Section 1: Introduction
This response report contains comments received on Section 1: Introduction.
Contents
Section 1: Introduction
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_18 | Darren White | It's difficult to make comment on this section if the text will not load opposite. |
DLP_62 | Thomas Weinberg | I am writing this out of deep concern caused by reading the Draft Local Plan, Regulation 18 Consultation Draft (20 September to 1 November 2019). I am made even more anxious after reading the Sustainability Appraisal of that plan. I am worried on a personal level, as the unavoidable pollution and noise will affect the health of my son. I am also distressed that historic communities will be carelessly and needlessly destroyed. The two documents are incomplete and worryingly misleading in a number of aspects which makes them entirely unfit for review by those who will be affected. They are also deeply compromised by being the product of a series of committees all chaired by one individual. That is not an allegation of corruption but one of alarm at the clear impossibility of fair and impartial assessment. I am also shocked that in the current environmental context that development which has not been evidenced to be necessary will destroy Green Belt land unnecessarily. It is astonishing that this plan has been shared when its impact is both environmentally and morally unsupportable. I hope that it will be withdrawn and reconsidered with far greater input from those this Council aims to serve. |
DLP_1582 | Mr Raymond Moon | Section1. Introduction. OBJECT. Foreword. In relation to this Draft Local Plan it is detailed, but also lacks the relevant detail of various objections to the need for an Infrastructure to be in place and the need for a Masterplan before any new houses are built in PW. The Surface Water and Foul Water flooding problems have not been addressed at this moment in time, even with the 900 new houses already approved by TWBC. The proposed new 4,000 houses and those planned for Capel cannot be agreed before the present problems are solved and any planned improvements for the future must be in place before any new houses are built. The Town centre needs to be redeveloped, for too long it has been a mess and allowed to remain that way, and its redevelopment can only benefit the local community and our retail outlets. Our identity as a Small Rural Town must be protected with any future development and must include buffer zones with our neighbouring villages. There is a lack of “ joined up” thinking in the Draft Plan concerning all the various documents and the Masterplan must address these issues and be implemented to prevent developers dictating the policy and shape of our Town. Introduction. The Draft plan mentions the adjacent Borough of Tonbridge and Malling (T&M) in relation to a proposed new school near Somerhill which is right on the boundary of T&M. There is no evidence that the new school will solely cater for new development in Capel & Paddock Wood.It is probable many places will be taken by T & M and would mean expansion of Mascalls in PW as it would not be able to cope with the extra new places. There should be a joint plan with TWBC and written proposals from T & M as part of this consultation. |
DLP_2004 | Dr David Parrish | Introduction – Plan preparation process – para 1.4 – p.13 No one in the Community was effectively approached in seeking early views on the development of the plan I understand just an A4 page notice went up in the village shop. The public were made aware of the Local Plan very late in the stage (May 2019). I know the press, CPC and employees of Hadlow Estate were all put under Non Disclosure Agreement (NDA) notices during the earlier planning stages. Not the action of an open, listening, TWBC who were elected to support their people. Introduction – Public Consultation – para 1.15 – p.15 The communications are not fully inclusive The proposed and current approach discriminates against older, vulnerable, IT-illiterate members of the public who have no access to the TWBC website – and thus no idea of what is planned – or the ability to comments. Employees of Hadlow Estate have been placed under NDA notice and cannot participate in the Consultation. |
DLP_2271 | Jackie Bourne | I Object: Central Government has determined the direction of the long-term strategic planning document for every County in the Country. Where is the research for Cranbrook and Sissinghurst that shows so many houses are required; and where are the people coming from? The population has steadied, and the only Group substantially increasing is the Older Persons Group, so the DLP should focus on this Group and its needs in the next decade or so, but without disregarding the requirements of younger Groups and Families. |
DLP_2273 | Jackie Bourne | I Object: Quote from Section 1, Page 14: However, six of the nine sites, ie two thirds of the Cranbrook and Sissinghurst sites, are within the AONB (AL/CRS 1, 2, 3, 4, 5, 7, 9), plus one (AL/CRS 14), adjoins the AONB. Additionally, at least three (AL/CRS 1, 2, 5) are also within or adjacent to the Wilsley Conservation Area, and one site (AL/CRS 4) contains Ancient Woodland, which is irreplaceable. How can this be defended, other than saying the Borough has to find the sites somewhere! This is just not acceptable. |
DLP_2486 | Mr John Wotton | I am a resident of Cranbrook & Sissinghurst Parish. I agree with the comments on the draft Local Plan submitted by CPRE Kent (of which I am Chair), including those submitted by CPRE Kent's Tunbridge Wells District Committee (of which I am a member). I have also seen in draft and agree with the comments submitted by the High Weald AONB Unit. My comments on the policies contained in the draft Local Plan are made in a purely personal capacity. |
DLP_2718 | Paddock Wood Labour Party | Section1. 1-2. Section1.OBJECT. Introduction. Foreword. Vision Paddock Wood Labour Party (PWLP) recognises the challenges in the Local Plan to deliver on ambitious housing targets to 2033. Development though should be focused primarily on brownfield sites with undeveloped green sites safeguarded for future generations to enjoy as countryside, parks and open space. We believe that more effort should be made by TWBC to identify more Brownfield sites in the Borough to meet their housing targets. New infrastructure rather than through piecemeal smaller developments is essential for the new 4,000 houses in PW and needs the implementation of the Masterplan. With this in mind PWLP broadly supports the principles contained in the Local Plan to deliver new development subject to commitments on providing affordable & social housing including a significant proportion for social rent (as outlined in the Local Plan) and the new infrastructure being installed before any new houses are built in Paddock Wood. Local living wage - TWBC should take the lead and pay all workers including those employed by third parties carrying out services on their behalf a living wage. This sets a clear example to other employers in the Borough to ensure that no one should be paid a wage which guarantees being in poverty. Introduction In relation to this Draft Local Plan it is detailed, but also lacks the relevant detail of various objections to the need for an Infrastructure to be in place and the need for a Masterplan before any new houses are built in PW. The Surface Water and Foul Water flooding problems have not been addressed at this moment in time, even with the 900 new houses already approved by TWBC. The proposed new 4,000 houses and those planned for Capel cannot be agreed before the present problems are solved and any planned improvements for the future must be in place before any new houses are built. The Town centre needs to be redeveloped, for too long it has been a mess and allowed to remain that way, and its redevelopment can only benefit the local community and our retail outlets. The identity of Paddock Wood as a Small Rural Town must be protected with any future development and must include buffer zones with our neighbouring villages. There is a lack of “ joined up” thinking in the Draft Plan concerning all the various documents and the Masterplan must address these issues and be implemented to prevent developers dictating the policy and shape of our Town. |
DLP_2827 | Helen Parrish | Cross-referenced, detailed, reasons for my Objection: No one in the Community was effectively approached in seeking early views on the development of the plan |
DLP_2982 | Mr Keith Lagden | Comment relating to the 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. I certainly have and just hope this gets through so it can be taken note of! Nowhere does the Council encourage people simply to send in their comments in their own words. 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 I would draw your attention to the FACT that Hawkhurst has a Neighbourhood Development Plan which has been “made” and it is therefore a requirement that TWBC takes this into account when developing the Local Plan. Clearly when reading the Local Plan it is obvious that TWBC have ignored the NDP for Hawkhurst. |
DLP_3789 | Mr Peter Jefferies | TWBC: the following standard response was submitted by the list of 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 the majority of local residents and the Hawkhurst Parish Council, to preserve their village and their rural way of life. |
DLP_3863 | Mrs June Bell | The DLP fails to demonstrate confidence in Neighbourhood Plans, made or in progress and my concern is there is lack of due regard for Neighbourhood plans. Reasons for comment: These paragraphs do not confer confidence that TWBC will follow its legal duty as identified in the Localism Act to allow communities to make meaningful decisions over scale and location of development and policies to preserve and enhance their communities. Hawkhurst has a ‘Made’ (passed successful examination by independent Inspector) and locally endorsed Neighbourhood Plan. |
