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General Comments (Index of Policies and Foreword)

This response report contains comments received on General Comments (Index of Policies and Foreword).


General comments

Comment No.




Mr Peter Lovering

I appreciate that the Council has felt compelled to make provision for a large number of new dwellings within the Borough in order to comply with instructions issued by central government. However, I feel that the Council should have protested against those instructions instead of meekly accepting the targets imposed from above without protest and, as I understand it, endeavoured to exceed them. The housing crisis in the south-east of England is a London crisis. Demand for housing exceeds supply in London, with the result that prices have risen to unaffordable levels. Central government can address this by increasing housing density within London, and by ensuring that all existing dwellings are fully occupied. Building new housing outside London, whether in our Borough or elsewhere, in excess of the natural growth in local demand is not a sensible solution to London's problems, as newcomers whose jobs are in London will need to commute to the capital, wasting valuable time and placing an intolerable burden on roads and rail links.

These are matters beyond the control of TWBC, although energetic protests should be directed at the relevant Whitehall department in an attempt to change government policy. However, even if one accepts that these targets must be met, I would argue that the Council's strategy at a local level is seriously mistaken. The proper response to a perceived housing shortage in our Borough is not to build on the Green Belt and Areas of Outstanding Natural Beauty, as proposed, destroying prime agricultural land and beautiful, irreplaceable countryside. Instead, the responsible solution is to build on brownfield sites. This does not simply mean redeveloping redundant bus garages and gasworks, desirable though those measures are. More radically, the Council should aim to redevelop existing towns at far greater density.

To take Tunbridge Wells itself as an example: there are many single-storey shops, for instance on Mount Pleasant and Camden Road, that could be redeveloped as three-storey buildings, with or without retail space at ground level. There are also two-storey terraces, with shops at ground level, that could be redeveloped as three-storey buildings, for example on Vale Road.

More radically, I would suggest that the decline in retail and rise of internet shopping means that the North Farm retail park is larger than it needs to be. Certainly, much of the land there is wasted and used inefficiently. The Council should work with developers to concentrate the retail sheds that we actually need in a much smaller area, freeing up the remainder of the land, perhaps half the total, for housing development. Do we need to allocate so much land, there and elsewhere, to car parking? It seems clear that car use is going to have to be drastically reduced in the future to tackle the climate crisis. Do we really need to use so much land for car parking? Wouldn't multi-storey car parks be preferable to huge expanses of tarmac?

Large amounts of land that could be used for housing are currently occupied by railway lines, a legacy of the days when land was cheap and plentiful. That is no longer the case, so we need to adopt a different approach. We could build over railway lines in the middle of our towns; in particular, I would argue that the area where the High Street meets Mount Pleasant, Vale Road and Grove Hill Road should be redeveloped, with a new station being built down at track level and housing built on a platform above the lines. Hundreds of homes could be built where at present the only residents are pigeons. The Vale Road car park and the Range below it should also be demolished and redeveloped as housing.

I would also argue that redundant buildings such as unused churches (not to mention the Civic Centre) should be demolished and redeveloped. I realise that these are often listed buildings but, in my view, it would be better to sacrifice a crumbling Victorian church or characterless town hall rather than irreplaceable countryside. The Council should fight the central bureaucracy on behalf of local residents instead of accepting directives handed down by central government.

I find it astonishing that the Council's response to the housing crisis is so timid. Radical rebuilding of our towns at greater density is needed, not piecemeal redevelopment of individual sites. Why have the shops, music centre and Black Pig pub on Grove Hill Road not been redeveloped as one, rather than a single plot of land being used for new flats? Why does the proposed new development on the old cinema site in the centre of the town not extend down to Lonsdale Gardens, instead of leaving a row of unsightly single-storey shops to blight our town? And surely it would have been better to demolish the auction house on Linden Park Road and redevelop it instead of converting it to offices, leaving the site under-utilised.

Too often the Council (and developers) prefer to take the easy (and cheap) option: build on green fields, where no messy clearance works are needed and a single landowner is involved. This brings me to the most outrageous, deplorable and utterly unacceptable aspect of the Council's plan: the intention to build a new town at Tudeley. No doubt it seems like an easy solution: mark off a large area of countryside on a map and build on it, producing lots of housing with the minimum of effort and maximum profit. However, the environmental damage caused by this project is unaffordable and we will be cursed by generations yet unborn if we allow beautiful countryside to be destroyed and replaced by characterless housing estates that suit the convenience of the rapacious developers and no one else. People don't want to live on a sprawling housing estate in the middle of nowhere, filled with characterless, ugly houses, and dominated by roads to be used by pollutant-emitting cars, even if you call it a 'garden town'. In most cases, they want to live in London, close to its jobs and amenities, and that is where the new housing should be built.

I would urge the Council to be more imaginative and to push back against the intolerable demands of central government; to rebuild Tunbridge Wells and other towns at higher density, making the maximum use of the existing footprint; to view the decline of retail as an opportunity, not a threat, since it will allow us to convert sites currently dedicated to shopping (and the accompanying car parks) to residential accommodation; and above all to resist the temptation to build on open countryside in the belief that it represents an easy solution when, in reality, it will simply cause the needless destruction of our precious natural landscape with no commensurate benefit.


Rupert Lovell

While it acknowledged that rural communities such as Horsmonden need to accept some new development (housing), the scale of dispered growth proposed in the draft local plan is out of all proportion to what most rural communities, including Horsmonden, can sustainably and practically accommodate.

The large main towns in Kent have access to more 'brownfield' sites. Development of such sites is far more sustainable than developing the greefield sites proposed in rural communities. The development sites proposed in Horsmonden are highly valued tracts of greenfield rural countryside with distinct landscape character and important biodiversity and cultural associtations. Their development is simply not sustainable and at odds with various policies in the NPPF. Overall the development proposed for Horsmonden village need to be significantly scaled down.


Chris Gow

If you want the consultation to be fully participated by the local community, the process could be much simpler, the navigation of the response is not user friendly to less able and computer inexperienced participants.

The amount of supporting documentation and the use of numerical titles rather the friendly names does not make the process helpful.

The downloads are 1.5Gb of data, and result in 16641 pages, (including title and blank pages), so it is not easy to fully understand and even read everything that relates to the Local Plan.

This does not readily appear to be a clear and transparent delivery of the relevant material, and more use of summary documents could have been available to help your respondents.


Thomas Weinberg

Comments on the Foreword p.12

The result of this document has been to cause several communities who love their homes and surrounds with fear and anxiety. It does without providing any clear evidence for why new houses need to be built on green belt land.

We live in this area for family health reasons. This development would unquestionably diminish the health of my family. Pollution, noise and destruction of habitat would be unavoidable.

There are also clear challenges to the impartiality of this document: Cllr McDermott has created through agreeing to Chair every group, I’m sure unwittingly, an inability for the Council, the Planning Policy Working Group, the Planning & Transportation Cabinet Advisory Board and the Cabinet to be in any way impartial or independent when addressing these issues.

In any industry or institution, public or private, this would be considered an unwise and questionable accrual of influence. There should be absolute distinction between the TWBC Planning & Transport Cabinet Advisory Board and the TWBC Cabinet.

Alongside this the Borough Councillor for Capel has campaigned for a Colts Hill Bypass (the offline A228) to lessen traffic directly outside her house. This is a significant conflict of interest as the draft Local Plan proposes massive amounts of housing with creation of the offline A228 as a direct beneficiary from developer contributions from this housing.

These two factors make an already highly contentious plan to destroy communities and the green belt they sit within unsound and deserving of at the very least an independent review.


The Access Group


3.1 I recently visited the Cotswolds where many of the villages are having to face an increase in housing development. The conditions imposed by the LPA's means that the height of housing and the design creates a seamless and harmonious outcome and does not in any way detract from the existing ancient housing, also these new properties are independently accessible. The major exception was Cheltenham which is a large town and may well grow to become a city; here too wherever possible the LPA has ensured harmony with existing buildings.

3.2 This should be the key requirement by our LPA and they should not be afraid to impose strict conditions upon developers, especially with regard to the three legal demands. [TWBC: see Comment Numbers DLP_66-67] Both the All Party Political Group for Disability Chaired by the RT Hon Dr Lisa Cameron MP of which I am an adviser/member; the Minister for the Disabled requires this as part of the government "Welfare to Work Programme" and meeting total compliance with the requirements of the UN Convention by 2025 and the Planning Minister (DfHC&LG) who has made clear that the needs of all disabled people must be met.

3.3 Likewise, the Supreme Court have already made clear that the legal requirements imposed by the UN Convention & The UK Disability Strategy 2012 are "stand alone" from the Equality Act 2010 and must be complied with, irrespective of cost.

3.4 May I remind you, the LPA and the Council, since 2000 when Tony Blair introduced the legally binding "Equality Standards in Local Government Targets 2000" (ESLG), which require, at the lowest compliance level, "adoption and full compliance with the UN Convention also known as the Social Model of Disability", there has been, according to the Cabinet Office in 2018, "an expection of total compliance by all local authorities by 2025 with the requirements of the ESLG". TWBC and KCC both produced in 2001 their disability policies which they have so far failed to uphold, which will leave them post 2025 vulnerable to litigation which will doubtless, according to our legal advisers, cost millions of pounds in fines with an addition bill for compensating all disabled residents within their area currently set at £10000 per disabled person. this is without doubt the "ticking time bomb" that all local authorities and the government face post 2025 and requires urgent action.

As a Disability Access Group our prime concern is to ensure that the requirements of the Planning Inspector's order is enforced, irrespective of the cost, to provide total independent access for all to buildings, dwellings, workplaces and townscapes. Within this document which applies to the proposed developments there is no clear requirement to ensure this, which implies that the council is not inclusive and not prepared to enforce total inclusion and independent access which amounts to de facto discrimination against all people with disabilities including the elderly.

I have been instructed by our members to seek from the Planning Team a written apology and assurance that the LPA will enforce all the legal demands and conditions we have suggested.


Roger Bishop

Miscellaneous important comments

  1. I can see no evidence in the Plan that TWBC have   considered using the freedoms given to councils in late 2018.

    Below is a direct quote from

    “The government is committed to delivering 300,000 homes a year by the mid   2020s and has today (1 October 2018) announced further plans to speed up the   planning system as well as make better use of land and vacant buildings to   provide the homes that communities need. (My emphasis)

    Local authorities will also receive additional freedom to make the most of   existing brownfield land and dispose of surplus land that could instead   accommodate new homes”. (My emphasis)

    2. Action on Empty Homes and Nationwide reported recently (the Times, 23   September 2019) that the number of empty homes increased by almost 11000 last   year and now stands at 216000. Why build more, when homes stand empty, and,   as in Paddock Wood, houses are not being built on sites where there is   planning permission already?

[TWBC: see also Comment Numbers DLP_81 to 93].


Gregg Newman

Opening Comments 

It appears to me that the Draft Local Plan has been drafted in such a way as intentionally to mislead the voters and public and is yet another example of the failure of local government (and national government) to represent both their constituents and also the planet as a whole with short-sighted, ill thought through schemes that do not serve either future generations or the other inhabitants of our planet that cannot speak for themselves, be they trees or wildlife.

This should also be read in conjunction with objections to the extension of quarry adjacent to this development which is also destroying unique habitats and AONB.

Your plan also endangers human lives, particularly those of children – see below for an explanation of this. There will be deaths in the winter months, and you would be well served to think long and hard about this before any such deaths end up on your consciences. This is not scaremongering – I am an ex-Policeman who has faced the realities in the past of ill thought through plans.


Forestry Commission

Local Plans and ancient woodland – Forestry Commission approach

The Forestry Commission is not in a position to input into the consultation process for Local Plans.  However, the information below is provided to assist you in assessing the appropriateness of sites for future development, and to highlight opportunities for achieving your renewable energy obligations.

A summary of Government policy on ancient woodland 

National Planning Policy Framework (Published July 2018)

Paragraph 175c

“development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient trees or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists”

Natural Environment and Rural Communities Act 2006 (published October 2006).

Section 40 – “Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity”.

National Planning Practice Guidance – Natural Environment Guidance.  (Published March 2014)

This Guidance supports the implementation and interpretation of the National Planning Policy Framework.  This section outlines the Forestry Commission’s role as a non-statutory consultee on  “development proposals that contain or are likely to affect Ancient Semi-Natural woodlands or Plantations on Ancient Woodlands Sites (PAWS) (as defined and recorded in Natural England’s Ancient Woodland inventory), including proposals where any part of the development site is within 500 metres of an ancient semi-natural woodland or ancient replanted woodland, and where the development would involve erecting new buildings, or extending the footprint of existing buildings”

It notes that ancient woodland is an irreplaceable habitat, and that, in planning decisions, Plantations on Ancient Woodland Sites (PAWS) should be treated equally in terms of the protection afforded to ancient woodland in the National Planning Policy Framework.  It highlights the Ancient Woodland Inventory as a way to find out if a woodland is ancient.

Standing Advice for Ancient Woodland, Ancient trees and Veteran Trees.  (Published November 2018)

The Forestry Commission has prepared joint standing advice with Natural England on ancient woodland and veteran trees which we refer you to in the first instance.  This advice is a material consideration for planning decisions across England.  It explains the definition of ancient woodland, its importance, ways to identify it and the policies that relevant to it.  It also provides advice on how to protect ancient woodland when dealing with planning applications that may affect ancient woodland.  It also considers ancient wood-pasture and veteran trees.

The Standing Advice website will provide you with links to Natural England’s Ancient Woodland Inventoryassessment guides and other tools to assist you in assessing potential impacts.  The assessment guides sets out a series of questions to help planners assess the impact of the proposed development on the ancient woodland.

The UK Forestry Standard (4th edition published July 2017).

Page 23 “Areas of woodland are material considerations in the planning process and may be protected in local authority Area Plans.  These plans pay particular attention to woods listed on the Ancient Woodland Inventory and areas identified as Sites of Local Nature Conservation Importance SLNCIs)”.

Keepers of Time – A Statement of Policy for England’s Ancient and Native Woodland (published June 2005).

Page 10 “The existing area of ancient woodland should be maintained and there should be a net increase in the area of native woodland”.

Natural Environment White Paper “The Natural Choice” (published June 2011)

Paragraph 2.53 - This has a “renewed commitment to conserving and restoring ancient woodlands”.

Paragraph 2.56 – “The Government is committed to providing appropriate protection to ancient woodlands and to more restoration of plantations on ancient woodland sites”.

Biodiversity 2020: a strategy for England’s wildlife and ecosystem services (published August 2011).

Paragraph 2.16 - Further commitments to protect ancient woodland and to continue restoration of Plantations on Ancient Woodland Sites (PAWS).

Renewable & low carbon energy

The resilience of existing and new woodland is a key theme of the Forestry Commission’s work to Protect, Improve and Expand woodland in England we will continue to work with Forestry / Woodland owners, agents, contractors and other Stakeholders to highlight and identify, pests and diseases and to work in partnership to enable Woodlands and Forests are resilient to the impacts of Climate Change.

Woodfuel and timber supplies continues to be an opportunity for local market growth whilst also enabling woodlands to be brought back into active management.

Flood risk

The planting of new riparian and floodplain woodland, can help to reduce diffuse pollution, protect river morphology, moderate stream temperature and aid flood risk management, as well as meet Biodiversity Action Plan targets for the restoration and expansion of wet woodland.

The Forestry Commission is keen to work in partnership with Woodland / Forest Stakeholders to develop opportunities for woodland creation to deliver these objectives highlighted above.

In the wider planning context the Forestry Commission encourages local authorities to consider the role of trees in delivering planning objectives as part of a wider integrated landscape approach.  For instance through:


Mr David Smith

General Comments:

1. The exhibition Program tries to encourage all comments to be made via the TWBC website. There is no mention of other ways to comment for those who do not use the Internet. Reinforcing the impression that TWBC have no interest in receiving comments from such people, there were no forms on which to provide instant written comment whilst at the exhibition on this date. Comments written down at that time are certain to be received and are therefore likely to be more representative of the general public feeling than those made later since a proportion of people intending to reply later may either forget to comment on-line or find later they do not have the time to do so or perhaps try but are unable to do so for a variety of other reasons. Nowhere on your web site could I find details of where and to whom written comments should be sent. The need to register and log in to provide comments on-line is likely to dissuade those who are not computer-literate from commenting, which is grossly unfair to the point of discrimination.

Furthermore, the structure of the on-line commenting process where the complete plan for the entire area is set out in full and then broken down into ever more detailed sections makes it extremely time consuming and tedious for a resident of any specific town or village to locate the appropriate section in which to make their comments. It is a highly structured bureaucratic process which may seem easy to those already familiar with it but which requires a good deal of concentration in the on-line situation which some residents might find challenging and therefore give up on. Whilst this form of consultation may be very efficient for the council staff who therefore do not have this categorisation work themselves, it is clearly very likely to dissuade some less academically gifted or computer literate individuals from using that form of commenting and therefore underestimate considerably the strength of feeling in the community. Frankly it appears to me to be blatantly anti-democratic. I am not aware of any demonstration that this form of consultation is genuinely representative and until it is shown to be valid, unbiased and fully representative individual written comments should be encouraged, not dissuaded.


Dr P Whitbourn

I wholeheartedly agree with the opening words of the Foreword to the Draft Local Plan, that "our borough is a great place to live, work or visit", and I am deeply concerned that this should continue to be the case, particularly with regard to its principal historic town of Royal Tunbridge Wells.

The Foreword goes on to point out that the Local Plan provides "an opportunity to look afresh at what sort of place we want" in the future. I am very clear about what I want, namely that, set in the "garden of England", our inland spa town of Royal Tunbridge Wells should be a fine, vibrant and attractive historic DESTINATION town, that is to the south of England as Harrogate is to the north, and Cheltenham is to the west country.

The foreword then makes the further point that achieving a balance between growth, on one hand, and safeguarding the special historic environment on the other, can be difficult.

That balance has, in my view, been tipping away too far from safeguarding side of the scales in recent times, with large and unattractive modern blocks receiving permission at Union Square on the Pantiles; at the former cinema site; and in Calverley Grounds. More of the same could quickly put our very special historic town in real danger of becoming like the despoiled Kentish towns of Maidstone and Ashford.

It is never easy to put the clock back but, looking forward, if we can get this new Local Plan right, there could be a great opportunity to be grasped for a better future.


Ian Pattenden

Your comments procedure is extremely difficult when we are expected to annotate each comment referring to a paragraph within your document. I believe this is a strategy to dissuade people from taking the time to comment. I have made my best efforts to comply with this clumsy and time consuming requirement on the basis that if I do not my comments MAY BE IGNORED.


Roger Bishop


Below are extracts from a speech made on 23 October 2019 by the Rt Hon Robert Jenrick MP Housing Secretary, taken from

In 3 areas at least, highlighted below, his speech suggests that TWBC’s Plan contravenes Government policy.

Vision and Objectives 2 – p32

Preserving Green Belt

Another of my predecessors, John Prescott, in a classic of the genre that he created of inadvertent phrases, he said when he was addressing a Labour Party Conference as Housing Secretary that the green belt was a great post-war achievement, and I intend to build on it.

That isn’t one of my priorities, Number 10 will be pleased to hear if they’re listening to this speech.

Local Heritage

Protecting the historic environment must be a key function of the planning system.

All local planning authorities must play a far more proactive role in supporting local communities and heritage groups to identify and to protect more historic buildings.

In the 1980s, Michael Heseltine reinvigorated our national heritage lists. And now I want to complete that work and to do the same at the local level.

As a first step, I am announcing, what I think will be the most ambitious new heritage preservation campaign since Michael’s work 40 years ago.

Re-use of buildings and using brownfield sites

For the country to cut its carbon footprint, drive sustainability and meet our net-zero targets, all of us – in industry and in government – have a responsibility to promote the re-use of existing buildings.

We also need to be ambitious, creative and imaginative in repurposing commercial and public buildings.

I will certainly be supporting initiatives likes that, through the planning system and through my powers as Secretary of State. Bringing new purpose to brownfield land to historic buildings, to get people back to living in empty homes.


Mr and Mrs Copping


I am a working mother who has limited time to respond to this consultation. I have tried to cross reference the 545 page draft Local Plan Regulation 18 consultation draft 20th September to 1st November 2019 to allow me to fill in this form; however,  I was not able to do so. I would question if any residents within the Borough have found this process easy to understand


Tom Tugendhat MP

Please accept this letter as my official response to the Tunbridge Wells Borough Council (TWBC) Draft Local Plan, Regulation 18 consultation, which is currently in progress. Though I do not represent any part of the borough of Tunbridge Wells in Parliament, I am taking the time to respond to the consultation as some of the proposals will have a direct impact on residents in Tonbridge, Golden Green, East Peckham and surrounding communities.

I appreciate this is highly unusual but it is clear from the draft proposals, as they stand, that the impact of development at many of the largest sites will not be on Tunbridge Wells borough, but Tonbridge and Malling. Mass development planned at Paddock Wood, Tudeley and on the very outskirts of Tonbridge will fundamentally change the lives of residents in these areas.

In responding to the consultation, I am drawn to the National Planning Policy Framework (NPPF) which sets the parameters of good planning. Specifically, Paragraph 16c which states that plans should:

"be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees".

Though I accept that we are at a very early stage of the plan making process, and the current timetable has an additional consultation to come before it is examined by the Planning Inspectorate, I am concerned at the short lead time between publication of the Draft Local Plan at the end of July 2019, and the current consultation. While residents in Tunbridge Wells may have been consulted ahead of time, this privilege did not extend to those in Tonbridge and surrounding villages. Consequently, in advance of the next consultation in 2020 I would urge TWBC to ensure greater engagement with those communities outside of its borough boundary, whom would be significantly disrupted by the proposals.

