Section 4: The Development Strategy and Strategic Policies
This response report contains comments received on Section 4: The Development Strategy and Strategic Policies.
Contents
Section 4 The Development Strategy and Strategic Policies
Comment No. | Name/Organisation | Response | ||||||||||||||||
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DLP_375 | Mr David Smith | Specifically, the targets for the growth in housing provision are unreasonably high and are based on figures which were revised some time ago, although central government chose to ignore the downward revisions recommended. In practical terms the fact that these are far too high is being demonstrated by the slowdown in the sales and further building on the sites already earmarked for growth in the current period. It is understood that Sevenoaks have lodged an appeal to the growth estimates in their own plan but that TWBC have simply chosen to "wait and see" what the outcome of this is. This attitude simply does not make sense since the cases for Sevenoaks and TW are quite different so the failure of one appeal does not necessarily imply that the other would necessarily also fail. However, this TWBC attitude simply demonstrates and reinforces the widespread belief here in Paddock Wood that TWBC do not have PW interests at heart and are in fact following another more sinister agenda. | ||||||||||||||||
DLP_1136 | Carolyn Gray | While I understand that the government wants to build loads of houses, ome of this feels a step too far for the streets and green spaces of Tunbridge Wells. But maybe by 2036 less people will own cars. At the moment driving around in a car is a nightmare, with so much on street & on road & on pavement parking - in fact with the multitude of new bins walking on a pavement can be an effort at times - bins to one side, cars to the other. In short: the town centre will stop being a pleasant place to live. | ||||||||||||||||
DLP_1697 | Frittenden Parish Council | Frittenden Overview - In respect of the Retail section, there is currently no part time shop. There are two public houses within the Parish of Frittenden, the Bell & Jorrocks and the Knoxbridge Inn. In the Employment section, in addition to Fridays Egg Farm, there is in the Parish Larchmere House, a Nursing Home, and CWP Fencing, a fencing company. Policy STR/FR1 - With regard to paragraphs a-g setting out the items for which contributions will be required, we would not see the items at paragraphs a, b and d as a priority. Frittenden is too small to support secondary education and healthcare facilities within the Parish, with residents accessing such facilities elsewhere in the Borough, and the Parish already has a well advanced community led scheme for improving broadband connectivity. In order of priority, we would start with the provision of a refurbished/redeveloped village community hall and a community cafe/shop. As speeding is a constant issue in the Parish, we would also add a contribution to highway improvements specifically targeted at reducing speed. Parking in the centre of the village is also a problem so the provision of additional off street parking as referred to in paragraph e is a priority. Policy AL/FR1 - In respect of the development requirements for Late Site 28, the layout and design should also take account of the size of houses which are not in supply in the area. We see a number of new developments in the locality which offer 5 bedroom 'executive homes'. We need homes that fulfill local need, for example to include 2 or 3 bedroom homes. | ||||||||||||||||
DLP_1729 | Mr Raymond Moon | The Strategic Policies The Development Strategy Section.4. Policy STR 1 OBJECT. The Development Strategy
Policy STR 3 OBJECT. Masterplanning and use of Compulsory Purchase powers. With the failure of a “ joined up approach” to the building approved at Church Road, Green Lane & Badsell Road where the present infrastructure is unable to cope it is imperative that a Masterplan is in place for the proposed new 4,000 houses in PW and that it is implemented before they are built and the developers adhere to it and the TWBC monitors its progress. Compulsory Purchase powers. OBJECT. With the £90 Million project in Calverley road TW being scrapped it is not good practice to rely on Compulsory purchase orders to ensure new development in PW. Policy STR 4 OBJECT. Green Belt Ref 4.47-4.52. Green belt status should be allocated to the land East of PW to ensure that the adjacent rural villages and PW do not lose their identity to future development. Green open spaces provide wildlife corridors and maintain our rural identity Policy STR 5 OBJECT. Essential Infrastructure and Connectivity. Transport. The country lanes and residential streets in PW are already clogged with commuter cars and heavy lorries. The Maidstone road with 900 homes already approved would have increased traffic from 4,000 new houses and any new houses to the East would create “ Rat Runs” in our narrow country lanes. There needs to be a new ring road from the East to the North of PW and a new road to relieve the centre of PW. The railway station at PW will not be able to cope with the new proposed development resulting in over crowding. Detailed discussions need to take place with Network Rail to ensure that the rail way infrastructure can cope in PW. Water It is clear that these 4,000 new houses need water supplies but there is no detail how this will be provided. South East Water need to submit real proposals to fulfil this requirement and give information and costs to the Masterplan. The present surface and foul water network infrastructure can clearly not cope with the increased surface water flooding and the resultant leakage of sewage onto roads and residents property in the Town. Greg Clark MP for Tunbridge Wells has intervened concerning this problem with Southern Water but at present Southern water have not submitted any real solutions to the problem. It is common sense to provide a new Foul water ring network around PW to relieve the present problems and plan for the new 4,000 houses. A new Sewage Treatment centre should be provided on this new ring network or the present one expanded. The issue is, who pays for this in the future before the new houses are built. Health The healthcare facilities in PW will be stretched with the present agreed 900 new houses and will not cope with 4,000 new houses. The present Health care centre at |Woodlands will be unable to manage the potential new patients and it has ready taken on the patients that live in East Peckham. A new health centre is required to deal with increased dental, and social care provision and should be mentioned in the Draft Plan.. Policy STR 6 OBJECT. Transport and Parking. As already mentioned to increase foot fall to our retail centre new free parking needs to be introduced and a joined up public transport network that offers on time reliable services at a reasonable cost. Policy STR 7 OBJECT. Place Shaping and Design. As regards the type of build no mention is made of the use of renewable energy and the TWBC policy on the issue. The draft plan should insist that all new houses have solar panels installed and electric points for recharging electric cars in the future. Also an alternative to gas fired boilers to provide central heating should be mentioned.. Policy STR 8 OBJECT. Conserving and enhancing the natural, built, and historic environment Mature trees and hedgerows need to be protected as also our adjoining woodlands to protect our wildlife and enhance the country side around the new houses.This will reduce the risk of flooding and increase the air quality in the environment. Mitigation of replacing trees can take years to mature and should be incorporated in the Masterplan to ensure our country side is protected. | ||||||||||||||||