DLP_6740 | Mrs Carol Richards | Introduction – Plan preparation process – para 1.4 You state that the Issues and Options process in 2017 sought early views on the best way to approach specific challenges, but it is not clear that these views have been taken into account. |
DLP_6741 | Mrs Carol Richards | Public Consultation – para 1.10 I object to the assertion that the Council is adequately seeking “an opportunity for you to have further input”. Evidence – paras 1.30 – 1.33 Duty to Cooperate – para 1.38 Producing a new Local Plan p17-21 1.27 1.29 Neighbourhood plans – paras 1.34-1.37 There is nothing neighbourly about having a policy that has the potential to cause more flooding into neighbouring boroughs and will cause havoc – gridlock-on roads, in shops and services in Tonbridge. |
Purpose of the Plan
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_36 | Thomas Weinberg | Comments the Introduction – Plan preparation process – para 1.4 - p.13 |
DLP_121 | Gregg Newman | You state that the Issues and Options process in 2017 sought early views on the best way to approach specific challenges. This is a TWBC Consultation but actually and directly affects residents also of Tonbridge and Malling Borough Council. There was no early consultation in respect of either development that was notified to residents of TMBC in a way that could easily be responded to. TW residents will not be affected by the Tudeley/Capel development at all. |
DLP_849 | Ian Pattenden | Comments the Introduction – Plan preparation process – para 1.4 - p.13 Your Issues and Options process in 2017 excluded any mention of a garden settlement at Tudeley. One of the key issues raised as a result of the Issues and Options consultation was the protection of the green belt; Tudeley is in the centre of the Green Belt and therefore undermines the soundness of this plan and undermines the effectiveness of this current public consultation. |
DLP_956 | Mrs Karen Stevenson | I have a concern regarding the language used often being imprecise, creating space for flexible interpretation when making planning decisions. For example, it includes phrases such as, “consideration will be given to…,”“… will not normally be permitted,”“where possible…” and “encourage improvements.” Whilst policy may appear to protect, the language is not sufficiently robust to achieve consistency, transparency, nor confidence in the protection it refers to. It will assist misinterpretation when making planning decisions and could undermine policies that the local plan should be seeking to enforce. |
DLP_3866 | Ide Planning for Paddock Wood Town Council | OBJECT 1. The Plan is confined to the borough’s boundary. The strategy proposes transformational change to Paddock Wood/east Capel, and a new settlement at Tudeley, close to Tunbridge Wells and Tonbridge. Paddock Wood would no longer remain a small rural town. The strategy proposed would more sharply divide the borough into an urban west and rural east. 2. There is a Duty to Cooperate in Plan preparation concerning strategic cross boundary matters. Statements of common ground have not yet been agreed with Tonbridge and Malling BC, or for West Kent. 3. In its present form, the Plan should proceed on the basis of a joint Plan that includes Tonbridge and Malling BC (i.e. Tonbridge) and perhaps part of Maidstone BC in order i. to ensure cross boundary issues are fully addressed including health, transport, social care and education; 4. For development to be sustainable there is a need to identify land for the right type of development, sites must be in the right place, and development must be supported by infrastructure. c. further to ‘b’, it is unclear at the moment what this means for the individual parcels identified for development under AL/PW1. For example, in the Level 2 Report, for parcel 1, it was noted by the borough council’s consultants ‘Parcel 1a is located in the path of an easterly flood flow route, which continues into Paddock Wood. During initial discussions with the council, it was agreed to position the residential area in this location (and therefore not following the sequential approach for placement of development)…’ (Appendix I). 5. Whilst the LPA subscribes to garden settlement principles in guiding development at Paddock Wood/east Capel and Tudeley, it is unclear whether both places could be designated as garden villages and so benefit from assistance that the government’s programme can provide. The Plan proposes masterplanning and betterment as a cure-all. When the planning, resource and coordination that is implied by this is compared, to take one example, with Homes England’s garden community initiative in West Ifield (West Sussex), PWTC remains unconvinced that the borough council, despite its best intentions, has the capacity to deliver its strategy in its present form. 6. Homes England suggests ‘given its complexity, potential for infrastructure provision needed up front and long timeframe for delivery, CIL may not always be feasible or appropriate for a garden community scheme’ (MHCLG Land Value Capture and Funding Delivery, 27th September 2019). 7. The LPA’s assessment of housing need/provision inflates housing numbers required over the Plan period which has a bearing upon the allocations proposed for Paddock Wood/east Capel. 8. With regard the distribution of housing development, objection is made above under ‘4’ above to the loss of green belt. It is considered there is more scope for development to be allocated elsewhere within the borough. For example, Cranbrook has escaped the development allocated in the SALP, whilst Hawkhurst (a smaller town in the Borough & the AONB) has seen considerable house building and is taking more houses than Cranbrook in the draft Local Plan. Why has Cranbrook not been allocated an increased share, when flooding is not a problem and the town centre is well established with schools that have capacity for increased student numbers? It is possible to build sympathetically within the AONB – other Boroughs have done this. It is also unclear whether some of the development proposed at Paddock Wood/east Capel could be more sustainably located at Tudeley. 9. Questions arise concerning the identification, prioritisation and phasing of specific infrastructure schemes and hence the deliverability of the strategy. In respect of their prioritisation, more infrastructure may be critical and essential than desirable. Of particular concern is how critical many of the projects are, the magnitude of cost, the uncertainty concerning their phasing and the funding position overall. For example, the IDP lists the new Colts Hill bypass as being critical (p94), as needing to be in place before sites come forward for development, yet the all-important policy STR1(2) refers to the bypass in terms of it being a potential scheme. Comment follows [below] on improvements required to the highway network to accommodate the development proposed. These improvements are needed to add to capacity locally and to mitigate impacts upon air quality. 10. The viability of the Plan is unconfirmed – whilst the Stage 1 Viability Assessment says the consultant’s find reasonable viability prospects available borough-wide to support the Plan’s delivery, the viability of the larger/strategic site allocations has yet to be addressed in a Stage 2 assessment. Dute to cooperate OBJECT as above |
DLP_4103 | Tunbridge Wells District Committee Campaign to Protect Rural England | It does not appear to CPRE’s Tunbridge Wells District Committee that the key concerns expressed in the hundreds of responses to the Issues and Options document have been adequately met in this new draft Plan, which appears to us to have been more led by slavish adherence to Government housing targets, a wish to justify building some new roads that have long been desired by KCC and TWBC, and the easy option of dealing with a single willing landowner in the Southborough/Capel area, than by the very reasonable and justified concerns of the local population. That said, we recognise the constraints imposed by Government policies and legislation and by the Council’s limited powers. Please see our and CPRE Kent’s Head Office’s comments on Policies for more detail. |
DLP_4448 | Paddock Wood Neighbourhood Plan Steering Group | The Plan is confined to the borough’s boundary. The strategy proposes transformational change to Paddock Wood/east Capel, and a new settlement at Tudeley, close to Tunbridge Wells and Tonbridge. Paddock Wood would no longer remain a small rural town. The strategy proposed would more sharply divide the borough into an urban west and rural east. Although outside the Neighbourhood Plan designated area we are very concerned about the loss of Green Belt between Paddock Wood and Capel. For development to be sustainable it must be supported by infrastructure that is reasonably necessary. All the housing sites identified in the Key Diagram and under AL/PW1 require flood compensation. This will absorb developer contributions better put elsewhere and compromises the garden village ideal that underpins the strategy for Paddock Wood/east Capel. Questions arise concerning the identification, prioritisation and phasing of specific infrastructure schemes and hence the deliverability of the strategy. In respect of their prioritisation, more infrastructure may be critical and essential than desirable. Of particular concern is how critical many of the projects are, the magnitude of cost and the uncertainty concerning their phasing, and the funding position overall. For example, the IDP lists the new Colts Hill bypass as being critical (p94), as needing to be in place before sites come forward for development, yet the all-important policy STR1(2) refers to the bypass in terms of it being a potential scheme. The Plan proposes masterplanning and betterment. The NP group still has to be convinced that TWBC can deliver this. |
DLP_7265 | Mrs Katie Lee-Amies | Section 1, para 1.7 1. The consideration of responses to the 2017 Issues and Options Consultation (September 2019) is skewed to suit the location of a new settlement in Tudeley. 67% of responses disagreed with The Vision; 60% of responses ranked Option 4 (Growth corridor-led approach) as most preferred. However, TWBC dismiss the feedback and respond that one of their three development strategy options is:
The above statement is misleading. TWBC need to explain why they have selected Option 5 development strategy. 2. The other two development strategy options are:
Negative issues associated with the second and third strategy options implies that the first option is more favourable. This is a deliberate unbalanced view and also misleading. The strategic development selection process has not been objective. 3. When asked about views of a new settlement in TWB, the majority of responses suggested that the new settlement should be outside the AONB and Green Belt. Some suggested that there is no suitable location in TWB for a new settlement with 5,000 – 7,000 homes. The emerging Local Plan has dismissed the findings of the Consultation and cherry picked responses as justification for pursuing Tudeley as a legitimate growth option. |
DLP_7498 | Sarah Parrish | Why was no one approached in seeking early views”. |
DLP_7826 | Andrew Chandler | The draft Local Plan does not represent a 15 year strategic plan for Sissinghurst. All sites included for development are subject to current development proposals and so this is at best a 3 year plan for our village. It is in reaction to and an endorsement of recent aggressive development proposals and you should not suggest otherwise. We have been let down by the TWBC planning department in recent years and these proposals will perpetuate that situation and irretrievably change the character and settlement pattern immediately adjacent to the High Weald AONB. This is not good planning. |
Public consultation: how to get involved
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_37 | Thomas Weinberg | Comments the Introduction – Pubic Consultation – para 1.15 - p.15 |
DLP_81 | Roger Bishop | Summary The Plan contravenes Government policy on the Green Belt, and TWBC’s policies and aspirations with regard to, for example, the environment and biodiversity, climate change, transport, and heritage assets, all in the pursuit of meeting a stated housing need which it is acknowledged is not soundly based. The demographics of Capel mean that many residents are unable to use a computer and/or have no access to one. They are penalized twice over. First, they are unable to access and read the Plan. This is especially worrying as you have said that if they don’t relate their comments to a specific section of the Plan or Sustainability Appraisal they may be misinterpreted or ignored. Secondly, they will receive no acknowledgement of any comments they send by post (and these people have no alternative), nor be able to view the comments of others. [TWBC: see also comments DLP_81 to 93]. |
DLP_122 | Gregg Newman | We live directly opposite the residence of the landowner proposing the development in Tudeley. When we place posters regarding the SaveCapel.com campaign on the hedges outside our property, they mysteriously disappear as soon as we are no longer watching. There is no doubt that besides the inability of many older residents to have their voices heard (because of lack of access to internet or simply inability to communicate effectively in the modern environment), there is a concerted and sinister campaign by a very wealthy landowner to stifle the voices of poorer and less influential residents. There are definite echoes of the feudal era here. |
DLP_850 | Ian Pattenden | Comments the Introduction – Pubic Consultation – para 1.15 - p.15 You have stated that if we don’t relate our comments to a specific section of the Plan or Sustainability Appraisal they may be misinterpreted or ignored. This appears to me that a conscious effort has been made to make the consultation process overcomplicated and difficult to respond. You have spent years producing huge amounts of technical documents, yet we as ley persons have just 6 weeks to digest all of this technical information and make comments to specific paragraphs. Moreover, it is clear that whilst small developments have been carefully considered, the vast majority of the Borough’s proposed development is in Capel and that aspect is vague, confused and lacks detail. |
DLP_1560 | Peter Hay | 1.11 Period for consultation is wrong 1.13 and 1.14 Process for making comments is very confusing and not clear where to go or what the process is. Seems to be conflicting website addresses giving completely different layout beta on non beta? 1.19 Consultation times was poor and not sufficient for those who work some distance from exhibition locations and were unable to reach the venue before closing. 7pm far too early. |
DLP_1970 | Ms Jacqueline Stanton | I strongly object to the public consultation process for the Draft Local Plan. Whilst the public exhibition was useful, the whole process for making comments discriminates against a large section of the population. 1. People with accessibility needs (for websites etc) would not be able to view the documents; 2. People who do not own a computer cannot easily record their comments, thus making it unlikely they will bother doing so; 3. The many hundreds of pages and variety of documents are difficult to understand; 4. The online system expects a level of understanding of policies and legislation the general public may not have and references many other policies and legislation. In addition, the whole process is complicated and not user-friendly, thus, again, putting off people making comments. |
DLP_1973 | Mr Jeremy Waters | Even as a regular, experienced computer user I have found this process extremely tiresome and frustrating so I am certain that a very large proportion of respondents will give up trying. The forms are very time-consuming and confusing to complete and requires respondents to cross-refer codes to the plan. Overall I think that it is discriminatory against residents who are unable to devote the time and perseverance to completing it. |
DLP_2016 | Penelope Ennis | TWBC: the following standard response was submitted by the list of responders on the left: Comment relating to the procedure for submitting comments on the Draft Local Plan. This is an impenetrable procedure designed to dissuade comment from an already ‘battle weary’ community besieged with planning applications. I know that a few members of our community will able to work online and offline to complete the document you have provided. Those who do put something on paper will undoubtedly complete the process in a way that you do not consider valid and others will not comment. You may interpret this as disinterest I fear but our community is anything but disinterested. I have concerns over your Consultation Process. I was unable to attend the public event but I hear that you ran out of material for residents to take away. It takes 4 maybe 5 clicks to reach the point that residents can comment on the document and I believe that to be against the principles of consultation. |
DLP_2278 | Jackie Bourne | I Object: This whole Planning process seems very complicated, and not resident friendly. It really needs simplifying. In addition to the DLP (500+ pages long), there are numerous other reference documents to consider, if you wish residents to make, and the Council to receive, meaningful, relevant and constructive comments. Naturally, subjects can cross over a number of Sections and Documents, so it makes the process very time consuming and complex to fully understand. Not everyone, particularly those working full time and with families, may not have the time, or are disheartened with the process, or are not familiar with vast official Documents and Forms. However, whatever the reason, the majority will not pursue such an onerous task, and make meaningful or constructive comments, no matter how many weeks consultation there is. Personally, I have already spent a few hours on the process. |
DLP_2686 | Stephen Crane | Para 1.13 Consultation Portal together with 1.14 and 1.15 Response form in MSWord |
DLP_2745 | Rosanna Taylor-Smith | I attended the event in Hawkhurst on 30/9/2019. The timing was not convenient for many residents who work and there were insufficient numbers of the outline draft local plan brochure as there were none left mid way through the event. No forms were available to take away with details of how to comment and for many without access to a computer, this means that they were left without details on how to respond. The process of responding online is also fairly difficult to navigate and personally I have had significant difficulties in accessing much of the consultation on many occasions. Page not found and error messages are repeatedly what I find when coming back to answer more sections. Not good enough TWBC. (I have responded on other occasions to draft local plans in 2 other local authority areas with far less difficulty) |
DLP_2828 | Helen Parrish | Cross-referenced, detailed, reasons for my Objection: The communications are not fully inclusive |
DLP_2860 | 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. I attended the display of the plan in the Victoria Centre where staff were available for discussion. It was difficult to have conversation in the noisy open area of the concourse and this was a disadvantage, and a better option would have been the quieter location, where a fully recorded discussion may have been held. |
| DLP_3048 | Mr Adrian Cory | I find the process mandated by the Council for commenting on the Draft Local Plan to be extremely onerous. The process does not allow for the submission of narrative commentaries, but instead prescribes two highly structured and complex proforma, one hosted online and an offline alternative in similar form. The online form is unlikely to be used by those who are not comfortable with the technology and also by those who (like myself) are expert users of IT but whose experience leads them to distrust Web-based forms owing to their propensity to malfunction, losing previously entered content. The offline form is long and complex, requiring comments to be assigned to the correct text boxes (which are sometimes ambiguous) and requiring sections of tables to be copied and pasted. This, again, will deter those who are not comfortable dealing with Word documents. Both proforma require comments to be structured in a form which is clearly designed to assist officials in consolidating comments at the expense of complexity in completing the form. 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. It is hard to avoid the conclusion that this is a deliberate tactic by TWBC to minimise public response to the proposals. 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. |