I would wish to start with a positive comment on the Draft Local Plan in that TWBC seeks to meet its objectively assessed housing need. Representing areas of both Tonbridge and Malling Borough Council (TMBC) and Sevenoaks District Council, I am well aware of the pressures on authorities with significant amount of Greenbelt and Areas of Outstanding Natural Beauty. Yet is is clear from both their own local plans that there is no available room to take any additional surplus from Tunbridge Wells. Therefore it is right that the objectively assessed housing need should be met in full.

This response will focus entirely on the impact on those communities I represent in Tonbridge and Malling. It would not be appropriate for me to pass comment on issues which do not affect residents here. While I appreciate there are significant concerns within the borough on the use of greenbelt, protection of ancient woodland, and other material planning considerations I do not feel it is the purpose of my response to comment on them. As Member of Parliament for Tonbridge and Malling my responsibility is exclusively to residents here and the impact of the Plan on them; this is my priority. I will, however, copy this letter to the Members of Parliament covering Tunbridge Wells Borough, The Rt Hon Greg Clark MP (Member of Parliament for Tunbridge Wells) and Helen Grant MP (Member of Parliament for Maidstone and the Weald), so they are aware of my concerns on the impact in Tonbridge and Malling of the proposals in this document.

I shall also limit my comments to those issues which I feel are crucial in respect of the Regulation 18 consultation. I note from the planned timetable that we should expect the Pre-Submission Local Plan to come out to consultation under Regulation 19 between August and September 2020 and it is during this period that I shall comment on the impact of the proposals, and whether the failure to address cross boundary issues would contravene any of the policies identified in the NPPF.

Yet many parts of the plan as it stands gives me great concern about the impact the proposals will have. I shall address these in turn.

[TWBC: the following site-specific comments have also been entered under the individual policies. See comment numbers DLP_1642 to 1649]

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

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

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

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

AL/CA 2 - Land to east of Tonbridge/west of site for Tudeley Village

Following the allocation at Mabledon, this is the next proposal that is closest to the borough boundary, and would have the biggest impact on residents in Tonbridge - by sheer virtue of the fact that the allocation is on the very outskirts of Tonbridge.

South Tonbridge has one of the highest concentrations of secondary schools for a town of its size in the whole country. This, along with the nature of our education system, puts immense pressure on the local road, bus, and rail network as travel to school plans are increasingly difficult to manage. Pupils often have to travel long distances to schools and it is right that Kent County Council (KCC) have strategic oversight of this. However, as we have seen recently with school expansion in Maidstone, even the slightest increase in a school's yearly roll, or a small change to its catchment area can disrupt bus services and bring gridlock to the area.

My concern is that a secondary school off Woodgate Way in Tonbridge would make peak time traffic movements in Tonbridge unsustainable. The site is not within easy walking distance of Tonbridge Station nor on the busiest bus routes in the town. Indeed, as things stand it is only services such as the 205 from Kings Hill which pass this location and this has only started this year. There is no doubt that this allocation would bring chaos to the already finely balanced public transport network in Tonbridge.

It is noticeable from the extremely detailed 544 page Draft Local Plan that there is absolutely no mention of the impact of this secondary school on Tonbridge. This gives me significant cause for concern and is a glaring omission from the Draft Local Plan. Ahead of Regulation 19 consultation it is urgent that the impact on Tonbridge is fully understood.

However, at Pages 163-164 we have the smallest of details available about the characteristics of the site itself. As I said at the start of this letter I am focusing this response on the impact on Tonbridge and Malling so won't comment on specific details within allocated sites. However, it is concerning that a high pressure gas pipe, presumably to serve residents in Tonbridge, runs from south to north through this allocated site and I would appreciate further details on where this gas pipe services, and the impact that development of a secondary school above it would have on residents should it be deemed acceptable here, of which I have my doubts.

Finally, I wish to add my support to the comments of TMBC on this allocation, which they strongly object to. They are right to say that a development of the size of which is proposed at Tudeley, as I will comment on shortly, is of a suitable size to encompass on site provision of a secondary school. The large employment site allocation on the neighbouring land in the TMBC Draft Local Plan, which is currently awaiting examination from the Planning Inspectorate, also needs to be considered. This site sits on the edge of Tonbridge's industrial heartland and, as a town steeped in history with close ties to the printing industry, any threat to this should be fully demonstrated.

In summary, a new secondary school on this site would have such adverse impacts on the town of Tonbridge that I strongly doubt whether it would be feasible to deliver.

AL/RTW 12 - Land Adjacent to Longfield Road, Tunbridge Wells

I also wanted to touch on Policy AL/RTW 12 in the TWBC Draft Local Plan in light of my previous comments about industry in Tonbridge. I note that the Sevenoaks and Tunbridge Wells Economic Needs Study, produced in 2016, is used as the document to inform the decision on where to allocate sites in the Draft Local Plan. I'm aware this looks at land around the A21 as a significant opportunity for further employment growth potential. However, there are two issues with this that bring me to have concerns about this allocation.

First, since 2016 there have been two important developments which might overstate this need. The first is the completion of the A21 dual carriageway between Tonbridge and Pembury. This is something I strongly welcomed - and even opened at its completion - but we must recognise that there are some design issues which need to be resolved. At the time of writing we do not have confirmation from Highways England that any identified works will be funded following the completion of the Road Safety Audit Stage 4 that is currently being undertaken. In the event that we are unsuccessful in getting any road improvements delivered, then I have concerns about development which would increase the volume of traffic using this road at peak times. Employment sites with an additional 80,000sqm floorspace across B1, B2 and B8 uses would generate huge traffic movements during the rush hour and the impact on the A21 both here, and further north towards Morleys Roundabout, gives me cause for concern.

Second, we have had the publication and submission to the Inspectorate of the TMBC Local Plan and its plans for employment land allocations in Tonbridge. Though TMBC have had to take some difficult decisions about the sites which it selected for development, they have sought to keep Tonbridge's industrial heart in the Cannon Lane and Vale Road area by rejecting the opportunity to replace employment land here with residential units.

I am concerned that this allocation, and the sheer size of it, does not account for the development which TMBC plans to bring forward for employment land too. As TMBC are further advanced with their Local Plan it is incumbent upon TWBC to address the issues which are raised in it, rather than vice versa. I am afraid I need more reassurance about this impact and wish for a better assessment when it gets to Regulation 19 stage.

STR/PW 1 and AL/PW 1 - The Strategy for Paddock Wood

The Draft Local Plan proposes approximately 4,000 additional homes on land at Capel and Paddock Wood. This gives me huge concerns, specifically for the impact on those neighbouring communities.

Over the past few years I, along with East Peckham Parish Council and many patients and local residents, fought hard to save the East Peckham Doctors Surgery. We managed to in the short term, before it shut last year and residents were forced to travel to Paddock Wood to access Woodlands Health Centre as their local GP instead. This was a shame but it was felt that £250,000 was needed to bring the existing surgery up to scratch, a figure which Woodlands did not dispute when I quoted this to them in a letter dated 31 January 2018 about the closure.

On Page 170 of the Draft Local Plan, I note that it is referenced that Paddock Wood has its own doctors surgery. This is seen as one of the justifications for such large scale development here. However, in order for the existing surgery to cope with the demand from 4,000 additional homes in the town alone it will need to expand, and repurchasing a branch in East Peckham would be the best way to achieve this. It would enable the village to keep its facilities for the local population and ensure that Woodlands Health Centre can adequately deal with the greater number of patients visiting it from Paddock Wood. Meanwhile, East Peckham gets its branch surgery back and reduces the need to travel into Paddock Wood. I hope this is an issue which TWBC will pursue alongside West Kent Clinical Commissioning Group (WKCCG) to ensure that a significant increase in the population of Paddock Wood will not impact on the ability of East Peckham residents to see a doctor.

Furthermore, an additional impact of the Paddock Wood development which gives me great concern is capacity on the Southeastern mainline. We are already seeing significant development in the adopted Maidstone Borough Council (MBC) Local Plan in Marden, Staplehurst and Headcorn, the next stations down the line. The justification used by MBC to designate each of these areas as Rural Service Centres was that they had a railway station. Indeed, as some of these developments have been brought forward and built out they have already gone above the indicative figures in the MBC Local Plan. For example at Marden, Land South of The Parsonage on Goudhurst Road has an allocation for 50 dwellings, yet planning permission was granted for 65 dwellings in 2017. This represents an uplift of almost an additional third of the site allocation.

Consequently, we must accept that there will be significant additional demand on the rail network from Maidstone borough, and I am hugely concerned that, coupled with the volume of development proposed at Paddock Wood, it will result in overcrowding from these stations on the Southeastern mainline. At present, Tonbridge is the last realistic stop where passengers heading to London can expect a seat, and on the way back commuters are almost always standing from London Bridge. With further stops at Orpington and Chelsfield planned by the Department for Transport in the Invitation to Tender for a future Southeastern franchise, this line will only get busier.

I am hugely concerned that the only perceived impact on the rail network identified in the Draft Local Plan is the need for improved vehicle and cycle parking at Paddock Wood station. While this may be needed, it will do absolutely nothing to mitigate the impact of the development on commuters from Tonbridge and only seek to encourage more people to use the Southeastern mainline. I am extremely disappointed that there is no assessment of this and would urge TWBC to include this as part of their Regulation 19 consultation.

STR/CA 1 - The Strategy for Capel Parish and AL/CA1 - Tudeley Village

Finally, I wanted to comment on the allocation for the strategic site at Tudeley which has probably attracted the most publicity in the run up to this consultation. It has certainly galvanised the interest of residents in Tonbridge and Golden Green since the proposals were published a few short weeks ago and from the allocation it is obvious to see why.

The boundaries of both Tonbridge and Golden Green are very clear and self-defined. On the south east of Tonbridge, Woodgate Way forms a natural buffer between the town and the countryside, and in the most part acts as the borough boundary as well. In Golden Green, the River Medway acts as a natural boundary between it and Tudeley. The result is that development here cannot be considered to be congruous with either settlement. The lack of acceptance that development at Tudeley would provide north-south traffic movements between it, Golden Green, Hadlow and East Peckham is striking of the need for additional work.

As I mentioned in my response to STR/PW 1 and AL/PW 1, the impact on the rail network is one of significant concern for any development on or near the Southeastern mainline. In the most likely event that a railway station is not built at Tudeley, residents will use Tonbridge station as their closest and I have significant concerns about the travel connections between Tudeley and Tonbridge.

First, considering the most sustainable form of transport, there are no cycle paths between the development and even if one was constructed along the B2017, there are many questions about the route it should take in Tonbridge. For a number of years I have been campaigning alongside Kent County Councillors, Richard Long and Michael Payne, as well as Tonbridge Bicycle Users Group to connect Tonbridge Station with the A21 Non-Motorised User Route and we have found agreeing an acceptable route with all parties extremely difficult. There are no indications that this would be any easier from Tudeley. Consequently, we cannot rely on the bicycle as being a primary and suitable mode of transport for residents in Tudeley.

Furthermore, parking capacity at Tonbridge station is already both limited, and expensive. Access to the car parks can be tricky, especially on the way in from the B2017, with cars having to go through Sovereign Way and Avenue du Puy to get there. This area is also frequently congested at peak times with existing business access, and possible improvements to the road network are limited. Consequently, development of this scale at Tudeley would have an unacceptably high impact on the centre of Tonbridge, and one which I highly doubt can be appropriately mitigated.

It is essential that TWBC looks at the impact of development on key junctions in Tonbridge if its proposals are to be progressed any further. If this does happen, it is down to TWBC to suggest ways that these will be improved which will not have an adverse impact on the quality of life of residents in Tonbridge, will come with the agreement of KCC and TMBC and, crucially, will not be funded by them either.

Turning to Golden Green, it is not possible to adequately assess the impact of development near the village without referencing the terrible flood events which have caused so much trouble for people here in recent decades. Like Tonbridge, in 2013/14 the flooding event hit Golden Green hard and the suitability of the land in the immediate area for further development is questionable. At the time of writing, the River Medway Flood Relief Act 1976 has yet to be amended and consequently we must assess these proposals on the basis that improvements to flood defences at the Leigh Flood Storage Area don't happen as quickly as we would like, although I am confident that they will be delivered. In light of any additional flood defences in the Golden Green area, I have my concerns that the increase in development will increase the flood risk and would request that TWBC engages closely with the Environment Agency to produce accurate models for the Regulation 19 consultation under all eventualities. Of course, these models should extend to Tonbridge as well.

Finally, I wish to cover the health provision needed to make this development acceptable. I am hugely concerned that these have not been identified and cannot find any reference in the Local Plan to the number of GPs needed to serve this development, and where they will be located. My concern is based on my experience representing Leybourne Chase. While TWBC may not be aware, this development of 733 dwellings came with provision for a GP surgery. However, now 5 years on from the first occupation, there isn't a GP on site, with discussions now taking place about changing the use of the building through the planning process.

Like in Leybourne Chase, neighbouring practices are full and in Tonbridge WKCCG has to allocate surgeries to new residents because of their closed lists. Therefore GP facilities are needed on site, but only if agreement can be found with a GP provider to take on ownership of the building. If this doesn't happen, development should not be permitted here as it would put an additional burden on the three Tonbridge GP practices.

In addition, shortly following the conclusion of this consultation we eagerly await the result of WKCCG's study into the need for hubs across West Kent. In Tonbridge Cottage Hospital we have the ideal site for one of these to serve residents across Tonbridge and the borough of Tunbridge Wells and I am concerned that the vague nature of the policy in the current Draft Local Plan leaves open the possibility for a hub to be located at Tudeley. This would no doubt be used as a reason to make any development acceptable, but would also undermine the viability of Tonbridge Cottage Hospital. Therefore, I urge TWBC to do much more work on the health impacts of these proposals on a strategic level ahead of the next consultation.

In summary, based off the available evidence it is clear that the development proposals at Tudeley would fundamentally change the character and nature of Tonbridge and Golden Green. I am hugely concerned that many of the key issues have not been adequately assessed so far and urge TWBC to complete this work so we know what the impact is on communities across the borough boundary. Without this being done, the Draft Local Plan cannot be considered sound, and I would not be surprised at all if it demonstrated that there was an unacceptable impact on towns and villages in Tonbridge and Malling as a result of these proposals.

I appreciate that this is a long response but hope you understand the severe impact which some of the allocations in the TWBC Draft Local Plan will have on Tonbridge and Malling. I look forward to you addressing these issues ahead of the Regulation 19 consultation next summer.


Wood E&I Solutions UK Ltd for National Grid

Tunbridge Wells Borough Council: Draft Local Plan Consultation SUBMISSION ON BEHALF OF NATIONAL GRID

National Grid has appointed Wood to review and respond to development plan consultations on its behalf. We have reviewed the above consultation document and can confirm that National Grid has no comments to make in response to this consultation.

Further Advice National Grid is happy to provide advice and guidance to the Council concerning our networks. If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us.

To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, National Grid wishes to be involved in the preparation, alteration and review of plans and strategies which may affect our assets. Please remember to consult National Grid on any Development Plan Document (DPD) or site-specific proposals that could affect our infrastructure.


Brenchley and Matfield Parish Council

1. Introduction 

a. The Council welcomes the opportunity to comment on the proposals set out in the Draft Local Plan (DLP). Members are appreciative of the significant amount of time and other resources that have been dedicated to formulating the Plan and recognize the considerable energy that has been brought to bear on evidence-gathering, research, and the compilation and analysis of data.

b. Regarding the “Vision and Objectives” of the DLP, the ambition for the borough to be “vibrant and prosperous” is well-said. We are encouraged by the consideration given to expanding the base for economic activity, and for enhancing the facilities to support sustainable growth. However, given the constraints imposed by the AONB and the Metropolitan Green Belt, we would question the validity of the scale of housing development being proposed, and, as noted below, TWBC’s acceptance of the centrally-imposed target for that housing. The proposed strategy will cause considerable harm to the protected status of the landscape, by doubling the size of Paddock Wood, and creating a wholly-new settlement in Tudeley. The Council will stand with communities in those areas to resist those developments.

c. In formulating this response, the Council engaged with the local community through two public meetings, to present the DLP to residents and businesses. These meeting were in addition to the exhibitions provided by TWBC. At each meeting the Council’s independent planning advisor made a presentation summarizing the contents of the DLP and highlighted the key issues – as they relate to the borough as a whole, and the particular relevance for the parish. Subsequently, the Council received copies of the responses submitted by residents to TWBC. The key issues from those responses have been incorporated into this response.

d. Concern has been expressed by residents about the “under-powered” nature of the consultation arrangements – even taking account of the exhibition events. More resources must be found for the next phase of consultation, to provide additional opportunities for residents, community groups, and businesses to properly engage in determining the future direction of our borough.

e. In common with other Local Councils in the borough, this parish is engaged upon the preparation of a Draft Neighbourhood Development Plan (DNDP). As the completed NDP will need to be in general conformity with the Local Plan, this response makes reference to policy matters relevant to that requirement.

2. The Local Plan Development Strategy

a. We are not convinced that the case for the approach of dispersed growth across the borough has been soundly made. It is too far removed from the aims of the adopted Core Strategy which recognizes that rural settlements, such as those in Brenchley and Matfield, are least able to support sustainable development. The majority of responses to the five strategy options set out in the Issues and Options consultation did not favour dispersal or semi-dispersed growth across the borough. Crucially, dispersed growth would not conform to the requirements of the National Planning Policy Framework (NPPF).

b. Attention is drawn to paragraphs 102 and 103 of the NPPF (February 2019) which concern the need for plans to locate development so as to reduce the need to travel and to increase the scope for walking, cycling and public transport. In addition, paragraphs 171 and 172, which seek to conserve and enhance Areas of Outstanding Natural Beauty (AONBs) by limiting the scale and extent of development within such designated areas: 77% of the parish is with the High Weald AONB. Accordingly, the Parish Council objects to the dispersed growth strategy for housing development, as set out in the Draft Local Plan. This is because it directs a disproportionate amount of growth to rural settlements with limited facilities and jobs, and with poorer access to public transport. These rural settlements have higher dependence on the private car and access to them is generally along low capacity rural roads and lanes.

c. The issue of a high dependency on the private car highlights a significant weakness in the strategy. It can be argued that whilst a number of the general policies in the DLP (for example STR6 and EN2) are aimed at reducing car dependency, one of the effects of the dispersed growth strategy would be to substantially undermine the intentions of those policies.

d. It is extremely disquieting to read in Section 3 of the Development Constraints Study (DCS) that “as it stands, there is not yet the evidence in place to arrive at a definitive conclusion as to how highways capacity could impact on the development strategy for the new Local Plan. The Council will work with its partners, including Kent County Council and Highways England, to carry out relevant technical work and assessments…” From that statement it is assumed the reverse is also not quantified - that is, the impact of the adopted development strategy on the highways capacity is similarly not known. This is a significant weakness in the DLP and raises questions over the deliverability of the planning strategy.

e. A further significant weakness is the incomplete Infrastructure Delivery Plan (IDP). It is disappointing to note in the column marked “Expected Funding Gap” that the contribution of all of the third-party agencies is given as “TBC”. Residents and businesses cannot see how the DLP can be considered credible and deliverable without an IDP specifying core infrastructure assets being in place and ready by construction or occupation of the first phase of house-building.

f. Given the situation with the IDP, we would urge TWBC to quantify the impact of the proposed developments on the residents and businesses in Brenchley and Matfield. In particular: the prospect of increased congestion at the junction of A21 and the B2160 at Kippings Cross; the B2160 through Matfield; and other roads that would be affected by proposed developments in Paddock Wood and Horsmonden.

g. The most significant consequence of the policy of dispersed growth is that the area covered by five local councils in the north-east of the borough would take the lion’s share of housing development. An arc, roughly comprising Horsmonden, Brenchley and Matfield, Paddock Wood, Capel, and Pembury, has been allocated in excess of 7,000 units. However, we cannot find any acknowledgement in the DLP that this “quadrant” is to be the focus of the proposed development strategy, or, if so, that it is the priority area for infrastructure investment. Nor is there any indication of the cumulative impact of development across the arc. Whilst it is recognized that a master-planning approach would be taken in the development of the strategic sites, this does not go far enough in dealing with such issues as the social, economic, and environmental infrastructure needed to support development on that scale.

h. There is also no indication that the potential coalescence of settlements and parishes has been properly addressed. An obvious example of this is the proposed extension of Paddock Wood into Capel. Within Brenchley and Matfield we are concerned that it appears (on a map on p.174) that Mile Oak, one of the historic hamlets in the parish, and a section of Chantlers Hill, would coalesce with new development in Paddock Wood – both of which would be vigorously resisted. We are also concerned that the extent of development to the south of Paddock Wood could erode the size of the gap in the landscape which separates it from Matfield. The development strategy must include the provision of a landscape policy to prevent the coalescence of settlements.

i. In addition to being contrary to the aims of the AONB designation, the proposed development strategy also rides roughshod over policy aimed at protecting the Metropolitan Green Belt. It is not clear to us what the “exceptional circumstances” are that would warrant such an approach. The intention not to replace land lost to development runs counter to the conclusions of TWBC’s own review of the Green Belt, for which no convincing evidence is offered.

j. Given the foregoing, it is clear to us that an adopted policy of dispersed growth would cause the irreversible loss of character and separate identity of some of our villages and hamlets. This will also loosen the bonds of vibrant localities that promote cohesive social interaction and which underpins the well-being of communities. We therefore do not think that the proposed development strategy would be in the public interest and, if implemented, would cause significant harm to both the AONB and Green Belt designations. TWBC is strongly urged to consider retaining a development strategy which continues to recognize the need to protect the rural areas, and which concentrates development in sustainable locations, either in or adjacent to the main urban area (Royal Tunbridge Wells and Southborough), or along transport corridors with high capacity.

