic link has been mooted for the last forty years, initially as a requirement due to the Channel Tunnel! The whole area surrounding Paddock Wood needs a radical holistic solution. The dualling of the A21 was supposedly going to reduce traffic in this area but as TMBC have discovered, through traffic has actually increased in volume in Tonbridge since the “improvement” [TWBC: See comments DLP_8189-8214 for full representation] |
DLP_2490 | Mr John Wotton | The proposed distribution of development appears to have been more led by slavish adherence to Government housing targets, a wish to justify building some new roads that have long been desired by KCC and TWBC, and the easy option of dealing with a single willing landowner in the Southborough/Capel area, than by objective assessment of where development should take place. The weighting to be given to particular considerations is not always clear; in several cases it appears inconsistent and judgments appear subjective. Most importantly, in order to give proper regard to paragraph 172 of the NPPF, the impacts on the AONB of TWBC’s policies and allocations need to be assessed using the adopted statutory AONB Management Plan 2019. This paper fails to do so. The paper quotes (at 6.80) Paragraph ID: 8-041-20190721 PPG, which states, “[NPPF} policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas”. I agree, but the Council seems not to have taken this possibility into account in the draft Plan. I agree with the Council, at 6.89, that the High Weald AONB could not be a suitable location for strategic growth, such as a new or significantly expanded settlement. However, the expansion proposed for Cranbrook & Sissinghurst and Hawkhurst can only be described as “significant”. 6.96 et seq set out the Council’s approach to the tests of exceptional circumstances and the public interest in relation to major development in the AONB. There are in my view important errors in the Council’s approach, which undermine the basis of the allocations for major development within the AONB contained in the Plan and form part of the basis for my objection to certain of these allocations, set out elsewhere in my response. 6.100 states that the particular circumstances of the individual proposals are critical, but in the SHELAA, there is very little of substance on this subject. 6.101 sets out a set of considerations which apply to Tunbridge Wells Borough, but they cannot be regarded as “exceptional”. The Borough is by no means unusual in having a high proportion of its land area comprised of protected landscapes and this is an immutable and enduring aspect of the Borough’s geography, not an exceptional circumstance. Meeting the need for affordable housing for local residents in the Borough is, we accept, in the public interest, but not a consideration that points towards exceptional circumstances, justifying major housing development in the AONB. To the extent that there is a housing shortage in the Borough, this is an ongoing situation which affects the whole country, most acutely the South East region, which has persisted through several reiterations of the NPPF. It is not peculiar to Tunbridge Wells or in any way exceptional. The assertion of insufficient opportunities to meet housing need elsewhere in the Borough must been seen in the context of unprecedentedly high allocations in this Plan outside the AONB. The discussion of factors relating to the housing market, growth and economic vitality are of general application and in no way indicative of exceptional circumstances. The extensive discussion of the exhaustion of opportunities for development outside the AONB merely demonstrates that Tunbridge Wells is a case in which it is not possible to meet the OAN, in accordance with the passage from the PPG, quoted above. Consideration of the opportunities to moderate the detrimental effect of major development in the AONB is something that can properly be considered only in relation to particular sites and proposals, not in general. In conclusion, I do not consider that the analysis in this Topic Paper provides support for the satisfaction of the paragraph 172 NPPF test for major development in the High Weald AONB in this Borough. |
DLP_6638 | Isla Tompsett | TWBC: the following comment was submitted by the list of responders on the left: Planning Strategy |
DLP_3950 | Mrs June Bell | Topic Paper title: Distribution of Development page 7 Areas of flood risk Reason for comment: |
DLP_3948 | Mrs June Bell | Topic Paper title: Distribution of Development page 12 Reason for comment: |
DLP_7960 | Wendy Owen | Sections 4.8-4.11: these identify a need for many thousands of square metres of additional retail floor space. This number should be reduced to take account of the many empty retail units in the town centre. This would release more land to housing, saving more sensitive sites which are currently identified for potential development. Section 6F, table 6.62: notwithstanding our fundamental objection to releasing AL/RTW 18 / site 137 from the Green Belt, the mitigation should include buffering to the south (not north) in order to strengthen the boundary with the Green Belt and the Wealden border. Section 6I: please refer to our comments in respect of the transport and infrastructure issues relating to AL/RTW 18 / site 137. Section 6J: please refer to our comments in respect of the sustainability appraisal issues relating to AL/RTW 18 / site 137. Appendix 1: AL/RTW 18 / site 137: we consider the contribution to purpose 3 – encroachment, and purpose 4 – settings/character/historic towns, should both be rated as ‘strong’, and buffering should be changed as per our comment above. Appendix 3: AL/RTW 18 / site 137: we consider the setting of the AONB part of the site is poorly related to the urban settlement. It should also be noted part of a Scheduled Monument is in the site. We also dispute that this is the only site suitable for a new secondary school in this part of the borough, having already identified at least one other available site which is not in the AONB. For these reasons, and the sites we have identified that are not in the AONB, we do not consider the Plan demonstrates that “great weight” has been placed on protecting the AONB (or Green Belt) and consequently the case for exceptional circumstances is not made. |
DLP_8149 | Ashley Saunders |
These views have been completely ignored by TWBC! They should carry weight and should have informed the decision on the proposals for Capel Parish. Suggestions for a possible location for a new settlement included many different locations within the borough, some based on existing transport links and good access to other infrastructure. NOT ONE suggested a site in the Green Belt away from existing development and infrastructure.
I considers that, without a Garden Village and/or New Settlement Feasibility Study, the proposal for two large developments modeled on those principles is unsound. There is no evidence base that either of the sites is sustainable. It would appear that TWBC has taken shortcuts and easy options to produce this dLP thereby making it unsound. |
DLP_569 | Lee Prebble | Introduction I am not a resident of Tunbridge Wells Borough but live near to the Borough boundary with Tonbridge. I do visit the Borough on a regular basis and enjoy the significant benefits of the countryside and Green Belt that should both be protected and enhanced as required by National Planning Policy. The Draft Local Plan documents produced are vast and complex. As an individual I do not have the time and resources to examine each and every part and policy in detail. I have, therefore, concentrated on consideration of two particular aspects of the Draft Plan that concern me most (the proposed development at Tudeley and the proposed secondary school on land in west Capel). That is not to say that I support other policies in any way. Indeed, I am aware of some of the concerns of others and agree with many of them. I may also add that I am a retired member of the Royal Town Planning Institute and have some considerable experience of the production of local plans. I have to say that I would not be at all happy to put documents like these to the public. In essence, I consider the approach has been shoddy and the output both dubious and faulty in many respects. I would go so far as to say I would be ashamed to have these as part of my legacy. My comments are in relation to three documents: the Distribution of Development Topic Paper; the Sustainability Appraisal and the Draft Local Plan. Distribution of Development Topic Paper
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DLP_3727 | Capel Parish Council |
These views have been completely ignored by TWBC! They should carry weight and should have informed the decision on the proposals for Capel Parish. Suggestions for a possible location for a new settlement included many different locations within the borough, some based on existing transport links and good access to other infrastructure. NOT ONE suggested a site in the Green Belt away from existing development and infrastructure.
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DLP_3826 | Government Team | As acknowledged in the topic paper, some 70% of Tunbridge Wells Borough lies within the High Weald AONB. Considering the level of protection afforded to the AONB, there are particular challenges for plan making where a protected landscape forms a large proportion of a plan area. Nevertheless, the AONB must still be protected and enhanced. We agree that sensitively designed development need not be ruled out within the AONB (3.11) however any development proposed in the AONB needs to be limited in scale. Natural England does not support the principle of major development within the AONB. Whilst we generally agree with the approach to identifying major development sites as provided in Appendix 2 of the Topic Paper, we consider this approach as a tool for the identification of such sites. The approach does not indicate that a site is appropriate for development with regards to both local and national policy regarding development within protected landscapes. Section 6.13 indicates the overall strategy for the pattern and scale of development proposed in this plan. We agree that development potential should be maximised outside of the AONB, and a robust evidence base should support this approach. We refer to NPPF para 11, which states that protected areas including AONBs provide a strong reason for restricting the overall scale, type or distribution of development in the plan area. With reference to approach 6, all development needs to be considered against national policy, and this should include strategic and non-strategic development. We welcome the Council’s views that development with a significant impact on the AONB is unlikely to be supported (6.85) and that the AONB is not a suitable location for strategic growth (6.89). Given these views, we are therefore very concerned that the development strategy for this plan includes 17 allocation sites considered by the Council to be major development. Natural England considers that the proposed distribution of development, namely the quantum of development within the AONB is not a sustainable solution, and does not align with national planning policy affording the highest level of protection to designated landscapes, nor the aims of the High Weald Management Plan, to which your authority is a signatory. We therefore do not agree with the summary finding that the plan is proposing ‘ as much development as could be sustainably accommodated’; the amount of development proposed within and in the setting the AONB is not considered sustainable due to the significant landscape impacts and harm to the purposes of designation of the AONB. At this stage Natural England’s comments on individual allocations are limited by the information currently available (See Appendix 3). We welcome the commitment to provide detailed landscape and visual impact appraisals for the proposed major development sites in the AONB prior to the Regulation 19 consultation. Following submission of this information we will be able to provide further advice on individual allocation sites. |
DLP_3512 | High Weald AONB Unit | Paragraph 172 of the NPPF requires that “great weight’ be given to conserving and enhancing the landscape and scenic beauty” in AONBs, “which have ‘the highest status of protection in relation to these issues”. In order for great weight to be given, the impacts of TWBC’s policies on the AONB need to be properly assessed using the statutory AONB Management Plan.
AONB and major development (Appendices 2 and 3) We welcome TWBC setting out the principles (Appendix 2) relating to the definition of major development in the AONB as required by Footnote 55, however, the method for assessing factors, particularly ‘AONB impact’, is muddled and unclear. In our view the assessment of adverse impact should not take into account policy compliant development. Policy compliance is dependent upon a number of factors in the future, negative impact will be immediate and in many case irreversible. The example given, that the negative effects of development on ancient woodland can be largely avoided by a buffer and woodland management is not supported by evidence 8 [https://www.woodlandtrust.org.uk/media/43620/impacts-of-nearby-development-on-theecology-of-ancient-woodland.pdf]. The table setting out the criteria for High, Medium and Low impact (para.21, p.83) demonstrates a fundamental misunderstanding of the AONB Management Plan. Impact on the AONB is not a simple numbers game. The natural beauty of the AONB is a compilation of the core components at a landscape scale. The number of core components on any one site within that landscape is dependent upon location, geography and scale. Destruction of a single component may impact on the coherence of the whole. We question why the AONB Unit, who are funded by TWBC to provide expert advice on the AONB were not consulted on the method of AONB impact assessment (Appendix 2), or the assessments themselves (Appendix 3). The first we have seen of it has been the public consultation. In our view many of the impact assessments made are inconsistent and not justifiable. It is recommended that the justification for major development in the AONB is separated out from assessment of whether sites should be considered major or not. Notwithstanding this the High Weald AONB Unit does not agree that the levels of development proposed within the AONB or the major development sites allocated have been justified under paragraph 172 of the NPPF. As stated above, Appendix B should confine itself to matters which relate to whether development is major or not according to the NPPF definition and should not stray into possible mitigation measures, justification for the development in economic terms or make spurious claims of AONB ‘opportunities’ or ‘benefits’, none of which are properly evidenced. Subjective judgements of landscape quality should also not be used to justify enhancements claimed by the development. For example development of 270 dwellings and a school at Spratsbrook (RTW18, Site 137) suggests that the site has a ‘poor edge to settlement’ and a ‘strong landscape structure of containment’ and that through the development the landscape can be ‘reinforced’ and provide a ‘strong edge to settlement’. These are opinions about aspects of visual experience which are not relevant to impact on the AONB. Impact on the AONB should be judged against the Statement of Significance and supporting chapters set out in the AONB Management Plan. We have the following site specific comments: RTW12 – Land adjacent to Longfield Road – agree that this is major development |
DLP_2790 | Mrs Karen Langston | With specific reference to appendix 2 and appendix 3, I challenge the assessment of two of the four allocated sites in Matfield as to whether or not development on them would be considered ‘major’. Currently, only AL/BM 1 is assessed as ‘major’. I strongly argue that sites AL/BM 2 and AL/BM 3 should also be ‘major’ in AONB terms. The relative scale of BM 2 is ‘substantial’, therefore, according to the banding used for assessment, development on the site is, “Very likely to be ‘major’ unless other factors more favourable.” The relative scale of BM 3 is ‘very substantial’, meaning that development on the site is “almost certainly going to be ‘major’.” (Distribution of Development Topic Paper, Appendix 2, paragraph 11) Due to the sensitive location of BM 2, which lies within the AONB, adjacent to a Conservation Area, associated with a Listed Building and local heritage asset and outside of the existing LBD, I argue that the setting and adverse impact on the AONB should also play a significant role in the determination of the site, as per NPPF footnote 55. These factors, coupled with the ‘substantial’ relative scale of any development should warrant a determination of ‘major’. Site BM 3 is within the AONB, outside the existing LBD, adjacent to ancient woodland, on undeveloped BMV agricultural land with economic and other benefits that the NPPF “expects local planning authorities to take into account.” (Draft Local Plan, paragraph 6.227) Considering the relative scale of development on this site would be ‘very substantial’ and, accordingly, it would “almost certainly” be determined as major, I strongly argue that its assessment should be reviewed and a designation of ‘major’ be considered. |
DLP_1631 | Maggie Fenton | Distribution of Development Topic Paper for Draft Local Plan
These views have been completely ignored but should and must carry weight
Level of growth to be delivered by Local Plan questioned ·
3.Overall focus on sustainable locations & focus on the A21 corridor. One again these view have not been considered
Expected share % of preferred growth Strategy:
Core Strategy
Strategy Options presented in Issues / Options consultation document Option 1: Focused growth - as per existing strategy Villages with growth exceeding 150 dwellings over the Plan Period
Further assessment will filter out more sites - there will be a reduced number of sites to deliver the growth Despite the above evidence base & the assertion “there will be a reduced number of sites to deliver growth” and a preferred strategy of Option 3 & 4, why was there then a move in April 2019 to Growth Strategy Option 5 & the inclusion of two extra enormous sites, resulting in Capel Parish being allocated 60% of the supposed housing need?? 440 houses for Five Oak Green was an unsustainable option too not least given the lack of facilities in the village. KCC Highways appear to understand this although TWBC do not. The application by TWBC Estates for 16 houses (including affordable homes) at Sychem place TW/18/03797/OUT was strongly objected to by Highways (disappointingly TWBC decided to then reduce the number of dwellings to five large executive homes, which was approved, which if built will remain unsold!) “The highway authority has previously advised the LPA that the site is considered unsuitable for development as part of a plan lead approach due to a lack of key facilities in the village which will result in car borne trips’. |
DLP_4222 | Tunbridge Wells District Committee Campaign to Protect Rural England | In general we are impressed by the great efforts that have clearly been made to gather all the relevant evidence, during a time when the Government kept moving the goalposts. Most comments that we make relating to the topic papers and other supporting documents are made in our comments on policies. However, we make the following additional comments: Distribution of Development Topic Paper The proposed distribution of development appears to us to have been more led by slavish adherence to Government housing targets, a wish to justify building some new roads that have long been desired by KCC and TWBC, and the easy option of dealing with a single willing landowner in the Southborough/Capel area, than by objective assessment of where development should take place. The weighting to be given to particular considerations is not always clear; in several cases it appears inconsistent and judgments appear subjective. Most importantly, in order to give proper regard to paragraph 172 of the NPPF, the impacts on the AONB of TWBC’s policies and allocations need to be assessed using the adopted statutory AONB Management Plan 2019. This paper fails to do so. The paper quotes (at 6.80) Paragraph ID: 8-041-20190721 PPG, which states, “[NPPF} policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas”. We agree, but the Council seems not to have taken this possibility into account in the draft Plan. We agree with the Council, at 6.89, that the High Weald AONB could not be a suitable location for strategic growth, such as a new or significantly expanded settlement. However, the expansion proposed for Cranbrook & Sissinghurst and Hawkhurst can only be described as “significant”. 6.96 et seq set out the Council’s approach to the tests of exceptional circumstances and the public interest in relation to major development in the AONB. There are in our view important errors in the Council’s approach, which undermine the basis of the allocations for major development within the AONB contained in the Plan and form part of the basis for our objection to many of these allocations, set out elsewhere in our response. 6.100 states that the particular circumstances of the individual proposals are critical, but in the SHELAA, there is very little of substance on this subject. 6.101 sets out a set of considerations which apply to Tunbridge Wells Borough, but they cannot be regarded as “exceptional”. The Borough is by no means unusual in having a high proportion of its land area comprised of protected landscapes and this in an immutable and enduring aspect of the borough’s geography, not an exceptional circumstance. Meeting the need for affordable housing for local residents in the Borough is, we accept, in the public interest, but not a consideration that points towards exceptional circumstances, justifying major housing development in the AONB. To the extent that there is a housing shortage in the borough, this is an ongoing situation which affects the whole country, most acutely the South East region, which has persisted through several reiterations of the NPPF. It is not peculiar to Tunbridge Wells or in any way exceptional. The assertion of insufficient opportunities to meet housing need elsewhere in the Borough must been seen in the context of unprecedentedly high allocations in this Plan outside the AONB. The discussion of factors relating to the housing market, growth and economic vitality are of general application and in no way indicative of exceptional circumstances. The extensive discussion of the exhaustion of opportunities for development outside the AONB merely demonstrates that Tunbridge Wells is a case in which it is not possible to meet the OAN, in accordance with the passage from the PPG, quoted above. Consideration of the opportunities to moderate the detrimental effect of major development in the AONB is something that can properly be considered only in relation to particular sites and proposals, not in general. In conclusion, we do not consider that the analysis in this Topic Paper provides support for the satisfaction of the paragraph 172 NPPF test for major development in the High Weald AONB. |
DLP_4668DLP_4674 | Mandy CornickSue Ashe | TWBC: the following comment was submitted by the responders on the left: Proposed Development of 30 houses at Misty Meadow Farm, Furnace Lane, Lamberhurst I write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site at Misty Meadow Farm on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2). Planning Strategy
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
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DLP_6457 | Cranbrook & Sissinghurst Parish Council |
The Parish Council firmly believe that the distribution of development assumptions that underpin the draft TWBC Local Plan strategy are wrong, as follows:
Given the lack of support for the distribution approach at the previous stage of the local plan preparation, how can TWBC continue with this strategy at Reg 18 stage? para. 6.7 and 6.9 This background paper sets a threshold of 10 minimum for site allocations but why was the threshold set so high? A typical threshold for minimum units is just 5 or 6 homes, allowing smaller sites to be considered. This is in line with NPPF para. 68 that states that small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built-out relatively quickly. Why has TWBC taken a different approach? The SHEELA contains many sites of this scale across the Borough that have not been allocated because of the artificially high threshold imposed by the draft TWBC LP. Smaller sites can often be built out quicker than large sites and can be delivered by non-mainstream developers e.g. CLT, housing cooperatives and so on. Setting a high threshold will tend to rule these organisations out of the picture, thereby concentrating risk on a few larger players, rather than spreading risk more widely. Neighbourhood plans tends to favour a strategy based around smaller sites, more widely distributed. This threshold also undermines neighbourhood planning. Smaller sites also allow for smaller developments that give a greater opportunity to build more sustainably and of better quality than 'mass produced' developments. Cranbrook and Hawkhurst together (both in the AONB completely) are taking the same numbers as Tunbridge Wells and Southborough combined (not in the AONB) – this cannot be right when considered against:
p.33 footnote 19 We consider this to be a major error on the part of TWBC as it has defined the “urban area” for planning purposes as the main urban area of Royal Tunbridge Wells and Southborough, together with the larger rural settlements of Paddock Wood, Cranbrook, and Hawkhurst. How can it be that smaller settlements of Cranbrook and Hawkhurst, both deep within the AONB, can be given the same urban status as Royal Tunbridge Wells and Southborough? This is critical because the definition of “urban area” then leads directly to a strategy that maximises development within existing built up areas and optimised densities. While this strategy of maximisation and optimal density may be appropriate in genuine urban areas such as Royal Tunbridge Wells, it cannot be considered appropriate for rural communities in nationally protected landscape areas. It is from this mistaken assumption that much disturbing content of the draft TWBC LP follows. Correct this assumption (i.e. Cranbrook and Hawkhurst will not be subject to the maximisation strategy) and a whole different approach is possible. [TWBC: see full response]. |
DLP_6425 | Hawkhurst Parish Council | Response to the “Distribution of Development” Topic Paper for Draft TWBC Local Plan The Parish Council firmly believe that the distribution of development assumptions that underpin the draft TWBC Local Plan strategy are wrong, as follows: Hawkhurst is a village, not an urban area. Not only is Hawkhurst a village, but a village in the AONB, a nationally protected landscape area. Cranbrook and Hawkhurst together (both in the AONB) are taking the same numbers as Royal Tunbridge Wells and Southborough combined– this cannot be right when considered against:
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DLP_7233 | DHA Planning for Notcutt Nurseries Ltd | Distribution of Development Topic Paper The purpose of the Distribution of Development Topic Paper (herein ‘the Topic Paper’ or ‘the Paper’) is to explain the background to the proposed Development Strategy. This includes the consideration of development potential in the Green Belt (Chapter 6(F)). The Topic Paper makes clear that the Council considers there to be exceptional circumstances to alter Green Belt boundaries, in order for the Local Plan to meet identified needs. This includes ‘Areas providing opportunities for delivering key infrastructure’, with land adjacent to the Tunbridge Wells Hospital at Pembury used as an example. At paragraph 6.62 of the paper, the Council state that the approach for each allocation has taken into account the outcomes of the Green Belt study at a site specific level as well the usual assessment of planning opportunities and constraints. In this respect, the Council conclude that there are exceptional circumstances to release Green Belt - having regard to constraints, development needs and the lack of reasonable alternatives - and then go on to consider whether specific sites are suitable to deliver development to meet identified needs. The assessment followed a three stage process, with the Green Belt study assessing both broad locations (Stage 1) and smaller parcels of land (Stage 2). This was followed by a detailed assessment of individual sites. The finer grained assessment undertaken by TWBC included the following:
Section 3.4 of this representation summarises the conclusions of the Stage 1 and 2 Green Belt study, however it is our view that they cannot all be reasonably applied to the Garden Centre site in isolation. Further, we consider that the woodland to the north west of the Garden Centre is a strong and defensible boundary that will endure beyond the plan period. This boundary could also be strengthened as part of wider proposals for redevelopment. The above matters aside, the Topic Paper goes on to list the proposed site allocation policies in the plan and provides a summary of the development type and whether it is proposed to remove it from the Green Belt. A summary of mitigation is also provided and attempts to rationalise the policy approach. However, a number of allocated sites are proposed to remain in the Green Belt despite being allocated for development, and the rationale section does not explain why this is the case. In our view, it is entirely illogical to identify sites for future development or infrastructure provision and then decide not to remove the land from the Green Belt when exceptional circumstances have been fully evidenced and justified through the plan making process. Taking the above into account, AL/PE 6 should be removed from the Green Belt to provide certainty that the required infrastructure can be delivered. At the very least, the Garden Centre should be removed from the Green Belt on the basis that it no longer contributes to the five purposes of Green Belt. [TWBC: see full representation. See also Comment No. DLP_7216 (Policy AL/PE 6)]. |
DLP_6528 | G and J Moger | TWBC: the following comment was submitted by the list of responders on the left: Draft Local Plan and Sustainability Appraisal We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Misty Meadow, Lamberhurst for around 30 dwellings (site reference AL/LA2). Planning Strategy
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
Conclusions The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan. Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant on the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments. The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB. Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community. |
DLP_7289 | Miranda Hungerford | Draft Local Plan and Sustainability Appraisal We are writing to you to register our concerns and objections to the following:
Planning Strategy 1) The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 4 and 5.5 of the Topic Paper confirmed that 60% of respondents would like to see housing growth along “growth corridors”, whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents. Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. The Council would need to be able to demonstrate that it has reacted appropriately to the consultation feedback, so a far greater emphasis on growth in established centres rather than rural locations would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on private cars as a means of travel – which surely must be of paramount importance given climate change commitments. Conclusions The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan. Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will be heavily reliant on the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments. The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB. |
DLP_7396 | Andrew Ford | Paragraph 172 of the NPPF requires that ‘great weight’ be given to conserving the landscape and scenic beauty in AONBs, who have ‘the highest status of protection in relation to these issues’. In order for great weight to be given, the impacts of TWBC’s policies on the AONB need to be properly assessed using the statutory AONB Management Plan. It is our view that TWBC does not give proper regard to impact on the AONB in the DDTP as required by NPPF, Para 172 and Section 85 of the CROW Act 2000 for the following reasons:
AONB and major development (Appendices 2 and 3) We welcome TWBC setting out the principles (Appendix 2) relating to the definition of major development in the AONB as required by Footnote 55, however, the method for assessing factors, particularly ‘AONB impact’, is muddled and unclear. The method proposed blurs the distinction between assessment of adverse impact on the purposes of the AONB, and the planning officer’s judgement on whether effects could be avoided by policy compliance. This is neither clear nor transparent and gives the impression of trying to avoid scrutiny. These steps need to be separated, in order that soundness and compliance with Footnote 55 can be assessed. In our view the assessment of adverse impact should not take into account policy compliant development. Policy compliance is dependent upon a number of factors in the future, negative impact will be immediate and in many case irreversible. The example given, that the negative effects of development on ancient woodland can be largely avoided by a buffer and woodland management is not supported by evidence[1]. The table setting out the criteria for High, Medium and Low impact (para.21, p.83) demonstrates a fundamental misunderstanding of the AONB Management Plan. Impact on the AONB is not a simple numbers game. The natural beauty of the AONB is a compilation of the core components at a landscape scale. The number of core components on any one site within that landscape is dependent upon location, geography and scale. Destruction of a single component may impact on the coherence of the whole. NPPF, para 172, states that - ‘great weight should be given to conserving the landscape and scenic beauty’ in AONBs. The ‘what’ is described in the Statement of Significance and is based on core components of character (AONB Management Plan, p. 23). The ‘how’, i.e. the conserving, is set out in the management plan policy objectives and actions. The method of assessing AONB impact in the DDTP Appendix 2 does not consider the impact of development on management plan policy objectives, and this is reflected in the limited and partial conclusions for each site set out in Appendix 3. This method is not fit for purpose. Neither the ‘Scale’ formula nor ‘Setting’ scale takes into account the distinctive characteristic of High Weald Settlement, namely its dispersed historic character, which is vulnerable to any increase in the size of later medieval villages that leads to coalescence between villages and their surrounding farmsteads, or between adjacent farmsteads. We question why the AONB Unit, who are funded by TWBC to provide expert advice on the AONB were not consulted on the method of AONB impact assessment (Appendix 2), or the assessments themselves (Appendix 3). The first we have seen of it has been the public consultation. In our view many of the impact assessments made are inconsistent and not justifiable. The conclusions to the assessment of AONB sites in Appendix 3 stray into justification for the development in economic terms or make spurious claims of AONB ‘opportunities’ or ‘benefits’, none of which are properly evidenced. The conclusions appear to attempt to address the sequential major development test required by NPPF, Para 172, although in an inconsistent manner. However, it is not made clear whether Appendix 3 is indeed intended to be an assessment of AONB sites in line with the major development test required by the NPPF, Para 172, or whether it is restricted to determining whether a proposal is ‘major development’ as required by Footnote 55. If the latter, then the sequential ‘tests’ required by Para 172 for those sites that are identified as potentially ‘major’, appears missing from the suite of Local Plan documents. Subjective judgements of landscape quality are being used to justify enhancements claimed by the development. For example development of 270 dwellings and a school at Spratsbrook (RTW18, Site 137) suggests that the site has a ‘poor edge to settlement’ and a ‘strong landscape structure of containment’ and that through the development the landscape can be ‘reinforced’ and provide a ‘strong edge to settlement’. These are opinions about aspects of visual experience which are not relevant to impact on the AONB. Impact on the AONB should be judged against the Statement of Significance and supporting chapters set out in the AONB Management Plan. [[1] https://www.woodlandtrust.org.uk/media/43620/impacts-of-nearby-development-on-the-ecology-of-ancient-woodland.pdf] |
DLP_7343 | Campaign to Protect Hawkhurst Village | Distribution of Development Topic Paper Paragraph 5.5 records that the most preferred option at the Issues and Options stage was Option 4 (Growth Corridor) obtaining 60% support. The most preferred combination was Option 5 and Option 4 – receiving 47%. This was the option also recommended in the Interim Sustainability Appraisal. Instead the Council has pursued Option 5 in combination with Option 3 – which only received 8% support at the Issues and Options stage. Paragraph 6.85 provided that the Council takes the view that where development is considered likely to cause significant harm to the defining character of the AONB then it is very unlikely to be supported. The Council’s proposed allocations in Hawkhurst directly contradict this approach. The Council’s own Landscape Sensitivity Analysis provides that the Hawkhurst Golf Course site is of high sensitivity and cannot accommodate anything other than small scale development. Instead the Council is proposing the largest ever single release of AONB land in the England. Paragraph 6.146 – records that Option 3 in the Interim Sustainability Appraisal was less positive than the other options. Yet this is the option that has been pursued in part. |
DLP_7490 | Freya Alder | TWBC: the following comment was submitted by the list of responders on the left: Draft Local Plan and Sustainability Appraisal We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2). Planning Strategy
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments. Conclusions The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan. Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments. The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB. We trust that these comments will be taken into account. |
DLP_3945 | Mrs June Bell | Topic Paper title: ‘Distribution of Development’ 6.106 Sites found to meet the relevant tests and suitable for allocation are normally those in a highly sustainable location, with limited negative effects on the wider AONB and/or AONB components and/or can make a positive contribution to AONB and landscape objectives and/or generate other wider public benefits, such as affordable housing and community infrastructure. The DLP development strategy does not appear to observe this condition. Reason for comment: Affordability is defined as 80% of market value/rent. The average house price in 2017 in the parish was £534,000, whereas the average earnings for workers in the Parish was £28.2k per annum (a ratio of 19:1 compared to the national figure of 12:1) making the Parish one of the most unaffordable areas in the country for local people1. More houses on rural sites will not lead to affordability for workers who wish to live and work in the parish. |
DLP_2782 | Mr Andrew McConnell | This provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents. Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments. |
Energy Topic Paper
Comment No. | Name/Organisation | Response |
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DLP_4223 | Tunbridge Wells District Committee Campaign to Protect Rural England | In general we are impressed by the great efforts that have clearly been made to gather all the relevant evidence, during a time when the Government kept moving the goalposts. Most comments that we make relating to the topic papers and other supporting documents are made in our comments on policies. However, we make the following additional comments: Energy Topic Paper This paper clearly sets out the current legislative and Government policy confusion and the unfortunate limitations on what the Borough Council can currently do to meet its and the Government’s aspirations on carbon reduction and energy saving. It is to be hoped that some of this legislative mess will have been sorted out by a new Government by the time of the Reg 19 consultation. |
Green Belt Study
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DLP_6198 | Turley for Bellway Homes Strategic | Sustainability Appraisal Whilst the Sustainability Appraisal appears to consider the options for a Garden Settlement, we have been unable to locate any assessment at this stage which does not include such an option as part of the distribution strategy. In our view, it would be a reasonable alternative to consider a solution which does not include a Garden Village. In particular we consider that this is essential due to the fact that the Tudeley Village site is remote, does not benefit from access to rail services, is not related to existing services/facilities and significant intervention will be required to provide any facilities in the area. In contrast, alternative sites would provide opportunities to locate development in areas which already relate to existing settlements and services. We note that Table 20 of the Sustainability Appraisal sets out a list of reasonable alternative sites in Royal Tunbridge Wells. Site reference 53 (being the land promoted by Bellway) is referred to in that list of sites. Table 20 confirms part of the site is proposed to be allocated under AL/RTW 23. The scoring of site 53 against the SA objectives is contained on page 164 of the Sustainability Appraisal. The SA does not appear to include any detailed explanation as to how the scores have been calculated and so it is not possible for respondents and stakeholders to analysis the impacts of one site over another. [TWBC: the comments above have also been entered against the Sustainability Appraisal as Comment Number SA_109]. Proposals Map The Proposals Map published for consultation is of extremely low resolution and does not allow a clear understanding of the policies applicable to any specific area. We consider that it is essential, in order to understand how the Local Plan is to be applied, that a higher resolution version of the Proposals Map is made available. Green Belt Assessment In the LUC Green Belt Strategic Study of November 2016, the southern part of the site is located in Parcel TW6 and the remainder in Broad Are BA7, as shown below: [TWBC: see map on page 11 of full representation]. Parcel TW6 is identified as an area for further assessment, with Table 6.2 of the 2016 document identifying ‘Potential Stage Two parcels and broad areas’. In relation to TW6, Table 6.2 identifies the ‘Key Stage 2 Considerations’ as being the “Relationship between settlement and countryside, with reference to role of High Wood in forming barrier to encroachment/sprawl.”
