Appendix 6: Submitted sites not included in this Draft Local Plan

DLP_4226

Tunbridge Wells District Committee Campaign to Protect Rural England

General Comments

In the time available we have been unable to respond concerning individual sites.  However, CPRE generally agrees with the Council's decisions not to select the sites in the AONB and Green Belt that have been put forward but not selected, though we consider that the grounds for the sites’ non-selection have not been fully set out in the plan documents and could be stated more strongly.

We may make a more detailed response at Reg19 stage.

DLP_4455

Mr Andrew Rankine

Alternative Sites:

I note that TWBC has another consultation in progress at the moment – namely the Brownfield Register. Without this register being kept up-to-date by the council and relying solely on the owners of possible brownfield sites to register their existence, how can the council be assured that it has truly reached its threshold to consider Green Belt sites as possible options? I note that during the council’s second call for sites they proactively contacted landowners to search for suitable areas for development – it was at this stage I assume that the Tudeley site came to the fore as it was not included in the original SHELAA and therefore not considered as a possible option throughout the Issues and Options Consultation. Was there any resource devoted to searching out additional brownfield sites at this point or was all the focus on Greenfield landowners? If the latter and just one unidentified brownfield site exists that would be suitable for development then I would suggest that the threshold for development on Green Belt (as defined by the NPPF) has not been reached.

The Distribution of Development Topic Paper apparently places much weight on the responses received during the Issues & Options Consultation as guiding local strategy, citing various percentages of respondent opinions on proposals. TWBC have reached the conclusion that there is a local preference for a combination of Growth Option 4 and 5 although the location of the New Settlement was not specified. This seems to ignore the fact that the same respondents also stipulated that any New Settlement should be outside of the AONB and Green Belt, that infrastructure improvements would need to be delivered prior to commencing any building work and that all other development potential should be maximised before this was considered – in other words, as a last ditch resort. However, the Draft Local plan appears to have positioned the New Settlement as the poster child of the entire plan, in a location with little or no existing infrastructure and within the Green Belt abutting the AONB. I would suggest that if the respondents knew the location of the proposed development then the New Settlement growth option would have been rejected outright.

There are a number of other sites that have been put forward for consideration through the Call for Sites but rejected by TWBC for reasons that seem similar to those that have resulted in the inclusion of STR/CA1. Horsmonden, for example appears to have been rejected due to “access difficulties” – yet STR/CA1 has no better existing infrastructure but has the additional restrictions of being wholly contained within the Green Belt. Blantyre House may not have been put forward during the Call for Sites but did TWBC officers then contact the owners in the same way that they did other landowners “that had not been submitted through the first Call for Sites to enable them to submit sites if they wished”? These are just two examples of the seemingly inconsistent approach to identifying and rejecting sites for development that have the same (if not more) development constraints as the proposed policy.

DLP_2998

DHA Planning for The Cysters Partnership

land rear of Field House, Iden Green and land adjacent to Pinyons in Sandhurst and other sites

1 Introduction

1.1 Purpose of this report

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

1.1.2 The Partnership are landowners in Tunbridge Wells and are promoting two sites in Tunbridge Wells; land rear of Field House, Iden Green and land adjacent to Pinyons in Sandhurst and other sites.

1.1.3 The former consists of an area of 0.6ha of agricultural land to the south east of Iden Green Road and the east of Standen Street, Iden Green. The land is bound to the north west, west and north east by residential development which aligns the south east of Iden Green Road and east of Standen Street. To the south east there is wider agricultural land also owned by the applicant.

1.1.4 The latter is a 2.3ha area of agricultural land to the west of-the dwelling known as Pinyons on the north side of Queen Street (before the junction with Sponden Lane), Sandhurst. It is bounded to the east by residential development which aligns the north side of Queen Street. To the north is agricultural land, with Queen Street and then further residential dwellings to the south. To the west is Sponden Lane.

1.1.5 Based on the current national and local planning context, we consider these parcels to be suitable for development and we consider there to be ‘exceptional circumstances’ to release this additional land within the High Weald Area of Outstanding Natural Beauty (‘AONB’).

1.1.6 Given this context, this representation responds to the content of the draft plan (and relevant supporting documents) and reinforces why the sites represent suitable locations to accommodate growth. Furthermore, we fully emphasise why such additional housing is needed.

2 The Tunbridge Wells Draft Local Plan

2.1 Overview

2.1.1 The TWBC Draft Local Plan (herein referred to as ‘the plan’) sets out the spatial vision, strategic objectives, and overarching development strategy for the borough. It details overarching place shaping policies for each parish and settlement, as well as site specific allocations to deliver the strategy and detailed policies to be applied to all new development.

2.1.2 The plan will set the agenda for development across the borough to 2036 and replace the current Development Plan, which comprises the Local Plan 2006 (saved policies), the Core Strategy 2010, and the Site Allocations Local Plan 2016.

2.1.3 This representation comments on the following elements of the plan:

• Vision and Strategic Objectives;
• Development Strategy and Strategic Policies;
• Place Shaping Policies for the Parishes of Benenden and Sandhurst;
• Development Management Policies; and
• Omission Sites.

2.2 Vision and Strategic Objectives

2.2.1 The TWBC draft Local Plan is underpinned by a future vision up to 2036 and beyond. The vision is for Tunbridge Wells to be vibrant and prosperous and there is also an expectation that it will have grown significantly. The Council aim for growth to be infrastructure led and largely funded by new development. The key components of the vision are summarised below:

• The heart of Royal Tunbridge Wells and Southborough will be culturally rich, full of vitality, and will have the flexibility, robustness, and adaptability to cope with changes in the economy and other circumstances.
• Paddock Wood as a settlement will have developed considerably (including on land in eastern Capel parish) on the basis of garden settlement principles, using a comprehensive, master-planned approach.
• A new garden settlement will have been established at Tudeley Village, including homes, employment, and community facilities (which will continue to develop over the following years).
• High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure
• Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

2.2.2 The plan stresses that all development will achieve high quality design, responding to the distinctive character of particular locations and in certain instances valued and protected landscapes. Further, the timely delivery of infrastructure will be central to the plan.

2.2.3 In order to turn this vision into reality the plan sets a number of strategic objectives.

1. To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high quality development;
2. To achieve the delivery of all forms of infrastructure to mitigate the impact of development and where possible to result in 'betterment';
3. To prioritise active travel, but where necessary to plan appropriately for use by private motor vehicle, in particular embracing new technology;
4. To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough;
5. To ensure that the borough is vibrant, culturally rich, and economically buoyant;
6. To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature;
7. To release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land;
8. To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation;
9. To establish garden settlements as a model for the future delivery of development in the borough;
10. To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications.

2.2.4 We support the general thrust of these objectives, which seek to meet identified housing needs in full and boosting significantly the supply of new affordable homes. However, we would suggest some minor modification to clarify that the plan is positively prepared and fully aligned with the provisions of the National Planning Policy Framework (‘NPPF’). Indeed, we acknowledge that the Plan aspires to achieve the full development needs of the borough and therefore we consider that objective 1 should be modified to make certain on this point.

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

2.3 Development Strategy and Strategic Policies (Policy STR1)

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

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

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

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

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

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

2.3.7 We support the general principle of proportionately spreading the benefits of growth and we recognise the opportunity to direct a greater level of growth to villages and towns compared with previous plan periods. Furthermore, adopting a pattern of dispersed growth approach would allow a number of sites to be developed at the same time, serving different segments of the local housing market, which is preferable to saturation of the market in a single area.

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

2.3.9 In this regard, we would draw the Council’s attention back to the 2016 document published by Nathaniel Lichfield’s and Partners (NLP) - ‘Start to Finish: How Quickly do Large-Scale Housing Sites Deliver’, which provides evidence pertaining to the speed and rate of delivery of large-scale housing, based on a large number of sites across England and Wales. It identifies that the average lead in time for the submission of a planning application is 3.9 years, from the date the site is first identified. In terms of the planning approval period, for larger scale sites (2,000 + homes) this is circa 6 years. After planning permission is granted, larger sites start to deliver within a year and the average build out rate thereafter is 161 dwellings per annum, although it can be as high as 301 dwellings per annum.

2.3.10 On the basis of this research, if the Local plan is adopted by 2021, planning permission approved by 2023 and delivery commences within 6 years (2029), the likely delivery for the plan period would be no more than 966 homes.

2.3.11 Despite this evidence, TWBC has set a much more optimistic trajectory for delivery of Tudeley Garden Village and the strategic extension of Paddock Wood, which is detailed in the Housing Trajectory Paper. The Council forecast that the Tudeley Garden Village will begin to deliver homes from 2025/26 onward, with an initial build out rate of 150 dwellings per-annum, rising to 200 dwellings per annum from year 6 onward. Likewise, the Council suggests that the extension to Paddock Wood will start to deliver in 2024/25 at an average build out rate of 333 dwellings per annum – which is nearly double the average rate for larger schemes identified in the NLP document. This higher build out trajectory is predicated on the basis that there would be a number of house builders involved the construction of different parts/phases. However, by their own admission, TWBC do not currently know how many housebuilders will be involved.

2.3.12 Taking the above into account, our view is that the Council have applied a drastically overly optimistic development trajectory for the delivery of strategic sites, both in terms of the start date for completions and the expected build out rates. Accordingly, we would encourage the Council to increase the balance of small and medium sized sites, which can deliver quickly and usually require limited intervention to infrastructure.

2.3.13 Given the absence of any similar scale strategic sites in Tunbridge Wells Borough as a point of comparison, one could have regard to similar scale delivery in neighbouring authority Tonbridge and Malling Borough. In this respect, we provide evidence below of its three key strategic sites and the associated delivery rates (derived from the Tonbridge and Malling BV Annual Monitoring Report 2017).

2.3.14 Kings Hill is an extremely prudent example to consider in the context of the Paddock wood extension and new garden village at Tudeley, how deliverable this would be. Indeed, Kings Hill was a new village started in 1989 near land previously occupied by RAF West Malling. The concept was for a multipurpose site of both residential and office business space. The development is still being delivered some 30 years later, despite having multiple national housebuilders delivering different phases concurrently. Based on the most up-to-date delivery data for the last decade, Kings Hill has only delivered 131 dwellings per annum, despite multiple developers delivering concurrently. Furthermore, the earlier delivery phases we delivered at lower rates given the need to front load infrastructure.

2.3.15 Therefore, we consider that whilst some development may come forward in the plan period from the two proposed strategic sites, in reality these strategic allocations are longer term aspirations that will extend beyond 2036.

2.3.16 Accordingly, we would encourage the Council to increase the balance of small and medium sized sites, which can deliver quickly and usually require limited intervention to infrastructure, so that it may reduce the reliance upon Tudeley & Paddock Wood within this current plan period.

2.4 Place Shaping Policies

2.4.1 The place shaping policies establish the spatial priorities for different areas in the borough, organised according to non-parish and parish areas. For each area, there is an overarching policy that development should adhere to and details are provided for individual allocated sites that will deliver the quantum of development proposed. The site-specific allocations provide both strategic and development management guidance.

Benenden

2.4.2 Policy STR/BE1 sets the proposed strategy for Benenden and states that Approximately 119-129 new dwellings will be delivered on four sites.

2.4.3 Our client supports the principle of proportionate growth for the Parish. However, we consider it inappropriate to site all new housing entirely within Benenden and the East End of Benenden, and not to provide a degree of disbursal to Iden Green given it is a hamlet in its own right and should be afforded some wider scope for growth. In this regard, our client has advanced a proportionate and logical infill scheme for circa 7/9 new homes and associated open space.

2.4.4 This being the case, we object to the Council’s failure to consider the associated benefits of small parcels of the wider land promoted via the ‘call for sites’ process.

2.4.5 We also object to the removal of the LBD from Iden Green, especially on the ground that it is unsustainable. Furthermore, the methodology used to arrive at this conclusion is flawed and inconsistent. For Example, within the SHELAA assessments site BE4, at the East End of Benenden, was accepted as sustainable, yet sites 18, 21, 437 and 8 are far closer to the village centre are dismissed as being too remote. With this in mind, there is no reasonable basis to withdraw the LBD boundary in Iden Green.

Appeal Ref: APP/M2270/W/16/3163774 - Killillea, Parkfield Crescent, Iden Green

2.4.6 The above appeal was a scheme for two new dwellings allowed in Iden Green in April 2017 should also be factored into the wider site assessments. In this respect, the appeal followed a refusal of planning permission of a similar nature to that of the current application site. Accordingly, the main issue was whether the proposed development would constitute sustainable development and the effect of the proposed dwellings on the surrounding rural landscape, including whether they would conserve the landscape and scenic beauty of the High Weald Area of Outstanding Natural Beauty.

2.4.7 In reaching the decision, the Inspector stated (with our underlining):

‘Paragraph 55 of the Framework confirms that housing should be located where it would enhance or maintain the vitality of rural communities and that, where there are groups of smaller settlements, development in one village may support services in a village nearby. New isolated homes in the countryside should be avoided, but this site is located adjacent to the defined limits to built development of the settlement of Iden Green, such that it cannot be considered isolated. Development in this location would support services and facilities within this settlement and those of surrounding settlements.

2.4.8 The Inspector then concluded:

‘With regard to the three dimensions of sustainable development, the proposed development would provide economic benefits during the construction of the dwellings and residents would support local services and facilities within this village and surrounding villages once they are occupied. The provision of two dwellings would have a positive social impact in contributing to the need for homes in the area, particularly as the Council confirm there is a lack of a five year housing land supply. I have concluded above that the proposed development would support services and facilities within this settlement and those surrounding, reflect the surrounding rural landscape and conserve the landscape and scenic beauty of the AONB. As a result, the adverse impacts of the proposed two dwellings would not significantly or demonstrably outweigh the benefits, such that the proposed development would comprise sustainable development as defined by the Framework’.

2.4.9 On the basis of this decision, the Planning inspectorate has clearly identified that proportionate development adjacent to rural settlements such as Iden Green can be sustainable owing to the role they play in sustaining rural communities.

2.4.10 Finally, within the ‘overview’ table for Benenden the site assessments are not consistent. For example:

1. Iden Green is better located to Benenden that the East End, but is not fully referenced;
2. Landscape Character – Iden Green should add orchards.
3. Bus frequencies are consistent between Iden Green the East End of Benenden, yet are not referenced;
4. Staplehurst station 8.9 miles from Iden Green by road but is not referenced;
5. Education Facilities – the East End has no preschool, Iden Green does at present.
6. Recreational facilities – the East End has tennis courts, cricket pitch and a café – but these are not publicly available? Within Iden Green there is a pub, a nursery school, a community hall, a church, a tennis club and recreation field. There is also a paved footpath link to Benenden Village and a lot of local children already walk up to Benenden’s new primary school.

2.4.11 Given this context, we do not consider the site selection that underpins the current choices is adequately informed or sound.

Sandhurst

2.4.12 Policy STR/SA1 sets the proposed strategy for Sandhurst and states that Approximately 20-27 new dwellings will be delivered on two sites.

2.4.13 Our client objects to the extremely low provision of housing for the village, particularly when Benenden is to be afforded circa 6 times the proposed growth of Sandhurst despite similar AONB constraints. Given the availability of additional sites, we strongly consider that Sandhurst could accommodate additional growth in a sustainable manner. Furthermore, our client has already advanced a formal application and subsequent pre-application for circa 20 homes on a small parcel of the land promoted under reference 438.

Exceptional Circumstances

2.4.14 Paragraph 172 of the NPPF states that great weight should be given to conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection. It goes on to state that planning permission should be refused for major developments in AONB areas except in exceptional circumstances and where it can be demonstrated they are in the public interest.

2.4.15 Consideration of such major applications should include an assessment of:

1. the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
2. the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and
3. any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.

2.4.16 It is important to stress that footnote 55 of the NPPF is clear that for the purposes of paragraphs 172 and 173, whether a proposal is ‘major development’ is a matter for the decision maker, taking into account its nature, scale and setting, and whether it could have a significant adverse impact on the purposes for which the area has been designated or defined. The term has no direct correlation with the definitions set out in the Town and Country Planning (Development Management Procedure) (England) Order 2015.

2.4.17 Whilst this document supports the promotion of the land rather than a formal planning application, we set out below why we consider exceptional circumstances exist for the release of this land within the AONB.

2.5 The need for the development

2.5.1 As outlined by the plan, there is an overriding and growing housing need within the Borough. The Council’s SHMA findings initially identified the future need to plan for some 648 new homes per year. This in turn has seen a further uplift as a result of the standard methodology for calculating housing need, which based on the most credible set of population projections suggests a further uplift to circa 680 new homes per year.

2.5.2 In addition to the need moving forward, the previous difficulties in keeping pace with delivery has resulted in a need to accommodate a significant number of dwellings in the short term with a deficit in five year supply.

2.5.3 Given the current development plan has seen documented difficulties in meeting the existing core strategy housing target, the need for new housing is compelling and indisputable and must be addressed by the new plan as a priority.

2.6 The cost of, and scope for, developing elsewhere

2.6.1 Tunbridge Wells is a constrained borough. There are a number of archaeological and heritage sites, including 45 Historic Parks and Gardens, 25 Conservation Areas and 11 Scheduled Ancient Monuments. In addition, there are approximately 3,000 Listed Buildings.

2.6.2 The landscape of the High Weald AONB contains numerous historic landscape features, including field patterns, settlements and ancient woodland, whilst the borough also hosts a number of, or is close to, areas of ecological importance. These include:

1. Ancient Woodland (approximately 16% of the borough)
2. Circa 60 Local Wildlife Sites (approximately 11% of the borough)
3. Ten Sites of Special Scientific Interest (SSSI)
4. Five Local Nature Reserves (including one Community Woodland)
5. One Regionally Important Geological Site, at Scotney Castle Quarry.

2.6.3 The nearby Ashdown Forest is a designated Special Area of Conservation (SAC) and Special Protection Area (SPA).

2.6.4 Although not an environmental constraint, the Metropolitan Green Belt covers 22% of Tunbridge Wells borough.

2.6.5 Given the above constraints, it is acknowledged that planning for housing requires the need to balance a number of core environmental and planning matters in order to reach a sensitive future development strategy.

2.6.6 In respect of Benenden and Sandhurst, the villages are not located within the 22% of the borough that is Green Belt and where an ‘in principle’ objection to development applies. Furthermore, there are no non-AONB alternative sites available given the entire extent of the villages are washed over by the designation. Any growth that will provide a meaningful input of market and affordable homes is going to have a degree of adverse impact.

2.6.7 The priority must therefore be prioritising the sites with the lesser impact and where possible, concentrating new development so that it reads as a next chapter in the history and evolution of the village.

2.7 Any detrimental effects and the extent to which that could be moderated

2.7.1 Opportunity exists to moderate the effects of development, including areas of landscaping and associated ecological and heritage buffers and the opportunity to increase public access to the land.

2.7.2 In summary, we object to the Council’s exclusion of our client’s sites and consider that there are exceptional circumstances exist to justify the allocation of these sustainable parcels of AONB land. Furthermore, ways in which the site’s impact could be mitigated have already been fully considered in detail and the schemes have been shown to be deliverable owing to their advancement through the development management process.

3 Section 6: Development Management Policies

3.1.1 In addition to our comments on the strategy, we have reviewed the proposed replacement development management policies as set out in chapter 6 of the document.

3.1.2 In general terms, we would refer back to paragraph 15 of the NPPF that promotes succinct and up-to-date plans, which provide a positive vision. In contrast, the draft policies currently proposed are of such prescriptive detail that they are neither positively prepared nor flexible enough to allow for a range of different circumstances. Furthermore, many aspirations result in inevitable conflict. On this basis, we would recommend that the majority of proposed policies are simplified and where additional guidance is needed, this be included within secondary Supplementary Planning Documents.

3.1.3 Turning to detailed policies, there are a number of contradictory elements that need to be remedied before the plan proceeds to Regulation 19. For example, policy EN1 seeks to ensure development is consistent with the established character and surrounding form. However, policy EN4 places significant emphasis on measures to radically reduce greenhouse gas emissions. The provision of a step change towards more sustainable construction and climate change is, inevitably going to result in a need for a change in attitude towards design, material and construction. Accordingly, a cohesive policy approach is needed that allows innovative and different design if supported on wider environmental and planning grounds. As drafted the policies are too inconsistent.

3.1.4 A number of policies also seek to provide guidance rather than policy. For example, policy EN6 seeks to clarify what information is needed in order to assess a heritage proposal. This level of information should instead feature within a support SPD not policy.

3.1.5 In respect of the natural environment, policy EN20 seeks to protect the rural landscape. It states that development will be required to:

‘1. Conserve and enhance the unique and diverse variety and juxtaposition of the borough’s landscape and the special features that contribute positively to the local sense of place; and

2. Not cause significant harm to the landscape setting of settlements, including historic farmsteads and hamlets; and

3. Not result in unsympathetic change to the character of a rural lane, which is of landscape, amenity, nature conservation, or historic or archaeological importance; and

4. Restore landscape character where it has been eroded; and

5. Preserve intrinsically dark landscapes in accordance with Policy EN 10: Outdoor Lighting and Dark Skies’.

3.1.6 We support the principle of the policy but consider amendments are needed to ensure that it does not result in a blanket reason to refusal otherwise sustainable greenfield development. We suggest it be amended to read:

‘1. Conserve and enhance the unique and diverse variety and juxtaposition of the borough’s landscape and the special features that contribute positively to the local sense of place; and

2. Not cause Include appropriate mitigation to ensure against significant harm to the landscape setting of settlements, including historic farmsteads and hamlets; and

3. Not result in unsympathetic change to the character of a rural lane, which is of landscape, amenity, nature conservation, or historic or archaeological importance; and

4. Restore Enhance landscape character where it has been eroded; and

5. Preserve intrinsically dark landscapes in accordance with Policy EN 10: Outdoor Lighting and Dark Skies’.

3.1.7 Turning to housing policies, we have significant concerns about the drafting of several policies, that show a degree of misunderstanding of the development industry. For example, policy H1 states:

‘Unless there are exceptional circumstances due to specific site or development constraints, a condition will be attached to any grant of planning permission for new major residential development (including change of use) requiring one or the other of the following conditions:

1. That the permission be implemented within two years from the date of decision; or

2. That groundworks and the construction of the ground floor base of at least two buildings be completed within three years of the permission’.

3.1.8 Whilst the majority of developers would aspire to be ‘on site’ and under construction within 2 years, the reality is that there are often processes that need to be adhered to that are outside of the applicant’s control, including the need to formally conclude land purchases, to discharge conditions and to deliver off site mitigation. There are also ‘non planning’ consents that need to be achieved for example Section 278 Highway works, infrastructure agreements (S38 of the Water Industry Act), ecology licensing etc

3.1.9 The Council will also be aware that commencement of development is often prohibited by seasonal restrictions in respect of ecology and wider constraints.

3.1.10 The second requirement for two buildings to be commenced is arbitrary, for example what is the test for single unit schemes or conversion works? The correct test should be as set out in statute i.e. ‘a material start’.

3.1.11 With the above in mind, we consider the Council’s policy should be deleted or modified to the extent that it will endeavour to agree a two year start date based on site circumstances.

3.1.12 In respect of policy H2, and the preference for Multi-developer schemes and comprehensive masterplanning, we understand the aspiration. However, in reality such stringent requests often result in conflict and further delay and the Council should be careful not to try and impose itself on wider commercial arrangements that may prohibit rather than assist delivery. With this in mind, it is our view that the Council should shift focus away from how it wishes to change development industry practices and instead concentrate on what it can influence, namely the provision of detailed guidance for the proposed site allocations (including potential phasing plans and areas zoned for different forms of development). The Council could also consider imposing an illustrative delivery trajectory as part of the validation process.

3.1.13 We note that policies H3 and H4 have regard to housing mix and density yet provide little or no detailed requirement. On the basis that mixes must reflect market requirements, we consider any aspirational densities would be better placed being inserted into the wider reaching policy EN1.

3.1.14 Policy H5 sets out affordable housing requirements. Whilst we support the general thrust of the objectives and the securing of affordable provision, we object to the rounding up of the calculations and contributions being based on a net rather than gross number of units. For small scale proposals this will often see the proposed percentage increase to closer to 45% and 35% respectively. Such thresholds would therefore need to be tested and justified by evidence. A pragmatic approach would be to apply traditional rounding up or down.

3.1.15 The phasing of affordable provision also needs to be sufficiently flexible so as to not prohibit wider delivery. In this regard, we consider that entering into contract with a registered affordable prior ahead of the 50% occupation should provide the certainty of delivery, but without risking a wider delay in market delivery.

3.1.16 We also object to the expectation of sites that provide between one and nine units to pay a contribution towards affordable housing. This conflicts with Paragraph: 023 Reference ID: 23b-023-20190901 of National Planning Practice Guidance, which states planning obligations for affordable housing should only be sought for residential developments that are major developments. Any reduced threshold should be restricted to designated areas only and should be underpinned by detailed evidence.

3.1.17 The Council will be aware of wider country wide discussions regarding the viability of providing social rented accommodation as part of a wider offer. Such provision is becoming increasingly difficult and without robust policy in place that addresses this matter, this matter is likely to significantly slow delivery.

3.1.18 We note that the Council is only willing to allow the use of Vacant Building Credits in exceptional circumstances. However, the test proposed appear significantly more onerous than have been considered and applied elsewhere. Based on the tests proposed, we fear that there will be a delay in genuinely vacant buildings, that are entitled to use of VBC, to be delayed in coming forward in order to meet the overly onerous criteria.

3.1.19 Finally, we note that paragraph 6.160 states:

“…The Council will assume a buffer of 25m from the edge of [ancient] woodland expecting through assessment for developers to confirm that this or any other distance is appropriate and that the priority for such buffers will be ecological mitigation and enhancement for the woodland rather than the amenity of the proposed development.”

3.1.20 The advice from the Government’s statutory advisor on biodiversity, Natural England, states that:

“For ancient woodlands, you should have a buffer zone of at least 15 metres to avoid root damage. Where assessment shows other impacts are likely to extend beyond this distance, you’re likely to need a larger buffer zone.” [1] https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences

3.1.21 Whilst it is recognised that every case will need to be treated on its merits, the Council has provided no justification for imposing a new starting point of 25m, which is nearly double the standard minimum requirement set out by Natural England. This increased buffer zone does not appear to have been based on any evidence. It will simply reduce the quantum of development that can be achieved on many sites, which will in turn increases the risk that additional land is likely to be required elsewhere to meet development needs. We object to this proposed buffer, and request that the standard accepted minimum distance of 15m should be stated instead.

3.1.22 In summary, whilst this overview is not exhaustive, we do have concerns about the nature of the proposed policy framework and the degree to which it appears to be trying to limit and frustrate development. Accordingly, in the interests of positive planning, we recommend that the policy framework is simplified and refined and subject to further detailed consultation and focussed on planning matters.

4 Conclusion

4.1.1 This representation has been prepared on behalf of The Cyster Partnership in response to the Tunbridge Wells Borough Council Draft Local Plan Consultation. The purpose being to provide comment on the Council’s proposed development strategy.

4.1.2 In this respect, we support the aspiration to meet housing need in full and consider that a dispersed growth strategy represents the optimum means to achieve this. Nonetheless, we object to the exclusion of our client’s land parcels at Iden Green and Sandhurst, which is unsubstantiated by evidence.

4.1.3 Furthermore, we consider that the Local Plan strategy relies heavily on the delivery of strategic sites that would require the provision of supporting infrastructure. Moreover, the Council have applied overly optimistic projections to the delivery of housing for the extension of Paddock Wood and the Tudeley Garden Village, largely disregarding the NLP 2016 report and the time it would take to masterplan the strategic sites and deliver the required infrastructure.

4.1.4 In our view, a more realistic trajectory would see some housing delivered, albeit not at the suggested build out rates and much later in the plan period. Further small to medium sites are therefore needed and they should be directed to locations such as our clients land where a commitment to delivery has already been demonstrated.

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

DLP_5291

Wilf Andrews

Site 158 Land to the rear of Greenacres, The Street, and adjacent to New Pond Road, Benenden

AL/BE2: the plan acknowledges that 158 is suitable (via the request for an access road through site AL/BE2 to “the land located to the north (158), which may be allocated for development as part of a future Local Plan”). If suitable then, why not suitable now? 158 is a much more sustainable location than AL/BE4. 158 was considered as a site for a  primary school and, at one point, as a site for 174 houses.

DLP_5961

Gerald Conyngham

Site 158 Land to the rear of Greenacres, The Street, and adjacent to New Pond Road, Benenden

I am writing with comments about the part of the local plan which deals with housing allocation in Benenden. And in particular about site 158 which has been dropped from the plan as a possible site for development:

* This site was considered as a possible site for the new primary school and later TWBC officers considered it as a possible site for 174 houses. Under policy ALBE2, there is an acknowledgement that site 158 is suitable, via the request for an access road through site AL/BE2 to ‘the land located to the north ( ie 158), which may be allocated for development as part of a future local plan’. If suitable then, why is it not considered suitable now?.

* In the draft Benenden Neighbourhood Plan, it states that ‘the sustainability credentials of this site are high’.

* We are open minded about the number of houses that might be built on the site and do not have any particular number in mind at this time. We would be happy with a more modest development than 174. We would want a high proportion to be affordable, be open to local people, and meet the needs of elderly people and people with disabilities. And to be built in ways which fit into the local environment in terms of building design. We would seek a developer who could meet these criteria.

* In relation to Limits to Built Development it appears that sites were chosen first and then a line drawn round them to exclude other sites. Thus it appears that the line is somewhat arbitrary.

* The site lies at the heart of the village and building here would prevent ribbon development or development in random sites in the rural parts of the parish. In that sense it would preserve the rural nature of the parish in making it less necessary to build houses outside the built up village centre.

* It is a very good site from the point of view of sustainability and reducing pollution. People living there could walk to the village school, village shops, church and local meetings. There is no need for an extra car and the extra carbon emissions which would be essential for people living 3 miles from the heart of the village. Pedestrian access is already available to the site.

* It doesn’t make good planning sense to plan a large development at the East End and leave the village centre for development at some later time. It goes against the environmental interests of everyone.

* Using brownfield sites is said to be a priority yet the plan being proposed eats into the countryside since travel links, and the pollution associated with them, would be needed between the new settlement at the East End and the village. We believe that sustainability should be considered as the primary goal.

* In the comments on the original Neighbourhood Plan It was agreed that site 158 is not a site of particular wildlife significance. And is not visible thus reducing its attractiveness as a green field site.

* It does not block views and is discreetly hidden behind the Street, as are the current recent developments at St George’s Close and Horton’s Close.

* Development here supports the Borough Council’s recent commitment to make the District carbon neutral by 2030.

* The site 158 is specifically mentioned in the Strategic Housing and Land Availability Assessment paper (SHELAA) and I would make the following comments:

* It states that ‘the land lacks services and facilities including public transport’ yet it is central to the village and near bus stops so this is clearly inaccurate.

* It also states that the site is ‘sensitive in landscape terms and there is concern regarding scale and impact on the landscape’. However the site is hidden and well tucked away, unlike some of the other developments being approved. Also the scale of any development would be sensitively managed to ensure it fits well with the environment of the village.

* The site is also analysed in the Strategic Environmental Assessment for the Benenden Neighbourhood Plan and is given a rating of ‘likely positive effect’ under the headings of Population and Community, Health and Well being, and Transport.

* Under Population and Community it states that ‘Allocation of the site will contribute positively to 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’.

* Under Health and Well being, it states that ‘The site is accessible to the village’s public rights of way and green infrastructure networks. ‘

* Under Transportation it makes the same point as in the Population and community above. And adds that ‘The site is approximately 250 m from the nearest bus stop with hourly services.’

All these points from the AECOM report reinforce the points made earlier in this submission.

In the light of all the points above, we conclude that the site is well placed for development and we recommend that the development takes place at the same time as the other sites approved .