3. Mitigating the Impact of Development 

a. Should the proposal to concentrate development within the north-east quadrant be taken forward, the Council would argue strongly that it be conditional on significant improvements to the A228 – indeed, we would press for a re-alignment of the road to support the scale of development. It should also be conditional on all other forms of infrastructure, such as water supply, and sewerage disposal and treatment, to be delivered in tandem with development.

b. We would also press for significant development contributions from the strategic sites in Paddock Wood and Tudeley, to all five parishes within the quadrant. This would be to compensate for the individual and cumulative impact on the quality of life – particularly the substantial increase in traffic – on each parish and town.

c. The Council supports policy STR/PW1 Transport 5, which requires provision of improved vehicle and cycle parking at Paddock Wood railway station. However, we note that it only refers to retaining the Commercial Road East and West public car parks, not increasing public parking provision in the town centre.  Unless public parking in the town centre is increased substantially, the existing public car parks will be entirely taken up by residents from the outlying new developments, which will mean that residents of surrounding parishes, who rely on Paddock Wood as their local centre for much of their shopping and services and who have limited access to public transport, will be unable to park. This will also impact adversely on retailers in Paddock Wood, who depend on a turnover of parking places for shoppers, rather than having most spaces taken up from early morning to evening by London commuters. The Council will therefore wish to see a substantial increase in public parking in Paddock Wood town centre.

d. We do not support policy STR/BM1, which requires contributions from developments at Brenchley and Matfield to mitigate the impact of the developments in Paddock Wood. This exposes the absence of a clear approach to responding to the cumulative impact of development across the north-east quadrant. A sustainable approach would be to balance improvements to facilities (such as children’s playgrounds) that are within walking distance in the smaller settlements with the provision of larger-scale facilities (such as swimming pools) within Paddock Wood. It is not clear to us why contributions from developments in Brenchley and Matfield would be diverted to the Hop Pickers’ Line, which is not in the parish.

4. Meeting Housing Needs

a. It is recognized that TWBC has had to contend with the capricious requirements of government policy. However, in disregarding the Office for National Statistics’ forecast of 2016 (reducing the housing needs figure from 300,000 to 160,000), it appears to us that TWBC has unquestioningly accepted the number of housing units dictated by that policy – and has designed a development strategy which seeks to accommodate it. That doesn’t appear to us to be an approach that is likely to achieve sustainable development, especially given that the borough’s real needs are for affordable housing and social housing.

b. There seems to be an acceptance that the “Standard Method” is mandatory when in fact the government has itself signalled its intention to review its approach to determining the allocation of housing – which it accepts is outdated. Moreover, the methodology for the derivation of the final housing figure is fundamentally flawed.

i. The base figure of 484 was derived using the 2014 figures for housing growth in England over a ten-year period. This figure had already been questioned in the light of the reduced housing growth indicated in the 2016 figures.

ii. It appears that TWBC has applied the “Standard Method” to the base figure, using a multiplier based on an affordability ratio of 12.74 for Tunbridge Wells borough, to generate an annual figure of 749 homes – which is misleading. The erroneous assumption appears to be that building more homes, which will inevitably be sold at the same high prices, would be a means of tackling the overriding issue of affordability in the borough.

iii. Furthermore, the housing figure based on the “Standard Methodology” appears to have been set aside in favour of an alternative, questionable calculation. To the base-figure of 484 has been added an arbitrary 40%, resulting in an annual requirement of 678 homes.

iv. We are forced to the conclusion that the base-figure is unsound and that there appears to be no justification for adding a further 40% to it.

c. Given that conclusion, we are very surprised at the prominence given to the housing target within the proposed development strategy; it has an over-determining influence on all aspects of the DLP, distorting policy intentions to an alarming degree.

d. We are fundamentally opposed to the construction of a policy framework based on an unsound housing target, which, if pursued, would cause irreversible damage to the landscape and habitats, pose a significant threat to wildlife – including protected species – and lead to the urbanizing of the north-east quadrant of the borough.

e. The Council does not support the over-cautious approach to challenging what is clearly a false housing target, which takes little account of the decline in the birth-rate, the downward trend in home-ownership, or pressures of affordability which nationally are well-evidenced. TWBC must consider adopting a more realistic and sustainable approach which recognizes the constraints of the AONB and the Green Belt, and which takes account of the challenges of providing the physical and social infrastructure required to support development – the delivery of which cannot be guaranteed.

f. Given the foregoing, we do not accept the premise that development within the AONB and the Green Belt can be justified, or that it is necessary, or that it is unavoidable. If TWBC does not intend to challenge the basis of the housing allocation it must make clear to residents and businesses the reasons for its position.

g. Regarding the issue of the relationship between assessed housing need and “affordability”, there seems to be an unfounded assumption in the DLP that increasing supply will automatically lead to more people being able to buy a house. This is at odds with housing market data and national statistics, and further consideration should be given to testing this assumption and to providing stronger evidence to support it. As one community group has pointed out, “…we can find no evidence in the supporting documents to justify the assumption that an increase in supply of housing will cause a fall in general market house prices. Therefore, building more homes that are unaffordable for the people who need them is not the solution.” We would also point to a number of research and policy papers which address the flaws in the government’s housing targets, including Tackling the UK Housing Crisis – is Supply the Answer?, (Ian Mulhern, UK Collaborative Centre for Housing Evidence, August 2019.)

h. There is an argument that the “exceptional circumstances” provision of the NPPF could be used to justify an alternative approach to meeting housing need. As noted above, there is evidence that the impact of “affordability” is driving a decline in home ownership – so the over-provision of new homes will do little to address local need.

5. Development Proposals for Brenchley and Matfield

a. From the outset it should be noted that the Parish Council is not against development. Indeed, in 2017 we published Shaping the Future, a document setting out our policy-position. In that document we make the following declaration:

There is currently pressure across the country to increase housing supply. That pressure is particularly acute in the South-East where housing shortage is most pronounced. Given that the borough of Tunbridge Wells is in one of the most prosperous corners of the region, it is inevitable that the district will be obliged to deliver its share of government-imposed targets.

However, we will aim to ensure that the impact on Brenchley and Matfield, in the pursuit of those targets, does not destroy the character, heritage, and sustainability of our settlements. Alongside that, we will support development that adds to the vitality of the parish and which enhances the social infrastructure to underpin the well-being of the community.

b. That declaration underpins our consideration of the development proposals for the parish. Given that, we believe that the strategy of dispersed growth with proportional development distribution would have a detrimental impact on our communities, particularly Matfield, which, in the TWBC Settlement Role and Function Study 2017, is one of the least sustainable settlements in the borough – an assessment also supported by Kent County Council. The untested projected growth (over 37.5%) would be contrary to the sustainability criteria set out in the NPPF (paragraphs 7 and 8) as it lacks most of the services and amenities required for development on that scale. We therefore reject the inclusion of all four of the sites proposed to be allocated to Matfield as they would constitute unsustainable development.

c. The Council considers the expectation that Matfield could accommodate 91 to 150 new houses to be wholly unfounded. The proposed allocation seems to be based solely on the availability of sites put forward by landowners or their agents, rather than any criteria which recognizes the real housing needs of the parish. We therefore reject the basis on which the proposed allocation is made. TWBC should reconsider that allocation, taking into account the well-known constraints, and fully assess the potential to deliver a development package that is truly sustainable.

d. Notwithstanding our rejection of the proposed allocation, it is very disappointing to note that the twenty units being constructed by Rydon Homes have been excluded from the projected numbers. In earlier communication with TWBC we were led to believe that that development would be included in the proposed allocation.

e. We do not support the intention to extend the LBD for Matfield, which seems to be predicated on the need to accommodate three of the four allocated sites, rather than providing a buffer to protect the village from further expansion. The Council also rejects the extension of the LBD at Market Heath, and around the former Corsica Nursery in Matfield, for which there does not appear to be any justification. Given that LBDs would be reviewed every five years, it is possible that the Matfield LBD could be repeatedly redrawn to accommodate other development sites. That is of particular concern to the Council and we will robustly challenge any such attempt to continually extend the LBD.

f. We also do not support the extension to the LBD in order to accommodate sites BM1, BM2, and BM3. By our calculation the LBD would increase from 17.44 hectares to 27.03 hectares in Matfield, an increase that would be at odds with the policy objective to protect and enhance the AONB.

g. Specifically, with regard to sites BM1 and BM3, we fundamentally disagree with their inclusion in the draft plan.

1. Site BM1, which is already the subject of a planning application to build 45 homes, is a key site at the gateway of Matfield village and forms part of the High Weald AONB; major development here would not conserve or enhance the AONB. The site also forms part of the “Matfield and Brenchley Fruit Belt”, with high-quality Grade 2 agricultural land, as identified in the Landscape Character Assessment SPD 2017, and incorporated within the Environment and Design policies EN20, EN21 and EN22. Collectively these policies state that such sites should be protected from development, to “conserve and enhance the essentially rural, working agricultural character of this area”.  The introduction of a large housing estate would surely be contrary to these policies.

ii. Site BM3 is also within the AONB, and adjacent to Ancient Woodland - but with particularly poor means of access. The proposed access is through Oakfield Road, which is a narrow cul-de-sac of approximately 40 homes with significant on-street parking. It is not suitable for accommodating safe access for another 60 homes on the adjacent site. The site further abuts estate-managed parkland gardens, which are part of the 400-year-old Friars estate; any development there would risk considerable adverse impact on the abundant existing wildlife. Development of this site would be wholly contrary to paragraphs 171 and 172 of the NPPF, and in conflict with Environmental and Design Policies EN14, EN15, and EN21.

h. Two areas of the parish that are designated OSSR1 in the DLP no longer have any recreational role. However, they are featured on the maps produced in the 2018 study commissioned by TWBC.  The inclusion of the former Moatlands Golf Course is particularly misleading, if it is being counted as available Open Space for this parish, Paddock Wood and Capel.  It closed in 2009, and the land shown on the map is now in private ownership, with several owners and land uses. It should also be noted that the allotments in Tibbs Court Lane have not been leased by the PC for many years and are now also in private ownership. The Council therefore requests that the policy designation be removed from the map, so as to provide clarity for residents and businesses. We would be concerned if both these areas were to become vulnerable to development, if a developer could claim they were redundant as Open Spaces. It would also be misleading to include these areas in any statutory requirement for the provision of Open Space in the parishes.

i. In addition to the churchyard at All Saints’, Brenchley, being safeguarded as a Local Open Space, consideration should be given to extending the same designation to the two churchyards connected to St. Luke’s, Matfield. They are considered special to the community as attractive areas at the southern gateway to the village, close to the communities at Sophurst Lane and Bramble Reed Lane.  Each churchyard provides an area of tranquillity containing wildlife-rich habitats, with a high level of biodiversity. The churchyard at the Church itself has several Commonwealth War Graves, and a number of Listed monuments that form part of the valued heritage assets of the community.

j. From the representations the Council has received from residents it is clear that there is widespread concern about the development proposals for Matfield. Below we summarize the substance of those concerns:

i. the inappropriateness of the proposed developments, in terms of location and scale;

ii. acute lack of confidence that the developments would be sustainable, given absence of an appropriate range of services and facilities;

iii. heartfelt awareness of the adverse impact on wildlife and habitats, the harm that would be done to the landscape and the loss of views, and well-articulated passion against the potential loss of the essential character of the settlement;

iv. the significant harm that would be done to the AONB designation, and the Conservation Area status;

v. powerful references to the expected impact of noise and light pollution, and the loss of “dark skies”, which are a characteristic feature of the parish;

vi. graphic illustrations of the devastating impact of increased traffic – not just that generated by the developments in Matfield, but also the cumulative impact from developments in Horsmonden and Paddock Wood;

vii. the requirement that no development can take place without due regard for updating the physical infrastructure, such as the realignment of the A228, tackling the congestion at Kippings Cross, rural lanes being uses as “rat-runs”, and traffic-calming measures on the B2160; and

viii. highlighting the pressures on public transport, water supply and sewerage capacity, the deficiencies of broadband coverage, and the under-provision of access to primary healthcare and post office services.

k. As has been highlighted by a resident, we have noted the potential for 55 dwellings at the Horsmonden end of Furnace Lane. A development of that scale is likely to be extremely harmful because it is a historic sunken lane of nature conservation value, which in places is not wide enough for cars coming in opposite directions to pass each other, and where blind bends contribute to the hazards.  Any “improvement” to this lane will result in a loss of its historic character and nature conservation and recreational value. If development were to take place, mitigation arrangements would need to be considered – the lane could be signed as “narrow lane” for local access only or closed off to vehicular traffic near Furnace Pond so that it no longer becomes a through route to vehicular traffic.

6. Development Management Policies

a. There is concern, both within the Council and in the community-at-large, regarding the language used in the description and definition of policies; it is often imprecise, leaving open the possibility of flexible interpretation when planning decisions are made. For example, and has been highlighted by residents, it includes phrases such as “consideration will be given to…,” “… will not normally be permitted,” “where possible…” and “encourage improvements.” Used in that way, the language is not considered sufficiently robust to achieve consistency and transparency; nor is there any confidence in achieving the specific protection to which it refers. We urge TWBC to consider strengthening the language it uses, to limit interpretations that could undermine the policies it seeks to describe and define.

b. From the large number of policies in the DLP, the Council wishes to comment on the following, the aims of which relate to policies that will be included in the Brenchley and Matfield NDP.

1. EN1-3 (Design and other development management criteria, Sustainable Design and Construction, Sustainable Design Standards). We are pleased to see that TWBC have adopted the Design Guide for New Housing Development, produced by the High Weald AONB Unit, and will expect to see the high bar it has set given due weight in all relevant planning applications.

ii. EN5-7 (Climate Change Adaptation, Historic Environment, Historic Assets). We support the broad aims of these policies, which are key to both future-proofing of developments and the retention of the “inherited wealth” of the natural and built environments.

iii. EN21 (High Weald AONB). The defence of the AONB must be at the forefront of all planning decisions. TWBC should resist the temptation to encroach upon the protections provided by the NPPF and keep faith with the passion within the community for safeguarding this precious landscape.

iv. H3-4 (Housing Mix; Housing Density). We are in broad agreement with these policies. However, with regard to density, we are very surprised that the potential for “building upwards” in Royal Tunbridge Wells and Southborough does not appear to have being explored. Given the constraints to outward expansion attending both settlements, there must surely be some merit in having a policy that encourages more multi-storey developments in the urban areas.

v. H5 (Affordable Housing). The bold step of requiring a 40% contribution from relevant development is to be commended. In the rural areas we wish to see a high proportion of such housing being safeguarded to people with a strong local connection, and active consideration should be given to exploring an enhanced role for arish and town councils in the nomination and allocation process.

vi. H15-16 (Residential Extensions, Alterations etc. inside and outside the LBD). The test of these policies will be their stringent application to all and every relevant application. Extensions, alterations, and replacements should, at the very least, demonstrate soundness of proposals, integrity in the use of materials, and well-founded arguments for any proposed departure from commonly-accepted standards of design.

vii. TP3 (Parking standards). We welcome this proposed policy, which provides for a more realistic approach to parking than is currently the case.

c. Regarding STR/BM1:

i. we are concerned that the approach to “windfall” sites leaves open the door for additional development, which could undermine the number of houses envisaged in the site policies – especially for parishes with relatively few sites;

ii. in relation to paragraph 3, it seems to us unlikely that proposals for the sites in Matfield would “make a positive contribution towards achieving the objectives of the most recent ANOB Management Plan”;

iii. the list of developer contributions should focus much more on the needs of the parish – they are much too generic and do not provide sufficiently clear guidance to developers; and

iv. we wish to propose an amendment to include a reference that the Council would negotiate with prospective developers, to agree terms for a suitable body to assume responsibility for owning and maintaining any relevant community facility that may arise from planning consents, such as playgrounds.

d. In terms of prioritising the allocation of affordable housing, the Council is concerned about the exceptionally strict criteria that are being proposed, whereby only those people who are living in the parish, in unsuitable housing and who meet one or more of the other criteria, would qualify. A resident has pointed out that such an approach would exclude anyone with a long connection to the parish, who had moved away (such as students, or people forced to rent in Paddock Wood due to the absence of affordable units in the parish), would be excluded. The policy should be amended to make it clear that people who have moved away, and those forced to leave would qualify under the scheme – otherwise almost no-one would meet the local criteria, and thus undermine the intention of the policy.

7. Conclusion

a. We wish to underline the considerable harm that would be done to the rural areas of the borough if the proposed strategy of dispersed development were to be adopted by TWBC. The traffic that it would undoubtedly generate, compared to more centralized/brownfield development in the urban areas with existing rail infrastructure, would severely exacerbate the well-documented pressures in the rural areas. Development on the scale envisaged is unlikely to be sustainable and would fly in the face of current environmental concerns about climate-change and global-warming.

[TWBC: this response has also been broken down and set against specific policies. See comment numbers DLP_1690, 1694-1696, 1698-1699, 1701-1710].


Dr David Parrish

Their seems to be no independence where the Leader of the Council is also chair of the Planning Policy Working Group, the Planning & Transportation Cabinet Advisory Board and the Cabinet

The Planning Advisory Board not independent of the TWBC Cabinet

The Planning & Transportation Cabinet Advisory Board should be entirely independent of the Cabinet.

The plan should be reviewed and re-drafted by a Planning Policy Working Group that is independent of the Planning & Transport Cabinet Advisory Board (which in turn should be independent of the Cabinet)

Also - the Borough Councillor for Capel sits on the Planning Policy Working Group and Cabinet. She has campaigned for a Colts Hill bypass for many years but has not done anything to listen to, or address, the Capel PC and Tudeley concerns. Supporting the Local Plan and a Tudeley Garden Village gives her a way to introduce the bypass she wants.


Terry Everest

My Foreword would agree with the observation that Tunbridge Wells is a great place to live, work and visit but add that a more sustainable policy of development be pursued, with far greater protection for historic villages, towns and hamlets, and proper protection for the Green Belt, Areas of Outstanding Natural Beauty, green field sites, the countryside and local green spaces throughout the borough.

I have a BSc (Hon) in Geography and Environmental Assessment and an MSc in Environmental Assessment and Management and I have tried to approach this local plan in an open minded and fair, scientific manner. With some experience in planning and local land charges I hope therefore that my comments will carry greater weight and that my objections should be listened to and acted upon as far as possible.

I believe we should join our neighbouring council of Sevenoaks in not building the full allocation of housing as calculated on a government projection, but act to guard the remaining "garden of England" against misguided excessive growth and protect what countryside and green space remains.


Mr Terry Cload

The on-line consultation exercise is extremely unfriendly with several contradictions that I had to resolve by contacting the planning department. Under 'about this consultation' it stated that 'you will be able to submit further comments'. In another place it stated that you would have to submit comments all together and not be able to comment further.

Some contradictions may have been fixed and extra information added or amended since the start of the consultation, but there are still ambiguities and misleading red herrings. For example, today November 12th 2019, by following the path to the 'Event' the Consultation Home page appears.  If I click on 'What people say' I get 'We didn't get anything to show here'.  At the bottom of the page it states 'Be the first to comment on this event' although it turns out that hundreds of comments have already been made. These comments can only be accessed from a 'Making Comments' page that is not obvious to someone who goes straight to the 'Event' and logs in.

These ambiguities and the complicated access and provision for commenting will have put off numerous residents from participating in the Draft Local Plan consulation.  I have completed numerous national and local government consultations over the years including for previous TWBC Local Plans and this is the most unfriendly I have ever come across.

It is awkward and time consuming to be expected to annotate each comment with the paragragh number instead of being able to comment directly against the paragraph.

Why today, November 12th, are responses only available to view up to more than twelve days ago? People should be able to view other opinions concurrently in order to help them make their own informed judgements and comments.

Why is there no spellcheck for comments? Why isn't it possible to copy and paste into this comment box?  All I get when I try is an invitation to insert a hyperlink. (CTRL +K)


Peter Tate

General comments to whole plan:

I believe Karen Baker rejected Sevenoaks local plan for the same reason that this plan should be rejected

Quote ~"My main concern relates to the lack of constructive engagement with neighbouring authorities to resolve the issue of unmet housing need and the absence of strategic cross boundary planning to examine how the identified needs could be accommodated.

"Indeed, the council did not formally ask neighbouring authorities if they were in a position to address its unmet housing need until just before the Local Plan was submitted for examination.

"Any failure of the duty to co-operate cannot be rectified during the examination and therefore the only option is for a report recommending non-adoption to be issued or for the plan to be withdrawn." unquote.

Were TMBC actually consulted at any time?

Very little thought appears to have been given to already congested roads. The road through Tudeley is not much more than a country lane and other roads in the area are not up to the increased volume of traffic.

Train services are already seriously overcrowded, this plan will swamp them and where will all these new commuters park their cars at Tonbridge and other stations in the area?

TWBC will reap the benefits of increased Council Tax whilst TMBC will have to foot the bill for increased health and support services etc.

Agricultural and 600 acres of green belt land will be lost forever.

The area is already a flood risk and this amount of building will only exacerbate the problem.

The developments will create a huge increase in light. air and noise pollution.