Appendix A of the 2017 report also provided an analysis of the specific parcels against the Green Belt purposes. Bellway consider that the assessment in relation to Parcel TW6a is flawed. The table below sets out the assessment of this parcel in the LUC 2017 report and provides our response and reason why the conclusions are flawed:
The Turley Outline Landscape, Visual and Green Belt Advice Note demonstrates that the contribution of Parcel TW6a has been overstated, particularly when the land promoted by Bellway is considered independent. In the July 2019 SHELAA the land promoted by Bellway is considered under site reference 53. The assessment found that the “Site is suitable in part as a potential Local Plan allocation subject to further consideration”. The reason for this conclusion was stated as being “The southern parcel of this site lies adjacent to the LBD and is likely to be sustainable in this context. This would form a logical extension to LBD. The remaining area, the first parcel whilst in proximity to the LBD would not form a logical extension to the LBD and is considered to adversely affect the landscape setting of the town and is part of a Green Belt parcel the release of which is considered to result in very high harm, and setting of an Historic Park and Garden.” [TWBC: see full representation and Comment Numbers DLP_6189-6198]. | ||||||||||||||||||||||||
DLP_8214 | Mrs Suzi Rich | Topic Paper or supporting document title: Comments on the Distribution of Development Topic Paper Chapter 3: Development Constraints (p.4) Chapter 5: Issues and Options consultation (p.11) Paragraph 5.6 summarises the main outcomes of the consultation for the question relating to the five strategic options for delivery presented in the Issues and Options document. Only 18% ranked Option 5 (new freestanding settlement) as their most preferred approach. It is submitted that this would have been even less if the site/sites now proposed at AL/CA 1 and AL/CA 3 & AL/PW 1 had been identified at that time. Appendix 1 to The Issues and Options Consultation Statement, available on the Tunbridge Wells Borough Council website at https://beta.tunbridgewells.gov.uk/local-plan/issues-and-options, lists the Strategy Considerations at Section 5 (p.26-39). It is clear from p.33, that by far the largest level of support was 60% for Option 4 (Growth Corridor led approach). However, p.39 of the same document states that “A level of support was indicated in the Issues and Options responses for a new settlement.” This is misleading. The Consultation Statement goes on to consider the responses to question 10 and 10a relating to preferences for a combination of Options (p.35). The first bullet point states that the responses indicate that it is worth “Exploring further the potential for ‘new settlement growth’, as this was the most commonly preferred (alone or in combination) of all the options”. The statement is blatantly not true! Paragraphs 5.7-5.8 cover question 11/11a, which asked for views about the possibility of a new settlement somewhere in the borough and suggestions for possible locations. It lists the key issues referred to across the response groups, which include:
These views have been completely ignored by TWBC! They should carry weight and should have informed the decision on the strategic site proposals. Paragraphs 5.9-5.10 cover question 12/12a, which asked whether all reasonable options for accommodating future development growth within the borough have been considered and identified and if not, what other options should be considered. Respondents suggested that the following options should be considered:
Where have these responses been acknowledged in the dLP? Have these options been considered at all? Chapter 6: Formulating the development strategy (p.14) Paragraph 6.2 states “For the second Call for Sites, officers contacted the promotors of sites submitted to the first Call for Sites and identified and then contacted owners of land around settlements (on a ‘without prejudice’ basis) that had not been submitted through the first Call for Sites to enable them to submit sites if they wished. This proactive approach encouraged owners of land that could be suitable for development to submit sites for consideration”. Why were we told by Stephen Baughan at the Capel Annual Parish Meeting that TWBC had no influence on what sites were submitted and that the officers just had to work with what appeared in the Call for Sites! Paragraph 6.2 also expressly states that the second 'Call for Sites' was undertaken between May and June 2017. In the Interim New Local Plan Strategic Housing & Economic Land Availability Assessment 2017. It was stated “although the call for sites remains open, it will no longer be possible to include any new sites within the site assessment process that is informing the Draft Local Plan (being prepared under Regulation 18) AS THERE IS INSUFFICIENT TIME TO ADEQUATELY ASSESS SUCH SITES. (TWBC will continue to accept in order that they may be assessed & potentially included at Reg 19)”. The evidence base persuaded TWBC to opt for Growth Strategy Option 3 (existing urban distribution plus villages) and Option 4 (A21 growth corridor). There was a possibility of Option 5 (new settlement) in the longer term (8 possible sites but 5 not shortlisted including AL/ CA 1). Presumably this underwent a robust process based on robust evidence? This was still the preferred stance March 2018, however in April 2018, there appeared to be a complete change of direction which resulted in the allocation of 60% of the proposed development in the Parish of Capel. Where in the DLP is this new evidence base? When was site 448 (Land at Tudeley) first considered (p.24-30)? Table 2 details TWBC’s Conclusions of the SHELAA and SA on garden settlement options but gives no credible explanation as to why the Tudeley site is considered to be ‘well located’ as required by para 72 of the NPPF. Neither does Table 3 which details the outcome of TWBC’s Consideration of proposed strategic allocation sites against para 72 of the NPPF. This table is misleading and inaccurate. The site is NOT well located. Comments on the Green Belt Study The site at Tudeley (AL/CA 1) falls within Broad Areas BA3 and BA4. The ‘Potential Level of Harm to the Green Belt Associated with Release of Broad Areas BA3 and BA4 is ‘VERY HIGH’ (Figure 1.1 (p.8)) Comments on the Infrastructure Delivery Plan Education Health Under the heading ‘Additional future requirements needed to deliver growth proposed in the Draft Local Plan’ at paragraph 3.104 (p.40) it states that “The Council has not been made aware of any specific requirements over the plan period; however, discussions with the Maidstone and Tunbridge Wells NHS Trust have highlighted potential need for extension of either the Tunbridge Wells Hospital or Maidstone Hospital to serve the West Kent Area over the Plan period” Please also see my comments in COMMENT BOX 2 under the heading ‘Strategic Objective 5: Essential Infrastructure and Connectivity’ Comments on the SWECO Local Plan Transport Evidence Base Figure 9-2 shows the ‘Mitigation Interventions Mapped’ (p.142) which shows the proposed routes for the following ‘highway measures’ detailed in Table 9-2 (p.138): It is suggested building the Colts Hill strategic link is vital to delivery of the proposed new developments in Capel. How will this improve connectivity? It will be a faster, polluting road to nowhere unless the congestion on the A264 and the two roundabouts at Pembury can be dealt with (there are no proposals to do so in the dLP and the Hendys development will make this worse). Traffic to the A21 from Paddock Wood will continue to use the B2017. The A228 strategic link has been mooted for the last forty years, initially as a requirement due to the Channel Tunnel! The whole area surrounding Paddock Wood needs a radical holistic solution. The dualling of the A21 was supposedly going to reduce traffic in this area but as TMBC have discovered, through traffic has actually increased in volume in Tonbridge since the “improvement” [TWBC: See comments DLP_8189-8214 for full representation] | ||||||||||||||||||||||||
DLP_4457 | Mr Andrew Rankine | Green Belt: The council states that it places high importance on protection of Green Belt and AONB and this was raised as one of the major concerns raised in the Issues and Options Consultation. However, STR1 of the Plan reveals that it is in fact a specific objective to target development within the Green Belt: “7. The release of Green Belt around the settlements of Royal Tunbridge Wells, Southborough, Paddock Wood, Pembury, and in the parish of Capel, to deliver development allocated in this Local Plan”. I fail to see how having a named strategy to target the release of Green Belt aligns the importance of protecting it. As such I think that this Strategy should be removed as it is at odds with the stated position of TWBC, the desires of the local residents (as evidenced by the responses to the Issues and Options Consultation) and the NPPF 2019. To actively not consider the NPPF’s option (and it is an option) to revise the local housing figure based on what is achievable without impacting on this most important factor is inconceivable. The borough is constrained but the council is actively choosing to destroy an area that is has itself had categorised in its own Green Belt study as “High Impact”. To use a revised and more realistic Housing Needs projection based on 2016 figures would seem to be an sensible rationale for not actively choosing to needlessly destroy protected countryside. You will be aware that The Ministry of Housing, Communities and Local Government has recently consulted on whether the latest ONS figures should be used to revise the Housing Needs calculation. Although this remains a contentious area as latest data does not support a Government policy to deliver a seemingly arbitrary 300,000 houses per annum, Tunbridge Wells Borough Council needs to make an assessment of what its actual housing need is and plan towards this. To not do that goes against the fundamental reason that local government exists. “Exceptional Circumstances” - TWBC clearly believes that “exceptional circumstances” (as defined by the NPPF 2019) exist which gives this draft plan the license to alter the Green Belt boundaries in Policy STR/CA1. Assuming that these circumstances do exist (but they don’t), these same circumstances give the local planning authority the ability to undertake a Housing Needs calculation not using the Standard Methodology. The Housing and Economic Needs Assessment guidance from the Ministry of Housing, Communities and Local Government states. “There is an expectation that the standard method will be used and that any other method will be used only in exceptional circumstances”. Once TWBC had concluded that they had reached the threshold to consider sacrificing the Green Belt, they should then have referred back to this guidance and looked at an alternative method to calculate the local Housing Need – for example by using the latest data from the ONS which reduces the estimated housing need by 32%. By the very nature of circumstances being deemed “exceptional”, TWBC simply cannot apply this designation to one area of planning and not another. | ||||||||||||||||||||||||
DLP_1632 | Maggie Fenton | Green Belt Assessment
“The eastern boundary abuts THE settlement edge”. Contribution to GB purposes 2. Prevent neighbouring towns merging into one another “The gap between Five Oak Green and Paddock Wood represents a faily small proportion of the overall gap between towns, but coalescence or near coalesence of these separate settlements would have a disproportionate impact due to the open and flat nature of the landscape, more likely to be perceived as sprawl. Development within the parcel would therefore result in some narrowing of the gap between gaps but a significant gap would remain” Relatively weak Given that the whole of this site is in another parish (Capel) the assessment is entirely inaccurate. The Western boundary (Tudeley Brook) is not mentioned and yet is the most important boundary in terms of two settlements coalescing as the authors recognize in their text but they have assessed assuming this area is part of Paddock Wood, “THE settlement”. This is the only part of the so called “Paddock Wood” garden village development which falls in Capel, to have been assessed. BA3 (west from Tudeley Brook to include properties in Five Oak Green) & BA4 (northwards to also include properties also in Five Oak Green) are not assessed BUT with both of those areas now in the DLP as the assessment states “would have a disproportionate impact’ as the “significant gap” would no longer exist. Contribution to GB purposes 3. Assist in safeguarding the countryside from encroachment. “The parcel relates to both the settlement & the wider countryside” Moderate value Again the assessment is talking about the wrong settlement, this parcel of land is Five Oak Green within Capel and is not part of Paddock Wood. Neither CA1 nor CA2 are included in the Green belt assessment – why not? However the previous study in 2017 indicates that the release of the MGB for development in the area of CA1 as proposed by TWBC would be sheer vandalism. TWBC can not argue a lack of land for housing supply as justification to release any of this greenbelt – it is not sufficient in isolation to establish VSC. The evidence in 2017 was that this GB was very much fulfilling its function. Tunbridge Wells Green Belt Study (2017) – Stage 2 Tudeley area falls within Broad Area BA3 and partly BA4. These ‘Broad Areas’, like all of the others identified across the Borough is categorised as being of ‘very high’ harm caused by release. There are no ‘green belt parcels’ identified for release in the Tudeley or Capel area. Broad Area BA3 is considered to provide ‘contribution to gap between Tonbridge and Paddock Wood; extent of openness; distinction between Low and High Weald landscapes’. Broad Area BA4 is considered to provide ‘contribution to preventing countryside encroachment and a gap between Tonbridge and Paddock Wood’. The document seeks to measure these Broad Areas against the purposes of the Green Belt which include:
The results of the assessment are summarised in Table 6.1. Broad Area BA3 is assessed as contributing strongly to three out of four of the purposes identified above. The exception to this is Purpose 4 which is categorised as weak/no contribution but the overall contribution to the Green Belt is assessed to be ‘VERY HIGH’. BA4 contributes strongly to purpose 2 and 3 but relatively weak to purpose 1 and 4. Overall its contribution remains ‘VERY HIGH’. - There appears to be a total disregard for the Green Belt allocation that covers the Capel area and the Borough’s own study that was commissioned to identify the contribution of different areas to the purposes of the Green Belt - the allocation to the East of Five Oak Green actually connects the village of Five Oak Green and Paddock Wood, and subsumes dwellings that are in Five Oak Green (failing the first 3 criteria) | ||||||||||||||||||||||||
DLP_8150 | Ashley Saunders | The Green Belt Study consists of a Stage 1 Green Belt Study, completed November 2016 (48 pages), a Stage 2 Green Belt Study, completed in July 2017 (38 pages) and four separate documents within Appendix A containing Broad Area and Parcel Assessments (127 pages). Tunbridge Wells Green Belt Study Stage Two (2017) The Executive Summary outlines that each ‘assessment’ of a broad area of parcel of land considers the parcel boundaries and gives a rating for the broad area / parcel of land for each ‘Purpose’ of the Green Belt as identified by Paragraph 80 of the NPPF. These are:
Although not assessed by itself in the appendices, the site at Tudeley (AL/CA 1) falls within Broad Areas BA3 and BA4. Figure 1.1 (p.8) illustrates that the ‘Potential Level of Harm to the Green Belt Associated with Release of Broad Areas BA3 and BA4 is ‘VERY HIGH’. Table 4.1 (p.17) identifies key considerations for each broad area: Broad Area BA3 is considered to provide “contribution to gap between Tonbridge and Paddock Wood; extent of openness; distinction between Low and High Weald landscapes” Broad Area BA4 is considered to provide “contribution to preventing countryside encroachment and a gap between Tonbridge and Paddock Wood” Table 6.1 (p.28) lists the ratings assigned to each parcel and each broad area for each of the Green Belt purposes set out in the NPPF. BA3 is assessed as contributing strongly to three out of four of the purposes identified. The exception to this is Purpose 4 which is categorised as weak/no contribution but the overall contribution to the Green Belt is assessed to be ‘VERY HIGH’ BA4 contributes strongly to purpose 2 and 3 but relatively weak to purpose 1 and 4. Overall its contribution remains ‘VERY HIGH’. There appears to be a total disregard for the Green Belt allocation that covers the Capel area and the Borough’s own study that was commissioned to identify the contribution of different areas to the purposes of the Green Belt Assessment of Paddock Wood Parcel PW 1 (Appendix A – second document from p.25) The outcome of the assessment as to this parcel’s contribution to Green Belt purposes states under Purpose 2 is that “The gap between Five Oak Green and Paddock Wood represents a fairly small proportion of the overall gap between towns, but coalescence or near-coalescence of these separate settlements would have a disproportionate impact due to the open and flat nature of the landscape, being more likely to be perceived as sprawl. Development within the parcel would therefore result in some narrowing of the gap between towns but a significant gap would remain.” The rating given is ‘Relatively weak’ Given that the whole of this site is in another parish (Capel) the assessment is entirely inaccurate. The Western boundary (Tudeley Brook) is not mentioned and yet is the most important boundary in terms of two settlements coalescing as the authors recognize in their text but they have assessed assuming this area is part of Paddock Wood, “THE settlement”. This is the only part of the so called “Paddock Wood” parcel, which actually falls within Capel Parish, to have been assessed. Broad areas BA3 (west from Tudeley Brook to include properties in Five Oak Green) and BA4 (northwards to include properties also in Five Oak Green) are not assessed BUT with both of those areas now in the DLP as the assessment states “would have a disproportionate impact’ as the “significant gap” would no longer exist. The outcome of the assessment as to this parcel’s contribution to Green Belt purposes states under Purpose 3 is that “The parcel relates to both the settlement & the wider countryside”. The Rating given is ‘Moderate value’ Again the assessment is talking about the wrong settlement, this parcel of land is Five Oak Green within Capel Parish and is not part of Paddock Wood. Assessment of Tudeley Parcel CA 1 / Land to East of Tonbridge / West of Tudeley Village Parcel CA 2 Neither CA1 nor CA2 are included in the Green Belt Assessment Appendices – why were they not assessed? I considers that the findings of the Green Belt Study indicate that the release of the MGB for development in the area of CA1 as proposed by TWBC would be sheer vandalism. TWBC cannot argue a lack of land for housing supply as justification to release any of this Green Belt land – it is not sufficient in isolation to establish Very Special Conditions. The evidence in 2017 was that this area of Green Belt was very much fulfilling its function | ||||||||||||||||||||||||
DLP_3729 | Capel Parish Council | The Green Belt Study consists of a Stage 1 Green Belt Study, completed November 2016 (48 pages), a Stage 2 Green Belt Study, completed in July 2017 (38 pages) and four separate documents within Appendix A containing Broad Area and Parcel Assessments (127 pages). Tunbridge Wells Green Belt Study Stage Two (2017) The Executive Summary outlines that each ‘assessment’ of a broad area of parcel of land considers the parcel boundaries and gives a rating for the broad area / parcel of land for each ‘Purpose’ of the Green Belt as identified by Paragraph 80 of the NPPF. These are:
Although not assessed by itself in the appendices, the site at Tudeley (AL/CA 1) falls within Broad Areas BA3 and BA4. Figure 1.1 (p.8) illustrates that the ‘Potential Level of Harm to the Green Belt Associated with Release of Broad Areas BA3 and BA4 is ‘VERY HIGH’. Table 4.1 (p.17) identifies key considerations for each broad area: Broad Area BA3 is considered to provide “contribution to gap between Tonbridge and Paddock Wood; extent of openness; distinction between Low and High Weald landscapes” Broad Area BA4 is considered to provide “contribution to preventing countryside encroachment and a gap between Tonbridge and Paddock Wood” Table 6.1 (p.28) lists the ratings assigned to each parcel and each broad area for each of the Green Belt purposes set out in the NPPF. BA3 is assessed as contributing strongly to three out of four of the purposes identified. The exception to this is Purpose 4 which is categorised as weak/no contribution but the overall contribution to the Green Belt is assessed to be ‘VERY HIGH’ BA4 contributes strongly to purpose 2 and 3 but relatively weak to purpose 1 and 4. Overall its contribution remains ‘VERY HIGH’. There appears to be a total disregard for the Green Belt allocation that covers the Capel area and the Borough’s own study that was commissioned to identify the contribution of different areas to the purposes of the Green Belt Assessment of Paddock Wood Parcel PW 1 (Appendix A – second document from p.25) The outcome of the assessment as to this parcel’s contribution to Green Belt purposes states under Purpose 2 is that “The gap between Five Oak Green and Paddock Wood represents a fairly small proportion of the overall gap between towns, but coalescence or near-coalescence of these separate settlements would have a disproportionate impact due to the open and flat nature of the landscape, being more likely to be perceived as sprawl. Development within the parcel would therefore result in some narrowing of the gap between towns but a significant gap would remain.” The rating given is ‘Relatively weak’ Given that the whole of this site is in another parish (Capel) the assessment is entirely inaccurate. The Western boundary (Tudeley Brook) is not mentioned and yet is the most important boundary in terms of two settlements coalescing as the authors recognize in their text but they have assessed assuming this area is part of Paddock Wood, “THE settlement”. This is the only part of the so called “Paddock Wood” parcel, which actually falls within Capel Parish, to have been assessed. Broad areas BA3 (west from Tudeley Brook to include properties in Five Oak Green) and BA4 (northwards to include properties also in Five Oak Green) are not assessed BUT with both of those areas now in the DLP as the assessment states “would have a disproportionate impact’ as the “significant gap” would no longer exist. The outcome of the assessment as to this parcel’s contribution to Green Belt purposes states under Purpose 3 is that “The parcel relates to both the settlement & the wider countryside”. The Rating given is ‘Moderate value’ Again the assessment is talking about the wrong settlement, this parcel of land is Five Oak Green within Capel Parish and is not part of Paddock Wood. Assessment of Tudeley Parcel CA 1 / Land to East of Tonbridge / West of Tudeley Village Parcel CA 2 Neither CA1 nor CA2 are included in the Green Belt Assessment Appendices – why were they not assessed? Capel Parish Council considers that the findings of the Green Belt Study indicate that the release of the MGB for development in the area of CA1 as proposed by TWBC would be sheer vandalism. TWBC cannot argue a lack of land for housing supply as justification to release any of this Green Belt land – it is not sufficient in isolation to establish Very Special Conditions. The evidence in 2017 was that this area of Green Belt was very much fulfilling its function | ||||||||||||||||||||||||
DLP_4321 | Town and Country Planning Solutions for Gleeson Strategic Land |
List of Appendices | ||||||||||||||||||||||||
DLP_4643 | CBRE Ltd for Dandara Ltd | 3.7 Dandara also welcomes TWBC’s approach to releasing appropriate land from the Green Belt, where there are exceptional circumstances to justify release of the above-mentioned sites for reasons which include the delivery of new housing in sustainable locations, providing new educational facilities, facilitating wider economic growth through a plan-led approach, and increasing public accessibility to it, as well as ensuring development protects the openness of remaining Green Belt land. 3.8 A summary of the exceptional circumstances as set out in TWBC’s Distribution of Development Topic Paper for Draft Local Plan Regulation 18 Consultation (September 2019) for each of the sites Dandara holds a specific land interest in are set out below:
3.9 Dandara considers that the above reasons are in accordance with paragraphs 135 and 136 of the NPPF insofar as these sites demonstrate exceptional circumstances – and therefore sound reasoning – exist to justify the amendments to Green Belt boundaries and release of Green Belt land for housing and new educational facilities. 3.10 Dandara also considers TWBC’s Green Belt Study (Stages 1 and 2) to be a thorough and robust report. The methodology and coverage of the Study are also considered to be sound. [TWBC: see page 7 of full representation]. | ||||||||||||||||||||||||
DLP_4797 | DHA Planning Ltd for Caenwood Estates and Dandara | 4 Comments on technical documents Comments on Green Belt Study 4.1.12 The north-eastern part of the site is identified as parcel SO1a in the GB study. It is classified as causing moderate harm if released from the Green Belt. 4.1.13 The GB study identifies the majority of the site as parcel SO1b and inconsistently states that it would cause a very high level of harm if the parcel was released. The study’s findings in relation to the various Green Belt purposes are summarised and commented upon below. 1. Check the unrestricted sprawl of large built-up areas 4.1.14 The study comments that: “The parcel is adjacent to the large built-up area but has some separation from it and relates strongly to the wider countryside – development would represent significant expansion of the large built-up area into countryside.” 4.1.15 In response, we consider that the parcel adjoins the current defined settlement confines and rural fringe on its north and eastern side. It is a logical extension rather than piecemeal and out of keeping release in the countryside. 2. Prevent neighbouring towns merging into one another 4.1.16 The study comments that: “Development of this parcel would result in physical or visual coalescence of settlements which form a significant proportion of the land between towns.” 4.1.17 In response, we comment that in this case, Southborough and TW are already joined by linear development along St Johns Road. Development on this parcel would form a logical extension to the west and would not contribute to the coalescence of Southborough and TW any more than currently exists. 3. Assist in safeguarding the countryside from encroachment 4.1.18 The study comments that: “The parcel relates strongly to the wider countryside, has a sense of separation from the settlement and lacks urbanising development – development would represent encroachment into the countryside.” 4.1.19 In response, we comment that the site adjoins existing built development. The 2009 assessment was clear that the landscape quality of the site had degraded, it is not AONB and it is clear the site is a logical extension to existing development. 4. To preserve the special character of historic towns 4.1.20 The study comments that: “The parcel’s openness contributes to the relationship between the settlement and characteristics identified as contributing to special character or historic setting.” 4.1.21 In response, we comment that the historic core of Tunbridge Wells is centred on the High Street and Pantiles area. The existing built up area in this part of Tunbridge Wells and Southborough does not have any special historic character and development of this site would have no effect on this. [TWBC: see full representation]. | ||||||||||||||||||||||||
DLP_6779 | DHA Planning Ltd for Axiom Developments | 3.5 Comments on Green Belt Study 3.5.1 Proposed allocation site AL/RTW 13 falls within parcel TW4 as considered in the Council’s Green Belt Study. This is the same parcel as the neighbouring allocation AL/RTW 12 which, unlike Colebrooke House, is proposed to be removed from the Green Belt. Contribution to Green Belt purposes 3.5.2 In terms of the parcel’s contribution to Green Belt purposes, we note that: * The parcel makes a weak/no contribution to the purpose of preventing neighbouring towns merging into another. We agree that this site makes no contribution to this purpose. Green Belt boundary strength 3.5.3 We agree with the conclusion that “the A21 would constitute a stronger boundary to the east”. It is noted that the proposed Green Belt boundary ignores this recommendation and instead proposes to place the Green Belt boundary between draft allocation sites AL/RTW 12 and AL/RTW 13, as shown in Figure 3.4. [TWBC: for Figure 3.4 see full representation attached]. 3.5.4 The proposed Green Belt boundary does not follow any obvious features, but is tight to the boundary of the proposed allocation site AL/RTW 12. 3.5.5 We consider that the Green Belt boundary should be amended to include proposed allocation AL/RTW 13 up to the A21, which is a much stronger and more defensible boundary. At the very least, the boundary should be consistent with the proposed Limits to Built Development as shown on the draft Proposals Map. 3.5.6 That said, we consider that both the Green Belt and Limits to Built Development boundaries should be altered to include: * The vehicular access to Colebrooke House; and 3.5.7 Our proposed boundary is shown in Figure 3.5 below. [TWBC: for Figure 3.5 see full representation attached]. [TWBC: see also Comment Nos. DLP_6777-6779 and full representation and supporting documents: Design Overview , Ecology Report, Heritage Report and Landscape & Visual Appraisal . See also Comment No. SA_118 on the Sustainability Appraisal]. |
Green Infrastructure Framework
Comment No. | Name/Organisation | Response |
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DLP_3858 | Government Team | In addition to a stand-alone policy for green infrastructure (GI), we welcome the production of a supporting GI Framework. The collation of information within the Framework presents a positive and pro-active approach to informing the Council’s strategic GI approach, with reference to neighbouring authorities’ GI strategies. We are pleased to note the consideration of urban GI (in addition to rural) and the discussion of how GI can contribute to managing climate change challenges (reflected also in policy wording at EN 5 and EN 16). Appendix 1 includes our recommendation that the relevant plan policy (EN 16) provides a clear link to the GI Framework to provide a ‘hook’ to the Framework, and to highlight the aims and recommendations of the document. Similarly, a link to the SPD (acknowledging the likelihood of future revisions) would be helpful to provide clear guidance to developers on the means of GI delivery. Section 3 of the Framework lists a number of features which are considered ‘GI Assets’. Whilst a number of these would be considered to contribute towards GI, not all of them are considered to be GI assets in their own right. For example, it is not considered that cycleways, public rights of way, outdoor sports facilities or provision for children and teenagers, are considered to reliably contribute to GI and are therefore not considered to be GI assets themselves. However, they certainly provide valuable opportunities for GI provision. It may therefore be better to avoid the assumption that all of the mentioned assets will contribute to GI, and instead clarify that, when designed with GI in mind, these features can provide an important contribution to GI provision. Section 61 of the Framework concerns net gain and ‘offsetting’. Detailed advice on net gain is provided in Appendix 1, however it needs to be made absolutely clear throughout the local plan and in supporting documents that net gain can only be achieved where provision is measurably greater than any losses. It is therefore recommended that any reference to ‘providing biodiversity gains equal to […] losses’ is removed. Approaches (including policy wording) for biodiversity provision are only acceptable where measurable net gains are provided, and this applies to on site and off site delivery. Off-site provision should be justified and provided in accordance with current guidance documents, including local policy and emerging national policy. Regarding implementation (Section 5), we welcome the inclusion of provisions for both existing and new GI within the plan. To secure the longevity of GI provision, we recommend that policy and supporting documentation requires suitable long term management and maintenance of GI features, which is properly and securely funded for the lifetime of the development. Suitable funding mechanisms should be secured by planning conditions and or/legal agreement, which may include (but should not be limited to) income from ground rent (as indicated in section 67). |
DLP_7363 | Wealden District Council | The Green Infrastructure Framework Supporting Document acknowledges that GI often extends beyond political/administrative boundaries. WDC welcomes this acknowledgement and the reference to the GI evidence base/work being undertaken in Wealden District and the potential for this to be furthered with cross boundary working. |
Habitat Regulations Assessment
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_7362 | Wealden District Council | Wealden District Council submitted its HRA and subsequent documentation and evidence in January 2019 to support its Submission Wealden Local Plan and subsequently submitted further information in response to the Inspectors Matters. Stage 1 of the EiP for the Submission Wealden Local Plan took place in May and July 2019. Several days were dedicated solely to HRA matters, mainly in relation to the impact of air quality on European sites. The Council is now waiting to receive the Inspector’s letter in relation to the outcome of its stage one EiP. |
DLP_3856 | Government Team | Impact Pathway: Atmospheric Pollution Natural England concurs with the conclusions drawn in the HRA which state that “there will be no adverse effects upon the integrity of Ashdown Forest SPA / SAC as a result of increased atmospheric pollution resulting from the Tunbridge Wells Local Plan”. Impact Pathway: Recreational Disturbance Natural England disagrees that the standalone approach of SAMMs contributions as mitigation for recreational pressure is consistent with other local authorities’ agreed approaches. As such we do not agree it can currently be concluded that there will be no adverse effects upon the integrity of Ashdown Forest SPA / SAC as a result of increased recreational pressure resulting from the Borough of Tunbridge Wells Local Plan. Natural England advises that for consistency with other local authorities, the strategic approach as detailed below is adopted to avoid an adverse effect on the integrity of Ashdown Forest SPA and SAC.. This approach has already been agreed between Natural England and local authorities within the area, including Tunbridge Wells Borough Council. Ashdown Forest SAC/SPA agreed strategic approach: In order to prevent adverse effects on the Ashdown Forest SPA and SAC, new development likely to have a significant effect, either alone or in combination with other development, will be required to demonstrate that adequate measures are put in place to avoid or mitigate any potential adverse effects. Within a 400 metres buffer zone around Ashdown Forest, mitigation measures are unlikely to be capable of protecting the integrity of the SPA and, therefore, residential development will not be permitted. Within a 7km zone of influence around the Ashdown Forest SPA, residential development leading to a net increase in dwellings will be required to contribute to mitigation through:
Large schemes proposed adjacent or close to the boundary of the 7km zone of influence may require mitigation for the SPA. Such proposals for development will be dealt with on a case-by-case basis. Where bespoke mitigation is provided, these measures will need to be in place before occupation of development and must be managed and maintained in perpetuity. The effectiveness of such mitigation will need to be demonstrated prior to approval of the development. Bespoke mitigation will need to be discussed and agreed by the District Council as the competent authority following advice from Natural England. Natural England advise that implementation of the above strategic solution, including SANG and SAMM contributions, is required to avoid an adverse effect on the integrity of Ashdown Forest SPA and SAC. The details of the above strategy should be reflected in Policy EN 13: Ashdown Forest Special Protection Area and Special Area of Conservation. |
Housing Needs Assessment
Comment No. | Name/Organisation | Response |
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DLP_8314 | Andrew Richards | INTRODUCTION I am not a resident of Tunbridge Wells Borough, but I live near to the Borough boundary just outside Tonbridge. I visit the Borough regularly and enjoy the benefits of its countryside, notably the Green Belt and the Areas of Outstanding Natural Beauty, which need to be preserved in line with National Planning Policy. I also drive around Tonbridge regularly and am shocked at the impact the proposals in your draft Local Plan (LP) would have on Tonbridge and its environs. The LP is vast and complex and has clearly consumed a significant amount of effort; I congratulate the officers for their diligence in seeking to balance the various competing demands of policy, legislation and local constraints. As a private individual I do not have similar resources or expertise; I have therefore confined my comments to a small number of topics. This is not to say I endorse the remainder of the LP and its associated material; I am aware of some of the concerns raised by others and support many of them. Notwithstanding the level of effort that has gone into the LP, I’m afraid my overall assessment is that the Borough has fallen short of the diligence needed. Sadly, it seems to have taken the easy way out of its obligations in a number of areas. It has:
I conclude that the Borough has failed to meet the required standard for a Regulation 18 consultation and should repeat the exercise, having first addressed some of the fundamental concerns raised. I believe this plan requires too substantial a series of amendments to proceed directly to a Regulation 19 consultation. My comments are in relation to a number of documents identified below. housing needs assessment aug 2019
No, if it is felt that circumstances warrant an alternative approach but authorities can expect this to be scrutinised more closely at examination. There is an expectation that the standard method will be used and that any other method will be used only in exceptional circumstances” (PPG 2a-003-20190220)
[[1] https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populationprojections/bulletins/subnationalpopulationprojectionsforengland/2016based]
[[1] https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populationprojections/bulletins/2016basedhouseholdprojectionsinengland/2016basedhouseholdprojectionsinengland]
[[1] https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populationprojections/bulletins/nationalpopulationprojections/2018based]
4. On this basis, TWBC have failed to underpin their analysis using “relevant and up-to-date evidence”, and the LP is therefore unsound. Housing provision for elderly5. I am not convinced the needs of an increasingly elderly population have been taken into account in terms of the type of housing needed. Specifically:
6. In conclusion, more consideration should be given to developing appropriate housing – typically bungalows - to accommodate the over 60s in more rural locations, as retired persons often contribute to volunteer work within a community and make a very valuable contribution. Building large greenfield settlements is the wrong answer to this problem. Conclusion39. In conclusion, to reiterate the point made in opening, I conclude that the Borough has failed to meet the required standard for a Regulation 18 consultation. It should therefore repeat the exercise, having first addressed some of the fundamental concerns raised. [TWBC: See full representation] |
DLP_2791 | Mrs Karen Langston | I firmly believe that Tunbridge Wells Borough Council should adopt an alternative approach to assessing housing need, rather than use the standard methodology as described by the NPPF. This is because the standard methodology uses out-of-date data and because there are exceptional circumstances that justify an alternative approach. As it stands, the policies in the draft Local Plan hinge entirely on an untested target that will result in the unnecessary development on and irreversible damage to the AONB; the unnecessary loss of Green Belt land, despite its characteristic “permanence” (NPPF paragraph 133); the irreversible loss of rural landscape and wildlife habitats; a supply of housing that is too expensive to meet local need; an unsustainable strain on infrastructure, services and amenities, particularly for smaller settlements that already have low sustainability, such as Matfield. The untested and unchallenged housing target is given alarming prominence, influencing policy and strategy throughout the plan. This is despite the fact that the Housing Needs Assessment Topic Paper (August 2019) states that, “…the Government has indicated that it will be reviewing the methodology in the next eighteen months, but this has yet to be determined. This is because the current methodology relies on dated, 2014-based projections, instead of newer projections. The Government reasoning for continuing to use these, on an interim basis, is to provide stability and certainty to the planning system in the short-term, noting also that the standard method does not represent a mandatory target for local authorities to plan for, but the starting point for the planning process.” The standard methodology is, therefore, not mandatory. The target that the Plan aims to achieve could be, and is most likely to be, far higher than the actual need. Meanwhile, it is not appropriate for the Council to adopt its ‘wait and see’ position, as it may have built its policy framework around a false target that will likely prove difficult to reduce once submitted for inspection. I argue that it is vital that the Plan is based upon the most realistic assessment of need, taking into account the constraints that characterise the Borough (such as 70% of the borough being within an AONB, significant affordability pressures and the falling trend in home ownership). Such a revision could avoid the Plan’s current position that major development in the AONB and loss of Green Belt land is justified, necessary and unavoidable; a position I strongly object to. |
DLP_4514 | Town & Country Housing Group | Paragraph Number(s): 119 in particular but more generally the approach to providing social housing With over 5,000 affordable homes in the Borough we believe we are well placed to respond to the proposals relating to affordable housing within the Local Plan. We applaud the approach the Council is taking. Although we would wish to see an even greater proportion of rented housing to intermediate housing we recognise the approach taken is both commercially sensible whilst addressing a fundamental problem within the Borough. It is imperative that the rented tenure proposed remains as social rent. The affordable rent model within Tunbridge Wells is broken and as the major local provider we can see the impact. The affordable rent model is unaffordable to significant numbers of people within the waiting list. Producing more affordable rent homes using the current definition will not ease the demand. Paragraph Number(s): 66 We would highlight that the Council should recognise that if they seek to provide affordable housing for older people that they focus on 2 key aspects.