DLP_6485

Woolf Bond Planning for Millwood Designer Homes Ltd

Site 222: Land on the west side of Iden Green Road, Benenden, TN17 4ES

Introduction

General

We refer to the above Regulation 18 Local Plan (“LP”) consultation document and write on behalf of our client, Millwood Designer Homes, setting out a number of comments upon the policies and proposals contained therein.

As you will doubtless be aware, our client is a Kent-based developer of long standing repute for high quality residential schemes. They have a number of current land interests in the Borough, and these representations are submitted both generally in terms of the overall spatial strategy, and settlement-specific in relation to their land interest to the west of Iden Green Road, Benenden (SHLAA Site Ref: 222).

Policies and Proposals

Our representations relate to the following policies and proposals:

* STR 1: The Development Strategy

* STR10: Limits to Built Development

* STR/CA 1: The Strategy for Capel Parish; as well as:

- AL/CA 1: Tudeley Village

- AL/CA 3: Land at Capel and Paddock Wood

* STR/PW 1: The Strategy for Paddock Wood; as well as:

- AL/PW 1: Land at Capel and Paddock Wood

* STR/BE1: The Strategy for Benenden Parish

- AL/BE4: Land at Benenden Hospital

* EN17: Local Green Space

Our representations are also accompanied by a duly completed response form. Our detailed comments are set out below.

Supporting Particulars: Site Specific Representation - the omission of land to the west of Iden Green Road, Benenden as a housing allocation

Millwood Designer Homes has a controlling interest in land to the west of Iden Green Road which extends to approximately 2.5ha.

The site has been assessed in the Council’s Strategic Housing and Economic Land Availability Assessment (“SHELAA”) under Site Ref: 222.

We have undertaken a thorough assessment of the character of the site and surrounding area and consider that it affords a sustainable development opportunity for approximately 28 dwellings, to include the creation of a larger publicly accessible area of green space and reinstatement of the pond in the north east corner of the site.

We consider this would enhance the public realm and would enable a high-quality scheme for a small number of dwellings to be located within walking distance from local services and facilities, helping to further sustain and support local businesses.

Plans and particulars are enclosed in support of our representations, which seek the allocation of the site for approximately 28 dwellings as follows:

(i) Site Location Plan No. P318/LP/1001

(ii) Figure 3 – Landscape Strategy

(iii) Heritage Statement and Local Green Space Assessment (Nov 2019) (RPS)

We set out the merits of the site as a housing allocation in response to the Benenden-specific policies below.

Our detailed representations are also accompanied by a duly completed comment form.

Overarching Comments

As an overarching position statement, it is our view that the Plan as drafted is unsound having regard to

1. The over reliance on housing delivery from strategic sites.

2. The allocation of sites that cannot be said to be justified when taking into account the reasonable alternatives (see point (3) below)).

3. The omission of land west of Iden Green Road, Benenden as a housing allocation for approximately 28 dwellings (Site Ref: 222)

On the basis of the foregoing, and as expanded upon below, we do not consider the Plan to be positively prepared, justified, effective or consistent with national policy at this stage in the plan–making process. However, it is clearly a good start and we welcome the opportunity to work with the Council in addressing our comments, including in relation to the omission of our client’s land interest.

The next iteration of the Local Plan (the Regulation 19 stage) provides the opportunity to make the necessary changes in order to ensure the Plan can be said to be sound and that it represents the most appropriate strategy when assessed against the alternatives; and that it is consistent with national policy.

For the Plan to be found sound, modifications are required to be made to the Plan in response to our concerns expressed at points (1) to (3) above.

NPPF Considerations

General: Tests of Soundness

Section 3 of the NPPF (February 2019) sets out the principal components to be included in local plans.

In order to be found “sound”, paragraph 35 of the NPPF requires the plan to be positively prepared, justified, effective and consistent with national policy.

A positively prepared plan provides a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities so that unmet need from neighbouring areas is accommodated where practical to do so and is consistent with achieving sustainable development.

In order to be justified the DPD must be an appropriate strategy, taking into account reasonable alternatives; and should be informed by a proportionate evidence base.

Effective means the document must be deliverable over the plan period and based on effective joint working on cross-boundary strategic matters, including meeting unmet needs from adjoining authorities.

Proposed Amendments

For the reasons set out in these representations there are a number of shortcomings with the Plan as currently drafted, that result in the need for amendments.

Our suggested amendments, necessary to satisfy the tests of soundness, may be summarised as relating to the following:

* Acknowledgement that the existing supply of housing commitments are insufficient in both quantum and nature to meet both immediate and longer term needs;

* The need for greater flexibility within the Plan to meet the overall housing requirement for the plan period. These concerns can only be resolved through the identification of additional allocations;

* Delete the proposed Local Green Space designation of land west of Iden Green Road, Benenden (Ref AS_45); and

* The allocation of land west of Iden Green Road, Benenden for approximately 28 dwellings (SHELAA Site Ref: 222)

Summary

On the basis of the foregoing, the Regulation 18 draft Local Plan does not currently satisfy the tests of soundness for the following reasons:

* Unjustified – The plan is not the most appropriate strategy when compared to the reasonable alternative of additional allocations in sustainable locations such as Site 222 at Benenden.

* Ineffective – The proposed distribution strategy and over-reliance on strategic sites fails to deliver the necessary level of housing development, including addressing potential unmet needs (to be agreed during the evolution of the Local Plan process).

* Inconsistent with National Policy – The proposed distribution strategy fails to boost the supply of housing or maximise sustainable patterns of housing growth, including on account of failing to provide for an appropriate level of growth on sustainably located sites.

Our client’s site west of Iden Green Road, Benenden offers a sustainable and deliverable opportunity to provide for approximately 28 dwellings, in a landscaped setting, within walking distance from local services and facilities.

The northern part of the site can provide for publicly accessible amenity space, providing for an enhanced public realm.

We trust the above comments are of assistance in producing the Local Plan and await confirmation of receipt of our representations in due course.

Finally, we welcome the opportunity to enter into dialogue with the Council in order to discuss our comments in the context of seeking to ensure a sound Local Plan.

Please do not hesitate to contact the writer should you wish to discuss any matter(s) arising.

[TWBC: see full representation, Figure 3 Landscape Strategy, Heritage & LGS Assessment, and site location plan].

[TWBC: see also Comment Numbers DLP_6485, 6487-6489, 6491-6494]

DLP_8258

Emily and Victoria Pettit

Site 222 Land on the west side of Iden Green Road, Benenden

Specific Position of the heart of Benenden Village

Site 222 and inconsistent methodology:

• adjacent to the new LBD, arbitrarily construed, now omitting
  
  The Manor House that is one of the original dwellings in Benenden (the
  
  hospital site is 3 miles outside LBD)
• adjacent to a listed building (the hospital site includes a listed
  
  building in its land scheduled for development)
• lacks splay to field gate (there is sufficient road frontage on a
  
  straight road to achieve the required visibility splay and this is a
  
  technical detail that can be devised at the planning application stage)
• no pavements along Iden Green Road (part of the proposal
  
  submitted to TWBC from Millwood Designer Homes includes the
  
  instatement of a pavement, while maintaining existing hedges. There are no pavements on Walkhurst Road)
• greenfield site (so is site AL/BE1 on Walkhurst road and site
  
  AL/BE2 on Walkhurst Road)
• AONB (so are the sites above and so is site AL/BE2 and parts
  
  of site AL/BE4)
• lacks services and facilities including public transport (we are the closest site to all services of all sites that were submitted in the call for sites. Site AL/BE4 lacks these a good deal more).
  
  Site 222, which is a few minutes’ walking distance to all the village services, includes the creation of a substantial green space around the pond near the cross roads of Benenden for the whole community to enjoy in its current proposal. This is a very low density development proposed by the appointed developer of 28 dwellings over 2.5 hectares, including a fair and integrated representation of much-needed affordable, quality homes.
  
  Independent assessments by professionals have been made into impact on heritage and scenery, demonstrating little effect with the minimal impact, sensitive, quality design and landscaping, for which the proposed developer has won national awards and is working on Site 222 on an exclusive basis. Not all developers are the same, as you are aware. As landowners who have invested considerable personal funds to planting more trees at the western side of our property over the past decade and have been approached by more aggressive and less designoriented developers in the call for sites, we do not buy into fuzzy promises of great design from other developers on other sites.

The landowner of Site 222 has stated, and reiterated through confirmation in writing to, and acknowledgement from, The Benenden Neighbourhood Planning Group, that in the event planning permission is granted for the smaller scale development as outlined above, they will provide a strip of land to the Parish Council, to uphold their intention of not undertaking ribbon development, while maintaining the trees we have planted on the western side of our property. There will therefore be no effect on views and the Roman Road outside the western edge of the property. Likewise, there will be no effect on the Conservation Area, which will be preserved in perpetuity as a green space according to the landowner’s current proposal.

DLP_5153

Herbert Boxall

Site Reference Number and Site Address column: Site No. LS_8 (Land south of Chapel Lane, Iden Green, Cranbrook)

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_4972

Chris Gilchrist-Fisher

Site 406 Land at Glebe House, Brenchley Road, Brenchley

Site Number and Site Address: LS 406 – Land at Glebe House, Brenchley Road, Brenchley, Kent

With regard to the above land which we have put forward for development but has not been designated within the proposed Local Plan for housing development. We think it should be considered for being included as housing development land for the following reasons;

1. It is immediately available for development

2. The draft Local Plan allocated no sites in Brenchley

2. The land adjoins the village boundary and is in the heart of Brenchley village

3. It is close to the village school and bus stops thereby making it a sustainable site

4. It has good access in one of two ways; either a new entrance on Holly Bank or via the use of an existing access from Brenchley Road

5. The land has no agricultural use due to its isolated location and small size

In keeping with the immediate surroundings of this part of the village, we believe that a development of low density units would suite the site extremely well and fit into the surroundings. We are exploring self-build options with stringent parameters on the architecture/design and materials to suit the surrounding area in line with its situation in the Conservation Area. The demand from the community for self build options is very high but the supply is very limited and therefore this would provide much needed supply.

DLP_7983

Wendy Owen

Site 459, 23, 214, 333, 383

459 Kippings Cross

23 Kippings Cross farm land, Hastings Road, Tunbridge Wells TN12 7HB

214 Land at Kippings Cross (rear of Blue Boys and north of Cryals Road), Brenchley

333 Kippings Cross Distribution Centre, Hastings Road, Kippings Cross, Kent

383 Land to the south of the A21 and east of Dundale Road, Kippings Cross, TunbridgeWells, Kent

We wish to challenge why the Kipping’s Cross site was omitted from the sustainability appraisal – the purpose of the appraisal process is to fully consider the positives and negatives, in a structured and documented way. This site appears to have been rejected because it is “within the AONB and landscape impacts were considered too severe to warrant consideration”. Other sites within the AONB with equally adverse landscape impacts have been taken forward and without a full suite of sustainability assessments it is not possible to make properly evidenced based policy. As such this omission renders the sustainability appraisal unsound as a whole.

DLP_1926

Royal Tunbridge Wells Town Forum

Site Numbers 49, 62, 77

Although the following sites are outside the unparished area of Royal Tunbridge Wells, we make the following commentary on the basis that these un-allocated sites are important to the setting of Royal Tunbridge Wells and/or also serve to prevent the coalescence of RTW with other settlements

Site Number and Site Address: 49 (Capel) Land at Castle Hill Farm

We support the conclusion that the site is unsuitable for development. The western part of this site is AONB and Green Belt, part of a key landscape approach to RTW from the north and is visible not only from the railway line but also from the Tunbridge Wells Circular Walk. It is Town Forum policy to seek to maintain the integrity of this high quality landscape as the most significant green gateway to the urban area and a clearly visible barrier to coalescence of RTW with Tonbridge.

Site Number and Site Address: 62 (Capel)  Land south of Devils Wood 

We support the conclusion that the site is unsuitable for development. This site is AONB and Green Belt, part of a key landscape approach to RTW from the north and is visible not only from the railway line but also from the Tunbridge Wells Circular Walk. It is Town Forum policy to seek to maintain the integrity of this high quality landscape as the most significant green gateway to the urban area and a clearly visible barrier to coalescence of RTW with Tonbridge.

Site Number and Site Address: 77 (Capel) Land adjacent to Forest Farm 

We support the conclusion that the site is unsuitable for development. This site is AONB and Green Belt, part of a key landscape approach to RTW from the north. It is Town Forum policy to seek to maintain the integrity of this high quality landscape as the most significant green gateway to the urban area and a clearly visible barrier to coalescence of RTW with Tonbridge. The northern part of the site, which is an open field, is one of the rare places in the area where it is still possible to hear the song of skylarks.

DLP_2712

DHA Planning for Mr Mark Cubbon and the Billings Group

Late Site 29 Land at Sychem Lane, Five Oak Green

1 Introduction

1.1 Purpose of this report

1.1.1 This representation has been prepared on behalf of Mr Mark Cubbon (the landowner) and the Billings Group - in response to the Tunbridge Wells Borough Council (‘TWBC’) Draft Local Plan Consultation, which runs until 15th November 2019.

1.1.2 Our clients are collaboratively promoting land east of Sychem Lane, Five Oak Green, which has not been included within the plan.

1.1.3 Based on the current national and local planning context, we consider this additional site to be suitable for development and we consider there to be ‘exceptional circumstances’ to release the land from the Green Belt as part of the plan making process. Furthermore, we consider the type of development proposed by our client better accords to the recommended approach to Green Belt release as set out within the National Planning Policy Framework (NPPF) 2019.

1.1.4 Give this context, this representation responds to the content of the draft plan (and relevant supporting documents), reinforces why the sites represent suitable locations to accommodate growth and outlines how development could be delivered on site.

2 The Tunbridge Wells Draft Local Plan

2.1 Overview

2.1.1 The TWBC Draft Local Plan (herein referred to as ‘the plan’) sets out the spatial vision, strategic objectives, and overarching development strategy for the borough. It details overarching place shaping policies for each parish and settlement, as well as site specific allocations to deliver the strategy and detailed policies to be applied to all new development.

2.1.2 The plan will set the agenda for development across the borough to 2036 and will replace the current Development Plan, which comprises the Local Plan 2006 (saved policies), the Core Strategy 2010, and the Site Allocations Local Plan 2016.

2.1.3 This representation comments on the following elements of the plan:

• Vision and Strategic Objectives;
• Development Strategy and Strategic Policies;
• Place Shaping Policies;
• Development Management Policies; and
• Omission Sites.

2.2 Vision and Strategic Objectives

2.2.1 The TWBC draft Local Plan is underpinned by a future vision up to 2036 and beyond. The vision is for Tunbridge Wells to be vibrant and prosperous and there is also an expectation that it will have grown significantly. The Council aim for growth to be infrastructure led and largely funded by new development. The key components of the vision are summarised below:

• The heart of Royal Tunbridge Wells and Southborough will be culturally rich, full of vitality, and will have the flexibility, robustness, and adaptability to cope with changes in the economy and other circumstances.
• Paddock Wood as a settlement will have developed considerably (including on land in eastern Capel parish) on the basis of garden settlement principles, using a comprehensive, master-planned approach.
• A new garden settlement will have been established at Tudeley Village, including homes, employment, and community facilities (which will continue to develop into the following years).
• High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure
• Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

2.2.2 The plan stresses that all development will achieve high quality design, responding to the distinctive character of particular locations and in certain instances valued and protected landscapes. Further, the timely delivery of infrastructure will be central to the plan.

2.2.3 In order to turn this vision into reality the plan sets a number of strategic objectives.

1. To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high quality development;
2. To achieve the delivery of all forms of infrastructure to mitigate the impact of development and where possible to result in 'betterment';
3. To prioritise active travel, but where necessary to plan appropriately for use by private motor vehicle, in particular embracing new technology;
4. To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough;
5. To ensure that the borough is vibrant, culturally rich, and economically buoyant;
6. To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature;
7. To release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land;
8. To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation;
9. To establish garden settlements as a model for the future delivery of development in the borough;
10. To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications.
    
    2.2.4 We support the general thrust of these objectives, which seek to meet identified housing needs in full and to boost the supply of new homes. We also consider it essential that the Green Belt is reviewed and suitable Green Belt land is brought forward for development.

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

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

2.2.6 Furthermore, the release of a large expanse of Green Belt to facilitate a new settlement is yet to be fully tested and we question to what degree this approach accords with the guidance set out in the NPPF. We address these points in further detail within the subsequent sections below.

2.3 Development Strategy and Strategic Policies (Policy STR1)

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

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

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

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

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

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

2.3.7 We support the general principle of proportionately spreading the benefits of growth and we recognise the opportunity to direct a greater level of growth to villages and towns compared with previous plan periods. Furthermore, adopting a pattern of dispersed growth approach would allow a number of sites to be developed at the same time, serving different segments of the local housing market, which is preferable to saturation of the market in a single area.

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

2.3.9 In this regard, we would draw the Council’s attention back to the 2016 document published by Nathaniel Lichfield’s and Partners (NLP) - ‘Start to Finish: How Quickly do Large-Scale Housing Sites Deliver’, which provides evidence pertaining to the speed and rate of delivery of large-scale housing, based on a large number of sites across England and Wales. It identifies that the average lead in time for the submission of a planning application is 3.9 years, from the date the site is first identified. In terms of the planning approval period, for larger scale sites (2,000 + homes) this is circa 6 years. After planning permission is granted, larger sites start to deliver within a year and the average build out rate thereafter is 161 dwellings per annum.

2.3.10 On the basis of this research, if the Local plan is adopted by 2021, planning permission approved by 2023 and delivery commences within 6 years (2029), the likely deliver for the plan period would be circa 966 homes.

2.3.11 Despite this evidence, TWBC has set a much more optimistic trajectory for delivery of Tudeley Garden Village and the strategic extension of Paddock Wood, which is detailed in the Housing Trajectory Paper. The Council forecast that the Tudeley Garden Village will begin to deliver homes from 2025/26 onward, with an initial build out rate of 150 dwellings per-annum, rising to 200 dwellings per annum from year 6 onward. Likewise, the Council suggests that the extension to Paddock Wood will start to deliver in 2024/25 at an average build out rate of 333 dwellings per annum – which is nearly double the average rate for larger schemes identified in the NLP document. This higher build out trajectory is predicated on the basis that there would be a number of house builders involved the construction of different parts/phases. However, by their own admission, TWBC do not currently know how many housebuilders will be involved.

2.3.12 With the above in mind, our view is that the Council have applied drastically overly optimistic development trajectory for the delivery of strategic sites, both in terms of the start date for completions and the expected build out rates. Accordingly, we would encourage the Council to increase the balance of small and medium sized sites, which can deliver quickly and usually require limited intervention to infrastructure. This would also provide a greater degree of flexibility for the plan in the event that strategic sites are delayed.

2.3.13 In addition to the concern about slow delivery, we object to the potential impact that a new garden village would have on a settlement such as Five Oak Green if it means future development will be sterilised. In this regard, our client is promoting a sustainable and logical site on the edge of the village. However, owing to the scale and proximity of Tudeley the Council has effectively and unjustly ruled out further growth of the village and has made no allowance for any growth within the plan period. In our view, this is wrong and the ability of an existing settlements to evolve and thrive should not be sacrificed just to facilitate a new garden village.

2.3.14 Furthermore, the NPPF (para 138) is clear that where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land.

2.3.15 Our client’s land is well served by a local village bus stop. Furthermore, it is situated in good proximity to a much wider range of opportunities situated in Paddock Wood. More compellingly, there are significant opportunities available to provide public access to the land and provide a meaningful contribution towards ecological and green infrastructure enhancements and provide public access.

[TWBC: to view map/plan please see page 7 of attached full response document submitted by DHA Planning].

2.3.16 On the basis of the above, we consider that there are sound planning policy grounds to a proportionate level of growth to Five Oak Green

2.4 Objection to the omission of SHELAA Site 29

Evidence

2.4.1 The SHELAA’s basis for rejecting the inclusion of site 29 is extremely limited, with the only justification being that ‘there is concern about landscape impact and the in principle Green Belt objection’.

2.4.2 However, the SHELAA is not a policy document and instead should be a ‘policy off’ technical assessment of site availability. For this reason, the site should be identified as being suitable, available and achievable given it is the control of a developer and has no overriding constraints. Furthermore, on the basis that TWBC’s SHELAA appears to only find sites suitable for development where they are then allocated, this means it is not a robust and reliable piece of evidence base upon which sound decisions can be reached.

2.4.3 The Council has accepted that the unmet housing need in the borough is sufficient to amount to exceptional circumstance to justify a review of Green Belt boundaries and this approach has been endorsed by the Court in the Hunston High Court judgement in St Albans where judge stated:

‘Having identified the full objectively assessed needs figure the decision maker must then consider the impact of the other policies set out in the NPPF. The Green Belt policy is not an outright prohibition on development in the Green Belt. Rather it is a prohibition on inappropriate development in the absence of very special circumstances. It is entirely circular to argue that there are no very special circumstances based on objectively assessed but unfulfilled need that can justify development in the Green Belt by reference to a figure that has been arrived at under a revoked policy which was arrived at taking account of the need to avoid development in the Green Belt.’

2.4.4 It should also be noted that neighbouring authorities such as Sevenoaks, Tonbridge and Malling and Tandridge are all instigating Green Belt release.

2.4.5 We are concerned with the Council’s approach to Green Belt release in a single location. In this respect, Calverton Parish Council v Nottingham City Council, Broxtowe Borough Council and Gedling Borough Council [2015] EWHC 1078 (Admin)) provides very clear guidelines for determining whether exceptional circumstances exist.

‘planning judgments involved in the ascertainment of exceptional circumstances in the context of both national policy and the positive obligation located in section 39(2) should, at least ideally, identify and then grapple with the following matters:

(i) the acuteness/intensity of the objectively assessed need (matters of degree may be important);

(ii) the inherent constraints on supply/availability of land prima facie suitable for sustainable development;

(iii) (on the facts of this case) the consequent difficulties in achieving sustainable development without impinging on the Green Belt;

(iv) the nature and extent of the harm to this Green Belt (or those parts of it which would be lost if the boundaries were reviewed); and

(v) the extent to which the consequent impacts on the purposes of the Green Belt may be ameliorated or reduced to the lowest reasonably practicable extent’.

2.4.6 Considering these parameters, the acuteness of the local housing need is clear. The Council’s housing need is more than double what has previously been required and urban sites have been depleted since the last wholescale review of the Green Belt boundaries.

2.4.7 As with the acuteness of need, the constraints of the borough are indisputable. There are a number of archaeological and heritage sites, including 45 Historic Parks and Gardens, 25 Conservation Areas and 11 Scheduled Ancient Monuments. In addition, there are approximately 3,000 Listed Buildings.

2.4.8 The landscape of the High Weald AONB contains numerous historic landscape features, including field patterns, settlements and ancient woodland, whilst the borough also hosts a number of, or is close to, areas of ecological importance. These include:

(1) Ancient Woodland (approximately 16% of the borough)

(2) Circa 60 Local Wildlife Sites (approximately 11% of the borough)

(3) Ten Sites of Special Scientific Interest (SSSI)

(4) Five Local Nature Reserves (including one Community Woodland)

(5) One Regionally Important Geological Site, at Scotney Castle Quarry.

(6) The nearby Ashdown Forest is a designated Special Area of Conservation (SAC) and Special Protection Area (SPA).

2.4.9 Although not an environmental constraint, the Metropolitan Green Belt covers 22% of Tunbridge Wells borough.

2.4.10 Given the above constraints, it is acknowledged that planning for housing requires the need to balance a number of core environmental and planning matters in order to reach a sensitive future development strategy.

2.4.11 In respect of the extent to which the consequent impacts on the purposes of the Green Belt may be ameliorated or reduced, this is to be judged on a site by site basis, but there is little doubt that there are far greater opportunities to mitigate impact by releasing small parcels of land compared with that of a strategic new village scale.

2.4.12 Taking the above into consideration, it is our view that the Calverton judgement sets out very clear parameters for assessing whether Exceptional Circumstances exist and that a sound case could be made for releasing our client’s land in line with NPPF guidance. Some growth for Five Oak Green should therefore be revisited and such allocations should not be rejected just to facilitate Tudeley.

3 Section 6: Development Management Policies

3.1.1 In addition to our comments on the strategy, we have reviewed the proposed replacement development management policies as set out in chapter 6 of the document.

3.1.2 In general terms, we would refer back to paragraph 15 of the NPPF that promotes succinct and up-to-date plans, which provide a positive vision. In contrast, the draft policies currently proposed are of such prescriptive detail that they are neither positively prepared nor flexible enough to allow for a range of different circumstances. Furthermore, many aspirations result in inevitable conflict. On this basis, we would recommend that the majority of proposed policies are simplified and where additional guidance is needed, this be included within secondary Supplementary Planning Documents.

3.1.3 Turning to detailed policies, there are a number of contradictory elements that need to be remedied before the plan proceeds to Regulation 19. For example, policy EN1 seeks to ensure development is consistent with the established character and surrounding form. However, policy EN4 places significant emphasis on measures to radically reduce greenhouse gas emissions. The provision of a step change towards more sustainable construction and climate change is, inevitably going to result in a need for a change in attitude towards design, material and construction. Accordingly, a cohesive policy approach is needed that allows innovative and different design if supported on wider environmental and planning grounds. As drafted the policies are too inconsistent.

3.1.4 A number of policies also seek to provide guidance rather than policy. For example, policy EN6 seeks to clarify what information is needed in order to assess a heritage proposal. This level of information should instead feature within a support SPD not policy.

3.1.5 In respect of the natural environment, policy EN20 seeks to protect the rural landscape. It states that development will be required to:

‘1. Conserve and enhance the unique and diverse variety and juxtaposition of the borough’s landscape and the special features that contribute positively to the local sense of place; and

2. Not cause significant harm to the landscape setting of settlements, including historic farmsteads and hamlets; and

3. Not result in unsympathetic change to the character of a rural lane, which is of landscape, amenity, nature conservation, or historic or archaeological importance; and

4. Restore landscape character where it has been eroded; and

5. Preserve intrinsically dark landscapes in accordance with Policy EN 10: Outdoor Lighting and Dark Skies’.

3.1.6 We support the principle of the policy but consider amendments are needed to ensure that it does not result in a blanket reason to refusal otherwise sustainable greenfield development. We suggest it be amended to read:

‘1. Conserve and enhance the unique and diverse variety and juxtaposition of the borough’s landscape and the special features that contribute positively to the local sense of place; and

2. Not cause Include appropriate mitigation to ensure against significant harm to the landscape setting of settlements, including historic farmsteads and hamlets; and

3. Not result in unsympathetic change to the character of a rural lane, which is of landscape, amenity, nature conservation, or historic or archaeological importance; and

4. Restore Enhance landscape character where it has been eroded; and

5. Preserve intrinsically dark landscapes in accordance with Policy EN 10: Outdoor Lighting and Dark Skies’.

3.1.7 Turning to housing policies, we have significant concerns about the drafting of several policies, that show a degree of misunderstanding of the development industry. For example, policy H1 states:

‘Unless there are exceptional circumstances due to specific site or development constraints, a condition will be attached to any grant of planning permission for new major residential development (including change of use) requiring one or the other of the following conditions:

1. That the permission be implemented within two years from the date of decision; or
2. That groundworks and the construction of the ground floor base of at least two buildings be completed within three years of the permission’.

3.1.8 Whilst the majority of developers would aspire to be ‘on site’ and under construction within 2 years, the reality is that there are often processes that need to be adhered to that are outside of the applicant’s control, including the need to formally conclude land purchases, to discharge conditions and to deliver off site mitigation. There are also ‘non planning’ consents that need to be achieved for example Section 278 Highway works, infrastructure agreements (S38 of the Water Industry Act), ecology licensing etc

3.1.9 The Council will also be aware that commencement of development is often prohibited by seasonal restrictions in respect of ecology and wider constraints.

3.1.10 The second requirement for two buildings to be commenced is arbitrary, for example what is the test for single unit schemes or conversion works? The correct test should be as set out in statute i.e. ‘a material start’.

3.1.11 With the above in mind, we consider the Council’s policy should be deleted or modified to the extent that it will endeavour to agree a two year start date based on site circumstances.

3.1.12 In respect of policy H2, and the preference for Multi-developer schemes and comprehensive masterplanning, we understand the aspiration. However, in reality such stringent requests often result in conflict and further delay and the Council should be careful not to try and impose itself on wider commercial arrangements that may prohibit rather than assist delivery. With this in mind, it is our view that the Council should shift focus away from how it wishes to change development industry practices and instead concentrate on what it can influence, namely the provision of detailed guidance for the proposed site allocations (including potential phasing plans and areas zoned for different forms of development). The Council could also consider imposing a illustrative delivery trajectory as part of the validation process.

3.1.13 We note that policies H3 and H4 have regard to housing mix and density yet provide little or no detailed requirement. On the basis that mixes must reflect market requirements, we consider any aspirational densities would be better placed being inserted into the wider reaching policy EN1.

3.1.14 Policy H5 sets out affordable housing requirements. Whilst we support the general thrust of the objectives and the securing of affordable provision, we object to the rounding up of the calculations and contributions being based on a net rather than gross number of units. For small scale proposals this will often see the proposed percentage increase to closer to 45% and 35% respectively. Such thresholds would therefore need to be tested and justified by evidence. A pragmatic approach would be to apply traditional rounding up or down.

3.1.15 The phasing of affordable provision also needs to be sufficiently flexible so as to not prohibit wider delivery. In this regard, we consider that entering into contract with a registered affordable prior ahead of the 50% occupation should provide the certainty of delivery, but without risking a wider delay in market delivery.

3.1.16 We also object to the expectation of sites that provide between one and nine units to pay a contribution towards affordable housing. This conflicts with Paragraph: 023 Reference ID: 23b-023-20190901 of National Planning Practice Guidance, which states planning obligations for affordable housing should only be sought for residential developments that are major developments. Any reduced threshold should be restricted to designated areas only and should be underpinned by detailed evidence.

3.1.17 The Council will be aware of wider country wide discussions regarding the viability of providing social rented accommodation as part of a wider offer. Such provision is becoming increasingly difficult and without robust policy in place that addresses this matter, this matter is likely to significantly slow delivery.

3.1.18 We note that the Council is only willing to allow the use of Vacant Building Credits in exceptional circumstances. However, the test proposed appear significantly more onerous than have been considered and applied elsewhere. Based on the tests proposed, we fear that there will be a delay in genuinely vacant buildings, that are entitled to use of VBC, to be delayed in coming forward in order to meet the overly onerous criteria.

3.1.19 Paragraph 6.160 states:

“…The Council will assume a buffer of 25m from the edge of [ancient] woodland expecting through assessment for developers to confirm that this or any other distance is appropriate and that the priority for such buffers will be ecological mitigation and enhancement for the woodland rather than the amenity of the proposed development.”

3.1.20 The advice from the Government’s statutory advisor on biodiversity, Natural England, states that:

“For ancient woodlands, you should have a buffer zone of at least 15 metres to avoid root damage. Where assessment shows other impacts are likely to extend beyond this distance, you’re likely to need a larger buffer zone.” [1] https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences

3.1.21 Whilst it is recognised that every case will need to be treated on its merits, the Council has provided no justification for imposing a new starting point of 25m, which is nearly double the standard minimum requirement set out by Natural England. This increased buffer zone does not appear to have been based on any evidence. It will simply reduce the quantum of development that can be achieved on many sites, which will in turn increases the risk that additional land is likely to be required elsewhere to meet development needs. We object to this proposed buffer, and request that the standard accepted minimum distance of 15m should be stated instead.

3.1.22 In summary, whilst this overview is not exhaustive, we do have concerns about the nature of the proposed policy framework and the degree to which it appears to be trying to limit and frustrate development. Accordingly, in the interests of positive planning, we recommend that the policy framework is simplified and refined and subject to further detailed consultation and focussed on planning matters.