The school is located in a ludicrous location creating serious traffic congestion morning and evening as there is no other feasible means of access.

The areas between will gradually infill creating even more problems for Tonbridge.

Ill conceived at best, at worst disastrous!


Helen Parrish

Cross-referenced, detailed, reasons for my Objection:

Their seems to be no independence where the Leader of the Council is also chair of the Planning Policy Working Group, the Planning & Transportation Cabinet Advisory Board and the Cabinet

The Planning Advisory Board not independent of the TWBC Cabinet


Cranbrook Conservation Area Advisory Committee

I would like to register how disappointed I am in this part of the Consultation process. I am a qualified town planner, well used to responding to all manner of government and other documents. This i would rate as the most poorly presented, confusing and limited response process I have encountered:

- Firstly this a very long document of 500 pages, hard and expensive to print or to download and impossible to do on say an IPad.

- Secondly, the forms provided do NOT translate to say a Mac computer and therefore as my only computer is a Mac, I have provided a clear response but only part using the forms

- Thirdly the forms are hard to interpret and seen designed for the convenience of TWBC staff to ‘slot into boxes ‘ rather than a genuine attempt to discover local views on what are some very significant proposals. I have encountered many local people who are deterred from responding, having seen the forms and the bureaucracy.

- Fourthly, anyone who has used the portal and been timed out, losing all material ,will be wary of using that method of responding

- Fifthly, only 2 hard copies were made available in CRANBROOK at the Parish office and the Library, both with quite limited opening times. Recent statistics show that there are 13m adults currently in the Uk who do not have a computer or who are not sufficiently competent to use the internet . There has to be a more genuine attempt to be inclusive of people, who are not computer literate, if this process is to be in way fair.

It is hard not to draw the cynical conclusion that the complication of the response process and the lack of non computer methods are useful in limiting the response. It feels like a tick box exercise on consultation rather than a Genuine engagement of local people. Badly done Tunbridge Wells BC.


Andy Bashford

General comments…

  • Everyone’s first priority should be to look after the planet by minimising destruction of wildlife and vegetation to reduce not increase pollution.
  • Given that we are supposed to be in a democratic society, the general public should have the last say in the likes of planning decisions that clearly will affect current and future generations.
    • It shouldn’t be down to a handful of people in a Planning Department (some of whom have a vested interest) to decide these things.
    • The ratio of the number of people affected by some of the proposed plans compared to the number of people involved in suggesting/agreeing the plans must be in the order of 10,000 to 1.
  • One of the main attractions to places in the High Weald is the beauty of the surrounding countryside, hence it being the 4th largest AONB in the country.
    • Such landscapes should never be destroyed.
  • No more large housing developments can be considered until
    • The roads are improved
    • Reservoirs are increased to minimise droughts
    • GP appointments can be made within a couple of days maximum (not 2+ weeks) of booking them
    • Sewage issues are eradicated
  • It is very unclear why the Tunbridge Wells Borough (and other Boroughs around the country no doubt) is expected to have so many homes built.
    • How many are going to be affordable to people that live in the Borough?
    • Presumably they are not for people outside the Borough (e.g. from London) or if they are I assume it would be a very small percentage
      • If the bulk of the homes are for “Londoners” why should we have to give up our Green Belt and AONB?
    • It shouldn’t be about building homes for people that already have a home and want to move, it should be about people that don’t have a home!
    • Social housing needs addressing more.
    • It should be down to each Borough Council to decide if and how many new dwellings are needed in their Borough, not the Government.
  • What was the point of defining Green Belt and AONB only a couple or so decades ago (to “prevent urban sprawl”), only to now effectively scrap significant parts of them?
    • The High Weald AONB is the 4th largest AONB in the country, and it shouldn’t be contaminated by unnecessary buildings.
    • Green Belt/AONB “should only be altered in exceptional circumstances” (rather than just for the benefit of the future home owner and Developer).
    • The Plan refers to allowing for “future growth”.
      • Does this mean even more Green Belt/AONB to be removed in years to come, i.e. setting a precedent?
  • Infrastructure in particular dealing with existing road congestion must be resolved before building more homes and making the congestion even worse.
    • Children walking/cycling to/from schools along Pembury Road (from Pembury High St to Blackhurst Lane) are already having to breathe unacceptable levels of car fumes.
    • Emergency vehicles and Buses must have the ability to avoid congested roads.
    • Funding of Infrastructure after Developments (contributions) obviously hasn’t worked in the past (hence the congestion) so it won’t work in the imminent/long term future!
    • Dealing with Waste Water/Sewage and removing the risk of overflows/leaks, in particular in Paddock Wood, need addressing before considering relevant developments.
  • Presumably councils know the number (and names) of people living in all houses in their area (via voting form submissions), therefore they know which houses/flats are or potentially are empty.
    • Owners of such homes should be made to ensure they are used.
    • People and Pension Companies are known to buy new houses and keep them empty to maximise “their investment” because investing in stocks & shares is less “attractive” these days.
  • Why does the Local Plan include sites that aren’t expected to be providing any of the required homes, e.g. for new schools, green spaces etc?
    • Do the government dictate this as well?
    • Surely housing and the other things should be just down to the local borough!
    • Where is the democracy - in being dictated to by a government that has little understanding/knowledge of each borough?
    • Ordinary people should have a say (which is what the consultancy period is trying to do) but they must be listened to.
      • My recent experience at a Planning Meeting at the Town hall was that our local Parish Councillors explained a lot of local objections, but most of the voting Planning Committee clearly didn’t listen.
  • Children living close to Primary Schools should be given priority over those from places where they need to be driven to for remote schools.
    • Driving and car fumes needs to be minimised.
    • “Direct walking and cycling” and “increase walking and cycling permeability” sounds good.
  • Compulsory Purchase Orders only being applicable if there is a “wider benefit for the community” is right.
    • But this doesn’t include building hundreds if not thousands of houses (in such areas) that clearly are against the views of the relevant community.
  • Any items in the Local Plan should be on hold (planning permission withheld) until the Local Plan is fully accepted by the public.
  • “Low levels of private car use” is a good idea, but if this means limiting the parking spaces for most new build homes, the car owners will park in places that affect other road users and cause more accidents and congestion.
    • There should be more Park and Ride sites – Tunbridge Wells has none!


Andrew Pinhorn

I am not a resident of Tunbridge Wells Borough but live near the Borough boundary with Tonbridge. I have lived at my current address for 22 years and prior to that for 5 years in Golden Green. I know the area around Paddock Wood, Capel and Tudeley well. This is an attractive rural landscape and an important reason why I choose to live here.

I am writing to object strongly to The Local Plan on the grounds that it does not take proper account of the majority views expressed during the consultation stage of The Local Plan. Indeed, it appears to have ignored repeatedly the majority view.

A good example of my point is the section on Strategic Options, starting at page 33, of The Consultation Statement for The Draft Local Plan.

“ Of those who ranked the Strategic Options:

  • 116 respondents (about 60%) ranked Option 4 (Growth Corridor-led Approach) as their most preferred Option;
  • 34 respondents (about 18%) ranked Option 5 (New freestanding settlement) as their most preferred Option;
  • 26 respondents (about 13%) ranked Option 1 (Focused Growth) as their most preferred Option”

Why has the Option which received only 18% support by the responders been made one of the centrepieces of The Local Plan? Where is the democratic mandate?

In my view, the Local Plan should reflect better the views of the residents in Tunbridge Wells Borough. The Local Plan needs to be withdrawn, reviewed and revised.


Kent County Council (Growth, Environment and Transport)

Thank you for inviting Kent County Council (KCC) to comment on the Tunbridge Wells Borough Council – Draft Local Plan Regulation 18 Consultation.

The County Council recognises the role and importance of the Local Plan in guiding and managing sustainable development in the Borough up to 2036.

The proposed spatial strategy for growth is characterised by a mix of dispersed growth across the majority of settlements in the Borough, a new ‘standalone’ garden settlement and the transformational expansion of an existing settlement using garden settlement principles. The County Council recognises the challenges for the Borough Council to allocate sites that will meet the identified housing requirement but would strongly emphasise the necessity for a robust approach to the identification, funding and delivery of necessary infrastructure and services to support the delivery of truly sustainable new communities. It will be imperative that this approach provides a strategic focus for the planning and delivery of KCC infrastructure and services in an effective and timely manner.

The County Council recognises that the Borough Council has commissioned specialist consultant advice on whether it is most appropriate to secure infrastructure through CIL, section 106 agreements, or a combination of both for the site allocations within the Draft Local Plan. The County Council would strongly recommend that the section 106 agreement approach is the most effective approach to secure development contributions towards infrastructure in a timely manner to deliver sustainable growth in the Borough, and this must be a vital component of the master-planning work of the strategic sites, going forward.

The County Council has reviewed the relevant consultation documents and provides a full technical commentary on the Draft Local Plan in the attached appendices, which include a Technical Schedule of Policy Commentary and comments on the Infrastructure Delivery Plan (IDP).

Highways and Transportation

The County Council as Local Highway Authority provides comments on this Local Plan consultation with reference to the Draft Local Plan and accompanying documents [1 TWBC Draft Local Plan: Regulation 18 Consultation Draft, SWECO Local Plan Transport Plan Evidence Base, TWBC Infrastructure Delivery Plan – August 2019 and other supporting documents]. The Draft Local Plan and accompanying documents have been valuable in determining the need for public transport, cycling and walking infrastructure to be dramatically improved in order to achieve the modal shift required to make the Local Plan work. They have also been important in identifying the junctions and links that require further investigation before the Local Highway Authority can be confident mitigation is possible to alleviate severe impact on the network. It is hoped that work will continue on these points prior to the Regulation 19 consultation to give reassurance to the County Council as Local Highway Authority that the modal shift and highway mitigation required to make the Local Plan growth targets is deliverable.

New Settlement at Tudeley Village (AL/CA1) / Paddock Wood (AL/PW 1)

The proposed Colts Hill bypass and a direct public transport link between Tonbridge town centre/station, Tudeley and Paddock Wood town centre/station are absolutely key to the delivery of Tudeley settlement and the Paddock Wood extension. Whilst the opportunity exists to deliver dedicated and direct bus routes through the allocated sites, little work has been done on connections into the existing town centre networks. This should be a priority as part of the upcoming masterplanning exercise programmed for these allocations.

There is currently no reference to a new rail station at Tudeley Village in the Draft Local Plan or IDP. The inclusion of an additional stop on this line in the heart of the new Tudeley settlement would make a considerable difference to the road traffic generated by these developments and exploration into the feasibility for a station should be pursued in conjunction with the masterplanning exercise, prior to the Regulation 19 consultation. Without this station, the 11% modal shift would be even more difficult for the very limited remaining public transport options to deliver.

Consideration should also be given to trips heading north on the A228 into Maidstone/Tonbridge and Malling to understand the impact on the wider road network and whether mitigation is required.

Royal Tunbridge Wells

There is concern over the cumulative impact of the allocations in the town centre, Pembury and Southborough, coupled with the trips that would be generated by the new settlement at Tudeley Village and the Paddock Wood housing allocations – particularly with regard to congestion on the A26 and A264. Where junction upgrades on the A26 and A264 are referred to, these are identified as requiring mitigation (identified in the SWECO Local Plan Transport Evidence Base). However, at this stage, no work has been done to identify if and how improvements can be made and the costs of such improvements. Further work will be required to show how capacity can be increased whilst maintaining or improving safety.

With respect to the A26, the IDP states the intention for the ‘reallocation of road space with smart traffic management to improve journey time reliability and provide infrastructure for sustainable modes (walk, cycle and bus)’. The County Council as Local Highway Authority is not confident that this methodology will improve flows on the A26 enough to mitigate the additional traffic generated by Local Plan growth. The addition of smart traffic management (such as MOVA or SCOOT) to junctions that currently do not have signals in order to control the corridor could add delays that cannot be mitigated against, and may not bring benefits to this corridor either in the current situation or with the housing growth and associated trips applied.

This is not acceptable and mitigation measures should be explored before the Regulation 19 consultation, in order to provide assurance to KCC as Local Highway Authority that the impact of growth will not result in unacceptable safety or congestion issues on the A264, A26 and other key junctions in the town.

To assist at this stage, KCC as Local Highway Authority has provided site specific comments on all policies (Appendix 1).


The IDP sets out that new infrastructure is required in the form of a new relief road through the Hawkhurst Golf Club site, linking the A268 High Street and A229 Cranbrook Road and new junction with the existing A229 Cranbrook Road.

The reference to the new section of road being a ‘relief’ road is misleading. It is not yet evident that the changes to the main junction (proposed through the Hawkhurst Golf Club planning application (Ref: 19/02025/HYBRID)) will be acceptable in achieving nil detriment or decrease the level of traffic/congestion/journey time through the junction - thereby not causing a severe impact for the number of dwellings proposed on the Golf Club site. It also does not take into account the further allocations in the area that would affect the junction. There is a presumption that the road diversion will relieve the junction significantly in order to allow more development in the village. However, this has not yet been demonstrated to the Local Highway Authority’s satisfaction.

Until the Hawkhurst Golf Club application is properly assessed, the cumulative impact of all the allocations at Hawkhurst would be likely to cause a severe impact on the junction, in lieu of suitable mitigation proposals. KCC Highways and Transportation Officers are currently awaiting more information on the Golf Club application which will assist in this assessment.

To assist Tunbridge Wells Borough Council and KCC in understanding the impact of development in this area, it is recommended that Tunbridge Wells Borough Council undertakes:

  • An assessment of the cumulative impact of all proposed allocations (excluding the Golf Club) on the junction as it is currently; and
  • An assessment of the cumulative impact of all proposed applications (including the Golf Club) with the proposed A229 diversion across the Golf Club site in place.

As it stands, this matter has resulted in an objection from the County Council as Local Highway Authority, to all residential allocations in Hawkhurst (as set out in Appendix 1).

It is also pertinent to mention that whilst developer contributions towards much needed public transport services have, to date, been a suitable mitigation measure in relation to the most recent small site applications in the village, this is not an effective mitigation for the level of growth proposed through the Local Plan allocations as part of a plan-led approach. Public transport improvements are likely to always be required through developer contributions, but highway infrastructure improvements are key to sustainably delivering the growth planned for Hawkhurst.

Car-dependant locations

In response to the “Issues and Options” consultation in Spring 2017, the County Council as Local Highway Authority raised concern that, in relation to the option for dispersed growth (Option 3), without significant growth in individual areas, services (including health centres, retail facilities and education facilities) are likely to be a car-drive away, and so this option would be likely to cause the most significant increase in vehicular trips to the Borough.

Since the consultation, the County Council as the Local Highway Authority has continued to raise concerns about new residential development in locations across the Borough (Sissinghurst, Frittenden, Beneden, Goudhurst, Sandhurst and Brenchley/Matfield) that have no, or very few, facilities. With only a very few non-residential allocations that would provide services and facilities within these settlements, such housing growth would result in a large percentage of car borne trips.

Whilst the County Council has provided comments on individual sites in these villages (Appendix 1), Tunbridge Wells Borough Council is asked to consider the implication of locating housing sites that are a car drive away from key facilities.

The Park and Ride site at Woodsgate Corner (Policy AL/PE 7)

KCC as Local Highway Authority agrees with the ambitions of Tunbridge Wells Borough Council to maintain and enhance the rail and bus networks and services and to ‘encourage an efficient and improved strategic public transport network and safeguard any routes that may be required in the future, in places that will cater to those who commute, and will encourage a reduction in the necessity for the private car' (paragraph 4.60).

However, the allocation of the Park and Ride site at Woodsgate Corner (Policy AL/PE 7) as car showrooms goes against this objective. The proposed removal of the Park and Ride site effectively removes the chance of an improved direct public transport service into the town. With the levels of proposed growth to the north of this site further along the A228 corridor, the safeguarding of this well located site for Park and Ride (or innovative alternative) is vital. The inability to deliver a Park and Ride site could compromise the Borough Council’s ability to deliver the preferred growth strategy.

Impact on adjacent districts

The impact of the proposed settlement in Tudeley will have an impact on Tonbridge town and this impact will need to be assessed in much greater detail prior to the Regulation 19 consultation. In addition, impacts resulting from the Tudeley Village and Paddock Wood allocations on the road network in Tonbridge and Malling Borough and Maidstone Borough should also be assessed.

Developer contributions and mitigation

Throughout the Draft Local Plan, many of the policies state that ‘It is expected that contributions will be required towards the following if necessary, to mitigate the impact of the development…’. This wording is not acceptable to the County Council as Local Highway Authority. It is suggested instead that the policies state that ‘It is expected that mitigation measures will be implemented by the developer. A contribution may be taken if appropriate’.


The County Council as the Local Highway Authority has fundamental concerns that the impact of the additional vehicular traffic brought about by the preferred growth strategy has not yet been effectively addressed in the Draft Local Plan by clearly defined mitigation measures. KCC would welcome continued dialogue to address these matters as the Local Plan progresses.


Proposed growth within Paddock Wood and Tudeley Village (Policy STR/PW 1) is forecast to generate the combined need for an additional eight forms of entry of secondary provision. It is proposed that two forms of entry are provided through the expansion of the existing Mascalls School prior to the establishment of a new six form entry secondary school within the area. The total level of growth cannot be accommodated through the expansion of Mascalls School alone and therefore Policy STR/PW 1 relating to growth in Paddock Wood must reflect the need for sites relating to the policy to contribute financially to the provision of the new six form secondary school.

The policy referring to Land to east of Tonbridge/west of site for Tudeley Village (Policy AL/CA

2) relates to land proposed for the establishment of a new six form entry secondary school. The establishment of a new school is wholly required to support the proposed level of growth. It would be advantageous for the school to be located closer to the proposed development towards the east; this would increase the likelihood of more sustainable modes of travel being used by students. However, the geographic location of the school is acceptable in order to meet the additional need for school places. However, the identified site is significantly constrained - consisting of two sites separated by a railway line with deep embankments, the southerly part of the site containing a sizeable area of Ancient Woodland, a high pressure gas pipeline runs from south to north through the western side of the site and the south of the site is identified as an area of potential archaeological importance.

It would not be KCC’s preferred option to establish a new school on split sites and the site’s additional constraints are likely to make design and construction of a new secondary school far more challenging. The maintenance and management of the Ancient Woodland could not be the responsibility of the school, nor could the maintenance of the bridge that crosses the railway line. However, the school would require security that the bridge will be maintained in perpetuity and there is potential that a second bridge over the railway would be required within the school site to overcome some of the site’s constraints; this would enable students to cross the two sites without leaving the safeguarding line of the school during the school day.

Delivery of a secondary school at this location is therefore highly likely to cost significantly more than that of a regularly shaped and unconstrained single site; the school will need to be wholly funded by development and therefore the financial contributions from contributing developments would need to be increased to cover the additional costs derived from both the site’s abnormals and the likely need to deviate from the Department of Education’s baseline design. In order for the County Council to confirm that the necessary secondary provision could be provided within the proposed site, it is suggested that prior to the Regulation 19 stage, the Borough Council undertakes a detailed design and costing exercise relating to the site, or that an alternative site with fewer physical constraints is identified within the area.

Provision and Delivery of County Council Community Infrastructure

The County Council generally favours growth strategies that include sustainable, larger development sites as they are more capable of supporting new infrastructure, including schools, early years, childcare, libraries and community centres. KCC supports the objective to establish garden settlements as a model of future delivery, provided that they are suitably located with respect to existing infrastructure and that upgrades to existing infrastructure are properly assessed for their ability to cope with new development. New supporting infrastructure must be appropriate in terms of scale. The Paddock Wood and Tudeley Village developments will be considerable, so it is critical that KCC services are considered at an early stage and that they are commensurate with the scale of the development and future proofed to cater for the growing community.

The County Council is responsible for ensuring the provision of Community Learning (formerly known as adult education), as well as Early Help for young people (from birth to 25 years old). Early Help duties include the delivery and commissioning of children’s centre services, other specialist children’s services, youth services and wider public health services. KCC also has a duty to ensure early years childcare provision in Kent, as set out in the Childcare Acts (2006 and 2016).

The County Council would like to see continued support for funding towards multi-functional Cultural Hubs at Tunbridge Wells, Cranbrook and Southborough. These provide an excellent mix of services including social care, libraries and education facilities.

KCC would emphasise the need for close collaboration between key partners to ensure that required infrastructure is planned, funded and delivered in a timely manner – this is critical to the success of new developments, ensuring a sustainable community is created and maintained.

Youth Services

There does not appear to be specific reference to youth services within the consultation document. There is a county wide need to make appropriate consideration for youth services – and youth services should clearly be seen as an essential element of community services.

Adult Social Care

The County Council has adult social care responsibilities (delivered through the Kent Accommodation Strategy for Adult Social Care) to ensure adequate facilities for older persons in the County. The Borough Council should have regard to the Kent Accommodation Strategy for Adult Social Care in determining housing options for adult social care clients.

The Local Plan should also reference “Your Life Your Well-Being” - Kent County Council’s strategy for Adult Social Care. The strategy seeks to ‘help people to improve or maintain their well-being and to live as independently as possible’. Its vision is for people to live independently in their own home receiving the right care and support and the strategy sets out the strategic direction for suitable housing and care home provision for all Adult Social Care client groups. It identifies the need for more extra care housing and to explore the opportunities to develop mixed tenure models of extra care housing. It is important to support older persons’ care homes in the areas where there is a need for specific support, including for people with dementia that presents as challenging. High quality, affordable dementia care is needed across Kent. In Tunbridge Wells, the average cost for care home beds is significantly higher than the Kent average and this creates a challenge for the County Council to place people in suitable, affordable residential care. The County Council is keen to work with the Borough Council to ensure an adequate, affordable supply of housing options are delivered through the Local Plan.