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DLP_4447 | James Whitehorn | Housing Needs Study 2018 Housing Needs Assessment Topic Paper Housing Supply and Trajectory Topic Paper I have referred to these documents in my comments on the strategic policies above [TWBC: See comments 4443_4445-4446]. |
DLP_451 | Tetlow King Planning for Rentplus UK Ltd | Please see attached out letter [TWBC: copied below] which requests an update to the SHMA and Housing Needs Study to reflect the NPPF definition of affordable housing including other affordable routes to home ownership. [TWBC: see extract of Ministry of Housing Communities & Local Government letter dated 18 June 2019]. We represent Rentplus UK Ltd, an innovative company providing affordable rent to buy housing for hard-working people aspiring to home ownership. Rentplus provides an accessible route to achieve their dream through the rent - save - own model, renting at an affordable rent and a gifted 10% deposit upon purchase. Rentplus have been recognised by the National Housing Awards as the most innovative Home Ownership Scheme for 2019. We previously responded to the Local Plan Issues and Options Consultation in June 2017. The Rentplus model of affordable rent to buy, aims to help those hard-working families unable to access ownership either through shared ownership, starter homes or homes on the open market to overcome the mortgage ‘gap’. This is achieved through a defined period of affordable rent, during which all Rentplus residents are able to save. Since our last comments, the National Planning Policy Framework has been revised as expected to incorporate a wider definition of affordable housing, now providing four categories; rent to buy is included within category d) Other affordable routes to home ownership. Each scheme delivered by Rentplus offers a unique, affordable route to home ownership through affordable rented housing, set at the lower of 80% market rate (affordable rent) or LHA, including any service charge, with a planned route to ownership at years 5, 10, 15 or 20 after first occupation. The most important difference to other affordable tenures is that families are able to save for a mortgage deposit while renting the same home at an affordable - intermediate rent, with a 10% gifted deposit to assist with the purchase. The new Housing Minister, Esther McVey highlighted the importance of Rent to Buy in her first speech to the RESI Convention (12th September 2019) 1. The speech is accessible via https://www.gov.uk/government/speeches/resi-convention-2019 2 The report is accessible via www.affordablehousingcommission.org. In talking about the Government’s drive to increase home ownership she stated that it includes “Rent to Buy, so people can rent knowing that they are going to buy, knowing that they’ve got a bit of breathing space, maybe it’s in 5 years, maybe it’s in 10 years, but they will get to own that property - so they can plan, knowing they have the certainty of getting a deposit and getting that house.” These supportive comments concisely summarise the Rentplus model described above which currently provides a home for 650 households across the UK. Her comments not only reinforce the NPPF provision for additional affordable housing routes to home ownership, but also endorses directly the work of Rentplus. A further recent development - The Affordable Housing Commission, chaired by one of the pre-eminent voices on affordable housing, Lord Best, published its interim report Defining and Measuring housing affordability – an alternative approach in June 20192. This was produced in response to the difficulties that the standard measure of affordability, comparing house prices to incomes, poses in recognising housing stress and affordability across the housing spectrum. The report proposes recalling the approach of measuring affordability by reference to rents or purchase costs exceeding one third of household income (for those in work) in order to better pose a pro-active and interventionist response to housing difficulties. This follows recent work which suggests that the probability of housing stress increases with housing costs exceeding a quarter of gross income on rent. The Commission also highlights the findings of numerous surveys which state that the majority of tenants and adults living with parents aspire to own their own home; of the 5.5m ‘frustrated first time buyers’, 1.6m are in the private rented sector. This group is one of four the report identifies as having particular needs and housing stresses, and who can’t buy “mainly because of the time needed to save for large deposits”. These numbers represent an increase of 0.6 million renters since 2010, many of whom are paying over 40% of household income on rent. The report recognises the well-known problem that many households in the private rented sector are likely to have multiple affordability issues, exacerbated by insecurity of tenure and poor-quality living standards. The report states that “good quality homes of the right size for the household is seen as a basic minimum”; while this is a generally accepted principle in the delivery of housing, and in particular of affordable housing across England, this can be difficult to achieve through the planning system which does not adequately reflect the variations in household needs. The decrease in the numbers of households able to access home ownership is in large part due to the time taken to save for a mortgage deposit without the help of the ‘Bank of Mum and Dad’. The Affordable Housing Commission notes that “those just able to buy are likely to have to save for an unrealistic period or unlikely ever to be able to raise an adequate deposit” – for the purposes of assessing the numbers of would-be purchasers, the Commission ‘cuts off’ the savings period at ‘just’ five years. The difficulty in saving for a deposit is one of the most critical barriers to home ownership, and the focal point for Rentplus – providing a clear route and time period for working households, including those with children, to save. Using the Commission’s proposed measure of affordability would better capture the needs of struggling first-time buyers, many of whom are otherwise likely to remain trapped in insecure private rented sector accommodation. Policy H5 – Affordable Housing Policy H5 relates to affordable housing. The supporting text reflects the affordable housing definition from the NPPF which includes Rent To Buy, this is welcomed. However, the draft Local Plan does not reference the NPPF requirement to provide at least 10% of affordable homes as ‘other affordable routes to home ownership’. Policy H5 outlines the Council’s preferred tenure mix for affordable housing, with 60% provided as social rent and 40% as intermediate tenures. We would like to see Rent to Buy identified within the ‘other affordable routes to home ownership’ as identified in the definition of affordable housing in Annexe 2 of the NPPF. Despite the period of affordable rent, Rent to Buy is not an intermediate tenure and the term intermediate is no longer referenced in the NPPF. We recommend that the tenure mix breaks these percentages down further, with specific reference to a percentage allocated for ‘other affordable routed to home ownership, including Rent To Buy. We recognise that the SHMA which forms part of the evidence base for this Local Plan was published prior to the adoption of the NPPF revision in 2018 when the affordable housing definition was widened. As such, we recommend that a SHMA update should be carried out, encompassing all tenures of affordable housing in accordance with the NPPF definition which would enable the Council to outline an appropriate affordable housing tenure mix including Rent to Buy. The SHMA update should follow the Lichfields Model (attached for information). The policy and supporting paragraphs should then be updated further. We acknowledge that the draft Local Plan is also supported by a Housing Needs Study. The study outlines the Borough’s existing housing stock and identifies 63 Rent To Buy Properties. Despite this, the identified affordable housing need is still only split in terms of tenure into Social/Affordable rented and Intermediate. As with the above SHMA, this study should be updated to fully reflect the NPPF definition of affordable housing which includes Rent To Buy. The Rentplus model offers the opportunity for the Council and RPs to diversify the local housing offer without further recourse to public subsidy. The affordable rented period provides local families with security of tenure, with certainty of management and maintenance by a local partner RP, and critically the opportunity to save towards purchase. As affordable rent to buy meets needs for affordable rent (the only difference being marked by the expectation by all parties of purchase), it comes with a significant benefit of freeing up existing affordable rented homes for others in priority need, as demonstrated by Rentplus schemes across England. Rentplus undertakes rigorous affordability testing of potential purchasers to ensure that this is a realistic expectation and can be achieved within the set timeframes of five to 20 years. This means that substantial discounts at the point of purchase are not required, as it is the inability to save for a mortgage deposit or other financial issues that prevents a significant number of households from accessing ownership, and not the ability to service a mortgage over the long term. Working with local authorities to meet local priorities is critical to the success of the Rentplus model of affordable rent to buy, as helping hard-working local families access ownership reduces the pressure on the housing waiting list, freeing up local authority and housing association time to focus on meeting priority needs for social and affordable rented homes. Rentplus can assist in meeting local need, allocating all of its residents through the Housing Allocation Scheme; by enabling real savings to be built while renting at an affordable rent the Council can help meet the needs of low and middle income households, providing greater choice and flexibility in the planning system. The Council’s work to understand the potential delivery of affordable housing is supported. Should officers wish to discuss how best to facilitate the Rentplus model, please do get in touch. |
Strategic Housing Market Assessment
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_1120 | John Hurst | |
DLP_6832 | Mrs Carol Richards | Sevenoaks and Tunbridge Wells Strategic Housing Market Assessment (SHMA) The Planning process is a great vehicle to help solve some of the future issues in the coming decades-particularly the increasing elderly population and the issues regarding homes, health and wellbeing. Enabling this section of the population to live useful independent lives if planned well, could relieve the strain on social services with appropriate housing, and free up family homes in commuter belt areas. Paragraph 47 in the NPPF outlines that to significantly boost the supply of housing, local planning authorities (amongst other things) should use their evidence base to ensure that their Local Plan meets the full, objectively-assessed needs for market and affordable housing in the housing market area, as far as is consistent with the policies set out in the NPPF. In regard to housing mix, the NPPF sets out that local authorities should plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community. Planning authorities should identify the size, type, tenure and range of housing that is required in particular locations reflecting local demand. Although the SHMA is dated 2015 and therefore somewhat out of date, it does say:-- 1.30 The SHMA indicates’ that the population of persons aged over 65 accounts for 18% of the population in Tunbridge Wells; and 20% in Sevenoaks. The number of residents aged over 65 is expected to grow substantially – by 49% in Sevenoaks and 61% in Tunbridge Wells to 2033, with particularly strong growth expected in those aged over 75, driven by improving life expectancy.’ 1.31 A growing older population and increasing longevity is expected to result in a substantial growth in people with dementia and mobility problems. Across the two areas, the number of people with mobility problems is expected to increase by over 6,000; with an increase of more than 2,500 persons with dementia projected (based on the SNPP) to 2033. Some of these households will require adaptions to properties to meet their changing needs whilst others may require more specialist accommodation or support – including Lifetime and wheelchair-accessible homes. There is clear evidence of need for properties which are capable of accommodating people’s changing needs. Specialist housing includes sheltered and extra care housing. Based on the expected growth in population of older persons, the SHMA estimates a need for an additional 1,400 dwellings for older persons in T. Wells covering the period 2013-2033 Some older households may wish to downsize, suitable, attractive properties should be available locally. The SHMA report emphasises the demographics of the LP area. Table 13 shows the population in the T.Wells area is estimated to be 134,669. By 2033 the population of the 60+ age group between T. Wells and Sevenoaks to be 85,175-Tunbridge Wells is expected to see a greater ageing of the population and lower growth in the number of younger people and those of working age. This figure is believed to be about 43,000 in number, maybe slightly more.85175 (divided by 2 as it is the S’oaks and TWells). This represents 32% of the population being 60+. Para 7.32 of the SHMA (2015) states. “Our experience when carrying out stakeholder work as part of SHMA commissions typically identifies a demand for bungalows. Where developments including bungalows are found it is clear that these are very popular to older people downsizing. It should be acknowledged that providing significant numbers of bungalows involves cost implications for the developer given the typical plot size compared to floor space – however providing an element of bungalows should be given strong consideration on appropriate sites, allowing older households to downsize while freeing up family accommodation for younger households” Yet Table 4.2 p35 of the T. Wells Borough Housing Needs Study 2018 shows T. Wells Borough has only 4.8% of its housing stock to be bungalows compared to 31.6% in Tonbridge and Malling and 25% in Sevenoaks and Maidstone. I would like TWBC to look at this issue as building of bungalows should be a priority. Bungalows can be designed to be level access throughout allowing for both disabled persons and those with limited mobility to live in a safer environment for longer -this will save KCC Social Services huge amounts of money in future years. So why can’t for example TWBC look at site 134 and 75 both of which are in Flood Zone 1 (100%) they are both surrounded by existing other houses, both could be used as a cul de sac for bungalows for 60+ persons? The reasons for unsuitability are not valid when other houses have been build around these sites -so any reasons for example say ‘ arcadian site’ are ridiculous, a tree preservation -so incorporate it into the landscape -footings for bungalows are not as deep as a multiple storey, bungalows can be easily hidden from view as they are single storey, It seems the council can apply rules when they think it is necessary and then drop them when it suits them e.g Tudeley. Look at the site 15 in Goudhurst in Flood zone 1 (100% small site), has a good hedge to screen from the road, 12 semi detached 2 bed bungalows would fit well into this site -providing local people- wishing to down size- a chance to stay in the village. It is in part- in the LTB, in the village, near a pub and tearoom. TWBC should be talking to Parish councillors getting local agreements for small scale developments of this kind-many small villages could welcome this type of development-especially with local involvement. This process is of course a lot more effort- but far more beneficial and would bring real consultation with local people- spread around the borough with good bus routes and small local shops. The Housing Needs Assessment Topic Paper states (para 115): “The NPPF requires local plans to promote small and medium sizes sites as a means of meeting the housing requirement of an area to ease over-reliance on large sites that often take time for delivery to start. As such, local planning authorities should aim to: “identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare; unless it can be shown, through the preparation of relevant plan policies, that there are strong reasons why this 10% target cannot be achieved; (para 68)” It can be achieved, look at my example. Instead TWBC propose a massive development in totally unsuitable areas because it is easy. With the constraints in TWB Green belt/ANOB/ Flood Risk and an aging population, think of who you are building for by 2036-think local-taking the easy way out is not the answer. In fact, think and take more time to develop a safer strategy that will be a legacy, not a blot on the landscape and cause misery for Tonbridge, Tudeley, Five Oak Green and Paddock Wood residents. |
DLP_451 | Tetlow King Planning for Rentplus UK Ltd | Please see attached out letter [TWBC: copied below] which requests an update to the SHMA and Housing Needs Study to reflect the NPPF definition of affordable housing including other affordable routes to home ownership. [TWBC: see extract of Ministry of Housing Communities & Local Government letter dated 18 June 2019]. We represent Rentplus UK Ltd, an innovative company providing affordable rent to buy housing for hard-working people aspiring to home ownership. Rentplus provides an accessible route to achieve their dream through the rent - save - own model, renting at an affordable rent and a gifted 10% deposit upon purchase. Rentplus have been recognised by the National Housing Awards as the most innovative Home Ownership Scheme for 2019. We previously responded to the Local Plan Issues and Options Consultation in June 2017. The Rentplus model of affordable rent to buy, aims to help those hard-working families unable to access ownership either through shared ownership, starter homes or homes on the open market to overcome the mortgage ‘gap’. This is achieved through a defined period of affordable rent, during which all Rentplus residents are able to save. Since our last comments, the National Planning Policy Framework has been revised as expected to incorporate a wider definition of affordable housing, now providing four categories; rent to buy is included within category d) Other affordable routes to home ownership. Each scheme delivered by Rentplus offers a unique, affordable route to home ownership through affordable rented housing, set at the lower of 80% market rate (affordable rent) or LHA, including any service charge, with a planned route to ownership at years 5, 10, 15 or 20 after first occupation. The most important difference to other affordable tenures is that families are able to save for a mortgage deposit while renting the same home at an affordable - intermediate rent, with a 10% gifted deposit to assist with the purchase. The new Housing Minister, Esther McVey highlighted the importance of Rent to Buy in her first speech to the RESI Convention (12th September 2019) 1. The speech is accessible via https://www.gov.uk/government/speeches/resi-convention-2019 2 The report is accessible via www.affordablehousingcommission.org. In talking about the Government’s drive to increase home ownership she stated that it includes “Rent to Buy, so people can rent knowing that they are going to buy, knowing that they’ve got a bit of breathing space, maybe it’s in 5 years, maybe it’s in 10 years, but they will get to own that property - so they can plan, knowing they have the certainty of getting a deposit and getting that house.” These supportive comments concisely summarise the Rentplus model described above which currently provides a home for 650 households across the UK. Her comments not only reinforce the NPPF provision for additional affordable housing routes to home ownership, but also endorses directly the work of Rentplus. A further recent development - The Affordable Housing Commission, chaired by one of the pre-eminent voices on affordable housing, Lord Best, published its interim report Defining and Measuring housing affordability – an alternative approach in June 20192. This was produced in response to the difficulties that the standard measure of affordability, comparing house prices to incomes, poses in recognising housing stress and affordability across the housing spectrum. The report proposes recalling the approach of measuring affordability by reference to rents or purchase costs exceeding one third of household income (for those in work) in order to better pose a pro-active and interventionist response to housing difficulties. This follows recent work which suggests that the probability of housing stress increases with housing costs exceeding a quarter of gross income on rent. The Commission also highlights the findings of numerous surveys which state that the majority of tenants and adults living with parents aspire to own their own home; of the 5.5m ‘frustrated first time buyers’, 1.6m are in the private rented sector. This group is one of four the report identifies as having particular needs and housing stresses, and who can’t buy “mainly because of the time needed to save for large deposits”. These numbers represent an increase of 0.6 million renters since 2010, many of whom are paying over 40% of household income on rent. The report recognises the well-known problem that many households in the private rented sector are likely to have multiple affordability issues, exacerbated by insecurity of tenure and poor-quality living standards. The report states that “good quality homes of the right size for the household is seen as a basic minimum”; while this is a generally accepted principle in the delivery of housing, and in particular of affordable housing across England, this can be difficult to achieve through the planning system which does not adequately reflect the variations in household needs. The decrease in the numbers of households able to access home ownership is in large part due to the time taken to save for a mortgage deposit without the help of the ‘Bank of Mum and Dad’. The Affordable Housing Commission notes that “those just able to buy are likely to have to save for an unrealistic period or unlikely ever to be able to raise an adequate deposit” – for the purposes of assessing the numbers of would-be purchasers, the Commission ‘cuts off’ the savings period at ‘just’ five years. The difficulty in saving for a deposit is one of the most critical barriers to home ownership, and the focal point for Rentplus – providing a clear route and time period for working households, including those with children, to save. Using the Commission’s proposed measure of affordability would better capture the needs of struggling first-time buyers, many of whom are otherwise likely to remain trapped in insecure private rented sector accommodation. Policy H5 – Affordable Housing Policy H5 relates to affordable housing. The supporting text reflects the affordable housing definition from the NPPF which includes Rent To Buy, this is welcomed. However, the draft Local Plan does not reference the NPPF requirement to provide at least 10% of affordable homes as ‘other affordable routes to home ownership’. Policy H5 outlines the Council’s preferred tenure mix for affordable housing, with 60% provided as social rent and 40% as intermediate tenures. We would like to see Rent to Buy identified within the ‘other affordable routes to home ownership’ as identified in the definition of affordable housing in Annexe 2 of the NPPF. Despite the period of affordable rent, Rent to Buy is not an intermediate tenure and the term intermediate is no longer referenced in the NPPF. We recommend that the tenure mix breaks these percentages down further, with specific reference to a percentage allocated for ‘other affordable routed to home ownership, including Rent To Buy. We recognise that the SHMA which forms part of the evidence base for this Local Plan was published prior to the adoption of the NPPF revision in 2018 when the affordable housing definition was widened. As such, we recommend that a SHMA update should be carried out, encompassing all tenures of affordable housing in accordance with the NPPF definition which would enable the Council to outline an appropriate affordable housing tenure mix including Rent to Buy. The SHMA update should follow the Lichfields Model (attached for information). The policy and supporting paragraphs should then be updated further. We acknowledge that the draft Local Plan is also supported by a Housing Needs Study. The study outlines the Borough’s existing housing stock and identifies 63 Rent To Buy Properties. Despite this, the identified affordable housing need is still only split in terms of tenure into Social/Affordable rented and Intermediate. As with the above SHMA, this study should be updated to fully reflect the NPPF definition of affordable housing which includes Rent To Buy. The Rentplus model offers the opportunity for the Council and RPs to diversify the local housing offer without further recourse to public subsidy. The affordable rented period provides local families with security of tenure, with certainty of management and maintenance by a local partner RP, and critically the opportunity to save towards purchase. As affordable rent to buy meets needs for affordable rent (the only difference being marked by the expectation by all parties of purchase), it comes with a significant benefit of freeing up existing affordable rented homes for others in priority need, as demonstrated by Rentplus schemes across England. Rentplus undertakes rigorous affordability testing of potential purchasers to ensure that this is a realistic expectation and can be achieved within the set timeframes of five to 20 years. This means that substantial discounts at the point of purchase are not required, as it is the inability to save for a mortgage deposit or other financial issues that prevents a significant number of households from accessing ownership, and not the ability to service a mortgage over the long term. Working with local authorities to meet local priorities is critical to the success of the Rentplus model of affordable rent to buy, as helping hard-working local families access ownership reduces the pressure on the housing waiting list, freeing up local authority and housing association time to focus on meeting priority needs for social and affordable rented homes. Rentplus can assist in meeting local need, allocating all of its residents through the Housing Allocation Scheme; by enabling real savings to be built while renting at an affordable rent the Council can help meet the needs of low and middle income households, providing greater choice and flexibility in the planning system. The Council’s work to understand the potential delivery of affordable housing is supported. Should officers wish to discuss how best to facilitate the Rentplus model, please do get in touch. |
| DLP_8429 | Euan Burrows, Mockbeggar Lane and group of East End residents | Introduction
The Sustainability Appraisal (‘SA’)
“All sites submitted to the Council’s Call for Sites process were assessed against a robust methodology which is set out in the Strategic Housing and Economic Land Availability Assessment (SHELAA). This included all sites received through two Call for Sites processes and sites received since then but prior to the 22nd February 2019 (known as ‘late sites’ or ‘additional sites’ and ‘A_S’ on all figures in this chapter).”
“* Located in remote locations away from existing settlements; such sites considered unlikely to be sustainable in this context; in some instances some remote sites have been considered in the context of a new garden settlement where applicable or as urban extensions; (Bullet Point 1)
Strategic Housing and Economic Land Availability Assessment (‘SHELAA’)
“The outcomes of the SHELAA should be to identify sites and broad locations with potential for development, assess their development potential, assess their suitability for development and the likelihood of development coming forward.”
Policy AL/BE4
The Principle of Development
[1] This is the same list applied to the SHELAA filtering process (paragraph 3.23 SHELAA) although different results were achieved, as commented on below [2] Sites 424 and AS_40 are included in the analysis of AS_41 [3] Ref: 17/00951/FULL [4] https://www.gov.uk/guidance/housing-and-economic-land-availability-assessment [5] Table 6 SA [6] Noting the inaccurate statement in the Local Plan that there are educational facilities on the site [TWBC: this response has been duplicated under Section 5: Benenden (Policy AL/BE4), Appendix 5 (SHELAA) and the Sustainability Appraisal] |
Housing Supply & Trajectory Topic Paper
Comment No. | Name/Organisation | Response | ||||||||||||||||||||||||
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DLP_8315 | Andrew Richards | INTRODUCTIONI am not a resident of Tunbridge Wells Borough, but I live near to the Borough boundary just outside Tonbridge. I visit the Borough regularly and enjoy the benefits of its countryside, notably the Green Belt and the Areas of Outstanding Natural Beauty, which need to be preserved in line with National Planning Policy. I also drive around Tonbridge regularly and am shocked at the impact the proposals in your draft Local Plan (LP) would have on Tonbridge and its environs. The LP is vast and complex and has clearly consumed a significant amount of effort; I congratulate the officers for their diligence in seeking to balance the various competing demands of policy, legislation and local constraints. As a private individual I do not have similar resources or expertise; I have therefore confined my comments to a small number of topics. This is not to say I endorse the remainder of the LP and its associated material; I am aware of some of the concerns raised by others and support many of them. Notwithstanding the level of effort that has gone into the LP, I’m afraid my overall assessment is that the Borough has fallen short of the diligence needed. Sadly, it seems to have taken the easy way out of its obligations in a number of areas. It has:
I conclude that the Borough has failed to meet the required standard for a Regulation 18 consultation and should repeat the exercise, having first addressed some of the fundamental concerns raised. I believe this plan requires too substantial a series of amendments to proceed directly to a Regulation 19 consultation. My comments are in relation to a number of documents identified below. Housing supply and trajectory paper7. Para 3.1.1: to note, the final sentence states that “the 2014 household projections are to be used when calculating the objectively assessed need via the standard methodology unless required otherwise by the Government”, and offers in evidence footnote 7, which refers to para ref 2a 004020190220 in the Housing and Economic Development Needs Assessment (https://www.gov.uk/guidance/housing-and-economic-development-needs-assessments), which offers no such support. Local planForward – para 38. The draft LP is defective as it omits to show the changes it proposes to the previous Core Strategy 2006. 9. Planning policy requires that:
10. Whilst the LP includes a policies map, that map does not show the ‘delta’ from the previous Core Strategy policies, which in summary were to:
Introduction – Plan preparation process – para 1.411. You state that the Issues and Options process in 2017 sought early views on the best way to approach specific challenges, but it is not clear that these views have been taken into account. 12. For instance, the Consultation Statement (Appendix 1, page 47) stated in relation to the Core Strategy 2020:
13. Specifically, in the consideration of responses to Q13 re the 2010 Core Strategy in the preparation of the Draft Local Plan:
14. How can this be accordance with NPPF when you plan to build on Green belt and all respondents wanted the Green belt protected? How can you state most of the policies have been ‘carried through’?. 15. Again, regarding Settlement Groupings, 202 responses were received to this question. 56 respondents (about 28%) agreed with the suggested settlement groupings, 130 respondents (about 64%) disagreed, while 16 respondents (about 8%) did not express an opinion. Overall, of those who expressed an opinion, the majority of 70% disagreed with the suggested groupings, while 30% agreed. 16. The Plan Process has again ignored these respondents and by planning a garden village at Tudeley with 2,800 planned homes, so I don’t understand how you leapt to the conclusion that this:
17. This is the first time the expansion of Paddock Wood has been identified – the Issues and Options process wholly excluded any mention of a garden settlement at Tudeley. Given that one of the key issues raised as a result of the Issues and Options consultation was the protection of the green belt, the failure to identify at an early stage in the Issues and Options process the potential for a large amount of development in Tudeley (on Green Belt) undermines the soundness of this plan and undermines the effectiveness of this current public consultation. Evidence – paras 1.30 – 1.3318. I object to the assertions made that the LP has been drawn up using an evidence-led approach:
19. It therefore follows that the LP has not been drawn up using an evidence-led approach and is therefore in contravention of national policy. Duty to co-operate – para 1.38 – 1.4420. I object to the assertion that the Borough has discharged adequately its Duty to Cooperate. 21. Planning policy requires that: b. TWBC has failed to establish a statement of common ground with TMBC, the borough most significantly impacted by the proposals under STR/CA 1 and STR/PW 1, most notably the likely traffic congestion and overcrowding of train services from commuters living in the Tudeley garden settlement at AL/CA 1, the likely traffic congestion and risk to life from the school proposed at AL/CA 2, and the likely overcrowding of train services from commuters living in the Paddock Wood garden settlement at AL/PW 1. c. TMBC is on record in objecting to the LP, noting that (letter of 16 Oct 19 from TMBC): d. This failure to agree a statement of common ground with TMBC is not compliant with policy that requires a Duty to Cooperate, “evidenced by the statement of common ground” and demonstrates that the LP is unsound Conclusion39. In conclusion, to reiterate the point made in opening, I conclude that the Borough has failed to meet the required standard for a Regulation 18 consultation. It should therefore repeat the exercise, having first addressed some of the fundamental concerns raised. [TWBC: See full representation] | ||||||||||||||||||||||||
DLP_7095 | Sigma Planning Servicews for Rydon Homes Ltd | 45. The trajectory is too ambitious in terms of the projected delivery of completed dwellings from the proposed large garden community community developments and Paddock Wood and Tudeley and does not recognise the potential for smaller, unconstrained sites to come forward quickly. 46. The suggestion that there will be 150 dwellings completed at Tudeley by 2025/26 is unrealistic given the very formative stage of the proposal and the extent of the infrastructure that must be planned and provided before occupation of housing can occur. A realistic trajectory is not possible at this stage until the details of the extent and timing of infrastructure delivery is more certain and a detailed and realistic phasing programme has been prepared. The trajectory at this stage is aspirational but not sufficiently based on evidence to be relied upon. 47. Similar considerations apply at Paddock Wood. The recent consents for large urban extensions can be expected to be built our in the early part of the plan period but the 4000 new homes in addition that form part of the current draft plan proposals require extensive infrastructure provision and no reliable trajectory can be produced until further details of the timing and practicality of such provision is more certain. An assessment of the housing trajectory and land supply commissioned by Rydon from Neame Sutton is attached and forms part of these representations (APP 1). 48. On the other hand -
Are all smaller unconstrained sites that will utilise spare capacity in existing local infrastructure or make the necessary new provision and do not need to be delayed until the 9-15 year period of the plan beyond 2024/2025. These sites should be put into the trajectory as likely to provide completions from 2021/2022 onwards. 49. Rydon are happy to meet with planning officers to discuss the timing of the delivery in more detail but, particularly in the case of Fowlers Park and Boycourt Orchards where planning applications are in preparation and outline consent is expected to be forthcoming in 2020. This would be 4/5 years into the plan period and will assist in addressing the current five year housing land supply shortfall and maintaining development rates in the early part of the plan period. This fills the gaps whilst the complications of large site delivery are investigated and projected phasing of those sites can be better and more realistically assessed. 61. For all these reasons there is a strong case for the allocation of new housing sites at Finches Farm. 62. The Council has not produced a Strategic Environment Assessment or a full Sustainability Appraisal. The current SA appears to only review sites in isolation against a limited set of 'traffic light' criteria and does not reach the standard of a full SA. There is no understanding or conclusion reached of the cumulative effects of the quantum of development or its distribution across the District. There is also no testing of alternatives as required by the PPG, such as lower or higher housing targets or of different distribution strategies. Appendix 1 1.0 Instructions and Introduction 1.1 Neame Sutton Limited, Chartered Town Planners, is instructed by Rydon Homes Limited ("Rydon") to prepare representations on the soundness of the Tunbridge Wells Borough Local Plan Regulation 18 consultation version ("the Plan"). 1.2 This Technical Note focuses specifically on the following matters:
1.3 The Plan has been prepared in the context of the Government policy set out in the National Planning Policy Framework ("the Framework 2019") and in this respect the minimum Local Housing Need figure generated using the Standard Method is the figure against which the housing trajectory and consequent 5-year housing land supply position is calculated. 1.4 This Technical Note has therefore been prepared having regard to the Framework 2019 and corresponding National Planning Practice Guidance ("PPG"). 2.0 Housing Trajectory - draft Policy STR1 and Table 1 2.1 Draft Policy STR1 does not actually set out the Local Housing Need figure that the Plan is seeking to meet. This information is contained in Table 1 of the Plan. 2.2 The Plan's housing trajectory is also not set out in the document itself and is instead contained within the Housing Supply and Trajectory Topic Paper - September 2019. The Council's approach to the supply sources that its housing trajectory is reliant upon is explained in the Topic Paper along with its calculation of 5-year housing land supply. 2.3 These representations are therefore based on the evidence contained in the Council's Topic Paper. 2.4 The supply sources the Council relies upon in the trajectory for the Plan are summarised in Table 1 of the Topic Paper (Page 8):
2.5 These supply sources are intended only to meet the Local Housing Need figure calculated via the Standard Method. The Council is not at this stage seeking to address any unmet need arising from neighbouring authorities such as Sevenoaks. 2.6 In giving consideration to the Council's supply sources in its housing trajectory it is important to have regard to the recruitments of National Policy, namely the Annex 2 definitions of deliverability and developability (as supplemented by the PPG). Most notably is the requirement, placed on the Council by Government, to provide 'clear evidence' of deliverability for all proposed housing allocation sites relied upon for the first 5-years of the Plan period2. [2 Annex 2 of Framework 2019 on Page 66 refers] Extant Planning Consents as at 01 April 2019 (Commitments): 2.7 The Council seeks to rely on a total of 3,127 no. dwellings from extant consents. The majority of these dwellings are programmed for delivery by the Council within the current 5-years of the Plan period commencing in the 2019/20 monitoring year. 2.8 Whilst the Council appears to have applied a 10% lapse rate to its small-sites commitment rate (schemes of 1-9 dwellings)3 [3 See Paragraph 13, third bullet on Page 4 of 5-year Housing Land Supply 2018/19 – June 2019] no detailed consideration, in accordance with the Annex 2 requirement, appears to have been undertaken in relation to the large sites component of the commitments. 2.9 On this basis any sites, which benefit only from Outline Consents for 10 or more units should be removed from the current 5 years of the trajectory unless there is clear evidence that completions will be delivered at the point envisaged in the trajectory. 2.10 At this stage and given that the Plan is only at Regulation 18 Stage Neame Sutton has applied a 10% discount to the total Commitment supply to take some account of those sites that fail the clear evidence of deliverability test. The Council should however review all sites in the Context of Annex 2 prior to the Regulation 19 consultation stage. Outstanding Allocations and New Allocations 2.11 The Council is seeking to rely on a total of 9,3974 [4 Figure extracted from trajectory on Pages 25-32 of Housing Supply and Trajectory Topic Paper – September 2019] dwellings coming forward across the the Plan period from a combination of outstanding unimplemented allocations in the extant Local Plan and New Allocations in the Plan. This supply source comprises the majority of the Council's supply for the Plan period. 2.12 Whilst at this Regualtion 18 stage a detailed site-by-site analysis has not been undertaken by Neame Sutton there are two key points to note: 2.12.1 Point 1: The Council is relying on delivery from two strategic scale allocations that are required to provide 1900 dwellings and 4000 dwellings respectively. Whilst the Council has set out the evidence it has relied upon for the projected delivery rates from these sites in the Topic Paper it has also freely accepted that it has no experience of delivering development on this scale5 [5 See Paragraphs 4.10.1 and 4.11.1 on Pages 19 and 20 of Housing Supply and Trajectory Topic Paper – September 2019]. 2.12.2 The Council should therefore be taking a cautious approach to the delivery trajectory for these two sites. It is clear however from the trajectory in the Topic Paper that this is not the case. For example the Council expects the Paddock Wood site to deliver 333 no. dwellings in its first year and to continue this level of completion year on year though until the end of the Plan period. This is simply unrealistic. 2.12.3 An adjustment has therefore been made to reflect the empirical evidence contained in the research report prepared by Lichfields6 [6 See Lichfields – Start to Finish: How Quickly do Largescale Housing Sites Deliver – November 2016] and referred to by the Council, namely that the maximum reasonable delivery from a site of this scale of 161 dpa. 2.12.4 Point 2: There is an apparent inconsistency between the Council's approach to the delivery from site allocations in its trajectory within the Topic Paper and the approach to the site allocations applied to its 5-year housing land supply calculation in the Five Year Housing Land Supply 2018/19 document. The latter document applies a blanket 10% reduction to the delivery expected from allocations whilst the former expects 100% delivery. 2.12.5 In Neame Sutton's view and, before undertaking a site-by-site analysis in the context of the Annex 2 definition, a 10% reduction should be applied to all allocations relied upon in the current 5-year period of the housing trajectory. Windfalls: 2.13 The Council places relatively heavy reliance upon windfalls to help meeting the minimum local housing need for the Plan period. A total of 700 no. dwellings are relied upon at a rate of 50 dpa spread across a period of 14 years commencing in 2022/23 monitoring year. 2.14 Whilst the evidence fora windfall provision is set out in the Topic Paper, it is important to note the following points: 2.14.1 Point 1: The Council's evidence in the Topic Paper is based primarily on historic trend data. In a Borough that is constrained by Green Belt and, in the absence of an up-to-date Local Plan, the historic trend data is likely to contain higher windfall rates than will prevail in the future. 2.14.2 Point 2: The Council seeks to rely on 100 dwellings from windfalls in the current 5-year period yet no compelling evidence has been presented as required by Paragraph 70 of the Framework 2019 to demonstrate that this is a reliable source for delivery in the first 5-years. This component of supply should be removed. 2.15 As a result of the above headline points the affect on the Council's supply sources is summarised in the table below: Table 1: Summary of Amendments Made to Council's Supply Sources:
*10% reduction to allow for flexibility **10% reduction to allocations in current 5-year period and adjustment to strategic site delivery expectations in line with empirical evidence ***remove of 100 dwellings from current 5-year period 2.16 The affects of the above amendments on the Council's housing trajectory is demonstrated in Tables 1 and 2 attached at Appendix 1 of this Note. Application of the Appropriate Buffer (Paragraph 73 of the Framework 2019): 2.17 In addition to the above points relating to supply and given that this Plan is being progressed in compliance with the Framework 2019 the Council should have tested its trajectory on the basis of a 10% buffer applied in accordance with Paragraph 73 b). Instead the Council has only applied a 5% buffer, which cannot be correct where it will seek, in due course, to place reliance on the safeguard in footnote 38 of the Framework that is afforded to a recently adopted Plan. 2.18 A 10% buffer should therefore be applied to the housing requirement figure in the trajectory. 3.0 5-Year Housing Land Supply 3.1 The Council's housing trajectory set out in the Topic Paper does not provide a rolling 5-year supply calculation so it is not possible to ascertain whether the Plan will deliver and maintain a 5-year supply as required by the Framework 2019. 3.2 The only 5-year supply calculation provided by the Council is set out in Five Year Housing Supply 2018/19 document, which is clearly out-of-date. 3.3 Neame Sutton's Table 1 in Appendix 1 of this Note provides a rolling 5-year supply calculation based on the Council's own data and appears to confirm a relatively healthy positive position. 3.4 However, when the adjustments are made to the Council's supply sources as set out in Section 2 of this note the supply position alters dramatically. 3.5 Table 2 in Appendix 1 sets out the rolling 5-year housing supply position with the supply sources amended and confirms that at no point during the Plan period will the Plan deliver a positive 5-year supply position. 3.6 It is important to note that this position will persist even if one was not to apply all of the adjustments set out in Section 2 of this Note. 3.7 The Plan therefore fails the key soundness test of planning positively and in accordance with National policy to help significantly boost the supply of housing. 4.0 Conclusions on Soundness of Plan 4.1 On the basis of the headline assessment undertaken in this Technical Note it is apparent that the housing trajectory proposed for the Plan will not deliver a rolling 5-years supply of deliverable housing sites and as a consequence the Plan is unsound as currently drafted. 4.2 The solution for the Council is a simple one. Further site allocations are required to ensure adequate delivery of the right sites at the right time to ensure a robust housing delivery trajectory and consequently a positive rolling 5-year supply position. [TWBC: See full response] | ||||||||||||||||||||||||
DLP_7961 | Wendy Owen | Given the challenges acknowledged in many places facing the borough, and the proposals to release Green Belt and build on AONB land, it is not at all clear why the Draft Local Plan proposes to build more dwellings than is actually required. We have already set out in our response why we consider the number is too high in the first place based on population growth projections. For TWBC to propose even more dwellings are built seems very strange. We strongly recommend the final draft of the plan should reduce the number of dwellings to the required level and remove sites from the plan based on the sensitivity of the site. We note that according to correspondence with the developer, the plan anticipates build-out rates for Policy AL/RTW 18 / site 137 will commence in 2024 and run until 2028. However we also note that the proposed secondary school will be built post 2030 (see Infrastructure Delivery Plan). If development on this site does go ahead, no housing should be permitted until the school is complete. Not only will this preserve the AONB/Green Belt in the meantime, but it also ensures the developer at least part funds the build of the school and this will not necessarily be the case if the homes have already been built – the developer could cease trading between 2028 and post 2030. | ||||||||||||||||||||||||
DLP_4447 | James Whitehorn | Housing Needs Study 2018 Housing Needs Assessment Topic Paper Housing Supply and Trajectory Topic Paper I have referred to these documents in my comments on the strategic policies above [TWBC: See comments 4443_4445-4446]. |
Infrastructure Delivery Plan
Comment No. | Name/Organisation | Response | |
|---|---|---|---|
DLP_1903 | Royal Tunbridge Wells Town Forum | Topic Paper or supporting document title: SHELAA Site Assessment sheets for Royal Tunbridge Wells We previously submitted detailed comments on a number of the sites submitted under the Call for Sites which might become subject to an allocation. We set out those comments again under each specific AL/RTW Policy in relation to the sites now proposed for allocation in the Draft. So far as sites which were considered unlikely to be allocated and have now not been allocated for future development, we set out our comments in Appendix 6. Town Forum policy is that development in the AONB and Green Belt should take place only on proof of exceptional circumstances. Any evidence put forward of exceptional circumstances will have to satisfy the Inspector at Examination in accordance with relevant legal precedent. In the very difficult circumstances of the current unsatisfactory relationship between Central Government and Local Authorities and subject to the important caveat above, we are broadly supportive of most of the sites now selected for allocation in the unparished area of Royal Tunbridge Wells, subject in many cases to conditions. We also strongly support decisions taken on those submitted sites deemed unsuitable for allocation as set out in our comments in Appendix 6. Full comments on sites proposed for allocation appear in our response to the AL/RTW Policies ante. This is subject also to the caveat that we do not agree with the method by which Central Government calculates housing need and the consequent target housing numbers. In particular, the Office for National Statistics produced a revised 2016 methodology, which in the case of Tunbridge Wells Borough would require only 67% of the 2014 figure, according to some analysts. The government-imposed methodology and fears of the Draft Local Plan being found unsound at Public Examination have perhaps led TWBC not to seek fully to exploit potential constraints recognised by the NPPF in relation to the 70% of the Borough which is classified as AONB and the 22% which is classified as Metropolitan Green Belt and also infrastructure constraints such as acknowledged severe existing water stress and problems with waste water treatment. The approach taken in this Regulation 18 Draft has resulted in some draft allocations in RTW and elsewhere in the Borough which are intrusive into Green Belt and AONB. We would therefore urge TWBC to keep carefully under review the legislation and any legal precedents and Inspectors’ decisions arising under the legislation in the period up to submission of the Regulation 19 Draft in relation to exceptional circumstances and housing need methodology, in case some mitigation of proposed incursions into the AONB and Green Belt may be possible. Topic Paper or supporting document title: Infrastructure Delivery Plan Please see our comments on infrastructure delivery in relation to individual Policies above Topic Paper or supporting document title: Transport Strategy Review Please see our comments under the TP Policies above. Topic Paper or supporting document title: Transport Study Please see our comments under the TP Policies above. | |