4 Conclusion

4.1.1 This representation has been prepared on behalf of Mr Mark Cubbon and Billings Group in response to the Tunbridge Wells Borough Council Draft Local Plan Consultation. The purpose being to provide comment on the Council’s proposed development strategy.

4.1.2 In this respect, we support the aspiration to meet housing need in full and consider that a dispersed growth strategy represents the optimum means to achieve this. Nonetheless, we object to the exclusion of our client’s land at Five Oak Green purely to facilitate development at Tudeley.

4.1.3 Furthermore, we consider that the Local Plan strategy relies heavily on the delivery of strategic sites that would require the provision of supporting infrastructure. Moreover, the Council have applied overly optimistic projections to the delivery of housing for the extension of Paddock Wood and the Tudeley Garden Village, largely disregarding the NLP 2016 report and the time it would take to masterplan the strategic sites and deliver the required infrastructure.

4.1.4 In our view, a more realistic trajectory would see some housing delivered, albeit not at the suggested build out rates and much later in the plan period. Further small to medium sites are therefore needed and they should be directed to locations such as Five Oak Green that have been afforded no growth.

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

TWBC: see full representation

DLP_7073

Sigma Planning Services for Rydon Homes Ltd

Site 329 School Field and

Site 331 Forstal Field, Finches Farm, Five Oak Green

50. Capel - sites:-

329 School Field, Finches Farm, Five Oak Green

331 Forstal Field, Finches Farm, Five Oak Green

These two fields adjoin each other and lie on the western outskirts of the village with Capel Primary School adjoining Site 329 to the west.

51. Both sites were considered as being "unsuitable" by the SHELAA assessment for the reason that there were heritage and landscape concerns with those sites which lie adjacent to historic farmsteads and form part of the landscape setting of the settlement. The sustainability assessment also refers to noise from the railway line and the current Green Belt designation on the sites.

52. Rydon hold an interest in these two fields and consider that they could be developed, either together or the eastern field (331) separately. The sites have a combined total area of 10172 ha (26.5 acres) with the eastern field being 3.39 ha (8.4 acres).

53. They have commissioned consultant reports in relation to:

Heritage

Landscape

Noise

Flood Risk

Highways

The reports demonstrate that there are no overriding constraints that would prevent the sites coming forward for housing development if carefully and sensitively designed. In particular, they demonstrate that the SHELAA and accompanying SA incorrectly scores the impact of development of this site due to the following conclusions:- 

• Noise Report - The whole site experiences noise levels below 50 db during the day and 45 db during the night and noise levels can be further mitigated through the provision of double glazing windows.
• Heritage Report - The proposed green buffer around the development will mitigate any impact on the adjoining heritage assets.
• Landscape - the site has moderate landscape sensitivity and there are opportunities to improve the urban rural edge through reinstating historic boundaries.
• Flood Risk - there have been no reported flooding incidents to property or roads within the close vicinity of the site in the past. The majority of the site lies primarily within a Zone 1 area denoting a very low risk of surface water flooding. There are some areas to the north of the site classified as Zone 2 and 3 but these can be left as open space with no built development and there is potential for flood compensation works.

54. Development at Five Oak Green should play a larger part in the Draft Plan strategy - particularly as an alternative to the Tudeley Garden community proposal which is fundamentally unsound and risks making the whole strategy unsound if it is carried forward into the Submission Plan.

55. Five Oak Green is a Group 3 settlement yet there are no housing or employment allocations at the settlement within the Local Plan. Development at Five Oak Green would provide a lesser scale but more realistic alternative to the Tudeley proposal that would fit well within the overall Boroughwide strategy and would more effectively utilise existing local infrastructure and services and also benefit from the major new transport infrastructure associated with the expansion of Paddock Wood but avoiding the costs, uncertainty and environmental damage of the by-pass link that is required to serve the Tudeley project.

56. Unlike Tudeley, which is an open countryside location with no critical mass of existing development, Five Oak Green has shops, employment, a primary school, recreational facilities and social/community structure. Most importantly it has an existing bus service that links to Tunbridge Wells and Maidstone. This nucleus of existing facilities and services provides a much stronger basis for the delivery of new housing with more certainty, less need for new infrastructure and more certain phasing.

57. There is an aggregation of potential sites around the village that can be brought together to provide a co-coordinated and holistic development of some scale and significance.

58. Alternatively the two sites at Finches Farm could deliver an individual development to contribute significant housing numbers, including affordable housing and make provision for the expansion of Capel Primary School and also lending support to the local flood mitigation proposals that are being progressed by the Environment Agency. This represents a valuable contribution to the Plan strategy, the delivery of housing and the maintenance of a five year housing land supply either as part of an alternative strategy or in addition to the housing allocations proposed, in order to strengthen the trajectory and to compensate for likely delays in very large sites coming forward. Rydon have commissioned Richards Urban Design to prepare a constraints plan and a concept masterplan and these form part of this representation.

59. The Green Belt study conclude that the site makes a weak or no contribution to urban sprawl of large built up areas, weak or no contribution to prevent neighbouring towns merging into one another, weak or no contribution to preserving and special character of historic towns and a moderate contribution to assisting in safeguarding the countryside from encroachment. The assessment concludes that the existing settlement edge is not distinctive and that there is not a clear transition between the built form and the wider countryside. It leads on to conclude that the field boundary within the site and the western parcel boundary of the site could potentially form strong Green Belt boundaries through strengthening with additional tree planting to form a well-integrated settlement edge. 

60. The SHELAA report fails to recognise the above, limiting the assessment conclusions to a negative score as the site is part of a Green Belt parcel, the release of which would cause moderate harm. This conclusions does not reflect the Council's own evidence base and fails to assess how development of this site could improve the existing boundary edge, a point to which weight should be afforded. 

[TWBC: See full representation]

DLP_7728

Nicholas Fisher

Site Number 440: The Old Vicarage, Five Oak Green road, Tudeley

There is no logical or coherent reason why this 3.5 acre/1.41 hectare site should not be allocated for development. It is large enough to provide a yield of over 10 dwellings and possibly in excess of 30(see the SHELAA referred to in the strategic assessment undertaken by TWBC). It has good access on two sides (east and north) of the plot direct onto the B2017 and new entry/exit road entrances could be made onto this site. For the plot to be not allocated appears to be in breach of TWBC methodologies, possibly because of TWBC’s reliance on the Tudeley garden settlement proposal.

Whether or not the proposal for the garden settlement at Tudeley is accepted in whole or part, the current draft transport infrastructure proposal suggests that a large roundabout will be constructed at the junction of Hartlake Road and Tudeley Road/Crockhurst Street which

is likely to require some land to be taken from plot 440. The B2017 may need widening as part of that proposal and this will impact plot 440.

Plot 440 falls on the perimeter of the AONB represented by the B2017. It adjoins the B2017 and is already impacted by traffic on the north and east boundaries of the plot that back onto the B2017. The views to open farmland and woods would be retained on the other two sides of the plot (west and south). The DLP provides for a strategy to use AONB land spread across a number of settlements. Whether or not the garden settlement at Tudeley is approved, housing could be provided in site 440; it would be perverse to permit an initial development of up to 2,800 houses on site CA1, part of which is immediately opposite plot 440 on the other side of the B2017 and to not permit development on plot 440. If the garden settlement were refused, then plot 440 is still viable for development. The current transport infrastructure assists without additional cost as the plot is adjacent to the bus stop in

Crockhurst Street opposite All Saints Church and opposite the bus stop at the Hartlake Road intersection. The plot boundary is next to the B2017 (see above). As is well known Tudeley is well placed for access to Tonbridge and the rail network, based on current road use. A permissive pathway exists that is accessed from the southern boundary of the plot and this leads to various footpaths and bridleways forming part of the High Weald network.

This site does not suffer from flooding and is within the existing urban settlement of Tudeley.

NOTE:

This comment relates to the “not allocated”: plot 440 of which I am joint owner. I object to the unsound concept of the Tudeley garden settlement (a proposed town not a village) and have made separate comments in relation to that. For the avoidance of doubt, my comments in this section/response are not to be taken or read as being supportive of the Tudeley garden settlement proposal; quite the oppositein fact. In relation to plot 440 the comments extrapolate what may be relevant points arising under the DLP.

DLP_8003

Alexa Fisher

440: The Old Vicarage, Five Oak Green road,Tudeley, Tonbridge, Kent

I live at The Old Vicarage, Tudeley Road, Tudeley, Kent TN11 0NS.  My husband and I are the joint owners of the Property. We responded to the Call for Sites but our plot 440 was not allocated. 

There is no logical or coherent reason why this 3.5 acre/1.41 hectare site should not be allocated for development. It is large enough to provide a yield of over 10 dwellings and possibly in excess of 30(see the SHELAA referred to in the strategic assessment undertaken by TWBC). It has good access on two sides (east and north) of the plot direct onto the B2017 and new entry/exit road entrances could be made onto this site. For the plot to be not allocated appears to be in breach of TWBC methodologies, possibly because of TWBC’s reliance on the Tudeley garden settlement proposal.

Whether or not the proposal for the garden settlement at Tudeley is accepted in whole or part, the current draft transport infrastructure proposal suggests that a large roundabout will be constructed at the junction of Hartlake Road and Tudeley Road/Crockhurst Street which

is likely to require some land to be taken from plot 440. The B2017 may need widening as part of that proposal and this will impact plot 440.

Plot 440 falls on the perimeter of the AONB represented by the B2017. It adjoins the B2017 and is already impacted by traffic on the north and east boundaries of the plot that back onto the B2017. The views to open farmland and woods would be retained on the other two sides of the plot (west and south). The DLP provides for a strategy to use AONB land spread across a number of settlements. Whether or not the garden settlement at Tudeley is approved, housing could be provided in site 440; it would be perverse to permit an initial development of up to 2,800 houses on site CA1, part of which is immediately opposite plot 440 on the other side of the B2017 and to not permit development on plot 440. If the garden settlement were refused, then plot 440 is still viable for development.

The current transport infrastructure assists without additional cost as the plot is adjacent to the bus stop in Crockhurst Street opposite All Saints Church and opposite the bus stop at the Hartlake Road intersection. The plot boundary is next to the B2017 (see above). As is

well known Tudeley is well placed for access to Tonbridge and the rail network, based on current road use. A permissive pathway exists that is accessed from the southern boundary of the plot and this leads to various footpaths and bridleways forming part of the High Weald network.

This site does not suffer from flooding and is within the existing urban settlement of Tudeley.

NOTE: This comment relates to the “not allocated”: plot 440 of which I am joint owner. I object to the unsound concept of the Tudeley garden settlement (a proposed town not a village) and have made separate comments in relation to that. For the avoidance of doubt, my comments in this section/response are not to be taken or read as being supportive of the Tudeley garden settlement proposal; quite the opposite in fact. In relation to plot 440 the comments extrapolate what may be relevant points arising under the DLP.

DLP_8228

Lichfields for U + I Group Plc

Site 62: Land to the south of Appletree and Devils Wood (north of North Farm Lane), Tunbridge Wells

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

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

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

Employment land

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

Housing land

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

Representations

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

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

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

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

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

Proposed amendment

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

Conclusion

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

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

[TWBC: for annex 1 see full representation].

[TWBC: this representation also entered under Policy AL/RTW 12 - see Comment No. DLP_8227].

DLP_974

Mrs A Marley

No. 92 Land South of Grove Cottage Tilsden Lane

No. 92 Land South of Grove Cottage Tilsden Lane

665-1331 houses Far too extenisve. No infrastructure no shops or facilities.

DLP_975

Mrs A Marley

No. 122 Gate Farmland and Charity Farm, Glassenbury RD.

No. 122 Gate Farmland and Charity Farm. Glassenbury Rd. 78 houses too extensive on good agricultural land and too far from local facilities & shops.

DLP_976

Mrs A Marley

No. 188 Land adjacent Hartley Dyke

No. 188 Land adjacent Hartley Dyke 227 houses too large & extensive in rural area.

DLP_977

Mrs A Marley

No. 325 Land adjacent to Colliers Green

No. 325 Land adjacent to Colliers Green up to 500 houses too rural. Lanes/Roads too narrow. No infrastructure shops facilities.

DLP_980

Mrs A Marley

Late Site 17 Tenterden Rd & Golford Rd

Late Site 17 Tenterden Rd & Golford Rd

356 houses

Too rural & isolated

No infrastructure.

DLP_981

Mrs A Marley

Late Site 22 Land East of Cranbrook & South of Sissinghurst

Site 22 Land East of Cranbrook & South of Sissinghurst

2000-3000 houses Too rural & isolated

No infrastructure.

DLP_2918

Victoria Groves

LS_37 (Glenn House, Hartley Road, Cranbrook) and LS_54 (Courtlands, Turnden Road, Cranbrook)

We object to the failure to allocate SHLAA sites LS_37 (Glenn House, Hartley Road, Cranbrook) and LS_54 (Courtlands, Turnden Road, Cranbrook).  It should be noted that whilst SHLAA site LS_54 is listed in Appendix 6 as a site not allocated in the Draft Local Plan, there is no corresponding SHELAA site assessment site in the SHELAA document. We are therefore unable to review the Council’s assessment of the site or appreciate the reasons why it was rejected.

These representations are made on behalf of the two landowners who wish to jointly promote their land through the Tunbridge Wells Draft Local Plan. A site location plan has been attached to these representations.

We consider that both sites together present a suitable and logical extension to Hartley and the reasons given for its rejection are unreasonable when compared against the draft allocations.

Suitability

Sustainable Location and Access

We agree with the Council that Hartley should be viewed as part of the wider settlement of Cranbrook as Hartley is located approximately 1km south west of Cranbrook.  There is existing pedestrian access via a continuous footpath along Hartley Road, as well as an hourly bus service providing access to Cranbrook and the wider area.  Cranbrook is one of the most sustainable villages within the district providing a full range of facilities and services which meet the day to day needs of its residents.

In the SHLAA assessment for Glenn House (SHLAA LS_37) the site was given a negative rating for accessibility and sustainability.  In terms of its access it was assumed that Turnden Lane would be used, which is a narrow rural lane with no existing pedestrian connection.  However Glenn House can provide access directly onto Hartley Road where there is an existing footpath.  Bus stops are located approximately 150m to the south providing hourly services to key settlements such as Cranbrook, Hawkhurst and Maidstone.  The existing bus service also provides increased services in the peak AM period to the mainline train station at Staplehurst.  There is also a shop and café located within 750m of the site selling fresh food and groceries.

It should be noted that the draft allocation AL/CRS6 is located a greater distance from Cranbrook and this is considered to be a sustainable location for development.

Landscape Impact

The site as a whole is bounded by existing development to the south and east as well as farm buildings to the north. The land has a mature hedgerow along its northern boundary which provides an effective screen from both the immediate and wider landscape.  The Landscape Sensitivity Assessment of Additional Settlements (July 2018) identifies the site to fall within landscape area CR9.  This assessment acknowledges the urbanising influence of the properties which bound the A229 and concludes that the area to the south of the ridge which runs along Turnden Lane, is less sensitive in this regard than the farmsteads at Goddards Green and Gate Farm.  The report concludes that views from the northern part of the character areas should be protected.  This development is located within the area considered to have less sensitivity to development than the draft allocation CRS6 and the existing mature hedgerow protects any views to the north.

Ecology

The SHLAA assessment for LS_37 indicated that other negative scores included the site’s proximity to Ancient Woodland to the north and location within the SSSI Impact Risk Zone.  At its closet point the site is located in excess of 80m from the Ancient Woodland. There is also physical separation created by the farmstead to the north and Turnden Lane.  We consider that this site can be developed without having any measurable impact on the Ancient Woodland. We also note that the proposed allocation AL/CRS6 is closer to Ancient Woodland and there is not the same level of physical separation.

With regard to potential ecological impacts, any planning application will be supported by an assessment of the habitats on site and the potential impact on nearby areas of interest. The site is largely pasture which has a low ecological value.  Habitats of elevated value within the site includes the hedgerow and tree belt along the northern boundary, this will be retained and enhanced where necessary.  The site is located some distance from the SSSI which is located to the south and we consider that there are no matters which cannot be suitably mitigated. It should be noted draft allocations CRS4 and CRS6 are also located within the buffer zone and in fact are closer to the SSSI.

Deliverability

We are promoting this site on behalf of the two landowners who wish to see this site brought forward for housing development.  For the reasons set out above we object to the Council’s assessment of the site.  We believe the site offers a suitable location adjacent to a very sustainable settlement and would be a logical extension to Hartley.  We have not identified any environmental or technical constraints which could not be appropriately mitigated. It is considered that this site should be included in the Council’s Local Plan as an allocation site for a residential led development.

TWBC: site location plan 1 and site location plan 2

DLP_4034

Brian Swann

Site No 92 - Land South of Grove Cottage Tilsden Lane

This is derelict farm land and could be used for building a estate of houses which would not be intrusive.

DLP_3695

Lynne Bancroft

LS-22 – Land to the East of Cranbrook and the south of Sissinghurst, Cranbrook

Site Number and Site Address: LS-22 – Land to the East of Cranbrook and the south of Sissinghurst, Cranbrook

I agree that this area of greenfield AONB land should not be included within the Local Plan and consider that it should never be considered for development. TWBC has quite rightly excluded it from any consideration for any development, due to importance and high sensitivity of the landscape of the area as has the Cranbrook and Sissinghurst Parish Council/neighbourhood development plan. This areas can be seen from miles away and Benenden and Cranbrook themselves can be seen from it so any development in these two areas also need sensitive consideration so it does not impact the views from this land.

None of the land is within the current Limits to Build, or adjacent to it, but is entirely within the AONB.

It has historic landscape features within the land in the High Weald, such as Chad Lake, a Roman road, and is of environmental importance due to its woodlands, adjacent priority habitat and the Crane river and valley. It is a key area for green tourism, between the historical Sissinghurst Castle Gardens and Cranbrook town and many local and other users walk this beautiful area on long distance trails such as The 1066, Harold’s Way and walks such as “Walks in Time” and Green Book walks. It is also adjacent to the historical Sissinghurst Court Gardens and Park.

It is not accessible for developments and there are no local facilities.

For these reasons there should be no development on this site.

DLP_4036

Brian Swann

Site 325 - Land adjacent to Colliers Green Primary School

This would provide for a large number of houses as suggested by the Cranbrook Parish N.D.P Steering Group.

DLP_4035

Brian Swann

Site No 155 - Park Farm, Goudhurst Rd

Please look at this again - it would not be intrusive and ideal for transport & cars to Tunbridge Wells and Staplehurst Railway Station.

DLP_4480

Patrick Booth-Clibborn

Local plan allocation Golford Road AL/CRS7 [TWBC: This is a proposed site allocation].

DLP_6072

Kember Loudon Williams for Cranbrook School

SHELAA Site 132 – Rammell Field, Bakers Cross, Cranbrook

See Attached 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 attached].

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 attached].

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_6142

Turley for Taylor Wimpey UK Ltd

Site 25: Land west of Frythe Way, Cranbrook

Thank you for the invitation to comment on the above consultation. We write on behalf of our client, Taylor Wimpey UK Ltd, who control land west of Frythe Way, which abuts the south eastern edge of Cranbrook (SHELAA Site Ref: 25, July 2019).

Whilst our client supports the need for and benefits of strategic growth at Cranbrook, they contend the Sustainability Appraisal (September 2019) and SHELAA (July 2019) that informed the Draft Local Plan contained site assessment errors and inconsistencies, which appear to have contributed significantly to this sites omission in favour of less sustainable and peripheral sites to the west and east of the settlement (Draft Allocations CRS6, CRS7 and CRS4).

For example, the conclusion of the SHELAA (July 2019) indicates that Site 25 may be unsuitable for housing, owing to a perceived ‘…concern about ability to provide an appropriate means of vehicular access to the site, which is likely to require access through adjacent site’. However, we can confirm that an ‘adjacent site‘ is not needed to form a suitable and appropriate means of access to this site. Taylor Wimpey is working with local housing association, Town & Country Housing (TCH) to deliver this site. TCH own the land and properties at the end of Frythe Way, from which access is proposed to be taken. We attach a letter from TCH confirming this forms part of the red line site submission and is readily deliverable without the need for an ‘adjacent site’ (See Document A).

This factual inaccuracy within the assessment of the site in both the SHELAA (July 2019) and Sustainability Assessment (September 2019) has in our view incorrectly underscored the accessibility credentials of this site. In doing so, our client contends the Council has incorrectly discounted this option in favour of less accessible peripheral options such as draft Local Plan allocation CRS6. Our client instructed consultant transport engineers i-transport to examine and conclude on this in further detail (see appended Document B). I-transport’s assessments conclude the site has been significantly underscored against the transport sustainability objectives of the Council’s Sustainability Assessment (SA). Our clients respectfully request therefore that the site be reassessed in light of these factual corrections.

The second stated ground for concluding that Site 25 is unsuitable for housing relates to a perceived negative impact on landscape from the loss of a greenfield site in the AoNB adjacent to this settlement. Yet a similar comment is absent in the SHELAA in respect of draft allocations CRS7, CRS4 or CRS 6; which are also in the AoNB, yet comprise lands we contend are far less contained and related to the settlement than Site 25. Site 25 is surrounded and contained by existing landscaping that is capable of being enhanced further; comprising a highly accessible location for a modest development of the scale proposed by our clients (around 70 homes). Our client instructed landscape consultants CSa to independently assess site 25 and compare this with draft allocation sites CRS6, CRS 4 and CRS7 (see Document C). The conclusions highlight landscape impacts in respect of CRS6, CRS4 and CRS7 that appear to have been understated and/or inconsistently assessed when compared with those arising from Site 25.

For example, draft allocation CRS7 is in the AoNB, detached from the urban area and is categorised in the Council’s own landscape assessment [1 Landscape Sensitivity Assessment of Additional Settlements in Tunbridge Wells (Paddock Wood, Horsmonden, Hawkhurst and Cranbrook), LUC, July 2018. ] as having a ‘strong separation from adjacent settlements’ and being ‘very sensitive to any strategic development’. The western half of Site CRS7 is also stated as playing ‘a significant role in the setting of the Cranbrook Conservation Area’. Yet, unlike the assessment undertaken on Site 25, the SHELAA seeks to assess different densities and forms of development that may be acceptable in this location. The SHELAA concludes that whilst the site is detached from the settlement, it lies in proximity to it, has pedestrian access to the centre of Cranbrook and is likely to be sustainable in this context. Site 25 is conversely attached / part of the settlement, contained by existing landscaping and has arguably better pedestrian access to the centre of Cranbrook. It is therefore unclear how the Council concludes that Site 25 is not sustainable in this context. Our client can only assume that the Council have not accounted for the evidence highlighted in this letter, including that now confirmed regards a suitable access and its landscape containment credentials. Our client contends that had such evidence been accounted for, the SHELAA and SA would have concluded that Site 25 was a logical, suitable and sustainable integrated extension to Cranbrook. One that has notable advantages over one or more of the alternatives proposed at CRS6, CRS7 and CRS4 and should be ranked sequentially higher on its sustainability credentials as a consequence.

In addition, Draft Local Plan allocations CRS4 and CRS6 seek to locate development to far more peripheral locations at and beyond the settlement edge. Options that taken together seem set to contribute to the sprawl of the settlement towards the south west into Hartley. Options that do little to neither respect each settlements identity, nor reduce the need to travel by car to local services and facilities, almost all of which are located in Cranbrook. Conversely, Taylor Wimpey’s Frythe Way proposal is better located and contained; and comprises a relatively modest development (around 70 homes) that respects the character and context of its location. Our client therefore respectfully requests that TWBC re-assesses the benefits of this modest site in liaison with the Parish Council and Neighbourhood Plan Steering Group as soon as possible.

Over the last year Taylor Wimpey have appointed a full consultant team to undertake a thorough assessment of the opportunities for and benefits of growth in Cranbrook; particularly in respect of lands under their control at Frythe Way (SHELAA Site Ref. 25). As part of their assessments of this opportunity, they have started to explore an early vision for what the neighbourhood and benefits accrued from this may look like. These benefits could include, amongst others:

• The delivery of much needed housing (around 70 homes), including affordable housing for local people in a highly accessible and well contained location;
• The creation of publicly accessible and diverse open spaces, footpaths and trails through the site and into existing public rights of way to and from the countryside;
• A new natural play space for children located close to existing homes;
• A trim trail for all ages to enjoy outdoor activities, providing an attractive gateway to access public rights of way and the countryside beyond;
• Edible landscapes for the benefit of the wider community (including native species planting within the scheme), providing a net potential gain over the existing provision, which is presently unmanaged, largely inaccessible and of poor quality;
• A comprehensive package of landscape and biodiversity enhancements in keeping with the characteristics of the surrounding area.

Our client is keen to share their emerging vision for the future of this site and attaches a copy for the Council’s consideration and information (See Document D). A copy has also been provided to representatives of the local Parish Council and Neighbourhood Plan Steering Group. We would welcome an opportunity to meet with TWBC, Members of the Parish Council and the Neighbourhood Plan Steering Group to discuss this further.

The land required to deliver the proposed development, its accompanying infrastructure and community benefits is in the control of Taylor Wimpey and Town & Country Housing. It is available for development now and is considered a suitable and logical location to direct some of the future growth needed at Cranbrook. The emerging vision document appended confirms there to be no known overriding constraints to the delivery of these proposals. We would be happy to meet the Council to discuss this opportunity further.

In the interim, the following comments are made to assist the Council’s progression of the Local Plan and the evidence base required to underpin this.

[TWBC: see Comment Numbers DLP_6144, 6146-6148, 6150-6161]

We trust these comments are useful and duly noted. We would welcome the opportunity to meet to discuss such matters further with Tunbridge Wells Borough Council, Cranbrook and Sissinghurst Parish Council and Neighbourhood Plan Steering Group over the coming months. 

[TWBC: see full representation and supporting document A, supporting document B , supporting document C, and supporting document D].

DLP_7673

Mr J Boxall

LS-22 – Land to the East of Cranbrook and the south of Sissinghurst, Cranbrook

I agree that this area of greenfield AONB land should not be included within the Local Plan and consider that it should never be considered for development.  TWBC has quite rightly excluded it from any consideration for any development, due to importance and high sensitivity of the landscape of the area as has the Cranbrook and Sissinghurst Parish Council/neighbourhood development plan.  This areas can be seen from miles away and Benenden and Cranbrook themselves can be seen from it so any development in these two areas also need sensitive consideration so it does not impact the views from this land.

None of the land is within the current Limits to Build, or adjacent to it, but is entirely within the AONB.

It has historic landscape features within the land in the High Weald, such as Chad Lake, a Roman road, and is of environmental importance due to its woodlands, adjacent priority habitat and the Crane river and valley.  It is a key area for green tourism, between the historical Sissinghurst Castle Gardens and Cranbrook town and many local and other users walk this beautiful area on long distance trails such as The 1066, Harold’s Way and walks such as “Walks in Time” and Green Book walks.  It is also adjacent to the historical Sissinghurst Court Gardens and Park.

It is not accessible for developments and there are no local facilities.

For these reasons there should be no development on this site.

DLP_2078

Canterbury Diocesan Board of Finance Ltd

CRANBROOK VICARAGE – The site was the subject of formal pre-application advice in 2015 which confirmed the acceptability of the principle of development. The Local Planning Authority then went on to allocate the site (AL/CR3) for housing development just 3 years ago in conformity with the National Planning Policy Framework presumption in favour of sustainable development. Since then comprehensive surveys commissioned by the owners have demonstrated that there are no physical constraints that would prevent development, thereby paving the way for an application for planning permission. There have been no material changes in the planning circumstances that would justify removal of the allocation.

DLP_987

Mr Mark Ellis

No1 Land at Brewer Street, Lamberhurst (former Abattoir Car Park)

Call for Sites - No1 Land at Brewer Street, Lamberhurst (former Abattoir Car Park)

This site should be considered for the following reasons:

It is central to the village, and not a virgin or greenfield site at the edge of the village unlike the other proposed sites. It has a similar status to the other sites in that it is in AONB and outside the limits to build, however unlike them it will not encroach of Scotney or Bayham, is not adjacent to a conservation area, listed buildings or adjacent woodland. Highways Dept have visited the site and there are no initial objections just recommendations which have been verbally agreed. There is also provision within the proposal to allow for 8 additional car parking spaces for Brewer Street residents to ease the on-pavement parking issues in the area. There are multiple site access options which Highways are also aware of. The land is comprised of hard standing material (former car park for 60 vehicles)  and shielded from the valley by mature trees and vegetation. Subject to Planning pledges to enhance the village have been proposed to the Parish Council incl a large donation for the local school.

DLP_8372

ASP Planning for Wellsbridge Estates Ltd

Site 1: Car Park for former Slaughterhouse, Brewer Street Lamberhurst and

Site 363: Land at 36 Brewer Street, Lamberhurst

Please see attached letter on behalf of our client Wellsbridge Estates Ltd.

DRAFT LOCAL PLAN (REGULATION 18) CONSULTATION

LAMBERHURST CAR PARK, BREWER STREET, LAMBERHURST, KENT

We write on behalf of our client Wellsbridge Estates Ltd who wish to make representations regarding the policy approach to Lamberhurst. We acknowledge that the Tunbridge Wells Draft Local Plan 2019 proposes to allocate between 50 - 60 houses in the village of Lamberhurst. In light of the proposed allocations we consider that as a matter of principle residential development in Lamberhurst is acceptable and that the settlement performs adequately in terms of sustainability. Within the context of this we would like to make representations on two sites identified in the draft local plan and an additional site we believe the council should consider for allocation. The sites are as follows:

• Misty Meadow, Furnace Lane
• Land to the West of Spray Hill
• Car Park for former Slaughterhouse, Brewer Street Lamberhurst and Land at 36 Brewer Street, Lamberhurst (see attached SHELAA assessment entries).

Misty Meadow, Furnace Lane

Following on from the SHELAA assessments the Draft Regulation 18 Local Plan has proposed in policy AL/LA 2 to allocate 25-30 residential dwellings on land known as Misty Meadow, Furnace Lane. Having reviewed the SHELAA entry for the land it is clear that there are several concerns regarding the allocation. Firstly, the land is distanced from the village development boundary by approximately 100 metres and as such is poorly integrated. Secondly, Furnace Lane is predominantly characterised by a ribbon form of residential development. As such the proposed allocation would result in backland development which would be contrary to policy and out of keeping with the surrounding residential character of the locality.

Irrespective of this fact the site has still been brought forward for allocation. Lastly, the SHELAA entry for the site notes that ‘parts of the site are sensitive in landscape terms.’ The site is very exposed and poorly contained in relation to adjacent residential development. In this regard it is considered that there are more appropriate alternative sites which would be more appropriate in Lamberhurst as will be detailed in subsequent paragraphs.

Land to the West of Spray Hill

It is acknowledged that the council proposes to allocate land to the west of Spray Hill for 25-30 residential dwellings within policy AL/LA1. We do not wish to contend this allocation and have no objection. It is clear that this allocation provides wider benefits to Lamberhurst including an extension to Lamberhurst Primary School and the intention to provide improved pedestrian and cycle linkages in the locality and in relation to the Scotney Castle Estate.

Car Park for former Slaughterhouse, Brewer Street Lamberhurst and Land at 36 Brewer Street, Lamberhurst.

The land known as ‘Car Park for former Slaughterhouse, Brewer Street’ and ‘Land at 36 Brewer Street, Lamberhurst’ has been assessed by the council as part of the Strategic Housing and Economic Land Availability Assessment (SHELAA) produced in conjunction with the Draft Regulation 18 Local Plan under two separate entries; references 1 and 363 respectively. After consideration the council concluded that both sites were ‘unsuitable as a potential site allocation’. It is our view that when viewed as one entity these sites represent an ideal allocation for residential development as will be explored in more detail below.