Broadband and mobile connectivity

KCC welcomes the inclusion of the policy ED 3 (Digital Communications and Fibre to the Premises), as there is a need to ensure that new development has either full fibre (FTTP) or gigabit capable connections. Given the recent shift in Government policy (set out in the Future Telecoms Infrastructure Review) from superfast speeds (in excess of 24mbps) to ‘gigabit- capable’ speeds (delivered either via wired i.e. FTTP or wireless solutions), the County Council would request that the references to 24mbps, high speed and ‘next generation-access’ are replaced with the term ‘gigabit-capable’. This will help ensure that the plan is in keeping with current and emerging national digital infrastructure policy.

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

Sustainable Businesses and Communities

KCC is supportive of the Plan’s approach to sustainable development. The Plan’s policies to support the transition to a zero-carbon economy to promote environmental sustainability, through requiring high standards of energy and water efficiency, improving climate change resilience, incorporating green infrastructure and supporting innovative low carbon transport options and renewable energy are particularly welcomed. These measures align with and support the priorities of the Kent Environment Strategy and the draft Kent and Medway Energy and Low Emissions Strategy, which sets a vision for achieving net-zero carbon emissions by 2050.

The draft Kent and Medway Energy and Low Emissions Strategy seeks to ensure that the decisions and plans made for the future embrace clean growth and allow the development of a clean, affordable and secure energy future. This can only be achieved through informed planning decisions, good quality sustainable design, investment in new technologies and cleaner fuels.

The Local Plan presents a real opportunity to progress future low carbon energy infrastructure such as district heating schemes, hydrogen grids and local energy centres supplied by locally produced renewable energy sources. The draft Local Plan could further support the zero- carbon agenda by identifying where there is potential for new settlements to become zero- carbon development hubs, for instance, utilising district heating networks or hydrogen energy grids. This could encourage investment in trials and pilots of new zero-carbon technologies and infrastructure. The County Council would be keen to explore these opportunities further with the Borough Council to support the transition to a zero-carbon economy.

Place shaping and design

The County Council strongly supports the Local Plan’s ethos of place shaping and good design. Kent Design Guidance is being refreshed for publication in 2020 and there is opportunity to make appropriate reference to ensure that development is aligned to the principles set out in the Kent Design Guidance.

Minerals and Waste

There are economic mineral deposits that are potentially threatened with sterilisation by the allocations in the Draft Local Plan. The safeguarding of these potentially economic minerals is required by Policy CSM 5 of the adopted Kent Minerals and Waste Local Plan 2013-30 (KMWLP). Whilst the KMWLP is referenced at paragraph 6.1 and in Policy EN 32 of the consultation document, it does not evidence that any assessments against the criteria of

Policy DM 7 have been carried out to determine if there are grounds for exemption from the presumption to safeguard the potentially affected minerals. Given the economic resources affected, it is possible that an argument could potentially be advanced that the sandstone formations are not threatened with sterilisation in any meaningful manner. This is because they are massive crustal sedimentary units that do not require a maintained landbank in the County as required by aggregate minerals.

The County Council has submitted a Mineral Sites Local Plan to the Secretary of State, which is currently under examination. It identifies two allocations in the vicinity of the proposed Tudeley Village allocation (CA1). Whilst policy STR/CA1 does identify that this allocation is in the vicinity of the mineral site allocations and should have regard to them, it is unclear as to whether there may be any conflict with the mineral site allocations; their accessibility in the future; or whether there is any significant potential for adverse impacts on their future potential to supply mineral to the market as required by National Planning Policy Framework (paragraph 207).

Given the implications for mineral and waste safeguarding and the need for both local planning authorities to work together on this strategic matter, the County Council’s Waste and Minerals Planning Policy team would be grateful to be kept engaged as the Tunbridge Wells Borough Local Plan progresses.

Sustainable Urban Drainage Systems

The magnitude of the impacts of flood risk and surface water flooding within the considered and understood within the Draft Local Plan to the satisfaction of the County Council. The Draft Local Plan recognises the importance of ensuring that the necessary infrastructure is in place to accommodate new development. The Draft Local Plan recognises that for a number of developments, an improvement in the existing flood alleviation situation in the area must be evidenced. Multi-functionality within sustainable drainage schemes and/or integration within open space should be considered.

Heritage and Conservation

The County Council supports the inclusion of a strategic objective to protect the valued heritage and built and natural environments of the Borough, and the recognition that design must take account of the outstanding built and historic environment of the Borough.

Some sites have been identified as having major or sensitive archaeological issues and some that KCC recommends should be withdrawn on heritage grounds, or for which an allocation will need to be supported by an Archaeological Desk-based Assessment. Full comments on policies are provided in Appendix 1.

Public health and air quality

It will be essential for the growth strategy to address health and wellbeing – and this must capture wider determinants of health, such as access to green space and air quality. It is considered that this could be brought out more explicitly as a priority in the Vision of the Local Plan. The County Council supports the recognition in the Plan of the role of open space and the recognition of the need to enhance opportunities to provide linkages between cycle and pedestrian routes to help improve public health and air quality in the Borough. The inclusion of active travel in the vision of the Local Plan is welcomed - active travel can help reduce vehicle congestion on roads, alleviate air quality issues and improve the health and well-being of the public.

The County Council also welcomes the incorporation of air quality policies EN 23 and EN 24 - to mitigate air quality issues and control development in Air Quality Management Areas (AQMA). Air quality issues identified in the consultation document must be addressed and mitigated against – they will need to be managed through a range of means and this can include engineering solutions, reduction in emissions from vehicles and access to cleaner forms of transport (such as electric vehicles).

The County Council recognises the role and importance of the emerging Local Plan in guiding and managing sustainable development in the Borough up to 2036. The County Council will continue to work closely with the Borough Council to ensure the delivery of new housing, employment and required infrastructure and services across the Plan period.

If you require any further information or clarification on any matter, please do not hesitate to contact me.


Andrew & Bronwyn Cowdery

We have attached our comments to the Draft Local Plan for Hawkhurst. Our response to this Plan confirms our opposition to the contents of this document. It is frustrating that the residents of Hawkhurst are continually being required to respond to Parish and Local authority requests and the Draft Local Plan seems to take no account of previous reservations we have made to additional development in an area of Outstanding Natural Beauty. [TWBC: comments in response form submitted have been entered into the relevant sections].


Martin Robeson Planning Practice for Tesco Stores Ltd

As you know, we act on behalf of Tesco Stores Ltd, in respect of their various interests in Tunbridge Wells Borough and respond on their behalf to the Regulation 18 Tunbridge Wells Local Plan consultation, under the following headings.


MRPP has extensive knowledge of both Tesco’s activities in the Borough and the present (and historic) formalisation of planning policy in the Borough. We welcome the opportunity to engage with the emerging Local Plan and do so positively both in terms of representing our client’s interests, and in terms of helping the Council to formulate effective policies which support development for the benefit of the Borough’s businesses and residents.

Tesco Stores Ltd engaged with various components of the adopted Local Plan, both in terms of the development needs identified in the existing Core Strategy (primarily in relation to retail capacity) and the treatment of its various interests in the Borough in the subsequent Site Allocations DPD. We have, on their behalf, thoroughly reviewed the current draft Local Plan and have sought to respond only to those policies and issues which directly or indirectly affect their property interests. We trust that this targeted approached assists officers, who will find our comments generally supportive, subject to several clarifications regarding evidence and the particular justification for designations, allocations and polices.

For ease, we set out our representations in a single letter and have, for each relevant policy or supporting text, used the Council’s recommended responses (i.e. objection, support, support with conditions, or general observation). We have also set out some basic background to our client’s presence in the Borough

Tesco in Royal Tunbridge Wells

Tesco has been represented in Royal Tunbridge Wells since 1969 when its store at 29 Grosvenor Road first opened. Tesco has continue to serve the community, uninterrupted, since then and has subsequently enhanced its presence to now include:

  • Supermarket Format – Woodsgate Corner (Pembury)
  • Metro Format – Grosvenor Road, Tunbridge Wells Rye Road, Hawkhurst
  • Express Format - St. Johns Road (Tunbridge Wells), London Road (Southborough) and Commercial Road (Paddock Wood)
  • One Stop Format – Badsell Road (Five Oak Green), Forest Road (Hawkenbury)

It is well documented that Tesco, having secured planning permission for a substantial replacement superstore at Pembury, took the difficult decision not to implement this, arising from significant changes in the convenience shopping sector and other local factors. However, a number of its stores, including Pembury, have undergone improvements as part of the firm’s ‘refresh’ programme, wither greater focus on customers, merchandising and the quality of the retail environment.

As you’re aware, Hendy Group is presently promoting a Motor Village Proposal on surplus land at Pembury. Tesco firmly support this proposal and wrote to the Council on 15th July 2019 confirming its position. That letter also confirmed that Tesco “…remains wholly committed to continuing to serve” its customers at Pembury. To confirm, Hendy Group has also responded to this Reg 18 Consultation. Tesco was provided with the opportunity to review these representations prior to submission and confirms to the Council its support of Hendy’s position in so far as it relates to Pembury and Policy AL/PE7.

[TWBC: see responses to individual policies]

Duty to Cooperate

The Council is no doubt aware of the recent suggestion by the Sevenoaks Local Plan Inspector that SDC has failed to discharge the (legal) Duty to Cooperate arising from an alleged lack of engagement with neighbouring authorities and other relevant interests. We are confident that TWBC officers will take necessary steps to protect the emerging Tunbridge Wells Local Plan from a similar assertion. However, we wish to draw officers’ attention to the increasingly high threshold that Inspectors appear to be imposing, and thus, to engage extensively, meaningfully and consistently with stakeholders throughout the process.

We trust our comments are of assistance and we look forward to continuing to liaise with officers and other interests in respect of the emerging Plan.


Natural England

Thank you for your consultation on the above dated 19 September 2019 which was received by Natural England on the same date.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England has reviewed the Draft Local Plan and accompanying appendices together with the Habitats Regulations Assessment and Sustainability Appraisal (SA) for the Draft Local Plan. A summary of our advice and main concerns is provided below, with detailed advice provided in appendices as indicated. Please note that we have not provided comments on all policies but those which have most influence on environmental issues.


  1. Draft Local Plan
  2. Distribution of Development Topic Paper
  3. Site Allocations
  4. Sustainability Appraisal (SA)
  5. Habitats Regulations Assessment (HRA)
  6. Green Infrastructure Framework


  • STR 1: Development strategy

Natural England advises that this strategy is not justified because insufficient evidence has been provided to demonstrate that the strategy is deliverable without resulting in an adverse impact on the High Weald Area of Outstanding Natural Beauty (AONB), considered against reasonable alternatives. The allocation is not consistent with national policy with regard to conserving landscape and scenic beauty within a nationally protected landscape (NPPF para 172).

Subject to the provision of further information to support the proposed site allocations, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to Development Strategy STR 1.

Further advice regarding Development Strategy STR 1 and the distribution of housing is provided in Appendices 1 and 2, respectively.

  • Site Allocations

The inclusion of multiple allocation sites within the AONB which are considered to constitute major development is of significant concern.

Natural England objects to the principle of major development within designated landscapes.

Subject to the provision of further information to support the proposed site allocations, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects in principle to allocation sites proposing major development within the AONB.

Further details on our objection to individual allocations is provided in Appendix 3

I hope the advice and comments in this letter are useful. We remain committed to working closely with your authority to help ensure that a sound plan is secured that enables growth in accordance with the principles of sustainable development. We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.

[TWBC: see further comments under individual sections and policies].


Celia Leake

I would like to object to the plan on the following grounds.

1. Local plans are supposed to meet local housing needs. There is simply no local demand for the number of houses proposed they will simply be bought by commuters wishing to move out of London.

2. Recent flooding events have mainly occurred where towns have historically been built on low laying ground alongside rivers. In these cases, all that can be done is to defend these towns as well as possible. To propose to build a New Town on a low laying area that is well known for flooding is the height of reckless irresponsibility reflecting on the planners seeking the easy option of dealing with a single landlord and that landlord looking for a way to make potentially vast profits.

3. This ill thought out. ill-conceived and frankly naive plan shows absolutely no regard for the consequences that it will inevitably lead to.

4. The fact that No Green Belt Assessment, No Flood Risk Assessment, No Ecological/Biodiversity Assessment, No Environmental Assessment, No Transport Assessment and No Heritage Assessment seems to have been carried out is almost beyond belief and amply illustrates the unprofessional and frankly cavalier approach that of the architects of this plan have adopted.

5. Inspectors are clearly not prepared to accept plans such as this and there are numerous examples of similar proposals being turned down, most often on the grounds of flooding. This coupled with the vast amount of evidence gathered by the various Save Capel working groups especially with regard to flooding and transport will ensure that should TWBC persist with this plan it will without doubt be rejected at the inspection stage leaving egg on the face of TWBC yet again. My objection is to this the obviously ludicrous plan and I would suggest that they stop pouring good rate payers’ money after bad and apply plain old common sense, drop the plan and devote their energy and resources to looking for more sensible alternatives.


Mrs June Bell

There is unquestionable amount of work afforded by TWBC to preparing this DLP. I support the purpose and need for a Local plan to enable local decision making and guide development. The colour coding separating the policy boxes from supporting text is effective. The plan has highlighted to me how great the Borough is and the challenges to achieve infrastructure led sustainable development in the future. It also highlights a lack of recognition and place given to the Neighbourhood Plans made or in progress and lack of timely collaboration not just consultation with the residents of the Borough.

Reasons for comment:

* The first part of the plan process ‘Issue & Options’ consultation seeking early views received less than 0.5% response from residents and individuals. Evidence within the plan does not suggest a resolution by TWBC to encourage community collaboration and a timely input of views.

* The Borough has nine Neighbourhood Plan groups which have been approved by TWBC between 2014 and 2017 with only 1 of the 9, Hawkhurst, successfully passing Inspection in March 2018. A made plan is a statutory part of the planning framework as stipulated in The Localism Act of 2011 and should demonstrate a partnership between the LA and NP group.

Paragraph 1.21 does not demonstrate LA confidence and endorsement of locally-led policies

* The Reg 18 Public Consultation process has been less than straightforward. Registration issues have been experienced by many with the online consultation portal. Paper response forms were not available at the Borough Council exhibition in the Vestry Hall.

* Timing of the 1 exhibition was Friday 27th Sept between 4-7pm which is less than ideal for those in the community with families to feed, prepare for bed nor does it allow adequate access for shift workers and those returning from workplaces outside the parish at peak travel times.

* Efforts to ameliorate this less than ideal response experience deserve mention.

TWBC extended the response period by 2 weeks.

The Cranbrook & Sissinghurst Parish Council clerks have patiently assisted with the photocopying of response documents and guidance notes

The response officer at TWBC has made great efforts to answer queries and provide encouragement and assistance to complete responses.


Ide Planning for Paddock Wood Town Council


Paddock Wood Town Council (PWTC) thanks the borough council for staging the two local exhibitions and welcomes the opportunity to respond to the Plan.

Alongside other consultees, PWTC has had limited time in which to prepare its response.

The point is made at the outset that PWTC has not been able in the time available to study in the necessary depth all that is proposed in the Plan and, in particular, the supporting documents. The PWTC also notes further work is needed on the Plan. The Town Council’s comments should be read in that light. PWTC will be looking to add to its representations at the next stage in Plan-making following what is hoped will be a meaningful and constructive dialogue with the LPA.

PWTC resolved on 11th November 2019 to OBJECT overall to the Plan.

Objection is made at three levels.

Firstly, objection is made in principle which reflects 3 underlying concerns -

a. the number and extent of existing problems that have and continue to affect the town i.e. before the planning/development at Mascalls Farm, Mascalls Court Farm and Church Farm and which, in the past, appear not to have been capable of redress through the parties involved on either an individual or collaborative basis.

The most prominent of these issues being –

i. fluvial flooding;

ii. surface and foul water drainage, and their interrelationship; and

iii. the vitality and viability of the town, including its small commercial centre, across the spectrum of uses including business, health, social, leisure etc. for the benefit of the wider community.

b. that these problems will remain unaddressed, become worse or added to with the addition of 4000 new dwellings at Paddock Wood/eCapel, and (nearby) new settlement at Tudeley.

c. the loss of green belt and the need to preserve the setting of the town particularly to the west given the scale of development proposed at and around the proposed garden village at Tudeley within the Plan period and beyond.

Secondly, the objection identifies a number of cross cutting issues common to a number of policies. As these objections are relevant, in part or in whole, to more than one paragraph/policy/plan, they appear more than once in the representations and are shown in italics.

Thirdly, this response picks out individual policies where comment is made as appropriate – these are presented either as objections or as expressions of support.

The representations made by the Town Council have drawn upon a number of sources including a public exhibition held on 19th October 2019, from meetings of the Planning and Environment Committee and full Council during the consultation period, and specialist contributions, in particular, on flood risk.


Lamberhurst Parish Council

Lamberhurst Parish Council welcomes the opportunity to comment on the proposals set out in the Draft Local Plan (DLP). Members appreciate the significant amount of work that has been undertaken in formulating the Plan.


Rother District Council

I refer to your notification on the publication of the above Local Plan for representations.

By way of introduction, as a neighbouring Authority, my Council welcomes the production of statutory local plans in its locality in order to provide a clear, coherent, and locally-driven planning policy framework for the wider area. In this respect, it recognises the efforts of Tunbridge Wells Borough Council (“TWBC’”) in preparing a local plan that addresses a complex mix of needs, constraints and development demands.

There are a number of issues covered by the Local Plan that are common with those facing my Council. Some of these would clearly be regarded as strategic matters, such as in relation to international wildlife sites, housing provision and related major infrastructure, notably transport, and conservation of the High Weald Area of Outstanding Natural Beauty (AONB). Other issues may not be strategic in the sense that they do not require common policy responses, but would nonetheless benefit from similar or otherwise complementary policy responses; this covers such matters as water efficiency standards, the general approach to biodiversity, developments in the countryside, including equestrianism and rural employment sites. My Council's representations in respect of these common issues are attached as Appendix 1.

In relation to major infrastructure and transport, the main cross boundary issue arising would appear to relate to the effect that the proposed site allocations in the Parish of Hawkhurst will have on the Flimwell crossroads (which are physically located within Rother District). This issue should be investigated with East Sussex County Council Highway Authority and Kent County Council Highway Authority, where necessary, to see if there are any capacity issues and whether improvements are required at Flimwell or at junctions beyond. In this regard the reference within the policy strategy for Hawkhurst Parish [1] to establish the impact of the proposed developments on the Flimwell crossroads, and if necessary provide contributions towards works to this junction to mitigate that impact, is welcomed.

[1] Policy STR/HA 1 (requirement 6)

In respect of the individual site allocation policies, it is appreciated that under ‘contributions’, ‘any other highway related works’ are specified but it is requested, for clarity, that specific consideration is given to making an explicit cross-reference to requirement 6 of Policy STR/HA 1 or that its general requirements are repeated in some form in each of the site allocation policies[2] to ensure the traffic impacts are robustly considered.

[2] Policies AL/HA 1, AL/HA 2, AL/HA 3, AL/HA 4, AL/HA 5, AL/HA 6, AL/HA 8, AL/HA 9 and AL/HA 10.

There is much that is welcomed in the new Tunbridge Wells Borough Draft Local Plan ("the TWBDLP’) in relation to what are often termed as the “development management policies’. There is a high degree of consistency with this Council's policies, which not only reflects a consistent analysis of similar (but not necessarily the same) circumstances, but also will help provide a consistent message to developers and others, including residents and businesses being close to the administrative boundary.

While the two District Council areas are adjoining, Rother is substantially oriented towards Hastings Borough, whose area it (with the sea) envelops. Hence, a point that has been consistently made is that Rother is seen as integral to the ‘Hastings housing market area’ rather than to those of any other neighbouring authorities.

It is noted that TWBC does not propose to meet any unmet housing need from Rother. At the time of the Core Strategy, there was a shortfall in Rother of 480 dwellings over the period 2011-2028. Most of the demand stemmed from in-migration from the greater London area. Given that this information is now somewhat dated and that my Council is, in conjunction with Hastings Borough Council, in the process of undertaking a new Housing and Employment Development Needs Assessment for its respective forthcoming Local Plan Reviews, it would not seem timely or reasonable, at this juncture to expect the current TWBDLP to make provision for further housing to meet any unmet need from Rother district.

Looking ahead, infrastructure capacity, notably of transport networks/services as well as that of the natural environment, of which the High Weald AONB is a vital element, should be kept under close and constant review. In this regard I look forward to continuing our positive working relationship in the future.


Withyham Parish Council

Withyham Parish Council has approximately 3,000 residents and sits against the Kent border at the River Grom. Many of our residents use the amenities and facilities within Kent, including those of Tunbridge Wells Borough Council and equally many of our services and amenities are used by residents in Kent, including those covered by Tunbridge Wells Borough Council. Withyham Parish Council welcomes the opportunity to respond to this consultation.

General Observation It would appear that the whole plan is driven by the housing requirement set out in the working paper Housing requirement. This has simply applied the Government’s standard prediction model resulting in a step change from the current Core strategy requirement of 300 dpa to 678 dpa. In our view this is not sustainable and cannot be achieved. The Draft TWBC Local Plan also states the prediction is based on 2014 data which is out of date and that HMG plans to review the model in 18 months time in any event. We suggest the whole plan should be delayed by 18 months or TWBC prepares its prediction based on the model used for the adopted Core Strategy.