DLP_3419 | Mr A J Holding | TWBC: the following standard response was submitted by the list of responders on the left: |
DLP_3753 | John Windeatt | I assume that comments submitted by letter will be considerd equally with those more formally submitted on the Response Form as suggested and referred to in this clause. I refer particularly to my letter to Stephen Baugham dated 20 May 2019, and another letter to Kevin Hope dated 19 September 2019 both of which refer to the proposed development at the Hawkhurst Golf Club. Please confirm your receipt of these letters and that they will be included with the other responses |
DLP_4984 | Kristina Edwards | 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. 2.7. This section (and the Plan itself) misleadingly equates the village of Hawkhurst with the much larger towns of Paddock Wood and Cranbrook. The Plan wrongly treats Hawkhurst as an urban area and applies strategic planning policies designed for urban areas to the rural village. This is a major error in the Plan. As a village, Hawkhurst should be counted among the “variety of villages and hamlets” mentioned in paragraph 2.8, not bracketed together with towns like Paddock Wood and Cranbrook. 2.11. The Draft Local Plan claims that the infrastructure needs associated with new developments will be assessed and addressed. This claim lacks credibility because the council either does not have the necessary powers of compulsion in relation to infrastructure, or has a track record of failing to use the powers it does possess. We therefore cannot rely on this reassurance. 2.13. This paragraph records that sustainable development is a key theme underpinning national planning policy. This submission argues that many of the proposals in the Plan (including those for Hawkhurst) do not remotely meet the sustainability criteria, or reflect provisions in the NPPF relating to AONBs. 2.32. The Draft Local Plan demonstrates that the council is failing in its duty as custodian of the AONB within its boundaries. There is very little content in the Plan which recognises its responsibilities to preserve the AONB, which accounts for 70% of the Borough. The reference in this paragraph to ensuring that development “does not have an unacceptable adverse impact on the character and setting of the natural and build environment of the borough” is ironic in view of the many proposals in the Plan which will clearly have such an adverse impact. 2.46. The assertion, here, that the Plan will encourage the provision of community leisure and recreation facilities is called in question by the proposal to replace the Hawkhurst golf course with a housing estate. It is merely one example of the insincerity and “lip service” which pervades the whole Plan. |
DLP_5104 | Mr Peter Brudenall | TWBC: the following standard response was submitted by the list of 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. |
DLP_5273 | Rachel Smith | I am a resident of Paddock Wood and have lived in 3 homes within the town over a period of around 30 years. I am providing my remarks in an email as I do not have the time to get to grips with the planning portal and risk losing my comments, as has been reported in social media. Indeed, the first point I wish to make is that I am aware that many individuals are not responding for this very reason. The production of the 8-page outline document has been very helpful but people I know do not have the time or patience to research the full Draft Local Plan and comment as advised. I concur with the points made by Mr David Smith (no relation) as published in your response report ‘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.’ |
DLP_5279 | Susan Lovell | I am very upset that the consultation was not made easy for people who find it difficult to respond, such as the elderly, infirm, those who have mental health problems, etc. I do not believe TWBC has served its residents at all well in this process. |
DLP_5702 | Mrs Jacqueline Cobell | ACTUALLY I OBJECT TO YOU THREATENING TO IGNORE MY COMMENTS IF I DON’T RELATE EACH COMMENT TO A SPECIFIC SECTION AND PARAGRAPH. BEARING IN MIND THAT YOU SHOULD KNOW YOUR DRAFT LOCAL PLAN LIKE THE BACK OF YOUR HAND YOU SHOULD BE ABLE TO RELATE ALL MY COMMENTS TO YOUR SECTIONS AND PARAGRAPHS. THIS OBJECTION LETTER THAT WE ARE SUPPOSED TO WRITE ON YOUR TERMS IS INTIMIDATING, CONDESCENDING, AGEIST AND DONE ON PURPOSE TO CONFUSE THE ORDINARY FOLK. HUMANITY IS THE GREATEST QUALITY THAT MAN CAN HAVE, ARROGANCE IS UNDOUBTEDLY THE WORST !! I’M SURE MY FRIEND AT THE BBC WILL BE VERY INTERESTED TO KNOW HOW THE NUMBER OF OBJECTORS HAS BEEN KEPT LOW DUE TO THE HOOPS AND HURDLES THAT THEY HAVE HAD TO MEET TO AVOID BEING IGNORED |
DLP_5817 | Charles Vernede | TWBC: the following standard response was submitted by the list of 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. |
DLP_5898 | Tim Elliott | The complete document is not easy to read nor access, it is clear that the plan has been written by experts, but they need to use language that is accessible to the residents of Tunbridge Wells. It uses too much impenetrable jargon. The consultation website is poor. It is very difficult to access on apple Macs and difficult to leave a comment. Registration is complex and I have failed 3 times to do so. It is almost if TWBC does not actually want anyone to comment. |
DLP_5957 | Mr Chris Austen | Regarding the Draft Local Plan for Hawkhurst it was very disappointing that TWBC Planning Department only showed the plan for one afternoon from 4.00pm -7.00pm This prevented anybody who works away from the village, especially commuters, to be unable to come to the display and talk to the Planning Dpt. When the NDP was being prepared we stayed available until 10.00pm in the evenings and were also available on Saturday mornings giving all residents the opportunity to come and discuss the NDP with us. We feel that the consultation for this DLP is nothing more than ticking a box to say that there was a display of some kind. |
DLP_6113 | Charlotte Walter | As a resident who suffers from post stroke fatigue, I have found it very difficult to be able to submit my comments as the portal is not user friendly, nor is the form below. It feels intentional that TWBC have made this process difficult to dissuade older residents or those with mental health problems to not be able to respond. |
DLP_6117 | Charlotte Walter | I have attached the form to object to the over development of Paddock Wood. It is not completed in all the boxes as I found it very difficult to navigate. I feel that it is intentional of TWBC to make a response so complicated to put people off. What about people, such as myself, who suffer with a disability and find the form and online portal difficult to understand? What about the older generation who don't use computers and don't have the mental energy to try and understand how to fill in all the boxes? [TWBC: comments in response form submitted have been entered into the relevant sections]. |
DLP_6201 | Marion Cranmer | 1.10 This is an opportunity for you to have further input into the Council’s preparation of a new Local Plan for the borough… It is a problem that a response cannot be made without having your name put forward in public. Why can a response not be identified as, for example, ‘Resident, TN17, name held by TWBC’? The inability to do this is clearly discriminatory. Anyone who has been subjected to domestic abuse, stalking, or any other form of hate crime is unlikely to respond. Having spoken to a senior member of TWBC about this discrimination, and the inability to overcome it, his response was beyond lack of empathy or understanding, it was truly shocking. 1.17 The consultation documents can be viewed on the Council's website 1.18 The documents can also be viewed at the following locations for those without access to a computer: The access to such a major document has been woefully poor for anyone without a computer! The amount of time needed to read and consider even small parts of the document, within the restricted hours of local libraries, means that very few people have had proper access to it. It is, yet again, an example of a huge number of residents of the parish being discriminated against due to the digital divide. There was a single exhibition for Cranbrook and Sissinghurst, which was poorly publicised as also for Frittenden and Benenden. The shortness and time of day made it hard for many parents/carers/people in work to attend, and it was certainly not good enough to have been told by TWBC that those people could go elsewhere. This was not real consultation. The portal for responding was frequently not working properly, and despite some extension to the consultation period to compensate, it still often performed badly, and many people were so put off by their experiences that they gave up. This is not true consultation. |
DLP_6253 | Claire Penney | * Accessibility to proposals: Can you advise how you have shared these proposals, other than to display in TW Gateway and libraries in the borough? I’m intrigued to know how many residents you believe you are reaching through these portals, as many people will set foot in neither from year to year. Information should be shared in local print media, on social media, and where local to residents, should be leafleted door to door. There will be many Southborough residents who are not aware of these proposals, which could impact heavily on their day-to-day lives. It is imperative that you share these proposals more widely, aiming to reach every single household that will be affected. You must surely be aiming to avoid the mistakes made through lack of consultation on the Calverley Park development catastrophe. |