Briefly in regard to the specifics of the site. The sites accumulate to measure approximately 1.22 hectares and comprise a former car park previously used in association with a slaughterhouse. The site also contains a residential property and its curtilage. The site is adjoined by residential properties, allotments and fields. The boundaries of the site are a series of hedgerows. At present the area of land containing the former car park is accessed via a track which runs up to the southern boundary adjacent to the allotments. There also exists a vehicular driveway from Brewers Street which at present serves a single residential dwelling and its curtilage.

The SHELAA entries for the sites have expressed several concerns which have led to the council determining that the site is unsuitable for allocation. The entry for reference 1 states that ‘there is a landscape concern about the allocation of this site and concern about deliverability’. In relation to entry reference 363 the council considered that the ‘allocation of this site would result in unacceptable back land development’. Whilst these points have been acknowledged it is our view that if the sites are considered collectively as a single entry, as is proposed by our client that the issues raised can be overcome. In this respect we have the following comments:

• First, the SHELAA assessment noted that there were highway issues in relation to site reference 1. By considering sites referenced 1 and 363 together, an acceptable means of access can be achieved by using the access from Brewers Street associated with reference 363. It is considered that with improvements, this access is suitability located and capable of providing access to the site in its entirety. In terms of deliverability, it is considered that this access solution can provide the council with more certainty as it is within the ownership of 36 Brewers Street.
• Second, it is noted that the council reached the conclusion that the land at reference 363 would result in unacceptable backland development. By considering the two sites as a single entity, a more comprehensive and coordinated form of development can be achieved, such that the suggestion of backland development is no longer relevant.
• Third, a more coordinated development of the site will be in keeping with the character of residential development adjacent at Hopgarden Close. The location of the allotments will be a buffer from existing housing. In terms of the potential wider effect of the development the SHELAA assessment of site ref 1 mentions landscape concerns as a factor that contributes to the unacceptability of the site, such that it is unsuitable for allocation, although it remains unclear as to the how this conclusion has been drawn. The overall assessment of the potential for sites 1 and 363 to collectively accommodate 37 dwellings is potentially unhelpful in this respect; it is not clear how the council’s capacity analysis has been reached. A smaller development is entirely practicable, and would facilitate a less dense, more open form of development that would respect the location of the sites on the edge of the village. In our view this would produce a more appropriate form of development.
• Fourth, in locational terms it has been noted that the site ‘is let down by a lack of key services and options for public transport’. As expressed earlier it is considered that the council having proposed to allocate 50-60 houses in Lamberhurst have considered that as a matter of principle residential development in Lamberhurst is acceptable and performs adequately in terms of sustainability. It is therefore considered that this site is located adjacent to the development boundary for Lamberhurst and thus there is sufficient opportunity to access key services and facilities. It is also apparent from the manner in which the council has considered other allocations in Lamberhurst that the question of access to services and location of public transport has not been seen as a definition reason for not allocating land for development as is clear from the proposed allocation at Misty Meadow, Furnace Lane in which the SHELAA entry recognises that there would be ‘dependency on private car use’.

In light of the above the allocation of the land at site refs 1 and 363 should be obvious; it is a logical and acceptable location for additional small-scale development adjacent to the village boundary. The allocation should be made as a single entity. At present the absence of the allocation leads us to believe that the plan is not justified, in that it is not putting forward an appropriate strategy taking into account reasonable alternatives. As such, the plan at present cannot be considered to be robust nor reliable. This representation demonstrates that the council must reconsider that land at reference 1 and 363 as a single entity for allocation. The land represents an excellent opportunity and we consider that the site allocation be modified accordingly. It is clear that opportunity does exist here.

DLP_6804

Kember Loudon Williams for Wedgewood (New Homes) Ltd

Site 355: Land adjacent to Goudhurst Road, Horsmonden

This site should be removed from the Table at Appendix 6, reflecting the suggested change to include the site as a residential allocation for 35 housing units.

[TWBC: see Supporting Statement and Comment Numbers DLP_6793, 6797-6799, 6801, 6803-6804]

DLP_987

Mr Mark Ellis

No1 Land at Brewer Street, Lamberhurst (former Abattoir Car Park)

Call for Sites - No1 Land at Brewer Street, Lamberhurst (former Abattoir Car Park)

This site should be considered for the following reasons:

It is central to the village, and not a virgin or greenfield site at the edge of the village unlike the other proposed sites. It has a similar status to the other sites in that it is in AONB and outside the limits to build, however unlike them it will not encroach of Scotney or Bayham, is not adjacent to a conservation area, listed buildings or adjacent woodland. Highways Dept have visited the site and there are no initial objections just recommendations which have been verbally agreed. There is also provision within the proposal to allow for 8 additional car parking spaces for Brewer Street residents to ease the on-pavement parking issues in the area. There are multiple site access options which Highways are also aware of. The land is comprised of hard standing material (former car park for 60 vehicles)  and shielded from the valley by mature trees and vegetation. Subject to Planning pledges to enhance the village have been proposed to the Parish Council incl a large donation for the local school.

DLP_8372

ASP Planning for Wellsbridge Estates Ltd

Site 1: Car Park for former Slaughterhouse, Brewer Street Lamberhurst and

Site 363: Land at 36 Brewer Street, Lamberhurst

Please see attached letter on behalf of our client Wellsbridge Estates Ltd.

DRAFT LOCAL PLAN (REGULATION 18) CONSULTATION

LAMBERHURST CAR PARK, BREWER STREET, LAMBERHURST, KENT

We write on behalf of our client Wellsbridge Estates Ltd who wish to make representations regarding the policy approach to Lamberhurst. We acknowledge that the Tunbridge Wells Draft Local Plan 2019 proposes to allocate between 50 - 60 houses in the village of Lamberhurst. In light of the proposed allocations we consider that as a matter of principle residential development in Lamberhurst is acceptable and that the settlement performs adequately in terms of sustainability. Within the context of this we would like to make representations on two sites identified in the draft local plan and an additional site we believe the council should consider for allocation. The sites are as follows:

• Misty Meadow, Furnace Lane
• Land to the West of Spray Hill
• Car Park for former Slaughterhouse, Brewer Street Lamberhurst and Land at 36 Brewer Street, Lamberhurst (see attached SHELAA assessment entries).

Misty Meadow, Furnace Lane

Following on from the SHELAA assessments the Draft Regulation 18 Local Plan has proposed in policy AL/LA 2 to allocate 25-30 residential dwellings on land known as Misty Meadow, Furnace Lane. Having reviewed the SHELAA entry for the land it is clear that there are several concerns regarding the allocation. Firstly, the land is distanced from the village development boundary by approximately 100 metres and as such is poorly integrated. Secondly, Furnace Lane is predominantly characterised by a ribbon form of residential development. As such the proposed allocation would result in backland development which would be contrary to policy and out of keeping with the surrounding residential character of the locality.

Irrespective of this fact the site has still been brought forward for allocation. Lastly, the SHELAA entry for the site notes that ‘parts of the site are sensitive in landscape terms.’ The site is very exposed and poorly contained in relation to adjacent residential development. In this regard it is considered that there are more appropriate alternative sites which would be more appropriate in Lamberhurst as will be detailed in subsequent paragraphs.

Land to the West of Spray Hill

It is acknowledged that the council proposes to allocate land to the west of Spray Hill for 25-30 residential dwellings within policy AL/LA1. We do not wish to contend this allocation and have no objection. It is clear that this allocation provides wider benefits to Lamberhurst including an extension to Lamberhurst Primary School and the intention to provide improved pedestrian and cycle linkages in the locality and in relation to the Scotney Castle Estate.

Car Park for former Slaughterhouse, Brewer Street Lamberhurst and Land at 36 Brewer Street, Lamberhurst.

The land known as ‘Car Park for former Slaughterhouse, Brewer Street’ and ‘Land at 36 Brewer Street, Lamberhurst’ has been assessed by the council as part of the Strategic Housing and Economic Land Availability Assessment (SHELAA) produced in conjunction with the Draft Regulation 18 Local Plan under two separate entries; references 1 and 363 respectively. After consideration the council concluded that both sites were ‘unsuitable as a potential site allocation’. It is our view that when viewed as one entity these sites represent an ideal allocation for residential development as will be explored in more detail below.

Briefly in regard to the specifics of the site. The sites accumulate to measure approximately 1.22 hectares and comprise a former car park previously used in association with a slaughterhouse. The site also contains a residential property and its curtilage. The site is adjoined by residential properties, allotments and fields. The boundaries of the site are a series of hedgerows. At present the area of land containing the former car park is accessed via a track which runs up to the southern boundary adjacent to the allotments. There also exists a vehicular driveway from Brewers Street which at present serves a single residential dwelling and its curtilage.

The SHELAA entries for the sites have expressed several concerns which have led to the council determining that the site is unsuitable for allocation. The entry for reference 1 states that ‘there is a landscape concern about the allocation of this site and concern about deliverability’. In relation to entry reference 363 the council considered that the ‘allocation of this site would result in unacceptable back land development’. Whilst these points have been acknowledged it is our view that if the sites are considered collectively as a single entry, as is proposed by our client that the issues raised can be overcome. In this respect we have the following comments:

• First, the SHELAA assessment noted that there were highway issues in relation to site reference 1. By considering sites referenced 1 and 363 together, an acceptable means of access can be achieved by using the access from Brewers Street associated with reference 363. It is considered that with improvements, this access is suitability located and capable of providing access to the site in its entirety. In terms of deliverability, it is considered that this access solution can provide the council with more certainty as it is within the ownership of 36 Brewers Street.
• Second, it is noted that the council reached the conclusion that the land at reference 363 would result in unacceptable backland development. By considering the two sites as a single entity, a more comprehensive and coordinated form of development can be achieved, such that the suggestion of backland development is no longer relevant.
• Third, a more coordinated development of the site will be in keeping with the character of residential development adjacent at Hopgarden Close. The location of the allotments will be a buffer from existing housing. In terms of the potential wider effect of the development the SHELAA assessment of site ref 1 mentions landscape concerns as a factor that contributes to the unacceptability of the site, such that it is unsuitable for allocation, although it remains unclear as to the how this conclusion has been drawn. The overall assessment of the potential for sites 1 and 363 to collectively accommodate 37 dwellings is potentially unhelpful in this respect; it is not clear how the council’s capacity analysis has been reached. A smaller development is entirely practicable, and would facilitate a less dense, more open form of development that would respect the location of the sites on the edge of the village. In our view this would produce a more appropriate form of development.
• Fourth, in locational terms it has been noted that the site ‘is let down by a lack of key services and options for public transport’. As expressed earlier it is considered that the council having proposed to allocate 50-60 houses in Lamberhurst have considered that as a matter of principle residential development in Lamberhurst is acceptable and performs adequately in terms of sustainability. It is therefore considered that this site is located adjacent to the development boundary for Lamberhurst and thus there is sufficient opportunity to access key services and facilities. It is also apparent from the manner in which the council has considered other allocations in Lamberhurst that the question of access to services and location of public transport has not been seen as a definition reason for not allocating land for development as is clear from the proposed allocation at Misty Meadow, Furnace Lane in which the SHELAA entry recognises that there would be ‘dependency on private car use’.

In light of the above the allocation of the land at site refs 1 and 363 should be obvious; it is a logical and acceptable location for additional small-scale development adjacent to the village boundary. The allocation should be made as a single entity. At present the absence of the allocation leads us to believe that the plan is not justified, in that it is not putting forward an appropriate strategy taking into account reasonable alternatives. As such, the plan at present cannot be considered to be robust nor reliable. This representation demonstrates that the council must reconsider that land at reference 1 and 363 as a single entity for allocation. The land represents an excellent opportunity and we consider that the site allocation be modified accordingly. It is clear that opportunity does exist here.

DLP_528

Mr Neil Franklin

Various

28 Land at Woodside Road, Pembury TN2 4BG
64 Land at Woodside House, Woodside Road, Pembury TN2 4BG
187 Yew Tree Farm, Pembury Road, Pembury
190 Land south east of Sandhurst Avenue, Pembury
191 Land north of Henwoods Mount, Pembury
208 Romford House Farm, Kings Toll Road, Pembury, TN2 4BE
241 Land south of Sandhurst Avenue and east of Woodside Road, Pembury
282 Romford House Kings Toll Road, Pembury, Kent
290 Abbots, Woodside Close, Pembury, Kent
300 Marlborough Wood, Pembury, Tunbridge Wells, Kent
304 Land to the north east of Tonbridge Road, Pembury, Tunbridge Wells, Kent
332 Priory Farm, Romford Road, Pembury, Kent
336 Bentinck Farm, Romford Road, Pembury, Kent
354 Stone Court Farm, Stone Court Lane, Pembury, Kent
367 Land to the southwest of Woodside House, Woodside Road, Pembury, Kent
373 Land at Downingbury Farm, Pembury, Kent
420 Land at Downingbury Farm, Maidstone Road, Pembury, Kent
443 Land east of A228, Pembury, Tunbridge Wells, Kent
LS_58 Land adjacent to Hawkwell Business Centre, Colts Hill

I support your decisions in not adopting the sites you list in the Pembury area as potential sites for development.

DLP_2203

Mr Terry Cload

Site 354 Stone Court Farm Pembury

Site 354 Stone Court Farm Pembury

I strongly agree that Stone Court Farm Pembury Site 354 should not be included as a designated site in the New Local Plan.  It should remain totally within the MGB and outside of the LBD.  The site directly abuts the High Weald AONB. The soil is high grade agricultural 2.

In addition I support the designation of all of the Pembury sites that are not allocated in the Draft Local Plan. It is a great pity that there are not more of them as almost all of the allocated sites appear to be in the MGB and High Weald AONB and outside the current LBD.

DLP_2653

John Duffy

Site 354 Stone Court Farm,Pembury

Site Reference 354 Stone Court Farm, Pembury

(SUPPORT the decision to NOT ALLOCATE this site in the draft plan)

The authority granted Prior notice to build and Full permission for two former agricultural building adjoining this site, owned by the same developer. This despite numerous local objections from Parish, Borough and County Councillors and for which the application was called in. This site is a vital buffer and protecting barrier for the Green Belt around Pembury. The authority has in this plan accepted that the site 354 field to the rear of Herons Way is unsuitable for inclusion stating airquality, high harm to the Green Belt and notes it is adjacent to the ANOB.It also states that the disance to local facilities would a) require car usage and b) be not user friendly to those persons with mobility issues. The authority MUST ensure that it continues to decline this land for development and that of the adjacent Stone Court Farm, to revert on its decision that this land is unsuitable would cause further severe loss of confidence in the planning process. Pressure from developers and unwitting pre application advice is no excuse for the further destruction of the green belt in this site and the adjacent Stone Court Farm ANOB / MGB.

I object to any reconsideration for inclusion of this site to any amended draft plan. The site should NOT be considered for allocation

DLP_2797

Nicola Duffy

354 Stone Court Farm,Pembury

I wholly support the exclusion of this site from the draft local plan, it is an inappropriate and unsustainable location which impacts on the MGB and adjacent ANOB. TWBC should resolutely refuse any suggestion that this site be allowed, the impact of a planned 59 residential properties on an inaccesible narrow lane and their impact on the local services and infrastructure would be extremely damaging. TWBC will note the developer who submitted this plot also purchased the verges in the access road Stone Court Lane presumably to allow road widening and access through his neighnouring proeprty at Nursery Cottage, Stone Court Lane if the plot had been included in the development plan. This green area is a vital consitituent part of the Green Belt that protects the village and the adjacent ANOB of the iwder Stone Court Farm, at no time should there be a consideration of its destruction.

DLP_3117
DLP_3137

Andy Bashford
Teresa Stevens

28 - Land at Woodside Road, Pembury TN2 4BG

64 - Land at Woodside House, Woodside Road, Pembury TN2 4BG

191 - Land north of Henwoods Mount, Pembury

332 - Priory Farm, Romford Road, Pembury, Kent

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

Site Number and Site Address:

28 - Land at Woodside Road, Pembury TN2 4BG
64 - Land at Woodside House, Woodside Road, Pembury TN2 4BG
191 - Land north of Henwoods Mount, Pembury
332 - Priory Farm, Romford Road, Pembury, Kent

None of the above would be extending Pembury, unlike proposed sites PE1-PE3, therefore they would be more appropriate. “North of Henwoods Mount” is presumably a few houses along Woodside Road without a major site on the agricultural fields to the east of Woodside Road. How many homes could be built on each of these sites?

DLP_6262

Kember Loudon Williams for Mr R Barnes

Site 354 Stone Court Farm, Stone Court Lane, Pembury

The site assessment sheet provided in the Strategic Housing and Economic Land Availability Assessment (SHELAA) finds that the site is unsuitable for residential development. It suggests that there are highway constraints but is vague as to what these highway matters actually involve other than referring to the fact that there is a lack of pavement along Stone Court Lane. The sheet concludes by stating that “highway matters mean that any likely yield is likely to be of a scale that is not considered suitable for allocation”.

The Sustainability Assessment has also identified that Stone Court Lane is not “user friendly for those with mobility problems” and it would appear that negative scores have to given to the air quality, resources, services & facilities and travel objectives because of this lack of accessibility.

We do not agree that Site Number 354 (Stone Court Farm) should be considered unsuitable for residential development. The highway concerns identified in the SHELAA and in the Sustainability Assessment can be easily overcome, and a supporting Transport Statement including highway access has been specifically prepared to demonstrate this. With this supporting technical information, we urge the Council to update the SHELAA to recognise that the site is accessible and sustainable and, that as result, the site should be allocated for residential development in the emerging Local Plan.

Site Background

Planning consent (19/01696/FULL) and prior approval (19/01430/PNQCLA) have been recently obtained to convert the former fruit farm buildings into a total of 7 residential dwellings. This fact is not acknowledged in the site assessment sheet provided in the SHELAA.

Now that the above-mentioned consents are in the process of being implemented, there is no longer any reason to include the former fruit farm buildings as part of this site promotion exercise. Accordingly, we would like to submit a revised Site Plan which excludes the former fruit farm buildings. This Plan also excludes the adjacent existing semi-detached properties (Nos. 1 and 2 Stone Court Cottages). The revised site plan is provided below.

As a result of these changes, the site now comprises of one residential dwelling (Nursery Cottage) and the land previous associated with Stone Court Farm.

[TWBC: see full representation form for site plan].

The site is positioned on the southern side of Stone Court Lane of the eastern edge of Pembury. It adjoins the development boundary of Pembury and is well related to the village core area. The development strategy (STR1) has already located Pembury as being a sustainable location for new housing due to the range of services and facilities offered within the settlement. The subject site therefore offers an excellent opportunity for an extension to eastern area of Pembury.

Highway Improvements

The supporting Transport Statement (prepared by Inspire Transport Planning) demonstrates that several improvements to Stone Court Lane can be made to address any highway concerns. These improvements include the following:

• the provision of a continuous footway link along Stone Court Lane to connect with the site;
• an additional passing place on Stone Court Lane; and
• the provision of a new and improved access into the site (achieved by demolishing the existing Nursery Bungalow).

The proposed access arrangements have been shown in Appendix 1 of the Transport Statement (drawing number ITP 292 – 1- Rev P1). The arrangements are demonstrated to be safe and appropriate and conform with Kent County Council Guidance.

There are no ownership issues affecting the deliverability of the above-mentioned proposals. Other than highway authority land, the provision of the footpath and carriageway widening would not directly involve any other third-party land.

In assessing sites that may be allocated for development in plans, the NPPF states at Paragraph 108 that it should be ensured that:

a) appropriate opportunities to promote sustainable transport modes can be or have been – taken up, given the type of development and its location;

b) safe and suitable access to the site can be achieved for all users; and

c) any significant impact from the development on the transport network or on highway safety, can be cost effectively mitigated to an acceptable degree.

In this case, the proposed access arrangements and improvements to Stone Court Lane will promote sustainable modes of transport. The development would also have no significant adverse impact on highway safety or any adverse impact on vehicular traffic on the surrounding highway network. As such, there are no highway constraints that should restrict the development of this site and the SHELAA and Sustainability Assessment should be updated to reflect this position.

Sustainability Assessment

The NPPF states that in order for a plan to be found sound it must, inter alia, be justified. This means that Councils must take into account reasonable alternative sites based on proportional evidence. As a result of this requirement, the Council have undertaken a appraisal of the alternative sites in the Borough and Appendix Q of the Sustainability Assessment scores all the allocated sites and all the reasonably alternative sites in in Pembury Parish.

Now that it has been demonstrated that highway improvements can be made to Stone Court Lane, it is considered that a number of the negative scores that have been attributed to the site in Appendix Q (such as those relating to air quality objectives and travel objectives) can be changed to positive scores.

With a more positive score being achieved overall, the subject site will score higher than a number of the other competing sites (including those that have already been allocated for development).

Other Site Considerations

Landscape and Green Belt Designations

The subject site is in the Green Belt. Undoubtedly, any development will have an effect on the landscape but it is important to recognise that all the other sites in Pembury identified for development are also affected by this designation. Furthermore, the subject site is not located in the AONB, whereas some of the other sites that have been selected in Pembury are affected by this AONB designation.

The fact that the subject site is not located in the AONB is important. The development strategy (as outlined in Policy STR1) has been based around looking at maximising opportunities outside of the AONB in the first instance. It is crucial therefore that the subject site is reassessed given this background.

Paragraph 35 of the National Planning Policy Framework (NPPF) states that in order for a Local Plan to be found “sound”, the Plan must, inter alia, be justified. This means that all reasonable alternatives have to be considered. The subject site is considered a strong alternative option (scoring more highly against landscape sustainability objectives than other sites in Pembury) and as such should be allocated for development in the Local Plan.

Loss of Agricultural Land

Whilst the site has a Grade 2 (very good) Agricultural Land Classification, it is important to recognise that in reality there is no agricultural potential for the site. The land has not been farmed for many years and there are no longer any buildings to support an agricultural use. Due to the small size and the unsuitable nature of the site there is no prospect of the site being used for agriculture in the future.

Flood Risk

The site lies outside of any defined Flood Zone so it is not clear why it is stated on the Site Assessment SHELAA form that a part of the site in Flood Zone 2. Again, the form needs to be updated to reflect this.

In terms of other constraints, there are no other known heritage, environmental or ecological issues preventing the site coming forward for development.

Conclusion

Overall, it is considered that the subject site has been dismissed outright because of highway concerns. However, we have now provided technical evidence to demonstrate that with a new access arrangement and improvements to Stone Court Lane these highway concerns can be overcome. The development will be accessible to all and the revised arrangements are demonstrated to be safe and appropriate.

With the proposed highway improvements, the site is considered entirely suitable for development and the site should be reconsidered. The Sustainability Appraisal should be updated to reflect more positive scores and the SHELAA assessment should be updated. It would be unsound not to reconsider this site given the technical evidence provided and we respectfully urge the Council to give series consideration to these comments, to allocate the subject site and to amend the Draft Local Plan and supporting documents accordingly.

[TWBC: see also supporting document Transport Statement].

DLP_1904

Royal Tunbridge Wells Town Forum

Site 7 Montacute Gardens

Site Number and Site Address: Site 7 Montacute Gardens 

We support the conclusion that the site is presently unsuitable for development.

DLP_4295

Changing Cities for 42 Leisure PLC

Site 7 Montacute Gardens

42 Leisure object to the omission of Site ref: 7 Montacute Gardens from Table 4. The site is an allocated site in the adopted Development Plan (AL/RTW 4B) and should be included in the Draft Local Plan.

DLP_4297

Changing Cities for 42 Leisure PLC

Site 7 Montacute Gardens

42 Leisure objects strongly to the omission of land at Montacute Gardens (site ref 7) from the Draft Local Plan. The site is allocated for development as Site RTW 4B in the Tunbridge Wells Sites Allocation Local Plan adopted in July 2016. The SHEALA provides no justification as to why the site should now be excluded from the Local Plan.

Land at Montacute Gardens was identified by the Council alongside Union House (Site ref 265) and the surface car park at Montacute Gardens (Site ref 266) as part of the Eridge Road Area of Change in the Draft Tunbridge Wells Sites Allocation Document. Whilst it is acknowledged that the Union House site is now underdevelopment, the exclusion of the land and car park at Montacute Gardens has not been justified and runs counter to the objective of the Council to regenerate this part of the town centre through the promotion of mixed use development and new cultural and public spaces. The development of the Union House site will not deliver this objective on its own. The land at Montacute Gardens (including the surface car park) presents a unique opportunity to continue the regeneration of this part of the town centre. The area is underutilised and poorly integrated with the Pantiles and wider town centre and the car parking occupies a prime frontage and could be more appropriately located. The continued development of this area will act as a catalyst for the rejuvenation of the Pantiles and the wider town centre and help to ensure the future prosperity and vitality of the town.

Development and enhancement of the existing properties land at Montacute Gardens and the surface public car park are essential to realising the benefits for Royal Tunbridge Wells. This should be acknowledged in the new Local Plan which should adopt a vision for the Town centre and promote high quality development which is well integrated with the wider Area delivers a rich mix of uses, high quality design and attractive streets and public spaces which respect the character and heritage of Royal Tunbridge Wells.

We would therefore request that Sites ref 7 and 266 are included in the Draft Local Plan with an acknowledgement that development should be integrated with the Union House site (Site ref 265) in accordance with the vision, policies and development and design principles set out in the adopted Development Plan.

DLP_1905

Royal Tunbridge Wells Town Forum

Site 12 Tunbridge Wells West to Grove Junction

Site Number and Site Address: Site 12 Tunbridge Wells West to Grove Junction 

We support the conclusion that the site is unsuitable for development. It is vitally important to the long term strategic development of a sustainable transport policy for the Borough and for Royal Tunbridge Wells in particular, that the full double track alignment of the safeguarded railway route from Grove Junction to the West Station and onwards to Eridge should be protected, to allow for future restoration of public passenger rail services.

DLP_1906

Royal Tunbridge Wells Town Forum

Site 30 Caenwood/Whitgates Farm Reynolds Lane

Site Number and Site Address: Site 30 Caenwood/Whitgates Farm Reynolds Lane 

We support the conclusion that this Green Belt site is unsuitable for development. The site is of significant landscape value and acts as buffer to the adjacent AONB and the setting of the historic house and Park at Salomons. It also acts as the only remaining tract of open land preventing coalescence of RTW and Southborough and is part of a Local Wildlife Site. There are very significant highway issues with the AQMA in Southborough/Tunbridge Wells on the A26.

DLP_2435

Peter Avgherinos

Site 30 - Land at Caenwood Farm and Whitegates Farm, Reynolds Lane, Royal Tunbridge Wells

Site 100 - Land to the south of Speldhurst Road adjacent to Whitegate Close, Tunbridge Wells

COMMENTS ON UNALLOCATED SITES 30 and 100.

If either of these sites had been included in the selected sites, the effect on traffic along Reynolds Lane would be horrendous.  Traffic is already at or above its full capacity three times a day - the morning and evening rush hours, and the afternoon school run.

In part the existing capacity is determined by the lane itself, but also by the Speldhurst Road/London Road juction.  One important aid to flow along the lane at the junction with Speldhurst Road is the extra manoeuvring space provided by the entrance to Whitegate Close, with little current traffic in or out of the close. Any significant increase of traffic into the close would create a dangerous situation to add to the existing chaos.

DLP_2696

St John’s Road Residents Association

Site 30 - Land at Caenwood Farm and Whitegates Farm, Reynolds Lane, Royal Tunbridge Wells

Site 199 - Land and buildings at Smockham Farm, Reynolds Lane, Tunbridge Wells TN4 9XL

Site Ref.30 and 199

Caenwood Farm Whitegates Farm and Smockham Farm

While these sites have not come up for development we believe that it should not be considered by potential developers now or in the future for allocation.  We believe that the scale and impact would be high and would have a serious impact on the existing highway.  It is situated on farmland which provides a green buffer between the Royal Tunbridge Wells and Southborough connurbations.  By putting potentially large scale development on this sensitive green belt land would cause damage to the landscape character. Development would add hundreds of motor vehicles to an already overburdened A21 route which carries the bulk of traffic from the A21 motorway into the town centre.   We also need the land as a sustainable green space for plant and animal biodiversity.

Site is located fairly close to main road between two settlements which could be usefully preserved for walking and cycling routes. Appendix 2 to Policy EN17 Reynolds Lane is designated under AS_80 as local green space and this is adjacent to Caenwood Farm and Whitegates Farm and therefore should form part of the protected local green space.

DLP_2959

Peter Lidstone

Site 30 - Land at Caenwood Farm and Whitegates Farm, Reynolds Lane, Royal Tunbridge Wells

I would support the decision of the Council not to include the land at Caenwood Farm for development, due to the potential impact on traffic and congestion, and air pollution on the A26.

In addition, this would reduce the distinctiveness of Tunbridge Wells and Southborough as separate settlements.

DLP_4750

DHA Planning Ltd for Caenwood Estates and Dandara

Site 30 Caenwood/Whitgates Farm and Site 100 Land to the south of Speldhurst Road

1 Introduction

1.1 Purpose of this report

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

1.1.2 These representations relate to land at and adjacent to Caenwood Farm, Tunbridge Wells, which our client is promoting for residential-led mixed use development as part of the wider development plan review.

1.1.3 Based on the current national and local planning context, we consider this site to be suitable for development. Furthermore, the site is of a size and scale to play a role in accommodating the wider overspill of housing need from London and elsewhere within the South East of England.

1.1.4 This representation therefore responds to the content of the draft plan (and relevant supporting documents), reinforces why the site represents a suitable location to accommodate growth and outlines how development could be delivered on site.

2 Omission Site

2.1 Comments on Appendix 6: Submitted Sites not included in this Draft Local Plan

2.1.1 This section relates to the following sites which have not been included in the draft Local Plan:

• 30: Land at Caenwood Farm and Whitegates Farm (referred to in this document as “Caenwood Farm”; and
• 100: Land to the south of Speldhurst Road, adjacent to Whitegate Close (which adjoins Caenwood Farm and is referred to in this document as “the Dandara land”).

2.1.2 As discussed above, these sites have been considered together and so our comments below relate to both the above sites.

2.1.3 As set out below, these parcels can be developed in a sustainable manner, to provide up to 395 additional dwellings (on the basis of the smaller allocation) along with open space, and with the potential for further community facilities as required. We comment below on matters arising from various aspects of the evidence base, in relation to these parcels.

The Case for Development at Caenwood Farm and the Dandara Land

2.1.4 Caenwood Estates, as landowner, is promoting land at Caenwood Farm and Whitegates Farm on the western edge of Royal Tunbridge Wells, close to Southborough town centre, for a comprehensive, residential-led mix of uses. The site was promoted via the original call for sites process in 2016 (site reference 30) and in the 2017 Regulation 18 consultation.

2.1.5 Dandara is also promoting an adjacent parcel of land (site reference 100 in the Call for Sites) which fronts onto Speldhurst Road, to the west of Whitegates Close. This is shown edged blue in Figure 2.1.

2.1.6 Caenwood Estates and Dandara have agreed in principle to work together to promote the Caenwood Farm land as a whole, with both parties committed to finalising an agreement shortly. These representations therefore consider the planning merits of a master-planned approach to include both sites 30 and 100.

[TWBC: for Figure 2.1 see copy of full representation attached].

Natural extension to the urban area

2.1.7 The 150-acre Caenwood Farm site has been promoted as a natural extension of Tunbridge Wells for almost two decades. The 2009 SHLAA recognised that a substantial part of the site was suitable for development, with the remainder being excluded from further consideration only by virtue of the criteria applied at that time.

2.1.8 The case for allocating the site for development has been set out in detail in the previous submissions and so we will not repeat information unnecessarily here. In summary, unlike much other land locally the site is not in the Area of Outstanding Natural Beauty (AONB). 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, High Brooms station 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. The site currently comprises low quality (Grade 3 and 4) agricultural land, but also includes some existing residential and agricultural buildings and structures.

Site capacity

2.1.9 Initial studies have been carried out to demonstrate that a development of several hundred homes would be deliverable in the short term, without causing any demonstrable harm to the local highway network. It is likely that a greater quantum of development could be delivered with further mitigation in place. Opportunities also exist to substantially improve local road access to the site.