More Specifically:

1. Tunbridge Wells is on the Kent/East Sussex border. There is no evidence in the Local Plan of any impact assessment of the proposed expansion of Tunbridge Wells (to include 780 new dwellings and 80,000 sq M of business space) on towns and villages just the other side of the border. This is a significant omission because we believe TWBC has a legal duty to assess and take into account such impacts.

2. WPC considers that the impact on adjoining settlements is potentially very significant because:

Traffic – the A26, which passes close to the WPC Parish Boundary and feeds the village of Groombridge and the B2110 that passes through Withyham Parish (leading from the A272), are both significant feeder roads into Tunbridge Wells, yet they are already sub-standard and congested.

The A26 is also significant because it is the primary route between Tunbridge Wells the Port of Newhaven and the Brighton conurbation resulting in a lot of heavy traffic in both directions.

The A272 (and the B2110) is significant because it provides routes to and from Gatwick Airport and Crawley New Town

Extra pressure on these roads will exacerbate the already unacceptable tendency of traffic to use minor roads as ‘rat runs’ causing increased danger and disturbance to local residents and businesses.

Recreation – The proposed residential expansion of Tunbridge Wells will inevitably lead to recreational pressures on the surrounding countryside and particularly in the countryside in the East Sussex side of the border. WPC is concerned that not only will existing facilities become overused and will therefore have to be more tightly controlled but it will also lead to additional recreational development pressure in this area of the AONB. It is noted that this pressure would arise directly from a population that has no direct stake in, or responsibility for, this area.

3. Other Observations:

House Prices – WPC is concerned that the proposed expansion of Tunbridge Wells will place an upward pressure on house prices in the surrounding villages where supply is essentially finite. WPC is extremely concerned that first time buyers and many key-workers are already priced out of the local market. This has social implications for the vitality and sustainability of local villages.

Spratsbrook Farm: WPC objects to the proposed allocation at Spratsbrook Farm, Frant Road (Policy AL/RTW18) on the grounds that it has an illogical southern boundary defined only by the Borough boundary. Its development will also impact on the Ashdown Forest Special Protection Area.

Schools: WPC considers that Spratsbrook is a poor location for a new secondary school as the majority of the new housing will be to the east of Tunbridge Wells. WPC is also concerned that the extra pressure on secondary schools in Tunbridge Wells will put a squeeze on the number of pupils that can be accommodated from outlying towns and villages.

Consistency with the Wealden Draft Local Plan – The Wealden Draft Local Plan as currently proposed places the development emphasis firmly in the South of the District around Hailsham primarily to protect the Ashdown Forest from traffic and recreational pressures from the further expansion of areas in and around Crowborough and Uckfield. The proposed development of Tunbridge Wells being promoted in the TWBC Local Plan appears to fly in the face of Wealden’s rational and interpretation of the Habitat Regulations. Both Councils cannot be right on this point.

The Metropolitan Green Belt - It is noted that the TWBC Draft Plan proposes a loss of 5.35% of the MGB to achieve the predicted housing requirement. It is further noted that Sevenoaks District Council’s Draft Local Plan claims the Green Belt is sacrosanct which will result in a shortfall of 1,900 dwellings. Again, both positions cannot be a sound interpretation of Green Belt policies.

Gatwick Airport - We note the TWBC Draft Local Plan is silent on Gatwick Airport. While WPC accepts that TWBC has no direct control over Gatwick Airport (albeit that Gatwick is seeking to influence neighbouring land use policies) there is without doubt considerable environmental concern locally over noise and air pollution from overflying aircraft, especially in relation to sensitive parts of the AONB and Green Belt. It is noted that pollution levels, especially over the Ashdown Forest Special Protection Area (which is extensively over-flown by Gatwick) are forecast to continue rising significantly. WPC proposes there should be a positive policy in the Local Plan committing TWBC to engaging with other Local Planning Authorities similarly effected, the various Air Traffic Bodies, Pressure Groups, and Government with a view to making sure the voice of Tunbridge Wells is heard when changes are being proposed to flight paths and the frequency/timing/height etc at which they are flown. WPC has made a similar representation on the WDC Local Plan.


British Horse Society

Introduction and General Comment

The British Horse Society (BHS) is a registered charity with over 100,000 members. The BHS represents and promotes the interests of all horses and those who care about them, including 2.7 million people in Britain who ride or who drive horse-drawn carriages.  We offer world-class qualifications, an approvals system awarding quality instruction and care, and support and guidance on access, safety and welfare issues.

Equestrianism is a popular and healthy activity for people of all ages.

Whether purely for recreation or when riding or driving professionally, equestrians may use public rights of way (including roads) and open spaces, and may rely on them as the only place they may ride or drive. Routes free from motorised traffic are preferable, for safety and for freedom from noise and pollution, providing a healthy respite for body and mind.

The BHS commissioned research into the physical health, psychological and wellbeing benefits of recreational horse riding in the United Kingdom which was published in 2011. It assessed riding as a moderate intensity exercise and examined the frequency with which individuals take part. Reliable evidence indicates that physical exercise produces wellbeing benefits linked to social interaction and changes in mood, anxiety, self-esteem and other personal emotions.

The report is available on .

Horse activities engage a high proportion of people with disabilities, women participants and participants over the age of 45. Nearly 40% of those taking part do not participate in other forms of physical activity. All these factors are very important in recognising that equestrianism is vital to the health of a significant section of the population which is known to be at risk.

Equine and equestrian businesses include riding schools and coaches, livery yards, competition yards, trekking centres, breeders, trainers, welfare charities, veterinary services, farriers, feed merchants, tack, equipment and clothing manufacturers and retailers, shows and event services.

The British Equestrian Trade Association (BETA) represents more than 800 member companies. The most recent BETA National Equestrian Survey (2015)1 indicated:

  • Estimated £3,600 spent on each horse
  • £4.3 billion economic value of the equestrian sector
  • £560 million spending on items such as hats and body protectors, clothing, books and magazines
  • 944,000 horses in Britain
  • 3 million regular riders of 2.7 million total
  • 74% female (962,000 female regular riders, 348,000 males)

44% of those riding once a week or less say they would ride more frequently if they had access to safe off road riding or bridleways. This is the most cited reason that would make people ride more frequently. .

England has 117,250 miles of recorded public rights of way, of which only 22% are bridleway or byway (available to riders).

Many of these paths are unusable on horseback because isolated by busy roads or truncated by development or a failure to record a through route. Some areas may have a network of bridleways or byways, other areas have none at all, including the whole of adjacent parishes, meaning that riders may have no off-road access for a ten mile radius or more, and carriage-drivers may have nothing within tens of miles.  This is the case in much of the Borough of Tunbridge Wells, where the proportion of public rights of way that are of bridleway or byway status is considerably lower than the national average (only 16% are bridleways); most of these are very short routes that would take no more than a few minutes to ride, linked by increasingly busy roads.

The BHS considers horse-related traffic incidents to be significantly under reported, to it, the police or any other body. This view is supported by the Hospital Episode Statistics (NHS Digital) in 2015-16 which reported 4,094 episodes requiring treatment in hospital for ‘animal-rider or occupant animal-drawn vehicle injured in transport accident’.

395* Road Traffic Incidents were reported on BHS in 2016 which included:

1 rider fatality

10 severe rider injuries

17 horse fatalities

5 severe horse injuries

(* Note that this figure is undoubtedly a fraction of those that occurred.)

The cost of a fatal road traffic collision is around £1.8million per casualty; with even slight incidents around £18,000 per casualty ( based on medical, police, insurance, lost output and ‘human’ (distress, suffering, pain) costs. It does not take account of secondary costs to other people affected by a road traffic incident, for whom the consequence of delays could be considerable.

A figure for an equine casualty is not available, but transport and disposal of a dead horse alone is likely to be £1,000. Replacement for the majority of horses is likely to cost several thousand pounds. For some horses there may be lost output in terms of stud fees or prize money. In UK law unfortunately a horse is considered to be property, not a sentient being, but most horse owners will attribute the equivalent of human cost (distress, suffering, pain) as well as veterinary and insurance costs and lost benefits of ownership.

The thousands of new homes proposed in this Draft Plan will contain a large number of additional households containing one or more people who want to ride, yet this Plan, so far, appears to contain no proposals whatsoever for improving and extending public riding facilities, the only mention of equestrians being Policy ED6 placing conditions on recreational (including equestrian) uses in the countryside.  Moreover, the additional motor traffic which will be caused on rural roads which are currently used by equestrians will mean there are even fewer places where people can safely ride.  

In creating the new strategic settlements and in providing access improvements to the Green Belt designed to compensate for the loss of areas of Green Belt, the opportunity should be taken to create a network of new public bridleways and horse riding routes. As at Trent Park in London, these should be linked to the provision of riding centres, or else access to the riding routes should be within safe and easy reach of an existing riding centre.  

Wherever possible, new cycle routes should be dedicated as public bridleways, so that horse riders are able to use them as well as cyclists and walkers.  The proposed cycle route linking Sissinghurst , Cranbrook and Hartley to Bedgebury Forest would be a particularly useful route for horseriders as Bedgebury Forest is the only place in the Borough where there is anything approaching a network of bridleways.  The new developments at Hawkenbury, particularly the new sports hub, should provide horse riding routes that link to the existing public bridleways nearby.  In some London Boroughs, horse riding routes have been created around the perimeter of playing fields and the same could be done here.


Mr Andrew Rankine

The Draft Local Plan documents that Tunbridge Wells Borough Council have produced are vast, complex and interspersed with planning jargon, making them virtually unintelligible to the common man. As an individual in full-time employment, assimilating all this information during the relatively short consultation process has been next to impossible. As I have not had the time or resources to comment on each and every part and policy in detail I have instead concentrated on the particular aspects of the Draft Plan that concern me most – namely the policies relating to my home parish of Capel. This has necessitated me digesting all aspects of the Draft Local Plan and associated documents, as well as familiarising myself with the relevant national planning policies and frameworks. As such, my response is considered the context of national and local environment and is not simply a “not in my back yard” reaction. I have lived in the Borough for over 20 years and enjoyed the past 12 years as a resident in Capel Parish and my family live and work across the borough so I comment with their interests in mind also.


Historic England

Thank you for your email of 16 October 2019 inviting comments on the above consultation document. Please note that since 1 April 2015 English Heritage has become Historic England for the purposes of statutory consultations on planning and related matters.

As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully taken into account at all stages of the planning process. This includes formulation of local development policy and plans, supplementary planning documents, area and site proposals, and the on-going review of policies and plans.

There are many issues and matters in the consultation document that are beyond the remit and concern of Historic England and our comments are, as required, limited to matters relating to the historic environment and heritage assets. We note that as an early stage in the formulation of a local plan the current document may be subject to significant change and consequently we consider it appropriate to limit our comments to more general matters; we will comment more specifically and in detail at later stages in the plan making process as appropriate. In this respect, you should not take the comments below as the definitive view of Historic England on the matters contained in the plan; they are provided for general guidance in the iterative process of preparing appropriate policies for the historic environment. In particular, it focusses on the objective of the National Planning Policy Framework, inter alia, to set out a positive and clear strategy for the conservation, enjoyment and enhancement of the historic environment; and contain strategic policies to deliver the conservation and enhancement of the historic environment.

A positive strategy in the terms of NPPF is not a passive exercise but requires a plan for the maintenance and use of heritage assets and for the delivery of development including within their setting that will afford appropriate protection for the asset(s) and make a positive contribution to local character and distinctiveness.

This strategic approach can inform all aspects of the planning system by recognising and reinforcing the historic significance of places. As part of a sound conservation strategy, policies for local housing, retail and transport, for example, may need to be tailored to achieve the positive improvements in the historic environment that the NPPF expects. Conservation is certainly not a stand-alone exercise satisfied by stand-alone policies that repeat the NPPF objectives.

A conservation strategy can help with site allocations in terms of considering environmental and policy constraints against the evidence in the relevant Strategic Housing Market Assessment (ref. Planning Minister’s letter to Chief Planners 19 December 2014 publications/strategic-housing-marketassessments).

It can identify opportunities to conserve the historic environment, such as site allocations positively addressing heritage assets at risk, and can help to ensure that site allocations avoid harming the significance of heritage assets (including effects on their setting). The strategy can also be used to inform the nature of allocations so development responds to and reflects local character. Site allocations should be informed by an evidence base and an analysis of potential effects on heritage assets.

We note the Historic Environment Review (January 2018) that provides a robust evidence base, and can be a useful tool to amplify and elaborate on the delivery of the positive heritage strategy in the Local Plan. We note also that the Council undertook some work on a Heritage Strateg, but we are not clear if this has proceeded and will alos form part of the evidence for the local plan or could be the basis for a future conservation strategy or heritage specific SPD.


Mrs Suzanne Callander

Initial comments:

I feel that the Local Plan and this response mechanism itself sets out to confuse the public with far too much planning jargon. The response mechanism is difficult to navigate and to ensure that all the points have been addressed – could this be to the dissuade the public from raising objections? Anyway, I apologise to Steven Baughen and his team in advance, as I know he publicly stated that he would prefer we use to the online forms, otherwise his team would “have to read it,” Unfortunately, you have made it far to difficult for the public to make your lives easier.


Michael Weston

I may have missed it but there appears to be no adequate justification in the Draft Plan for building on green field sites and developing villages within the Green Belt and the AONB, such as Matfield, which lacks all facilities except an Anglican Church and a pub, rather than extending the existing main areas of population, particularly Tunbridge Wells itself and Southborough, but also Cranbrook and Hawkhurst. I also question whether it makes sense to extend Pembury along the A21 until that road is made dual carriageway at least as far as the Lamberhurst bypass. The long overdue dualing of Castle Hill, though most welcome, has only moved the bottleneck South to Kippings Cross. Building more houses either on the A21 or off it, for example in Matfield, without creating proper access to it, will only compound the problem. Finally, I am concerned that there is little sign that care is being taken to preserve public rights of way and footpaths and disappointed that the opportunity is not being taken to create new cycle paths


Laurence Jarman

Having seen the Local Plan proposed by TWBC I must object to the large amount of agricultural land selected for development. I think this valuable resource should be retained for future food production.

We are told that we have a housing crisis. I would suggest that what we have is a population crisis and this large population will have to be fed. At present most of our food is imported but this situation cannot continue when we consider the effects of climate change and the inevitable problems with transportation. We need a lot more

home grown food and this will be impossible if our farm land is covered in housing. Locally, at TURNDEN we have lost 68 acres which is already being built on and joining this development another 180 houses are to be built at Brick Kiln Farm. The Plan proposes more housing at Bull Farm and there is an existing application to build 27 houses at Gate Farm, all on much needed agricultural land, and the situation is

repeated throughout the region.

I would urge the council to reconsider the Plan and protect this priceless land resource.


Mrs Rosie Bishop

I attach my response form.  I would like to make these additional points:

The online consultation process was very difficult to access and navigate and I should be very surprised if you have received many non-professional responses in this way.  Even the Word document provided was cumbersome and time-consuming to use; because of this, I have not managed to include all the comments that I would like to have made.

But I have seen the response from my Parish Council (Brenchley and Matfield) and I agree with all the comments they have made.  Please treat their comments as being also mine.

[TWBC: comments in response form submitted have been entered into the relevant sections].


Kevin Conway
Lorraine Soares
Angela Thirkell
Madelaine Conway
Clive Rivers
Rosemary Cory
Deborah Dalloway
Gillian Robinson
Paula Robinson
Andrew Roffey

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

Procedure for submitting comments on the Draft Local Plan.

The Council has made it very difficult to comment on the Draft Local Plan by requiring the completion of a complex form, on or off-line, which people not used to working on Word documents or completing online forms would find very off-putting. Nowhere does the Council encourage people simply to send in their comments as a narrative. The result will, inevitably, be that many people will not submit comments on the Draft Local Plan because they find it too difficult to do so and that the Council will draw misleading conclusions from an artificially low response rate.

1.35. The importance of producing and complying with neighbourhood plans (NDPs) is correctly described here. What is not explained is why, therefore, the Council has pointedly failed to recognise the existence of the 2019 NDP for Hawkhurst, duly prepared after local referendum and submitted in March 2019. And why the Council’s plans (and, indeed, many of its recent planning decisions) so flagrantly fly in the face of the NDP. There is substantial local opposition to the proposal (which has already been the subject of an application for outline planning permission) to build over the Hawkhurst golf course. It would be profoundly oppressive and undemocratic for the Council to ride roughshod over the clearly stated wish of local residents to preserve their village and their rural way of life.


Marion Cranmer

Foreword p12

Reconciling differing opinions, particularly about where housing and other development should take place, is never easy: however, we are keen to hear everyone’s views on this draft Local Plan document…

Having spoken to representatives of TWBC at the exhibition, I feel that many people within TWBC may say that they ‘hear’ everyone’s views on the draft, but it has not been demonstrated so far that opinions of locals are truly acted upon.


Sevenoaks District Council

Sevenoaks District Council (SDC) welcomes the opportunity to comment on Tunbridge Wells Borough Council’s (TWBC) Regulation 18 Draft Local Plan consultation. Please note that this is an officer level response.

SDC and TWBC share a number of key constraints including Green Belt, the High Weald Area of Outstanding Natural Beauty (AONB) and Sites of Specific Scientific Interest (SSSI). Also, it has been set out in the document that the Tunbridge Wells Borough shares similar issues with the Sevenoaks District in terms of development viability, a shared housing market area and issues surrounding housing affordability.

Before I make specific comments relating to the Regulation 18 Draft Local Plan, I would like make some observations relating to the progress of the Sevenoaks Local Plan, which was submitted in April 2019 for examination. Hearing sessions for the Local Plan began took place in late September/early October. We have recently received correspondence from the Inspector, advising the Council that there are significant concerns with the submitted Local Plan in relation to the Duty to Co-operate. We are currently responding to these concerns to determine how to proceed with our Local Plan, as discussed at our joint meeting on 12 November 2019.

Further information on the progress of the Local Plan Examination can be found our website (

Duty to Co-operate

As an adjoining Local Planning Authority, it is important that SDC works with TWBC to address strategic, cross boundary issues such as housing, infrastructure, employment, transport etc. to ensure that development can be enabled over the respective plan period. In this case, we note that TWBC’s new Local Plan will cover the plan period up to 2036, which closely aligns with the Sevenoaks Local Plan covering the Plan period up to 2035. It has been evidenced that both SDC and TWBC have been working closely on strategic crossboundary issues under the Duty to Cooperate since 2015. This has included the preparation of evidence-based documents as well as having constructive dialogue with TWBC over cross-boundary issues, both individually and collectively with Tonbridge & Malling Borough Council as a West Kent authority.

In May 2019, a Statement of Common Ground was signed between SDC and TWBC which sets out the issues and actions raised during the Duty to Cooperate meetings, which include how both local authorities seek to meet a variety of needs (i.e. housing, employment, retail etc.). It has been documented that TWBC is not in a position to assist SDC in meeting its unmet housing needs due to the Borough’s constraints (i.e. proportion of Green Belt and the High Weald Area of Outstanding Natural Beauty) and that TWBC is seeking to meet its housing needs in full.

It is noted that the Statement of Common Ground has been included in TWBC’s Interim Duty to Cooperate Statement. This Statement of Common Ground has also been submitted as part of the Examination Library for the Sevenoaks Local Plan. Despite the Sevenoaks Local Plan Examination being paused at present, SDC will continue positive and proactive engagement with TWBC and assist with respective plan-making.

Meeting the Borough’s Objectively Assessed Need (OAN) and Distribution of Development

In 2015, both SDC and TWBC commissioned a joint Strategic Housing Market Assessment (SHMA) to consider the area’s Objectively Assessed Need (OAN). This was based on 2012based population projections. It concluded that Tunbridge Wells had an OAN of 12,960 dwellings to be provided over the period 2011-2031.

The Government has introduced a standardised methodology for local authorities to calculate their own housing needs. This was adopted into national planning policy and guidance in February 2019. National policy and guidance states that local planning authorities are expected to meet the development needs in their area in full, unless there are compelling reasons as to why this is not possible.

Paragraph 4.7 of the TWBC Draft Local Plan document sets out the objectively assessed housing need for the Borough which equates to 13,560 dwellings up to 2036 (678 dwellings per annum). It is noted from Table 1 “Housing Need 2016-2036” that it is expected that the majority of the housing supply will come forward through new housing and mixed use allocations as set out in Policy STR1 of the Draft Local Plan. On this basis, it appears that TWBC is planning to meet its OAN in full.

SDC notes that TWBC consulted previously on a number of different approaches during its Issues and Options consultation, choosing Option 3 “Dispersed Growth” and Option 5 “New Settlement Growth” to base its Development Strategy as set out in paragraph 4.40 and Policy STR1 which adopts an infrastructure-led approach.

This is illustrated by Draft Local Plan Proposals Map which shows a dispersed approach to allocating sites where the distribution of development accords with the Tunbridge Wells Settlement Hierarchy. The main growth areas are around Paddock Wood and Tudeley, where a new Garden Village is proposed. Sevenoaks District shares an administrative boundary with western area of the Tunbridge Wells Borough. The Proposals Maps shows little development being proposed on this boundary and therefore the proposed growth is unlikely to have a significant impact on the Sevenoaks District.