DLP_1797 | Royal Tunbridge Wells Town Forum | In Paragraph 4.3, no mention is made of the landscape, heritage and water provision constraints on development which may well inhibit full provision of the development needs of the Borough as defined by central government. In Paragraph 4.9 we support the need to take account of new data on objectively assessed housing need in the period leading up to the Regulation 19 submission, because the most recent trend seems to be towards a reduction in some need assessed according to 2016 government methodology, but we think this does not include the urgent need for affordable housing in the Borough. In Paragraphs 4.19-4.20 we support the identified need to retain existing well located office accommodation in the centre of Royal Tunbridge Wells. In Paragraphs 4.24-4.25 we support the aim to maintain and develop cultural opportunities within the Borough. In Paragraphs 4.26-4.27 we broadly support the principles set out in the supporting Infrastructure Delivery Plan but are concerned that the resources needed to give effect to its objectives will not become available in time to mitigate problems arising from the planned development in the Borough. These doubts about adequate resources particularly apply to the required development of a coherent network of active travel routes in Royal Tunbridge Wells and between settlements in the Borough and neighbouring towns. For example, in our 2015 report “Developing our Green Network”, we advocated the establishment of an active travel route between Tunbridge Wells and Tonbridge on existing PROW via 21st Century Way, Apple Tree and Gorse Woods to Pembury Road in Tonbridge, avoiding the extremely challenging Quarry Hill and providing a very direct and pleasant link to Tonbridge. We are delighted that this appears to have been taken up in Table 3 of the Infrastructure Delivery Plan but how will such new infrastructure be effectively financed and in what timescale? In Paragraphs 4.28-4.40 we consider it regrettable but inevitable that a planning policy system based on call for sites from interested landowners may not result in optimal selection of land suitable for development. We have nonetheless welcomed, and have been able to express views and information on potential allocations within Royal Tunbridge Wells through, a number of workshops with TWBC Planning Policy Officers during the Issues and Options and later stages of the Draft Plan development. Our further views on the AL/RTW Policies appear in the relevant section below. Our views on the remaining Section 4 paragraphs appear under our comments on the accompanying STR Policies below. | ||||||||||||||||
DLP_1986 | Brenda White | STR/HO1 Horsmonden This is the second time that i have attempted to submit my comments as your website doesnt work on a tablet or smart phone. I strongly object to the numbers proposed for Horsmonden, the majority of people (long time residents and recent additions) live in Horsmonden because of its rural setting and village feel. This would be ruined with the proposed 300 new properties, an increase of nearly 30%. Whilst i accept that there needs to be development so that the village can be sustainable, this scale of increase is totally unsustainable. For a start why arent the majority of the dispersed development be placed in one place along the A21 corridor. This would not have a detrimental impact on the villages and could be easily linked to Tunbridge Wells and paddock Wood. I think that Horsmonden could not cope with more than 100 new properties as the current transport infrastructure is non-existent. Outside of school times, the bus service to Paddock Wood and TW is hopeless which means that people are reliant on cars. An increase of 300 new properties would result in 500 more cars. As you know there have been several serious crashes at the crossroads as there is no enforcement of any speed restrictions as there are no police ever in the village. I am also concerned about the extent of these windfall sites. Surely a limit of 10 or 15% of the total allocation should be set to avoid landowners selling their plots for an extra couple of hundred propeties. Also are there any plans for a nursing home as it would be quite nice for families to be able to stay together once they get older. I have 2 generations of family in the village and it would be nice if i could stay near them instead of being forced out for 5 or 6 bedroom houses that no-one can afford. Finally, additional speed controls such as a reduction to 20 mph in the centre and an eextension of speed reductions along lamberhurst rd would be good. In summary: Why not develop along the A21? Reduce speed in the village Limit windfall to 10% of total Reduce overall allocation to 100 properties New nursing home instead of a gun club for the rich and famous! AL/HO2 - will you be providing pavements or safe access along Brenchley Road as without this, this plot would be unsustainable as you would have to drive or walk along the main road AL/HO3 - how will this massive increase of cars safely access and egress Goudhurst Road??? Surely an accident waiting the happen. Would it be possible to provide an entertainment facilities for the teenagers in this area as there is currently nothing for them to do. | ||||||||||||||||
DLP_2007 | Dr David Parrish | Section 4 Paragraph 4.16 (The Development Strategy) p.35 The figures used are out of date and not imposed by the Government as TWBC state The ONS 2016 figures show a smaller housing need, than those used by TWBC, are valid. TWBC do not have to use the 2014 figures of the ONS who admit their planning model was wrong. The plan should reflect that. The TWBC have used the wrong figures – but even so, if they do use them, they do not need to, as stated by the NPPF, as they are not imposed by the Government under Green Belt, and other, special circumstances. Section 4 Paragraph 4.38 (The Development Strategy) p.39 The distribution of Housing Allocation so uneven throughout the Borough TWBC should build on areas of land with no Green Belt, No Flood Plain, No AONB locality and not next to Tonbridge The “Dispersed Growth” intentions stated are not actually true due in this LP. Capel accounts for 63% of the housing allocation – of which Tudeley Garden Village is 70%. This is unfair. If it does not work the TWBC LP fails – and wastes tax payers money. There is no Plan B (which should be Plan A actually – i.e. Horsmonden and Frittenden) Section 4 Paragraph 4.40 (The Development Strategy) p.39 TWBC want to create a ribbon-develop from Tonbridge to Paddock Wood This intention will lead to a built-up conurbation from Tonbridge to Paddock Wood – over the years. This is counter to the intention of a Green Belt which exists to stop conurbations and town sprawls. TWBC cannot ensure agreed levels of affordable housing to Local Residents – especially if Hadlow Estate controls the development – as developers cite economic conditions preventing promised financially viable development of such Affordable Housing There are no accurate analyses of the housing needs for Tudeley and Capel The LP will lead not to affordable housing (developers never honour their percentage affordable housing content – citing “new economic circumstances”, but to housing suited for London Commuters who will be using Tonbridge resources (roads, railways etc.) not Tunbridge Wells’ resources. | ||||||||||||||||
DLP_2275 | 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 other, younger Groups, or those with a disability. Please do not argue solely the housing “numbers game” and deeply consider all residents in the Borough. | ||||||||||||||||