DLP_4651 | Ann & John Furminger | 3.22 Table 2 Draft Infrastructure Where is the research on numbers for Staplehurst, Marden, and Etchingham which is where residents of Hawkhurst, Cranbrook and Sissinghurst, Goudhurst and Frittenden will commute from? | |
DLP_7966 | Wendy Owen | The IDP states the Spratsbrook site (AL/RTW 18 / site 137) is reserved until post 2030 for a new secondary school. Notwithstanding our significant objections to developing site 137 in the first place, if, come 2030, it transpires there is no need for a new school, TWBC should publicly commit to leave the whole site undeveloped. In addition, the IDP states the new secondary school should be 6FE (form entry classes) whereas the place shaping policy states it will be a 7FE school. The plan should be consistent on these things. | |
DLP_3942 | Mrs June Bell | 2.11 | |
DLP_7241 | Elizabeth Daley | Draft Infrastructure Delivery Plan 3.22 Table 2 3.36. ‘Requirement for parking has still not been identified’ There is recognition that parking is an issue at stations, but no plans have been made to address this and there are no figures on requirement. No bus service improvement is planned for the Parish of Cranbrook and Sissinghurst, despite the Parish massively under the planned allocations.. | |
DLP_6867 | John Gibson | Draft Infrastructure Delivery Plan Section 3 Paragraph 22 Table 2 There are no research figures provided for Staplehurst railway station which is where most new residents will commute from. Section 3 Paragraph 36 There is no mention of any improvement to the local public bus service. | |
DLP_8281 | Ann Gibson | Where is the research on numbers for Staplehurst Station which is where residents of Cranbrook and Hawkhurst will commute from? | |
DLP_8087 | Department for Education | 22. TWBC has produced an updated Infrastructure Delivery Plan (August 2019). Based on the proposed growth in TWBC, the IDP sets out the additional permanent capacity is needed to meet the need for school places, based on pupil projections. It would be helpful if the evidence base for the pupil projections could be included/published in order to understand the basis for this, and to demonstrate the likely population generated by the planned residential development. The IDP also includes indicative costs for the provision of new primary and secondary schools. It would be helpful to understand the basis for these indicative costs, to ensure that the assumptions are sufficient and provide robust evidence when seeking Developer Contributions. 23. The IDP should be regularly reviewed to ensure that it is accurately reflecting the latest data on pupil projections, school place need and to reflect school expansions and new school openings. The IDP should also be reviewed and monitored to assess data in relation to developer obligations received for education. 24. Given the significant cross-boundary movement of school pupils between TWBC and adjoining areas (particularly given the two-tier system as TWBC is not the Education Authority), as referenced in the IDP, DfE recommends that the Council covers this matter and progress in cooperating to address it as part of its Statement of Common Ground.8 This should be regularly updated during the plan-making process to reflect emerging agreements between participating authorities and the Council's own plan-making progress. Developer Contributions and Community Infrastructure Levy (CIL) 25. One of the tests of soundness is that a Local Plan is ‘effective’, meaning the plan should be deliverable over its period. In this context and with specific regard to planning for schools, there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments. DfE notes that TWBC have produced a Planning Obligations SPD which will need to be updated to reflect Local Plan priorities and the 2019 CIL Regulations. 26. Local authorities have sometimes experienced challenges in funding schools via Section 106 planning obligations due to limitations on the pooling of developer contributions for the same item or type of infrastructure. However, the revised CIL Regulations remove this constraint, allowing unlimited pooling of developer contributions from planning obligations and the use of both Section 106 funding and CIL for the same item of infrastructure. The advantage of using Section 106 relative to CIL for funding schools is that it is clear and transparent to all stakeholders what value of contribution is being allocated by which development to which schools, thereby increasing certainty that developer contributions will be used to fund the new school places that are needed. DfE supports the use of planning obligations to secure developer contributions for education wherever there is a need to mitigate the direct impacts of development, consistent with Regulation 122 of the CIL Regulations. 27. We also request a reference within the Local Plan’s policies or supporting text to explain that developer contributions may be secured retrospectively, when it has been necessary to forward fund infrastructure projects in advance of anticipated housing growth. An example of this would be the local authority’s expansion of a secondary school to ensure that places are available in time to support development coming forward. This helps to demonstrate that the plan is positively prepared and deliverable over its period. 28. DfE would be particularly interested in responding to any update to the Infrastructure Delivery Plan/Infrastructure Funding Statement, viability assessment or other evidence relevant to education which may be used to inform local planning policies and potential future CIL charging schedules should TWBC determine to proceed with CIL. As such, please add DfE to the database for future consultations on relevant plans and proposals. | |
DLP_8188 | Highways England | Whole IDP It would assist to include a map of the borough showing key infrastructure locations. This could be via different colour dots for each type of infrastructure. It would also assist in seeing the complete picture and any implications for the timing of infrastructure delivery. While the themes are helpful, the Plan/IDP should also ensure that a holistic approach is taken. For example, to ensure the transport implications of the delivery of education, health, energy or communications provision in particular locations are assessed at the outset. Theme 1 Transport Text should be included to acknowledge that mitigation required as a result of development within the Borough may be located beyond its boundary; for example, at the Flimwell Crossroads. Table 1 Equestrians should be included under transport. TWBC: see Technical Note. See also full representation.] | |
DLP_3730 | Capel Parish Council | Theme 2 Education In relation to Secondary Schools, under ‘Current planned provision’ from paragraph 3.71 (p.31-32) it is stated that provision for “One FE expansion of Mascalls Academy for 2021-22” is planned to meet existing needs. Further down p.32 the IDP details ‘Additional future requirements needed to deliver growth proposed in the Draft Local Plan’ have been identified as “Up to eight FE new Secondary School to be provided on land at the garden settlement at Tudeley Village and further expansion of Mascalls Academy at Paddock Wood”. There is no further detail; however, capacity at Mascalls Academy can only be increased by a finite amount due to location constraints. This, therefore, makes the development of 4,000 houses in East Capel (AL / CA 3 and AL / PW 1) unsustainable as many children will be required to travel to the planned new Secondary School at Tudeley. TWBC acknowledges that there are serious constraints; in the dLP under Policy AL/CA 3 & AL/PW 1 it states that “Development at this site is subject to the provision of land for the expansion of Mascalls” As the location of the potential land for expansion appears unknown, the proposed development is therefore unsustainable. The development at East Capel should be removed from the dLP unless there is certainty that sufficient Education provision can be made. Please also see our comments in COMMENT BOX 2 under the heading ‘Strategic Objective 5: Essential Infrastructure and Connectivity’ | |
DLP_8214 | Mrs Suzi Rich | Topic Paper or supporting document title: Comments on the Distribution of Development Topic Paper Chapter 3: Development Constraints (p.4) Chapter 5: Issues and Options consultation (p.11) Paragraph 5.6 summarises the main outcomes of the consultation for the question relating to the five strategic options for delivery presented in the Issues and Options document. Only 18% ranked Option 5 (new freestanding settlement) as their most preferred approach. It is submitted that this would have been even less if the site/sites now proposed at AL/CA 1 and AL/CA 3 & AL/PW 1 had been identified at that time. Appendix 1 to The Issues and Options Consultation Statement, available on the Tunbridge Wells Borough Council website at https://beta.tunbridgewells.gov.uk/local-plan/issues-and-options, lists the Strategy Considerations at Section 5 (p.26-39). It is clear from p.33, that by far the largest level of support was 60% for Option 4 (Growth Corridor led approach). However, p.39 of the same document states that “A level of support was indicated in the Issues and Options responses for a new settlement.” This is misleading. The Consultation Statement goes on to consider the responses to question 10 and 10a relating to preferences for a combination of Options (p.35). The first bullet point states that the responses indicate that it is worth “Exploring further the potential for ‘new settlement growth’, as this was the most commonly preferred (alone or in combination) of all the options”. The statement is blatantly not true! Paragraphs 5.7-5.8 cover question 11/11a, which asked for views about the possibility of a new settlement somewhere in the borough and suggestions for possible locations. It lists the key issues referred to across the response groups, which include:
These views have been completely ignored by TWBC! They should carry weight and should have informed the decision on the strategic site proposals. Paragraphs 5.9-5.10 cover question 12/12a, which asked whether all reasonable options for accommodating future development growth within the borough have been considered and identified and if not, what other options should be considered. Respondents suggested that the following options should be considered:
Where have these responses been acknowledged in the dLP? Have these options been considered at all? Chapter 6: Formulating the development strategy (p.14) Paragraph 6.2 states “For the second Call for Sites, officers contacted the promotors of sites submitted to the first Call for Sites and identified and then contacted owners of land around settlements (on a ‘without prejudice’ basis) that had not been submitted through the first Call for Sites to enable them to submit sites if they wished. This proactive approach encouraged owners of land that could be suitable for development to submit sites for consideration”. Why were we told by Stephen Baughan at the Capel Annual Parish Meeting that TWBC had no influence on what sites were submitted and that the officers just had to work with what appeared in the Call for Sites! Paragraph 6.2 also expressly states that the second 'Call for Sites' was undertaken between May and June 2017. In the Interim New Local Plan Strategic Housing & Economic Land Availability Assessment 2017. It was stated “although the call for sites remains open, it will no longer be possible to include any new sites within the site assessment process that is informing the Draft Local Plan (being prepared under Regulation 18) AS THERE IS INSUFFICIENT TIME TO ADEQUATELY ASSESS SUCH SITES. (TWBC will continue to accept in order that they may be assessed & potentially included at Reg 19)”. The evidence base persuaded TWBC to opt for Growth Strategy Option 3 (existing urban distribution plus villages) and Option 4 (A21 growth corridor). There was a possibility of Option 5 (new settlement) in the longer term (8 possible sites but 5 not shortlisted including AL/ CA 1). Presumably this underwent a robust process based on robust evidence? This was still the preferred stance March 2018, however in April 2018, there appeared to be a complete change of direction which resulted in the allocation of 60% of the proposed development in the Parish of Capel. Where in the DLP is this new evidence base? When was site 448 (Land at Tudeley) first considered (p.24-30)? Table 2 details TWBC’s Conclusions of the SHELAA and SA on garden settlement options but gives no credible explanation as to why the Tudeley site is considered to be ‘well located’ as required by para 72 of the NPPF. Neither does Table 3 which details the outcome of TWBC’s Consideration of proposed strategic allocation sites against para 72 of the NPPF. This table is misleading and inaccurate. The site is NOT well located. Comments on the Green Belt Study The site at Tudeley (AL/CA 1) falls within Broad Areas BA3 and BA4. The ‘Potential Level of Harm to the Green Belt Associated with Release of Broad Areas BA3 and BA4 is ‘VERY HIGH’ (Figure 1.1 (p.8)) Comments on the Infrastructure Delivery Plan Education Health Under the heading ‘Additional future requirements needed to deliver growth proposed in the Draft Local Plan’ at paragraph 3.104 (p.40) it states that “The Council has not been made aware of any specific requirements over the plan period; however, discussions with the Maidstone and Tunbridge Wells NHS Trust have highlighted potential need for extension of either the Tunbridge Wells Hospital or Maidstone Hospital to serve the West Kent Area over the Plan period” Please also see my comments in COMMENT BOX 2 under the heading ‘Strategic Objective 5: Essential Infrastructure and Connectivity’ Comments on the SWECO Local Plan Transport Evidence Base Figure 9-2 shows the ‘Mitigation Interventions Mapped’ (p.142) which shows the proposed routes for the following ‘highway measures’ detailed in Table 9-2 (p.138): It is suggested building the Colts Hill strategic link is vital to delivery of the proposed new developments in Capel. How will this improve connectivity? It will be a faster, polluting road to nowhere unless the congestion on the A264 and the two roundabouts at Pembury can be dealt with (there are no proposals to do so in the dLP and the Hendys development will make this worse). Traffic to the A21 from Paddock Wood will continue to use the B2017. The A228 strategic link has been mooted for the last forty years, initially as a requirement due to the Channel Tunnel! The whole area surrounding Paddock Wood needs a radical holistic solution. The dualling of the A21 was supposedly going to reduce traffic in this area but as TMBC have discovered, through traffic has actually increased in volume in Tonbridge since the “improvement” [TWBC: See comments DLP_8189-8214 for full representation] | |
DLP_3516 | High Weald AONB Unit | The Local Plan claims to be infrastructure-led but it is just a shopping list. No spatial analysis of need has been provided and as a result it is difficult for us to assess what is put forward as the overarching principle of the Plan. Para 3.64 of the IDP appears to suggest the opposite - ‘… summarises the transport needs … in order to support growth planned for in the Draft Plan’. Far from the Plan being ‘infrastructure-led’; it is the level of development that is driving infrastructure. Similar inconsistency is seen across other themes. For example, it is clear from the IDP that the need to allocate land for a new GP surgery in Cranbrook within the AONB has only been created by the decision to allocate significant number of new homes in the AONB, a position that remains to be tested through the local plan process. Likewise with water, Paras 3.133 and 3.150 suggest that the need to increase water supply and waste water capacity in Hawkhurst within the AONB is driven by ‘the needs of the growth proposed …’. There appears to be no analysis of constraints, impacts or options in relation to infrastructure. For example, a continuous footpath is proposed along A229 between Hawkhurst and Sissinghurst (Para 3.59). While we welcome improvements to the footpath and cycle network, a proper analysis of this proposal would have revealed that this route is a historic communication route lying within the High Weald AONB and representing a core component of its character and beauty. Part of this route is deeply sunken and associated with archaeologically valuable bank and ditch systems, ancient trees and ancient woodland. It is too far to be viable for everyday walking but cycling is not mentioned, nor are any off-road alternatives considered. | |
DLP_1528 | Mike Hinton | We refer to the transport section 3.50/3.59/3.64 of the infrastructure delivery plan 2019 for Tunbridge Wells. We are pleased to see the proposals for Calverley Park Gardens. They are clearly beneficial to the both the residents of the road and Carlton Road and we trust they will be implemented in the not too distant future. | |
DLP_3403 | Kent County Council (Growth, Environment and Transport) | Theme 1: Transport Paragraph 3.50 Highways and Transportation The paragraph aims to increase bus patronage proposing several schemes (such as a dedicated bus right turn lane at Woodsgate Corner, and the closure of Calverley Park Gardens to all traffic except for buses and access) – however these have not been fully explored. Paragraph 3.60 This paragraph refers to the North Farm Masterplan. This document will be superseded by the schemes resulting from the ongoing SWECO Local Plan Transport Evidence Base, a separate study on the North Farm area commissioned by KCC Highways and the Longfield Road business park planning application (TW/19/02267). Table 3 Transport needs for the settlements within Tunbridge Wells borough KCC recommends that this table should be amended to refer to improvements to the public footway network and PRoW network across the Borough. There is also reference to schemes (i.e. bus priority, A26, North Farm Masterplan, Hawkhurst junction) that should be amended in line within comments within Appendix 1. The IDP states: “A26 - reallocation of road space with smart traffic management to improve journey time reliability and provide infrastructure for sustainable modes (walk, cycle and bus)” KCC, as Local Highway Authority does not have confidence that this methodology will improve flows on the A26 enough to mitigate the additional traffic generated by Local Plan growth. The addition of smart traffic management (i.e. MOVA or SCOOT) to junctions that currently do not have signals in order to control the corridor will add delays that cannot be mitigated by such control systems. A need for “New relief road through the Hawkhurst Golf Club site linking the A268 High Street and A229 Cranbrook Road and new junction with the existing A229 Cranbrook Road” is included within the IDP. a) an assessment of the cumulative impact of all proposed allocations - excluding the Golf Club - on the junction as it is currently, and Theme 9: Waste and Recycling Paragraph 3.247 Waste Management KCC would like to provide update in respect of Waste to ensure the IDP is reflecting the most recent information. This paragraph notes the unprecedented demand for KCC Waste facilities, but it needs to be clearer to explain that whilst KCC does operate “a network of 18 Household Recycling Centres (HWRCs) and six co-located Waste Transfer Stations (WTSs)” this is across the whole County and that Tunbridge Wells Borough Council is served by one combined WTS and HWRC at North Farm. Current planned provision Paragraph 3.248 This paragraph only mentions Tunbridge Wells Borough Council’s service. It should also note that Tunbridge Wells Borough Council’s new recycling and waste collection service arrangements have already put additional pressure on the KCC North Farm WTS, as further separation of waste streams and collection of food waste has required additional infrastructure to be provided, effectively reducing the operational capacity of the site. Additional future requirements needed to deliver growth proposed in the Draft Local Plan Paragraph 3.251 The following statement is the Borough Council’s view on infrastructure requirements as Waste Collection Authority– “There are unlikely to be any major short term (five years) infrastructure requirements, but potentially some over the lifetime of the Plan, such as expansion to the depot”. KCC’s infrastructure requirements as the Waste Disposal Authority are different and noted in commentary relating to paragraph 3.253. Paragraph 3.253 KCC Waste Management has stated that as a result of additional demand generated by housing growth, this is likely to result in a requirement to build more, larger sites or invest in the maintenance or repair of existing Household Waste Recycling Centres (HWRCs) and Waste Transfer Stations (WTSs). At the Tunbridge Wells (North Farm) HWRC and WTS, KCC is expecting an increase in waste throughput especially through the Waste Transfer Station as a result of significant housing development resulting in an increase in kerbside collections. The WTS is already reaching its operational capacity, as evidenced through turnaround times for vehicles using the site. Consequently, mitigation at this site or provision of a new site to provide the required capacity is likely to be needed to deliver growth proposed in the Draft Local Plan. With regards to the HWRC provision at the site, the site operates well, although will near capacity by 2030, meaning that expansion or provision of a new or additional site is likely to be needed over the life of the Plan. The location of the site will make expansion challenging, however, minor amendments to facilitate access and flow around the site as throughput increases will be investigated in the short term. Table 15 Waste and recycling needs for settlements within Tunbridge Wells borough The County Council would like to see this table amended to include WTS expansion/improvement need. It is requested that the proposed changes read: “Possible expansion and improvements to the existing Waste Transfer Station and Household Waste Recycling Centre within the plan period”. Appendix 1: Infrastructure Delivery Schedule Table 16 Waste Management KCC would like to see a project to increase capacity at North Farm WTS and HWRC included in Appendix 1, Table 16 Infrastructure Delivery Schedule, under the Borough Wide heading. The County Council would be happy to provide details to complete this. Highways and Transportation The distinction between ‘Critical’ and ‘Essential’ priority is unclear. Early provision of certain transport infrastructure schemes will be fundamental to providing a sustainable development with reduced reliance on the private car. | |
DLP_4224 | Tunbridge Wells District Committee Campaign to Protect Rural England | In general we are impressed by the great efforts that have clearly been made to gather all the relevant evidence, during a time when the Government kept moving the goalposts. Most comments that we make relating to the topic papers and other supporting documents are made in our comments on policies. However, we make the following additional comments: Infrastructure Delivery Plan The draft Plan claims to be infrastructure-led but it appears to be primarily led by the proposed quantity and siting of new development and by a desire to build new roads. There appears to be no proper analysis of constraints, impacts or options in relation to infrastructure. Too much of the proposed new infrastructure appears to have little chance of being adequately funded (much of the funding being TBC) and therefore there can be little confidence that the infrastructure required to serve new development on the scale proposed will actually materialise and be in place when it is needed. | |
DLP_5618 | Mrs Jacqueline Hewitt | TWBC: The following comment was submitted by the responders on the left: Draft Infrastructure Delivery Plan 3.22 Table 2 Where is the research on numbers for Staplehurst, Marden and Etchingham which is where residents of Hawkhurst, Cranbrook and Sissinghurst, Goudhurst and Frittenden will commute from? 3.36. ‘Requirement for parking has still not been identified’ There is recognition that parking is an issue at stations, but no plans have been made to address this and there are no figures on requirement. This should include requirement at Staplehurst, Marden and Etchingham which are all used by Borough residents No bus service improvement is planned for the Parish of Cranbrook and Sissinghurst, despite the Parish massively under the planned allocations.. | |
DLP_5079 | Tally Wade | Infrastructure Delivery Plan 3.186 (page 59) I object to the planned replacement of the Cranbrook Library as part of a planned community centre and possible medical centre without any engagement of the community. The NDP has not been formally engaged as a whole and we have not engaged with the community on this subject. Where is the evidence that this has happened? Infrastructure Delivery Plan 3.194 (page 61) I object to the lack of consultation with the Cranbrook and Sissinghurst Neighbourhood Development Plan on the replacement of the Cranbrook library with book stock at the prosed Cranbrook Community Hub. The NDP has not been formally engaged as a whole and we have not engaged with the community on this subject. Where is the evidence that this has happened? Infrastructure Delivery Plan 3.107 Table 8 (page 41) and Appendix 1 – Infrastructure Delivery Schedule (page 101) I object to the lack of engagement with the Cranbrook and Sissinghurst Neighbourhood Development Plan on the incorporation of the three Cranbrook based GP practices into one medical facility proposed for the same site as the Cranbrook Community Hub (Wilkes Field). The Cranbrook and Sissinghurst Parish Council has formally agreed to engage the whole community on how this project should be shaped, what provisions should be incorporated, whether a new build is needed and how the ‘parish funding’ part of the project would be delivered. Where is the evidence that this has happened? | |
DLP_4352 | Tunbridge Wells Bicycle User's Group | Topic Paper or supporting document title: Infrastructure Delivery Plan (IDP) (Supporting doc) The IDP fails to communicate a sense of purpose. It acknowledges that “cycling provision has traditionally been poor.” It goes on to list “some improvements”, which are of varying quality and usefulness. What is striking is the piecemeal nature of these improvements. Nowhere is there any mention of the “network of high quality cycle routes” promised in the Cycling Strategy. The document then continues to the topic of ‘future provision’ and refers to the LCWIP, a work in progress which is likely to increase funding opportunities for various proposals. Under the ‘future provision’ banner para 3.59 repeats the need for a modal shift and then identifies just two town-centre routes along the A264 and A26, plus planning within the North Farm Masterplan for a multi modal shift. Thus the ‘future provision’ identifies only cycleways which already exist (albeit to a standard which is so low that they attract few users) or which are already planned. In these respects the IDP needs updating to match the more ambitious aims of the ‘Cycling Strategy’. | |
DLP_5083 | Southborough Cricket Club | Theme 7 (Sport and Recreation) We agree with the assessment that “Qualitative improvements are required to some clubhouses and pitches to meet modern standards” but would go further that some of the clubhouses require more than qualitative improvements, with some requiring complete re-design and re-build in order to meet modern standards. The pavilion currently utilised by Southborough Cricket Club is one of the clubhouses in the Borough that is close to reaching end of life and with the increase in numbers of female players, requires a complete re-design prior to re-build in order to offer a facility that meets the needs of all players and of spectators. Table Number: Table 14 Sport and recreation provision needs for settlements within Tunbridge Wells borough Within the Southborough Parish section, under the column headed “Requirement (outdoor)” we would ask that the requirement for the pavilion for Southborough Cricket Club needing to be re-built is incorporated as follows: “New enhanced and expanded cricket pavilion on the Common” | |
DLP_5311 | Judith Ashton Associates for Redrow Homes Ltd and Persimmon Homes South East | The draft Infrastructure Delivery Plan Having reviewed the draft Infrastructure Delivery Plan (IDP), we note that appendix 1 sets out the full extent of the infrastructure requirements that will be sought from the development in and around Paddock Wood/ Capel, some of which it acknowledges will also be connected to the development of the new settlement at Tudeley. The indicative costs of some of these infrastructure works vary significantly. Furthermore, it is not clear how the costs of these works will be divided between the various parts of the Paddock Wood/ Capel allocation, or how these costs have been factored into any viability assessments that have been undertaken. It is clear from a review of the Strategic Housing and Economic Land Availability Assessment (SHELAA) for the Draft Local Plan Reg 18 Consultation, especially the Site Assessment Sheets for Paddock Wood, that the Paddock Wood/ Capel allocation encompasses many sites, under different ownerships and that some may well progress in advance of others – as appears to be accepted by policy H2 of the Reg 18 Draft Local Plan. Albeit we note the apparent conflict between policy H2 and policy STR/PW1 concerning piecemeal delivery. Whilst policy AL/PW1 requires ‘all development to be delivered through a comprehensive masterplan approach’ and for the masterplanned approach to be ‘linked to the relevant and strategic delivery of infrastructure’, it would in our opinion be more effective to look to promote a Framework Plan and an overarching Strategic Infrastructure Plan separately rather than a masterplan. Whilst there will be cross over and the two will need to be interrelated, the complexities of the Strategic Infrastructure Plan are such that we believe work on this needs to progress at pace if the housing trajectory is to be met. We also believe it would be expedient if those assisting the Council on matters such as transport infrastructure could meet with those promoting the land at Paddock Wood/ Capel so that the practicalities of some of the proposed works could be discussed further. We say this as, by way of example, Table 3 of the draft Infrastructure Delivery Plan (Transport needs for the settlements within Tunbridge Wells borough) indicates that the plan should provide for ‘New cycling infrastructure within Paddock Wood town and linking to the proposed Hop Pickers Line cycle route via Horsmonden and Goudhurst to A229 Hartley Road’; and appendix 1 indicates that this will be delivered through the Paddock Wood/ Capel developments. Whilst, as the route of the old Hop Pickers Line passes through land in my client’s control and they are more than happy to integrate this into their scheme, they clearly have no control over the council’s ability to provide this through other third-party land. Thus, TWBC need to clarify how they see this being delivered in its totality so that people’s expectations are managed accordingly. To this end we note that reference is made in policy STR/PW1 of the Reg 18 plan to the use of CPO powers, which as we indicate below, whilst helpful in some regards needs to be adopted in a way that does not prejudice/ delay delivery of the strategic allocations. In the context of the above we note that the draft IDP also highlights the proposed distributor road to the east of Paddock Wood, (which would upgrade from single lane links around allocated sites to reduce congestion on local links and remove through vehicle trips in Paddock Wood) as being ‘Critical’. Unfortunately, the draft IDP, TA [3 Neither Fig 9.2 nor table 9.7 of the TA is clear.] and Reg 18 LP are all unclear as to the extent of the Eastern Distributor Road. We have assumed it will be a combination of online improvements that will provide for the widening of existing routes in places and offline improvements which will divert the route though the development in those places where it is necessary to protect existing properties/ landscape/ heritage features. As you will be aware, my clients have the ability to deliver a considerable part of this distributor road. That said they would question whether, as it is not clear, the Eastern Distributor Road needs to cross the railway and provide links to the north. Work undertaken by Milestone Transport Planning for my clients indicates that very little development related traffic would go north and east from the site [4 In this context ‘site’ means the land under Redrow and Persimmons control Milestones report suggests that just 8.1% of trips will go north, 4.1% south, 73.6% west and 14.2% North West (through the town). Which highlights the need for the distributor road to the east.]– the majority would go south and west. Thus any ‘upgrades’ to the east should be limited to the highway improvements to the south of the railway line. Whilst the draft IDP highlights the fact that Junction improvements at B2017 Badsell Road / B2160 Maidstone Road / Mascalls Court Road and the A228 / B2017 roundabout are to be “…funded as part of approved residential developments at Church Farm, Mascalls Farm & Mascalls Court Farm” we also note that the IDP suggests that a further upgrade to the B2017 Badsell Road / B2160 Maidstone Road / Mascalls Court Road junction to traffic signals could cost up to £550k. Whilst my clients are happy to contribute to any such upgrades, they would ask whether any design work has been carried out on this junction to date and question the extent to which any additional highway land is available to facilitate further improvements. These may in our opinion require cooperation with Mascalls School, which we assume TWBC will liaise with KCC highways and education alike on, rather than look to initiate CPO powers? We also note the IDP identifies additional future requirements for bus infrastructure including a ‘Demand-responsive urban bus service’ linking residential development to the town centre and rail station within Paddock Wood. Again, whilst I can confirm that my clients are happy to contribute to any such upgrades, they believe further liaison is required with KCC Public Transport officers and operating companies to agree the specification of any such service provision, especially as Church Road is the key sustainable transport corridor between their land and the town centre / rail station. Likewise, in noting the timescales for the delivery of the primary and secondary education facilities in Paddock Wood/ Capel in the draft IDP, we would stress the fact that these can only be delivered through the approval of the associated housing applications and that as such it’s imperative that plans are put in place to ensure that future applications are determined as swiftly as is practically possible. In this regard we note that the less constrained land to the east of Paddock Wood has, as it is not in the Green Belt and thus does not need to be allocated to be released, the ability to help deliver early on in the plan period – if required. Finally, we would submit that in order to establish a robust viability for the allocation at Paddock Wood as part of the Reg 19 plan, TWBC and KCC need to identify whether LEP or central government funding will be available to contribute towards the funding of the road and infrastructure improvements envisaged by the local plan and IDP, and the scale of said funding. The development industry will need to know what’s happening by the time the Stage 2 Viability is prepared so that sensible decisions can be taken about what pieces of infrastructure are needed and when and to try and tie infrastructure delivery to particular areas of growth so that house builders know what they need to provide by way of works or by way of contributions. This will help facilitate smooth delivery and thus protect the housing trajectory. [TWBC: see full representation]. | |
DLP_5355 | Jennifer Hemming | We are delighted to finally see in Calverley Park Gardens in the transport section 3.50/3.59/3.64 in the Infrastructure Delivery Plan 2019 for Tunbridge Wells, proposing restricting traffic on Calverley Park Gardens and improving the cycle route. We fully support the proposals in the plan, as do Calverley Park Gardens Residents Association, who have been campaigning for a safer environment in this area for many years. | |
DLP_5580 | Philip and Vera Stanford | My wife and I are very pleased that the above plan includes proposals for restricting traffic on Calverley Park Gardens. It is a continuing worry that large trucks and lorries continue to use Calverley Park Gardens as a cut through to Pembury Road. Many have difficulty in negotiating the Carr’s Corner roundabout and turning into CPG and the bollards are regularly damaged. There is insufficient room for these and other vehicles to avoid driving on part on the cycle paths. All of this spells particular danger for adults with children and older people. It is often observed that cars turning into GPG from the roundabout accelerate to speeds above the present limit. All of this raises major concern for pedestrian safely and we very much hope to see the implementation of these and other proposals in the Draft Plan. | |
DLP_5631 | Christian Nouyou | I recently read your Infrastructure Delivery Plan 2019 for Tunbridge Wells and was over the moon to see in the transport section 3.50/3.59/3.64 a list of proposals for restricting traffic on Calverley Park Gardens . I am a resident of Calverley Park Gardens and a parent of two primary school aged boys. Crossing this road daily is a constant worry. It's simply dangerous. I really fear for the safety of my boys. There is no where to cross safely and the majority of traffic seems to speed up and down it. The HGV use has lessened but it's still a problem. Please, please, please adopt the proposals. It would be a HUGE benefit to the pedestrians that use this otherwise dangerous road. | |
DLP_5904 | Simon Knechtli | Having read the transport section 3.50/3.59/3.64 of the Infrastructure Delivery Plan 2019 for Tunbridge Wells it is very encouraging to see a list of proposals for restricting traffic on Calverley Park Gardens . Traffic speed, noise and safety concerns have been an ongoing debate and these proposals, particularly stopping general through traffic, will answer to these threats. Only this morning, while waiting for an early morning taxi, I observed cars, HGVs (despite not allowed) and even buses travelling too fast down what is curving blind-spot road. This is a real danger to pedestrians as much as cyclist and I always have concern for mobility chair-users who at points have to use the cycle lane. Not good. With traffic and speed restricted, the small areas at bus stops, where Mum’s, schoolchildren and the less mobile congregate, would be at much lower risk of accident or injury. I suggest the stops are moved where possible to areas of larger pavement. Our property, at 4a, suffers from whooshing (almost a vacuum effect) of over-speeding buses and HGV’s as well as the vibrations (felt throughout the property from early morning) they and other speeding vehicles cause when driving over the cracked road surface to which we are adjacent. The cycle route linking central Tunbridge Wells to Pembury must surely be continuous rather than abruptly finishing at Carrs Corner. Cycling in reserved lanes should be safe as well as encouraging cycling as a fitness, hobby and eco-friendly activity. Currently I feel worry for their safety as well as the mobility users. Traffic crossing CPG at Carrs corner junction presents a certain risk. Traffic and lorries turn up this road at speed often with no indication or warning. Within 10 minutes this Sunday morning there was a cement mixer, two HGVs and an articulated lorry passed down CPG with no regard for pedestrians or cars pulling out. It’s no surprise that the pedestrian safe-point and bollards are regularly destroyed. We encourage that this draft proposal is taken forward to dramatically improve safety risk as well as the environment. | |
DLP_6415 | Hawkhurst Parish Council | Response to the Infrastructure Delivery Plan 2019 Transport 2.7 & 2.8 The Kent Growth and Infrastructure Framework (2018) does not identify the strategic need for road infrastructure improvements Hawkhurst and makes no mention of the A229. https://www.kent.gov.uk/__data/assets/pdf_file/0011/79913/GIF-West-KentOverview.pdf 3.4 & 3.6 We note that Highways England have “no further planned improvements to the A21 within the Borough.” However, do Highways England or East Sussex County Council have plans any further improvements to the A21 / A 268 junction at Flimwell? As outlined above, we have grave concerns about the effectiveness of the proposed new road through the golf course in addressing traffic concerns in Hawkhurst. This will require significant improvements to the Flimwell junction - far beyond what is proposed in the current planning application. 3.11 We note and agree that “The A229 is constrained at the junction with the A268 in Hawkhurst and that this cross roads suffers from severe congestion at peak times and other times of the day.” However, we are highly sceptical that a “new relief road through Hawkhurst Golf Club site linking the A268 High Street and A229 Cranbrook Road and a new junction with the existing A229 Cranbrook Road” will provide the necessary mitigation (3.14). Digital Communications (broadband and mobile) We note the expectation that new developments are expected to have ultra-fast full fibre to premises. However, there also needs to be a greater push towards better provision to existing properties, as well as improved mobile coverage. Community Centre 3.194 – Change text to “The King George V Playing Field at Hawkhurst the Moor is allocated within the Site Allocations Local plan (2016) for a new community centre to replace the existing Copt Hall. Hawkhurst Parish Council is working with Hawkhurst Community Trust 2018 to deliver the project in 2020, for an estimated £2.5 million. | |
DLP_7570 | Mark Beales | Draft Infrastructure Delivery Plan 3.22 Table 2 Where is the research on numbers for Staplehurst, Marden and Etchingham which is where residents of Hawkhurst, Cranbrook and Sissinghurst, Goudhurst and Frittenden will commute from? Infrastructure Delivery Plan 3.36. ‘Requirement for parking has still not been identified’ there is recognition that parking is an issue at stations, but no plans have been made to address this and there are no figures on requirement. 8This should include requirement at Staplehurst, Marden and Etchingham which are all used by Borough residents | |
DLP_6829 | Persimmon Homes South East | Draft Infrastructure Delivery Plan 3.6 The draft Infrastructure Development Plan (IDP) identifies several infrastructure improvements that are required to support of growth at Horsmonden, including:
3.7 Whilst the school extension and the new health centre are required to meet the needs of Horsmonden, they have been identified as come forward on safeguarded land identified as part of Policy Allocation AL/HO3. Whilst we are supportive of the safeguarding of land for the provision of new infrastructure to 634/B1/CC/TA 8 November 2019 support the sustainable growth of Horsemonden, it is also important that responsibility for the delivery the facilities, is made clear in the IDP. Given that these facilities are to serve the wider needs of Horsmonden, it is suggested that this safeguarded land is dealt with by way of a separate allocation specifically related to the delivery of the school and health centre. This is discussed further in Section 6 below. 3.8 Given the relatively low levels of traffic in the local area, and comparatively limited the scale of growth proposed at Horsmonden, the draft IDP does not identify any strategic highways improvements to be delivered within Horsmonden Parish in support of the development strategy. 3.9 Notwithstanding the absence of a requirement for highways improvements, the need to support sustainable opportunities in the village is noted and is supported by Persimmon and can be facilitated through the delivery of our Site. This is discussed further in Section 6 below. | |
DLP_7344 | Campaign to Protect Hawkhurst Village | Infrastructure Delivery Plan The introduction to the IDP confirms that its intention is to set out details of the infrastructure to support the existing and future needs to support the new development envisaged by the DLP. In respect of Transport matters: Paragraph 3.4 confirms that there are no planned improvements to the A21 in the Borough. It does not address whether any works are proposed to Flimwell – which whilst outside the borough will be severely impacted by the DLP growth strategy and relied upon by a large number of residents in the east of the Borough. Paragraph 3.7 acknowledges that the peak hour congestion suffered by Flimwell. Paragraph 3.14 sets out the additional future transport mitigation measures required to deliver the growth in the DLP. It includes the Hawkhurst relief road but makes no reference to any scheme at Flimwell. Appendix 1 identifies that the relief road is a “critical” piece of infrastructure. Paragraph 2.19 defines “critical infrastructure” as infrastructure that must happen to enable physical development to take place. However, as set out elsewhere in our representations there is no evidence before the Council that the relief road will actually achieve any improvements to the congestion in the village. Given this categorisation as “critical” if it is demonstrated that the relief road does not achieve the asserted improvements, the IDP suggests that no further development can be accommodated within Hawkhurst. In turn the IDP should specifically include necessary mitigation measures at Flimwell that at present have simply not been contemplated. In respect of Education matters, the IDP advises that it proposes to expand Hawkhurst Primary School to provide for Hawkhurst Sandhurst and Benenden by one form entry. There is no analysis anywhere in the IDP (or anywhere else in the evidence base) to suggest that such an expansion is sufficient to cater for the increased demand generated by the scale of proposed development in Hawkhurst. The IDP should make clear whether all demand generated by new development is capable of being accommodated within Hawkhurst Primary School even if it is expanded by one form. In respect of Health matters, the IDP recognises that the growth proposed will increase the patient list by 30%. It records that there is currently Stage 1 support from the CCG and that the practices are developing an outline business case to progress to Stage 2. This is at a very early stage and it is clear that there is no certainty at this stage that the proposed amalgamated medical centre is viable or deliverable. The IDP should make clear that the new centre should be funded by Developer contributions. In respect of waste water, the IDP acknowledges a need to ensure Hawkhurst has sufficient capacity to meet the needs of growth. In fact, Southern Water in their response to recent planning applications have made clear that there is currently insufficient capacity to meet existing demand. This additional infrastructure should be classified as “critical” given current issues. | |
DLP_8151 | Ashley Saunders | In relation to Secondary Schools, under ‘Current planned provision’ from paragraph 3.71 (p.31-32) it is stated that provision for “One FE expansion of Mascalls Academy for 2021-22” is planned to meet existing needs. Further down p.32 the IDP details ‘Additional future requirements needed to deliver growth proposed in the Draft Local Plan’ have been identified as “Up to eight FE new Secondary School to be provided on land at the garden settlement at Tudeley Village and further expansion of Mascalls Academy at Paddock Wood”. There is no further detail; however, capacity at Mascalls Academy can only be increased by a finite amount due to location constraints. This, therefore, makes the development of 4,000 houses in East Capel (AL / CA 3 and AL / PW 1) unsustainable as many children will be required to travel to the planned new Secondary School at Tudeley. TWBC acknowledges that there are serious constraints; in the dLP under Policy AL/CA 3 & AL/PW 1 it states that “Development at this site is subject to the provision of land for the expansion of Mascalls” As the location of the potential land for expansion appears unknown, the proposed development is therefore unsustainable. The development at East Capel should be removed from the dLP unless there is certainty that sufficient Education provision can be made. Please also see our comments in COMMENT BOX 2 under the heading ‘Strategic Objective 5: Essential Infrastructure and Connectivity’ | |
DLP_7928 | Fiona Dagger | TWBC: The following comment was submitted by the responders on the left: The Local Plan claims to be infrastructure-led but it is just a shopping list. No spatial analysis of need has been provided and as a result it is difficult to assess what is put forward as the over-arching principle of the Plan. Para 3.64 of the IDP appears to suggest the opposite - ‘… summarises the transport needs … in order to support growth planned for in the Draft Plan’. Far from the Plan being ‘infrastructure-led’; it is the level of development that is driving infrastructure. Similar inconsistency is seen across other themes. For example, it is clear from the IDP that the need to allocate land for a new GP surgery in Cranbrook within the AONB has only been created by the decision to allocate significant number of new homes in the AONB, a position that remains to be tested through the local plan process. Likewise with water, Paras 3.133 and 3.150 suggest that the need to increase water supply and waste water capacity in Hawkhurst within the AONB is driven by ‘the needs of the growth proposed …’. There appears to be no analysis of constraints, impacts or options in relation to infrastructure. The IDP does not appear to be based on any coherent, integrated and strategic consideration of sustainable transport options as required by paras 102-104 of the NPPF. | |
DLP_3489 | Sally Marsh | The Local Plan claims to be infrastructure-led but it is just a shopping list. No spatial analysis of need has been provided and as a result it is difficult to assess what is put forward as the over-arching principle of the Plan. Para 3.64 of the IDP appears to suggest the opposite - ‘… summarises the transport needs … in order to support growth planned for in the Draft Plan’. Far from the Plan being ‘infrastructure-led’; it is the level of development that is driving infrastructure. Similar inconsistency is seen across other themes. For example, it is clear from the IDP that the need to allocate land for a new GP surgery in Cranbrook within the AONB has only been created by the decision to allocate significant number of new homes in the AONB, a position that remains to be tested through the local plan process. Likewise with water, Paras 3.133 and 3.150 suggest that the need to increase water supply and waste water capacity in Hawkhurst within the AONB is driven by ‘the needs of the growth proposed …’. There appears to be no analysis of constraints, impacts or options in relation to infrastructure. The IDP does not appear to be based on any coherent, integrated and strategic consideration of sustainable transport options as required by paras 102-104 of the NPPF. | |