The Sevenoaks Local Plan is currently under Examination, following its submission to the Planning Inspectorate in April 2019. Under the standardised methodology, the housing need for the Sevenoaks District is 707 dwellings per annum (11,042 dwellings over the Plan period 2019-2035). As outlined in our response to the Inspector’s Initial Questions [ED3][1 ED3 “Sevenoaks District Council’s response to Inspector’s Initial Questions” can be found in the Sevenoaks Local Plan Examination Library (], the Local Plan seeks to deliver 9,410 dwellings over the Plan period which is equivalent 588 dwellings per annum. This results in an unmet housing need of approximately 1,900 dwellings over the Plan period 2019-2035 (equivalent to 119 dwellings per annum). This is due to the high level of Green Belt (93%) and AONB (60%) within Sevenoaks District. On 22nd July 2019 the PPG was revised to state that C2 units will need to be included in the Housing Land Supply. Therefore, this will result in a higher level of land supply as set out through the Examination hearings.

Due to these constraints, the Sevenoaks Local Plan is based on the following development strategy following extensive public consultation:

i. Focus on growth in existing settlements, including higher densities;

ii. Redevelopment of previously developed “brownfield” land in sustainable locations; and

iii. The development of greenfield Green Belt land only in “exceptional circumstances”, particularly where social and community infrastructure is being proposed, which could help address evidenced infrastructure deficiencies in the area.

As the submitted Plan does not meet housing need in full in the District, SDC will continue to engage with its neighbouring authorities, including TWBC, under Duty to Co-operate for further discussions on how this issue can be resolved. It is noted that SDC formally approached TWBC in April 2019 to ascertain whether TWBC could assist with unmet need. The letters were sent in order to formally document the already known position of neighbouring authorities, in preparation for examination, and the letters documented the conclusion of the process. TWBC re-confirmed its position that:

‘The Duty to Co-operate meetings which have taken place so far over recent years (both between TWBC and SDC and in the three way discussions with TMBC) have included discussions about any assistance with unmet need, but through these discussions it has been clear that TWBC is not in a position to assist either authority (if needed) in this regard’.


In summary, SDC believes that TWBC’s approach to the new Local Plan is positive and proactive in light of current national planning policy and guidance. SDC will continue to positively and constructively engage with TWBC under the Duty to Co-operate, as both authorities progress their Local Plans and try to meet their requirements over the Plan period, which will include further discussion around SDC’s current unmet housing need.


Hawkhurst Parish Council

Executive Summary

This submission represents the considered response of Hawkhurst Parish Council to the consultation on the Tunbridge Wells Borough Council (TWBC) Local Plan (Reg 18). This was agreed at a public meeting of Hawkhurst Parish Council on 4th November 2019, following work by Hawkhurst’s NDP Group.

Hawkhurst Parish Council welcomes the opportunity to contribute to the formulation of the Tunbridge Wells Local Plan which will have a direct impact on the future of Hawkhurst. The Parish Council are keen to be fully involved in order to help shape and influence the new TWBC Local Plan in a constructive and useful way.

There are fundamental issues that prevent Hawkhurst Parish Council offering its support for the document as it currently stands.

These are principally around:

Failure to follow the National Planning Policy Framework (2019)

  • the failure to consider the National Planning Policy Framework (NPPF) paragraph 11bi and ii to review the Standard Housing Formula housing figures for the borough as a whole, due to the significant portion of the Area of Outstanding Natural Beauty (AONB) within the borough. Thus the failure to reduce the housing/development within the borough as a whole;
  • indeed, TWBC decided to increase it by 900 houses borough-wide
  • the failure to consider NPPF paragraph 172 to maximise the call for sites opportunities within Tunbridge Wells and Southborough prior to allocating housing/development within the AONB;

Failure to consult

  • the limited amount of time for the consultation considering the extent of impact of the subject – the future of the borough; · the limited consultation - in Hawkhurst only one weekday session between 4 to 7 pm when many residents could not attend to offer their views;
  • the limited access to the online consultation – not on TWBC home page and hidden “four clicks” away buried in the planning section of the website;
  • a complex consultation form to complete that many residents have found baffling;

Inappropriate Distribution of Development Policy

  • the failure to consider the results of the previous Issues and Options consultation where only 8% supported the “dispersed growth” approach proposed by the draft Local Plan, with the most preferred option (60%) being a “growth corridor” approach;
  • the entirety of Hawkhurst parish is within the AONB. This means that all sites in Hawkhurst are within the AONB. STR /HA1includes a worrying mistake from the TWBC Local Plan team who consider that some sites may not be in the AONB and reveals a deeper problem with the way TWBC consider the parish as suitable for large scale development;
  • the fundamental mistake to include Hawkhurst as an urban area in the TWBC draft Local Plan – thus implementing urban strategic planning policies to a village in the AONB;
  • the Parish Council also has serious concerns about the scale (a 32%+ increase), pace and location of new development being proposed for Hawkhurst, most of which is at odds with the aims, objectives and planning policies of the made TWBC Neighbourhood Development Plan (NDP) for Hawkhurst;

Failure to proactively engage the Neighbourhood Development plans

  • the lack of conformity with, and recognition afforded by the TWBC draft Local Plan for the made TWBC NDP for Hawkhurst;
  • the lack of recognition of the updated NDP for Hawkhurst March 2019;
  • the lack of any coordinated support through the TWBC draft Local Plan for the neighbourhood planning process as a means of delivering the aims and aspirations of the TWBC draft Local Plan on the ground;

Failure to develop appropriate infrastructure

  • the proposed “relief road” is a substandard additional road to facilitate housing development within the AONB. It will not relieve anything. It will add to traffic, add to congestion and add to air quality problems;
  • the TWBC draft Local Plan has not considered the wider impact on Hawkhurst of development in neighbouring areas such as Hartley (an additional 300 houses), Cranbrook (600 houses) and Rother District (6,180 houses); and,
  • complete failure to consider the lack of current capacity in the sewage system, let alone plan for the development proposed in the TWBC draft Local Plan.


Gary Birch

Procedure for submitting comments on the Draft Local Plan.

1.35. The importance of producing and complying with neighbourhood plans (NDPs) is correctly described here. What is not explained is why, therefore, the Council has failed to recognise the existence of the 2019 NDP for Hawkhurst, duly prepared after local referendum and submitted in March 2019.


Cranbrook & Sissinghurst Parish Council

This submission represents the considered response of Cranbrook and Sissinghurst Parish Council to the consultation on the Tunbridge Wells Local Plan (Reg 18).

Cranbrook and Sissinghurst Parish Council welcomes the opportunity to contribute to the formulation of an important stage in the Local Plan process, creating a statutory plan that will guide the future of the whole Borough. The ideas and policies within the Tunbridge Wells Local Plan will have a direct impact on the future of Cranbrook and Sissinghurst and therefore the Parish Council is keen to be as fully involved as it can be in order to shape and influence the new TWBC Local Plan in a constructive and useful way.

While it is clear that a lot of effort has gone into the creation of the draft TWBC Local Plan, there are some fundamental issues that prevent Cranbrook and Sissinghurst Parish Council offering its full support for the document as it currently stands.

There are serious concerns about the scale, pace and location of new development being proposed for Cranbrook and Sissinghurst, as well as a lack of support for the neighbourhood planning process.

This submission comprises six sections, as follows:

  1. Summary of key objections to the Local Plan (Reg 18) Consultation
  2. Line by line response to Policy STR/CRS 1 strategy for Cranbrook and Sissinghurst
  3. Response to site specific allocation across the Parish as contained in the draft TWBC Local Plan
  4. Response by Cranbrook and Sissinghurst Neighbourhood Development Plan to key sections of the draft TWBC Local Plan
  5. Response to the “distribution of development” topic paper for draft TWBC Local Plan
  6. Concerns over the consultation exhibition programme

Much of the development in the TWBC Local Plan as proposed for the Parish is at odds with the aims, objectives and planning policies in the emerging draft Cranbrook and Sissinghurst NDP. A dedicated team of local residents has been working with the community to develop this draft since early 2017.  A key piece of early evidence was the production of a parish Housing Needs Assessment identifying a need for 610 houses.  This figure was confirmed to TWBC as deliverable, whilst honouring the expressed wish of the community for small developments.

There has been widespread support within the Parish for the neighbourhood planning process that the group has created. The publication of a draft TWBC Local Plan that fails to acknowledge the site assessment evidence work carried out by the NDP undermines confidence in the process adopted by TWBC.

More than ever, local communities want and need to be involved in the design and planning of the places they live, learn and work in. We therefore urge the team at TWBC to rethink its approach to the preparation and content of the Local Plan, in order to bring together communities across the Borough to make the places we all want for the future.

Clearer and stronger definitions of the role of the Local Plan and that of neighbourhood plans across the Borough are required. This will give Parish Councils the space within the system to develop and deliver effective spatial plans for their neighbourhoods.

We remain available to engage in further discussions and conversations with you about any of the points we raise in this submission.

Failure to conform to key aspects of the National Planning Policy Framework (2019)

  • Object: There appears to be a failure by TWBC to properly consider paragraph 11b)i and 11b)ii of the NPPF. These sections allow a discounting of the objectively assessed needs (OAN) housing figures if an area contains protected areas or assets of importance that provide a strong reason for restricting the overall scale, type or distribution of development. Significant parts of the Borough comprise nationally protected landscape, Area of Outstanding Natural Beauty (AONB) yet there appears to have been no effort to reduce the scale of housing and development across the Borough under the provisions of paragraph 11 of the NPPF.

Indeed, the reverse appears to be true as TWBC has decided to increase the OAN figure by 900 houses Borough wide. How can this be considered reasonable given the AONB landscape that is so significant in the area?

  • Object: The failure to consider NPPF paragraph 172. This sets out why great weight should be given to conserving and enhancing landscape and scenic beauty in AONBs, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas and should be given great weight. The scale and extent of development within these designated areas should be limited and planning permission should be refused for major development other than in exceptional circumstances. There appears to be no evidence that TWBC has followed this important national policy by maximising the sites within and around Tunbridge Wells, Southborough and Paddock Wood before allocating further within the AONB, in and around Cranbrook.

Failure to effectively engage and consult the resident population

  • Object: There was a very limited on-site engagement process during the consultation period, which we feel was an inadequate amount of time for such a large geographical area, the level of proposed development and to discuss other very complex matters.
  • Object: Difficulties in accessing the online consultation portal.
  • Object: A complex consultation form to complete that many residents have found confusing. This was belatedly recognised by TWBC when it extended its deadline for comments by two weeks.

Inappropriate Distribution of Development Policy

  • Object: There appears to be a failure to consider the results of a previous consultation where only 8% of respondents supported the “distribution of development policy” now being proposed by the draft TWBC Local Plan, as recorded in paragraph 5.5 on page 12 of the “Distribution of Development” background paper.
  • Object: There appears to be a fundamental mistake to categorise Cranbrook as an “urban area” in the TWBC draft Local Plan. This in turn triggers the implementation of urban strategic planning policies of the same type being applied to Tunbridge Wells, Southborough and Paddock Wood, but to a much smaller settlement, sensitive to change and located deep within in the AONB.
  • Object: The Parish Council also has serious concerns about the scale, pace and location of new development being proposed for the Parish, much of which is at odds with the aims, objectives and planning policies in the emerging Neighbourhood Plan for Cranbrook and Sissinghurst.
  • Object: The Landscape Sensitivity Report, commissioned by TWBC in 2017, concluded that there are significant areas of “high” landscape sensitivity across the Parish, yet significant numbers of new homes are now being proposed. Every allocated area in the Parish, bar one, was described as having ‘high’ landscape sensitivity. How can the conclusions of this report be squared with the content of the draft TWBC Local Plan?

Failure to properly and meaningfully engage with neighbourhood planning

  • Object: There is a lack of any coordinated support through the draft TWBC Local Plan for the neighbourhood planning process as a means of delivering the aims and aspirations of the TWBC draft Local Plan on the ground.

Failure to develop a coordinated approach

  • Object: The draft TWBC Local Plan does not appear to consider the wider impact on Cranbrook and Sissinghurst of development in neighbouring areas such as over 600 new homes in Hawkhurst and 6,180 homes in nearby Rother District. Meanwhile, the draft TWBC Local Plan proposes 1,751 new homes to the east of the Borough, with the majority of economic development to be around Tunbridge Wells, in the west. This is not a sustainable strategy.

[TWBC: see full representation].




1.1.1 Gladman specialise in the promotion of strategic land for residential development with associated community infrastructure. This document provides Gladman’s representations to the consultation on the Tunbridge Wells Draft Local Plan (the Local Plan).

1.1.2 Gladman welcome Tunbridge Wells Council’s (the Council) continued progress to advance the preparation of a new Local Plan towards adoption. The existing development plan is now significantly dated. An extensive period has passed since the development plan was prepared and examined. The dated nature of the development plan means that its strategic policies have never formally been tested against the policies of the NPPF. It is questionable how relevant these policies remain given that the supporting evidence base is inevitably significantly out-of-date.

1.1.3 The failure to adopt a new Local Plan could put at risk local decision making, and more importantly reduces the effectiveness of strategic plan making and decision making in meeting and responding to current local need, challenges, and fulfilling local opportunities.

1.1.4 This consultation provides the first opportunity to comment on the Council’s preferred approach for the Local Plan. The Local Plan is being prepared in conformity with the policies of the 2019 NPPF. Comments provided in this representation therefore consider whether the Council’s proposals meet the tests of soundness as set out in the 2019 NPPF.

1.1.5 The comments provided in this representation have been structured to reflect the Local Plan with Section 4 considering plan period, vision and objections; Section 5 spatial strategy; Section 6 Development Management Policies; and Section 7 Delivery and Monitoring. Before this Gladman briefly consider the latest national planning policy and guidance (see Section 2) and legal requirements (see Section 3).


2.1 National Planning Policy Framework (2019)

2.1.1 On the 24th July 2018, MHCLG published the revised National Planning Policy Framework. The first revision since 2012 sought to implement 85 reforms to national planning policy as announced through the 2017 Housing White Paper. This version of the NPPF was itself superseded on the 19th February 2019 (2019 NPPF), with the latest revision making alterations to wording relating to the approach to Appropriate Assessments, clarification to footnote 37, and minor amendments to the definition of ‘deliverable’ as set out in Annex 2 of the NPPF.

2.1.2 The revised NPPF introduces a number of major changes to national planning policy. The changes reaffirm the Government’s commitment to ensuring that up-to-date plans are in place which provide a positive vision for the areas they cover. Plans should also provide a framework for addressing housing needs and other economic, social and environmental priorities, and provide a platform for local people to shape their communities. In particular, Paragraph 16 of the 2019 NPPF states that Plans should:

‘Be prepared with the objective of contributing to the achievement of sustainable development;

Be prepared positively, in a way that is aspirational but deliverable;

Be shaped by early, proportionate and effective engagement between plan-makers, and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees;

Contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;

Be accessible through the use of digital tools to assist public involvement and policy presentation; and

Serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework), where relevant.’

2.1.3 NPPF 2019 revises the tests of soundness required to be demonstrated before a Local Plan can be adopted. Paragraph 35 of the NPPF confirms that to be considered ‘sound’ Plans must be:

a) Positively Prepared – providing 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 it is practical to do so and is consistent with achieving sustainable development;

b) Justified – An appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

c) Effective – Deliverable over the plan period, and based on effective joint working on cross- boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and

d) Consistent with national policy – Enabling the delivery of sustainable development in accordance with the policies in this Framework.

2.1.4 Annex 1 of the 2019 NPPF confirms that for Plans submitted for examination to the Secretary of State following the 24th January 2019, the policies contained in the 2019 NPPF apply. The Local Plan will therefore be tested against the policies of the 2019 NPPF.

2.1.5 To support the Government’s continued objective of significantly boosting the supply of new homes, it is important that the Local Plan provides a sufficient amount and variety of land that can come forward without delay where it is needed to meet housing needs.

2.1.6 In determining the minimum number of the amount of homes needed, strategic plans should be based upon a local housing needs assessment, defined using the standard method unless there are exceptional circumstances to justify an alternative approach.

2.1.7 Once the minimum number of homes that is required has been defined, Paragraph 67 of the 2019 NPPF requires a Local Planning Authority to have to clear understanding of the land available in their area through the preparation of a Strategic Housing Land Availability Assessment (SHLAA). This assessment should be used to identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability. Paragraph 67 requires a supply of:

A) Specific, deliverable sites for years one to five of the plan period; and

B) Specific, deliverable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan.

2.1.8 Annex 2 of the 2019 NPPF, provides updated definitions for the terms ‘deliverable’ and ‘developable’. These are:

‘To be considered deliverable, sites for housing should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years. In particular:

a) Sites which do not involve major development and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within five years (for example because they are no longer viable, there is no longer a demand for the type of units or sites have long term phasing plans).

b) Where a site has outline planning permission for major development, has been allocated in a development plan, has a grant of permission in principle, or is identified on a brownfield register, it should only be considered deliverable where there is clear evidence that housing completions will begin on site within five years.’

2.1.9 Local Authorities are required to meet the assessed housing need as defined by the Standard Method as a minimum, unless any adverse impacts would significantly and demonstrably outweigh the benefits of doing so. Where it is found that full delivery of housing needs cannot be achieved (owing to conflict with specific policies of the NPPF), Local Authorities are required to engage with their neighbours to ensure that identified housing needs can be met in full (see Paragraph 35 of the 2019 NPPF).

2.1.10 Securing the full and timely delivery of housing is a key objective of the 2019 NPPF. Paragraph 73 confirms the need for local planning authorities to identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing. This should include a 5%, 10% or 20% buffer to the five-year supply depending on local circumstances.

2.1.11 The 2019 NPPF introduces the need for local planning authorities to ensure that housing delivery is maintained in alignment with the minimum requirements of the Plan over the duration of the plan period. The Housing Delivery Test provides a measure of how many homes are delivered in an authority over a rolling 3-year period in contrast to its housing requirement or need. Where delivery falls below specific thresholds of the housing requirement, the Housing Delivery Test identifies specific actions or consequences required to be implemented to strengthen the future supply.

2.2 Planning Practice Guidance

2.2.1 The Planning Practice Guidance (PPG) was first published by the Government to provide clarity on how specific elements of the NPPF should be implemented. The PPG has been updated to reflect the changes introduced by the revised NPPF to national planning policy. The most significant changes made to PPG relate to defining housing need, housing supply and housing delivery performance.

2.2.2 The Standard Method was introduced by the Government to simplify the process for defining housing need, and avoid significant cost and delay experienced in the plan preparation process.

2.2.3 The Standard Method is derived utilising a three-step process defined in PPG. This confirms the use of nationally published household projections to determine the starting point for this assessment. An upward adjustment is then made in response to affordability problems based on a pre- determined formula. Where the Standard Method requirement results in an uplift of 40% or more to the existing OAN/requirement, a local authority is permitted to apply a cap to the requirement, adopting the capped requirement instead.

2.2.4 It is clear in both the NPPF and PPG that the Standard Method forms only the minimum level of housing need for a local authority area. PPG also sets out that there will be circumstances where the housing requirement could be increased to a level which is higher than that identified through the application of the Standard Method. These circumstances include (but are not limited to):

  • Where growth strategies are in place, particularly where those growth strategies identify that additional housing above historic trends is needed to support growth or funding to promote and facilitate growth (e.g. housing deals);
  • Where strategic infrastructure improvements are planned that would support new homes;
  • Where an authority has agreed to take on unmet need, calculated using the standard method, from neighbouring authorities, as set out in a statement of common ground;
  • Previous delivery levels, where these have exceeded the minimum figure identified; and
  • Recent assessments of need, such as a SHMA, where these suggest higher levels of need.

2.2.5 Whilst the Standard Method provides the Government’s preferred approach to defining the minimum level of housing need for each local planning authority, alternative approaches may be applied where justified by exceptional circumstances.


8.1 Assessment against the Tests of Soundness

8.1.1 Having considered the Draft Local Plan, Gladman is concerned by a range of matters including plan period, vision and objectives, housing need/requirement, duty to cooperate, housing supply (extent of), green belt release, neighbourhood planning, development boundaries, design, landscape, drainage, local green space, affordable housing, homes for older people, self-build, highways and transport.

8.1.2 In relation to all matters, Gladman has suggested how concerns might be overcome ahead of the future Regulation 19 consultation. Gladman also consider that the Council should insert a policy committing to an early review of the Local Plan should certain circumstances arise.

8.1.3 The Local Plan must be positively prepared, effective, justified and consistent with national planning policy to be found sound at examination.

8.1.4 Gladman welcomes the opportunity to comment on the draft Local Plan and hope that the Council finds these submissions constructive. Gladman requests to be added to the consultation database and looks forward to reviewing future versions of the Local Plan in due course.

[TWBC: see full representation].

[TWBC: see also Comment Nos. DLP_6656-6695]


Mrs Carol Richards

The Foreword p.12

The author of this Foreword, Councillor Alan McDermott, is the Leader of the Council and the Portfolio Holder for Planning and Transportation. He Chairs the Planning Policy Working Group, the Planning & Transportation Cabinet Advisory Board and the Cabinet. This structure is detrimental to the production of a sound plan. It would not be permitted in Tonbridge & Malling Borough Council, where the TMBC Planning & Transportation Cabinet Advisory Board is entirely independent of the Cabinet.

None of the members of the TWBC Planning & Transport Cabinet Advisory Board should be members of the TWBC Cabinet. The creation of this Local Plan as a product of the Planning Policy Working Group, Planning & Transportation Cabinet Advisory Board and Cabinet, all chaired by one individual, has resulted in an unsound plan. The plan should be reviewed and re-drafted by a Planning Policy Working Group that is independent of the Planning & Transport Cabinet Advisory Board which in turn is independent of the Cabinet.