DLP_2487 | Mr John Wotton | Given the extent to which the land area of the Borough consists of AONB and Green Belt, it is striking that the Council has given no serious consideration to not meeting in full the Objectively Assessed Housing Need of 13,560 homes (678 per year throughout the Plan period), assigned to it by the Government's artificial methodology. Indeed, the Plan provides for an extra 9% of homes to be built, a total of 14.776. I object to the total allocation in paragraph 4.18. For the reasons given by CPRE Kent in their comments, the Council should have considered and adopted a lower housing allocation, having regard in particular to the requirements of paragraph 11(b) NPPF. I also object to the following elements of Policy STR 1: Point 3 A new "garden settlement" at Tudeley. Points 4 and 5 to the extent that they involve major developments in the AONB Point 7 providing for the release of Green Belt land Point 8 concerning major development within the AONB, as the tests for such development within the AONB are not met, for the reasons given by CPRE Kent and the AONB Unit. I object to Policy STR 4. There should preferably be no loss of Green Belt in the Borough. If any green Belt land must be released to permit sustainable growth of Paddock Wood, an at least equal area of Green Belt should be designated to replace the area lost. I support Policy STR 8 Conserving and enhancing the natural, built and historic environment, but I conclude that the draft Local Plan does not adhere to this policy in many important respects. | ||||||||||||||||
DLP_2691 | St. John's Road Residents Association | 4.3. The development of a new garden village at Tudeley of some 2,500-2,800 new homes with 1,900 being delivered in this plan period. We support the garden village development in principal but it is important to weigh the environmental factors as this will be a major new development requiring major transport connectivity plans. With the Council’s newly adopted objective to reach net zero carbon emission by 2030, it would be difficult to realise this target if large scale housing is build without the requisite rail and road connections. We feel that attention should be given to core strategies TP3 which states councils should provide sustainable modes of public transport in the vicinity and to town centres; well connected to public transport and within range of services or facilities without use of the private car; TP4 and EN1 which state that the proposal should not cause significant harm to the area’s safety or generate excessive traffic, that there should be “safely located access with adequate visibility”; NPPF paragraph 17 encourages full use of public transport, walking or cycling i.e. active travel NPPF paragraph 130 relates to access and highway mitigation; if these are not met the scheme can be rejected. Paragraph 4.57 considers the importance of the Infrastructure Delivery Plan which we fear will not be delivered in time before a development is approved or sufficiently idenify which types of infrastructure will be required as well as how it is to be delivered. This is particularly so in relation to connectivity between and within new rural settlements in the Tunbridge Wells. We are concerned that the provisions for flood risk are insufficient in light of the extreme weather conditions which we are experiencing today and in the future. Will the council consider flood risk proofing as a priority before even considering building on land known to comprise flood plains. Para 4.7-4.9 Release of Green Belt As already recognised in the NPPF, green belt land is to be respected and should not be built upon only upon exceptional circumstances. Paragraph 2.40-2.44 mentions the constraints that Green Belt and AONB imposes but due regard must be paid to 2.10 of the balancing effect of landscape which we need to value in terms of tourism and environmental benefits, not least of which is air quality and flood defences. | ||||||||||||||||
DLP_2725 | Paddock Wood Labour Party | The Strategic Policies The Development Strategy Section.4. Policy STR 1 OBJECT. The Development Strategy
Policy STR 3 Masterplanning and use of Compulsory Purchase powers. With the failure of a “ joined up approach” to the building approved at Church Road, Green Lane & Badsell Road where the present infrastructure is unable to cope it is imperative that a Masterplan is in place for the proposed new 4,000 houses in PW and that it is implemented before they are built and the developers adhere to it and the TWBC monitors its progress. Compulsory Purchase powers. With the £90 Million project in Calverley road TW being scrapped it is not good practice to rely on Compulsory purchase orders to ensure new development in PW. Policy STR 4 OBJECT. Green Belt Ref 4.47-4.52. Green belt status should be allocated to the land East of PW to ensure that the adjacent rural villages and PW do not lose their identity to future development. Green open spaces provide wildlife corridors and maintain our rural identity Policy STR 5 OBJECT. Essential Infrastructure and Connectivity. Transport. The country lanes and residential streets in PW are already clogged with commuter cars and heavy lorries. The Maidstone road with 900 homes already approved would have increased traffic from 4,000 new houses and any new houses to the East would create “ Rat Runs” in our narrow country lanes. There needs to be a new ring road from the East to the North of PW and a new road to relieve the centre of PW. The railway station at PW will not be able to cope with the new proposed development resulting in over crowding. Detailed discussions need to take place with Network Rail to ensure that the rail way infrastructure can cope in PW. Water It is clear that these 4,000 new houses need water supplies but there is no detail how this will be provided. South East Water need to submit real proposals to fulfil this requirement and give information and costs to the Masterplan. The present surface and foul water network infrastructure can clearly not cope with the increased surface water flooding and the resultant leakage of sewage onto roads and residents property in the Town. Greg Clark MP for Tunbridge Wells has intervened concerning this problem with Southern Water but at present Southern water have not submitted any real solutions to the problem. It is common sense to provide a new Foul water ring network around PW to relieve the present problems and plan for the new 4,000 houses. A new Sewage Treatment centre should be provided on this new ring network or the present one expanded. The issue is, who pays for this in the future before the new houses are built. Health The healthcare facilities in PW will be stretched with the present agreed 900 new houses and will not cope with 4,000 new houses. The present Health care centre at |Woodlands will be unable to manage the potential new patients and it has ready taken on the patients that live in East Peckham. A new health centre is required to deal with increased dental, and social care provision and should be mentioned in the Draft Plan.. Policy STR 6. OBJECT. Transport and Parking. As already mentioned to increase foot fall to our retail centre new free parking needs to be introduced and a joined up public transport network that offers on time reliable services at a reasonable cost. Policy STR 7 OBJECT. Place Shaping and Design. As regards the type of build no mention is made of the use of renewable energy and the TWBC policy on the issue. The draft plan should insist that all new houses have solar panels installed and electric points for recharging electric cars in the future. Also an alternative to gas fired boilers to provide central heating should be mentioned.. Policy STR 8 OBJECT. Conserving and enhancing the natural, built, and historic environment Mature trees and hedgerows need to be protected as also our adjoining woodlands to protect our wildlife and enhance the country side around the new houses. |This will reduce the risk of flooding and increase the air quality in the environment. Mitigation of replacing trees can take years to mature and should be incorporated in the Masterplan to ensure our country side is protected. | ||||||||||||||||