2.1.10 However, if the whole site was not required at this stage, the north-eastern area of Caenwood Farm, together with the whole of the Dandara land, would continue to make a very logical extension to the existing built-up area. This could deliver around 395 homes comprising:

• Around 360 homes on a 35 acre area of Caenwood Farm; and
• Around 35 homes on the Dandara land.

2.1.11 These figures are based on previous submissions to the Council, though it should be noted that as the two sites are to be combined, there may now be a case for the new access to the whole site through the Dandara land. A detailed study of access to a combined site has not yet been undertaken; however, if this is pursued it may affect the split of housing allocated to each of the sites.

Transport

2.1.12 The owners recognise that there is a perception of highway capacity issues locally and have undertaken surveys to provide evidence that the development can be accommodated. It is noted in this respect that Automatic Number Plate Recognition (ANPR) surveys carried out for Kent County Council (KCC) suggest that the majority of traffic travelling on the A26 at peak times is destined for, or originates from within, the Tunbridge Wells urban area.

2.1.13 However, the Caenwood Farm site is adjacent to the town’s best served public transport corridor linking Southborough with Tunbridge Wells and Tonbridge, with the nearest bus stop only 130 metres away. High Brooms railway station is only a short walk to the east and offers frequent services to London, Tonbridge, Tunbridge Wells and Hastings. School transport services are also already focused on this area.

2.1.14 The area has already benefited from highways improvements funded by the Local Growth Fund, the aim of which is to finance infrastructure works that would lead to further growth. The nearby A26 junction with Speldhurst Road and Yew Tree Road has recently been upgraded by KCC to cater for growth arising from the new Tunbridge Wells Local Plan. In order to get best value from these works, the Council should be investigating opportunities for growth in this area.

2.1.15 Furthermore, the recent dualling of the A21 between Tonbridge and Tunbridge Wells has reduced the pressure on the A26 London Road. The South East Local Enterprise Partnership has also contributed £1,039m to the recently-completed A26 Cycle Route Phase 1 scheme between Tunbridge Wells and Southborough, which has further enhanced sustainable transport options on this corridor.

2.1.16 When completed, the A26 scheme is expected to deliver significant improvements to cycle infrastructure along the length of the A26 between Grosvenor Road, Tunbridge Wells, and Brook Street, Tonbridge, a distance of 6.1km (3.8 miles).

2.1.17 There could also be opportunities to address existing issues of ‘rat-running’ and excess speed on Speldhurst Road, Reynolds Land and Kibbles Lane/Constitutional Hill Road as part of the redevelopment of Caenwood Farm.

Other public benefits

2.1.18 There would of course be scope for further public benefits to arise from any proposed development. The details would depend on the amount of land allocated for development and the overall quantum of housing proposed, but these could include:

• A substantial amount of affordable housing, in line with new Local Plan policies;
• a new public park (see below);
• such as the provision of play areas;
• a doctor’s surgery, and/or other similar amenities;
• new (or off-site enhancement of) primary and secondary schools;
• new places of work;
• allotments (to replace those being proposed by TWBC to be redeveloped for housing on site SO2);
• other appropriate leisure facilities;
• wildlife and ecology areas;
• the introduction of public access into the site, with the potential for a network of footpaths to link into existing connections towards St John’s, Culverden Park, Rusthall, Salomons Estate, Speldhurst and Southborough Common;

2.1.19 It should be noted that small developments would be unlikely to provide such facilities (rather than just provide a contribution) even though they would still have a cumulative impact on existing facilities, which is why it is important that larger sites are allocated for development as part of the mix.

2.1.20 As noted above, there is scope to deliver large areas of open space and formal recreation land, facilitate improvements to recreation facilities, provide for and manage habitat land (especially in the western part of the site which is wetter and less well suited to housing) and potentially SANG (if that is considered appropriate to help further protect Ashdown Forest SPA).

2.1.21 There is an exciting opportunity to open up public access to the site, making best of use of connections into the large network of public rights of way, especially to the south and west of the site, but also north towards Southborough Common. A new public park could be created along the valley floor, which could connect into these rights of way to encourage access into the site and form part of a network of routes through to the St Johns Recreation Ground and Culverden Down.

2.1.22 The Southborough Church of England Primary School recently received 162 applications for its 90 places for admission to reception – equivalent to 1.8 applicants per place. It is proposed that if the land is allocated, additional land could also be offered on the wider landholdings at Caenwood Farm to make provision for a new primary school to meet the needs of new and existing residents.

2.1.23 The proposed allocation would support the viability of the Southborough Hub and help sustain the local retail offering on Southborough High Street.

Constraints

2.1.24 Initial studies undertaken for Site 30 have also shown that, through good design and phasing, there are no in principle constraints to development on landscape, archaeology, flood risk, ecology, heritage or air quality grounds. Existing public rights of way would be retained; indeed public access to the site would be substantially improved as, with the exception of a public footpath in the north-eastern corner of the site, there is currently no public access to the majority of the site.

2.1.25 Similarly, Dandara have undertaken various studies for Site 100 which have concluded that this 1.05ha site could deliver around 35 dwellings taking into account landscape and ecology constraints.

2.1.26 Development would be well screened from and would not adversely affect the heritage assets at Salomons. The information submitted previously remains correct and we reaffirm that the site is suitable and available for early delivery in the Local Plan period.

2.1.27 Like all open land immediately adjacent to Tunbridge Wells, the site is located within the Metropolitan Green Belt where strict policies of restraint apply. The NPPF requires local planning authorities with land within the Green Belt to establish boundaries that are capable of enduring beyond the plan period that should only be altered in exceptional circumstances.

2.1.28 My clients are happy to undertake further environmental and other relevant survey work to support the proposed development.

Strategic development strategy

2.1.29 In this regard, the objectively assessed need for new homes undoubtedly represents the exceptional circumstances that warrants the release of Green Belt land for development. Most suitable, available brownfield sites have already been developed over the last few years. Accordingly, we consider there to be ample justification to extend appropriate settlements to ensure the delivery of adequate housing throughout the plan period.

2.1.30 However, the Council is seeking to place substantial reliance on two strategic developments in Tudeley and Paddock Wood, and we are concerned that the Council’s expectations for delivery are over-optimistic as discussed further in section 3.3 below.

2.1.31 When drawing up or reviewing settlement boundaries local planning authorities should take account of the need to promote sustainable patterns of development. Authorities must also take account of wider sustainability issues, for example the creating of attractive homes where people wish to live their lives and the need to deliver development that is in character with the established character of an area.

2.1.32 As discussed above, Tudeley is an isolated location within the Green Belt and we are concerned that the Council has not demonstrated compelling reasons for its release when there are better, more sustainably located sites such as Caenwood Farm available for development, the release of which would comply with NPPF paragraph 138.

Delivery of family and specialist housing

2.1.33 In this instance, the site is a suitable location for appropriate housing growth because it represents an opportunity to provide high-quality family housing in a way that would not present itself on smaller, brownfield or infill plots.

2.1.34 The latest housing statistics from KCC show that Tunbridge Wells has the highest level of one-bed flats of any district in Kent and the lowest proportion of three-bed family homes, yet family housing is in great demand locally. If allocated, the scheme that would be brought forward would seek to redress this imbalance in the borough’s housing mix.

2.1.35 Recently approved residential planning applications have been for a large number of flats, for example at Quarry Road, adjacent to Hilbert & Grosvenor Park; Union House; Belvedere by Altitude and on St Johns Road, reducing the housing choice for young families. However, Tunbridge Wells remains a popular place to live for families, attracted out of London (many of whom are returning to the area in which they grew up) and elsewhere in the South East by the excellent schools and lifestyle offered by the town.

2.1.36 Development of this land would result in the creation of new properties that have easy access to a range of job and leisure opportunities. Part of the site may also be appropriate for much needed specialist forms of housing, such as self-build and/or elderly care housing.

2.1.37 Affordable housing would also be provided in accordance with new Local Plan standards.

Deliverability

2.1.38 The site has no recent planning history of relevance (other than the 2009 SHLAA recognition that at least part of the site was suitable for development) nor a history of unimplemented permissions. No unexpected financial restrictions are anticipated that would impact upon the viability of a housing scheme or that would prohibit development coming through within the early stage of the plan period. Subject to the site’s removal from the Green Belt in the Local Plan, there is an excellent opportunity to deliver a high-quality residential development scheme in the short term.

2.1.39 Finally, the whole of Caenwood Farm is within the control of a single owner which will assist the ability to bring forward the site early in the plan period. Site 100 is being promoted by Dandara, who have an excellent track record of delivering high quality residential development in Tunbridge Wells and elsewhere. As discussed above, Caenwood Estates and Dandara have agreed to work together to develop both sites together.

Conclusion

2.1.40 Taking all of the above into consideration, together the points that follow in our representations on the rest of the plan, we consider a sound planning case exists to support the sensitive release of this site as part of the Local Plan strategy.

[TWBC: see full representation].

DLP_7972

Wendy Owen

Site 30 Caenwood/Whitgates Farm Reynolds Lane

30 Land at Caenwood Farm and Whitegates Farm, Reynolds Lane, Royal Tunbridge Wells

We wish to dispute the ‘unsuitable’ decision for this site because the sustainability scores are inconsistent. We consider this site is suitable for a school and/or housing development.

This site has also been inaccurately assessed, for example, it is listed as being in the High Weald AONB when it is not. As such the sustainability assessment is unsound.

DLP_1907

Royal Tunbridge Wells Town Forum

Site 39 Land adjoining Dunorlan Park

Site Number and Site Address: Site 39 Land adjoining Dunorlan Park 

We support the conclusion that this Green Belt site is unsuitable for development. In the 2015 Royal Tunbridge Wells Forum document “Developing our Green Network” we suggested that this parcel of land should be considered for incorporation in Dunorlan Park if the necessary funds could be raised.

DLP_1908

Royal Tunbridge Wells Town Forum

Site 61 Robin Gate Blackhurst Lane

Site Number and Site Address: Site 61 Robin Gate Blackhurst Lane 

We support the conclusion that this Green Belt site is unsuitable for development.

DLP_3552

Royal Tunbridge Wells Town Forum

Site 61 Robin Gate Blackhurst Lane

We support the conclusion that this Green Belt site is unsuitable for development

DLP_1909

Royal Tunbridge Wells Town Forum

73 Land South of Pembury Road

Site Number and Site Address: 73 Land South of Pembury Road 

We support the conclusion that the site is unsuitable for development. It lies in the AONB and the southern parts of the site would have a significant adverse landscape effect if developed. There are also highway issues.

DLP_7974

Wendy Owen

Site 73: Land at Pembury Road (south), Tunbridge Wells

73 Land at Pembury Road (south), Tunbridge Wells

We wish to challenge the ‘unsuitable’ decision for this site because the sustainability scores are inconsistent. We consider this site is suitable for a school and/or housing development.

This site has also been inaccurately assessed, for example, it is listed as being in the High Weald AONB when it is not. As such the sustainability assessment is unsound.

DLP_7975

Wendy Owen

Site 99: Land at Pembury Road, Tunbridge Wells TN2

99 Land at Pembury Road, Tunbridge Wells TN2

We wish to challenge the ‘unsuitable’ decision for this site because the sustainability scores are inconsistent. We consider this site is suitable for a school and/or housing development.

This site has also been inaccurately assessed, for example, it is listed as being in the High Weald AONB when it is not. As such the sustainability assessment is unsound.

DLP_1910

Royal Tunbridge Wells Town Forum

99 Land north of Pembury Road

Site Number and Site Address: 99 Land north of Pembury Road 

We support the conclusion that this Green Belt site is unsuitable for development. This site constitutes an important landscape approach when arriving in Royal Tunbridge Wells from Pembury Road. It is even more significant when leaving RTW as it clearly marks the point at which the settlement ends and prevents coalescence with Pembury.

DLP_1911

Royal Tunbridge Wells Town Forum

100 Land adjacent to Whitegates Close

Site Number and Site Address: 100 Land adjacent to Whitegates Close 

We support the conclusion that this Green Belt site is unsuitable for development, notably on account of highway concerns and proximity to the AQMA.

DLP_359

Charlotte Raleigh

Site 114 - Land at Sandown Park, west of A21, Royal Tunbridge Wells TN2 4RT and

Site 411 - Land at Sandown Park between Pembury Grange and A21, Royal Tunbridge Wells, Kent

I think the site numbers are 114 and 411.

Land between Sandown Park, Pembury Rd and the A21 and the land either side of the north end of Sandown Park between Blackhurst Lane and A21.

I would like to strongly support that this land has not been included as sites for development in the Local Plan 2019.

DLP_1912

Royal Tunbridge Wells Town Forum

114 Land at Sandown Park

Site Number and Site Address: 114 Land at Sandown Park 

We support the conclusion that this Green Belt site is unsuitable for development, particularly the southern section, on landscape and highway concerns.

DLP_4429

Town and Country Planning Solutions for Gleeson Strategic Land

Site 114 Land at Sandown Park, west of A21, Royal Tunbridge Wells TN2 4RT

Appendix 6: Submitted sites not included in the Draft Local Plan 

SHELAA – site 99 Limits to Built Development Topic Paper

and Royal Tunbridge Wells and Southborough Draft Policies – Inset Map 2

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.

4. In April 2017, the Council published a SHELAA as a ‘Draft Interim Report’ with the land at Sandown Park being identified as site no. 99 (see Appendix 2 attached). The site assessment not only noted the site as being ‘’enclosed’ and ‘well screened’, but also noted its various sustainability credentials in relation to its proximity to local schools, the food store Tesco at Pembury to the east as well as local bus services and the National Cycle Route 18 adjacent to the site. This assessment made no mention (and presumably therefore, raised no significance) to the site being adjacent to the HWAONB boundary on the opposite side of Pembury Road to the south.

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.

6. On 10th May 2019 (Appendix 5), Gleeson responded to the matters raised by the Council in its pre-application advice dated 9th May 2018. This was accompanied by four additional supporting / amending documents (together with a consultation response from the Highway Authority that was dated 5th February 2019) to provide a revised Illustrative Layout Plan and a revised Access Drawing no. ITB12398-GA-005. In order to ensure that these supporting documents and illustrative drawings are considered by the Council as part of the Plan’s next Regulation 19 stage, they have been resubmitted again with these current representations and now form Appendices 6 – 12 attached.

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”.

9. The Council’s latest assessment states that “Negative scores are given for air, climate change, heritage land use, landscape and noise” and that “high harm” would be caused if the land were to be released from the Green Belt and there are also “highway concerns”.

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.

i) ‘Air score and climate change score’

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.

List of Appendices

1. Tunbridge Wells Borough Council Local Plan – Site Allocations Development Plan Document; Site Templates Green Belt and Rural Fringe Supporting Information – February 2015

Site 291; Land at Sandown Park.

2. Tunbridge Wells Borough Local Plan – Strategic Housing and Economic Land Availability Assessment; Draft Interim Report April 2017

Site 99; Land at Sandown Park.

3. Pre-Application Advice request (letter dated 2nd March 2018).

4. Tunbridge Wells Borough Council response to Pre-Application Advice request (letter dated 9th May 2018).

5. Response relating to matters arising following Tunbridge Wells Borough Council’s response (letter dated 10th May 2019).

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_5999

Pro Vision for Cooper Estates Strategic Land

Site 114 Land at Sandown Park, west of A21, Royal Tunbridge Wells TN2 4RT

Site Number and Site Address: 114: Land at Sandown Park, west of A21, Royal Tunbridge Wells, TN2 4RT

This site should be proposed to be allocated for C2 development to help towards meeting the need and requirement for C2 development as set out in the Council’s evidence base; and as should also be specifically reflected in the draft Local Plan by a clear and separate C2 housing need/requirement. The site is in the Green Belt (but not in the AONB) and removal of this land would otherwise be consistent with and enabled by draft Local Plan Policy STR 4.

CESL has promoted the allocation of this land through the ‘call for sites’ for a C2 older persons housing retirement village/community care home development. The site is sustainably located next to the northeast edge of the existing built-up area Royal Tunbridge Wells and within the visual and physical limitations of the A21 road to the east which provides a clear and logical boundary to the expansion of the town at this point. There are no overriding and/or serious adverse impacts that would be caused by development in the manner proposed. This is explained further in the separate submissions by Pro Vision on behalf of CESL to the Council’s first Call for Sites (2016) and the second Call for Sites (2017) as well as the Issues and Options 2017 which also include why the site is suitable for C2 development and is deliverable.

DLP_7976

Wendy Owen

Site 114: Land at Sandown Park, west of A21, Royal Tunbridge Wells TN2 4RT

114 Land at Sandown Park, west of A21, Royal Tunbridge Wells TN2 4RT

We wish to challenge the ‘unsuitable’ decision for this site because the sustainability scores are inconsistent. We consider this site is suitable for a school and/or housing development.

This site has also been inaccurately assessed, for example, it is listed as being in the High Weald AONB when it is not. As such the sustainability assessment is unsound.

DLP_7977

Wendy Owen

site 116: Land south of Pembury Road, Tunbridge Wells

116 Land south of Pembury Road, Tunbridge Wells

We wish to challenge the ‘unsuitable’ decision for this site because the sustainability scores are inconsistent. We consider this site is suitable for a school and/or housing development.

This site has also been inaccurately assessed, for example, it is listed as being in the High Weald AONB when it is not. As such the sustainability assessment is unsound.

DLP_1913

Royal Tunbridge Wells Town Forum

116 Land south of Pembury Road

Site Number and Site Address: 116 Land south of Pembury Road 

We support the conclusion that the site is unsuitable for development. It lies in the AONB and the southern parts of the site would have an adverse landscape effect if developed. There are also highway issues.

DLP_7716

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

Site 145: WA Turner Factory Site, Broadwater Lane, Tunbridge Wells TN2 5RD

This is an objection to the omission of site reference number 145 ‘WA Turner Factory Site, Broadwater Lane, Tunbridge Wells TN2 5RD’ from the draft Local Plan. We request this site is reinstated as an allocated site under Policy AL/RTW 20. As required under Appendix 6 (p.533), please find below reference to the Sustainable Appraisal and relevant SHELAA site assessment sheet.

Sustainability Appraisal – Table 20 of the Sustainability Appraisal (SA) -List of reasonable alternative sites in Royal Tunbridge Wells, records the subject site Ref. 145 as ‘Not allocated’. The scores for Site Ref. 145 is contained at Appendix E, p.167 of the SA.

It is submitted that the Sustainability Appraisal undertaken for site Ref. 145 is flawed. The commentary provided at Appendix E of the Sustainability Appraisal document states “Business Growth score is influenced by uncertainty over existing jobs on the site and the risk to these”. This factory is nearing the end of its life and it is not viable to refurbish the factory in order for it to meet modern manufacturing requirements. This site will not be a future employment generator. A submission was made in November 2013 as part of the review of the Strategic Housing Land Availability Assessment and the site is included in the Site Allocations Local Plan 2016 (Policy AL/RTW 13). This position was reaffirmed in 2016 when it was submitted in the Call for Sites.

DLP_7970

Wendy Owen

Site 146: Tunbridge Wells Golf Club, Langton Road, Tunbridge Wells TN4 8XH

146 Tunbridge Wells Golf Club, Langton Road, Tunbridge Wells TN4 8XH 

We wish to challenge the ‘unsuitable’ decision for this site because the sustainability scores are inconsistent. We consider this site is suitable for a school and/or housing development. 

This site has also been inaccurately assessed, for example, it is listed as being in the High Weald AONB when it is not. As such the sustainability assessment is unsound. 

In addition, we consider the Green Belt assessment of this site is incorrect. The score of “Strong” contribution to “preserving the special character of historic towns” is too high given the land is not visually prominent and is only adjacent to the common. The score should therefore be adjusted to “relatively strong”.

DLP_1914

Royal Tunbridge Wells Town Forum

165 Pantiles Car Park

Site Number and Site Address: 165 Pantiles Car Park 

We support the conclusion that the site is unsuitable for development. It would be inappropriate to allow any built development on a site which is an integral part of Tunbridge Wells Common in a particularly sensitive location and important to the semi-rural setting of Royal Tunbridge Wells. Tunbridge Wells Common is a Local Wildlife Site and also an important place for green recreation.

DLP_1915

Royal Tunbridge Wells Town Forum

199 Land at Smockham Farm

Site Number and Site Address: 199 Land at Smockham Farm 

We support the conclusion that this Green Belt site is unsuitable for development. The site is centred around a characteristic Wealden Farmstead of considerable antiquity and crossed by a non-designated heritage asset in the form of an ancient routeway which provides a recreational footpath linking the St John’s area of RTW with the Woodland Trust owned Hurst Wood, Rusthall and Speldhurst.

Within the Farmstead is another non-designated heritage asset, a 19th century  steam powered pumping station and underground reservoir for supplying water to the former Kelsey Brewery on St John’s Road. There are mediaeval assart fields and the whole site forms an important part of the setting of Royal Tunbridge Wells. It is close to Local Wildlife Site TW46 and Sites of Local Nature Conservation Value ID 08 and ID13 and development would be prejudicial to these sites.

DLP_1916

Royal Tunbridge Wells Town Forum

205 Land at Little Knoll Reynolds Lane

Site Number and Site Address: 205 Land at Little Knoll Reynolds Lane 

We support the conclusion that this site is unsuitable for development for landscape, highway and ecological reasons as part of a wider landscape in a Green Belt area which prevents coalescence of RTW and Southborough. It is close to Local Wildlife Site TW46 and Sites of Local Nature Conservation Value ID 08 and ID13  and development would be prejudicial to these sites

DLP_1917

Royal Tunbridge Wells Town Forum

226 St Marks Recreation Ground Frant Road

Site Number and Site Address: 226 St Marks Recreation Ground Frant Road 

We support the conclusion that the site is unsuitable for development as it would result in the loss of a useful sports facility and because it sits on a landscape edge of RTW.

DLP_1918

Royal Tunbridge Wells Town Forum

258 TN2 Community Centre

Site Number and Site Address: 258  TN2 Community Centre 

We support the conclusion that the site is unsuitable for development. It should be retained as a community centre and maintained as such in the event that further plans may materialise in the future.

DLP_1919

Royal Tunbridge Wells Town Forum

280 Land at Midway Nevill Court

Site Number and Site Address: 280 Land at Midway Nevill Court 

We support the conclusion that the site is unsuitable for development. It is Green Belt land and adjoins open countryside to the south west and to the east the iconic Arcadian parks and semi-rural setting of Hungershall Park and Nevill Park and to the west the 20th century parkland development of Nevill Court, which together form one of the jewels in the crown of Royal Tunbridge Wells’ parkland developments. All would be adversely affected by any further development in the area.

DLP_7978

Wendy Owen

Site 280: Land at The Midway, Nevill Court, Tunbridge Wells, Kent

280 Land at The Midway, Nevill Court, Tunbridge Wells, Kent

We wish to challenge why this site was omitted from the sustainability appraisal – the purpose of the appraisal process is to fully consider the positives and negatives, in a structured and documented way. This site appears to have been rejected because it is “within the AONB and landscape impacts were considered too severe to warrant consideration”. Other sites within the AONB with equally adverse landscape impacts have been taken forward and without a full suite of sustainability assessments it is not possible to make properly evidenced based policy. As such this omission renders the sustainability appraisal unsound as a whole.

This site has also been inaccurately assessed, for example, it is listed as being in the High Weald AONB when it is not.

DLP_1920

Royal Tunbridge Wells Town Forum

328 Land at Eridge Road

Site Number and Site Address: 328 Land at Eridge Road 

We support the conclusion that the site is unsuitable for development and should be retained as an important open space for the Ramslye estate and as a landscape approach to the town centre.

DLP_1921

Royal Tunbridge Wells Town Forum

359 Land to east of Kingswood Road

Site Number and Site Address: 359 Land to east of Kingswood Road 

We support the conclusion that this Green Belt site is unsuitable for development being part of the setting to the adjoining Dunorlan Park.

DLP_1922

Royal Tunbridge Wells Town Forum

384 Land at Great Bayhall

Although the following sites are outside the unparished area of Royal Tunbridge Wells, we make the following commentary on the basis that these un-allocated sites are important to the setting of Royal Tunbridge Wells and/or also serve to prevent the coalescence of RTW with other settlements

Site Number and Site Address: 384 Land at Great Bayhall 

We support the conclusion that the site is unsuitable for development. This AONB open farmland forms part of an iconic vista to a rising undeveloped horizon when viewed from the historic Dunorlan Park and the contrast between the formal parkland and the unspoilt countryside beyond is one of the defining features of this significant edge of RTW.

It is also a significant landscape feature crossed by the High Weald Landscape Trail and Tunbridge Wells Circular walk and High Woods Rural Lane which are important to health, recreation and tourism in the town and the Borough as a whole. It is also a significant landscape feature visible from Cornford Lane, another Rural Lane, which has sweeping far reaching  views over this site  to horizons to the east  at Pembury and south west at Hawkenbury.

DLP_1926

Royal Tunbridge Wells Town Forum

384 Land between Cornford Lane & Pembury Bypass 

Site Number and Site Address: 384 Land between Cornford Lane & Pembury Bypass 

We support the conclusion that the site is unsuitable for development. This very large site is a visually prominent part of the AONB viewed from Cornford Lane and it marks the new boundary for Pembury formed by the A21 bypass, which was set into the landscape so as  to be invisible from Cornford Lane and other parts of the nearby AONB. It also maintains a completely rural feel to the landscape adjoining Royal Tunbridge Wells and is an important landscape feature.

DLP_7980

Wendy Owen

Site 384: Land at Great Bayhall, Tunbridge Wells, Kent

384 Land at Great Bayhall, Tunbridge Wells, Kent

We wish to challenge the ‘unsuitable’ decision for this site because the sustainability scores are inconsistent. We consider this site is suitable for a school and/or housing development.

This site has also been inaccurately assessed, for example, it is listed as being in the High Weald AONB when it is not. As such the sustainability assessment is unsound.

DLP_1923

Royal Tunbridge Wells Town Forum

400 Land to the east of Kingswood Road

Site Number and Site Address: 400 Land to the east of Kingswood Road 

We support the conclusion that this Green Belt site is unsuitable for development. In the 2015 Royal Tunbridge Wells Forum document “Developing our Green Network” we suggested that this parcel of land should be considered for incorporation in Dunorlan Park if the necessary funds could be raised.

DLP_7981

Wendy Owen

Site 411: Land at Sandown Park between Pembury Grange and A21, Royal Tunbridge Well

411 Land at Sandown Park between Pembury Grange and A21, Royal Tunbridge Wells, Kent

We wish to challenge the ‘unsuitable’ decision for this site because the sustainability scores are inconsistent. We consider this site is suitable for a school and/or housing development.

This site has also been inaccurately assessed, for example, it is listed as being in the High Weald AONB when it is not. As such the sustainability assessment is unsound.

DLP_1924

Royal Tunbridge Wells Town Forum

434 Tutty’s Farm Hawkenbury

Site Number and Site Address: 434 Tutty’s Farm Hawkenbury 

We support the conclusion that the site is unsuitable for development. This Green Belt site adjoining the AONB sits in the middle of a fine landscape closed to the south west by Benhall Wood and is very visible from Hawkenbury Road. No further development should be allowed to occur on this far side of Hawkenbury Road.

DLP_7982

Wendy Owen

Site 434: Tutty's Farm, Hawkenbury, Royal Tunbridge Wells

434 Tutty's Farm, Hawkenbury, Royal Tunbridge Wells, Kent

We wish to challenge the ‘unsuitable’ decision for this site because the sustainability scores are inconsistent. We consider this site is suitable for a school and/or housing development.

This site has also been inaccurately assessed, for example, it is listed as being in the High Weald AONB when it is not. As such the sustainability assessment is unsound.

DLP_4891

Berkeley Strategic Land Ltd

Site 434 Tutty's Farm, Hawkenbury

Site Suitability

13. Site Description

13.1. Royal Tunbridge Wells is the principle town in Tunbridge Wells Borough. The town provides a large proportion of the social, cultural and economic opportunities available in the borough.

13.2. In addition to being the Borough’s principal retail centre, the town provides a wide variety of services, including primary and secondary schools, and sports and community facilities.

13.3. The town is strategically located lying just to the south of the urban area of Tonbridge connectable via the A21 and A26. The town also has strong train connections that provide commuter services to London in 50 minutes.

13.4. The site is located to the southeast of Tunbridge Wells two miles from the town centre and extends to approximately 17.2 acres and can be seen outlined in red on the site plan at Appendix 1.

13.5. The site is located in a sustainable location with both primary and secondary schools both being easily accessible from the site. A new primary school is being constructed as part of the Hawkenbury Farm site, which would be within walking distance of the Tutty’s Farm development. There are six secondary schools located in Tunbridge Wells with the Skinners’ Kent Academy closest to the site lying approximately 1.8 miles to the north-east of Tutty’s Farm.

13.6. The Hawkenbury Recreation Ground is located approximately 300m to the northwest of the site aswell as local shops and services, which are readily available nearby.

13.7. Tunbridge Wells station is located 1.4 miles from the site and provides direct train services to central London within 45 minutes.

13.8. The site consists of grassland and well established hedgerows which separate the land into six interconnecting parcels.

13.9. The site adjoins the eastern boundary of the existing Berkeley site of Hawkenbury Farm, which received planning consent in February 2017 for 243 homes. The eastern boundary is bounded by an open field and Hawkenbury recreation ground to the north, while existing woodland lies beyond the eastern and southern boundaries of the site.

13.10. The land is designated as Green Belt and in order to allow the site to come forward the land will need to be removed from the Green Belt. Berkeley’s assessment of the site against the five purposes of the Green Belt is outlined in Section 5. The site was previously identified as an area of search for Green Belt review in the draft Site Allocations DPD.

14. Access

14.1. An initial access assessment was carried out has been carried out in 2017 for the site by Glanville, who were also the appointed consultant for the Hawkenbury Farm site.

14.2. An update assessment has now taken place, which uses more up to date available data and agreed traffic flows with Kent County Council Highways, which were used as part of the Hawkenbury Farm application.

14.3. The highways access note is at appendix 4.

[TWBC: see full representation attached].

14.4. The proposed main site access is to be provided via a safeguarded corridor for a new highway link from the Hawkenbury Farm site. This safeguarded corridor has been designed to ensure that a safe and suitable access can be created into Tutty’s Farm that will meet required visibility and highway standards.

14.5. In accordance with KCC standards there will also be an emergency access link provided onto Hawkenbury Road. The drawing of the location and design of this emergency access has been included within Glanville’s technical note attached to this submission.

14.6. Parking will be provided for in accordance with KCC and Tunbridge Wells Borough Council standards. This will include provision for on-plot parking with garages, driveways and private parking bays. Cycling parking will also be accounted for in line with county and borough standards.

14.7. Pedestrian and cycle links will be provided throughout the new development with on-road cycling and off road pedestrian footways of 2.0m width, in line with KCC standards. Pedestrian and cycle linkages will also be provided to off-site routes.

14.8. The Hawkenbury Road / Forest Road junction would have capacity on the majority of the movements all though the right turn movement would be at capacity. However, due to the location of the connection with Hawkenbury Farm, it is considered that the majority of traffic would utilise Forest Way.

14.9. The Forest Way / Forest Road junction would have sufficient capacity to accommodate the Tuttys Farm flows following the completion of the Hawkenbury Farm improvements.

14.10. Any future planning application would include further traffic modelling to determine the reserve capacity of the Hawkenbury Road and Forest Way junctions to serve the Tuttys Farm development. This will include new traffic surveys to assess the impact of the completion of the A21 duelling, completed in 2017, on Hawkenbury Road. It is considered likely that an acceptable traffic solution can be identified for the two aforementioned junctions as the A21 duelling is proposed to reduce congestion and accidents on the A21, which will benefit wide journey to and from the site using this road and has removed diverted traffic away from Forest Road.