The Borough Councillor for Capel has also been overheard at public meetings saying that Five Oak Green residents should “keep quiet and they’ll get a new road”. This Councillor has declined invitations to speak in public to make her position regarding the 4,000+ houses planned for the Parish of Capel. After the TWBC Planning & Transportation Cabinet Advisory Board meeting on August 5th, Cllr McDermott told a member of the Save Capel team that they shouldn’t bother opposing the housing because “you’ll lose”. Overall, these examples mean I am left with the impression this Regulation 18 Consultation is nothing more than fudge and a nod to democracy and no objections from anyone will stop this process from reaching Regulation 19 as it stands.


Matfield Village Hall Management Committee

General comment on the TWBC Draft Local plan.

MVH MC are bemused by the fact that; The current housing ‘need’ figure of 300,000 is based on the Office of National Statistics 2014 calculations which the ONS overturned in 2016 saying the wrong methodology had been used and that the correct figure was 160,000.

TWBC do not appear to be challenging robustly these figures pro-actively, whereas Sevenoaks District and others are.

The Capel proposal is considered to be a very large threat to the whole of our area and being in Green Belt should not even be up for consideration.

TWBC seems somewhat confused; Its own Evidence Studies said that

Matfield was one of the least suitable villages for expansion, yet it has been allocated one of the highest numbers of housing in a village within the AONB.  In the draft plan TWBC states that the lack of infrastructure probably makes Matfield less suitable for housing for the elderly.

The draft plan makes no provision to protect our Dark Skies which are a most important feature of our Parish.


Mr Simon Whitelaw

The form is not at all clear or easy to complete and many people will be deterred from participating in the consultation as a result.

1.35 The Hawkhurst NDP seems to have been overlooked in drawing up the Local Plan so advice on why this has been done would be appreciated.


Andrew Dewdney

Sevenoaks council is more advanced in the local plan process than TWBC and has been the only borough in Kent that has had the courage to challenge its centrally imposed housing targets.  Sevenoaks is further advanced than TWBC in setting up the plan, but after years of developing that plan, consulting with thousands of residents (voters and taxpayers), Planning Inspector Karen Baker has basically thrown the work into the bin.  How can an unelected official override the interests of the residents and their elected representatives in such a way?

Perhaps because the Council refused to submit to centrally imposed housing figures.   I find myself in agreement with the Chairman of the CPRE who has said the housing targets have now been demonstrated to be politically determined by a promise to build 300,000 homes a year.   It doesn’t matter where, at what cost to local communities or the heritage of those areas.  It is, in effect, a Stalinist centrally imposed target that TWBC should challenge.

The draft Local Plan is not in compliance with the NPPF guidelines set out in 1.7.  It is not “positively prepared” – as it takes the government imposed targets and seeks to find space for them rather than developing a bottom-up approach to development needs in the borough.  It is not Justified – I can not see any proper analysis to take in to account “reasonable alternatives” in the paper.  The effectiveness of the draft plan must also be called into question given the track record of the Council over the last two decades.  The only way in which the draft local plan meets the NPPF Criteria is that it is Consistent with National Policy because TWBC has not chosen to challenge the centrally imposed targets with any meaningful analysis.

I am truly concerned that this process is a waste of time for residents and tax payers like me.  If TWBC were to challenge its centrally imposed targets, because of the high levels of green belt and AONB land in the borough, then in a Soviet style way, an unelected unaccountable planning officer can simply tear up any “reasonable alternative” and tell the council to start again.  The Sevenoaks experience demonstrates that this process is simply a sham exercise to justify centrally imposed targets rather than a true development of a sustainable, collaborative and sensible plan to address the needs of this area and its inhabitants.

I am completely in agreement with the Feedback you have received from my Parish Council


Sarah Parrish

How independent is the Leader of the Council who also chairs the Planning Policy Working Group, the Planning & Transportation Cabinet Advisory Board and the Cabinet?

Why is the Planning Advisory Board not independent of the TWBC Cabinet?


Peter Felton Gerber

Procedure for submitting comments on the Draft Local Plan.

The Council has made it very difficult to comment on the Draft Local Plan by requiring the completion of a complex form, on or off-line, which people not used to working on Word documents or completing online forms would find very off-putting. Nowhere does the Council encourage people simply to send in their comments as a narrative. The result will, inevitably, be that many people will not submit comments on the Draft Local Plan because they find it too difficult to do so and that the Council will draw misleading conclusions from an artificially low response rate.

1.35. The importance of producing and complying with neighbourhood plans (NDPs) is correctly described here. What is not explained is why, therefore, the Council has pointedly failed to recognise the existence of the 2019 NDP for Hawkhurst, duly prepared after local referendum and submitted in March 2019. And why the Council’s plans (and, indeed, many of its recent planning decisions) so flagrantly fly in the face of the NDP. There is substantial local opposition to the proposal (which has already been the subject of an application for outline planning permission) to build over the Hawkhurst golf course. It would be profoundly oppressive and undemocratic for the Council to ride roughshod over the clearly stated wish of local residents to preserve their village and their rural way of life.

It would appear that the council has made its mind up and frankly decided to do what it wants to do and has forgotten its democratic obligations.


Department for Education

Submission of the Department for Education

1. The Department for Education (DfE) welcomes the opportunity to contribute to the development of planning policy at the local level.

2. DfE previously engaged with TWBC in 2017 under the former title of the Education Skills and Funding Agency (ESFA).

3. Under the provisions of the Education Act 2011 and the Academies Act 2010, all new state schools are now academies/free schools and DfE is the delivery body for many of these, rather than local education authorities. However, local education authorities still retain the statutory responsibility to ensure sufficient school places, including those at sixth form, and have a key role in securing contributions from development to new education infrastructure. In this context, we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools. We have published guidance on education provision in garden communities and securing developer contributions for education, at You will also be aware of the corresponding additions to Planning Practice Guidance on planning obligations, viability and safe and healthy communities.

4. We would like to offer the following comments in response to the above consultation document.

General Comments

5. DfE notes that substantial growth in housing stock is expected in the borough; the consultation document anticipates an annual housing requirement of 678 homes to the end of the plan period in 2036 (13,560 dwellings total). This will place pressure on social infrastructure such as education facilities. The Local Plan will need to be ‘positively prepared’ to meet the objectively assessed development needs and infrastructure requirements.

6. DfE welcomes reference within the plan to support the development of appropriate social and community infrastructure at paragraphs 2.17-2.22, including reference to infrastructure needed for new development, to be funded by that development. The specific references to education provision within the Development Strategy Policy (STR1) is also welcomed.

7. The National Planning Policy Framework (NPPF) advises that local planning authorities (LPAs) should take a proactive, positive and collaborative approach to ensuring that a sufficient choice of school places is available to meet the needs of communities and that LPAs should give great weight to the need to create, expand or alter schools to widen choice in education (para 94).

8. DfE supports the principle of TWBC safeguarding land for the provision of new schools as part of development site allocations to meet government planning policy objectives as set out in paragraph 94 of the NPPF. When new schools are developed, local authorities should also seek to safeguard land for any future expansion of new schools where demand indicates this might be necessary, in accordance with Planning Practice Guidance and DfE guidance on securing developer contributions for education.[1] We would be happy to share examples of best practice.

9. TWBC should also have regard to the Joint Policy Statement from the Secretary of State for Communities and Local Government and the Secretary of State for Education on Planning for Schools Development [2] (2011) which sets out the government’s commitment to support the development of state-funded schools and their delivery through the planning system.

10. In light of the above and the Duty to Cooperate on strategic priorities such as community infrastructure (NPPF para 24-27) [3], DfE encourages close working with local authorities during all stages of planning policy development to help guide the development of new school infrastructure and to meet the predicted demand for primary and secondary school places. Please add DfE to your list of relevant organisations with which you engage in preparation of the plan.

11. Please note that there are two routes available for establishing a new school. Firstly, a local authority may seek proposals from new school proposers (academy trusts) to establish a free school, after which the Regional Schools Commissioner will select the successful trust. Under this ‘local authority presumption route’ the local authority is responsible for finding the site, providing the capital and managing the build process. Secondly, school proposers can apply directly to DfE during an application round or ‘wave’ to set up a free school. The local authority is less involved in this route but may support groups in pre-opening and/or provide a site. Either of these routes can be used to deliver schools on land that has been provided as a developer contribution. DfE has published further general information on opening free schools [4] as well as specifically in relation to opening free schools in garden communities. [5]



3 NPPF paragraph 24-27 specifies that this collaborative working should include infrastructure providers.


5 and

[TWBC: for further, specific comments, see:

Policy STR5 - DLP_8083
Site Allocations - DLP_8084
Policy EN3 - DLP_8085
Policy EN4 - DLP_8089
Policy H2 - DLP_8086
Appendix 5 (Infrastructure Delivery Plan) - DLP_8087
Developer Contributions and CIL - DLP_8088]


29. Finally, I hope the above comments are helpful in shaping TWBC’s Local Plan, with specific regard to the provision of land and developer contributions for schools. Please advise DfE of any proposed changes to the emerging Local Plan policies, supporting text, site allocations and/or evidence base arising from these comments.

30. Please do not hesitate to contact me if you have any queries regarding this response. DfE looks forward to continuing to work with TWBC to aid in the preparation of a sound Local Plan.


Highways England

Thank you for consulting Highways England regarding the above, seeking a response no later than 15 November.


Highways England has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority, and street authority for the strategic road network (SRN). The SRN is a critical national asset and, as such, Highways England works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs, as well as in providing effective stewardship of its long-term operation and integrity.

Highways England will be concerned with plans and/or proposals that have the potential to impact the safe and efficient operation of the SRN, in this case, particularly the A21.

Our primary concern, therefore, is the impact of proposed developments described in the Draft Local Plan (DLP) on the A21 trunk road.  Several key junctions within or beyond the Draft Local Plan area currently experience congestion during both AM/PM peak periods. Therefore, future development proposals that would impact the SRN network would need to be robustly assessed and mitigated via the appropriate channels.

Highways England has recently completed the dualling the A21 carriageway between Tonbridge and Pembury.  This work was undertaken between 2015-2017, and saw improvements to relieve congestion, maintain safety upon the SRN and maintain journey time.  At present, Highways England is currently working with its local service provider, AOne+, to development a standalone scheme of enhancements at Flimwell Crossroads, with details likely to become available late 2019/early 2020.  There are no other identified improvement works at this time on the A21.

Current traffic levels during the AM (08:00-09:00) and PM (17:00-18:00) Peak periods on the A21 indicate that there are a number of junctions which have congestions issues.  These include Kippings Cross, Lamberhurst, Longfield Road, Pembury Road, Mabledon and, beyond the borough boundary, Flimwell.

We therefore strongly advise that the emphasis within the Draft Local Plan should be placed upon reducing the need to travel and, where travel is necessary, to use more sustainable modes rather than relying on improvements being in place.

Any necessary improvements required as a result of proposed development would need to be identified, designed, managed and fully funded via the individual proposals or via a Local Plan mechanism.

Based upon the above, we have the following comments to make with regards various consultation documents:

Whole Plan

Highways England welcomes the opportunity to provide comments and notes the Duty to Co-operate discussions that have been held to date.

Within the Draft Local Plan (eg para 1.42), any reference to the Highways Agency should be changed to Highways England.

In supporting and considering draft local plans, Highways England will seek to influence the scale and patterns of development so that it is planned in a manner which makes best use of capacity on the SRN and will not compromise the fulfilment of the primary function of the SRN. Ideally, development locations should be chosen that would minimise travel and facilitate the use of sustainable transport.

Highways England will work with local planning and highways authorities to ensure that local plans and other relevant development plan documents are underpinned by a robust transport evidence base which fully assesses the transport implications of the growth options being considered. This will include two key assessments:

  • the individual and cumulative impacts of the authority’s policies and proposals upon the ability of the road links and junctions on the affected parts of the SRN to accommodate the forecast traffic flows in terms of capacity, safety and cumulative environmental effects; and
  • the interactions between the strategic and local road networks.

We will input to this work where we are able to, as well as share evidence that we have, and input our knowledge and experience of the network.

Summary and Conclusion

Highways England has assessed the Draft Local Plan and made comments in line with its remit to safeguard the safety and reliable operation of the Strategic Road Network.

Subject to the comments set out above, the Tunbridge Wells Draft Local Plan and its supporting documents contain policy, text and various means that should ensure that proposed developments effectively mitigate against any impacts upon the SRN.

However, in the short term there is an urgent need to address the various technical and other matters raised in our Technical Note on the Transport Model, and the implications for the wider Local Transport and Local Plan Evidence Base and the Local Plan policies and text.

Therefore, once you have been able to digest all the representations, it is suggested that the Council, Kent Highways, SWECO and Highways England meet to agree actions and a timetable.

I hope that the above information is helpful, but if you have any queries please do not hesitate to contact me.

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

Comments are entered as follows:

Section 2: DLP_8166
Section 3: DLP_8167
Policy STR 6: DLP_8168
Paragraph 6.511 (Policy TP 2): DLP_8169
Policy EN 9: DLP_8170
Policy EN 29: DLP_8171
Policy ED 1: DLP_8172
Development Management Section: DLP_8173

In a separate table below, we have provided a high level assessment of the allocated sites; although this is subject to the outcome of the local plan modelling and the Transport Assessment/Statement produced as part of any subsequent application.

For comments on site allocations see:

Frittenden: DLP_8174
Cranbrook & Sissinghurst: DLP_8175
Benenden: DLP_8176
Hawkhurst: DLP_8177
Five Oak Green, Paddock Wood & Tudeley: DLP_8178 (and Capel DLP_8179)
Southborough incl. Mabledon: DLP_8180
Royal Tunbridge Wells: DLP_8181
Pembury: DLP_8182
Horsmonden: DLP_8183
Matfield: DLP_8184
Lamberhurst: DLP_8185
Goudhurst: DLP_8186

Evidence Base

Local Transport Evidence Base (SWECO): DLP_8187
Infrastructure Delivery Plan: DLP_8188


Maidstone Borough Council

Thank you for consulting Maidstone Borough Council (MBC) on the draft Tunbridge Wells Borough Local Plan (TWBLP). The responses below are officer-level comments, submitted ahead of the extended consultation deadline of 5pm, 15 November 2019.

Duty to cooperate

The Localism Act 2011 places a legal duty on planning authorities to engage constructively, actively, and on an ongoing basis, to ensure the effectiveness of Local Plan preparation in relation to strategic, cross-boundary issues. Effective and on-going joint working between strategic policy-making authorities is integral to the production of a positively prepared and justified strategy. MBC formally responded to Tunbridge Wells Borough Council’s (TWBC) previous Local Plan consultation in 2017 and has continued to be informed of, and involved in, the preparation of the most recent draft Local Plan (the subject of this formal consultation) through regular officer-level meetings. This includes meetings to consider the proposed larger settlements/garden communities. MBC therefore considers that the duty to cooperate in planmaking between the two authorities is working successfully to date.

Strategic issues

The draft Local Plan is extensive and comprehensive, containing the spatial strategy for the borough, strategic and development management policies, land allocations and policies maps. As a neighbouring planning authority, MBC’s primary focus is matters of a strategic, crossboundary nature and as such this forms the basis of our comments.


The proposed spatial strategy is one of a dispersed growth approach, with site allocations in the majority of the settlements across the borough. In addition, proposals are included for a new garden settlement in Tudeley and the transformational expansion of Capel and Paddock Wood. This ‘transformational expansion’ is directly to the south of MBC’s administrative boundary and therefore has the greatest potential effect on Maidstone Borough. The matter will be discussed further under the heading Policy STR/PW 1, below. 

The objectively assessed need (OAN) for housing in the borough over the plan period is identified as 13,560 new dwellings to 2036. MBC recognises that the draft TWBLP proposes to fully meet this identified need over the plan period, and that at this stage TWBC are therefore not expecting any other authorities, including MBC, to accommodate any unmet need. This approach is fully supported. Similarly, MBC acknowledges the indication in the draft TWBLP that there is limited ability for TWBC to meet any unmet housing needs from other councils. MBC is at an early stage in our own Local Plan Review (LPR) process and will progress on the basis of seeking to meet our own OAN for housing without the need to seek to accommodate any unmet need from TWBC. As with all strategic matters, this shall be kept under review through regular and ongoing communications between the two authorities under the duty to cooperate.


The TWBLP strategy for employment growth is based on the outcomes of the Sevenoaks and Tunbridge Wells Economic Needs Study (2016), which includes the target of at least 14 hectares of new employment land allocations. This allocation is to be reviewed as part of the preparation of the Regulation 19 pre-submission TWBLP. MBC is fully supportive of this review approach as it reduces the risk of basing land allocations on evidence data that would be five, possibly even six years old at the time of submission and potentially ‘out of date’. It ensures that, as far as possible, the most accurate amount of land is allocated for employment uses based on the most up to date evidence at the point of submission.

The strategy to meet employment needs through allocations at, and extensions of, the defined Key Employment Areas (KEAs), particularly in proximity to the A21 Growth Corridor appears to be a logical and sensible approach. The expansion of the KEA around Maidstone Road and Paddock Wood is supported in principle and may well offer opportunities for residents and businesses particularly in the south of Maidstone to utilise the planned employment offering. MBC would request to be kept informed of the proposed make up of B1/B2/B8 employment uses as they become clearer throughout the masterplanning process specifically at Paddock Wood.


The proposed retail strategy is based on the 2017 Retail and Leisure Study, which projects the retail forecast forwards to 2033. MBC supports the approach to allocate retail floorspace for the first ten years of the plan period and to review this after five years, in line with the NPPF requirements. This is a particularly sensible approach given the current uncertainties surrounding the retail industry, and the difficulties this presents in projecting robust medium to long term forecasts with any real degree of certainty.

MBC agrees that the proposed additional provision of 400-700sqm of comparison retail floorspace plus additional town centre uses in Paddock Wood is consistent with, and justified by, the proposed increased level of growth of the town’s population. The additional shops and services constitute a sustainable pattern of development and may also be beneficial for residents in the south of Maidstone, living within a reasonable proximity of Paddock Wood.

Infrastructure and connectivity

The draft TWBLP growth strategy is based on the premise of infrastructure-led development to ensure that essential infrastructure and connectivity is integral to all new development. MBC strongly supports this approach to delivering growth, particularly the emphasis on ensuring that sufficient infrastructure capacity is either available or can be provided in time to serve new development (criterion 5, policy STR5).

As a minor point of correction, under the heading of ‘Water’ in policy STR5, Kent County Council should be referred to as the Lead Local Flood Authority as opposed to Agency.


MBC considers the draft TWLP strategy in relation to transport and parking to be a sustainable yet pragmatic approach. Delivering sustainable patterns of development and prioritising sustainable and active modes of transport, whilst recognising that private car ownership in the borough is currently very high and that sufficient levels of parking should be provided, offers an appropriate balance. The recognition of the rapid development of technology in transportation, including in relation to autonomous vehicles is welcomed and the acknowledgement that policy STR6 may require updating as part of the five-year review of the Local Plan is strongly supported by MBC. This approach provides a clear opportunity to refine and revise policy over the short-term to ensure it aligns with the latest evidence and best practices at the time.

[TWBC: see also comments on the following:

Policy STR/PW1: DLP_8234

Policy AL/PW1: DLP_8235

Maidstone Borough Local Plan Review

As alluded to earlier in our response, MBC is undertaking a Local Plan Review (LPR) of the adopted Maidstone Borough Local Plan (MBLP) 2017. As part of this, we carried out a public Call for Sites exercise, which ended in May 2019 and resulted in over 300 sites submitted to the Council for consideration for inclusion in the LPR. Whilst we are yet to assess the suitability of these sites for future development, all submissions are available to view on the Council’s website:

Your attention is drawn to the fact that some sites abut or are in proximity to the TW borough boundary. Site 273 in particular is located directly adjacent to your proposed allocation PW1_3 (as shown on the Paddock Wood Draft Policies Map). In the submission material, the site has been put forward for consideration for mixed employment uses in the first instance. As an alternative, the landowners would consider flood mitigation/SUDS uses to allow greater levels of housing on your proposed allocation (PW1_3). This is something MBC would welcome discussion with TWBC on, however, as the draft TWLP is able to meet its full housing needs, it is not expected that site 273 would be required purely for flood mitigation/SUDS purposes in order to allow greater levels of housing development within Tunbridge Wells borough. Indeed, MBC have received no such request from TWBC to date. At this stage, MBC are yet to assess our received site suggestions and as such, cannot say whether this site would be suitable for allocation as part of the LPR. Even in the instance that it is suitable, our evidence on employment land requirements and subsequent formulation of a strategy for the borough’s employment growth is yet to be formulated, therefore we cannot say at this stage whether the site would be required for allocation, regardless of its suitability.

Whilst MBC and TWBC are clearly at different stages in the plan making progress, it is important that these sites are considered holistically as part of the broader location to ensure a sustainable and joined up approach to planning the area, should MBC ultimately determine the site suitable for allocation. MBC are therefore very supportive of TWBC’s Council-led comprehensive masterplan approach to the broader area (policy STR/PW1). We would expect the masterplan to have regard to MBC’s LPR and any sites we may be assessing as part of that process, and that any further work from TWBC in this regard is made available to MBC to ensure cohesive strategic planning.

I hope these comments are helpful and look forward to continuing, constructive dialogue on strategic, cross boundary issues as part of the duty to cooperate as your Local Plan progresses.