DLP_2831 | Helen Parrish | Cross-referenced, detailed, reasons for my Objection: Section 4 Paragraph 4.16 (The Development Strategy) p.35 The figures used are out of date and not imposed by the Government as TWBC state Section 4 Paragraph 4.38 (The Development Strategy) p.39 The distribution of Housing Allocation so uneven throughout the Borough TWBC should build on areas of land with no Green Belt, No Flood Plain, No AONB locality and not next to Tonbridge Section 4 Paragraph 4.40 (The Development Strategy) p.39 TWBC want to create a ribbon-develop from Tonbridge to Paddock Wood TWBC cannot ensure agreed levels of affordable housing to Local Residents – especially if Hadlow Estate controls the development – as developers cite economic conditions preventing promised financially viable development of such Affordable Housing There are no accurate analyses of the housing needs for Tudeley and Capel | ||||||||||||||||
DLP_3014 | Cranbrook Conservation Area Advisory Committee | COMMENT -OBJECT As TWBC Cllr McDermott allegedly reported to the Cranbrook PC meeting in August 2019 the housing numbers for Cranbrook and Sissinghurst are arbitrarily based on the number of sites which came forward under the Call for Sites process. He said that if no landowner had put forward sites very little housing would be allocated ! TWBC can hardly claim that this is a scientific needs based process on what Cranbrook or Sissinghurst need in housing terms. | ||||||||||||||||
DLP_3016 | Cranbrook Conservation Area Advisory Committee | SECTION 2 2.44; SECTION 4 4.69; SECTION 4 4.70 AGREE with the aims set out in these sections COMMENT | ||||||||||||||||
DLP_3017 | Cranbrook Conservation Area Advisory Committee | SECTION 4 4.38; SECTION 4 4.59 COMMENT Growth should be concentrated in larger towns. The small hub of economic activity proposed for Hawkhurst is not likely to meet the employment needs of many existing or new residents, who would have to use their cars to access it in any case. The housing targets proposed for rural areas under this Plan are NOT based on local needs, which could be integrated but exceed it substantially, as discussed under 4 4.7. | ||||||||||||||||
DLP_3020 | Cranbrook Conservation Area Advisory Committee | COMMENT | ||||||||||||||||
DLP_3197 | Mr Peter Bird | What happened to development down the A21 corridor? No mention of social housing thats a real need. | ||||||||||||||||
DLP_3544 | Lynne Bancroft | The Local Plan states that the development strategy for housing growth needs are based on Option 3 (dispersed growth) and Option 5 (stand alone garden settlement). I agree with this strategy overall but the dispersed growth option does not appear to have been applied fairly or proportionately across the borough. The eastern area of the borough, in particular Cranbrook and Sissinghurst, has much more housing allocated to it compared to a proportionally very small number of houses to be developed in Tunbridge Wells. This is contrary to policy ED 8 which states the hierarchy of development. The Local Plan states that Tunbridge Wells is to be the economic and cultural centre so it should take more housing proportionate to its current population and additional housing due to its economic opportunities than is currently proposed. Given there will no longer be a new theatre then this area could be used to supply affordable housing. Sissinghurst has poor connectivity with Tunbridge Wells due to a slow, infrequent no. 267 daytime only bus service that does not even directly serve the village, or via the infrequent No. 5 bus service and 2 trains via Staplehurst station or via the congested A21 through the often gridlocked village of Goudhurst. | ||||||||||||||||
DLP_3545 | Lynne Bancroft | If housing is to be developed on a dispersed growth basis then employment opportunities through the economic growth strategy should also be on a dispersed growth basis to match increases in population and to minimise additional journeys, via public transport or car. TWBC should not put such large quantities of housing in Sissinghurst and Cranbrook without additional economic opportunities and should have a policy to provide additional business sites, other than those already shown in the Local Plan, in The Weald. This particularly important due to the poor public and road transport system for this area in getting to Tunbridge Wells. | ||||||||||||||||
DLP_3546 | Lynne Bancroft | This states that the growth strategy is based on the premise of infrastructure-led development. Key infrastructure required for additional housing in Sissinghurst includes greater accessibility to Tunbridge Wells on a dualled A21 between Lamberhurst and Blue Boys. This infrastructure is not in place and will not be in place before the housing in this plan is developed so the Local Plan is obviously not infrastructure led. To be an infrastructure led Plan then much more development should be around Tunbridge Wells and the already dualled A21. | ||||||||||||||||
DLP_3547 | Lynne Bancroft | I agree with the facilitation of sustainable transport for both pleasure and work requirements. This must include public transport in the evenings as well as the day for all villages connecting to towns, including those outside of the Borough such as Sissinghurst to Tenterden as well as Sissinghurst to Tunbridge Wells and Maidstone. The Borough should encourage cheaper and more frequent public transport to encourage additional useage, especially in the rural eastern areas of the Borough. Strategic bus and rail services should be improved firstly for those residents who wish to travel within the Borough. However, due to the rural nature of the eastern part of the borough, particularly Cranbrook, Sissinghurst and Goudhurst road improvements need to be made also as the A262 is congested in Sissinghurst and Goudhurst and the A21 between Blue Boys and Lamberhurst is also congested. | ||||||||||||||||
DLP_3548 | Lynne Bancroft | As most transport is by car in the rural areas of the Borough, additional car parking on any new development must be provided, over and above that shown in the Plan as walking round any recently occupied development demonstrates the inadequacy of these levels, particularly for visitors. | ||||||||||||||||
DLP_3549 | Lynne Bancroft | TWBC should allow more weight from Neighbourhood Development Plans (NDP) at any stage of their development regardless to whether they completely line up with the TWBC Local Plan and the Local Plan should never take precedence over NDP’s as the NDPs will have greater local knowledge of the area or item concerned. | ||||||||||||||||
DLP_3550 | Lynne Bancroft | A further/separate Limits to Build Development (LBD) within Sissinghurst is not acceptable as it has only been put in place now to allow TWBC to put more housing in the area. The new LBD around Wilsley Pound and Mill Lane will start to connect two previously separate settlements (Mill Lane and Wilsley Pound) as TWBC policy will then allow infilling as shown in their assessment of Site 54 Policy AL/CRS 13 (land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road). This site has been assessed in the Cranbrook and Sissinghurst draft Neighbourhood Development Plan and development here is not supported by them so should not happen. This infilling is not acceptable in a newly defined LBD especially given the rural and historic nature of Mill Lane. Mill Lane is part of Sissinghurst Village and not Wilsley Pound and should not be included in the new LBD | ||||||||||||||||
DLP_3868 | 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: | ||||||||||||||||
DLP_4050 | Roberta Neale | I support fully all the comments made by Brenchley and Matfield Parish Council in its excellent submission. Given the proportion of Green Belt and AONB land in our area it is difficult to understand why the Council has accepted the Government’s unsound housing targets and furthermore concentrating development in the northern arc. This surely makes Tunbridge Wells a target for future housing development as envisaged in the plans for Capel and Tudeley. In fact this is envisaged in the reference to keeping targets under review in the following paragraph. That can mean increases as well as decreases. I feel that the Council is letting down the existing residents of the area and I find it hard to understand how the Council thinks it is protecting the AONB and historic and cultural heritage viz the developments at Tudeley and Capel where both communities have exceptional churches both widely recognized as such. The ambience of these buildings will be destroyed if they are engulfed in new housing developments. | ||||||||||||||||