15. Green Belt & Landscape

15.1. Although the land is within the Green Belt as is all of surrounding Royal Tunbridge Wells the site is not within the AONB, which approx. 75% of the Borough is designated as.

15.2. Although the adjoining wooded triangular parcel on the eastern boundary of the site is within the AONB and under Berkeley ownership this land does not fall within the red line of the site. Furthermore this land is designated as dormouse mitigation land as part of the consent Hawkenbury Farm scheme.

15.3. The landscape section of the Green Belt Review and Landscape Appraisal Summary concludes that that views into the site including from the AONB are limited. The eastern boundary of the proposed site is strongly wooded and as such provides a natural stop to the urban edge, which beyond the woodland the AONB and open countryside begin.

15.4. The Green Belt Review and Landscape Appraisal Summary mentioned within Section 5: Green Belt is at appendix 2.

15.5. As mentioned in Section 5 the Green Belt summary provides an analysis of the sites contribution to the purposes of the Green Belt, which we deem as “low” and not “moderate” as classified within the Council’s Green Belt study.

15.6. The landscape section outlines and explains how the site is contained to the north by Hawkenbury Road and by the residential properties of Hawkenbury Farm and Hawkenbury Farm House and their respective curtilages. In addition, the Site is contained by the mature woodland of Benhall Wood to the south, with further woodland and agricultural land to the east. The substantial nature of this mature vegetation creates a strong landscape framework that creates physical and visual enclosure to the site and the south eastern corner of Tunbridge Wells.

15.7. The landscape section picks up on the varying topography of the site, which generally slopes steadily from a high point in the north to a low point in the southeast of the site.

15.8. The primary visual receptors to any residential development on the site would be limited to the existing nearby residential properties, the users of the public right of way and the users of Hawkenbury Road.

15.9. This work concludes that the site’s contribution to the character of the wider landscape in visual terms is limited. The size of the site means that residential development would have the potential to enhance the landscape character of the site and the wider area through the retention and management of existing landscape features and the opportunity to provide new tree and hedgerow planting. This approach would ensure that the impact on the wider landscape would be negligible as a result of the development of Tutty’s Farm.

6. Flooding

16.1. The Environment Agency Flood Maps show the site to be entirely within Flood Zone 1 meaning it is at the lowest risk of flooding.

17. Archaeology

17.1. There are no archaeological features or finds within the site according to the Historic Environment Records maintained by Kent and East Sussex County Councils.

17.2. If the site were to come forward within the emerging Local Plan, further archaeological works would be undertaken in order to fully assess the archaeological potential of the site.

18. Heritage

18.1. Although there are a number of heritage assets present throughout Tunbridge Wells there are no designated or non-designated heritage assets in the immediate area surrounding the site. 18.2. Furthermore, the site is also not nearby the Royal Tunbridge Wells Conservation Area.

18.3. Heritage concerns were mentioned within the SHELAA due to the potential likely impact on the settlement edge and landscape setting of Tunbridge Wells. However, as now the adjoining Hollyfields is under construction and adjoins Tutty’s Farm forming a new urban edge it is clear that the proposed site would act as a logical and natural extension to Hollyfields.

18.4. As such, it is considered that local heritage assets will not have an impact on the potential development of Tutty’s Farm.

19. Ecology

19.1. The site is not subject to any statutory or non-statutory nature designations such as Sites of Special Scientific Interest (SSSI) or Local Nature Reserves (LNR).

19.2. Part of the south east corner of the site holds a non-statutory nature conservation designation being a Local Wildlife Site (LWS). This part of the site is not included in the potential developable area. The area will be retained and incorporated into the landscape and ecological management plan for the site.

19.3. The ecological site assessment for the Hawkenbury Farm site identified the potential for dormice to be present on site. The recommended mitigation measures include the retention of hedgerows, buffer strips and new woodland planting. It is likely that similar sensitivities may be identified within Tutty’s Farm, which will also require the appropriate mitigation. There is ample room within Tutty’s Farm to support any dormice or other ecological mitigation where required.

Furthermore, there is potential for net-biodiversity gain through enhanced planting and management of landscape features within the site.

19.5. If the site was to come forward as part of the Local Plan full ecological works would be undertaken.

20. Arboriculture

20.1. There are a number of hedgerows within and along the boundary of the site, however there are no trees that are subject to any tree preservation orders within the site.

20.2. The woodland to the south of the site is designated as Ancient Woodland.

20.3. As part of any potential development the existing arboriculture will be maintained to their full extent where possible and incorporated into any potential scheme.

21. Site Masterplan

21.1. An initial site masterplan has been produced, which outlines an indicative layout for the site. This conceptual drawing responds directly to the opportunities and constraints that the site is subjected to in order to ensure that the most appropriate land-uses are considered for each area of the site.

21.2. The indicative layout could provide for approximately 100 homes.

21.3. The scheme includes a range of house types with a mix of 2, 3, 4 and 5 bed homes that are both detached and semi-detached.

21.4. The current layout also provides a proportion of affordable housing, which includes a blend of both shared ownership and affordable/social rent. These affordable units will be pepper potted across the site to ensure there is a strong variation and mix between the location of both private and affordable units.

21.5. The masterplan is at appendix 5.

21.6. Tutty’s Farm could deliver additional benefits if it was developed for the local area including;

• Bio-diversity gain
• Investment in Hawkenbury Recreation Ground
• Investment in Hawkenbury Allotments
• Investment in Hawkenbury Bowles Club

22. Conclusions 

22.1. Berkeley support the Council’s provisions to seek to meet their housing needs of the Borough of a minimum of 13,560 homes (678 per year) up to 2036.

22.2. We can support the Council’s decision to propose Option 3 a dispersed growth for the development strategy for the Borough along with a new garden village, however we believe that there is an unbalanced growth set out within the housing provision of the new allocations.

22.3. An over-reliance on Tudeley Garden Village we estimate will result in 450 homes being undeliverable while approx. 2,000 homes within the Paddock Wood allocations lie within flood zone 3 and are unsuitable.

22.4. Together we believe that there is a 550 homes shortfall within the Plan period.

22.5. The Council will need to allocate further sites to meet their housing needs. They should first look to the top tier of the hierarchy to its most sustainable settlement of Royal Tunbridge Wells.

22.6. Tutty’s Farm is not proposed for allocation, however it has been demonstrated throughout these reps along with the technical documents appended that it is a suitable and deliverable site, performs weakly in terms of purposes of the Green Belt, is in a sustainable location and can provide additional local benefits, which together amounts to proving that exceptional circumstances exist.

22.7. Tutty’s Farm is already within Berkeley’s ownership and would be a logical extension to the Berkeley scheme of Hollyfields that is already under construction.

22.8. The site is suitable and deliverable and we have shown within our Green Belt Review and Landscape Appraisal Summary that its development would be of “Low” harm to the Green Belt.

22.9. The site suitability section outlines that there are no significant or complex constraints that would prejudice the site from coming forward. In addition, through the potential section 106 contributions the Tutty’s Farm site could provide investment and improvements to the local area such as improving the recreational ground, local sports clubs or allotments.

22.10. The site is also deliverable without the need for major new infrastructure, which enables early delivery and the ability of the site to contribute to maintaining a five year supply of deliverable sites.

22.11. The allocation of the Tutty’s Farm site will assist in meeting TWBCs identified need for market and affordable housing early in the plan period and will thereby contribute to the sustainable growth of the town and benefit the local area of Hawkenbury.

22.12. Furthermore, we wish to work collectively with TWBC and the local community to bring forward proposals for this site.

[TWBC: see full representation and site location plan]

DLP_1925

Royal Tunbridge Wells Town Forum

457 Land adjacent to Tutty’s Farm

Site Number and Site Address: 457 Land adjacent to Tutty’s Farm 

Details seem to have been omitted from the SHELAA but the same comments would apply as in the case of site 434

DLP_5230

Culverden Residents Association

Sites 12, 30, 100, 165, 199, 205, 280 and 146 (RTW)

Site 12 Tunbridge Wells West to Grove Junction

We agree with the view of TWBC that the site is unsuitable for development because it may be needed in the future to reopen a passenger railway service to Brighton and Croydon.

Site 30 Caenwood/Whitgates Farm Reynolds Lane

We agree with the view of TWBC that the site is unsuitable for development. The site has high visible landscape value from Speldhurst Road and Broomhill Road and is a buffer to the adjoining AONB on the other side of Broomhill Road. It is an important part of the setting of the historic house, water tower, stables and Park at Salomons and is highly visible from the park. It is part of a Local Wildlife Site, Broomhill and Reynolds Lane Pastures. It is also the only remaining piece of open land preventing coalescence of Tunbridge Wells with Southborough. There are already serious highway issues in Southborough and Tunbridge Wells on the A26 which cause rat-running in our neighbourhood and air pollution.

100 Land adjacent to Whitegates Close 

We agree with the view of TWBC that the site is unsuitable for development, particularly because of highway issues at the junction of Speldhurst Road and the A26 which is an Air Quality Management Area at that point.

165 Pantiles Car Park 

We agree with the view of TWBC that the site is unsuitable for development. There should be no building on a site which is an integral part of Tunbridge Wells Common which is a Local Wildlife Site and also important for recreation.

199 Land at Smockham Farm 

We agree with the view of TWBC that the site is unsuitable for development. It contains a Wealden Farmstead with historic farmhouse and barns and Smockham Lane is an ancient routeway which is now also a footpath which links our neighbourhood with Hurst Wood, Rusthall and Speldhurst via other ancient routeways. It is important for tranquil recreation in a rural setting so close to the main urban area.

The yard at the Farmstead contains a 19th century pumping station with chimney and an underground reservoir which used to supply water to the former Brewery on St John’s Road through a pipe said to pass under the Reynolds Lane allotments and Standen Street . The field patterns are mediaeval assart fields and the site as a whole is an important part of the setting of Royal Tunbridge Wells. It is close to Local Wildlife Site TW46 and Sites of Local Nature Conservation Value ID 08 and ID13 which would be adversely affected by any development.

205 Land at Little Knoll Reynolds Lane 

We agree with the view of TWBC that the site is unsuitable for development for similar reasons to the ones we set out in relation to Caenwood Site 30 and also site 100.

280 Land at Midway Nevill Court 

We agree with the view of TWBC that the site is unsuitable for development as it would damage the setting of Hungershall Park, Nevill Park and Nevill Court, which are of significant heritage and landscape value and themselves are adjacent to the Tunbridge Wells and Rusthall Commons acting as an extension of both on the edge of the countryside beyond.

146 Tunbridge Wells Golf Course 

We agree that this site is unsuitable for development. It is an important wildlife corridor between Hurst Wood and Rusthall Common and a useful, tranquil pedestrian route between the Culverden area and Rusthall as well as being an attractive landscape on the edge of Tunbridge Wells.

DLP_1926

Royal Tunbridge Wells Town Forum

Site 146: Tunbridge Wells Golf Club, Langton Road, Tunbridge Wells TN4 8XH

Although the following sites are outside the unparished area of Royal Tunbridge Wells, we make the following commentary on the basis that these un-allocated sites are important to the setting of Royal Tunbridge Wells and/or also serve to prevent the coalescence of RTW with other settlements

Site Number and Site Address: 146 (Rusthall) Tunbridge Wells Golf Course

We support the conclusion that this Green Belt site is unsuitable for development. This site provides an important wildlife corridor to and from nearby Hurst Wood linking into the Rusthall Common. It maintains an attractive setting to the edge of Royal Tunbridge Wells and prevents coalescence between the settlements of RTW and Rusthall.

DLP_7349

Lambert Smith Hampton for Targetfollow (Pantiles) Ltd

Site 146: Tunbridge Wells Golf Club, Langton Road, Tunbridge Wells TN4 8XH

On behalf of our client, Targetfollow Estates Ltd, please find enclosed a representation to the Tunbridge Wells Draft Local Plan Regulation 18 consultation. We welcome the opportunity to engage with the Council for the duration of the Local Plan process.

This representation relates to the Land at Tunbridge Wells Golf Course and aspirations for the site to be allocated in the draft Local Plan for the delivery of retirement housing, housing and community uses. The representation outlines a detailed draft masterplan and assessment of the site and our recommended changes to the draft Plan so that it can be found sound. 

The Site

The site comprises a golf course that includes an area of Ancient Woodland and measures 14.6ha. The site is located adjacent to the settlement boundaries of Rusthall to the west and Tunbridge Wells to the east. The site is bounded to the north by residential development and open countryside and to the south by Langton Road.

The site is located In Flood Zone 1 and is therefore at low risk of flooding. The site is located in the metropolitan Green Belt. There are no heritage assets located within the site boundaries but the site is located adjacent to the Tunbridge Wells and Rusthall Conservation Areas. The site will be accessed by the existing access onto Langton Road.

An Access and Trip Technical Note has been prepared by MLM Consulting Engineers and is appended to the enclosed representation. The note concludes that the site is accessible by sustainable modes of transport such as bus, walking and rail. The site is therefore a sustainable location for development.

Summary of Representation

The draft local plan identifies an overall housing need of 13,560 (including 5,865 affordable) dwellings across the plan period. 5,967 units are identified and there is a consequent need for the draft plan to allocate sites to provide a minimum of 7,593 dwellings.

Tunbridge Wells Borough Council acknowledges that the release of Green Belt land is required to meet housing demand and therefore the draft plan proposes the release of approximately 5% of green belt land in the Borough for development.

The Tunbridge Wells golf course is located within the Green Belt and at this stage in the plan process has not been allocated for development. The enclosed representation promotes the land for allocation within the draft Local Plan to provide retirement living (C3 use class), housing and a new cricket pavilion and pitch, for use by the local community.

In determining that the site is suitable for limited release from the green belt, we have undertaken a detailed assessment of the key characteristics of the site and prepared an indicative masterplan that demonstrates how the development could provide limited infill sites that would not harm the overall function of the green belt in this location. A summary of the assessment of the site and the proposed development’s contribution to the Green Belt principles is assessed against the Borough’s Green belt Assessment within both the Executive Summary and Section 9 of the attached report and representation.

Our Green Belt Assessment concludes that that an overall harm rating of moderate would be a more appropriate conclusion and that contrary to the assessment, there is scope to amend the Green Belt boundary to exclude the proposed development parcels as outlined in Land Use Plan on page 6 of the enclosed representation.

A full planning assessment of the site is outlined in section 9 of the enclosed report. Our assessment concludes that at present there is a risk that the draft Local Plan will not be found sound due to an over reliance on large strategic allocations to meet the required housing need and the under provision of units to meet the assessed older persons housing need. The Tunbridge wells Golf Course site is located in a sustainable location and would contribute to meeting the required housing need across the Borough.

To ensure that the Local Plan can be found sound at examination, we urge the Council to allocate the site at Tunbridge Wells Golf Course, for older persons housing and standard housing together with public open space, to ensure that the housing need across the Borough can be met and delivered within the plan period.

As such, we request that the Golf Course site is allocated within the draft Local Plan and our wording for a proposed site policy is set out below:

‘Policy RU 2

Tunbridge Wells Golf Course, Langton Road

The site, as defined on Land Use Plan on page 6 of the enclosed representation, is allocated for residential (C3 development) providing approximately 62 retirement housing dwellings and 36 dwellings, public open space and a community cricket pitch and pavilion. Development on the site shall accord with the following requirements:

1. Vehicular access shall be taken from the existing accesses onto Langton Road (see Criterion 5 of Policy EN 1: Design and other development management criteria);
2. Pedestrian linkages shall be provided into wider network (see Policy TP 1: Transport Design and Accessibility);
3. Proposals to conserve and enhance the Conservation Area (see Policy EN 7: Heritage Assets);
4. Improvements to existing allotments, amenity/natural green space, parks and recreation grounds, children’s play space and youth play space in accordance with the requirements of Policy OSSR 2: Provision of publicly accessible open space and recreation.

It is expected that contributions will be required towards the following if necessary, to mitigate the impact of the development: a. Improvements to public realm; b. Any other highway related works;

a. Improvements to public realm; 

b. Any other highway related works; 

c. Improvements to pedestrian links or bus services’.

Our client would be able to support the plan as being sound, justified and in accordance with national policy, if the above changes are made and the golf course site is allocated.

Summary

The Tunbridge Wells golf course, which is capable of supporting additional housing need, is located within the Green Belt and at this stage in the plan process has not been allocated for development. This representation, therefore, promotes the land for a residential led allocation, together with public open space, a new cricket pavilion and pitch, for use by the local community. It is also proposed that a significant proportion of the residential allocation within the draft Local Plan will be required to provide retirement living accommodation (C3 use class). The new public open space within the site will also be registered as a Village Green, which will preserve its open nature and prevent encroachment of development in future. We request that the site is allocated accordingly.

We hope that these representations are of assistance in taking the plan forward to the next stage of preparation and examination, and would welcome, in due course, participating in the relevant hearing sessions during the Examination in Public.

Should you require any further clarification in relation to this representation, please do not hesitate to contact me

[TWBC: see supporting documents attached:

VisionTransport Assessment Part 1 Transport Assessment Part 2 Transport Assessment Part 3].

DLP_1935

Miss Noreen O'Meara

SHELAA site reference 146 (Tunbridge Wells Golf Club).

It is stated that this site is within the High Weald Area of Outstanding Natural Beauty. This is incorrect. In view of this, and the fact that the site lies on the least busy main road in Tunbridge Wells, that it has existing access, and that it is available,  I believe that this site should not have been ruled out, and I ask that it is  reconsidered.

The High Weald AONB Unit have confirmed that not only this site but several other sites that were rejected were incorrectly described as being in the AONB. These major errors must surely call the whole site selection process into question.

DLP_3630

Watsons Estates for Dr D G M Powell

Sites 337 and 338 (Rusthall/Speldhurst)

1. Watsons, Chartered Surveyors in Heathfield, East Sussex are retained by Dr D G M Powell who submitted two sites for consideration int he SHELAA second call for sites 2017.

2. These sites are a) allotment land North East of the end of Southwood Road Rusthall (site reference 337) and b) land between Ferbies and Ewehurst Lane, Speldhurst (site reference 338).

3. Both sites referred to above were considered in the SHELAA to be unsuitable for development for the following reasons:

Site reference 337:

"There is concern about the ability to provide an appropriate means of vehicular access to the site as well as concerns regarding effect on settlement pattern and impact on the Green Belt. The site forms part of a Green Belt parcel the release of which would cause high harm".

Site reference 338:

"It is considered that allocation of this site would result in encroachment beyond what would be a logical extension to the LBD (Limits to Built Development). In addition the site forms part of a parcel the release of which would cause high harm if released from the Green Belt".

4. We have studied the draft Local Plan, the Sustainability Appraisal, the Borough of Tunbridge Wells Housing Needs Study (2018) and consultation responses received by the Council and published on the Local Plan website. These studies lead us to disagree with these Assessments and to conclude that further consideration should be given to their suitability for residential development to meet the Council's housing needs.

5. We have come to this conclusion specifically in relation to Rusthall and Speldhurst for the following reasons:

6. Whilst the Housing Needs Study is dated 2018, much of the data contained therein is outdated, being based on a Housing Needs Survey undertaken in 2017. Whilst this is a significant piece of work, it does not provide a sound basis for establishing District wide housing allocations throughout the life of the plan, nor does it take account of the continuing uncertainty caused by the failure to deliver Brexit and the consequences to jobs, household incomes, movement of labour and, therefore, housing needs.

7. At a more local level, we are surprised to read that there is no imbalance in the need for affordable housing in Rusthall Parish alone. We find that hard to believe.

8. In the absence of made Neighbourhood Plans for Rusthall and Speldhurst we suggest that, before the draft Local Plan is put forward for examination, further work be undertaken to more accurately define the housing needs of both parishes.

9. In our view, further consideration needs to be given as to whether the provision of housing is best achieved by allocating the requisite number of new dwellings on just two sites, one in each parish.

10. Turning to the SHELAA in relation to sites 337 and 338 we wish to make the following observations to support re-consideration of their suitability for development.

11. It is said that both sites would cause harm to the Green Belt. However, it should be remembered when assessing sites for development that the National Planning Policy Framework 2019 says of developments in the Green Belt that "limited infilling of villages is not inappropriate". With so much of the Borough in the Green Belt, it is inevitable that boundaries will need to be adjusted if identified housing needs are to be met.

12. Neither do we agree in relation to site 337 that there is a technical difficulty in providing access to the site. Further work needs to be done in this regard.

13. Neither do we agree that allocation of site 338 would result is such a level of encroachment beyond the LBD as to justify not releasing this site for residential development.

DLP_6548

Woolf Bond Planning for Millwood Designer Homes Ltd

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

OMISSION OF LAND AT HOME FARM, LOWER GREEN ROAD, RUSTHALL AS A HOUSING ALLOCATION

Introduction

General

We refer to the above Regulation 18 Local Plan (“LP”) consultation document and write on behalf of our client, Millwood Designer Homes, setting out a number of comments upon the policies and proposals contained therein.

As you will doubtless be aware, our client is a Kent-based developer of long standing repute for high quality residential schemes. They have a number of current land interests in the Borough, and these representations are submitted both generally in terms of the overall spatial strategy, and settlement-specific in relation to their land interest at Home Farm, Lower Green Road, Rusthall (SHELAA Site Ref: 60).

Policies and Proposals

Our representations relate to the following policies and proposals:

* STR 1: The Development Strategy

* STR 4: Green Belt

* STR10: Limits to Built Development

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

* STR/CA 1: The Strategy for Capel Parish; as well as:

- AL/CA 1: Tudeley Village

- AL/CA 3: Land at Capel and Paddock Wood

* STR/PW 1: The Strategy for Paddock Wood; as well as:

- AL/PW 1: Land at Capel and Paddock Wood

Our representations are also accompanied by a duly completed response form. Our detailed comments are set out below.

Supporting Particulars: Site Specific Representation - the omission of land at Home Farm, Lower Green Road, Rusthall as a housing allocation

Millwood Designer Homes has a controlling interest in land at Home Farm, Lower Green Road, Rusthall which extends to approximately 1.3ha

The site has been assessed in the Council’s Strategic Housing and Economic Land Availability Assessment (“SHELAA”) under Site Ref: 60.

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

Development of the site for approximately 25 dwellings would enable a high-quality housing scheme to be located within walking distance from local services and facilities, including the High Street which is within an easy 0.5km walk to the south of the site. The site is also within a short 0.25km walk to a bus stop which provides regular services to Tunbridge Wells.

Plans and particulars are enclosed in support of our representations, which seek the allocation of the site for approximately 25 dwellings as follows:

(i) Site Location Plan No. WBP1

(ii) Potential Access Improvements Plan No. P352/MDR

(iii) Site Context Plan No. WBP2

(iv) Duly completed Response Form

We set out the merits of the site as a housing allocation in response to the Royal Tunbridge Wells-specific policies below.

Overarching Comments

As an overarching position statement, it is our view that the Plan as drafted is unsound having regard to

1. The over reliance on housing delivery from strategic sites.

2. The allocation of sites that cannot be said to be justified when taking into account the reasonable alternatives (see point (3) below)).

3. The omission of land at Home Farm, Lower Green Road, Rusthall (SHELAA Site Ref: 60) as a housing allocation for approximately 25 dwellings.

On the basis of the foregoing, and as expanded upon below, we do not consider the Plan to be positively prepared, justified, effective or consistent with national policy at this stage in the plan–making process. However, it is clearly a good start and we welcome the opportunity to work with the Council in addressing our comments, including in relation to the omission of our client’s land interest.

The next iteration of the Local Plan (the Regulation 19 stage) provides the opportunity to make the necessary changes in order to ensure the Plan can be said to be sound and that it represents the most appropriate strategy when assessed against the alternatives; and that it is consistent with national policy.

For the Plan to be found sound, modifications are required to be made to the Plan in response to our concerns expressed at points (1) to (3) above.

NPPF Considerations

General: Tests of Soundness

Section 3 of the NPPF (February 2019) sets out the principal components to be included in local plans.

In order to be found “sound”, paragraph 35 of the NPPF requires the plan to be positively prepared, justified, effective and consistent with national policy.

A positively prepared plan provides a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities so that unmet need from neighbouring areas is accommodated where practical to do so and is consistent with achieving sustainable development.

In order to be justified the DPD must be an appropriate strategy, taking into account reasonable alternatives; and should be informed by a proportionate evidence base.

Effective means the document must be deliverable over the plan period and based on effective joint working on cross-boundary strategic matters, including meeting unmet needs from adjoining authorities.

Proposed Amendments

For the reasons set out in these representations there are a number of shortcomings with the Plan as currently drafted, that result in the need for amendments.

Our suggested amendments, necessary to satisfy the tests of soundness, may be summarised as relating to the following:

* Acknowledgement that the existing supply of housing commitments are insufficient in both quantum and nature to meet both immediate and longer term needs;

* The need for greater flexibility within the Plan to meet the overall housing requirement for the plan period. These concerns can only be resolved through the identification of additional allocations;

* The allocation of land at Home Farm, Lower Green Road, Rusthall (SHELAA Site Ref: 60) as a housing allocation for approximately 25 dwellings.

Summary

On the basis of the foregoing, the Regulation 18 draft Local Plan does not currently satisfy the tests of soundness for the following reasons:

* Unjustified – The plan is not the most appropriate strategy when compared to the reasonable alternative of additional allocations in sustainable locations such as Site 60 at Home Farm, Lower Green Road, Rusthall.

* Ineffective – The proposed distribution strategy and over-reliance on strategic sites fails to deliver the necessary level of housing development, including addressing potential unmet needs (to be agreed during the evolution of the Local Plan process).

* Inconsistent with National Policy – The proposed distribution strategy fails to boost the supply of housing or maximise sustainable patterns of housing growth, including on account of failing to provide for an appropriate level of growth on sustainably located sites.

Our client’s site at Home Farm, Lower Green Road, Rusthall offers a sustainable and deliverable opportunity to provide for approximately 25 dwellings, in a landscaped setting, within walking distance from local services and facilities.

Against the above background, including on the basis of the Council’s evidence base, there are no known constraints to releasing SHELAA Site 60 from the Green Belt as a housing allocation for approximately 25 dwellings in helping to meet identified housing needs during the early part of the plan period (following a review of the Green Belt boundaries).

We trust the above comments are of assistance in producing a revised version of the Local Plan for a subsequent Regulation 19 consultation and we await confirmation of receipt of our representations in due course.

Finally, we welcome the opportunity to enter into dialogue with the Council in order to discuss our comments in the context of seeking to ensure a sound Local Plan.

Please do not hesitate to contact the writer should you wish to discuss any matter(s) arising.

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

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

DLP_2998

DHA Planning for The Cysters Partnership

land rear of Field House, Iden Green and land adjacent to Pinyons in Sandhurst and other sites

1 Introduction

1.1 Purpose of this report

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

1.1.2 The Partnership are landowners in Tunbridge Wells and are promoting two sites in Tunbridge Wells; land rear of Field House, Iden Green and land adjacent to Pinyons in Sandhurst and other sites.

1.1.3 The former consists of an area of 0.6ha of agricultural land to the south east of Iden Green Road and the east of Standen Street, Iden Green. The land is bound to the north west, west and north east by residential development which aligns the south east of Iden Green Road and east of Standen Street. To the south east there is wider agricultural land also owned by the applicant.

1.1.4 The latter is a 2.3ha area of agricultural land to the west of-the dwelling known as Pinyons on the north side of Queen Street (before the junction with Sponden Lane), Sandhurst. It is bounded to the east by residential development which aligns the north side of Queen Street. To the north is agricultural land, with Queen Street and then further residential dwellings to the south. To the west is Sponden Lane.

1.1.5 Based on the current national and local planning context, we consider these parcels to be suitable for development and we consider there to be ‘exceptional circumstances’ to release this additional land within the High Weald Area of Outstanding Natural Beauty (‘AONB’).

1.1.6 Given this context, this representation responds to the content of the draft plan (and relevant supporting documents) and reinforces why the sites represent suitable locations to accommodate growth. Furthermore, we fully emphasise why such additional housing is needed.

2 The Tunbridge Wells Draft Local Plan

2.1 Overview

2.1.1 The TWBC Draft Local Plan (herein referred to as ‘the plan’) sets out the spatial vision, strategic objectives, and overarching development strategy for the borough. It details overarching place shaping policies for each parish and settlement, as well as site specific allocations to deliver the strategy and detailed policies to be applied to all new development.

2.1.2 The plan will set the agenda for development across the borough to 2036 and replace the current Development Plan, which comprises the Local Plan 2006 (saved policies), the Core Strategy 2010, and the Site Allocations Local Plan 2016.

2.1.3 This representation comments on the following elements of the plan:

• Vision and Strategic Objectives;
• Development Strategy and Strategic Policies;
• Place Shaping Policies for the Parishes of Benenden and Sandhurst;
• Development Management Policies; and
• Omission Sites.

2.2 Vision and Strategic Objectives

2.2.1 The TWBC draft Local Plan is underpinned by a future vision up to 2036 and beyond. The vision is for Tunbridge Wells to be vibrant and prosperous and there is also an expectation that it will have grown significantly. The Council aim for growth to be infrastructure led and largely funded by new development. The key components of the vision are summarised below:

• The heart of Royal Tunbridge Wells and Southborough will be culturally rich, full of vitality, and will have the flexibility, robustness, and adaptability to cope with changes in the economy and other circumstances.
• Paddock Wood as a settlement will have developed considerably (including on land in eastern Capel parish) on the basis of garden settlement principles, using a comprehensive, master-planned approach.
• A new garden settlement will have been established at Tudeley Village, including homes, employment, and community facilities (which will continue to develop over the following years).
• High quality development at other settlements across the borough will have been realised, with the timely provision of relevant infrastructure
• Rural enterprise will have been supported, and the exceptional quality of the built and natural environments will have been protected and enhanced.

2.2.2 The plan stresses that all development will achieve high quality design, responding to the distinctive character of particular locations and in certain instances valued and protected landscapes. Further, the timely delivery of infrastructure will be central to the plan.

2.2.3 In order to turn this vision into reality the plan sets a number of strategic objectives.

1. To deliver the housing, economic, and other needs identified for the borough by the end of the plan period through well designed, sustainable, plan led, and high quality development;
2. To achieve the delivery of all forms of infrastructure to mitigate the impact of development and where possible to result in 'betterment';
3. To prioritise active travel, but where necessary to plan appropriately for use by private motor vehicle, in particular embracing new technology;
4. To boost significantly the supply of affordable housing, and to seek to redress the disparity between house prices and income in the borough;
5. To ensure that the borough is vibrant, culturally rich, and economically buoyant;
6. To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature;
7. To release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land;
8. To tackle climate change and minimise the impact of development on communities, the economy, and the environment with carefully considered design and by embracing technology, such as renewable energy generation;
9. To establish garden settlements as a model for the future delivery of development in the borough;
10. To work with neighbourhood plan groups to ensure the formation of locally-led policies, with this reflected in decisions on planning applications.

2.2.4 We support the general thrust of these objectives, which seek to meet identified housing needs in full and boosting significantly the supply of new affordable homes. However, we would suggest some minor modification to clarify that the plan is positively prepared and fully aligned with the provisions of the National Planning Policy Framework (‘NPPF’). Indeed, we acknowledge that the Plan aspires to achieve the full development needs of the borough and therefore we consider that objective 1 should be modified to make certain on this point.

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

2.3 Development Strategy and Strategic Policies (Policy STR1)

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

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

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

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

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

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

2.3.7 We support the general principle of proportionately spreading the benefits of growth and we recognise the opportunity to direct a greater level of growth to villages and towns compared with previous plan periods. Furthermore, adopting a pattern of dispersed growth approach would allow a number of sites to be developed at the same time, serving different segments of the local housing market, which is preferable to saturation of the market in a single area.