DLP_4454 | Mr Andrew Rankine | The Infrastructure Delivery Plan is lacking in any detail or substance in relation to the proposed new settlement. A development of this size would require specific road infrastructure to be delivered prior to any construction work commencing otherwise the impact on the existing road network would be intolerable. There is also no detailed analysis or modelling to show what infrastructure improvements would be required. Without this analysis I fail to see how the suggestions of a large roundabout by All Saint’s Church, “improvements” to the B2017 (which is the boundary to the AONB) and improvements to the junction with Vale Road would address the vastly increased traffic flow in the area and in the surround boroughs of Tonbridge and Malling and Maidstone. The nod towards provision of “active travel connections” seems somehow to mitigate any rational consideration for the genuine transport issues that 4000+ houses in Capel would cause. | |
DLP_7973 | Sharon Pickles | TWBC: The following comment was submitted by the responders on the left: 3.22 Table 2 Where is the research on numbers for Staplehurst, Marden and Etchingham which is where residents of Hawkhurst, Cranbrook and Sissinghurst, Goudhurst and Frittenden will commute from? 3.36 There is recognition that parking is an issue at stations, but no plans have been made to address this and there are no figures on requirement. This should include requirement at Staplehurst, Marden and Etchingham which are all used by Borough residents | |
DLP_6871 | Persimmon Homes South East |
Further, as noted in the IDP, the school extension and the health centre are required to meet some existing local needs and also the need of all of new the development coming forward within village, not just the development within AL/HO3. As such the requirement for this land is not fairly and reasonably related in scale and kind, or directly linked, to the housing coming forward on AL/HO3. As such a Section 106 requirement for the delivery of the safeguarded land may not be CIL 122 complaint (without a mechanism for recouping the cost of land from the other developments in the village which would benefit). Further, neither the school nor the health centre will not be expected to be delivered by the developer, rather it will be brought forward by the infrastructure providers (namely the NHS Clinical Commissioning Group in respect of the Medical Centre and the Kent Local Education Authority in respect of the school extension) in accordance with their delivery programme. It is noted that the draft IDP explains that both the NHS CCG and the Kent LEA have further work to undertake to determine the scale of provision required in this location. Ambiguity on the responsibility for the delivery of infrastructure could lead to uncertainty and delay in the delivery of units on the Site, undermining the robustness of the Borough housing land supply assumptions. Given that the safeguarded land will benefit all development sites coming forward in the village, and given the school and health centre will not be delivered by the developers, we request that the safeguarded land is subject to a separate allocation policy rather than being included within AL/HO3. This will allow for a much clearer framework for delivery with clear responsibilities. It will also allow the community land to come forward independently in accordance with the requirements and programme of the infrastructure providers and in accordance with the CIL 122 test. We thereby also request that the IDP is updated to explicitly acknowledge that the safeguarded land will be delivered by the infrastructure providers in accordance with their delivery requirements and programme. Persimmon Homes would of course provide CIL compliant contributions toward the delivery of necessary infrastructure improvements, secured by way of a Section 106 agreement, and we would therefore be keen to see necessary infrastructure delivered in a timely fashion. | |
DLP_8282 | Ann Gibson | There is no recognition that parking is an issue at stations and no plan has been made to address this. There are no figures on requirement. This should include requirement at Staplehurst, Marden and Etchingham Stations which are used by borough residents. No bus service improvement is planned for the Parishes of Cranbrook and Sissinghurst despite the parishes being massively enlarged under the planned allocations. | |
DLP_409 | Jane Kingsley | I recently saw your ‘Infrastructure Delivery Plan 2019 for Tunbridge Wells’ and in particular noted the transport section 3.50/3.59/3.64 a list of proposals for restricting traffic on Calverley Park Gardens . As a resident of this road who has experienced the dangers of the large trucks and speeding cars using this as a cut through I am sure that if the general through traffic is stopped it will make a greatly improved environment for pedestrians, children waiting at bus stops and cyclists who are in constant danger from traffic . It is great news TWBC are continuing to enhance the cycle route linking central Tunbridge Wells to Pembury rather than just abruptly finishing at Carrs Corner . Currently , cycling on CPGs is a very frightening experience and general traffic simply use the cycle lanes as the road is quite restricted. Promoting the cycle lane will also make a better experience for the growing population using mobility scooters who currently have to share the pavement making pedestrian step out onto CPGs road to pass by or indeed mobility scooters use the current cycle lane which looks extremely precarious when large trucks pass by within inches . You are probably aware of the vast problems over the years of inappropriate vehicles cutting up this road from Carrs corner , across the pedestrian safe area ,constantly damaging the bollards and furnishings. The corner of CPGs and Carrs Corner is a very dangerous place for pedestrians. If your plans go ahead they will only need to be aware of buses when waiting to cross the road making it a much safer environment . We understand this is only a draft proposal but very much hope this forward thinking plan to improve the safety on CPGs for a better pedestrian and cyclist experience will be implemented . | |
DLP_467 | William Apted | Calverley Park Gardens Traffic Proposals. Your Infrastructure Delivery Plan 2019 includes some excellent proposals for Calverley Park Gardens. Over the years this road has become a rat-run for traffic entering Tunbridge Wells and the large lorries and general speed of vehicles poses a constant threat to the Residents. The problem is exacerbated by the extremely narrow pavement especially near the bus stop and those of us that are over 80 have difficulty in avoiding stepping onto the busy road. Your plans to make this a bus route and cycle lane only have our full support. | |
DLP_511 | Barbara and Paul Cresswell | We are delighted to see the transport section 3.50/3.59/3.64 list of proposals for restricting traffic in Calverley Park Gardens. We want to encourage safe cycling in Tunbridge Wells. We wouldn’t let our grandchildren cycle down Calverley Park Gardens under the existing traffic conditions. We have an ageing population who need to be able to cross the road in safety. The sign banning HGV vehicles is ignored. The bollards at the junction of Calverley Park Gardens and Carrs Corner seem to be damaged on a weekly basis. There now appears to be a realistic prospect of these outstanding dangerous traffic matters being addressed. We urge the Planning Department to implement these proposals. | |
DLP_567 | Andrew and Amanda Poole | So delighted at the proposals for Calverley Park Gardens. The quality of life for residents has been blighted by the number of heavy trucks using this beautiful road as a cut through. I’m particularly happy for parents of young children who can look forward to having a much safer road. The cycle proposal is fantastic, makes complete sense and is progressive, making a real statement of intent from our environmentally astute planning department. | |
DLP_4606 | Keith Stockman | Draft Infrastructure Delivery Plan 3.36. ‘Requirement for parking has still not been identified’ Despite the Parish potentially increasing massively in population under the planned allocations, no bus service improvement is planned for the Parish of Cranbrook and Sissinghurst, a service that is barely adequate as it stands at present. | |
DLP_5986 | Steve Rix | Infrastructure Delivery Plan 3.186 (page 59) I object to the planned replacement of the Cranbrook Library as part of a planned community centre and possible medical centre without any engagement of the community. The NDP has not been formally engaged as a whole and we have not engaged with the community on this subject. Where is the evidence that this has happened? Infrastructure Delivery Plan 3.194 (page 61) I object to the lack of consultation with the Cranbrook and Sissinghurst Neighbourhood Development Plan on the replacement of the Cranbrook library with book stock at the prosed Cranbrook Community Hub. The NDP has not been formally engaged as a whole and we have not engaged with the community on this subject. Where is the evidence that this has happened? Infrastructure Delivery Plan 3.107 Table 8 (page 41) and Appendix 1 – Infrastructure Delivery Schedule (page 101) I object to the lack of engagement with the Cranbrook and Sissinghurst Neighbourhood Development Plan on the incorporation of the three Cranbrook based GP practices into one medical facility proposed for the same site as the Cranbrook Community Hub (Wilkes Field). The Cranbrook and Sissinghurst Parish Council has formally agreed to engage the whole community on how this project should be shaped, what provisions should be incorporated, whether a new build is needed and how the ‘parish funding’ part of the project would be delivered. Where is the evidence that this has happened? | |
DLP_7399 | Andrew Ford | The Local Plan claims to be infrastructure-led but it is just a shopping list. No spatial analysis of need has been provided and as a result it is difficult for us to assess what is put forward as the over-arching principle of the Plan. Para 3.64 of the IDP appears to suggest the opposite - ‘… summarises the transport needs … in order to support growth planned for in the Draft Plan’. Far from the Plan being ‘infrastructure-led’; it is the level of development that is driving infrastructure. Similar inconsistency is seen across other themes. For example, it is clear from the IDP that the need to allocate land for a new GP surgery in Cranbrook within the AONB has only been created by the decision to allocate significant number of new homes in the AONB, a position that remains to be tested through the local plan process. Likewise with water, Paras 3.133 and 3.150 suggest that the need to increase water supply and waste water capacity in Hawkhurst within the AONB is driven by ‘the needs of the growth proposed …’. There appears to be no analysis of constraints, impacts or options in relation to infrastructure. For example, a continuous footpath is proposed along A229 between Hawkhurst and Sissinghurst (Para 3.59). While we welcome improvements to the footpath and cycle network, a proper analysis of this proposal would have revealed that this route is a historic communication route lying within the High Weald AONB and representing a core component of its character and beauty. Part of this route is deeply sunken and associated with archaeologically valuable bank and ditch systems, ancient trees and ancient woodland. It is too far to be viable for everyday walking but cycling is not mentioned, nor are any off-road alternatives considered. | |
DLP_8344 | Joe Matthews | TWBC: correspondent submitted the following comments on 20/11/19, after the close of consultation on 15/11/19: Paragraph 3.22 Draft Infrastructure Delivery Plan 3.22 Table 2 Where is the research on numbers for Staplehurst, Marden and Etchingham which is where residents of Hawkhurst, Cranbrook and Sissinghurst, Goudhurst and Frittenden will commute from? Paragraph 3.36 Requirement for parking has still not been identified’ There is recognition that parking is an issue at stations, but no plans have been made to address this and there are no figures on requirement. This should include requirement at Staplehurst, Marden and Etchingham which are all used by Borough residents | |
Landscape Sensitivity Assessment
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_3522 | High Weald AONB Unit | While the highest sensitivity rating is applied, rightly, to most parcels of land in the AONB, one parcel stands out - Ha5 - as meriting a medium-high rating. We dispute this rating. Fowler’s Park is eighteenth century parkland developed from a medieval farmstead. The distinctive curve of the historic routeway around the parkland to the north delineates what the Landscape Sensitivity Study has identified as landscape parcel Ha5. The outline of medieval fields from which the park was created can still be traced by the lines of trees left in the pasture. The historic nature of these features is likely to support high biodiversity. Small parklands like this are typical of the High Weald AONB. A revised high sensitivity rating should be reflected in a score for landscape impact in the SA adjusted to ‘Very Negative’. |
DLP_7672 | Mr J Boxall | Page 149-150: Cranbrook sub-area CR 11 The historic character of this site should also include the Roman Road, which goes through the land south of Sissinghurst, parallel to Chapel Lane, as well as Lake Chad in the valley floor which is of historic interest to both Sissinghurst and Cranbrook. I agree that there is a high degree of landscape sensitivity in this area Cranbrook sub-area CR 11 |
DLP_7400 | Andrew Ford | While the highest sensitivity rating is applied, rightly, to most parcels of land in the AONB, one parcel stands out - Ha5 - as meriting a medium-high rating. We dispute this rating. Fowler’s Park is eighteenth century parkland developed from a medieval farmstead. The distinctive curve of the historic routeway around the parkland to the north delineates what the Landscape Sensitivity Study has identified as landscape parcel Ha5. The outline of medieval fields from which the park was created can still be traced by the lines of trees left in the pasture. The historic nature of these features is likely to support high biodiversity. Small parklands like this are typical of the High Weald AONB. A revised high sensitivity rating should be reflected in a score for landscape impact in the SA adjusted to ‘Very Negative’. |
DLP_3689 | Lynne Bancroft | Landscape sensitivity study for PW, Horsmonden, Hawkhurst and Cranbrook Page 149-150: Cranbrook sub-area CR 11 The historic character of this site should also include the Roman Road, which goes through the land south of Sissinghurst, parallel to Chapel Lane, as well as Lake Chad in the valley floor which is of historic interest to both Sissinghurst and Cranbrook. I agree that there is a high degree of landscape sensitivity in this area Cranbrook sub-area CR 11 |
DLP_6828 | Mrs Carol Richards | The Landscape Sensitivity Assessment (Feb 2017) states (para 1.1):- “The purpose of the study is to provide an assessment of the extent to which the character and quality of the landscape within the study area is, in principle, susceptible to change as a result of introducing particular types of development into certain landscape character areas”. It goes on to say (para 1.3): “It is intended that the assessment will help to inform the preparation of the Local Plan” It has 6 Criteria for consideration (see para 2.9). * The LSA omits a number of significant sites, such as 448, 447 and 454 (designated as LP allocations AL/CA 1 and AL/CA 2) This is a material omission, given the scale of development proposed. Overall, this means that the LSA is failing to address LCA 13 and its immediate impact, an area proposed to hold around 89% of the LP housing need – see Table 1 page 35 of the LP (13500-5967=7593 and 6800 is 89% of 7593) |
Limits to Built Development Topic Paper
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_472 | Robert and Lynne Mills | We wish to comment regarding the Limit to Built Development Topic Paper for Draft Local Plan amendments that have been made around our property Greenacres, The Street, Benenden, Kent TN17 4DB, which are shown on Item 10.1 map Benenden LBD Boundary Amendments, map reference No 4 taking account of Principles 7.5, 4 and 7.6 a,c,d,e,f,g and Criteria X1, X111. On looking at the map we note that our neighbour Little Barn which has also been incorporated within the revised plan has their garaging and main building all included within the LBD boundaries whereas our property has the main building but our garage where we store our cars and gardening equipment, ride on mower etc., is not included, which seems very strange and we wonnder why? There is a tarmac drive which passes the front of our property and leads to our garaging making it an integral functioning part of the property. In addition we also have a small orchard and copse to the front of the property which also appears to have been excluded and we feel it should be included in the LBD. We would appreciate if you could look into these points that we have raised and let us know if amendments to the above matters can be dealt with. |
DLP_2609 | Mark Wildi | I wish to comment on the Limits to Built Development (LBD) as regards Five Oak Green. The topic paper notes that there are no proposed boundary amendments for Five Oak Green. The Five Oak Green LBD is shown in Draft Policies Map 6. The map shows that the boundary at Orchard Brook, Five Oak Green Road (TN12 6TJ) cuts through the middle of a building, the gym building (see extract). A stated aim of the review is to ensure that LBD boundaries are logical and reflect what is on the ground. In practical application of these, it is stated that the principles and criteria set out in section 7 of the paper were consistently applied in revising the existing LBD boundaries. Reliance was made on aerial photographs, the Council’s Geographical Information System and Google Maps and Street View. This does not appear to be the case as regards the property at Orchard Brook, TN12 6TJ. Specifically, principle 4 states: “LBD boundaries should normally follow physical features, e.g. roads, walls, field boundaries, although there may be instances where it is appropriate to cut across property curtilages to ensure that local character and/or amenities are protected.” As regards Orchard Brook, the boundary appears to be completely arbitrarily drawn with no reference to existing buildings or boundaries, bisecting the gym building. The entire site of Orchard Brook combines residential and commercial buildings, including gardens which are in use as such. I would request that you review the boundary as shown, and show the boundary as following the natural boundaries of the site – those being established hedge lines and ditches. I consider that this would meet the criteria set out in 7.6, being adjacent to and forming a logical extension to the built up area, which would not result in harmful protrusion into the countryside and be in accordance with criteria (b) to (g). |
DLP_7739 | Fiona Chapman | * Limits to Built Development the plan shows consistent inconsistency over matters relating to LBDs. The village LBD is to be altered, or rather engineered, to include areas currently outside the LBD but slated for development (AL/BE1, AL/BE2 and AL/BE3) and to exclude those not currently favoured, such as 158 and 222. At Iden Green, where the neighbourhood plan and the LP recommend no development at all, the LBD is to be removed thereby freezing the hamlet in time by stopping all infill. This is inconsistent with Objective 1 urging the growth of existing settlements. |
DLP_7841 | Andrew Chandler | Topic Paper or supporting document title: Limits to Built Development In terms of the justifications advanced in Table 31 of the LBD Topic Paper for extending the Sissinghurst LBD, I would comment that the justifications advanced for the proposed revised LBD for Sissinghurst do not stand up to scrutiny. In particular: - Principle 2. Land inside the LBD will generally be substantially developed – including buildings, roads (excluding roads on the edge), etc. This is not true in the case of the proposed extension of the Sissinghurst LBD, which has simply been drawn around existing houses outside the existing settlement to justify the proposed site allocations. To the contrary, all of the houses and potential development sites that have been included in the extended LBD are surrounded by fields. This Principle does not provide a justification for the proposed extension of the LBD in Sissinghurst. - Principle 5. LBDs need not be contiguous. It may be appropriate for a settlement to have two (or more) separate elements, where this reflects distinct built up parts. The proposed LBD is drawn around the built up area of three separate areas of settlement, Sissinghurst, Mill Lane, Wilsely Pound. Wilsely Pound in particular has never been treated as part of the Sissinghurst settlement and in fact the green gaps that you now propose be allocated are precisely what has separated it from Sissinghurst. This Principle does not provide a justification for the proposed extension of the LBD in Sissinghurst. - Criterion (a) be adjacent to and form a logical extension to the built up area and not result in harmful protrusion into the countryside It is inaccurate to describe the extension to the current LBD as being adjacent to the current one and artificial to state that the proposed extension provides one contiguous LBD for Sissinghurst. The additional sites that you seek to include will be disconnected from the existing settlement at Sissinghurst, just as all of the existing houses in the proposed extension are. We are outside the village. Further, Mill Lane is a rural lane and the sites along the A229 are farmland. By including them in the LBD you achieve precisely the opposite of what this criterion requires. This Criterion does not provide a justification for the proposed extension of the LBD in Sissinghurst. - Criterion (b) not result in coalescence – important gaps should be retained The proposed LBD extension achieves precisely the opposite of what this criterion requires. Although it is proposed to retain a gap within the settlement of Sissinghurst, the proposed LBD coalesces settlement between Sissinghurst and Wilsley Pound. This Criterion does not provide a justification for the proposed extension of the LBD in Sissinghurst. - Criterion (c) have no adverse impact on landscape character Mill Lane is a rural lane. By including it in the LBD you achieve precisely the opposite of what this criterion requires. Similarly the proposed inclusion of current pasture land (AL/CRS13), significant grassland (AL/CRS12) and agricultural land (AL/CRS16) achieves precisely the opposite of what this criterion requires. This Criterion does not provide a justification for the proposed extension of the LBD in Sissinghurst. - Criterion (d) have no adverse impact on designated areas of national and local landscape, archaeological, geological, ecological or heritage importance of site Once again, you seem to be intent on disregarding the historical and heritage significance of AL/CRS13 (which used to have a windmill) and Mill Lane (which is the most highly rated rural lane in the entire borough for its historical significance - see comments on AL/CRS12 and AL/CRS13). This Criterion does not provide a justification for the proposed extension of the LBD in Sissinghurst. - Criterion (e) be of a scale/nature in keeping with the form and function of the settlement and result in no harm to its character, appearance or setting - does it relate more to the built environment or to the surrounding countryside? I would dispute that this criterion provides a justification for the proposed extension of the LBD in Sissinghurst. - Criterion (f) not extend existing linear features or result in ribbon development Whilst the proposed LBD does not extend linear features, it does amount to ribbon development along the roads around Sissinghurst without any connection to the current settlement. This Criterion does not provide a justification for the proposed extension of the LBD in Sissinghurst. - Criterion (g) allow reasonable access to local facilities and services (non-private car mode) As noted in my comments elsewhere, Sissinghurst is rated near bottom of the 2017 Settlement Role and Function Study, with only four settlements scoring lower. Most facilities including doctors, dentists, hospitals, the only primary schools likely to have any availability, secondary schools, supermarkets and the railway station are all are only realistically accessible by car. This Criterion does not provide a justification for the proposed extension of the LBD in Sissinghurst. In terms of the specific Amendments to SALP LDB boundaries, I would comment on the following Map References: 2 – If you do extend the LBD, I support only including the western part of the site fronting Mill Lane (although see comments on AL/CRS12, as the site does not front Mill Lane in the North East corner). 8 – I dispute the reason given for these inclusions. These areas only form a logical extension of the built form of the settlement if site allocations AL/CRS12 and AL/CRS13 are approved for development and built on. None of these areas is currently an extension of the existing settlement. |
DLP_2330 | Colin Inwood | TWBC: the following response was submitted by the list of responders on the left: * Limits to Built Development the plan shows consistent inconsistency over matters relating to LBDs. The village LBD is to be altered, or rather engineered, to include areas currently outside the LBD but slated for development (AL/BE1, AL/BE2 and AL/BE3) and to exclude those not currently favoured, such as 158 and 222. At Iden Green, where the neighbourhood plan and the LP recommend no development at all, the LBD is to be removed thereby freezing the hamlet in time by stopping all infill. This is inconsistent with Objective 1 urging the growth of existing settlements. |
DLP_5772 | Herbert Boxall | I am writing to object to the part of the Tunbridge Wells Draft which deals with the parish of Benenden and, in particular, with that part which deals with the hamlet of Iden Green. within that parish. I am a former resident of Iden Green and I am an owner of land there. My objections are as follows: First, the allocation of new housing throughout the parish is seriously imbalanced with over half of the total for the whole parish allocated to the East End and none at all to Iden Green. I submit that new housing should be distributed much more evenly and fairly around the parish. In particular the site that I own (LS8, adjacent to the Congregational Church) would offer a modest 26 units according to its Strategic Housing and Economic Land Availability Assessment (SHELAA) – a worthwhile and proportionate contribution. Second, the SHELAA for the site gives its remote location from “services and facilities” as a reason for rejecting it. Regarding facilities, as noted in the SHELAA, it adjoins the Congregational Church which also houses a nursery, the community hall and recreation ground (with tennis courts) are alongside, and The Woodcock, a well established pub and restaurant, lies within easy walking distance. These are all worthwhile facilities, while others such as the village shop and the primary school are only a mile away in Benenden. They are, moreover, easily accessible by footpath, which is safe for schoolchildren and pleasant to walk particularly through Hilly Fields. None of these facilities exist at the East End – three times further than Iden Green from Benenden. Third, the site’s SHELAA also rejects it on grounds of remoteness from public transport. There are is in fact an occasional bus service with a stop near to the site – not ideal but that serving the East End is, I believe, no more adequate. Rail services are some distance away, but this is true for all parts of the parish. In the Overview of Benenden (pp264 & 265 of the Plan) Staplehurst Station is not mentioned for Iden Green and should be shown, at a distance only 0.2km greater than for the East End, while the distances to Etchingham for Benenden and Iden Green appear to be inconsistent. Access to public transport for Iden Green and site LS8 in particular are thus no worse than for Benenden centre or the East End so not a valid reason for rejection of thesite. Fourth, the SHELAA claims that site LS8 is “likely to adversely impact upon the Conservation Area” (of Iden Green), because development allocation would influence “loss of Greenfield land within the AONB … adjacent to an Historic Settlement.” Exactly the same could be said of any of the allocated sites, indeed 98% of the whole parish lies within the AONB and LS8’s impact on Greenfield land would be relatively slight – certainly less severe than for some of the others, notably AL/BE1, 3 and 4, given it’s relatively small size and flatness, with well grown boundaries as acknowledged in the SHELAA. The prominence of sites 421 and 424 at the East End makes them significantly more damaging. LS8 would in fact round out the “Historic Settlement”, since it lies within it so would be infilling, not an extension of the settlement as implied by “adjacent to”. It would thus on balance be a preferable site for development allocation. Fifth, it is noted that LS8 is outside the Limits to Built Development as presently drawn. If the Local Plan is adopted unamended then Iden Green’s LBD will no longer exist. The reasons for the LBD’s removal repeat those already addressed above. I contend that sites such as LS8, which provide relatively modest infilling offer housing to help meet needs with minimal impact upon visual amenities. Finally, I understand that your Borough Council has recently established a cross-party Task Force with the objective of reducing carbon emissions and thus to make a positive contribution to climate change. To respect this aim, allocation of sites such as LS8 within feasible walking distance of the village should take precedence over sites where every family would require at least two cars. I request that these objections are given full consideration in the review of the draft plan. Site LS8 is worthy of inclusion in the plan. Building within a long-established settlement contributes much more to conserving our landscape and protecting wildlife than building three miles outside it, as proposed for the East End hospital area. I should appreciate it if you would kindly acknowledge receipt of my letter. |
DLP_7799 | Mr and Mrs T Hollings | Could you please ensure that the following is included with the above submission. Unfortunately I was unable to get sight of the document prior to its submission, meeting change dates by the Parish Council. Having now read the document in full I have become aware of a mistake in one area that has slipped through, particularly the latter part of the second sentence section 5 As shown below. ‘Section 5 Development proposals for Brenchley and Matfield paragraph e. Second sentence ‘The Council also rejects the extension of the LDB at Market Heath and around the former Corsica Nursery in Matfield, for which there does not appear to be any justification’ The TWBC document ‘ LDB Topic paperwork draft local plan regulation 18 consultation August 2019’ This document outlines the methodology and criteria for the establishment of LDB Minor extension of of the LDB at Corsica Nursery is specifically justified Items 1 to 7 then item 25 and 25.1 Of note para 7 Boundary review 7.1 a. To ensure that LDB boundaries are logical and reflect what is on the ground The said buildings and sheds have been in existence for over fifty years! I should also like to point out that no one from the Parish Council has visited Corsica Nursery or at any time contacted myself in this regard. |
DLP_7963 | Wendy Owen | Royal Tunbridge Wells and Southborough LBD Boundary Amendments (SOUTH; site reference 13-30) Map reference 19: The proposed boundary amendment in respect of Policy AL/RTW 18 / site 137 is contrary to many of the criteria set out in this Topic Paper (see examples below) and consequently we strongly challenge it. “The definition of LBDs is an established policy tool to provide both certainty and clarity to residents, landowners, developers, and other interested parties on where new development would generally be acceptable in principle. By drawing LBDs around settlements (including land to meet growth needs), LBDs help focus growth to sustainable locations/settlements, while protecting the surrounding, more rural areas from inappropriate and intrusive development. LBD boundaries should normally follow physical features, e.g. roads, walls, field boundaries… Any amendment to LBDs should:… (c) have no adverse impact on landscape character (d) have no adverse impact on designated areas of national and local landscape, archaeological, geological, ecological or heritage importance (e) be of a scale/nature in keeping with the form and function of the settlement and result in no harm to its character, appearance or setting - does it relate more to the built environment or to the surrounding countryside? IV. Large rear gardens or paddocks stretching well out from the built form of the settlement. Where there is an obvious variation in the rear line of garden curtilages along the edge of a settlement, then a striking line will be applied through these to form a uniform edge to the settlement XIV. Heritage assets with important landscape settings Site allocation AL/RTW 18 (land to the west of Eridge Road at Spratsbrook Farm) incorporated, with landscape buffer excluded. Policy wording in the Local Plan ensures this site will be appropriately developed and the natural boundaries suitably retained where appropriate and taking into account local landscape sensitivity. As there is at present insubstantial site layout information for the school part of the site, the LBD boundaries will be reviewed at the first Local Plan review 5 years postadoption of the Local Plan. This site (excluding landscape buffers) will form part of a Green Belt release. (a), (c), (d), (e), (f), (g), III, and XIX”. Map reference 28: We challenge the LBD boundary in respect of map reference 28 and the land to the east of Rusthall currently used by TW golf club, which appears to be outside the LBD. The site was offered for development but for the purposes of this draft plan deemed unsuitable, a decision we are challenging. There are far fewer and less significant criteria which apply to this site; in fact only “(b) not result in coalescence – important gaps should be retained” is relevant. “Extent of The Spa Hotel grounds within the LBD on the northern side of Langton Road, adjacent to the Tunbridge Wells Golf Club, reduced as this is a large, landscaped, partly open and wooded area in the Conservation Area on the edge of the settlement. VI and XIV” Also see comments above: * Section 4: Policy STR 10 |
DLP_4801 | DHA Planning Ltd for Caenwood Estates and Dandara | 4 Comments on technical documents Comments on Limits to Built Development Topic Paper 4.1.22 Amendment 10 to the TW LBD now excludes Tunbridge Wells Sports Centre from the LBD and places it in countryside as they are used for recreational purposes on the edge of the settlement. The adjacent LBD boundary excludes areas of development to the rear of the Sports Centre, including the extension to St Gregory’s Catholic School (currently under construction immediately west of the Sports Centre) and the adjacent 3G floodlit pitches. These form part of the urban environment and should be included in the LBD. [TWBC: see full representation]. |
Local Green Space Assessment
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_222 | Ian Russell | I am writing following the recent release of the TWBC Draft Local Plan, Regulation 18 Consultation Draft, 20th September 2019 to 1st November 2019 to register our OBJECTION to the inclusion of the Standen Street Orchards (North) as a Local Green Space (LGS) candidate site within the LGS assessment, Document 3.2, Settlement: Iden Green. Please see the attached extract from Supporting Documents, 3. Environment and Landscape, LGS Assessment Draft Dated July 2019, Page 12. (TWBC LGS Iden Green July 2019) The stated bases for its inclusion are factually incorrect in almost every respect:
Following the Standen Street orchards inclusion as an LGS candidate site in the Benenden Parish NDP, Regulation 14 Edition INITIAL Draft dated July 2019, representations were made by ourselves and others to the Green Working Group in the above terms following which and after reconsideration the Parish Council decided to withdraw the site from its candidate list and has been deleted from its FINAL version Regulation 14 Draft. For your further information, attached is a copy of email correspondence with Nancy Tolhurst serving on that Working Group giving further detail to the scope of our private land holding, our objections and incorporating Parish Council confirmation of the orchard site’s withdrawal. Also for your further information, we are attaching a copy of our response to the Parish Council Clerk Caroline Levett within the formal comments process following publication of the initial Regulation 14 draft. You will note that personal contact details are contained within each of the attached .pdf documents. If these are to form part of the published record please take normal steps to see these private details are obscured. Having regard to all of the above, we would request that the Borough Council reconsiders on this inclusion and that it adopts a position consistent with the Parish Council leading to withdrawal of the Standen Street orchards from its list of LGS candidate sites. See image |
DLP_421 | Jasper Bundy | My family own a sizable portion of the total acreage including all access ways and boundary hedges and I am writing to put on record that we fully endorse the comments made by Mr and Mrs Russell in their letter of objection dated 26th September 2019 [see comment number DLP_222]. As the largest land owner within the orchard I would like to point out that there has been absolutely no attempt to contact or inform us of this impending change of status. In fact, we along with the other 300+ land owners within the orchard would, potentially, have had our property reclassified with absolutely no notice or opportunity to object. I hope that our objections bring clarity to the situation and our property is removed from the LGS candidate site. |
DLP_657 | Anthony Harris | Local Green Spaces Firs Pitch, Curtisden Green Goudhurst To support the Parish Council and NDP application to designate the Firs Pitch in Curtisden Green, Goudhurst as a Local Green Space I would offer the following history of the site over 85 years and my own recollection over 60 years. From a historical perspective the currently named Firs Pitch and formerly named Cricket Meadow has for probably a century or more been the centre of the community and is probably the area that was referred to as The Green of Curtisden Green. Victorian Ordinance Survey maps show the area to the east and west of the lane running between the Providence Chapel and the original Bethany House School as Curtisden Green. Further, in the book published by Cambridge University Press in 1930, written by Frank Kendon, the son of the founder of Bethany School and called The Small Years he describes his childhood at the Bethany School House. He describes the view from his nursery window at the school and on pages 4 to 6 of the book he describes the walk around the Cricket Meadow, the house and their occupants walking past The farm or house known as The Firs and back to the school house past the cobnut wood as. ”... it was known as going round the Green”. The Cricket Meadow evolved and by the 1960s was a lovely cricket field with a mown cricket square sloping gently down from the pavilion now positioned by the Firs and where the orchard once was. In the late 1960s cricket was even played in the summer holidays between the local farming community led by the Wickham’s from Combourne Farm and Bethany School staff (led by the Bursar Roger Vickers if memories are correct ) The losers then bought the beer for the winners at the then Woolpack Inn at Winchett Hill. It is therefore difficult to describe the Cricket Meadow as a rough field and part dump at this period mid 60’s into the 70’s. It was eventually levelled into today’s flat pitch after the great storm when many of the great trees around the boundary came down. From my own memory I first visited Curtisden Green and walked on The Green in 1953 when my parents moved to Kent and visited their friend and writer on Kent, Richard Church. Richard lived opposite the Firs at The Oast House he had converted into a house during the war years and where he wrote his books looking across the Combourne valley to Goudhurst, as one can today. The views and lanes of the surrounding area are featured in his books including A window on a Hill published in 1950 and Small Moments published in 1957. My memory of the house and the Green being solidified when my parents bought The Oast House from Richard Church in the 1960’s and I took it over in 2010 after my father’s death. It is therefore in my recollection that the Cricket Meadow now called The Firs Pitch forming the historic centre of Curtisden Green has been open to and used by the community throughout the last 60 years and most probably the 60 years before, as indicated in The Small Years and ancient Ordinance Survey and other maps. The Firs Pitch, formerly the Cricket Meadow, today forms the centre or apex of the hamlet of Curtisden Green. Looking across from Curtisden Green Lane one sees to the south across the Combourne valley to the ridge beyond. From the southern end of the pitch one has a lovely view to Goudhurst Village on the horizon with St Mary’s church tower at its apex as indeed the reverse from the top of the church tower. Curtisden Green forms one of the three prominent ridge or hilltop settlements that comprise the Parish of Goudhurst. The character of the settlement of Curtisden Green and the views of and from it being protected and enhanced by the open 5-acre field just to its south. See supporting documents from Frank Kendon’s 1930 book The Small Years - namely the hand drawn map of Curtisden Green and the Cricket Meadow and description of “the walk around the green” on pages 4 to 6. |
DLP_6416 | Hawkhurst Parish Council | Response on Local Green Space Hawkhurst Parish Council are generally supportive of the principles: to protect Green Space Hawkhurst Parish Council is supportive of the proposed Local Green Spaces in Hawkhurst – sites 108 – 133 and As26. However, note that Site 119, Dunks Alms House, is, in fact, the residential garden for the residents of Dunks Alms House. |
DLP_8152 | Ashley Saunders | Site 27: Whetsted Wood was submitted by Paddock Wood Town Council to be designated as a Local Green Space in the dLP (see Local Green Space Assessment page 29), however, it was not selected with the justification being “There is insufficient evidence that this site meets the designation criteria, is already sufficiently protected under other designations, and is to be an allocated site in the new Local Plan” Clearly, it is not sufficiently protected by its status as Ancient Woodland (see Tunbridge Wells Borough Landscape Character Assessment LCA 13 – Paddock Wood / Five Oak Green Low Weald Farmland p.127) or the land would not be included in Policy AL / CA 3 & AL / PW 1. I requests that this area is designated as a Local Green Space and protected from development. Site 24: Green Area with Village Sign was not designated as a Local Green Space, the justification being that “This area was not considered as it is already sufficiently protected under other designations”. I requests that this area is designated as a Local Green Space and protected from development. |
DLP_490 | Dunk's Almshouse Charity | We have been passed your letter of 29th July addressed to Buss Murton of Cranbrook concerning the proposal to consider the frontage of Dunks Almshouse, Hawkhurst as a designation Local Green Space. We write to register our objection to the proposal. We must confess to being somewhat confused by the proposal as the land is not owned by or regularly used by the general public but rather is within the curtilage of the Dunks Almshouse and is for the benefit of the Almshouse residents and not for public enjoyment or use. We do not encourage any access by the public as we would have grave concerns as to the safety and security of the residents of the Almshouses and their right to quiet enjoyment of their own residence. We would also be apprehensive as to our residents' own wellbeing, some of whom are over 90, if the space was allowed to be designated as such it could become a communal area for the wider Hawkhurst community. The only time there is any public access is along the path to the School Room that is used by the local community for recreational purposes but those visitors are not allowed or encouraged to use the lawns and only have access within the terms of the hire of the Hall and for the period that it is rented out. It is not a public area and we do not encourage it to be so. Having considered the notes for guidance to which you refer we do not consider that the frontage constitutes a green space within the meaning described in the notes and hence write to register our strong objection to the proposal that it be considered designated a Local Green Space. We note that Hawkhurst's own Neighbourhood Plan Inspector has considered and rejected the site as a Local Green Space already and we support that decision. Further we consider the area to have a high level of protection due to the planning restrictions already in place. As early as 1972 it formed part of the Highgate and All Saints Church designated Hawkhurst Conservation Area's as Special Character (as continued under the revisions of 1992 and 1999). The lawns at the front of the historic and beautiful Dunks Almshouse are an important part of the Alsmhouse for the reasons set out above and as Trustees we will continue to respect and tend them in the future. |
DLP_563 | Mr Mike Prentis | I refer to the letter dated 29 July 2019 from the Planning Officer addressed to myself, and the request for Representations from the Head of Planning Services (email dated 16 October 2019). My wife and I own site 101 now proposed as Local Green Space. This site is subject to a tenancy. Whilst my wife and I are happy to see this site designated as Local Green Space there is a small part of this land we would request to be excluded. The area we would like to see excluded is West of Oakley and Pedler's End, and bound to the West by a line which links the end of the garden of The Stores and half way along the Northern boundary of Shepherds Lawn, roughly as Westerly as the Western most part of the buildings which form Shepherds Lawn. This small parcel of land is one on which we may one day seek to obtain planning permission for a one or two storey residential property, probably which we could occupy when we are perhaps too old to live in our existing property (Benyons, which we have lived in for 20 years). Clearly any such development would have to have limited impact on adjoining properties. We are not seeking permission for such a development now, and indeed we may never do so. However my concern is that if this small land parcel is designated as Green Space now, we will never be able to seek the possible small development I have outlined; thus the email. I hope this is clear, and I would happily clarify the above if you would like. Please also let me know as soon as possible if this format of response is not acceptable; I am obviously keen that our views are properly taken into account. |
DLP_656 | Bethany School | 1. Introduction and Summary I am writing on behalf of Bethany School in response to your letter of 29 July 2019 which informed us that land owned by the school (Site AS-1 (The Firs Pitch)) was likely to be proposed in whole or in part for Local Green Space designation. Your draft Local Green Space Assessment dated July 2019 also refers to a second parcel of land owned by the school (Site AS-2 (Field to the South of the Firs Pitch)). The draft Local Space Assessment states that there is insufficient evidence that this second site meets the designation criteria. However, we understand from the Goudhurst Neighbourhood Plan committee that they may still consider whether this second site should be proposed for designation. Consequently this letter also deals with that second site. In the case of both plots of land we do not believe that the statutory criteria for designation are met and in particular, we are concerned that your proposed designation of Site AS-1 appears to have been based on inaccurate information provided to you. Therefore we do believe that either site can or should be designated as a local Green space. 2. National Planning Policy Framework (NPPF) As you are of course aware, the NPPF provides, at paragraph 100, that: "Local Green Space designation should only be used where the green space is: (a) in reasonably close proximity to the community it serves (b) demonstrably special to a local community, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife" We understand that both TWBC and those preparing the Goudhurst Neighbourhood Plan have had regard to these criteria. The Consultation Draft Neighbourhood Plan expressly sets out how the criteria in (b) have been applied in relation to each Site. The TWBC Local Green Space Designation Methodology, while also referring to paragraph 100, sets out a number of sub-criteria which TWBC will consider. We have commented on those in relation to each site below. However we believe that in considering those criteria both TWBC have been misled as to the history and use of the sites and that consequently the conclusions reached on designation are unsafe and should be reconsidered. Taking each Site in turn 3. Site AS-1 (The Firs Pitch) In the TWBC Local Green Space Assessment is states that: "This area is used by the local community for informal recreational activities. This area is also of local historic significance, having previously been called the Cricket Meadow back into the 19th century and has been continuously used since for walking dogs, families and children playing football, cricket, picnics etc. This area is an important central open space that makes a positive and significant contribution to the local landscape character. This area has panoramic views to the south and east looking onto the AONB" This wording is similar to much of that contained in the draft Neighbourhood Plan, from which we assume it was derived. However it is not accurate. The land now forming the Firs Pitch, the called Newhouse Farm, was acquired by the school in 1885. The sale included the farm house, four cottages, farm buildings and a saucer-shaped field that was then used for cricket by the school (the "cricket meadow"). The swamp near the Firs was filled in in 1973. For a while the area was used as an open tip. In around 1977 the Firs meadow was levelled, enlarged by removing an old path, hedge and trees and the school's vegetable patch, and filling in the old clay pit, to create the current playing fields. The source for this information is the History of Bethany School "From Acorn to Oak Tree", published some 20 years ago. A copy of the relevant extracts is attached to this letter. Over the last 30 years any use of the Firs pitch has only been with the permission of the school. That has normally been permitted (and a few years ago a neighbourhood event was held on the field). No doubt, given that the school has not chosen to fence the field, locals do occasionally walk over the field but the walking of dogs is, for obvious reasons, as it is a playing field, not permitted. It is helpful to review this Site against the sub-criteria in your Local Green Space designation methodology. Taking each in turn (with our comments in italics): "The proposed space is of particular local significance because of its beauty
Clearly the fact that the Firs Pitch is there gives a more attractive outlook for houses in Curtisden Green than if it was not - but no more so then any other green space.