DLP_4441 | Nick Lucas | TWBC: the standard response was submitted by the list of responders on the left: TWBC does not need to accept the levels of housing proposed by the government. 70% of the borough is protected as an AONB, and National Policy allows for development to be reduced where valued landscapes can be damaged (NPPF, Paragraph 11). By not getting housing numbers reduced, TWBC has created a draft local plan that has proposed major developments within the AONB, which is contrary to Policy EN21 which states that the High Weald AONB is one of the best surviving medieval landscapes in northern Europe. The NPPF states ‘great weight should be given to conserving and enhancing landscape and scenic beauty in the AONB. The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development, other than in exceptional circumstances’. Case history has proven that housing need alone does not equal exceptional circumstances. We would ask that TWBC assess the harm that cumulative development can do to the AONB Landscape and its communities, and argue for lower housing numbers as a result. | ||||||||||||||||
DLP_4574 | Keith Stockman | 4.19 In particular, the ENS recommended that expansion of the existing Key Employment Areas would be appropriate, at North Farm/Longfield Road in Royal Tunbridge Wells, around Maidstone Road in Paddock Wood, and at Gill's Green. Additionally, it recognised the area around the A21 highway improvements as a location for significant employment growth potential, subject to further investment. The importance of Royal Tunbridge Wells town centre is also recognised in terms of existing and future office provision, and the requirement to retain existing, well located, modern office stock within the centre. One must question why such a large proportion of housing is being targeted in Cranbrook and Sissinghurst given the expansion of existing key employment areas outlined above. All of these would necessitate travel by car on already crowded roads. 4.40 Sustainable development of an appropriate scale at the smaller settlements to provide opportunities at the local level to meet housing needs and sustain local services and infrastructure, as well as the support for new local facilities where required, and at all times being aware that such development is taking place on valued and (in many cases) protected landscapes. There should be no large scale development unless exceptional need is proven, which it most definitely is not in the Parish of Cranbrook and Sissinghurst. The development proposed in Cranbrook and Sissinghurst is not sustainable in terms of infrastructure and nor is it ‘aware of the valued and protected landscape.’ i.e. the AONB status. There is absolutely no need to put large scale development on AONB when NDP research has shown that the housing numbers can be delivered more sensitively and appropriately in small scale, sustainably designed developments that do not impact the AONB landscape in the same way that large estates do. Local research from the NDP group also indicates that the parishioners are unanimously against large scale development. national policy allows for development to be reduced where valued landscapes can be damaged (NPPF, Paragraph 11). Clearly, the large scale development proposed (all of which is on AONB land) will damage the valued AONB landscape. Development must be reduced to ameliorate this impact. | ||||||||||||||||
DLP_4578 | Keith Stockman | 4.7 Based on submission of the Local Plan in 2020, the objectively assessed housing need for the borough over the plan period to 2036 is confirmed as 13,560 dwellings (678 per year), identified by the standard methodology as required by the NPPF(20) It is true that more homes are needed in the Parish of Cranbrook and Sissinghurst. However, the independent research commissioned by the NDP, which proves that this need can be delivered by small scale housing developments, has been totally ignored by TWBC. | ||||||||||||||||
DLP_4581 | Keith Stockman | 4.40 Sustainable development of an appropriate scale at the smaller settlements to provide opportunities at the local level to meet housing needs and sustain local services and infrastructure, as well as the support for new local facilities where required, and at all times being aware that such development is taking place on valued and (in many cases) protected landscapes. The development proposed is neither small scale nor sustainable and exceeds the local need hugely. Development of the scale proposed in the AONB pays no regard whatsoever to protection of the landscape. | ||||||||||||||||
DLP_4762 | DHA Planning Ltd for Caenwood Estates and Dandara | 3.3 Development Strategy and Strategic Policies Context 3.3.1 The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the borough and where that development will be located. 3.3.2 In terms of the amount of housing, paragraph 59 of the NPPF states that to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient quantum and variety of land can come forward where it is needed. Furthermore, to determine the number of homes needed, strategic policies should be informed by a local housing needs assessment conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. 3.3.3 The Council confirm that their housing need target for the plan period 2016-2036 is 13,560 dwellings (678 dwellings per annum), which is calculated using the Government’s standard method and the 2014-based household projections. 3.3.4 In terms of the different supply components, the Council considers that the Local Plan must (as a minimum) include additional allocations to accommodate 7,593 homes. This figure was formulated taking into account:
3.3.5 The Council has applied a 10% non-delivery rate to these figures to err on the side of caution and consider that the plan would exceed the minimum housing requirement if all of the supply components were achieved. However, given the Plan’s reliance on large strategic sites, and the potential for delays in delivery as set out in our representations, we suggest it may be advisable to increase this buffer to ensure that the Council is in a position to meet its housing delivery targets throughout the plan period. If not, there is the risk of unplanned, speculative schemes coming forward. 3.3.6 We commend TWBC for seeking to meet their need in full and support this positive approach to plan-making. Likewise, we support the general thrust of the development strategy, which proposes a strategy to meet the housing needs of the borough with a dispersed growth approach. [TWBC: seefull representation]. | ||||||||||||||||