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

2.3.9 In this regard, we would draw the Council’s attention back to the 2016 document published by Nathaniel Lichfield’s and Partners (NLP) - ‘Start to Finish: How Quickly do Large-Scale Housing Sites Deliver’, which provides evidence pertaining to the speed and rate of delivery of large-scale housing, based on a large number of sites across England and Wales. It identifies that the average lead in time for the submission of a planning application is 3.9 years, from the date the site is first identified. In terms of the planning approval period, for larger scale sites (2,000 + homes) this is circa 6 years. After planning permission is granted, larger sites start to deliver within a year and the average build out rate thereafter is 161 dwellings per annum, although it can be as high as 301 dwellings per annum.

2.3.10 On the basis of this research, if the Local plan is adopted by 2021, planning permission approved by 2023 and delivery commences within 6 years (2029), the likely delivery for the plan period would be no more than 966 homes.

2.3.11 Despite this evidence, TWBC has set a much more optimistic trajectory for delivery of Tudeley Garden Village and the strategic extension of Paddock Wood, which is detailed in the Housing Trajectory Paper. The Council forecast that the Tudeley Garden Village will begin to deliver homes from 2025/26 onward, with an initial build out rate of 150 dwellings per-annum, rising to 200 dwellings per annum from year 6 onward. Likewise, the Council suggests that the extension to Paddock Wood will start to deliver in 2024/25 at an average build out rate of 333 dwellings per annum – which is nearly double the average rate for larger schemes identified in the NLP document. This higher build out trajectory is predicated on the basis that there would be a number of house builders involved the construction of different parts/phases. However, by their own admission, TWBC do not currently know how many housebuilders will be involved.

2.3.12 Taking the above into account, our view is that the Council have applied a drastically overly optimistic development trajectory for the delivery of strategic sites, both in terms of the start date for completions and the expected build out rates. Accordingly, we would encourage the Council to increase the balance of small and medium sized sites, which can deliver quickly and usually require limited intervention to infrastructure.

2.3.13 Given the absence of any similar scale strategic sites in Tunbridge Wells Borough as a point of comparison, one could have regard to similar scale delivery in neighbouring authority Tonbridge and Malling Borough. In this respect, we provide evidence below of its three key strategic sites and the associated delivery rates (derived from the Tonbridge and Malling BV Annual Monitoring Report 2017).

2.3.14 Kings Hill is an extremely prudent example to consider in the context of the Paddock wood extension and new garden village at Tudeley, how deliverable this would be. Indeed, Kings Hill was a new village started in 1989 near land previously occupied by RAF West Malling. The concept was for a multipurpose site of both residential and office business space. The development is still being delivered some 30 years later, despite having multiple national housebuilders delivering different phases concurrently. Based on the most up-to-date delivery data for the last decade, Kings Hill has only delivered 131 dwellings per annum, despite multiple developers delivering concurrently. Furthermore, the earlier delivery phases we delivered at lower rates given the need to front load infrastructure.

2.3.15 Therefore, we consider that whilst some development may come forward in the plan period from the two proposed strategic sites, in reality these strategic allocations are longer term aspirations that will extend beyond 2036.

2.3.16 Accordingly, we would encourage the Council to increase the balance of small and medium sized sites, which can deliver quickly and usually require limited intervention to infrastructure, so that it may reduce the reliance upon Tudeley & Paddock Wood within this current plan period.

2.4 Place Shaping Policies

2.4.1 The place shaping policies establish the spatial priorities for different areas in the borough, organised according to non-parish and parish areas. For each area, there is an overarching policy that development should adhere to and details are provided for individual allocated sites that will deliver the quantum of development proposed. The site-specific allocations provide both strategic and development management guidance.

Benenden

2.4.2 Policy STR/BE1 sets the proposed strategy for Benenden and states that Approximately 119-129 new dwellings will be delivered on four sites.

2.4.3 Our client supports the principle of proportionate growth for the Parish. However, we consider it inappropriate to site all new housing entirely within Benenden and the East End of Benenden, and not to provide a degree of disbursal to Iden Green given it is a hamlet in its own right and should be afforded some wider scope for growth. In this regard, our client has advanced a proportionate and logical infill scheme for circa 7/9 new homes and associated open space.

2.4.4 This being the case, we object to the Council’s failure to consider the associated benefits of small parcels of the wider land promoted via the ‘call for sites’ process.

2.4.5 We also object to the removal of the LBD from Iden Green, especially on the ground that it is unsustainable. Furthermore, the methodology used to arrive at this conclusion is flawed and inconsistent. For Example, within the SHELAA assessments site BE4, at the East End of Benenden, was accepted as sustainable, yet sites 18, 21, 437 and 8 are far closer to the village centre are dismissed as being too remote. With this in mind, there is no reasonable basis to withdraw the LBD boundary in Iden Green.

Appeal Ref: APP/M2270/W/16/3163774 - Killillea, Parkfield Crescent, Iden Green

2.4.6 The above appeal was a scheme for two new dwellings allowed in Iden Green in April 2017 should also be factored into the wider site assessments. In this respect, the appeal followed a refusal of planning permission of a similar nature to that of the current application site. Accordingly, the main issue was whether the proposed development would constitute sustainable development and the effect of the proposed dwellings on the surrounding rural landscape, including whether they would conserve the landscape and scenic beauty of the High Weald Area of Outstanding Natural Beauty.

2.4.7 In reaching the decision, the Inspector stated (with our underlining):

‘Paragraph 55 of the Framework confirms that housing should be located where it would enhance or maintain the vitality of rural communities and that, where there are groups of smaller settlements, development in one village may support services in a village nearby. New isolated homes in the countryside should be avoided, but this site is located adjacent to the defined limits to built development of the settlement of Iden Green, such that it cannot be considered isolated. Development in this location would support services and facilities within this settlement and those of surrounding settlements.

2.4.8 The Inspector then concluded:

‘With regard to the three dimensions of sustainable development, the proposed development would provide economic benefits during the construction of the dwellings and residents would support local services and facilities within this village and surrounding villages once they are occupied. The provision of two dwellings would have a positive social impact in contributing to the need for homes in the area, particularly as the Council confirm there is a lack of a five year housing land supply. I have concluded above that the proposed development would support services and facilities within this settlement and those surrounding, reflect the surrounding rural landscape and conserve the landscape and scenic beauty of the AONB. As a result, the adverse impacts of the proposed two dwellings would not significantly or demonstrably outweigh the benefits, such that the proposed development would comprise sustainable development as defined by the Framework’.

2.4.9 On the basis of this decision, the Planning inspectorate has clearly identified that proportionate development adjacent to rural settlements such as Iden Green can be sustainable owing to the role they play in sustaining rural communities.

2.4.10 Finally, within the ‘overview’ table for Benenden the site assessments are not consistent. For example:

1. Iden Green is better located to Benenden that the East End, but is not fully referenced;
2. Landscape Character – Iden Green should add orchards.
3. Bus frequencies are consistent between Iden Green the East End of Benenden, yet are not referenced;
4. Staplehurst station 8.9 miles from Iden Green by road but is not referenced;
5. Education Facilities – the East End has no preschool, Iden Green does at present.
6. Recreational facilities – the East End has tennis courts, cricket pitch and a café – but these are not publicly available? Within Iden Green there is a pub, a nursery school, a community hall, a church, a tennis club and recreation field. There is also a paved footpath link to Benenden Village and a lot of local children already walk up to Benenden’s new primary school.

2.4.11 Given this context, we do not consider the site selection that underpins the current choices is adequately informed or sound.

Sandhurst

2.4.12 Policy STR/SA1 sets the proposed strategy for Sandhurst and states that Approximately 20-27 new dwellings will be delivered on two sites.

2.4.13 Our client objects to the extremely low provision of housing for the village, particularly when Benenden is to be afforded circa 6 times the proposed growth of Sandhurst despite similar AONB constraints. Given the availability of additional sites, we strongly consider that Sandhurst could accommodate additional growth in a sustainable manner. Furthermore, our client has already advanced a formal application and subsequent pre-application for circa 20 homes on a small parcel of the land promoted under reference 438.

Exceptional Circumstances

2.4.14 Paragraph 172 of the NPPF states that great weight should be given to conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection. It goes on to state that planning permission should be refused for major developments in AONB areas except in exceptional circumstances and where it can be demonstrated they are in the public interest.

2.4.15 Consideration of such major applications should include an assessment of:

1. the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
2. the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and
3. any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.

2.4.16 It is important to stress that footnote 55 of the NPPF is clear that for the purposes of paragraphs 172 and 173, whether a proposal is ‘major development’ is a matter for the decision maker, taking into account its nature, scale and setting, and whether it could have a significant adverse impact on the purposes for which the area has been designated or defined. The term has no direct correlation with the definitions set out in the Town and Country Planning (Development Management Procedure) (England) Order 2015.

2.4.17 Whilst this document supports the promotion of the land rather than a formal planning application, we set out below why we consider exceptional circumstances exist for the release of this land within the AONB.

2.5 The need for the development

2.5.1 As outlined by the plan, there is an overriding and growing housing need within the Borough. The Council’s SHMA findings initially identified the future need to plan for some 648 new homes per year. This in turn has seen a further uplift as a result of the standard methodology for calculating housing need, which based on the most credible set of population projections suggests a further uplift to circa 680 new homes per year.

2.5.2 In addition to the need moving forward, the previous difficulties in keeping pace with delivery has resulted in a need to accommodate a significant number of dwellings in the short term with a deficit in five year supply.

2.5.3 Given the current development plan has seen documented difficulties in meeting the existing core strategy housing target, the need for new housing is compelling and indisputable and must be addressed by the new plan as a priority.

2.6 The cost of, and scope for, developing elsewhere

2.6.1 Tunbridge Wells is a constrained borough. There are a number of archaeological and heritage sites, including 45 Historic Parks and Gardens, 25 Conservation Areas and 11 Scheduled Ancient Monuments. In addition, there are approximately 3,000 Listed Buildings.

2.6.2 The landscape of the High Weald AONB contains numerous historic landscape features, including field patterns, settlements and ancient woodland, whilst the borough also hosts a number of, or is close to, areas of ecological importance. These include:

1. Ancient Woodland (approximately 16% of the borough)
2. Circa 60 Local Wildlife Sites (approximately 11% of the borough)
3. Ten Sites of Special Scientific Interest (SSSI)
4. Five Local Nature Reserves (including one Community Woodland)
5. One Regionally Important Geological Site, at Scotney Castle Quarry.

2.6.3 The nearby Ashdown Forest is a designated Special Area of Conservation (SAC) and Special Protection Area (SPA).

2.6.4 Although not an environmental constraint, the Metropolitan Green Belt covers 22% of Tunbridge Wells borough.

2.6.5 Given the above constraints, it is acknowledged that planning for housing requires the need to balance a number of core environmental and planning matters in order to reach a sensitive future development strategy.

2.6.6 In respect of Benenden and Sandhurst, the villages are not located within the 22% of the borough that is Green Belt and where an ‘in principle’ objection to development applies. Furthermore, there are no non-AONB alternative sites available given the entire extent of the villages are washed over by the designation. Any growth that will provide a meaningful input of market and affordable homes is going to have a degree of adverse impact.

2.6.7 The priority must therefore be prioritising the sites with the lesser impact and where possible, concentrating new development so that it reads as a next chapter in the history and evolution of the village.

2.7 Any detrimental effects and the extent to which that could be moderated

2.7.1 Opportunity exists to moderate the effects of development, including areas of landscaping and associated ecological and heritage buffers and the opportunity to increase public access to the land.

2.7.2 In summary, we object to the Council’s exclusion of our client’s sites and consider that there are exceptional circumstances exist to justify the allocation of these sustainable parcels of AONB land. Furthermore, ways in which the site’s impact could be mitigated have already been fully considered in detail and the schemes have been shown to be deliverable owing to their advancement through the development management process.

3 Section 6: Development Management Policies

3.1.1 In addition to our comments on the strategy, we have reviewed the proposed replacement development management policies as set out in chapter 6 of the document.

3.1.2 In general terms, we would refer back to paragraph 15 of the NPPF that promotes succinct and up-to-date plans, which provide a positive vision. In contrast, the draft policies currently proposed are of such prescriptive detail that they are neither positively prepared nor flexible enough to allow for a range of different circumstances. Furthermore, many aspirations result in inevitable conflict. On this basis, we would recommend that the majority of proposed policies are simplified and where additional guidance is needed, this be included within secondary Supplementary Planning Documents.

3.1.3 Turning to detailed policies, there are a number of contradictory elements that need to be remedied before the plan proceeds to Regulation 19. For example, policy EN1 seeks to ensure development is consistent with the established character and surrounding form. However, policy EN4 places significant emphasis on measures to radically reduce greenhouse gas emissions. The provision of a step change towards more sustainable construction and climate change is, inevitably going to result in a need for a change in attitude towards design, material and construction. Accordingly, a cohesive policy approach is needed that allows innovative and different design if supported on wider environmental and planning grounds. As drafted the policies are too inconsistent.

3.1.4 A number of policies also seek to provide guidance rather than policy. For example, policy EN6 seeks to clarify what information is needed in order to assess a heritage proposal. This level of information should instead feature within a support SPD not policy.

3.1.5 In respect of the natural environment, policy EN20 seeks to protect the rural landscape. It states that development will be required to:

‘1. Conserve and enhance the unique and diverse variety and juxtaposition of the borough’s landscape and the special features that contribute positively to the local sense of place; and

2. Not cause significant harm to the landscape setting of settlements, including historic farmsteads and hamlets; and

3. Not result in unsympathetic change to the character of a rural lane, which is of landscape, amenity, nature conservation, or historic or archaeological importance; and

4. Restore landscape character where it has been eroded; and

5. Preserve intrinsically dark landscapes in accordance with Policy EN 10: Outdoor Lighting and Dark Skies’.

3.1.6 We support the principle of the policy but consider amendments are needed to ensure that it does not result in a blanket reason to refusal otherwise sustainable greenfield development. We suggest it be amended to read:

‘1. Conserve and enhance the unique and diverse variety and juxtaposition of the borough’s landscape and the special features that contribute positively to the local sense of place; and

2. Not cause Include appropriate mitigation to ensure against significant harm to the landscape setting of settlements, including historic farmsteads and hamlets; and

3. Not result in unsympathetic change to the character of a rural lane, which is of landscape, amenity, nature conservation, or historic or archaeological importance; and

4. Restore Enhance landscape character where it has been eroded; and

5. Preserve intrinsically dark landscapes in accordance with Policy EN 10: Outdoor Lighting and Dark Skies’.

3.1.7 Turning to housing policies, we have significant concerns about the drafting of several policies, that show a degree of misunderstanding of the development industry. For example, policy H1 states:

‘Unless there are exceptional circumstances due to specific site or development constraints, a condition will be attached to any grant of planning permission for new major residential development (including change of use) requiring one or the other of the following conditions:

1. That the permission be implemented within two years from the date of decision; or

2. That groundworks and the construction of the ground floor base of at least two buildings be completed within three years of the permission’.

3.1.8 Whilst the majority of developers would aspire to be ‘on site’ and under construction within 2 years, the reality is that there are often processes that need to be adhered to that are outside of the applicant’s control, including the need to formally conclude land purchases, to discharge conditions and to deliver off site mitigation. There are also ‘non planning’ consents that need to be achieved for example Section 278 Highway works, infrastructure agreements (S38 of the Water Industry Act), ecology licensing etc

3.1.9 The Council will also be aware that commencement of development is often prohibited by seasonal restrictions in respect of ecology and wider constraints.

3.1.10 The second requirement for two buildings to be commenced is arbitrary, for example what is the test for single unit schemes or conversion works? The correct test should be as set out in statute i.e. ‘a material start’.

3.1.11 With the above in mind, we consider the Council’s policy should be deleted or modified to the extent that it will endeavour to agree a two year start date based on site circumstances.

3.1.12 In respect of policy H2, and the preference for Multi-developer schemes and comprehensive masterplanning, we understand the aspiration. However, in reality such stringent requests often result in conflict and further delay and the Council should be careful not to try and impose itself on wider commercial arrangements that may prohibit rather than assist delivery. With this in mind, it is our view that the Council should shift focus away from how it wishes to change development industry practices and instead concentrate on what it can influence, namely the provision of detailed guidance for the proposed site allocations (including potential phasing plans and areas zoned for different forms of development). The Council could also consider imposing an illustrative delivery trajectory as part of the validation process.

3.1.13 We note that policies H3 and H4 have regard to housing mix and density yet provide little or no detailed requirement. On the basis that mixes must reflect market requirements, we consider any aspirational densities would be better placed being inserted into the wider reaching policy EN1.

3.1.14 Policy H5 sets out affordable housing requirements. Whilst we support the general thrust of the objectives and the securing of affordable provision, we object to the rounding up of the calculations and contributions being based on a net rather than gross number of units. For small scale proposals this will often see the proposed percentage increase to closer to 45% and 35% respectively. Such thresholds would therefore need to be tested and justified by evidence. A pragmatic approach would be to apply traditional rounding up or down.

3.1.15 The phasing of affordable provision also needs to be sufficiently flexible so as to not prohibit wider delivery. In this regard, we consider that entering into contract with a registered affordable prior ahead of the 50% occupation should provide the certainty of delivery, but without risking a wider delay in market delivery.

3.1.16 We also object to the expectation of sites that provide between one and nine units to pay a contribution towards affordable housing. This conflicts with Paragraph: 023 Reference ID: 23b-023-20190901 of National Planning Practice Guidance, which states planning obligations for affordable housing should only be sought for residential developments that are major developments. Any reduced threshold should be restricted to designated areas only and should be underpinned by detailed evidence.

3.1.17 The Council will be aware of wider country wide discussions regarding the viability of providing social rented accommodation as part of a wider offer. Such provision is becoming increasingly difficult and without robust policy in place that addresses this matter, this matter is likely to significantly slow delivery.

3.1.18 We note that the Council is only willing to allow the use of Vacant Building Credits in exceptional circumstances. However, the test proposed appear significantly more onerous than have been considered and applied elsewhere. Based on the tests proposed, we fear that there will be a delay in genuinely vacant buildings, that are entitled to use of VBC, to be delayed in coming forward in order to meet the overly onerous criteria.

3.1.19 Finally, we note that paragraph 6.160 states:

“…The Council will assume a buffer of 25m from the edge of [ancient] woodland expecting through assessment for developers to confirm that this or any other distance is appropriate and that the priority for such buffers will be ecological mitigation and enhancement for the woodland rather than the amenity of the proposed development.”

3.1.20 The advice from the Government’s statutory advisor on biodiversity, Natural England, states that:

“For ancient woodlands, you should have a buffer zone of at least 15 metres to avoid root damage. Where assessment shows other impacts are likely to extend beyond this distance, you’re likely to need a larger buffer zone.” [1] https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences

3.1.21 Whilst it is recognised that every case will need to be treated on its merits, the Council has provided no justification for imposing a new starting point of 25m, which is nearly double the standard minimum requirement set out by Natural England. This increased buffer zone does not appear to have been based on any evidence. It will simply reduce the quantum of development that can be achieved on many sites, which will in turn increases the risk that additional land is likely to be required elsewhere to meet development needs. We object to this proposed buffer, and request that the standard accepted minimum distance of 15m should be stated instead.

3.1.22 In summary, whilst this overview is not exhaustive, we do have concerns about the nature of the proposed policy framework and the degree to which it appears to be trying to limit and frustrate development. Accordingly, in the interests of positive planning, we recommend that the policy framework is simplified and refined and subject to further detailed consultation and focussed on planning matters.

4 Conclusion

4.1.1 This representation has been prepared on behalf of The Cyster Partnership in response to the Tunbridge Wells Borough Council Draft Local Plan Consultation. The purpose being to provide comment on the Council’s proposed development strategy.

4.1.2 In this respect, we support the aspiration to meet housing need in full and consider that a dispersed growth strategy represents the optimum means to achieve this. Nonetheless, we object to the exclusion of our client’s land parcels at Iden Green and Sandhurst, which is unsubstantiated by evidence.

4.1.3 Furthermore, we consider that the Local Plan strategy relies heavily on the delivery of strategic sites that would require the provision of supporting infrastructure. Moreover, the Council have applied overly optimistic projections to the delivery of housing for the extension of Paddock Wood and the Tudeley Garden Village, largely disregarding the NLP 2016 report and the time it would take to masterplan the strategic sites and deliver the required infrastructure.

4.1.4 In our view, a more realistic trajectory would see some housing delivered, albeit not at the suggested build out rates and much later in the plan period. Further small to medium sites are therefore needed and they should be directed to locations such as our clients land where a commitment to delivery has already been demonstrated.

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

DLP_3581

Ian Bull Consultancy for Jarvis Strategic Land Ltd

299 – Oaklands Farm, Bodiam Road, Sandhurst.

299 – Oaklands Farm, Bodiam Road, Sandhurst.

Jarvis Strategic Land Ltd request that this site be included in the emerging Local Plan as an allocation for residential development. Sandhurst is a sustainable location for development, well related to the strategic highway network. Sandhurst has a range of local facilities and additional development will enhance the viability and vitality of the settlement. The site is well related to the existing built form and will enable a comprehensive master plan led development incorporating strategic landscaping, on site amenity and natural open space, open market and affordable housing, ecological enhancement and mitigation and off site development contributions.

DLP_632

Pippa Hillen

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I was delighted to see that Tunbridge Wells Borough Council has not included Site 45 in the Tunbridge Wells Borough Council Local Plan. As acknowledged in the Plan's Strategic Housing and Economic Land Availability Assessment, site 45 is a Green Belt location within an area of outstanding natural beauty set in a historic landscape. It is rich in biodiversity afforded by its location adjoining ancient woodland, a local wildlife site, and a wildflower meadow. The surrounding area does not have capacity to provide access to key services and facilities to support an additional residential population. Site 45 is used extensively by the local and wider population to provide access to green space to support wellbeing.

DLP_634

Mr A Richards

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Site 45

I support the TWBC decision not to include Site 45 Camp Field as a housing site.

Because it is in the Green Belt and an AONB in an historic landscape.  It is also let down by a lack of key services and desirable facilities within a desirable walking distance from the site.  It is also adjacent to Ancient Woodland , a Local Wildlife Site and a Wildflower Meadow.

DLP_635

Mr Dan George

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

We wholeheartedly support the council's decision not to include Site 45 in the Draft Local Plan. Site 45 is unquestionably inappropriate for development: a greenfield site situated in the Green Belt in an AONB and in a historic landscape.

The council's judgement in this case has been exemplary: development of this site would damage local wildlife, destroy biodiversity and adversely affect the heritage score of the site.

DLP_649

Mark Lauder

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Site 45 – Support for The Council’s Decision Not To Include This Site In the Draft Local Plan

I have the following comments relating to the points in the conclusion of the Plan’s Strategic Housing and Economic Land Availability Assessment with regard to Site 45.

The site in question is designated Green Belt and is also in an Area of Outstanding Natural Beauty (AONB) and historic landscape. I agree with the conclusion that losing this site to housing would cause harm to the green belt and landscape, but would argue that this harm would be severe not moderate, as it would have a detrimental effect on the biodiversity of the sites that border it, which include an Ancient Woodland, a Local Wildlife Site and a Wildflower Meadow. Losing this site would be the thin end of the wedge; proposals for development of the neighbouring green belt fields and woodland would inevitably follow.

As a local resident I agree wholeheartedly with the statement that the site’s potential as a housing development “Is let down by a lack of key services and facilities within a desirable walking distance from the site”

Furthermore any development so close to the A26 would also increase the traffic and potential for an accident to occur on this exceptionally busy road.

To summarise I agree and support the council’s decision not to include the site in the Draft

DLP_726

Mrs Sally Lewin

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Delighted that Site 45 has NOT been included in the Draft Local Plan. I support the Council's decision in rightly recognising this precious land as Green Belt. An area of AONB and part of an historic landscape, it is rich and diverse in wildlife and beauty. It is an essential and integral part of the natural environment and structure of the adjacent Ancient Woodland, Local Wildlife Site and Wildflower Meadow. The Council also rightly recognises that the site is not supported by key services and facilities and while there are transport links the A26 London Road is already highly congested. An commendable decision.

DLP_727

Mr David Lewin

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I agree that Site 45 should not be inculded in the Draft Plan as a housing site.  It should also not be included in any future Plan as a housing site.

The site has a Green Belt location the release of which would cause significant harm to the Green Belt.  It is a greenfield site in an AONB in an historic landscape.

There is a lack of key services and facilities within a desirable walking distance from the site. The local area could not support the additional housing and consequent overcrowding.

Moreover, the site has significant landscape value.  It is an assart field rich in biodiversity and is adjacent to Ancient Woodland, a Local Wildlife Site and a Wildflower Meadow.

Such a site should never be given over to housing development.  To the contrary, it should be protected and preserved for the benefit of the wildlife,  those local residents and visitors who enjoy walking alongside it, and indeed for future generations.

DLP_756

Liz Evans

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Site 45.

I strongly object to development on site 45 for the following reasons:

- it is a green belt location which should be preserved

- it would be a loss of a greenfield site in an AONB

- the location is part of Ancient Woodland, a wildlife site and also a wildflower meadow.

- I cannot see there are any key services close to the site and it also has very limited access

Dower House Crescent resident

DLP_778

Mr Warren Rowe

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Site 45 - I find it hard to believe that this site scored high for transport.  It is bad enough now trying to get onto the A26.  I have witnessed three accidents there myself, so god knows how many there have been.  Also the roads are narrow and in a poor condition.  The site is very steep and difficult to develop.  Flooding will be an issue.

Most importantly the site is green belt land in an area of outstanding natural beauty and is home to many native species.  Many of which are protected. There are bats, slow worms, owls, deer and just this weekend we saw a hare in the field.  A loss of this greenfield site in a historic landscape would be scandlous.

I reinforce and agree with your following comments:  There are no facilities in close proximity to the site.  The local school has no capacity and the site is adjacent to anciet woodland, a wildlife site and natural wild flower meadow.

DLP_788

Dominic Cole

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I have lived in Bidborough for 16 years and have regularly found it difficult to leave the village to join the A26, particularly when turning right towards Tunbridge Wells. On many occasions there are a number of cars in a queue waiting to join the A26 from the Ridge, Bounds Oak Way or Harland Rise. It would be totally impractical to believe that existing road infrastructure, which cannot be 'improved' could carry any additional traffic. In the plans for Site 45, the plans suggest 207 additional houses - typically that would add around a further 400 cars to the existing car 'population'. I therefore strongly object to any houses being build on this site (Site 45) as the roads cannot possibly cope/handle this. Furthermore there is a lack of other amenities ( shops, schools etc.) to support an additional 500 to 1000 people being housed here.

DLP_813

Mrs Judith Liddall

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

1. It is a green belt site therefore should not be even considered. We should safeguard countryside from encroachment
2. Valued by many for the outstanding views hence within the High Weald Area of Outstanding Natural Beauty. Would obviously be obliterated by development.
3. It is adjacent to the ancient woodland of Birch Wood and Southborough Woods.Wild life such as bats need this habitat not to be destroyed to survive.Also within close proximity of a wildflower meadow.
4. Access only by A26 an already congested over-used road makes it unsuitable for development
5. No key services and facilities within a desirable walking distance

DLP_821

Peter Enefer

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Site 45

I strongly oppose any building on Site 45 between Bidborough and Southborough. This is a Green Belt site in an AONB adjacent to delicate Ancient Woodland with significant biodoversity and rare wildflower meadow with similar qualities. These increasingly rare ecosystems must be protected. Furthermore there are limited transport and other amenities in this areas that further undermine this as a suitable choice for any development.

DLP_822

Peter Enefer

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I respectfully strongly oppose any development on site 45 between Bidborough and Southborough. The site is a Greenfield site in an AONB and adjacent to Ancient Woodland and wildflower meadows, increasingly very rare and precious ecosystems that must be strenuously protected for the preservation of the associated biodoversity. This is an area used by many children and animals for recreation, and enjoyment of this area.

Furthermore there are limited transport and other amenities here that could serve additional households but would undermine the quality of life of current residents.

DLP_902

Mr Peter Riley

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I would like to commend the decision to omit Camp Field (Site 45) from the Plan.  It is a Green Belt location the loss of which would be extremely harmful to the Green Belt.  It is a greenfield site which it is very important to retain in the AONB being adjacent to Ancient Woodland and both a Local Wildlife Site and a Wildflower Meadow.  Its loss would cause disruption to a historic landscape and the site has a lack of key services and facilities within a desirable walking distance.

DLP_907

Birch Wood Association

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

The association membership are supportive of the specific assessment of Site 45 as set out in the draft local plan.

It is clearly an assart site but does have some heritage score in that it was part of the medieval bounds and possibly in its local description Camp Field. It certainly would be of great loss to the 5000 annual users of WT 52 footpath as it would to those affected from as far distant as Crowborough.  It's biodiversity is unmeasured but is in continual use,mainly at night, to passage a wide range of mammals between its adjacent areas. It is the path of choice of the bat population of the BirchWood which can be regularly observed . In fact the urbanisation of site 45 would be quite deleterious to these colonies.

We are somewhat less convinced of a positive score in transportation as immediate and consequent exit points would likely be harmful.

In general we find the assessment as is should prevail and thank you for your consideration.

DLP_908

Jessica Ives

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I am opposed to the development of houses on the site 45 - the historically significant land adjoining Birchwood Avenue and Dower House Crescent.  This land is part of the Greenbelt of the area that is enjoyed by many people including the local people.  To build on this site would have a huge detrimental effect on the environment of this area.  Taking away the habitat of many insects and wildlife and well as increasing the carbon footprint for this area and adding to the problems with climate change.  Use of building materials, concrete etc.  With more people living in this area with just a small road to service this area, which in turn would increase congestion as the roads are already clogged with cars.  With more families living in this area the already oversubscribed services of the area would be more pressured to provide places - schools, doctors, dentist to list but a few.  Surely there must be a better use for this land?  Furthermore there is already a housing develop in southborough using existing building sites, to provide more housing which will already add to the services and infrastructure of the area.  Are there not more areas with derelict buildings that could be regenerated?

DLP_930

Mrs Josine Baines

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I fully support the decision not include this site 45 in the Draft Local Plan. The use of the site for housing is not supported by the local road infrastructure - the A26 is barely sufficient for existing traffic and can not support additional demands from new housing.  The site is also adjacent on a number of sides to ancient woodland (with deer and slow worms) and building would have a hugely detrimental environmental impact - in terms of impacting the passage of wildlife and the habitat of protected species.

DLP_2003

Jessica Gordon

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I wholeheartedly support the council's decision not to include site 45 (Camp Field near Birch Wood) in the Draft Local Plan.

Development of site 45 would have caused harm to the Green Belt and landscape score being a loss of a greenfield site in the AONB in an historic landscape. There would not have been sufficient key services and facilities within a walking distance of the site, and it would have placed a burden on the services there which cater to the current residents. It is an assert field which lowers the heritage score of the site and its biodiversity score is informed by its location adjacent to Ancient Woodland, a Local Wildlife Site and a Wildflower Meadow. This Camp Field should remain as it is and should never be developed. It is a beautiful area that the residents enjoy walking in, with views across the valley. It would be tragic to cover this area with buildings and would severely detract from the area and put strain on the local services and facilities.

Map 35 Policy AL/SO 3 Mabledon and Nightingale

The site AL/S03 should not be developed. It is Green Belt land, and is in an AONB and heritage site. It would increase traffic volumes and would have a negative impact on the environment and air quality. It would also negatively affect the wildlife and biodiversity in the area, and would place a burden on local services and facilities. [TWBC: this comment has also been placed against Policy AL/SO 3]

DLP_2224

Mr Howard Mighell

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I read the plans for Southborough with interest. There was a specific reference in the assessment for site 45 that stated the site 'scores positively in terms of.......transport'. I do struggle to understand how any site along the A26 can possibly score favourably for transport. The road cannot cope with the current capacity and could certainly not handle additional traffic. The planning needs to revolve around wider issues of transportation before concluding on specific areas for residential development.