Not mentioned so far as we are aware. As a flat playing field it does not contain characteristic features
No
There are no particular valued views of the site. As with most open spots in the local area there are some views of surrounding countryside. However, that is only relevant if the school permits access. There is no public right of access. The proposed space is of particular local historic significance
No
No
No
No
No The proposed space is of particular local significance because of its recreational value
No community use for playing sport. It is used only by Bethany School
It is not used by the local community for formal and/or informal recreation.
It is a private playing field. It is only accessible with the permission of the school. It is obviously visually prominent to the inhabitants of the limited number of buildings adjoining the field - but not otherwise.
As the School has currently chosen not to fence the field, the public are physically able to access the field, although they need permission to do so. We note that the draft Goudhurst Neighbourhood Plan Stage 2 assessment did not consider that the criteria for recreational value were met. The proposed space is of particular local significance because of its tranquility
The site is surrounded by roads albeit minor village roads) on each side and therefore it is not particularly tranquil.
No The proposed space is of particular local significance because of its wildlife
No
No
No Based on the above we can see no basis for designation of this Site. In particular the suggestion in the draft Goudhurt Neighbourhood Plan "Assessment and Allocation" document that it should be designated because of its historic significance, tranquility and richness of wildlife, seem to us to be completely groundless. 4. Site AS-2 (Field to the south of the Firs Pitch) As refereed to above, TWBC did not in your Local Green Space Assessment propose designation of this Site. We believe that to be correct. However, also as mentioned above, we understand that this view may not be shared by the authors of the draft Goudhurst Neighbourhood Plan and therefore we have addressed your designation sub-criteria below. There is no description of this property in your draft Local Green Space Assessment. However the Neighbourhood Plan "Assessment and Allocation" document claims that "This area is of local significance because it affords long reaching views over the AONB...This area is uused by the adjacent Bethany School for occasional hockey games as well as as regularly by the community as a recreational walking area and for flying kites, playing with children and exercising dogs". This area of land was formerly an orchard and there is no historic access to it. It is also not in "reasonably close proximity" to the settlement at Curtisden Green (as required by paragraph 100 of the NPPF). The description quoted suggests regular use by the community for recreational activities (which is contrasted by, misleadingly, with "occasional" school use). There has been no recreational use - and although the School has historically tolerated occasional walkers, any greater use would require its permission and this has not been given. The views from this field are limited and it is sloped. The school has not used it as a playing field for a number of year due to the sloped nature of its surface. It is a privately owned school field with no permitted access to the public. "The proposed space is of particular local significance because of its beauty
The proposed space is of particular local historic significance
We note that the draft Goudhurst Neighbourhood Plan Stage 2 assessment did not consider that the criteria for beauty were met. The proposed space is of particular local significance because of its recreational value
We note that the draft Goudhurst Neighbourhood Plan Stage 2 assessment did not consider that the criteria for recreational value were met. The proposed space is of particular local significance because of its tranquility
The proposed space is of particular local significance because of its richness of wildlife
We note that the draft Goudhurst Neighbourhood Plan Stage 2 assessment did not consider that the criteria for richness of wildlife were met. Based on the above we can see no basis for designation of this Site. In particular the suggestion contained in the draft Neighbourhood Plan that it should be designated because of its tranquility (in the absence of the other factors above) seems to us completely groundless. 5. Conclusion As can be seen from the evidence above, it is beyond reasonable doubt that there is no case for the designation of either AS-1 or Site AS-2 as Local Green Spaces. Indeed, the designation of sites which are not in accordance either with the National Planning Policy Framework or in accordance either with the National Planning Policy Framework or in accordance with the methodology set by TWBC for the identification and designation of Local Green Spaces would render any related Local Plan or Neighbourhood Plan clearly unsound and open to challenge. If it would be useful for the school to provide any further information, please do let me know. |
DLP_3732 | Capel Parish Council | Comments are repeated from COMMENT BOX 7 above Site 27: Whetsted Wood was submitted by Paddock Wood Town Council to be designated as a Local Green Space in the dLP (see Local Green Space Assessment page 29), however, it was not selected with the justification being “There is insufficient evidence that this site meets the designation criteria, is already sufficiently protected under other designations, and is to be an allocated site in the new Local Plan” Clearly, it is not sufficiently protected by its status as Ancient Woodland (see Tunbridge Wells Borough Landscape Character Assessment LCA 13 – Paddock Wood / Five Oak Green Low Weald Farmland p.127) or the land would not be included in Policy AL / CA 3 & AL / PW 1. Capel Parish Council requests that this area is designated as a Local Green Space and protected from development. Site 24: Green Area with Village Sign was not designated as a Local Green Space, the justification being that “This area was not considered as it is already sufficiently protected under other designations”. Capel Parish Council requests that this area is designated as a Local Green Space and protected from development. |
DLP_6067 | Kember Loudon Williams for Cranbrook School | Our representations relate to the inclusion of Rammell Field, Bakers Cross (site no: 36) which we feel should be reconsidered for only a partial inclusion, as discussed in our accompanying Report, Chapter 7. [TWBC: see full supporting statement. Chapter 7 is copied below]: 7 Rammell Field Relevant Policies: STR1, STR/CRS1, EN17 7.1 The site in question is an existing ancillary playing field owned by Cranbrook School and used infrequently for rugby purposes. It is relatively remote from the main School campus and cut off from it by the main road (Bakers Cross). It is well within the limits to built development for Cranbrook and the Conservation Area boundary runs through the front of the site. 7.2 The field is surrounded by residential properties and the prevailing character is residential, with the exception of Rammel Boarding House & Tippins cottage to the west of the field. The field is set between and within close proximity to many notable listed buildings along the Hill and Bakers Cross, within the Conservation Area. The Conservation Area Appraisal Townscape Analysis also identifies significant tree groups opposite the site to the north, and along the western boundary to the field at the front. The Map below (Figure 8) has been taken from the Cranbrook Conservation Area Appraisal and shows the boundary to the Conservation Area. [TWBC: for Figure 8 Map showing Cranbrook Conservation Area Boundary, see full supporting statement]. 7.3 The Conservation Area Appraisal notes the site as having particular importance in providing a rural feel to the approach of the town from the east and the fact that the field is designated at a local level as an “important open space” in the 2006 Local Plan. This is further supported by TWBC in their recent Local Green Space Assessment where they proposed to designate Rammell Field in its entirety as a Local Green Space. The reasons given by TWBC for this designation were due to its visual prominence in the local community and its contribution to the character/setting of the settlement. 7.4 Notwithstanding the perceived community and visual value of the field, the land is privately owned and is gated, with any use by the wider community at the discretion of the school. Furthermore, by reference to historic aerial images, the site has been bordered to the south and south-west by housing since at least 1960 and accordingly has little or no broader visual relationship or contiguity with the wider, rural AONB landscape. 7.5 The field was previously considered under the SHELAA and Sustainability Appraisal, site reference 132, for its potential to accommodate housing development. However, it was concluded that the site was unsuitable as a housing allocation for a number of reasons, namely for heritage and landscape reasons. It was felt that the site makes an important contribution towards the setting of the Conservation Area and therefore it scored negatively in terms of heritage. Furthermore, it was suggested the development of the site would result in the loss of a historic field in the AONB, which resulted negatively on the landscape score. 7.6 Cranbrook School considers that the field remains a suitable and sustainable location to accommodate new housing and is promoting the inclusion of part of the field as an additional future housing allocation within the Local Plan. It is considered that in line with the diagram below (Figure 9) showing proposed land use, that the front part of the site should remain designated as Local Green Space, as per the recommendation under draft Policy EN17, but the rear section of the field be dedicated to housing development. [TWBC: for Figure 9 Map showing proposed housing allocation at Rammell Field, see full supporting statement]. 7.7 The recognised matters of importance in terms of the sites characteristics i.e. heritage and landscape features relate predominantly to the front section of the field. The retention of this part of the field as a Local Green Space, with additional landscape buffer beyond the Conservation Area boundary, will continue to provide the visual and landscape benefits to the setting of the Conservation Area, but will also offer wider community enhancements as a public open space for use by the local community. It should be noted that the dimensions of the field are such that it is very deep relative to its width (average depth of 180m approx.). Therefore, the visual significance of the rear part of the field is considered of lower value than the front portion. 7.8 In terms of the remainder of the site, this is considered a suitable location for housing, including affordable housing, potentially including key worker and/or local needs housing. Retaining a mixed and economically active population is a challenge with rural towns such as Cranbrook, owing to the affordability issue relating to its established housing stock. The provision of suitable lower cost housing to respond to local housing needs responds to both the TWBC Housing Needs Survey 2018 and the recent independent AECOM Housing Needs Assessment 2017 (as included within the draft Cranbrook and Sissinghurst Neighbourhood Plan). The draft Cranbrook and Sissinghurst Neighbourhood Plan includes a requirement of approximately 300 affordable homes made up of mostly 1-2 bedroom and some 3 bedroom properties. 7.9 Given the established residential pattern of development adjoining the site, a net yield of between 40-50 dwellings per hectare on the part of the site allocated for development has been identified as being appropriate. The size of proposed developable area measures approximately 1.1ha and therefore around up to 50 units should be considered, subject to design and landscaping considerations, which is less than the Housing Capacity Assessment yield identified by Tunbridge Wells in 2015. The potential for some apartments towards the south of the site should be considered but designed sensitively and incorporating a suitably ‘domestic scale’. Access is considered able to be achieved via Frythe Way, with public access into the front park area remaining via Bakers Cross. 7.10 On the basis of the above comments, we would urge TWBC to consider adapting its draft policies STR1, STR/CRS1 and EN17 to account for this additional housing and public space provision. |
DLP_4440 | Town and Country Planning Solutions for Gleeson Strategic Land | Paragraph Numbers 6.172-6.176 Policy EN 17 Local Green Space
101. Policies for managing development within a Local Green Space should be consistent with those for Green Belts”. 8. Appendix EDP 2b of the EDP Local Green Space Assessment contains extracts of the NPPG guidance relating to LGS designation. This includes;
9. For the detailed reasons set out in the EDP Assessment (Appendix 4), the Council’s proposal to designate the Gleeson land as Local Green Space fails the second of the three combined tests for designation set out in paragraph 100 of the NPPF and directly conflicts with all the NPPG guidance set out above 10. The Council has provided no evidence that the Gleeson land is ‘demonstrably special to the local community’ sufficient to justify Local Green Space designation. It is clear that from the schedule on page 94 of the Council’s dLGSA, that the proposed designation of the Gleeson land (proposed Local Green Space site no. 217) has (together with many others) not come about through any approach by the local community, but has instead resulted from an “in-office suggestion” (no doubt as a response to the previous Gleeson consultations to seek to release part of the land for housing purposes). Paragraph 2.11 of the LSGDM (and elsewhere) states that following the current draft Local Plan consultation, the Local Green Space designation might be changed prior to the formal submission of the Plan for Examination (i.e. at the Regulation 19 stage). All of these proposed designations should be reviewed and carefully assessed and judged against national policy and guidance, especially as of the 383 sites assessed in the DLGSA, some 69 (18%) have not actually been promoted by the local community, but have instead resulted from an ‘In Office Suggestion’. Of the 227 proposed Local Green Space designations in the draft Plan, some 44 (19.3%) were as a result of an ‘In Office Suggestion’. Inset Map 2 Delete policy alloctation EN17 from land at Sandown Park, north of Pembury Road, Royal Tunbridge Wells. |
Residential Parking Standards Topic Paper
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_7964 | Wendy Owen | The ONS 2011 census data is eight years old and therefore not necessarily accurate. The basis of the plan seems sound, but the amount of residential street parking suggests current provision is inadequate, making for slalom driving and bus access issues in some cases. Proposed development site AL/RTW 18 / site 137 is outside the LBD and consequently is subject to zone C requirements. |
Strategic Flood Risk Assessment
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_3940 | Mrs June Bell | Flood risk and spatial datasets has not included for allocation AL/CRS7 (site 32) which lies in a 3b flood zone. |
DLP_6221 | Paddock Wood Town Council | For Paddock Wood Town Council's comments, see full tracked version of the SFRA. |
DLP_7403 | ASP Planning for Yalding Parish Council | INTRODUCTION 1. ASP have been instructed by Yalding Parish Council to review the Regulation 18 Tunbridge Wells Local Plan 2019 (hereafter referred to as the Local Plan) and its associated evidence base as to the potential effects of the plan on Yalding Parish. FLOODING 11. The impact of any development on the river network is a significant consideration for Yalding Parish. The parish is the meeting point for three rivers; Medway, Teise and Beult. On reviewing the local plan and the relevant parts of the evidence base, the Parish have concerns regarding the impact of the proposed development strategy on two of these river networks; the Medway and the Teise. 13. In respect of fluvial flooding, the SFRA recognises that a primary cause of fluvial flooding events on the River Medway is the overloading of foul and/or sewer systems in the Paddock Wood area. The proposed level of development is thus likely to increase this issue. However, there are several mitigation schemes proposed, although precise details are not yet known. b. The DEFRA guidance requires neighbouring authorities to be consulted on the SFRAs and neighbouring district authorities have not been consulted e.g. Maidstone so the SFRA cannot have considered proposed strategic development in other authorities. c. New DEFRA guidance also requires a review of other local authority SFRA’s under a Stage 1 SFRA this doesn’t appear to have been done CONCLUSION 20. In conclusion, our review of the Regulation 18 Local Plan and associated evidence base has raised concerns about whether the impacts of the proposed level of development in the northern part of the district is effective and sustainable due to some gaps in the evidence base. [TWBC: see also Comment No. DLP_7402 - Appendix 5 (Transport)] TWBC note: no appendices were attached with the representation |
Strategic Housing and Economic Land Availability Assessment
Comment No. | Name/Organisation | Response | ||||||||||||||||||||||||
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DLP_1903 | Royal Tunbridge Wells Town Forum | Topic Paper or supporting document title: SHELAA Site Assessment sheets for Royal Tunbridge Wells We previously submitted detailed comments on a number of the sites submitted under the Call for Sites which might become subject to an allocation. We set out those comments again under each specific AL/RTW Policy in relation to the sites now proposed for allocation in the Draft. So far as sites which were considered unlikely to be allocated and have now not been allocated for future development, we set out our comments in Appendix 6. Town Forum policy is that development in the AONB and Green Belt should take place only on proof of exceptional circumstances. Any evidence put forward of exceptional circumstances will have to satisfy the Inspector at Examination in accordance with relevant legal precedent. In the very difficult circumstances of the current unsatisfactory relationship between Central Government and Local Authorities and subject to the important caveat above, we are broadly supportive of most of the sites now selected for allocation in the unparished area of Royal Tunbridge Wells, subject in many cases to conditions. We also strongly support decisions taken on those submitted sites deemed unsuitable for allocation as set out in our comments in Appendix 6. Full comments on sites proposed for allocation appear in our response to the AL/RTW Policies ante. This is subject also to the caveat that we do not agree with the method by which Central Government calculates housing need and the consequent target housing numbers. In particular, the Office for National Statistics produced a revised 2016 methodology, which in the case of Tunbridge Wells Borough would require only 67% of the 2014 figure, according to some analysts. The government-imposed methodology and fears of the Draft Local Plan being found unsound at Public Examination have perhaps led TWBC not to seek fully to exploit potential constraints recognised by the NPPF in relation to the 70% of the Borough which is classified as AONB and the 22% which is classified as Metropolitan Green Belt and also infrastructure constraints such as acknowledged severe existing water stress and problems with waste water treatment. The approach taken in this Regulation 18 Draft has resulted in some draft allocations in RTW and elsewhere in the Borough which are intrusive into Green Belt and AONB. We would therefore urge TWBC to keep carefully under review the legislation and any legal precedents and Inspectors’ decisions arising under the legislation in the period up to submission of the Regulation 19 Draft in relation to exceptional circumstances and housing need methodology, in case some mitigation of proposed incursions into the AONB and Green Belt may be possible. Topic Paper or supporting document title: Infrastructure Delivery Plan Please see our comments on infrastructure delivery in relation to individual Policies above Topic Paper or supporting document title: Transport Strategy Review Please see our comments under the TP Policies above. Topic Paper or supporting document title: Transport Study Please see our comments under the TP Policies above. | ||||||||||||||||||||||||
DLP_7292 | Miranda Hungerford | Draft Local Plan and Sustainability Appraisal We are writing to you to register our concerns and objections to the following:
2) With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the Limits to Build Development boundary, but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a clear and consistent manner. Conclusions The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan. Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will be heavily reliant on the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments. The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB. | ||||||||||||||||||||||||
DLP_6198 | Turley for Bellway Homes Strategic | Sustainability Appraisal Whilst the Sustainability Appraisal appears to consider the options for a Garden Settlement, we have been unable to locate any assessment at this stage which does not include such an option as part of the distribution strategy. In our view, it would be a reasonable alternative to consider a solution which does not include a Garden Village. In particular we consider that this is essential due to the fact that the Tudeley Village site is remote, does not benefit from access to rail services, is not related to existing services/facilities and significant intervention will be required to provide any facilities in the area. In contrast, alternative sites would provide opportunities to locate development in areas which already relate to existing settlements and services. We note that Table 20 of the Sustainability Appraisal sets out a list of reasonable alternative sites in Royal Tunbridge Wells. Site reference 53 (being the land promoted by Bellway) is referred to in that list of sites. Table 20 confirms part of the site is proposed to be allocated under AL/RTW 23. The scoring of site 53 against the SA objectives is contained on page 164 of the Sustainability Appraisal. The SA does not appear to include any detailed explanation as to how the scores have been calculated and so it is not possible for respondents and stakeholders to analysis the impacts of one site over another. [TWBC: the comments above have also been entered against the Sustainability Appraisal as Comment Number SA_109]. Proposals Map The Proposals Map published for consultation is of extremely low resolution and does not allow a clear understanding of the policies applicable to any specific area. We consider that it is essential, in order to understand how the Local Plan is to be applied, that a higher resolution version of the Proposals Map is made available. Green Belt Assessment In the LUC Green Belt Strategic Study of November 2016, the southern part of the site is located in Parcel TW6 and the remainder in Broad Are BA7, as shown below: [TWBC: see map on page 11 of full representation]. Parcel TW6 is identified as an area for further assessment, with Table 6.2 of the 2016 document identifying ‘Potential Stage Two parcels and broad areas’. In relation to TW6, Table 6.2 identifies the ‘Key Stage 2 Considerations’ as being the “Relationship between settlement and countryside, with reference to role of High Wood in forming barrier to encroachment/sprawl.”