DLP_6750 | Mrs Carol Richards | The development strategy – para 4.1 This is not as stated in 4.6 pt 2 ‘ a borough- wide spatial development strategy’ Housing Development – para 4.7 TWBC has been given a housing need figure of 13,560. TWBC has taken the housing need figure of 13,560 and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. The Ministry of Housing, Communities and Local Government have repeatedly made clear via their Ministers and the Secretary of State for Housing that “the housing need figure is not a mandatory target. Local Authorities should make a realistic assessment of the number of homes their communities need, using the standard method as the starting point in the process. Once this has been established planning to meet that need will require consideration of land availability, relevant constraints and whether the need is more appropriately met in neighbouring areas”. TWBC has chosen to accept the government’s housing need for Tunbridge Wells borough based on the standard method of calculation. However, TWBC knows that the ONS 2016 figures show a smaller housing need, as does the more recent 2018. TWBC can protect this borough from the destruction of Green Belt and AONB by following NPPF guidelines. i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or The NPPF makes provision for TWBC to have a choice in the provision of the objectively assessed 13,560 houses. If provision of these houses is really only possible by sacrificing Green Belt Land then the NPPF makes it perfectly possible for TWBC to say that this is not achievable. TWBC have chosen not to do so. TWBC could reduce the number of houses delivered by the Local Plan and could plan the houses it does build -more evenly around the borough i.e. more spatially distributed and not in AONB and not in green Belt Economic Development – paras 4.18-4.20 The rationale TWBC are following is to protect the A21 corridor as a Key Employment Area, which given the now excellent road is a very good idea. The ENS study/report states by helping to’ support the creation of new employment opportunities alongside the provision of new housing’ this would in turn help to reduce out- commuting. As one of the major requirements for a garden village is to provide employment within the village, (reducing carbon emissions)-surely placing more housing development closer to the A21 corridor and the Key Employment Area- is what should be in TWBC’s Local Plan - not a ‘Masterplan’ to develop Tudeley, Capel and Paddock Wood. N.B. Providing industrial development in the designated North Farm site- of which a tiny part is in Capel Parish- does not count as Capel Parish employment. It is a long way from TWBC’s proposed ‘garden village.’ and divided by the A21 The Development Strategy Formulating preferred options – paras 4.28 – 4.31 I refer to the Distribution of Development Topic Paper, in which * In para 2.7, the study findings indicate that larger settlements tended to score more highly across the range of sustainability indicators. Yet nowhere in Table 1 is there a mention of Tudeley. It is also worth noting that Five Oak Green sits with Goudhurst, Lamberhurst and Brenchley and yet Five Oak Green with the potential to flood is picked above all other towns in section B and the same goes for Paddock wood in Group A. For the same reason that Tunbridge Wells and Southborough are restricted by constraints- is not Tonbridge? The logic of placing 2800 homes on the doorstep of Tonbridge is not sound. 4.29 However, placing 63% of the housing need from Tudeley (with a garden settlement-option 5) and stretching to Paddock Wood- hardly constitutes ‘development distribution proportional across all the borough’s settlement’- Option3. The most concerning and subtle wording in Table 2 states, “A new settlement ………providing future development needs of the borough”. This apparently innocuous comment implies the addition of more and more houses- coalescing from Tonbridge to Five Oak Green and eventually to Paddock Wood forming a housing corridor to the North of TWB. Totally against para 134b of the NPPF. I personally find this Draft Plan totally unsound. It is a disgrace to TWBC and the underhand manner, in which it has been dealt with locally is shameful i.e. the total lack of information in Tonbridge public spaces. If the inspectorate would like to know more about this matter and other matters, a conversation with the Save Capel Group would inform her/him of the relevant details. Figure 4 Key Diagram page 41 The key to the map shows development sites in purple and the size of the circle indicating the size of the development. The Tudeley circle represents 1000 when in fact it should represent the ‘Garden Village’ of 1,900 homes i.e.it should be nearly 2 times the size of the circle representing 1000 homes- in fact for the full 2.800 it should be 3 times the size. As it is one of the main features of this Draft Plan, it should be more accurate. The only problem with that is there would be an almost solid line of large purple circles along the top of the map and this would not look- as if option 3 Dispersed growth was part of the Draft Plan. Perhaps more attention should be given to making a more accurate map, showing the true extent of the Tudeley/Capel/ Paddock Wood/ development and giving it a proper title. This map however does usefully show the building constraints within the borough because of the large Areas of Outstanding National Beauty and the Green belt. A total of 70% of the area. However, what is not easy to see is the extent to which the Tudeley/ Capel/ Paddock Wood area is affected by the River Medway. This is shown on p8 Fig4 Titled Flood Risk Zones (taken from (SFRA) in the Distribution of Topic Paper for the Draft Local Plan. These two Maps together - overlaid would show what should be considered further constraints to the Draft Plan. A further map which should also be included is a Contour Map, overlaid by the Flood Risk Zone Map showing the low- lying land and how flat this area is! This combination of information would demonstrate the “inappropriate development in areas at risk of flooding” para 155 of the NPPF-which goes on to state development “should be avoided- by directing development away from areas at highest risk (whether existing or future)”. We are all aware of the impact of Climate change and the risk of the higher frequency of flood water- which will increase and therefore the risk to this area in the future is very great. All of these Maps do visibly show, very easily, how unsuitable this proposed corridor of development is and how TWBC has failed to seriously look at alternative sites that are for example- in a far safer area, not in Green Belt and not in an AONB. There are other sites but TWBC have not looked at them seriously. The idea of a substantial garden village anywhere in this borough is unsound. Given the Constraints of ANOB, Green Belt and an aging population, Options 2 and 4 are a far better approach- far more work of course. but would keep the essentially Rural nature of the borough (Table 2 Local plan options (Issues and Options consultation 2017). The only other approach is to look at Horsmonden and perhaps Frittenden- both outside ANOB and Green Belt and the flood risk is less and therefore more future proof. | ||||||||||||||||
DLP_8190 | Mrs Suzi Rich | TWBC has interpreted its housing need figure to be 13,560. For various reasons, the dLP proposes that even more houses are built, a figure of 14,776. I object to this figure for the following reasons: TWBC has based its housing need on the standard method of calculation without challenge. This is despite knowing that the ONS 2016 figures show a smaller housing need and that policy will reflect that in due course. Why build more houses than Tunbridge Wells Borough needs? Why not protect areas of MGB and AONB by following NPPF guidelines? [TWBC: See comments DLP_8189-8214 for full representation] | ||||||||||||||||
DLP_8191 | Mrs Suzi Rich | TWBC has suggested that its development strategy is based on dispersed growth but the dLP is almost entirely dependent on the successful implementation of proposed garden settlement in Tudeley (AL/CA 1) and the expansion of Paddock Wood which includes development within East Capel (AL/CA 3 & AL/PW 1). These two developments form 63% of the new housing. [TWBC: See comments DLP_8189-8214 for full representation] | ||||||||||||||||
DLP_43 | Thomas Weinberg | Comments on Section 4 Paragraph 4.16 (The Development Strategy) p.35 TWBC has been given a housing need figure of 13,560. The NPPF para 11(b) says “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless: i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or ii. Any adverse impact of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework when taken as a whole”. | ||||||||||||||||
DLP_44 | Thomas Weinberg | Comments on Section 4 Paragraph 4.38 (The Development Strategy) p.39 You are proposing a development strategy based on dispersed growth, i.e. proportional distribution of development across all of the borough’s settlements and yet over 60% of new housing will be in the settlement in Tudeley and the expansion of Paddock Wood including building on East Capel. | ||||||||||||||||