DLP_2578

Mrs Alison Taylor

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Site 45 (Land adjoining Birchwood Avenue/Dower House Crescent, Southborough)

I support TWBC Draft Local Plan SHELAA for Southborough in concluding that Site 45 is unsuitable as a potential site.  I agree with the reasons given in the Plan’s Strategic Housing and Economic Land Availability Assessment  with regard to Green Belt Designation and  AONB/ Landscape matters.  I also resubmit my comments made to the consultation on 11/6/2017 in particular with reference to Highway Matters and the A26 which I do not think have been given enough consideration.

DLP_2601

Mr Philip Packer

45 Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I would like to support the decision of TWBC to recognise the landscape value of sites such as Site 45, and exclude these from allocation in the plan.

The recognition of the landscape value of the site is also fully consistent with the conclusions of the Landscape Sensitivity Assessment. The site is included within Sub Area SP2, which notes as follows:

"The ridge tops and sloping valley sides of the sub-area are visually prominent, particularly from higher ground. There are scenic views of the High Weald AONB landscape across the valley from the Tunbridge Wells Circular Walk at Stockland Green and from the ridge north of Southborough Common."

These views would be seriously adversely affected by any development on Site 45.

In passing, it is also worth noting that any development of Site 45 would significantly increase traffic flows at the junction of Birchwood Avenue and the A26 London Road, a junction which is already problematic at busy times.

DLP_2616

Jonathon Lane

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

To Whom is may concern.

I strongly support the exclusion of site 45 from the Tunbridge Wells Local Plan.

The rationale for its exclusion is sound, including the assessment of any impact of any proposed development to the AONB adjacent and surrouding the proposed site. The site also as the assessment shows has a lack of key services and facilities within a nearby walking distance. It is highly likely therefore that any housing development with generate an above average environmental impact with most potential residents driving to access facilities. The area surrounding the proposed site is also ancient woodland and is a local wildlife site.

Kind regards.

Mr Jonathon Lane

DLP_2634

Mr and Mrs David & Jennifer Heyes

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

In our opinion, by rejecting Site 45 as a housing development in the Draft Plan, the Council has taken a sound and wise decision, and one based on detailed local knowledge. Even the smallest housing development would seriously and irretrievably impact this site and its surrounding area for the following reasons:

1) Landscape:-

This site falls not only within the Metropolitan Green Belt (designated to "assist in safeguarding the countryside from encroachment") but also within the High Weald Area of Outstanding Natural Beauty.

2) Ecology:-

This site links two areas of Ancient Woodland, and falls within the Speldhurst Wooded Farmland Landscape. It is also a Natural Landscape and Priority Habitat, providing a main forage flight path for bats, and a natural link for other creatures between these two areas of woodland.

3) Traffic Congestion

Any development of Site 45, however small, would cause even further congestion on the already saturated A26 which carries a very large proportion of local traffic - private cars, buses and HGVs.

In 2015, official figures show that from Mount Ephraim to Birchwood Avenue (2 miles) the estimated annual average daily flow was 18,359 vehicles. In 2016 (the last official figures) this average had risen to 19,217 vehicles. One can assume a similar rise in the last three years - a rise which is, quite clearly, unsustainable. We also now await the impact of the 69 new flats at the Southborough Hub, the new theatre and the opening of Southborough Gate (McCarthy and Stone): these three new developments alone are likely to generate, at the very least, 150 extra vehicles on the A26.

The A26 serves 10 large secondary schools and many primary schools which lie on, and just off, this road - and there is no alternative route.

4) Air Quality:-

The Air Quality Annual Status Report of 2016 states that "Tunbridge Wells suffers from congestion, particularly on the approach roads to the town centre", one of which is the A26 through Southborough. As the traffic on this road is moving, of necessity, only very slowly between Hangman's Hill and Tunbridge Wells, it is producing up to twice as many exhaust emissions as free-flowing traffic.

For the above reasons, we wage the Council to remain resolute in its wise judgement to reject the inclusion of SITE 45 in the Draft Plan.

DLP_2750

Peter Worrall

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

45 Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I oppose the above submission number 45 on the following grounds:

The Plan's Strategic Housing and Economic Land Availability Assessment conclusion highlighted a range of strengths and weaknesses to this proposed development.

While scoring positively for housing provision and transport it was pointed out that it's Green Belt location would cause moderate harm to the Green Belt and would be a loss of a greenfield site in an AONB. In addition it is let down by a lack of key services within desirable walking distance. Consequently this would increase traffic in the existing quiet residential roads that are adjacent to the site. It is also a beautiful open rural space adjoining Ancient Woodland, a Local Wildlife Site and is a Wildflower Meadow.

In conclusion I firmly maintain that this further erosion of beautiful countryside enjoyed by the existing local residents coupled with the increased potential traffic makes this proposal unacceptable.

DLP_2794

Geoff & Barbara Francis

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

We support the Council’s decision to exclude Site 45 from the Draft Local Plan. In particular we remain concerned that the loss of one greenfield site to development in the AONB will lead to further inroads eventually destroying the AONB. Also there is no doubt that precious wild flowers would be destroyed and biodiversity damaged. We urge TWBC to take note of the scores identified in the Local Plan which conclude that overall the area is unsuitable for housing development, and to resist approaches by developers.

DLP_2798

Dawn Hall

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I support the Council’s decision not to include Site 45 “Land adjoining Birchwood Avenue/Dower House Crescent, Southborough”.

The site is in a greenbelt location and an AONB in an historic landscape surrounded by numerous public footpaths, and bridleways which include the Weald Way. It is ecologically important as there are numerous hedgerows and tress adjacent to the site which provide a habitat for a variety of birds, mammals, reptiles and insects.

The local primary schools at Bidborough and Southborough are regularly oversubscribed meaning that parents of young children would be forced to use private car to take them to and from school.

The nearest local GP service is located within Southborough but is heavily oversubscribed and has limited parking - this would result in household members being forced to travel by car to other GP surgeries.

Traffic congestion on the A26, which is the only route into Southborough, has increased during the 30 years I have lived here, causing excessive levels of pollution and CO2.  This also results in delays to the limited public transport services, especially during school travel times and is not sustainable.

The access roads Birchwood Avenue and Dower House Crescent are narrow and would not be suitable both during construction or by the resulting car ownership in the new homes. There are regular queues to join the A26 in peak hours which would be more frequent causing further delays to traffic on the A26.

DLP_2801

Brian Hall

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I support the Council’s decision not to include Site 45 “Land adjoining Birchwood Avenue/Dower House Crescent, Southborough”.

The site is in a greenbelt location and an AONB in an historic landscape surrounded by numerous public footpaths, and bridleways which include the Weald Way. It is ecologically important as there are numerous hedgerows and tress adjacent to the site which provide a habitat for a variety of birds, mammals, reptiles and insects.

The nearest local GP service is located within Southborough but is heavily oversubscribed and has limited parking - this would result in household members being forced to travel by car to other GP surgeries.

The local primary schools at Bidborough and Southborough are regularly oversubscribed meaning that parents of young children would be forced to use private car to take them to and from school.

Traffic congestion on the A26, which is the only route into Southborough, has increased during the 30 years I have lived here, causing excessive levels of pollution and CO2.  This also results in delays to the limited public transport services, especially during school travel times and is not sustainable.

The access roads Birchwood Avenue and Dower House Crescent are narrow and would not be suitable both during construction or by the resulting car ownership in the new homes. There are regular queues to join the A26 in peak hours which would be more frequent causing further delays to traffic and increased levels of pollution on the A26 London Road.

DLP_2824

Paul Taylor

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I would like to support the decision of TWBC to recognise the landscape value of sites such as Site 45, and exclude these from allocation in the plan.

The Tunbridge Wells brownfield register shows plenty of available sites, yet to be fully utilised. Please continue to protect the area from any/all of the larger developers whom are vying to exploit the concept of cramming housing onto ANOB/Greenbelt land.

DLP_2858

Kim Wilson

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I support the council's decision in Appendix 6 not to include Site 45 in Southborough in the Draft Local Plan as it would cause harm to the Green in an Area Of Outstanding Natural Beauty, and because of a lack of key services and facilities.

DLP_2880

John Hillen

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I support the decision of the council not to include Site 45 in the draft local plan.

Site 45 is a greenfield site in the AONB and provides good views of the landscape and enjoyment to the walkers who use the local footpaths.  Any proposed development would be likely to affect the local wildlife in the field and from the surrounding woodlands and wildflower meadow.  Any potential development would cause greater traffic flow from Birchwood Avenue onto the A26 which would need to be managed.  I congratulate the council in preserving this site for future generations.

DLP_2929

A Hillen

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I was glad to find Camp Field (site 45) was not to be included in the Local Plan for development. This historic site lies between Ancient Woodland of Birchwood and Southborough Common, with local wild life areas and wild flower meadows close by - all of which would be damaged and lost for the future if extensive building were to be allowed there. Another part of the AONB would be destroyed. I am delighted it has been saved and hope it will continue to be preserved.

DLP_2939

Priya Enefer

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I live on the edge of Birch Wood and I strongly support this site continuing to be excluded from this local plan. The reason we moved to this area and the reason most residents too is precisely because of the Green Belt and AONB that it sits within. We wanted a better environment for our children and we wanted to move to an area with the incredible diversity of wildlife and open spaces. This development, alongside many others in this local plan, threaten that. They threaten the cleanness of our air, they threaten the peace, they threaten biodiversity, they destroy the green belt and take away our right to green spaces. This proposal must remain OFF the plan for TWBC.

This site includes a mix of scores. It scores positively in terms of houseing provision and transport but it is let down by its land use score informed by its Green Belt location, the release of which would cause moderate harm to the Green Belt and landscape score being a loss of a greenfield site in the AONB in an historic landscape. It is let down by a lack of key services and facilities within a desirable walking distance from the site. It is an assort field which lowers the heritage score of the site and its biodiversity score is informed by its location adjacent to Ancient Woodland, a Local Wildlife Site and a Wildflower Meadow.

DLP_2969

Gladys Ann Moorby

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I would indicate my total support for the council's action in not including Site 45 within the allocated sites proposed for housing development within the Draft Local Plan.

The protection of the Green Belt to this location of Southborough is essential for the inhabitants of the Borough to have peaceful and open meadow walking space in an ANOB and wildlife location.

It is important that the Council protect agricultural land that was formed by the removal of forest area and not let these areas be released to developers.

Together with the above mentioned factors the site is also subject to being devoid of facilities and acceptable accessibility.

I look to the Council not to alter their present recommendations to Site 45.

DLP_2971

Mr John Rainsford

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I wish to record my full agreement to the Council's omission of Site 45 from the Draft Local Plan. The reasons given within the Plan relating to the non-allocation of particular request for inclusion of this exceptional countryside area are totally supported in relation to being a Green Belt zone, ANOB, Wildlife habitat and located next to a long established forest.

Apart from the above points, the plan's acknowledgement that Site 45 completely lacks any form of necessary key services and facilities are without doubt totally correct and entirely supported by myself. The Council must stand by their decision to leave out this site from the plan and not change their views should any lobbying occur from developers.

So protecting the area to remain a continuing open area for the pleasure of all Southborough residents.

DLP_2975

Alicia Rainsford

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I fully support the action of the Council in the non-allocation of Site 45 in the Draft Local Plan.

The amenities offered to Southborough residents by the open area of Camp Field include:-

• Countryside views and walking space
• Situated in an AONB area
• Part of the Southborough Green Belt
• Next to Ancient Forest areas
• Considerable biodiversity of wildlife and wildflower habitat, essential for local childrens' nature awareness.

The Council's omission of Site 45 must continue and not be amended if companies interested in developing the area try to change the non-allocation.

The reference to 'lack of services and facilities is without doubt the totally correct and completely supported. It is assumed that the unsuitable accessibility and traffic congestion is continued in this element of the assessment.

DLP_2977

Alan Smith

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I would advice that I completely agree with the Council's decision to make Site 45 a non-allocated site within the Draft Local Plan. The point identified within the Housing and Economic Land Availability Assessment in relation to Green Belt, ANOB, Biodiversity value, Ancient Woodland are fully supported by myself.

Also, a major factor identified in the local plan to not include Site 45 is the reference to a lack of key services and facilities. Not mentioned within the assessments conclusion to this area is the inadequate access, this being a small crescent road being an offshoot from Rounds Oak Way.

We look to the Council to maintain their non-inclusion of Site 45, if and when developers lobby to have the area made an allocated site.

DLP_2981

Sheila Smith

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I wish to have recorded my full agreement with the Council's omission of site 45 from inclusion in the Draft Local plan. Site 45 is a field changed years ago from forest to arable land and should continue to remain an open space providing views and walks to an area of natural beauty for the pleasure of Southborough residents.

The field is situated in the Green Belt and provides considerable biodiversity covering both wildlife and meadow flora.

Southborough residents are no doubt looking to the Council to maintain their present stance on the non-allocation of Camp Field in the plan, should developers commence lobbying to include the site.

Also, entry to the site is only gained by a narrow side entry which is solely reached by small side road. The notification that services and facilities are lacking is supported, together with the congestion that will result due to small side road access to the area, and this matter is presumably in this 'facilities' statement.

DLP_3411

Mr A J Holding

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I wish to state in the strongest possible terms my objection to the proposal to build 207 new homes in Camp Field, Southborough.

1. It would involve loss of a valuable greenfield site in an Area of Outstanding Natural Beauty;

2. This would harm the Green Belt area and local biodiversity, being adjacent to Ancient Woodland, a local Wildlife Meadow;

3. Local infrastructure struggles to cope with the current housing and resident numbers:

• The A26 is already overloaded, especially at peak times, with lines of stationary traffic; as a result levels of emissions are at or above safe limits;
• Access to teh A26 at the Birchwood Avenue junction is already hazardous; increased numbers would exacerbate this and increase the likelihood of a serious accident;
• Water provision is already under strain, especially in times of drought;
• Local schools are already full to capacity, even after recent building additions;
• Access to the area by contractors vehicles is not easy and the extra building work would blight the lives of current residents for several years;
• Peak hour trains are already dangerously overloaded and cannot accommodate extra passengers (it is assumed that many of the new residents would commute to London).

4. Recent building work by McCarthy & Stone and others must have increased the population of Southborough by at least 500, the last thing the area needs is another 500 or more.

In summary, I can think of no reasons for allowing this proposal to go ahead, but there are a good number of very substantial reasons why it should not. I hope the planning committee exercise their good sense and responsibility to the community they serve by rejecting this out of hand.

DLP_3429

Jean and John Tune

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

wish to state in the strongest possible terms my objection to the proposal to build 207 new homes in Camp Field, Southborough.

1. It would involve loss of a valuable greenfield site in an Area of Outstanding Natural Beauty;

2. This would harm the Green Belt area and local biodiversity, being adjacent to Ancient Woodland, a local Wildlife Meadow;

3. Local infrastructure struggles to cope with the current housing and resident numbers:

• The A26 is already overloaded, especially at peak times, with lines of stationary traffic; as a result levels of emissions are at or above safe limits;
• Access to teh A26 at the Birchwood Avenue junction is already hazardous; increased numbers would exacerbate this and increase the likelihood of a serious accident;
• Water provision is already under strain, especially in times of drought;
• Local schools are already full to capacity, even after recent building additions;
• Access to the area by contractors vehicles is not easy and the extra building work would blight the lives of current residents for several years;
• Peak hour trains are already dangerously overloaded and cannot accommodate extra passengers (it is assumed that many of the new residents would commute to London).

4. Recent building work by McCarthy & Stone and others must have increased the population of Southborough by at least 500, the last thing the area needs is another 500 or more.

In summary, I can think of no reasons for allowing this proposal to go ahead, but there are a good number of very substantial reasons why it should not. I hope the planning committee exercise their good sense and responsibility to the community they serve by rejecting this out of hand.

Please note that we support the above comments objecting to the proposal to build the new homes in Camp Field.

DLP_4075

Mrs Serwaa Afrifa Crocker

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Site 45

I agree with the council's decision not to include this site in its Draft Local  Plan as it would cause irreparable detriment to a historic landscape that also falls within an AONB.

Once a greenfield site is developed, it's lost forever: the ancient woodland, and meadows would be destroyed and the greenbelt further eroded.

Surely it's better to develop brownfield sites.

Any development of Site 45 would adversely impact school capacity, traffic on the A26.

DLP_5066

Dr Jane Ware

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Reference Site 45:

Reasons why this land is particularly unsuitable for development:

It is designated as GREEN BELT – one of the purposes of which is to assist in safeguarding the countryside from encroachment.

LANDSCAPE AND VIEWS –the site is within the High Weald Area of OUTSTANDING NATURAL BEAUTY.  It is not only the local residents who enjoy the spectacular and far reaching views across the site but also those from the wider community who use the footpath along the northern boundary of the site. Any development would ruin this view.

ANCIENT WOODLAND and ECOLOGY –the site is adjacent to an ancient woodland on two sides (Birch Wood and Southborough Woods) and it provides a main forage flight path for bats and a natural link for other animals between Birch Wood and Southborough Woods.

ACCESS- the A26 is already congested for large parts of the day and no solutions have been put forward to alleviate this congestion.  Development on this site would definitely generate car-based trips at peak time along the A26 in both directions. The increased volume of cars joining the A26, especially those having to cut across the flow of traffic, will reduce safety and increase the risk of accidents.

DLP_5636

Roy Mankelow

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Site 45

We have been informed that while the Camp Field has not been include in the Tunbridge Wells Draft Local Plan another housing developer is trying again.

My feeling are as before and as we have already had some extra houses in the area my points are even more relevent.

The site has a lack of key services within walking distance and the access would cause chaos with even more traffic.

We are already losing geen belt sites and this would not only lose part of an historic landscape but also the retention of the site in the AONB.

We also think it is important to keep its biodiversity as it is adjacent to ancient woodland is a wildlife site and is a wildflower meadow, of which there are few.

DLP_5652

Mrs Valerie Newton

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

We are resident at xx Bounds Oak Way [TWBC: full postal address redacted] and are writing to support the decision not to include Site 45 in the Draft Local Plan. We believe this is a case of the Council taking a commonsense approach and listening to the views of the local community. The field is a Green Belt location and an Area of Outstanding Natural Beauty. I know these are just words but the pleasure the views give to a large number of people should not be underestimated. The field and indeed the view, have been there for hundreds of years and it would be a travesty to lose them.

We would also question what impact the loss of the field would have on the local habitat. It does appear to be an integral link with the other local woodlands and wildlife sites.  To place a major housing development at its centre, would surely disrupt much of the surrounding area.

Finally we would also question the lack of local facilities. We recognise the Council has an obligation to minimise the impact of pollution and to encourage the use of public transport and more environmentally friendly methods of transport. However,  even with the best intentions, we all know that the reality would be the introduction of hundreds of additional car journeys every day in an already congested area. This is surely not the outcome that anyone is seeking.

DLP_5663

John White

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I totally agree with the decision on Site ref:45, known locally as Camp field, being classified as unsuitable for development.

The reasons given, on ecology and landscape concerns, are absolutely correct.

Thank you again for your wisdom in reaching this conclusion.

DLP_5665

Carol White

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I would like to acknowledge and support the councils decision not to include site 45 for selection regarding development. I agree and commend you on your findings.

DLP_5687

Mr John Baker

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

After careful consideration the council has decided not to include the above site for housing in the Draft Local plan, which I strongly support.

This site includes a mix of scores. It scores positively in terms of housing provision and transport but is let down by its land use score informed by its Green Belt location the release of which would cause moderate harm to the Green Belt and landscape score being a loss of greenfield site in the AONB in an historic landscape. It is let down by a lack of key services and facilities within a desirable walking distance from the site. It is an assart field which lowers the heritage score of the site and its biodiversity score is informed by its location adjacent to Ancient Woodland, a local Wildlife Site and a Wildflower Meadow.

I would also add that any housing development on this field would severely impact on Southborough Cemetery and the ability of those visiting the cemetery to enjoy peace and tranquillity. Any such development would also ruin the present historic view across the valley to Speldhurst. Any such development would pose a danger of water run off down to the lower fields and parts of Southborough Common. The Council comments that the site scores positively in terms of transport but any access would have to be from a corner where Birchwood Avenue bends round to the right. Traffic down the lower part of Birchwood Avenue is currently minor, however any such development would have a major and detrimental effect on traffic and hold ups. In Birchwood Avenue there is a parking restriction one side of the road whilst on the other side of the road there are cars parked all day by people using the coach to London. Increased traffic from any such development would further impact on the ability to enter on to the A26.

DLP_5751

Fred & Freda Bull

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

We are opposed to the proposed development of Site 45.

It is an essential green corridor between Whortleberry Wood and Birchwood and other wildlife sites. The area, from our own observations , is rich with wild life such as deer, badgers, foxes and rare invertebrates.

It is important to maintain a distinction between the historic settlement of Bidborough and the more recent development of Southborough.

The Council should prefer brown development sites.

The area is poorly served by public transport requiring requiring a dependence on private vehicles. At present traffic builds up in Birchwood Avenue to get onto the A26. A potential 400 extra vehicles would be a disaster.

Already it is difficult to get a medical appointment at the local medical centre and the schools are over subscribed.

Therefore we agree fully with the Council’s findings and support their decision not to include Site 45 in the draft plan.

DLP_5757

Mr Shane Dillon

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Site 45 Land adjoining Birchwood Avenue and Dower House Crescent:

I would like to fully support the council’s decision not to include Site 45 in the Draft Local Plan.

Currently, there is extreme congestion at peak times on the junction of Birchwood Avenue and the A26 and the local infrastructure could not cope with the significant additional traffic that any development would bring.

The conclusions of the Strategic Housing and Economic Land Availability Assessment highlight that the loss of this particular Green Belt land would be harmful both to the Green Belt and the AONB in which the site stands. In addition, I agree with the conclusion that there is a lack of key services and facilities within a desirable walking distance of the site.

It is commendable that the council has concluded that the site’s location next to Ancient Woodland in an historic landscape makes it unsuitable for development.

DLP_5758

Sam Dukes

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

TWBC has made a commendable decision NOT to include Site 45 in the Draft Local Plan.  The conclusions made in the SHELAA, acknowledge that the loss of this land would be detrimental to the Green Belt and to the site’s location within an AONB.

Site 45, or Camp Field as it is locally known, sits adjacent to local woodland in an historic landscape and any development would significantly harm this unique environment and its biodiversity.

The Council has correctly identified that the site is not supported by key services and facilities.  In addition, the junction from Birchwood Avenue onto the A26 is already highly congested at peak times and the additional weight of traffic that any development would bring, would have a significantly adverse effect on air quality, safety and noise pollution.

I would like, therefore, to fully support the decision not to include Site 45 in the Draft Local Plan.

DLP_5868

Rob and Lynn Birchard

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

We would like to thank you for taking into consideration our views on Site 45 and excluding it from a potential site allocation in the Local Plan. We fully support you in this decision.

In addition to the points mentioned in the sustainability appraisal (111) and SHELAA (112) we believe its worth mentioning that the site 45 is included within Sub Area SP2, which notes "The ridge tops and sloping valley sides of the sub-area are visually prominent, particularly from higher ground. There are scenic views of the High Weald AONB landscape across the valley from the Tunbridge Wells Circular Walk at Stockland Green and from the ridge north of Southborough Common."

Development of the land adjoining Birchwood would spoil a particularly beautiful landscape which is enjoyed by dog walkers, ramblers etc. Indeed we have fond memories of walking our children (and other local Soutborough children via a “Walking Bus”) to Bidborough Primary School on the Public Footpath which runs along the site. Now its us and the dog!

Any development of this site would blur the boundaries between Bidborough and Southborough and, not only would Bidborough lose it’s distinctive ‘village’ feel, but the impact of 207 houses on the local amenities must be considered.

Our other main concern is the impact that any development would have on Birchwood Avenue and the junction with the A26, which is already hazardous at peak times – in 40 years of driving I have had 2 accidents, both trying to get out of this junction at rush hour.

207 houses would generate at least 207 cars (probably nearer 350) and the impact this would have on Birchwood Avenue, which would take the full brunt of the traffic being the only access point to the site, must discount this as a suitable site.

The A26 is already a hot spot with regards to pollution  and air quality so, from a health and safety perspective, this should also rule out development of site 45.

DLP_5908

Catherine Deller

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I am writing to express my support for your decision to reject site 45 in Southborough as a site for development, on the basis that it is an historic landscape located in the Green Belt and in the AONB. It is absolutely the case that there is a lack of key services and facilities close to the location, and I am sure that you’re aware that local infrastructure is already under huge pressure.

We hugely value the field, which is a vital migration path for wildlife, linking Ancient Woodland, wildflower meadows and other locations of huge importance to wildlife and local residents alike.

I really appreciate that there is a need to provide additional housing in this part of West Kent and am relieved and grateful that you have rejected this site, the development of which would change the nature of the boroughs of both Southborough and Bidborough fundamentally.

DLP_6234

Rebecca Lloyd

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

We are writing concerning information received stating that, despite the Council's decision not to include it in the Draft plan as a housing site, a large developer is still showing interest in Site 45 (Camp Field) and would like this decision reconsidered. We would strongly object to this.

We want to show our full support for the Council's decision taken following consultations in 2017 and reiterate the conclusions that they came to in recognising the site as being in an Area of Outstanding Natural Beauty; located next to ancient woodlands and part of a valuable historic landscape. Developing this Green Belt site would ruin the local area which would not be able to offer the facilities and services necessary for such a large development. The infrastructure along the Tunbridge Wells/Southborough/Tonbridge A26 route can not cope with current volumes!

We look forward to hearing that this beautiful area will remain unspoilt for as long as it is possible.

DLP_6363

Heather and Martin Derham

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

We are writing to support TWBC’s decision to omit Site 45 from the Draft Local Plan.

Site 45 is now a rare area within Tunbridge Wells, giving wonderful views both out across the Weald as far as Crowborough, as well as in the reverse direction from the Weald and local villages such as Speldhurst towards Southborough. It is absolutely certain that loss of this will cause significant and irreparable damage both to the Green Belt and the AONB.  This is exactly the kind of site where Green Belt and AONB protection should be given maximum priority over any other concerns. There are now very few such sites accessible by the public within Tunbridge Wells, and as such this site has a very high environmental value and a rarity value. It needs to be retained both for the residents, and to preserve the town’s status of a historical centre with close and easy access to the AONB.

In a location such as Site 45 there can be no such thing as sensitive or sympathetic development. Once this area is lost , it is lost for good, to the detriment of thousands of people, and for the foreseeable future.

The site has a very high amenity value and the adjacent footpaths and common ground are used by many hundreds of people every week, and on a daily basis as part of many resident’s exercise. This usage would be degraded though development adjacent to the footpath and common ground areas. In addition to local residents of Southborough, the site is very close to a National Trail, the Wealdway, which passes within a few metres of the site boundary, and is walked by visitors from across the country.

The other aspect which affects the amenity value is that the site is surrounded by 3 areas of preservation offering substantial biodiversity and a historic landscape. The mix of ancient woodland, semi-ancient woodland, relic heathland and a publically accessible wildflower meadow, all linked together, form a rare environment that needs to be preserved. The development of Site 45 would mean that a block is placed in the middle of these sites, interfering with flightpaths and land based migration routes between the areas, and as such it is certain to damage both the environmental and the biodiversity value of the surrounding areas.

We are members of The Birch Wood Association and we also support the Association’s representations on this site.

Consequently we fully support the Borough Council’s decision on this site

DLP_6442

Jan Smith

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

I would like to reference Appendix 6 and the sites that have been chosen to not be included and like state that I agree with the councils assessment of Site 45 and that it would not be a suitable site for development for the following reasons:

Green Belt location

Loss of a greenfield site in the AONB in an historic landscape

Lack of key services and facilities within a desirable walking distance from the site.

Adjacent to Ancient Woodland, a Local Wildlife Site and a Wildflower Meadow.

As Camp Field is adjacent to Ancient Woodland and local wild life sites it acts a corridor for wildlife which would be lost if the field was built on. In addition there would be significant impact on the natural landscape and pressure on local roads at peak times would be increased if the development was to go ahead. The local area is also a popular destination for walkers and the impact of building on Camp Field would mean that the particular appeal of local walks in the area and the views south across to Ashdown Forest would be lost.

DLP_6806

Mr Arthur Hull

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Re Camp Field (Plot 45) The site King Harold was Known to have encamped on his way to the Battle at Hastings.

I would like to request that before any re-consideration for the Camp field site (Plot 45) to be re-included in to the counsels local plan, that an archaeological survey be undertake to establish that this is a historically significant site.

The survey should be of the whole area between Camp field and Bidborough Church.  I attach a photograph of a medieval axe head that I unearthed at the end of our garden: XXX Hardinge Avenue.  Which I think supports this clam [TWBC: House number redacted].

DLP_8226

Councillor David Shepherdson
Bidborough Parish Council

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Individual but also Parish Councillor for Bidborough PC

There remains significant local opposition to any development on this field and I note the comments that have been expressed in the analysis of the site in relation to its position adjacent to two sets of woods. It is to be hoped that the local plan can be adopted without infringing on this Green Belt location and note the lack of key services and facilities within a desirable walking distance of the site. However given my previous comments about Bidborough School, I must acknowledge that such housing provision would prove a boost to pupil numbers close to the school.

DLP_1012

Mrs Alison Mighell

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Site 45 - Land adjoining Birchwood Avenue and Dower House Crescent:

I am extremely pleased that Site 45 has not been allocated in the Draft Local Plan. I agree with conclusions made in the SHELAA that the site is a Green Belt location and the release of which would cause harm to the Green Belt and landscape. I also agee that there is a lack of key services and facilities within a desirable walking distance from the site. I am pleased that its location adjacent to Ancient Woodland and a local wildlife site and wildflower meadow has also been taken into consideration.

I feel strongly that Site 45 would not be a suitable site for building as the local infrastructure could not cope with the number of extra people needing to use local services and schools, and the number of cars trying to join the A26 or using short-cuts through Bidborough village would be unacceptable. There is too much traffic as it is and the roads cannot cope.

Therefore, I agree with the Council's decision regarding Site 45.

DLP_1022

Ms Sally Moesgaard-Kjeldsen

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

RE:      THE NON PROPOSAL OF THE PLANNING ON CAMP FIELD, SITE 45.

I refer to my previous letters to yourselves.

After my delightful telephone conversation with your Ellen Gilbert this afternoon at 14h00 in which I was advised by Ellen that planning on Camp Field was not on your agenda at present, I would like you to kindly ignore my recent letters, however I would like them kept on file.

I must apologise, I was advised on a Social Net Work that the proposal was going to be considered, now that it is not,  I am delighted and relieved for the following reasons.

Camp Field is the only Green Belt we have left in this area for families, children and dog walkers to enjoy.

It is historical land.  The trees, plants, fungi  and fauna emit oxygen.

There is an extinct species of newt living there, and many other wild animals, insects, birds, reptiles and amphibians and Bees.  Where will they go?  they have already had to move from other areas.

We do not have the infrastructure around this area, today I was in a 20 minute traffic jam in London Road where two huge juggernauts (left hand drive) had clogged up the road.  It took me 30 minutes to get from the  Magestic Wine Shop to the the Old Weavers Restaurant.

We would need extra sewerage and water pipes laid, would they be able to cope.

Our roads are already covered in Potholes which should be repaired.  We do not have the roads to cope with 207 new houses, which would potentially mean 414 cars, as every family has at least two.

We have not got the schools to cope, many children didn't get into their preferred schools in this area especially Bidborough School.

We already have a problem with speeding cars along Bounds Oak Way and the fumes they emit.

DLP_1794

Antony Edwards & Susan Hawkridge

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

Will you please add these comments below to the submitted sites not included in this draft local plan.

We are pleased to hear of your decision not to include the above Site 45 in the Draft Plan. From our point of view preserving the site  maintains an important buffer zone between the wildlife in the AONB and the suburban activity of Southborough.

Additionally your decision promotes the minimising of the toxic effects of the busy A26 on the local population. Air quality would significantly deteriorate in the area generally should this site be developed.