DLP_6259 | Anne Trevillion | It is not easy to respond – the document is so long, and there are so many sections and paragraphs. Much of the language is opaque, there is a lot of repetition between sections, and I imagine many people would find it very daunting to attempt to comment. I could not cope with the consultation portal – that was too difficult to work with. |
DLP_6419 | Hawkhurst Parish Council | p.16, para. 1.21: “Some policies in the Hawkhurst Neighbourhood Development Plan will be superseded.” It is a concern that the draft TWBC Local Plan intends to supersede the NDP without any explanation, justification or further details. For the statement to be included in the draft document, there must be some level of confidence within the TWBC planning team that this will indeed be the case. It is not yet two years since the NDP was adopted and it still has 13 years to run as the statutory planning document for the designated area. The key questions arising from this situation are:
TWBC planners must engage with HPC and the NDP Group to discuss this in detail before this is set out in the Pre-submission version of the Local Plan. |
DLP_6429 | Hawkhurst Parish Council | Concerns over the Consultation Programme “There must be sufficient opportunity for consultees to participate in the consultation. There is no set timeframe for consultation, despite the widely accepted twelve-week consultation period, as the length of time given for consultee to respond can vary depending on the subject and extent of impact of the consultation”. This late afternoon slot is very congested for working families – it is either the afterschool rush of supporting children in sports and activities or commuting home from work outside the parish. Selecting this time slot is seen by many as a deliberate way to prevent a high turnout and frustrate the views of local people. The Parish Council see no reason why, for example, a 7 pm until 10 pm time slot could not have been used. Indeed, during the preparation of the NDP, the parish regularly made use of the same venue throughout the daytime and late into the evening to ensure maximum opportunity for people to contribute ideas and thoughts. In addition, the exhibition boards were misleading, for instance “Government’s figures identify a housing need for the borough of 13,560 dwellings over the period 2016-2036.” What it did not say was that TWBC had the opportunity to reduce the number as a significant portion of the borough is within the High Weald AONB, but in fact, TWBC decided to increase the housing number. With regards to the online consultation, the Local Plan consultation on the TWBC website is hidden. There is limited access to the online consultation – it is not on TWBC home page and hidden “four clicks” away, buried in the planning section of the website. If residents can battle their way through TWBC’s website to the consultation form the complex nature of the consultation form has left many residents baffled. |
DLP_6458 | Cranbrook & Sissinghurst Parish Council |
[TWBC: see full representation]. |
DLP_7223 | Elizabeth Daley | Officers from did meet with representatives of the Cranbrook and Sissinghurst NDP group. Little discussion took place and despite repeated requests, no memorandum of understanding was ever forthcoming. |
DLP_7266 | Mrs Katie Lee-Amies | Section 1, para 1.13
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DLP_7448 | Catherine Pearse | Comment relating to the 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. I certainly have and just hope this gets through so it can be taken note of! Nowhere does the Council encourage people simply to send in their comments in their own words. 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 I would draw your attention to the FACT that Hawkhurst has a Neighbourhood Development Plan which has been “made” and it is therefore a requirement that TWBC takes this into account when developing the Local Plan. Clearly when reading the Local Plan it is obvious that TWBC have ignored the NDP for Hawkhurst. |
DLP_7500 | Sarah Parrish | Why are communications not fully inclusive? |
DLP_7585 | Victoria Dare | I have borrowed (with permission) the wording of another objector to this draft plan because it is far more eloquent and detailed than I would be able to achieve myself. This is no way diminishes my conviction on these points, many of which I have already commented on at length elsewhere to TWBC. 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. |
DLP_7609 | Jeremy Thompson | You have really not made this easy to make comments, perhaps that is what is intended. |
DLP_7753 | Annie Hopper | The process of commenting on the draft LP has not been easy. Going online and registering resulted in no confirmation email being sent in many cases and numerous people have said that this put them off commenting – this is not acceptable – the comment response process should be as simple as possible to enable as many people as possible to comment? The response form itself requires a lot of thought to fill it in, cutting and pasting sections to enable multiple comments to be made. Why is it necessary to fill in different types of comment boxes for each type of comment – the whole process could have been much simpler and easier? There have been lots of comments within the Parish of how difficult the process has been for those who do not have access to a computer and needed to send written comments. We were told at the only public engagement that was held in Cranbrook during the consultation period that TWBC ‘discouraged written comments preferring electronic comments as it was too much work transcribing written comments when received.’ There was not even one printed form available for people to take away with them! This is such an important document that affects so many Parishes in the borough that it is completely unacceptable that it has been made so difficult to comment! |
DLP_7853 | Phillip Tew | I am commenting on the Draft New Local Plan. I am a resident of Speldhurst and we have lived in Speldhurst for 25 years bringing up our children during this time. I would first like to object to the way in which the consultation process has been undertaken. The advertising of the Draft New Local Plan has been very poor, the maps contained within the Draft New Local Plan are almost impossible to decipher as they are poorly reproduced and this, in combination with the very short timetable given to the consultation process, ( I know it has been extended by a relatively trivial additional time ) will inevitably mean that a very large number of effected people will simply be unaware of the Draft New Local Plan and the proposals contained within it. I do not think you should assume that the responses you have received properly reflect the views of residents. |
DLP_7985 | Chris Callander | Initial comments
Firstly, I should like to apologies for not using your form structure or the online portal. I feel the systems put in place are far too complicated for the local residents to understand. It is clear they have been developed to make the work needed by the planning department easy, and not to make it easy for residents and members of the community to make their views heard. This was evidenced by comments from Stephen Baughan at a recent community meeting where he urged us to use the forms, otherwise the planning teams “would have to read the responses”! That was just one comment, or action, from the team driving this plan which has cast doubt over either the competency or the motives of the people involved. |
DLP_8012 | Penny Ansell | Comment relating to the procedure for submitting comments on the Draft Local Plan. How can The Council say that “it is quick and easy to comment online” when it is extremely difficult to do so. I have been onto the site quoted in ‘LOCAL’ - tunbridgewells.gov.uk/localplan- a number of times and have found it impossible to make any comment at all since none of the various instructions/sections I clicked on opened up a space for actually submitting comments. Nor did it allow me to download the appropriate comments form. The principle of consultation is that it should be easy and straightforward and the Council needs to provide a much simpler way of communicating either by email or by letter. Also, it is exceptionally tedious for ordinary, busy people to have to wade through the draft plan identifying the specific sections/paragraphs to which they wish to respond. I imagine it is also very tedious for whomever is analysing the responses since they will come across endless repetition! As a result of this unnecessarily complicated procedure, you will probably get a much lower response rate than desirable. 1.29 ‘the local plan should be: “positively prepared - as a minimum, seeks to meet the area’s objectively assessed needs” “justified, an appropriate strategy, taking into account the reasonable alternatives and based on proportionate evidence” I would be interested in knowing how ‘objectively assessed needs’ and ‘appropriateness’ result in a housing allocation of average 1,271 for Tunbridge Wells (2011 pop’n, 48,324) and average 668 for Hawkhurst (2011 pop’n, 4991) but more of this later. Please note points in 4.38 and 4.40 at end of this section. |
DLP_8156 | Myriam Ruelle | About Capel: the proposed “green settlement” was included as an easy option due to the fact one big landowner only is involved. This landowner has already been using bullying tactics with his tenants and this is extremely worrying. People from Tudeley commenting on the DLP wish to remain anonymous due to fear of reprisal. Are we in the 21st Century or back in mediaeval times? This particular point only should merit further investigation and criminal investigation if needed. The Council should never support any proposition clearly made to the benefit of one individual and threatening a whole community, their lives and livelihoods. Anyone should be able to voice their concerns without any fear. The new town at Capel must be rejected. |