DLP_45 | Thomas Weinberg | Comments on Section 4 Paragraph 4.40 (The Development Strategy) p.39 You have used NDAs to hide your plans until it was too late for residents to have a fair say. Hadlow Estate have offered one letter to residents and evicted residents to raise funds to pay their masterplanning consultants as their form of “community engagement”. | ||||||||||||||||
DLP_49 | Thomas Weinberg | Comments on Section 4 Paragraph 4.49 (The Green Belt) p.49 | ||||||||||||||||
DLP_50 | Thomas Weinberg | Comments on Section 4 Paragraph 4.50 (The Green Belt) p.49 Tudeley is a tiny hamlet. It has 50 houses at most. The whole of the Parish of Capel has only 950 houses in it. Adding 2,800 new houses at Tudeley is a massive increase that will fundamentally alter the nature of the communities involved for the worse. | ||||||||||||||||
DLP_55 | Thomas Weinberg | Comments on Section 4 Paragraph 4.87 (Limits to Built Development) p.62 | ||||||||||||||||
DLP_89 | Roger Bishop | The Development Strategy Section 4 - para 4.16 - p35 TWBC has chosen to accept the government’s housing need for Tunbridge Wells borough based on the standard method of calculation, i.e. 13,560, and then increased it to 14,776. [TWBC: see also Comment Numbers DLP_81 to 93]. | ||||||||||||||||
DLP_90 | Roger Bishop | Development Strategy of the Draft Local Plan – para 4.38 – p39 Reference is made to “dispersed growth” and site allocations for housing “located at the majority of settlements across the borough”. This is highly misleading given the planned dumping of over 25% of the total new houses in one parish, Capel.. [TWBC: see also Comment Numbers DLP_81 to 93]. | ||||||||||||||||
DLP_125 | Gregg Newman | Comments on Section 4 Paragraph 4.16 (The Development Strategy) p.35 Representations have, I understand, already been made to you in this respect, but to reiterate - TWBC has been given a housing need figure of 13,560. TWBC has taken the housing need figure of 13,560 and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. You have chosen to accept the government’s housing need for Tunbridge Wells borough based on the standard method of calculation. You know that the ONS 2016 figures show a smaller housing need and that policy will reflect that in due course. You know that you can protect this borough from the destruction of Green Belt and AONB by following NPPF guidelines. The NPPF para 11(b) says “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
The NPPF makes provision for TWBC to have a choice in the provision of the objectively assessed 13,560 houses. If provision of these houses is really only possible by sacrificing Green Belt land then the NPPF makes it perfectly possible for TWBC to say that this is not achievable. TWBC have chosen not to do so. Reduce the number of houses delivered by the Local Plan. | ||||||||||||||||
DLP_126 | Gregg Newman | Comments on Section 4 Paragraph 4.38 (The Development Strategy) p.39 Your stated development strategy based on dispersed growth is cynically phrased to imply it is being achieved through numerous means. However the Local Plan is almost entirely dependent on the successful implementation of proposed garden settlement in Tudeley and the expansion of Paddock Wood including building on East Capel. They form 63% of the new housing. This appears to be a very risky strategy and intentionally misleading to voters and the public at large. | ||||||||||||||||
DLP_127 | Gregg Newman | Comments on Section 4 Paragraph 4.40 (The Development Strategy) p.39 As a resident of Hadlow, this plan lays bare the naked truth. This will become a large conurbation, with huge adverse effects upon residents of areas outside of Tunbridge Wells, but also with no real benefits to TWBC residents either. | ||||||||||||||||
DLP_302 | Janet Sears | The housing target of 300,00 based on ONS 2014 calculation should be challenged. If these targets are reduced to 160,00 in line with the ONS recommendations of 2016 the destruction of our precious landscape, wildlife and for many residents way of life could be reduced. Surely we have learned from the problems we are now experiencing from the use of plastics which were seen as the way forward at the time. If we destroy our countryside by building houses and all the associated infrastructure there will be no going back. | ||||||||||||||||
DLP_854 | Ian Pattenden | Comments on Section 4 Paragraph 4.16 (The Development Strategy) p.35 TWBC has taken the housing need figure of 13,560 and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. The Ministry of Housing, Communities and Local Government have repeatedly made clear via their Ministers and the Secretary of State for Housing that “the housing need figure is not a mandatory target. Local Authorities should make a realistic assessment of the number of homes their communities need, using the standard method as the starting point in the process. Once this has been established planning to meet that need will require consideration of land availability, relevant constraints and whether the need is more appropriately met in neighbouring areas... The NPPF is clear that only in exceptional circumstances may a Green Belt boundary be altered, through the Local Plan process. Last year we strengthened Green Belt policy in the revised NPPF”. You have chosen to accept the government’s housing need for Tunbridge Wells borough based on the standard method of calculation. You know that the ONS 2016 figures show a smaller housing need and that policy will reflect that in due course so you should use it now and offer this as your compromise to protect the green belt. You know that you can protect this borough from the destruction of Green Belt and AONB by following NPPF guidelines. The NPPF para 11(b) says “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
The NPPF makes provision for TWBC to have a choice in the provision of the objectively assessed 13,560 houses. If provision of these houses is really only possible by sacrificing Green Belt land then the NPPF makes it perfectly possible for TWBC to say that this is not achievable. TWBC have chosen not to do so and have offered no explanation. Comments on Section 4 Paragraph 4.38 (The Development Strategy) p.39 You are proposing a development strategy based on dispersed growth, i.e. proportional distribution of development across all of the borough’s settlements. You imply that you have achieved this but this is misleading. The Local Plan is almost entirely dependent on the successful implementation of proposed garden settlement in Tudeley and the expansion of Paddock Wood including building on East Capel. They form 63% of the new housing which in my view is NOT DISPERSED GROWTH. If these sites fail to deliver then the associated infrastructure that is entirely reliant on developer capital would also never be realised. This appears to stack risk on risk, where both areas of development are inextricably linked and the failure of one would lead to collapse of the other and as a result the whole plan would fail. There are multiple major issues to be overcome with the proposed development, further underlining the enormous gamble TWBC are taking with this proposal. I object to such a gamble being taken on our precious green belt countryside. Comments on Section 4 Paragraph 4.40 (The Development Strategy) p.39 You refer to Tudeley Village securing a long term option for the borough to deliver the needs of future generations. It is clear from this statement that you intend to add more and more housing to this “garden settlement” in each five year review of future Local Plans. TWBC want to flood Tudeley and East Capel with housing until it coalesces with Tonbridge and Five Oak Green and coalesces Five Oak Green and Paddock Wood, ultimately creating a massive conurbation from Tonbridge to Paddock Wood. This is urban sprawl something the green belt is in place to stop. You have used NDAs to hide your plans until it was too late for residents to have a fair say, no local community engagement and somewhat sleezy. Hadlow Estate have sent us a sickening, self-serving and hypocritical letter trying to “justify” their appalling actions which is crass in the extreme, there is only one objective by this land owner…..grab the money and get out of farming. This important land asset deserves your protection and you as public servants have a duty to maintain it for future generations. | ||||||||||||||||