Appendix A of the 2017 report also provided an analysis of the specific parcels against the Green Belt purposes. Bellway consider that the assessment in relation to Parcel TW6a is flawed. The table below sets out the assessment of this parcel in the LUC 2017 report and provides our response and reason why the conclusions are flawed:
The Turley Outline Landscape, Visual and Green Belt Advice Note demonstrates that the contribution of Parcel TW6a has been overstated, particularly when the land promoted by Bellway is considered independent. In the July 2019 SHELAA the land promoted by Bellway is considered under site reference 53. The assessment found that the “Site is suitable in part as a potential Local Plan allocation subject to further consideration”. The reason for this conclusion was stated as being “The southern parcel of this site lies adjacent to the LBD and is likely to be sustainable in this context. This would form a logical extension to LBD. The remaining area, the first parcel whilst in proximity to the LBD would not form a logical extension to the LBD and is considered to adversely affect the landscape setting of the town and is part of a Green Belt parcel the release of which is considered to result in very high harm, and setting of an Historic Park and Garden.” [TWBC: see full representation and Comment Numbers DLP_6189-6198]. | ||||||||||||||||||||||||
DLP_7491 | Freya Alder | Draft Local Plan and Sustainability Appraisal We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2). Planning Strategy
Conclusions The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan. Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments. The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB. We trust that these comments will be taken into account. | ||||||||||||||||||||||||
DLP_7532 | Ruth Murphy | Draft Local Plan and Sustainability Appraisal We are writing to you to register our concerns and objections to the following:
2) With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the Limits to Build Development boundary, but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a clear and consistent manner. Conclusions The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan. Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will be heavily reliant on the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments. The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB. | ||||||||||||||||||||||||
DLP_316 | Colin Inwood | TWBC: The following comment was submitted by the responders on the left: Benenden: Strategic Housing and Economic Land Availability Assessment claims that site 158 and site 222 (south west of the crossroads, barring the pond which, if this area is developed, is to be given to the village as green space) are lacking in “services and facilities including public transport at the settlement”. One wonders if the person who wrote this has ever visited the village? The claim is astounding. It is untrue. Benenden: Strategic Housing and Economic Land Availability Assessment: Iden Green is omitted from development and its Limits to Built Development line is to be removed yet Iden Green is a hamlet with a pub/restaurant. It has the same unreliable bus service as the East End but it is within walking distance of the village school. It has a footpath to the school, a short part of which runs along the road and is classified as a “Roadside Nature Reserve”. The rest of the footpath goes through fields, through the churchyard, and then directly to the new school. Why talk of new cycle and foot paths to link an area two and half to three miles outside the village when such links, and far shorter ones, already exist in Iden Green? | ||||||||||||||||||||||||
DLP_7741 | Fiona Chapman | TWBC: The following comment was submitted by the responders on the left: This paper contains many statements which are so inaccurate as to provoke smiles, if not sighs of disbelief. For example, its assessment of sites 158 and 222, both of which are regarded as unsuitable, for they “lack services and facilities including public transport at the settlement.” Yet the AECOM assessment (used by Benenden Neighbourhood Planners) says of 222 “Allocation of this site will contribute positively towards meeting local housing needs. The site is located in good proximity to the services and facilities located in Benenden village centre (c.100m) which will limit the need for residents to travel for some day-to-day services and facilities.” And of site 158 AECOM reads “allocation of the site will contribute positively towards meeting local housing needs. The site is located in good proximity to the services and facilities located in Benenden village centre (c.300m) which will limit the need for residents to travel for some day-to-day services and facilities.” The reality on the ground agrees with the AECOM argument. * I also subscribe to the arguments put forward by the Friends of East End. | ||||||||||||||||||||||||
DLP_2136 | Ms Hazel Strouts | This paper contains many statements which are so inaccurate as to provoke smiles, if not sighs of disbelief. For example, its assessment of sites 158 and 222, both of which are regarded as unsuitable, for they “lack services and facilities including public transport at the settlement.” Yet the AECOM assessment (used by Benenden Neighbourhood Planners) says of 222 “Allocation of this site will contribute positively towards meeting local housing needs. The site is located in good proximity to the services and facilities located in Benenden village centre (c.100m) which will limit the need for residents to travel for some day-to-day services and facilities.” And of site 158 AECOM reads “allocation of the site will contribute positively towards meeting local housing needs. The site is located in good proximity to the services and facilities located in Benenden village centre (c.300m) which will limit the need for residents to travel for some day-to-day services and facilities.” The reality on the ground agrees with the AECOM argument. * Site 158 is rejected but only on a temporary basis. See AL/BE3 which requires an access route be allowed on that site for a road to access development on the land to the north, which is Site 158. This temporary rejection is curious. Delay in building at site 158 and instead building, at least in the first instance, 3 miles distant from the village, means that the parish will endure a double whammy of fairly large scale development. 92 houses at the hospital and 65 at 158 (considered by the council in 2018 as suitable for 174 houses). Building in two areas at some distance from each other, instead of from the settlement centre outwards, maximises damage to the environment and wildlife habitat as “travel connectivity” between the two are established. It threatens the landscape, tranquility and rural nature of the entire parish. It also raises questions of common sense, quite apart from challenging Objective 2, to “protect the valued heritage of the borough” and to “tackle climate change”. It is of interest to know why council officers changed their minds about siting development originally at site 158, once considered a site for building the new primary school. Why the decision to delay building there, at the expense of the East End and eventually, at the expense of the rural nature of the entire parish? | ||||||||||||||||||||||||
DLP_5770 | Herbert Boxall | I am writing to object to the part of the Tunbridge Wells Draft which deals with the parish of Benenden and, in particular, with that part which deals with the hamlet of Iden Green. within that parish. I am a former resident of Iden Green and I am an owner of land there. My objections are as follows: First, the allocation of new housing throughout the parish is seriously imbalanced with over half of the total for the whole parish allocated to the East End and none at all to Iden Green. I submit that new housing should be distributed much more evenly and fairly around the parish. In particular the site that I own (LS8, adjacent to the Congregational Church) would offer a modest 26 units according to its Strategic Housing and Economic Land Availability Assessment (SHELAA) – a worthwhile and proportionate contribution. Second, the SHELAA for the site gives its remote location from “services and facilities” as a reason for rejecting it. Regarding facilities, as noted in the SHELAA, it adjoins the Congregational Church which also houses a nursery, the community hall and recreation ground (with tennis courts) are alongside, and The Woodcock, a well established pub and restaurant, lies within easy walking distance. These are all worthwhile facilities, while others such as the village shop and the primary school are only a mile away in Benenden. They are, moreover, easily accessible by footpath, which is safe for schoolchildren and pleasant to walk particularly through Hilly Fields. None of these facilities exist at the East End – three times further than Iden Green from Benenden. Third, the site’s SHELAA also rejects it on grounds of remoteness from public transport. There are is in fact an occasional bus service with a stop near to the site – not ideal but that serving the East End is, I believe, no more adequate. Rail services are some distance away, but this is true for all parts of the parish. In the Overview of Benenden (pp264 & 265 of the Plan) Staplehurst Station is not mentioned for Iden Green and should be shown, at a distance only 0.2km greater than for the East End, while the distances to Etchingham for Benenden and Iden Green appear to be inconsistent. Access to public transport for Iden Green and site LS8 in particular are thus no worse than for Benenden centre or the East End so not a valid reason for rejection of thesite. Fourth, the SHELAA claims that site LS8 is “likely to adversely impact upon the Conservation Area” (of Iden Green), because development allocation would influence “loss of Greenfield land within the AONB … adjacent to an Historic Settlement.” Exactly the same could be said of any of the allocated sites, indeed 98% of the whole parish lies within the AONB and LS8’s impact on Greenfield land would be relatively slight – certainly less severe than for some of the others, notably AL/BE1, 3 and 4, given it’s relatively small size and flatness, with well grown boundaries as acknowledged in the SHELAA. The prominence of sites 421 and 424 at the East End makes them significantly more damaging. LS8 would in fact round out the “Historic Settlement”, since it lies within it so would be infilling, not an extension of the settlement as implied by “adjacent to”. It would thus on balance be a preferable site for development allocation. Fifth, it is noted that LS8 is outside the Limits to Built Development as presently drawn. If the Local Plan is adopted unamended then Iden Green’s LBD will no longer exist. The reasons for the LBD’s removal repeat those already addressed above. I contend that sites such as LS8, which provide relatively modest infilling offer housing to help meet needs with minimal impact upon visual amenities. Finally, I understand that your Borough Council has recently established a cross-party Task Force with the objective of reducing carbon emissions and thus to make a positive contribution to climate change. To respect this aim, allocation of sites such as LS8 within feasible walking distance of the village should take precedence over sites where every family would require at least two cars. I request that these objections are given full consideration in the review of the draft plan. Site LS8 is worthy of inclusion in the plan. Building within a long-established settlement contributes much more to conserving our landscape and protecting wildlife than building three miles outside it, as proposed for the East End hospital area. I should appreciate it if you would kindly acknowledge receipt of my letter. | ||||||||||||||||||||||||
DLP_6830 | Mrs Carol Richards | Site Reference 447 (Local Plan Allocation AL/CA 2 with site 454) * Green Belt considerations; AONB (2 component parts); These issues are NOT mentioned again in the following pages apart from the fact Suitability : It is found suitable and in the conclusion too. Reason : Proximity to settlements Tonbridge and Paddock Wood and can meet requirements of education need. The main reason for suitability seems to be single ownership and as a result it is therefore deliverable?. However, this fails to address a number of points, for instance: * The provision of a Secondary school at the Tonbridge Woodgate roundabout is utter madness. Every state school bar two ( the Hadlow rural community school and Hugh Christie) in Tonbridge are situated, as the crow flies along a distance of less than 2 ½ kms from Brook Street to the Woodgate roundabout. The number of pupils in these schools totals 5,206. There is also a large private school also within 100yds of the Woodgate roundabout, which has 750 pupils. In total within a 2 1/2 kms range, together with the 750 at the proposed new secondary school- there will be nearly 7000 school children. TWBC proposed site is on the other side of the roundabout to the Weald of Kent and opposite The Schools at Somerhill- that is 3 schools at the Woodgate roundabout. The logistics of those extra numbers on the traffic in Tonbridge is totally unacceptable. No infrastructure improvements will negate the problems that will arise from this plan. The knock on effect of roads in Tonbridge will mean traffic will tail back around the industrial estate and compound congestion in rush hour traffic along the Hadlow Road.( My main route into town.) The centre of Tonbridge will be tail to tail with traffic on every artery in the town. * The site is bisected by a main rail line which under legislation: www.legislation.gov.uk/uksi/2012/194/regulation/6/made States:- that under Health safe and welfare-The school premises and the accommodation and facilities provided therein must be maintained to a standard such that, so far as is reasonably practicable, the health, safety and welfare of pupils is ensured. The practicality of having a rail line running through the centre of the school site should stop this plan under uk law. TWBC estimate the school will cost approx. £31.9M. The lack of due diligence regarding this site makes this location unsound. | ||||||||||||||||||||||||
DLP_6831 | Mrs Carol Richards | Site Reference 448 (Local Plan Allocation AL/CA 1 Site address Land at Tudeley, Tonbridge in the Parish of Capel) This site is being proposed for a new settlement of up to 2,800 homes. * Green Belt considerations None of the above consider a Landscape Sensitivity Study (as site 447 does mention under issues and then conveniently forgets about it) If the SHELAA was to assess and consider this site against the LSA Criteria at para 2.9, the following observations would be relevant (LSA criteria in italics): * Physical and natural character (the shape, scale and complexity of the landform, the landscape pattern and the presence of natural or semi-natural features that are important to landscape character); Capel is geologically and topologically distinct- with a ridge leading down to the flood plain below teeming with wildlife * Settlement form and edge (the extent to which the sub-area relates to the form and pattern of existing adjacent settlement, and the character of the adjacent settlement edge); A description from LCA TWB Character 13 area p114 describes, A richer more diverse landscape pattern occurs on the undulating slopes around Capel and Tudeley where a historic field pattern of fields with wavy and irregular boundaries are separated by thicker hedges of locally distinctive hornbeam. * Settlement setting (the extent to which the sub-area contributes to the identity and distinctiveness of a settlement, by way of its character and/or scenic quality, or its value for recreation in which experience of the landscape is important); Views across this landscape provide a sense of rural charm, where historic farmsteads and oasts are a conspicuous features in the landscape stretching out towards the river Medway * Visual character (the visual prominence of the sub-area, the degree of intervisibility with the surrounding landscape, the role the sub-area plays in contributing to valued views, and the character of skylines); The views across the valley from Tudeley and from the valley up towards the skyline looking up towards Tudeley is a valued view on a sunny day or crisp winter’s morning the views stretch for miles around. TWBC ‘plan’ to destroy this landscape * Perceptual qualities (qualities such as rurality, sense of remoteness or tranquillity); Tudeley has a rural idyllic feel to i- that would be destroyed with the proposed settlement * Historic character (the extent to which the landscape has ‘time-depth’ – a sense of being a historic landscape – and/or the presence of heritage assets that are important to landscape character) Historic character is felt in spades at this site mainly due to the most phenomenally beautiful church of All Saints with the Marc Chagall windows. This importance of this site is a very obvious omission in the whole of this draft plan and is down played. A tactic I find shameful. It does not even feature on the Site Description regarding site 448 in the SHELAA Annex 04 The NPPF Section 16 states,’ Heritage assets of the highest significance , which are internationally recognised ( I think the Marc Chagall windows at Tudeley Church counts as such) ‘should be conserved in a manner appropriate to their significance’ The NPPF para 194 also states “Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification” Having the setting of the church surrounded by up to 2.800 homes is totally inappropriate. The NPPF rules are there for borough councils to follow -so please follow them. In domestic planning applications, TWBC requires an assessment of the impact of the proposed development on all heritage assets within a kilometre. Applying its own metric to its own development proposals the following approximate numbers of heritage assets in, or within a kilometre of CA1 are; 2 Grade 1, 1 Grade 2* and 70 Grade 2 listed heritage assets. This is a high number of assets that should be protected. Looking again at ‘Suitability’ in the SHELAA Annex 04 description of site 448, this seems to suggest the roads on this site have limited impact on its suitability for development. However, this ignores the fact that Sherenden Road is a tiny country twisty road and the Five Oak Green Road is Classified as a B road. The Achievability seems to rest on the fact that THIS SITE IS UNDER SINGLE OWNERSHIP AND THEREFORE ACHIEVABLE | ||||||||||||||||||||||||
DLP_6265 | Victoria Settle | TWBC: The following comment was submitted by the responders on the left: 2) With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner. | ||||||||||||||||||||||||
DLP_7929 | Fiona Dagger | TWBC: The following comment was submitted by the responders on the left: The decision making process is unclear and the decisions are muddled, inconsistent and incoherent. The lack of transparency makes scrutiny of the decisions problematic and it is difficult to ignore the conclusion that this is deliberate attempt to mask an inadequate evidence base, poor process and a desire to evade proper public scrutiny. The Site Assessment Sheets provide minimal information. We are aware of more detailed site assessment sheets being used by neighbourhood planning groups, such as Cranbrook NPC, based on an enhanced AECOM template. This information does not appear to have been used by TWBC in their assessments. Why? | ||||||||||||||||||||||||
DLP_3524 | High Weald AONB Unit | The decision making process is unclear and the decisions are muddled, inconsistent and incoherent. The lack of transparency makes scrutiny of the decisions problematic and it is difficult to ignore the conclusion that this is deliberate attempt to mask an inadequate evidence base, poor process and a desire to evade proper public scrutiny. SHELAA suggest that there were two stages to the decision process – an initial filtering (Stage 1) and a more detailed consideration (Stage 2). Topic paper para 6.7 states, that para 3.23 of the SHELAA provides a comprehensive list of the reasons why sites were filtered out. These reasons include significant landscape/topographical/heritage/coalescence concerns. All issues are not consistently noted on the site assessment sheets. Scores appear to have been used (e.g. Site 115 Hawkhurst Golf Course, ‘ A site with mixed scores’) but there is no indication of how issues are weighted. Sites where adverse impact on landscape, historic features, loss of greenfield/ soils, settlement coalescence is noted are generally considered unsuitable (e.g. Site 25, Frythe Way; Site 122, Charity Farm), but there are other sites, particularly larger sites, where such adverse impact is not considered to make the site unsuitable (e.g. Site 115, Hawkhurst Golf Course; Site 55, March Field ). We can only conclude that decisions are being made arbitrarily and that landscape considerations are not being properly applied. The Site Assessment Sheets provide minimal information. We are aware of more detailed site assessment sheets being used by neighbourhood planning groups, such as Cranbrook NPC, based on an enhanced AECOM template. This information does not appear to have been used by TWBC in their assessments. Why? It is also noted that the number of AONB components on a site is referenced in this column. This implies that TWBC are taking a simplistic approach of valuing the quality of the AONB according to the number of landscape components present on the site. To be clear the designation as an Area of Outstanding Natural Beauty confers the highest landscape status and value on all of the designated area equally. The landscape components identified in the Management Plan are those which are consistently found across the area, but there is no implication that all sites will display all five characteristics or that areas that don’t have all five are of lesser value. | ||||||||||||||||||||||||
DLP_3493 | Sally Marsh | The decision making process is unclear and the decisions are muddled, inconsistent and incoherent. The lack of transparency makes scrutiny of the decisions problematic and it is difficult to ignore the conclusion that this is deliberate attempt to mask an inadequate evidence base, poor process and a desire to evade proper public scrutiny. The Site Assessment Sheets provide minimal information. We are aware of more detailed site assessment sheets being used by neighbourhood planning groups, such as Cranbrook NPC, based on an enhanced AECOM template. This information does not appear to have been used by TWBC in their assessments. Why? | ||||||||||||||||||||||||
DLP_7401 | Andrew Ford | The decision making process is unclear and the decisions are muddled, inconsistent and incoherent. The lack of transparency makes scrutiny of the decisions problematic and it is difficult to ignore the conclusion that this is deliberate attempt to mask an inadequate evidence base, poor process and a desire to evade proper public scrutiny. SHELAA suggest that there were two stages to the decision process – an initial filtering (Stage 1) and a more detailed consideration (Stage 2). Topic paper para 6.7 states, that para 3.23 of the SHELAA provides a comprehensive list of the reasons why sites were filtered out. These reasons include significant landscape/topographical/heritage/coalescence concerns. All issues are not consistently noted on the site assessment sheets. Scores appear to have been used (e.g. Site 115 Hawkhurst Golf Course, ‘ A site with mixed scores’) but there is no indication of how issues are weighted. Sites where adverse impact on landscape, historic features, loss of greenfield/ soils, settlement coalescence is noted are generally considered unsuitable (e.g. Site 25, Frythe Way; Site 122, Charity Farm), but there are other sites, particularly larger sites, where such adverse impact is not considered to make the site unsuitable (e.g. Site 115, Hawkhurst Golf Course; Site 55, March Field). We can only conclude that decisions are being made arbitrarily and that landscape considerations are not being properly applied. The Site Assessment Sheets provide minimal information. We are aware of more detailed site assessment sheets being used by neighbourhood planning groups, such as Cranbrook NPC, based on an enhanced AECOM template. This information does not appear to have been used by TWBC in their assessments. Why? | ||||||||||||||||||||||||
DLP_7778 | Jacqueline Arscott, HHRA | TWBC: The following comment was submitted by the responders on the left: There are a number of errors and omissions re Site ref :445 (Local Plan Allocation AL/SO3) Gross Area: We assume that this includes the northern area of the site which is within the borough of Tonbridge and Malling. This should be made clear in the SHELAA as we are unsure of the implications of land outside Tunbridge Wells borough being included in an allocation in the local plan. Developable area: Is this simply the area that is within the Tunbridge Wells borough or does it take account of the constraints such as Ancient Woodland within the site? Site Type: We suggest that this should be re-phrased to “Greenfield, with a small number of pockets of PDL, one of which is in proximity to the LBD”. Moatenden (1.14 hectares) is clearly PDL but we are unsure whether the Mabledon Farm and the small number of converted farm buildings here should be classed as PDL. We have the same query in relation to Moat Farm. Moatenden is the only PDL that is in proximity to the LBD. Potential Yield if residential : We suggest that this should be the potential yield based upon the developable area not the proposed allocation i.e 5,000 dwellings (at 40 dwellings per hectare on a greenfield site) or 1,875 dwellings (at 15 dwellings per hectare for a mixed use site) Issues to consider: We are uncomfortable with the tick-box approach to AONB components as this does not give any indication of how important and extensive they are within the AONB landscape. Green Belt designation, Heritage Assets, Highway matters and Electricity Pylons should be added to the list. The need to discuss the portion of the site in Tonbridge should also be considered. Site description: The southern boundary does not follow a stream: this appears to have been copied from the site 180 Nightingale Farm and Land in the Interim SHEELA . Extension of the site in the 2017 Call for sites means that the southern boundary is Vauxhall Lane, with two parcels of land (Moatenden and Moat Farm) extending south of this. Reason: The site does not have good connections to the cycle network. | ||||||||||||||||||||||||
DLP_4788 | Alison Spender | Strategic Housing and Economic Land Availability (SHELAA) There are a number of errors and omissions re Site ref :445 (Local Plan Allocation AL/SO3) Gross Area: We assume that this includes the northern area of the site which is within the borough of Tonbridge and Malling. This should be made clear in the SHELAA as we are unsure of the implications of land outside Tunbridge Wells borough being included in an allocation in the local plan. Developable area: Is this simply the area that is within the Tunbridge Wells borough or does it take account of the constraints such as Ancient Woodland within the site? Site Type: We suggest that this should be re-phrased to “Greenfield, with a small number of pockets of PDL, one of which is in proximity to the LBD”. Moatenden (1.14 hectares) is clearly PDL but we are unsure whether the Mabledon Farm and the small number of converted farm buildings here should be classed as PDL. We have the same query in relation to Moat Farm. Moatenden is the only PDL that is in proximity to the LBD. Potential Yield if residential: We suggest that this should be the potential yield based upon the developable area not the proposed allocation i.e 5,000 dwellings (at 40 dwellings per hectare on a greenfield site) or 1,875 dwellings (at 15 dwellings per hectare for a mixed use site) Issues to consider: We are uncomfortable with the tick-box approach to AONB components as this does not give any indication of how important and extensive they are within the AONB landscape. Green Belt designation, Heritage Assets, Highway matters and Electricity Pylons should be added to the list. The need to discuss the portion of the site in Tonbridge should also be considered. Site description: The southern boundary does not follow a stream: this appears to have been copied from the site 180 Nightingale Farm and Land in the Interim SHEELA . Extension of the site in the 2017 Call for sites means that the southern boundary is Vauxhall Lane, with two parcels of land (Moatenden and Moat Farm) extending south of this. Reason: The site does not have good connections to the cycle network. | ||||||||||||||||||||||||
DLP_3091 | Tony Fullwood | Strategic Housing and Economic Land Availability Assessment for Draft Local Plan – Regulation 18 Consultation Site Assessment Sheets for Benenden Parish, July 2019 Site reference: 437 Land adjacent to Iden Green, Iden Green, Benenden Kent The text refers to some farm buildings within the Limits to Built Development; the rest of site is adjacent to the Limits to Built Development. As the Local Plan does not propose a Limit to Built Development for Iden Green, this appraisal needs amendment. In addition, given the scale of the site, much of it is not close to the hamlet of Iden Green. Access to the site is problematic particularly as this would be via the Iden Green crossroads and rural lanes. The site also provides habitat to protected species. | ||||||||||||||||||||||||
DLP_4296 | Changing Cities for 42 Leisure PLC | The Strategic Housing and Economic Land Availability Assessment concludes that the site at Montacute Gardens (ref: 7) is unsuitable for development but fails to recognise that it has already been allocated for development in the adopted Development Plan and has been assessed by an independently appointed Inspector who concluded it was suitable for mixed use development. The SHEALA provides no justification as to why the site should now be considered unsuitable for development and excluded from the Local Plan. The SHEALA fails to consider the site in the context of its contribution to the wider regeneration and enhancement of the area- a key reason for allocation of the site along with Union House for mixed use development. | ||||||||||||||||||||||||
DLP_4343 | Town and Country Planning Solutions for Gleeson Strategic Land | Appendix 6: Submitted sites not included in the Draft Local Plan 1. These representations on behalf of Gleeson Strategic Land (Gleeson) relate to the consultation draft of the Tunbridge Wells Local Plan published on 20th September 2019. Gleeson has an interest in land known as ‘Sandown Park’ located on the northern side of Pembury Road immediately adjoining the built up limits of Royal Tunbridge Wells (RTW) on the eastern edge of the town. 2. These representations (which compromise one of a number of other representations submitted to the Borough Council) relate specifically to the Council’s assessment of the land’s potential for housing purposes in the latest iteration of the Strategic Housing and Employment Land Availability Assessment (SHELAA) in the Council’s published ‘Site Assessment Sheets for Royal Tunbridge Wells’ dated July 2019. 3. In the Council’s previous ‘Site Allocations Development Plan Document: Site Templates Green Belt and Rural Fringes Supporting Information’ produced in February 2015, the land at Sandown Park was identified as site number 291 (see Appendix 1 attached). The land is noted as being ‘adjacent to the high Weald Area of Outstanding Natural Beauty’ (HWAONB), the boundary of which runs along the southern side of Pembury Road. 5. In response to this publication, Gleeson submitted representations explaining that since promoting the land for housing purposes at the Site Allocations Local Plan Examination in November 2015 (Representation no. SAL-S-732), extensive additional assessment work had been undertaken and various survey assessment reports and studies (in relation to ecology, landscape, archaeology, arboriculture and transport) in addition to an illustrative layout plan, were all submitted for the Council’s consideration in May 2017. Subsequent to this, further supporting documents were prepared and submitted to the Council as part of a ‘pre-application’ request by Gleeson on 2nd March 2018 (Appendix 3), to which the Council provided a response on 9th May 2018 (Appendix 4). While this consultation was through the Council’s ‘pre- application’ advice service, it was made clear at the time that Gleeson’s proposal related to submissions associated with the emerging Local Plan seeking the potential allocation of the land for housing proposes and for informal recreation. 7. Given this previous dialogue with the Council and the submission of detailed and comprehensive supporting documents, it is of considerable concern to Gleeson that none of this appears to have been taken into account in the Council’s more recent iteration of the SHELAA dated July 2019, in which site no. 99 now forms part of the ‘Site Assessment Sheets for Royal Tunbridge Wells’ (Appendix 13). 8. The Council’s most recent ‘Sustainability Appraisal’ for the site is seriously flawed and the ‘negative scores’ (which even in the Council’s ‘Sustainability Appraisal of the Draft Local Plan September 2019’ are not set out in any detail) are unjustified and as demonstrated by the supporting documents already submitted to the Council by Gleeson, any impact is capable of being mitigated. Furthermore, the Council’s flawed assessment now claims (incorrectly) that the site is “in the Area of Outstanding Natural Beauty”. 10. The Council’s Sustainability Appraisal (September 2019) includes a table of ‘scores’ for the site (number 99) in Appendix E on page 165 and states; “This site scores a number of neutral scores with some positive ones. Negative scores are given for air, climate change, heritage, land use, landscape and noise. The site is a greenfield site in the AONB, part of a Green Belt parcel of land that would cause high harm if released from the Green Belt. The location of the site along Pembury Road relative to distance to key services and facilities is likely to encourage car use. This has informed the air score and climate change score given. Noise score reflects location along the busy Pembury Road. The site forms part of the landscape setting of the main urban area of Tunbridge Wells and helps prevent coalescence between Tunbridge Wells and Pembury, the frontage is within the Conservation Area. This has influences the heritage and landscape scores given.” 11. Gleeson object to the Council’s SHELAA Assessment and sustainability scoring for the site on the basis set out below. 12. The Council’s Assessment states “The location of the site along the Pembury Road related to distance to key services and facilities is likely to encourage car use. This has informed the air score and the climate change score given”. 13. As demonstrated by the Transport Assessment submitted to the Council previously however and as previously recognised by the Council in its 2015 ‘Site Templates’ document, the site is in fact well located in relation to a number of local facilities including a number of schools within 200m – 2,800m distance, the Pembury Tesco store within 1,000m distance as well as Pembury Hospital within 1,500m distance. There are also convenient bus stops close by along both sides of Pembury Road which provide service connections to Tunbridge Wells town centre and the mainline rail station. In addition, the site is also well related to employment opportunities at North Farm Industrial Estate and Knights Park which the Council is proposing to build upon by releasing land within the Green Belt for employment purposes (Policy AL/RTW15). The Gleeson land is also located immediately adjacent to part of the designated National Cycle Network. 14. The site is therefore, in a sustainable location where there are opportunities for a range of means of transport that do not rely on car use. Indeed, as the largest town with the greatest range of facilities than any other settlement within the Borough, this edge-of-town location must reasonably be regarded as a far more sustainable location that other sites being promoted by the Council in the emerging Local Plan, which are bound to lead to much greater car use and longer car trips due to the lack of alternative means of transport and / or distance to facilities. This includes the Council’s proposal for a new ‘garden village’ at Tudeley at 17 ‘major’ development sites at locations within the High Weald Area of Outstanding Natural Beauty. ii) ‘Heritage, land use’ 15. The Archaeological and Heritage Assessment by EDP (May 2019) – Appendix 8, clearly demonstrates that the site could be developed in a form that would have no significant impact on any Heritage Assets (including the Tunbridge Wells Conservation Area boundary that runs along the Pembury Road frontage and the Grade II listed building located at Pembury Grange some 200m to the north of the site) and the site does not have any known significance in terms of archaeology. iii) ‘Landscape’ 16. The site has been the subject of a comprehensive Landscape Impact Assessment (Appendix 7), which again demonstrates that the site is capable of development in form that would have no harmful impact upon the character and appearance of the site or its wider landscaped setting. The majority of the trees along the road frontage would be retained (save for the few that need to be removed in order to provide a suitable means of vehicular and pedestrian access) and these can be reinforced with new planting. As such, the landscape setting along this part of Pembury Road in approaching Tunbridge Wells from the east, would not be harmed and could be enhanced so that there would be no harmful impact upon the part of the Tunbridge Wells Conservation Area that extends along the northern side of Pembury Road. iv) ‘Noise’ 17. Like any site abutting a road frontage, there is potential for some degree of exposure to road traffic and noise. The illustrative layout plan (Appendix 11) indicated however, that the proposed housing area would be set well back from the road frontage and with suitable mitigation measures adopted if required, there is no reason why road noise should in any way limit the site’s potential for housing purposes. v) ‘Green Belt’ 18. For the reasons put forward in the Green Belt Impact Assessment Report (Appendix 6) and in other separate current representations submitted in relation to the Draft Local Plan, the Council’s own Green Belt Study (June 2017) in relation to this land is severely flawed and unreasonable. The Council’s Green Belt Study looks at the effect of the removing of all of the land between the existing built up area of Tunbridge Wells and the Pembury by-pass from the Green Belt, which is expressed as ‘high’, whereas this is not the proposal being put forward by Gleeson. It remains unclear that given that Gleeson had raised concerns previously with the Council in the way that its Green Belt Study has been undertaken, why there has been no revision in selecting suitable sites for proposed release within the Green Belt at this location. 19. The Gleeson proposal is not to release the whole of the 6.5 hectare site for development as appears to have been assessed in the Council’s latest SHLAA iteration in July 2019 (Appendix 13). As clearly shown by the illustrative layout plan (Appendix 11) submitted to the Council previously, the Gleeson proposal is to only develop the western part of the site for 70 – 80 dwellings and retain the rest of the land within the Green Belt for use as informal recreation. Thus, the housing element released from the Green Belt would be closely related (and effectively round-off) existing built up limits to this part of RTW and the land to be retained within the Green Belt, as well as being made publically accessible for informal recreation, would help ensure retention of a significant green gap (with proposed structural planting and future management) so as to maintain and enhance its Green Belt function in preventing the coalescence between Tunbridge Wells and Pembury. vi) ‘Highway’ Impact 20. Following the submission of the previous supporting transport documents (Appendices 9 and 10), the Council is already aware that Gleeson has had an ongoing dialogue with the Highway Authority at Kent County Council. The Highway Authority’s latest response (Appendix 10) does not raise any fundamental concerns as to why a sustainable means of access for Pembury Road cannot be achieved as indicated on Access Drawing no. ITB12398-GA- 005 (Appendix 12), which has been modified in light of the Highway Authority’s latest response and also so as to minimise its visual impact on this part of the road frontage in light of comments contained in the Council’s ‘Pre-Application Advice’ response in May 2018 (Appendix 4). 21. The Council’s supporting document ‘Limits to Built Development’ (LBD) Topic Paper (August 2019) states (in paragraph 7.2) that “Reviewing the LBD’s will also ensure that development will be focused in those settlements which are most sustainable in terms of providing facilities and services…”. It also contains (at paragraph 7.6) a schedule of criteria that the Council claims to have used to determine land that should or should not be included within LBD’s. 22. The Gleeson proposal is to extend the RTW LBD to include approximately 3 hectares of land for housing purposes (for 70 – 80 dwellings) and release this land from the Green Belt. The proposal is also to retain the rest of the Gleeson land (some 3.3 hectares) immediately to the east of the housing allocation within the Green Belt and to undertake structural planting (with future management) so that this can be become publically accessible as informal open recreational space. 23. The various supporting documents produced by Gleeson and submitted to the Council previously (and resubmitted with these representations) demonstrate that this proposal would meet all the relevant criteria listed in the Topic Paper – selection criteria schedule, such as to warrant the allocation of the housing land and to accordingly extend the RTW LBD to include the land on Inset Map 2 of the emerging Local Plan. Instead, the Gleeson land has not been fairly or properly objectively assessed in the Council’s latest iteration of its SHLAA, nor has the proposed housing element be considered as a potential RTW LBD Amendment at Map reference 28.2 on page 60 of the LBD Topic Paper. 24. Gleeson also considers that their site has been unreasonably assessed and given low sustainability scores when considered against other potential housing sites at RTW and most notably SHELAA site 137, which is now proposed to be released from the Green Belt to provide approximately 270 dwellings as draft Policy AL/RTW 18. The SHELAA Sustainability Assessment notes that “The scores for this site are mixed” and include negative scores for air quality due to increased car use on the A26 and in terms of noise, the site is near to the main Gatwick flight path as well as road noise. There are also negative Green Belt loss and landscape impact scores and a negative heritage score due to compromising the setting of a Hill Fort (a scheduled Ancient Monument) and the complete loss of an assart field. 25. As can be determined by comparing the Sustainability Appraisal of this site in Appendix D (page 162) and the Gleeson land in Appendix E (page 165), the overall ‘scores’ for the two sites are similar and there is simply no sound justification for allocating one site and not the other. Conclusions 26. For the reasons set out in these representations on behalf of Gleeson, it is considered that the Council’s latest SHLAA assessment for Royal Tunbridge Wells site no. 99 is severely flawed and that this has resulted in unjustified and unreasonable negative ‘scores’ that has counted against the Council considering this site as a suitable edge of main settlement Green Belt release for housing purposes. This in turn, has resulted in site no. 99 being unreasonably included within Appendix 6 of the draft Plan as one of the ‘submitted sites not included in this draft Local Plan’ and as a consequence, not being shown as a housing and informal open space allocation on Inset Map 2, with the RTW ‘Limits to Built Development’ boundary amended to include the proposed housing area. 27. As such and compared to the proposed housing allocation the subject of draft Policy AL/RTW 18, the Council’s evidence in support of its proposed housing allocations is not positively prepared, justified or effective and therefore, conflicts with Government advice set out in paragraph 35 of the National Planning Policy Framework (NPPF) February 2019. Gleeson therefore invites the Council to now take the opportunity to review its SHLAA assessment (and Sustainability Appraisal) for Royal Tunbridge Wells site no. 99 in light of these Regulation 18 representations, to ensure that the site is fairly assessed as a suitable housing alternative to others being promoted by the Council at the Regulation 19 stage when the proposed submission draft version of the Local Plan is published. 28. It should be noted that these representations should also be read in conjunction with other representations submitted on behalf of Gleeson in relation to the Council’s proposed development strategy, Green Belt review and the proposed new policy relating to Local Open Space Designations. 1. Tunbridge Wells Borough Council Local Plan – Site Allocations Development Plan Document; Site Templates Green Belt and Rural Fringe Supporting Information – February 2015 2. Tunbridge Wells Borough Local Plan – Strategic Housing and Economic Land Availability Assessment; Draft Interim Report April 2017 3. Pre-Application Advice request (letter dated 2nd March 2018). 6. Green Belt Assessment by EDP dated May 2019. 7. Landscape and Visual Appraisal by EDP dated May 2019. See 7a and 7b 8. Archaeological and Heritage Assessment by EDP dated May 2019. 9. Technical Note by i Transport dated 14th December 2018. See 9a and 9b 10. Response from Kent County Council (Highway Authority) dated 5th February 2019. 11. Revised Masterplan Drawing no. 1232.02. 12. Revised Access Drawing no. ITB12398-GA-005. 13. SHELAA Site Assessment sheets for Royal Tunbridge Wells (Site 99) July 2019. | ||||||||||||||||||||||||
DLP_4794 | DHA Planning Ltd for Caenwood Estates and Dandara | 4 Comments on technical documents Comments on the SHELAA 4.1.1 The SHELAA is not a policy document, but is supposed to be a technical assessment of site suitability. For this reason, it is usual for such documents to adopt a ‘policy off’ position, which identifies sites as being potentially suitable for development even where those sites are not then proposed for development in the Local Plan. This normally results in a greater amount of land being found suitable for development than is actually required for the Local Plan, which then leads to judgements being made about the best planning strategy. 4.1.2 By contrast, TWBC’s SHELAA appears to only find sites suitable for development where they are then allocated, which is unusual in our experience. It begs the question whether the SHELAA findings are robust and reliable, or whether other policy objectives have influenced the findings. 4.1.3 This is clearly illustrated in the treatment of Caenwood Farm within the SHELAA. The north eastern part of this site was considered in the 2009 SHLAA as being a natural extension to the urban area, and was identified as being suitable for development (see Appendix). 4.1.4 However, in the July 2019 SHELAA, the Council considered the site as unsuitable for development. Whilst the Council recognises the site would make a significant positive contribution to housing, it is suggested that the substantial use of private vehicles in this location causes noise and air objectives to score very negatively, and that the site also has the potential to have a landscape impact. 4.1.5 The case for allocating the site for development has been set out in detail above, and in previous submissions and so we will not repeat information unnecessarily here. However, in summary, we consider this land to be a suitable area to release land and we consider there to be exceptional circumstances to release this site from the Green Belt and prioritise the development of this highly sustainable site. 4.1.6 The site has been promoted as a natural extension of Tunbridge Wells for several decades. The 2009 SHLAA recognised that a substantial part of the site was suitable for development. At this time, it was clear that landscape has been degraded and the northern part of the site would be suitable for development, given its proximity to existing residential and through topography and landscaping, would be well screened. 4.1.7 Parts of the site are contiguous with the established settlement boundary of Tunbridge Wells and it is within easy walking distance of a wide range of services and amenities including places of work, shops, recreational facilities, and an extensive range of community and education facilities including the main concentration of secondary school provision in the town. There would be opportunities to further improve education provision as a result of the development. [TWBC: see full representation, including Appendix: Extract from 2009 SHLAA ]. | ||||||||||||||||||||||||
DLP_6803 | Kember Loudon Williams for Wedgewood (New Homes) Ltd | In the table at page 206 (Appx. O) of the Sustainability Appraisal the commentary refers to an historic landscape. However, the site is not within a designated landscape and is very well contained by existing landscape features, topography, and adjacent built form. Furthermore the negative score on land use is questioned as the field is unused rough pasture which is dissected by a drainage ditch and is isolated from the wider agricultural landscape by adjacent orchard, hop garden and built form. In the SHELAA site assessment sheets for Horsmonden (July 2019) the reference to a historic landscape is repeated, however, the ADAS Landscape Report submitted with the KLW Supporting Report in response to the Reg. 18 Local Plan Consultation confirms that the site is of low visual value with low/medium sensitivity. The Ardent Technical Report submitted with the KLW Supporting Report shows that there are two suitable options for attaining vehicular access to the site. The comment about lack of access to services and facilities would apply equally to all sites in Horsmonden (although there is a range of local services available), and this site is well located in terms of distance to the core village services. Accordingly, the SHELAA assessment in our view does not withstand full analysis and particularly in light of the additional information now available. Accordingly, the conclusion that the site is unsuitable as an allocation is not, in our view, well founded and we would request that this is reviewed. [TWBC: see Supporting Statement and Comment Numbers DLP_6793, 6797-6799, 6801, 6803-6804.] [TWBC: this comment has also been entered as Comment Number SA_120 under the Sustainability Appraisal consultation]. | ||||||||||||||||||||||||