Producing a new Local Plan
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_66 | The Access Group | My members having looked at the proposed Draft Local Plan have instructed me to make the following observations and legal demands:
1.1 These are current conditions imposed by the Planning Inspector, the current Planning Minister and are legal requirements set out under Articles 9, 19 & 28 UN Convention on the Right of People with Disabilities, adopted 2000 and Formerly Ratified by Parliament in 2009; the legally binding UK Disability Strategy 2012 with particular reference to Part 6 requiring total compliance with all the articles of the UN Convention by 2025; The Equality Act 2010 & The Human Rights Act 1998 to ensure "inclusion and to ensure that no person is excluded or discriminated against in any way whatsoever". |
DLP_82 | Roger Bishop | Summary The Plan contravenes Government policy on the Green Belt, and TWBC’s policies and aspirations with regard to, for example, the environment and biodiversity, climate change, transport, and heritage assets, all in the pursuit of meeting a stated housing need which it is acknowledged is not soundly based. You state that, “As set out in the NPPF, each local planning authority should ensure that its Local Plan is based on adequate, proportionate, up to date, and relevant evidence about the economic, social, and environmental characteristics and prospects of the area.” [TWBC: see also comments DLP_81 to 93]. |
DLP_1737 | Peter Hay | It is a FACT that Hawkhurst has a Neighbourhood Development Plan which has been “made” and it is therefore a requirement that TWBC takes this into account when developing the Local Plan. Clearly when reading the Local Plan it is obvious that TWBC have ignored the NDP for Hawkhurst. |
DLP_2962 | Michael Alder | 1.35:- Hawkhurst has commissioned and submitted a Neighbourhood Development Plan which has been MADE which gives a requirement to TWBC the responsibility to take this into account when developing the Local Plan. It is obvious from the text of the Local Plan that the Hawkhurst NDP has been ignored. |
DLP_3160 | Kent County Council (Growth, Environment and Transport) | Provision and Delivery of County Council Community Services The County Council considers that whilst neighbourhood level funding for park benches and planters is important - KCC considers that in some instances, critical infrastructure such as education facilities should take precedence. |
DLP_3755 | John Windeatt | Rather than repeat all the comments made by Keith Lagden on his Response Form, I would simply say that I agree with his comments and reiterate our total objection to this development and to the loss of the sporting facilities provided by the Golf Club (even though the facilities have been intentionally run down as the scheme has been developed) |
DLP_3769 | Mary Jefferies | 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. A Council representative at the consultation meeting on 30th September was totally dismissive of the Hawkhurst NDP. For what reason? Also, 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. Local residents wish to preserve their village and their rural way of life. |
DLP_3859 | Geraldine Harrington | TWBC: the following standard response was submitted by the list of 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 the majority of local residents and the Hawkhurst Parish Council, to preserve their village and their rural way of life. |
DLP_4228 | East Sussex County Council | Thank you for the opportunity to comment on the Tunbridge Wells Borough Draft Local Plan. The following are officer comments from East Sussex County Council. Duty to Cooperate |
DLP_4231 | Rother District Council | There has been positive, active engagement between the two councils on strategic cross boundary issues, 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), together with a high degree of consistency between the “Development Management” policies. |
DLP_5818 | Charles Vernede | TWBC: the following standard response was submitted by the list of responders on the left: 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. |
DLP_5946 | Mr Andrew Constable | We have looked at the draft local plan and attended the presentation at the Royal British legion in Hawkhurst. As residents of Hawkhurst for over 20 years we feel extremely concerned that the extent of proposed development in the village is completely disproportionate to the size of the village and its facilities and infrastructure. The plan appears to show that a similar number of dwellings are proposed around Tunbridge Wells as there are in Hawkhurst – that fact alone speaks volumes for the inappropriateness of the development now proposed in the small village of Hawkhurst. The draft plan process. Firstly, we are very surprised at the lack of actual “planning” that has gone into the selection of sites for development. The sites in the “plan” are all included simply because their owners have responded to the “call for sites” and want to embark on some property development to make a profit. It seems to us that TWBC have taken the easy option here by simply including sites that are put forward rather than devising a plan based on what would seem to be the real planning criteria such as: actual need in each location, available infrastructure, transport links, the road network, schools, doctors surgeries, employment and so on. A TWBC officer at the Hawkhurst event confirmed that this was the approach taken. It is not right. [TWBC: See related comments DLP_5946_5949-5952] |
DLP_6202 | Marion Cranmer | 1.29 The Draft Local Plan has been prepared in compliance with national policy. In particular, the NPPF states that, for a local plan to be considered sound, it must comply with the legal and procedural requirements of plan making and demonstrate that it is: 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; The delivery of housing appears to be almost totally developer led, with very little consideration of the types/sizes/types of tenure truly needed. The speed at which developers buy up land means that many critical areas are lost to other, better uses. The build out rates are mostly at a rate that means that land is spoilt, even if the properties then take a very long time to sell, or do not sell at all. Circumstances may change radically in the near future, so land needs to be protected, not lost forever. 1.34 The Localism Act (2011) introduced neighbourhood planning as a way of passing decision making to a more local level. This allows communities the option of producing their own neighbourhood plans. A neighbourhood plan is a document produced by the community, for the community, to shape and guide its future development. It may contain a vision, aims, policies, and proposals to provide new development or improve existing facilities, and it may also allocate sites for specific development. Such plans need to be developed through cooperative working and extensive community engagement, and be in general conformity with the strategic policies set out in the Tunbridge Wells Borough Local Plan, as well as national policy. The Draft Local Plan provides the framework for those local communities preparing a neighbourhood plan. The experiences of residents in Cranbrook and Sissinghurst parish who have tried to engage through the NDP process have certainly not upheld the feeling that TWBC engage in, or even support the NDP process. |
DLP_6454 | L Noakes | The Consultation itself. Whilst I appreciate that the preparation of the Draft Local Plan has been a far from simple exercise, I do not feel that the consultation to the Draft plan has been adequately carried out. The documentation is extensive and does not lend itself easily to the general public and whilst copies have been made available in some public places and on line, the extensiveness of the documents and their complex nature means that making an informed comment on the plan is out of reach of the majority of everyday people as they will not have had the time nor the inclination to read the vast quantity of supplementary documents. Those without access to a computer or online documents will be very unlikely to have read more than what was provided in ‘The Local’ magazine provide by TWBC. The public exhibitions did not adequately fill the gap and explain fully access the core policies etc to the general public as the information was not detailed enough to give a full picture. In addition to this, the on line consultation process has proven difficult and unwieldy, as well as time consuming, hence this response is sent in a letter format. I really hope that TWBC will take into consideration the comments I have provided above and that we will see a change in the way they approach tackling this problem for the Borough. |