DLP_2783 | Mr Andrew McConnell | Site Number and Site Address: LA/LA2 Lamberhust It appears from the comments relating to a number of sites considered in Lamberhurst that they were rejected due to lack of access to public transport and nearby amenities. I fail to see why this is not equally applicable to the LA/LA2 site. 423 it appears that grounds for rejection of the Lamberhurst Winery were based on the proposed development being on a ridgeline. The proposed AL/LA2 site is if anything on a higher ridge line impacting views from both Furnace Lane, The Slade and Hoghole lane. The view from public footpath running along the Misty Meadow Farm access track and indeed the whole valley towards Hook Green will also be severely impacted. |
Transport General
Comment No. | Name/Organisation | Response |
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DLP_7402 | ASP Planning for Yalding Parish Council | INTRODUCTION 1. ASP have been instructed by Yalding Parish Council to review the Regulation 18 Tunbridge Wells Local Plan 2019 (hereafter referred to as the Local Plan) and its associated evidence base as to the potential effects of the plan on Yalding Parish. 5. The proposals for significant development in the Paddock Wood area are predicated on the fact that significant public transport improvements will ensure that additional transport impacts on the road network will be minimised. The analysis behind this conclusion does not sufficiently consider cross-border traffic movements and therefore fails to consider whether there will be traffic impacts beyond the areas where public transport improvements are proposed. CONCLUSION 20. In conclusion, our review of the Regulation 18 Local Plan and associated evidence base has raised concerns about whether the impacts of the proposed level of development in the northern part of the district is effective and sustainable due to some gaps in the evidence base. [TWBC: see also Comment No. DLP_7403 - Appendix 5 (Flooding)] TWBC note: there were no appendices attached to this representation |
DLP_4225 | Tunbridge Wells District Committee Campaign to Protect Rural England | Transport Study We are unclear as to what the transport study is that comment is invited upon in Appendix 5 as we cannot see a study of that name on the Local Plan website. Is it the Transport Evidence Base? |
Transport Evidence Base (SWECO)
Comment No. | Name/Organisation | Response |
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DLP_1903 | Royal Tunbridge Wells Town Forum | Topic Paper or supporting document title: SHELAA Site Assessment sheets for Royal Tunbridge Wells We previously submitted detailed comments on a number of the sites submitted under the Call for Sites which might become subject to an allocation. We set out those comments again under each specific AL/RTW Policy in relation to the sites now proposed for allocation in the Draft. So far as sites which were considered unlikely to be allocated and have now not been allocated for future development, we set out our comments in Appendix 6. Town Forum policy is that development in the AONB and Green Belt should take place only on proof of exceptional circumstances. Any evidence put forward of exceptional circumstances will have to satisfy the Inspector at Examination in accordance with relevant legal precedent. In the very difficult circumstances of the current unsatisfactory relationship between Central Government and Local Authorities and subject to the important caveat above, we are broadly supportive of most of the sites now selected for allocation in the unparished area of Royal Tunbridge Wells, subject in many cases to conditions. We also strongly support decisions taken on those submitted sites deemed unsuitable for allocation as set out in our comments in Appendix 6. Full comments on sites proposed for allocation appear in our response to the AL/RTW Policies ante. This is subject also to the caveat that we do not agree with the method by which Central Government calculates housing need and the consequent target housing numbers. In particular, the Office for National Statistics produced a revised 2016 methodology, which in the case of Tunbridge Wells Borough would require only 67% of the 2014 figure, according to some analysts. The government-imposed methodology and fears of the Draft Local Plan being found unsound at Public Examination have perhaps led TWBC not to seek fully to exploit potential constraints recognised by the NPPF in relation to the 70% of the Borough which is classified as AONB and the 22% which is classified as Metropolitan Green Belt and also infrastructure constraints such as acknowledged severe existing water stress and problems with waste water treatment. The approach taken in this Regulation 18 Draft has resulted in some draft allocations in RTW and elsewhere in the Borough which are intrusive into Green Belt and AONB. We would therefore urge TWBC to keep carefully under review the legislation and any legal precedents and Inspectors’ decisions arising under the legislation in the period up to submission of the Regulation 19 Draft in relation to exceptional circumstances and housing need methodology, in case some mitigation of proposed incursions into the AONB and Green Belt may be possible. Topic Paper or supporting document title: Infrastructure Delivery Plan Please see our comments on infrastructure delivery in relation to individual Policies above Topic Paper or supporting document title: Transport Strategy Review Please see our comments under the TP Policies above. Topic Paper or supporting document title: Transport Study Please see our comments under the TP Policies above. |
DLP_8187 | Highways England | Local Transport Evidence Base (SWECO Sept 2019) Whole LTEB Highways England notes the production of a Local Transport Evidence Base (SWECO Sept 2019). We welcome its aims to
Section 8 LTEB Transport Model The Council has separately provided Highways England with the Transport Model underpinning the Local Plan. We have therefore provided a separate technical note setting out our observations and requirements. In summary, while the model provides a good starting point, it requires further work before it can be formally signed off by Highways England. Particular matters include:
We will work with the Council, Kent County Highways and SWECO on these tasks. It should be noted that
The Council are advised not to proceed significantly further with their plan making and transport evidence ahead of resolving the outstanding LTEB and modelling matters. TWBC: see Technical Note. See also full representation] |
DLP_7345 | Campaign to Protect Hawkhurst Village | Transport Strategy Review Paragraph 29 acknowledges the pre-existing congestion in Hawkhurst – at paragraph 45 this is acknowledged to be “severe”. There is no acknowledgement here of the existing issues at the A21 at Flimwell, which whilst outside the borough is of crucial importance to residents in the east of the Borough. We note that in this document there is no analysis or assessment whatsoever of whether the proposed Hawkhurst Relief Road will provide any relief. The need to address the existing severe situation in Hawkhurst and at Flimwell should form a key component of the Council’s revised Transport Strategy. This will involve the Council properly assessing the existing issues, the actual effectiveness of proposed mitigation measures (including the relief road) and considering the residual impact of the Growth Strategy. At present this exercise simply has not been done. We make these observations in the context of our comments of the SWECO Transport Assessment Report. TWBC LOCAL PLAN TRANSPORT EVIDENCE BASE [SWECO] We make the following observations regarding this report:
The SWECO report is inadequate and fundamentally flawed as it does not address traffic congestion issues in a large part of the Borough. Its overall conclusion is therefore meaningless. It is in no way a proportionate evidence base on which the DLP as a whole can be taken forward. The strategic policies within the DLP suggest the Council considers the relief road will provide “significant improvements”. There is absolutely no evidence within this report to substantiate this conclusion. The Council’s reliance on this report to underpin the proposed allocations in Hawkhurst and the east of the Borough is demonstrably “unsound”. Given the acknowledged existing severe congestion issues, the Council needs to properly and fully assess the cumulative impact of the proposed allocations in Hawkhurst, the east of the Borough and neighbouring authorities, on the village crossroads and the Flimwell junction. It then needs to properly assess whether any mitigation measures can satisfactorily address this impact (including the relief road). Based on the information submitted with the Golf Course Transport Assessment it is clear that the provision of the relief road and Flimwell junction mitigation scheme will not result in any material improvement and in many respects will make the current “severe” position worse. We would highlight that the Golf Course TA does not include in its assessment the other allocations within Hawkhurst in the DLP. When the traffic associated with these other schemes is taken into account the impact will be demonstrably worse again. On this basis the Council’s whole Growth strategy for Hawkhurst and the east of the Borough should be completely reconsidered. |
DLP_3735 | Capel Parish Council | Chapter 2: Policy Context – Regional Policy covers the Kent County Council Local Transport Plan 4 (LTP4). Paragraph 2.3.7 (p.9) identifies that there are severe congestion problems in Tunbridge Wells “on the A264 between Pembury and the town centre”. Paragraph 2.3.9 (p.9) outlines the Local transport priorities specific to the borough of Tunbridge Wells, including “A264 Pembury Road capacity improvements”. Chapter 3: Socio-Demographics and Travel Behaviour – Current travel behavior at paragraph 3.4.3 (p.33) highlights that the ward of Capel has a significantly higher number of households with access to two or more cars at 58% (compared with 38% for Kent, 40% for the South East and just 32% for England on average) Chapter 6: Highway Network, Congestion and Collision Analysis – Congestion at paragraph 6.3.6 (p.105) sets out the aims of the improvements works along the A264 as being:
Chapter 5. Existing Public Transport Infrastructure and Level of Service divides the borough into four sectors for review. Capel and Paddock Wood fall under the ‘North’ section from paragraph 5.4 and paragraphs 5.4.4-5.4.7 detail the existing low frequency service. ALL cease at 7pm none start before 7am. There is no Sunday service. Chapter 9: Mitigation Measures – Mode Shift Spread Paragraph 9.1.1. (p.134) states “The modal shift analysis, using the Propensity to Cycle Tool (PCT) identifies a potential modal shift of 2%-11% from car if a high-quality cycle network is established for the study area. For some locations we have identified bus based schemes that we foresee can replicate the impacts of cycling interventions to attain the proposed modal shift” Paragraph 9.1.2 (p.134) states “The final mitigation scenario identifies an 11% reduction in car trips in the key Local Plan development allocation areas of Paddock Wood and Tudeley” Paragraph 9.6.5 (p.137) outlines that for rural locations, “we have looked to integrate greater access by using new technology such as Demand Responsive Bus (DRB)” Even with an 11% mitigation the number of cars in Capel would still be well above the Kent or SE average at over 50% Table 9.2 (p.138) shows mitigation for intervention type and includes the following measures:
Paragraph 9.7.9 (p.145) concerns Halls Hole Road / A264 Junction and Potential Bus Lane and states “Our analysis shows that this junction is at capacity and will remain overcapacity into the future. Options to increase capacity at the junction through additional approach and filter lanes are likely to be very costly as there are both significant land ownership issues (the highway boundary is close to the carriageway) and topography issues (in particular on Halls Hole Road where there is an immediate drop). The most affordable solution to improve traffic flow in the short term would be to recalibrate the traffic signals to better take account of the increased flows and to achieve a shift from car to cycling and bus” The A264 junction is over capacity in all scenarios even with mitigation. Chapter 10. Summary and Conclusions Paragraph 10.2.2 (p.165) states “The traffic modelling has tested the hard engineering measures and the effects of the walking, cycling and bus improvements, and has shown that the measures proposed will mitigate the impacts of the Local Plan housing and employment allocations” The conclusion is totally flawed, walking, cycling, buses & fiddling with traffic signals WILL NOT offset the sheer volume of traffic Capel will have to endure. With a level of 50% car ownership, even after successful mitigation, that is some 8,000 extra cars using the B2017 or country lanes. It is suggested building the Colts Hill strategic link is vital to delivery of the proposed new developments in Capel. How will this improve connectivity? It will be a faster, polluting road to nowhere. Until TWBC tackle the congestion on the two roundabouts at Pembury and the A264 it will be avoided, traffic to the A21 will still use the B2017. Given the development of Hendys in Pembury the congestion at this hotspot will be exacerbated. This development does not appear to have been addressed by SWECO. The A228 strategic link has been mooted for the last forty years. The whole area surrounding Paddock Wood needs a radical holistic solution. The dualling of the A21 was supposedly going to reduce traffic in this area but as TMBC have discovered, through traffic has actually increased in volume in Tonbridge since the “improvement” Apart from KentFastrack buses all the case studies BY SWECO regarding their analysis to lower car use, have used towns & cities. The case for using buses to bypass congestion hotspots is not made. The A264 has no capacity for a separate bus lane, fast track or otherwise. The much mooted northern route from Paddock Wood to AL/CA 1 is not within the document. How is access from the north of AL/CA 1 to be handled? The Five Oak Green bypass link to the Colts Hill bypass is unlikely to be used by anyone travelling out of the north of Paddock Wood to Tonbridge (the B2017 is approached first) or travelling along the existing B2017 from Paddock, they will continue straight across the roundabout. The grey blob of a new route, shown in most of the publically available maps, connecting the north of AL/CA 1 to Paddock Wood, appears to be missing in this assessment. What is traffic plan for egress from the north side of AL/CA 1 given it would either have to cross the railway line or use Hartlake Road without a new northern link? Huge volumes of traffic, without this much mentioned “triangle,” will leave & enter Paddock Wood onto the A228 causing unacceptable levels of pollution and congestion. Capel Parish Council suggested a new northern link from Paddock Wood to Tonbridge, to exclude any settlements in Capel, but this has not been assessed. The only sensible proposal within this document is for a southern bypass or ringroad for Tunbridge Wells, a southern bypass won’t help address the huge problems in the North East of the borough, but it would be the most sensible way forward especially if development were to follow, it would also reflect the preferred Growth Strategy that 60% preferred, namely Option 4, growth corridor led. |
DLP_4353 | Tunbridge Wells Bicycle User's Group | Topic Paper or supporting document title: SWECO document The SWECO document repeats previous findings that cycling for the region is very low, at only 1% mode share of trips to work. It states that implementing the cycle strategy for the region is likely to improve the number of cycle trips and goes on to remark that ‘Further consideration will also be needed on how to develop a comprehensive cycle network that covers existing and new developments. This would have the potential to reduce existing congestion and air quality issues on key corridors in the area’. This message needs to inform the transport section of the local plan. East and central and North Tunbridge Wells In para 5.2.31.the SWECO document states that ‘Currently, cycling would not be seen as a viable option for most existing and future development trips due both to distances and lack of quality infrastructure and connected network’ In the same paragraph the report states that ‘inter-settlement walk and cycle trips are limited by the lack of continuous dedicated links and paths for both [walking and cycling] modes The draft local plan transport section does not currently include details of how this deficiency will be made good and needs to be re-written to do so. |
DLP_1633 | Maggie Fenton | SWECO TRANSPORT DOCUMENT KCC LOCAL TRANSPORT PLAN 4 (LTP4) 2.3.7 Identifies severe congestion problems in T.Wells. A264 between Pembury and town centre 2.3.9 Specific priority in TWBC Identifies A264 Pembury Rd Capacity improvements needed. SWECO identify A264 issues
Current travel behaviour 3.4.3 Capel (58%) & Pembury (51%) have a significantly higher no. of households with 2 or more cars (38% Kent, 40% SE, 32% England) Bus services are very low frequency. ALL cease at 7pm none start before 7am. Suggested Mitigation Measures 9.1.2 The final mitigation scenario identifies an 11% reduction in car trips in the key local plan development areas of Paddock Wood & Tudeley. This is based on the modal shift analysis using the PCT – high quality cycle network. 9.6.5 For rural locations look to integrate demand responsive buses Even with an 11% mitigation the number of cars in Capel would still be well above the Kent or SE average at over 50% Table 9.2 Shows mitigation for intervention type
9.7.9 Halls hole A264 Our analysis shows that this junction is at capacity & will remain over capacity in the future constrained by land ownership, topography and conservation issues. Due to costs etc the most affordable solution to improve flow in the short term would be to recalibrate traffic signals and achieve a shift from car to cycling or bus. The A264 junction is over capacity in all scenarios even with mitigation. CONCLUSION 10.2.2 The traffic modelling has tested the hard engineering measures & the effects of walking, cycling and bus improvements & has shown that the measures will mitigate the impact of the Local Plan housing & employment allocations. The conclusion is totally flawed, walking, cycling, buses & fiddling with traffic signals WILL NOT offset the sheer volume of traffic Capel will have to endure. With a level of 50% car ownership, even after successful mitigation, that is some 8,000 extra cars using the B2017 or country lanes. It is suggested building the Colts Hill strategic link is vital to delivery of the proposed new developments in Capel. How will this improve connectivity? It will be a faster, polluting road to nowhere. Until TWBC tackle the congestion on the two roundabouts at Pembury & the A264 it will be avoided, traffic to the A21 will still use the B2017. Given the development of Hendys in Pembury (180 staff alone) the congestion at this Pembury hotspot will be exacerbated. This major development in Pembury does not appear to have been addressed by SWECO. Why? The A228 strategic link has been mooted for the last forty years. Even if successful, it is unlikely to be built until 2025/28. The whole area surrounding Paddock Wood needs a radical holistic solution. The dualling of the A21 was supposedly going to reduce traffic in this area but as TMBC have discovered, through traffic has actually increased in volume in Tonbridge since the “improvement” Apart from KentFastrack buses all the case studies BY SWECO regarding their analysis to lower car use, have used towns & cities. The case for using buses to bypass congestion hotspots is not made. The A264 has no capacity for a separate bus lane, fast track or otherwise. The much-mooted northern route from PW to CA1 is not within the document. How is access from the north of CA1 to be handled? The Five Oak Green bypass link to the Colts Hill bypass is unlikely to be used by anyone travelling out of the north of Paddock Wood to Tonbridge ( the B2017 is approached first) or travelling along the existing B2017 from Paddock, they will continue straight across the roundabout. The grey blob of a new route, shown in most of the publically available maps, connecting the north of CA1 to Paddock Wood, appears to be missing in this assessment. What is the traffic plan for egress from the north side of CA1 given it would either have to cross the railway line or use Hartlake Road without a new northern link? Huge volumes of traffic, without this much mentioned “triangle,” will leave & enter Paddock Wood onto the A228 causing unacceptable levels of pollution and congestion. The B2017, much of it residential will be transformed into a fast dangerous route. Alders Road & Whetsted Road in Capel already suffer hugely as rat-runs. Capel Parish Council suggested this new northern link from Paddock Wood to Tonbridge, if this proposal were approved, to exclude any settlements in Capel, but this has not been assessed and has in fact been completely ignored. The only sensible proposal within this document is for a southern bypass or ringroad for Tunbridge Wells, a southern bypass wont help address the huge problems in the NE of the borough, but it would be the most sensible way forward especially if development were to follow, it would also reflect the preferred Growth Strategy (60%), namely Option 4, growth corridor led. |
DLP_8153 | Ashley Saunders | Chapter 2: Policy Context – Regional Policy covers the Kent County Council Local Transport Plan 4 (LTP4). Paragraph 2.3.7 (p.9) identifies that there are severe congestion problems in Tunbridge Wells “on the A264 between Pembury and the town centre”. Paragraph 2.3.9 (p.9) outlines the Local transport priorities specific to the borough of Tunbridge Wells, including “A264 Pembury Road capacity improvements”. Chapter 3: Socio-Demographics and Travel Behaviour – Current travel behavior at paragraph 3.4.3 (p.33) highlights that the ward of Capel has a significantly higher number of households with access to two or more cars at 58% (compared with 38% for Kent, 40% for the South East and just 32% for England on average) Chapter 6: Highway Network, Congestion and Collision Analysis – Congestion at paragraph 6.3.6 (p.105) sets out the aims of the improvements works along the A264 as being:
Chapter 5. Existing Public Transport Infrastructure and Level of Service divides the borough into four sectors for review. Capel and Paddock Wood fall under the ‘North’ section from paragraph 5.4 and paragraphs 5.4.4-5.4.7 detail the existing low frequency service. ALL cease at 7pm none start before 7am. There is no Sunday service. Chapter 9: Mitigation Measures – Mode Shift Spread Paragraph 9.1.1. (p.134) states “The modal shift analysis, using the Propensity to Cycle Tool (PCT) identifies a potential modal shift of 2%-11% from car if a high-quality cycle network is established for the study area. For some locations we have identified bus based schemes that we foresee can replicate the impacts of cycling interventions to attain the proposed modal shift” Paragraph 9.1.2 (p.134) states “The final mitigation scenario identifies an 11% reduction in car trips in the key Local Plan development allocation areas of Paddock Wood and Tudeley” Paragraph 9.6.5 (p.137) outlines that for rural locations, “we have looked to integrate greater access by using new technology such as Demand Responsive Bus (DRB)” Even with an 11% mitigation the number of cars in Capel would still be well above the Kent or SE average at over 50% Table 9.2 (p.138) shows mitigation for intervention type and includes the following measures:
Paragraph 9.7.9 (p.145) concerns Halls Hole Road / A264 Junction and Potential Bus Lane and states “Our analysis shows that this junction is at capacity and will remain overcapacity into the future. Options to increase capacity at the junction through additional approach and filter lanes are likely to be very costly as there are both significant land ownership issues (the highway boundary is close to the carriageway) and topography issues (in particular on Halls Hole Road where there is an immediate drop). The most affordable solution to improve traffic flow in the short term would be to recalibrate the traffic signals to better take account of the increased flows and to achieve a shift from car to cycling and bus” The A264 junction is over capacity in all scenarios even with mitigation. Chapter 10. Summary and Conclusions Paragraph 10.2.2 (p.165) states “The traffic modelling has tested the hard engineering measures and the effects of the walking, cycling and bus improvements, and has shown that the measures proposed will mitigate the impacts of the Local Plan housing and employment allocations” The conclusion is totally flawed, walking, cycling, buses & fiddling with traffic signals WILL NOT offset the sheer volume of traffic Capel will have to endure. With a level of 50% car ownership, even after successful mitigation, that is some 8,000 extra cars using the B2017 or country lanes. It is suggested building the Colts Hill strategic link is vital to delivery of the proposed new developments in Capel. How will this improve connectivity? It will be a faster, polluting road to nowhere. Until TWBC tackle the congestion on the two roundabouts at Pembury and the A264 it will be avoided, traffic to the A21 will still use the B2017. Given the development of Hendys in Pembury the congestion at this hotspot will be exacerbated. This development does not appear to have been addressed by SWECO. The A228 strategic link has been mooted for the last forty years. The whole area surrounding Paddock Wood needs a radical holistic solution. The dualling of the A21 was supposedly going to reduce traffic in this area but as TMBC have discovered, through traffic has actually increased in volume in Tonbridge since the “improvement” Apart from KentFastrack buses all the case studies BY SWECO regarding their analysis to lower car use, have used towns & cities. The case for using buses to bypass congestion hotspots is not made. The A264 has no capacity for a separate bus lane, fast track or otherwise. The much mooted northern route from Paddock Wood to AL/CA 1 is not within the document. How is access from the north of AL/CA 1 to be handled? The Five Oak Green bypass link to the Colts Hill bypass is unlikely to be used by anyone travelling out of the north of Paddock Wood to Tonbridge (the B2017 is approached first) or travelling along the existing B2017 from Paddock, they will continue straight across the roundabout. The grey blob of a new route, shown in most of the publically available maps, connecting the north of AL/CA 1 to Paddock Wood, appears to be missing in this assessment. What is traffic plan for egress from the north side of AL/CA 1 given it would either have to cross the railway line or use Hartlake Road without a new northern link? Huge volumes of traffic, without this much mentioned “triangle,” will leave & enter Paddock Wood onto the A228 causing unacceptable levels of pollution and congestion. Capel Parish Council suggested a new northern link from Paddock Wood to Tonbridge, to exclude any settlements in Capel, but this has not been assessed. The only sensible proposal within this document is for a southern bypass or ringroad for Tunbridge Wells, a southern bypass won’t help address the huge problems in the North East of the borough, but it would be the most sensible way forward especially if development were to follow, it would also reflect the preferred Growth Strategy that 60% preferred, namely Option 4, growth corridor led. |
DLP_5314 | Judith Ashton Associates for Redrow Homes Ltd and Persimmon Homes South East | Local Plan Transport Assessment The Local Plan Transport Assessment (LPTA) reiterates a number of points raised in the IDP, including the provision of the Hop Pickers heritage route, the first phase of which could be delivered through my clients land; and improved bus services, which as noted above, could be provided via Church Road as well as surrounding key settlements, the specification of which will be directly related to the scale of development proposed and the anticipated level of bus patronage, recognising the aspiration that the development enables residents to travel door to door by public transport and active travel for the majority of trips. Likewise, the LPTA looks to “drive significant model shift away from car to more sustainable modes…” and seeks “sustainable transport infrastructure integrated into (new) settlement and have clear sustainable transport links to other key settlements” an approach we fully support. It also refers to TWBC’s emerging Local Cycle & Walking Infrastructure Plan (LCWIP) including (as Route 3) a Paddock Wood circular route which my clients could also help to deliver. [TWBC: see full representation]. |
Transport Strategy 2015-2026
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_211 | Julian Wilson | Transport Strategy 2015 - 2026 Section 4.28 – The statement on the problems on the A229 is very vague and wrong in respect of “The A229 is constrained at the junction with the A268 in Hawkhurst and this cross-roads suffers from congestion at peak times and during holidays.” It is more accurate to state that the crossroads at Hawkhurst suffers from congestion on all days Monday – Friday predominantly from HGV’s travelling North-South and South-North. It is a very dangerous and inconvenient junction for resident pedestrians Holiday congestion is mostly on Saturdays and Sundays during the sum The Local Plan is badly deficient in not stating a response to the A229 problems which are chronic and worsening. The options for improving traffic flow around Hawkhurst need to be included in the Local Plan eg. The proposed ‘relief road’ around north west side of Hawkhurst and much-needed widening of the A268 junction with A21 in Flimwell, to divert a large number of HGV’s away from the Hawkhurst crossroads. [TWBC: See also Comment Number DLP_210] |
DLP_5229 | Culverden Residents Association | Transport Strategy Review Our members frequently raise issues with us concerning traffic problems in the area and are very concerned to see a transport policy adopted which will restore the atmosphere of our area as a quiet and leafy neighbourhood of residential streets. We make a number of constructive suggestions below about Rat-running and road safety Commuter rat-running, compounded by the presence of so many schools in our area, has unfortunately now reached unacceptable proportions in the Culverden area. Its various effects (regular traffic jams, severely polluting diesel vehicles, turning conflicts, unwarranted hooting, regular road rage incidents, We were therefore extremely heartened to read in the 2019 Transport Strategy Review that TWBC will be seeking to achieve a modal shift to active travel, which, combined with some other local measures we propose below, could significantly improve the situation in our area. We strongly endorse paragraph 50 Measures that need to be taken in our area to encourage active travel and end rat-running include the following: 1. Filtered permeability The worst problem in Culverden is caused by rat-running between the A264 at Mt Ephraim and St John’s Road or Southborough and beyond on the A26. A secondary rat-running flow is more localised by people zig-zagging (sometimes several times) across the A26 at various points to gain a few seconds of overall When Reynolds Lane was closed for road works recently for around 9 days during term time, it was strikingly noticeable that nearly two thirds of the car traffic on Culverden Down had disappeared by the third morning. This is tell tale evidence of what could be achieved by a well thought out scheme of
These 3 simple and cheap closures would eliminate virtually all traffic having no business in the area while still allowing reasonable access, particularly to all the local schools. 2. 20mph Zone Introduction of a 20mph zone in the area bounded by Molyneux Park Road and Beltring Road/ Southfield Road would reduce the speed of any remaining traffic and encourage active travel by the local residents and the increasing number of school children. A resolution calling for such a scheme was passed “The Culverden Residents Association believes that introduction of a 20mph zone in our area would reduce the number of accidents and severity of injuries to pedestrians and create conditions in which more local people walk or cycle instead of driving. Reduced speeds would also reduce the attractiveness of our streets to rat-runners. We therefore call on our Borough and County Councillors to work with local people to secure introduction of a 20mph Zone throughout Culverden bounded by the entrances to Molyneux Park Road, Boyne Park, Royal Chase, Culverden Park, Culverden Down, Beltring Road and Southfield Road.” 3. Creation of Safe Routes to Schools To give just one example, car journeys from Rusthall to our neighbouring schools involve driving significantly over 2 miles along the most congested part of our main road system and can take longer in the rush hour than walking, let alone cycling. Creation of a Safe Route for walking and cycling to The route would run to and from Rusthall Primary School in the west to St Gregory’s secondary and primary schools and Southborough primary school in the north via branches across the Spa golf course and Stills Green at Rusthall, then Coniston Avenue, Rose Hill School, Culverden Down, Bennett 4. More local primary schools In the context of the climate emergency, there is a pressing need to establish smaller local primary schools in the town within walking distance for local parents and to eliminate the schooling of siblings at different Primaries which adds to the “school run”. This requires the earmarking of suitable Local Parking We refer to Paragraph 106 of the Transport Strategy Review. Local parking is a very difficult issue for us. Our residents face increasing difficulties in parking, as commuters take advantage of free parking on our streets. However, the large number of properties without off street parking in Without the measures to curb rat-running and excessive speeds on our streets we mention above, the present on-street parking in Culverden at least tends to slow traffic down. We think that our local parking problems will only be resolved if and when the level of car ownership in the area decreases. Rail Many of our residents commute by rail to London or take leisure trips by rail in all available directions. We were disappointed to note that none of the paragraphs 59-65 of the Transport Strategy Review make any mention of the longer term possibilities of reconnecting Tunbridge Wells with Crowborough, Uckfield, Lewes and Brighton in one direction and Croydon and London in the other through the re-opening of main line rail |
DLP_4351 | Tunbridge Wells Bicycle User's Group | Topic Paper or supporting document title: Tunbridge Wells Borough Development Plan: TRANSPORT STRATEGY 2015 – 2026 published July 2015 Para 2.24 of the local plan (Challenges and Opportunities) refers to a forthcoming “refreshed” Borough Transport Strategy 2015 - 2026 (TS) following updated transport assessment and modelling work, which are included in the Supporting Docs. This may be a reference to The Transport Strategy 2015 – 26 was prepared on basis of building 6,000 new homes. This number has now been doubled. This increase might weaken the relevance of the “unrefreshed” Strategy, although we appreciate the likelihood of significant carry-forward especially where not directly |
Transport Strategy Review
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_1903 | Royal Tunbridge Wells Town Forum | Topic Paper or supporting document title: SHELAA Site Assessment sheets for Royal Tunbridge Wells We previously submitted detailed comments on a number of the sites submitted under the Call for Sites which might become subject to an allocation. We set out those comments again under each specific AL/RTW Policy in relation to the sites now proposed for allocation in the Draft. So far as sites which were considered unlikely to be allocated and have now not been allocated for future development, we set out our comments in Appendix 6. Town Forum policy is that development in the AONB and Green Belt should take place only on proof of exceptional circumstances. Any evidence put forward of exceptional circumstances will have to satisfy the Inspector at Examination in accordance with relevant legal precedent. In the very difficult circumstances of the current unsatisfactory relationship between Central Government and Local Authorities and subject to the important caveat above, we are broadly supportive of most of the sites now selected for allocation in the unparished area of Royal Tunbridge Wells, subject in many cases to conditions. We also strongly support decisions taken on those submitted sites deemed unsuitable for allocation as set out in our comments in Appendix 6. Full comments on sites proposed for allocation appear in our response to the AL/RTW Policies ante. This is subject also to the caveat that we do not agree with the method by which Central Government calculates housing need and the consequent target housing numbers. In particular, the Office for National Statistics produced a revised 2016 methodology, which in the case of Tunbridge Wells Borough would require only 67% of the 2014 figure, according to some analysts. The government-imposed methodology and fears of the Draft Local Plan being found unsound at Public Examination have perhaps led TWBC not to seek fully to exploit potential constraints recognised by the NPPF in relation to the 70% of the Borough which is classified as AONB and the 22% which is classified as Metropolitan Green Belt and also infrastructure constraints such as acknowledged severe existing water stress and problems with waste water treatment. The approach taken in this Regulation 18 Draft has resulted in some draft allocations in RTW and elsewhere in the Borough which are intrusive into Green Belt and AONB. We would therefore urge TWBC to keep carefully under review the legislation and any legal precedents and Inspectors’ decisions arising under the legislation in the period up to submission of the Regulation 19 Draft in relation to exceptional circumstances and housing need methodology, in case some mitigation of proposed incursions into the AONB and Green Belt may be possible. Topic Paper or supporting document title: Infrastructure Delivery Plan Please see our comments on infrastructure delivery in relation to individual Policies above Topic Paper or supporting document title: Transport Strategy Review Please see our comments under the TP Policies above. Topic Paper or supporting document title: Transport Study Please see our comments under the TP Policies above. |
DLP_7968 | Wendy Owen | Transport Strategy Review: Context and Way Forward See comments above:
“Policy Implementation: Ensure provision of new infrastructure through working with developers, submit bids for funding (e.g. Local Growth Fund) for infrastructure improvements to deliver growth, take balanced approach to parking standards in new development and parking provision in town centres, public realm improvements in town and village centres, work with businesses to reduce travel footprint grants to businesses to support active travel.” Nobody is likely to disagree with these policy implementation statements, but they don’t really offer tangible solutions. The detail provided for each proposed development site should include specifics. Policy AL/RTW 18 / site 137 simply says “Development shall accord with the following requirements: Transport assessments and travel plans, as well as enabling a means of active travel to serve the new secondary school”. TWBC has published thousands of pages of plans, reports and appendices, but we don’t know what is proposed in terms of access roads for this site. The Policy then says “It is expected that contributions will be required towards the following if necessary to mitigate the impact of the development: The provision of sustainable and active transport mitigation measures, highway works within the vicinity of the site, including the provision of pedestrian crossings…”. This essentially says the developer might have to do NOTHING. The footpath adjacent to the A26 Eridge Road is a very unpleasant place to walk, until the location of the speed camera is reached. HGVs thunder past, so it is not a footpath for the faint hearted. The ‘best’ time to walk is when traffic is queuing to get into TW (although of course you then have to contend with poor air quality/increased emissions created by stop-start traffic). There have almost certainly been more accidents on Eridge Road than reported. On 16 October 2019 a car left the road, crossed the footpath, and ended up in the woods at the side of the road. It was dark and raining so the driver was most likely going too fast. The incident was reported to Kent police (ref 160169) but they did not want to attend the scene. The car knocked over the 30mph speed limit sign and gas main pipeline marker. KCC’s solution has been to remove the 30mph sign (ref 457498). |
DLP_8214 | Mrs Suzi Rich | Topic Paper or supporting document title: Comments on the Distribution of Development Topic Paper Chapter 3: Development Constraints (p.4) Chapter 5: Issues and Options consultation (p.11) Paragraph 5.6 summarises the main outcomes of the consultation for the question relating to the five strategic options for delivery presented in the Issues and Options document. Only 18% ranked Option 5 (new freestanding settlement) as their most preferred approach. It is submitted that this would have been even less if the site/sites now proposed at AL/CA 1 and AL/CA 3 & AL/PW 1 had been identified at that time. Appendix 1 to The Issues and Options Consultation Statement, available on the Tunbridge Wells Borough Council website at https://beta.tunbridgewells.gov.uk/local-plan/issues-and-options, lists the Strategy Considerations at Section 5 (p.26-39). It is clear from p.33, that by far the largest level of support was 60% for Option 4 (Growth Corridor led approach). However, p.39 of the same document states that “A level of support was indicated in the Issues and Options responses for a new settlement.” This is misleading. The Consultation Statement goes on to consider the responses to question 10 and 10a relating to preferences for a combination of Options (p.35). The first bullet point states that the responses indicate that it is worth “Exploring further the potential for ‘new settlement growth’, as this was the most commonly preferred (alone or in combination) of all the options”. The statement is blatantly not true! Paragraphs 5.7-5.8 cover question 11/11a, which asked for views about the possibility of a new settlement somewhere in the borough and suggestions for possible locations. It lists the key issues referred to across the response groups, which include:
These views have been completely ignored by TWBC! They should carry weight and should have informed the decision on the strategic site proposals. Paragraphs 5.9-5.10 cover question 12/12a, which asked whether all reasonable options for accommodating future development growth within the borough have been considered and identified and if not, what other options should be considered. Respondents suggested that the following options should be considered:
Where have these responses been acknowledged in the dLP? Have these options been considered at all? Chapter 6: Formulating the development strategy (p.14) Paragraph 6.2 states “For the second Call for Sites, officers contacted the promotors of sites submitted to the first Call for Sites and identified and then contacted owners of land around settlements (on a ‘without prejudice’ basis) that had not been submitted through the first Call for Sites to enable them to submit sites if they wished. This proactive approach encouraged owners of land that could be suitable for development to submit sites for consideration”. Why were we told by Stephen Baughan at the Capel Annual Parish Meeting that TWBC had no influence on what sites were submitted and that the officers just had to work with what appeared in the Call for Sites! Paragraph 6.2 also expressly states that the second 'Call for Sites' was undertaken between May and June 2017. In the Interim New Local Plan Strategic Housing & Economic Land Availability Assessment 2017. It was stated “although the call for sites remains open, it will no longer be possible to include any new sites within the site assessment process that is informing the Draft Local Plan (being prepared under Regulation 18) AS THERE IS INSUFFICIENT TIME TO ADEQUATELY ASSESS SUCH SITES. (TWBC will continue to accept in order that they may be assessed & potentially included at Reg 19)”. The evidence base persuaded TWBC to opt for Growth Strategy Option 3 (existing urban distribution plus villages) and Option 4 (A21 growth corridor). There was a possibility of Option 5 (new settlement) in the longer term (8 possible sites but 5 not shortlisted including AL/ CA 1). Presumably this underwent a robust process based on robust evidence? This was still the preferred stance March 2018, however in April 2018, there appeared to be a complete change of direction which resulted in the allocation of 60% of the proposed development in the Parish of Capel. Where in the DLP is this new evidence base? When was site 448 (Land at Tudeley) first considered (p.24-30)? Table 2 details TWBC’s Conclusions of the SHELAA and SA on garden settlement options but gives no credible explanation as to why the Tudeley site is considered to be ‘well located’ as required by para 72 of the NPPF. Neither does Table 3 which details the outcome of TWBC’s Consideration of proposed strategic allocation sites against para 72 of the NPPF. This table is misleading and inaccurate. The site is NOT well located. Comments on the Green Belt Study The site at Tudeley (AL/CA 1) falls within Broad Areas BA3 and BA4. The ‘Potential Level of Harm to the Green Belt Associated with Release of Broad Areas BA3 and BA4 is ‘VERY HIGH’ (Figure 1.1 (p.8)) Comments on the Infrastructure Delivery Plan Education Health Under the heading ‘Additional future requirements needed to deliver growth proposed in the Draft Local Plan’ at paragraph 3.104 (p.40) it states that “The Council has not been made aware of any specific requirements over the plan period; however, discussions with the Maidstone and Tunbridge Wells NHS Trust have highlighted potential need for extension of either the Tunbridge Wells Hospital or Maidstone Hospital to serve the West Kent Area over the Plan period” Please also see my comments in COMMENT BOX 2 under the heading ‘Strategic Objective 5: Essential Infrastructure and Connectivity’ Comments on the SWECO Local Plan Transport Evidence Base Figure 9-2 shows the ‘Mitigation Interventions Mapped’ (p.142) which shows the proposed routes for the following ‘highway measures’ detailed in Table 9-2 (p.138): It is suggested building the Colts Hill strategic link is vital to delivery of the proposed new developments in Capel. How will this improve connectivity? It will be a faster, polluting road to nowhere unless the congestion on the A264 and the two roundabouts at Pembury can be dealt with (there are no proposals to do so in the dLP and the Hendys development will make this worse). Traffic to the A21 from Paddock Wood will continue to use the B2017. The A228 strategic link has been mooted for the last forty years, initially as a requirement due to the Channel Tunnel! The whole area surrounding Paddock Wood needs a radical holistic solution. The dualling of the A21 was supposedly going to reduce traffic in this area but as TMBC have discovered, through traffic has actually increased in volume in Tonbridge since the “improvement” [TWBC: See comments DLP_8189-8214 for full representation] |
Cycling Strategy
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_4354 | Tunbridge Wells Bicycle User's Group | Topic Paper or supporting document title: Local Cycling and Walking Infrastructure Plan (LCWIP) It is essential that the LCWIP currently in preparation should specify that all Local Plan site allocations must prioritise walking and cycling to, from and within all new developments mentioned in the local plan. |
Viability Assessment
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_5315 | Judith Ashton Associates for Redrow Homes Ltd and Persimmon Homes South East | The Viability Appraisal We note that the Viability Appraisal (VA) has not as yet commented upon the viability of the proposed strategic allocation AL/PW1, and that criterion (i) of policy AL/PW1 makes it clear that the level and tenure mix of affordable housing within the Policy AL/PW1 site is to be determined through the Local Plan and CIL Stage 2 Viability Assessment; and that this figure will be confirmed in the Regulation 19 Pre-submission version of the Local Plan. As set out below we will respond on this matter and the associated VA when the Reg 19 plan and updated VA is published. In the context of the above I should highlight the fact that my clients will want the opportunity to comment on Benchmark Land Values, proposed sales prices and assumptions on the cost of providing “on-site infrastructure” when the Stage 2 VA is published. [TWBC: see full representation]. |