DLP_6666 | Gladman | 3 LEGAL COMPLIANCE 3.1 Duty to Cooperate 3.1.1 The Duty to Cooperate (DTC) is a legal requirement established through Section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. The DTC requires local planning authorities to engage constructively, actively, and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues through the process of ongoing engagement and collaboration. 3.1.2 As confirmed in Section 2 of this representation, the NPPF 2019 has introduced a number of significant changes for how local planning authorities are expected to cooperate, including a new requirement for the preparation of Statement(s) of Common Ground (SoCG) which demonstrate that a Local Plan has been prepared based on effective cooperation with agreements reached with neighbouring authorities on strategic level cross boundary issues. 3.1.3 The Council will be aware of the recent experience of its neighbour, Sevenoaks District Council and the examination of its emerging Local Plan where the Inspector concluded that the DTC undertaken during the preparation of their Local Plan has been insufficient. This conclusion has meant, that despite the best efforts of the Council in other areas of its plan making, future progress with the Local Plan in its current form is now subject to significant uncertainty and a likely lengthy delay. 3.1.4 The findings of the Inspector at Sevenoaks reflect the changing tests of the 2019 NPPF in comparison to the 2012 NPPF in relation to DTC and underlines the need for constant and proactive engagement between neighbouring authorities and key stakeholders at each step of the plan making process to inform strategic decision and satisfy legal requirements and meet tests of soundness in relation to DTC. 3.1.5 To illustrate actions taken in relation to the DTC to date, the Council has prepared an interim Duty to Cooperate Statement. Inclusive within this are a number of Statements of Common Ground prepared between the Council, its neighbouring authorities, and statutory bodies. 3.1.6 It is recognised by Gladman that DTC in relation to the Local Plan is an evolving process and as such the Interim Duty to Cooperate Statement does not represent the final position. To fully discharge its legal requirements, the Council will need to continue to meet with neighbours and statutory bodies throughout the remaining plan preparation period and beyond, with associated SoCG prepared to date updated in response to the evolving discussion. Most importantly for the Council in the preparation of its Local Plan, noting the recent conclusions of the Sevenoaks Inspector [1 1 See Letter Dated 28th October 2019.], is the need for engagement with its neighbours to formulate a strategy now as to how cross-boundary needs are to be dealt with effectively rather than deferring this to a later plan review. 3.2 Sustainability Appraisal 3.2.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, policies that are set out in local plans must be the subject of a Sustainability Appraisal. Incorporating the requirements of the Environmental Assessments of Plans and Programmes Regulations 2004, the SA is a systematic process that should be undertaken at each stage of a plan’s preparation; assessing the effects of a local plans proposals on sustainable development objectives when judged against reasonable alternatives. 3.2.2 The Council should ensure that the results of the SA process conducted through the preparation of the Local Plan clearly justify policy choices made, including proposed site allocations (or decisions not to allocate sites) when considered against reasonable alternatives. In meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed and others have been rejected. 3.2.3 The SA must demonstrate that a comprehensive testing of options has been undertaken and that it provides evidence and reasoning as to why any reasonable alternatives identified have not been pursued. A failure to adequately give reasons in the SA could lead to a challenge of the Council’s position through the examination process. The SA should inform plan making. Whilst exercising planning judgement on the results of the SA in the Local Plan is expected, the SA should still clearly assess any reasonable alternatives and clearly articulate the results of any such assessment. [TWBC: the above comments on the Sustainability Appraisal have been entered as a response to the SA consultation. See Comment Number SA_114]. 4.1.1 It is noted that the proposed plan period for the Local Plan runs from 2016 to 2036. The indicative timescale for the remaining stages of plan preparation to adoption as outlined in Figure 1 of the Local Plan show that the Council assume adoption in December 2021. The achievement of this timescale would provide for a plan period which is marginally less than 15-years post adoption contrary to Paragraph 22 of the 2019 NPPF. 4.1.2 Gladman consider that Figure 1 of the Draft Local Plan represents a best-case scenario for the adoption of the Local Plan in Tunbridge Wells, and it is likely this timescale will slip. It is noted that this timescale has already slipped from that outlined at Issues and Options, with plan preparation already falling 1-year behind the timeframe originally anticipated. 4.1.3 Evolving external factors beyond the control of the Council mean that it is likely the Local Plan will be subject to further delay. It is anticipated that the methodology for assessing housing need will be subject to review in 2020, with this completed ahead of the publication of the 2018-based household projections in September 2020. This will need to be reviewed by the Council in due course considering the role and weight both hold in national planning policy for defining housing need and implications this could have on the wider spatial strategy. 4.1.4 Gladman consider that it would be prudent for the Council to build flexibility into its timescales now and accept the potential for a delay over the next 12 months. Gladman consider that at least an additional year should be added to the plan period to account for this, with development requirements and supply increased proportionately. The plan period should therefore end, at the very least, in 2037. [TWBC: see full representation]. [TWBC: see also Comment Nos. DLP_6656-6695] |
DLP_6844 | Barton Willmore for Crest Nicholson | 3.0 DUTY TO COOPERATE 3.1 Section 11 of the Localism Act 2011 introduced a requirement for Planning Authorities to cooperate with neighbouring LPAs on cross boundary issues. The Draft Local Plan is accompanied by an “interim Duty to Cooperate Statement” which sets out way in which TWBC has sought to meets its obligations under s.110 of the Localism Act 2011. 3.2 The NPPF requires that strategic policy making authorities collaborate to identify the strategic matters to be addressed through their plans and requires that LPAs engage in effective and on-going joint working between strategic policy making authorities and relevant bodies. In order to demonstrate that “the Duty” has been met, the NPPF (para 27) suggests that LPAs prepare and maintain DtC Statements with relevant bodies. 3.3 Tunbridge Wells shares a boundary with six other Local Authorities with which it has a DtC on strategic issues: * Ashford Borough Council; 3.4 We note that a SoCG has been signed with Maidstone Borough Council, Ashdown Forest Working Group and Sevenoaks District Council, and that discussions with the remaining neighbouring authorities are ongoing. The ‘West Kent Housing Market Area’ extends across Sevenoaks, Tonbridge, Tunbridge Wells, Crowborough, Hawkhurst and Heathfield. The ‘best fit’ association is Sevenoaks as a borough, with the south and west of Tonbridge and Malling also falling within the same housing market areas as Tunbridge Wells. 3.5 Tunbridge Wells and Sevenoaks District Council produced a Statement of Common Ground in May 2019. This acknowledges that SDC has a significant housing land shortfall but confirms that TWBC is unable to assist SDC in meeting its unmet housing need. 3.6 The SDC Examination commenced in September 2019 but was recently halted after Hearing statements and sessions highlighted a number of unresolved issues which the Inspector felt could not be addressed in the original Examination timeframe. The headline concern was the lack of constructive engagement by SDC with neighbouring authorities to resolve unmet housing need, but additional issues were raised by the Inspector in relation to the Sustainability Appraisal; the chosen Strategy for Growth; the assessment of the Green Belt; and housing. 3.7 Whilst this does not necessarily place an additional burden on Tunbridge Wells to meet housing need, the Sevenoaks Local Plan Inspector has noted [2 28 October 2019, ED40] that the outcome of that Examination will have an impact on neighbouring Borough’s Local Plans. 3.8 We are also aware that TMBC has written to Tunbridge Wells highlighting its concerns that the scale of development in settlements close to Tonbridge, and that it has reservations about the impact that this would have on infrastructure and services in nearby settlements in its Borough. 3.9 We expect that in order to fulfil their Duty to Cooperate, TWBC will continue to engage with neighbouring authorities to address matters arising from the Sevenoaks Local Plan examination, Draft Local Plan allocations near TMBC, and any other matters that arise during the plan making process. [[TWBC: see full representation and supporting documents Appendix 1, Appendix 2 Part 1 , Appendix 2 Part 2 and Appendix 3]. See also Comment Numbers DLP_6836, 6844, 6847, 6843, 6855, 6859, 6860, 6863, 6865, 6866, 6869-6870, 6872, 6877, 6883, 6890, 6897, 6909-6911, 6926, 6928, 6931, 6933-6937]. |
DLP_7201 | Mr Michael Armitage | Hawkhurst already has an NDP, therefore TWBC should comply with this. |
DLP_7243 | Mr John Telling | This is an extremely convoluted and complex document for the 'man/woman in the street' who is not familiar with planning jargon, and with limited access to technology, to respond to, particularly as this consultation has coincided with the main Tunbridge Wells library being closed for computer access. |
DLP_7267 | Mrs Katie Lee-Amies | 1. I disagree. The evidence base does not support a development allocation in Tudeley and therefore it does not support the Draft Local Plan.
“The Local Character Area should be considered in the context of the High Weald AONB, particularly the role the character area plays in the setting of the AONB. The valued features and qualities of the landscape should be conserved and enhanced.” Also, the low and open nature of site CA1 means a large settlement would be widely visible from the extensive network of PROWs within the site, within the adjoining AONB, along the valley floor and from the rising land to the north. There are also long distance panoramic views of the site from Hartlake Road, along the B2017, and from higher ground to the north and south . Mitigation measures cannot screen a 600 acre development. The proposed allocation of such a development undermines the Landscape Strategy: “Consider the vulnerability of this open lowland landscape to built development which is likely to be very visible in views.”
“although the Call for Sites remains open, it will no longer be possible to include any new sites within the site assessment process that is informing the Local Plan (Reg 18 Consultation), as there is insufficient time to adequately assess such sites.” Site CA1 was not submitted in the call for Sites 2016 and not assessed in the Interim SHELAA. TWBC need to explain their justification for including the Hadlow Estate sites earmarked for Tudeley Garden Village in the Reg 18 Draft Local Plan and demonstrate adequate assessment.
“Transport issues should be considered from the earliest stages of plan-making and development proposals, so that: 1. a) the potential impacts of development on transport networks can be addressed;” Section 1, para 1.29 1. It appears the overriding reason for taking the Tudeley area forward to a proposed strategic site allocation is the convenience of a single landowner. This strategy is contrary to para 35 of the NPPF which requires that for a Local Plan to be sound it must be justified, based on “proportionate evidence”. 2. I note TWBC have taken a proactive approach to encourage development sites to be submitted by contacting the owners of land around settlements to submit more land. I can find no evidence that TWBC employed the same proactive approach to increase the number of Brownfield sites on their register by contacting and encouraging owners to submit sites if they wished to. This is an unbalanced and inconsistent approach. Section 1, para 1.30 - 1.33 1. TWBC have not used ”up to date evidence” with regard to housing needs. The level of housing growth is based on 2014 statistics figures (in fact, it is 9% above 2014 figures) and not the latest 2016 figures which would result in a significant reduction in objectively assessed need. 2. As noted above, there are serious omissions in the evidence base to support a stand-alone settlement in Tudeley. 3. The site allocation for a new settlement in Tudeley places low priority on the environment which conflicts with the NPPF and TWBC’s supporting documents. The NPPF states “to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities.”. Tudeley Garden Village will not enhance the existing small rural community of Tudeley. It will become a car dependent conurbation of Tonbridge creating unsustainable travel patterns. Section 1, para 1.39 1. I question whether TWBC have “actively engaged” with neighbouring councils. In July 2019, TMBC advised that they were unaware of an identified site for a proposed new settlement prior to the pre-Draft Local Plan. TWBC should have been actively engaged with TMBC when feasibility studies were carried out for potential settlement sites – assuming they were carried out. There is no evidence base to support this work. |
DLP_7326 | Campaign to Protect Hawkhurst Village | This section suggests that the Council has been “actively engaging” with neighbouring authorities on a number of cross border issues. However, from an analysis of the remainder of the Draft Local Plan (DLP), Sustainability Appraisal and associated evidence base, nowhere is there any indication that discussions have been had regarding the impact of the Council’s growth strategy on the Flimwell junction. There is one cursory mention of this junction in the Hawkhurst strategic policy. Whilst this junction is outside the Council’s administrative area, the proposed level of growth in the east of the Borough in particular will have a dramatic impact on this junction and the A21 (as part of the strategic road network) – this is evidenced in the Transport Assessment submitted with Planning Application for the Hawkhurst Golf Course which predicts significant worsening of the current congestion even after a proposed scheme of mitigation. This impact is not assessed in the Transport Evidence Base. The only publicly available information before the Council (the Golf Course Transport Assessment) illustrates the proposed growth will have a hugely detrimental impact on this part of the Strategic Road Network contrary to numerous policies in the NPPF. There is no evidence that this impact has been taken into account in the preparation of the DLP. On this basis the policies within the DLP have not been justified (for the purpose of paragraph 35 of the NPPF and the whole growth strategy for the east of the Borough in particular is not “sound”. For the same reason the Sustainability Appraisal (SA) has not been properly prepared. Paragraph 1.45 explains that the purpose of the SA is to evaluate the social economic and environmental impacts of policies and strategies, to determine the extent to which they are in agreement with sustainable development objectives. However, the SA makes various assertions regarding the travel impacts of the allocated sites – which has a direct impact on the conclusions relating to air quality, noise and climate change. None of the evidence base documents referred to in the methodology section of the SA contain any analysis of the impacts of the growth strategy on traffic at Flimwell, the Hawkhurst crossroads and/or the efficacy of the proposed relief road. The SA (and therefore the DLP) make the assumption that the relief road will be effective in reducing traffic at the village crossroads. This assumption is entirely unsubstantiated in the supporting evidence base. Again, this illustrates that the proposed Hawkhurst allocations (and therefore the overall Growth Strategy) has not been based on “proportionate evidence” and are therefore not justified or sound for the purpose of paragraph 35 of the NPPF. The response to this fundamental failure is not to retrofit a justification at a later stage of the plan process. Instead the Council should pause and genuinely reflect on whether the proposed strategy is sound, based on a proper and thorough evidential assessment Finally, this paragraph notes that the recommendations of the Sustainability Appraisal have at each stage informed the production of the LP. It is important to note that the interim SA recommended Growth Option 5 coupled with a growth corridor approach Growth Option 4. The Council has chosen not to follow this previous recommendation. |
DLP_7447 | Catherine Baker | I simply do not understand how TWBC can choose to completely ignore the supposed planning process. There is absolutely no point in having a 'process' when we appear to live in a dictatorship. The NDP for Hawkhurst was clearly a complete waste of time. Why bother with NDPs if they have no influence at all? They should forthwith be abolished. All over the country they are simply wasting people's time and taxpayers' money. There is NO justification for this. Now I see the Hawkhurst Golf Club development appears to be a foregone conclusion. Various Hawkhurst residents were advised (via 'golfing' sources close to TWBC's planning department) that this development was a done deal but I simply cannot understand how it can be. We are supposed to have a planning process. It appears the greed of a very few who have contacts at TWBC can completely blight the lives of so many. We see this happening over and over again. How can this be in this country today? The whole proposal re the golf club - unless it involves large scale new roads, new schools, new healthcare and employment opportunities, an overhaul of the A21, the removal of large supermarkets from village centres, and a complete overhaul of the rail network to London - is simply ludicrous. This may temporarily solve TWBC's housing allocation problems BUT it has far reaching consequences for all and just shifts and exacerbates problems elsewhere. I simply cannot understand how this is permissible. |
DLP_7642 | Keith Peirce | TWBC: the following standard response was submitted by the list of responders on the left: 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. I certainly have and just hope this gets through so it can be taken note of! Nowhere does the Council encourage people simply to send in their comments in their own words. 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 I would draw your attention to the FACT that Hawkhurst has a Neighbourhood Development Plan which has been “made” and it is therefore a requirement that TWBC takes this into account when developing the Local Plan. Clearly when reading the Local Plan it is obvious that TWBC have ignored the NDP for Hawkhurst. |
DLP_7827 | Andrew Chandler | The draft NDP for Cranbrook and Sissinghurst is not as advanced as it should be, but this is because TWBC planning department has repeatedly frustrated and delayed attempts to progress with proposals. You should give considerable weight to the 3 years’ work and consultation that have been carried out. |
DLP_8013 | Penny Ansell | 1.35, 4.35 and 4.36 I would draw your attention to the FACT that Hawkhurst has a Neighbourhood Development Plan which has been “made” and it is, therefore, a requirement that TWBC takes this into account when developing the Local Plan. Clearly when reading the Local Plan it is obvious that TWBC have ignored the NDP for Hawkhurst.This was produced at great expense earlier in the year and approved by popular vote. I would also draw your attention to the point made in 1.36 regarding the need to ‘ensure local development issues, needs and aspirations are understood by officers’ (of the Council) and to Strategic Objective 10 “to work with neighbourhood plan groups to ensure the formation of locally-led policies with this reflected in decisions on planning applications” The recent experience in Hawkhurst is that TWBC takes very little notice of the views and concerns of the Parish Council and the Council’s claim (4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. |
DLP_8316 | Pam Wileman | TWBC: Comment was submitted on 19/11/19 after close of consultation (on 15/11/19). 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. I certainly have and just hope this gets through so it can be taken note of! Nowhere does the Council encourage people simply to send in their comments in their own words. 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 I would draw your attention to the FACT that Hawkhurst has a Neighbourhood Development Plan which has been “made” and it is therefore a requirement that TWBC takes this into account when developing the Local Plan. Clearly when reading the Local Plan it is obvious that TWBC have ignored the NDP for Hawkhurst. |