DLP_954 | Mrs Karen Stevenson | The draft Local Plan sets out the policy framework in which the Borough Council will make planning decisions and deliver development to meet its housing target within the Plan period, 2016-2036. TWBC appear to be accepting without challenge the top-down target set by central government of 13,560 homes (in fact TWBC are proposing to set their own target actually 9% above this level at 14,776 homes). This is based on the objectively assessed housing need for the borough over the plan period, identified by the standard methodology as required by the NPPF. Yet this methodology is flawed, being based on historic data and despite their being considerable wealth of information available to argue that this is not correct. Many other local authorities including Sevenoaks, Guildford and Uttlesford to name a few, have taken the initiative to seek a reduction of these numbers based on a more pragmatic approach based on local need and capacity. One such piece of research which raises challenge to the out-dated approach in setting housing targets, is a paper published by UK Collaborative Centre for Housing Evidence – entitled: Tackling the UK Housing Crisis – is Supply the Answer, written by Ian Mulhern Aug 2019. (This examines and challenges the thinking that by building more house prices will come down). Is the problem not so much a housing shortage but a housing affordability crisis? Further to this, the Housing Needs Assessment Topic Paper (August 2019) already states that, the government will be reviewing the methodology for calculating housing numbers in the next eighteen months, because the current methodology it relies on is out of date, based on 2014 projections. The Government reasoning for continuing to use these, on an interim basis, is to provide stability and certainty to the planning system in the short-term. So these numbers should not be taken as a mandatory target for TWBC to plan for, but a starting point only. The standard methodology is, therefore not mandatory. The target that the Plan aims to achieve could be far higher than it needs to be. It is not appropriate for the Council to adopt its ‘wait and see’ position, which could lead to its policy framework being based on a false target. The Plan needs to be based upon the most realistic assessment of need, taking into account the constraints that characterise the Borough. Further, as 70% of the borough comprises AONB or Green Belt, which are supposed to be protected landscapes, there are further reasons why the overall number should be challenged. Such levels of development as are proposed in this draft local plan, will cause irreparable damage to the local environment. In fact Paragraph 4.8 specifically notes that Sevenoaks District Council is not proposing to wholly meet its housing need. If, as the Plan states, the constraints that apply to Sevenoaks District Council are similar to those of TWBC, why isn’t TWBC also challenging their housing target based on standard methodology and/or proposing to not wholly meet the need identified through this method? Isn’t there a case to argue that the constraints that apply to TWBC (the extent of AONB and Green Belt land in the borough and notable affordability pressures potentially causing a fall in home ownership) constitute “exceptional circumstances”, which could justify an alternative approach to assessing housing need according to NPPF paragraph 60? I will come to the more immediate issue of the allocation for the Parish of Brenchley and Matfield of 91-150 dwellings, further into this response document. | ||||||||||||||||
DLP_1102 | Mr John Hurst | Section 4 - The Development Strategy It is recommended to include in the DLP the distribution of the 3,127 dwellings that already have Planning Permission (line 3). It is currently impossible to see where they are, is greenfield or brownfield, and within or without the Green Belt. The DLP leaflet's central diagram only records about 692 dwellings in the "already have PP" category. Overall, same comments as for STR1 apply, ie challenge the number of new dwellings "needed". | ||||||||||||||||
DLP_1628 | Maggie Fenton | Repeated use of the phrase “To be determined as part of masterplanning” in reference to Paddock Wood, Capel and Tudeley is ridiculous when it refers to 63% of the houses in this Local Plan. You are asking residents and businesses to consult on a largely incomplete draft. Other regions may have Local Plans that do not have a complete map of roads and other infrastructure but they omit complete infrastructure specifications for minor parts of their plans – not for the majority of their plans. This is a gaping hole in the draft Local Plan. It is therefore unsound | ||||||||||||||||
DLP_1690 | Brenchley and Matfield Parish Council | 2. The Local Plan Development Strategy a. We are not convinced that the case for the approach of dispersed growth across the borough has been soundly made. It is too far removed from the aims of the adopted Core Strategy which recognizes that rural settlements, such as those in Brenchley and Matfield, are least able to support sustainable development. The majority of responses to the five strategy options set out in the Issues and Options consultation did not favour dispersal or semi-dispersed growth across the borough. Crucially, dispersed growth would not conform to the requirements of the National Planning Policy Framework (NPPF). b. Attention is drawn to paragraphs 102 and 103 of the NPPF (February 2019) which concern the need for plans to locate development so as to reduce the need to travel and to increase the scope for walking, cycling and public transport. In addition, paragraphs 171 and 172, which seek to conserve and enhance Areas of Outstanding Natural Beauty (AONBs) by limiting the scale and extent of development within such designated areas: 77% of the parish is with the High Weald AONB. Accordingly, the Parish Council objects to the dispersed growth strategy for housing development, as set out in the Draft Local Plan. This is because it directs a disproportionate amount of growth to rural settlements with limited facilities and jobs, and with poorer access to public transport. These rural settlements have higher dependence on the private car and access to them is generally along low capacity rural roads and lanes. c. The issue of a high dependency on the private car highlights a significant weakness in the strategy. It can be argued that whilst a number of the general policies in the DLP (for example STR6 and EN2) are aimed at reducing car dependency, one of the effects of the dispersed growth strategy would be to substantially undermine the intentions of those policies. d. It is extremely disquieting to read in Section 3 of the Development Constraints Study (DCS) that “as it stands, there is not yet the evidence in place to arrive at a definitive conclusion as to how highways capacity could impact on the development strategy for the new Local Plan. The Council will work with its partners, including Kent County Council and Highways England, to carry out relevant technical work and assessments…” From that statement it is assumed the reverse is also not quantified - that is, the impact of the adopted development strategy on the highways capacity is similarly not known. This is a significant weakness in the DLP and raises questions over the deliverability of the planning strategy. e. A further significant weakness is the incomplete Infrastructure Delivery Plan (IDP). It is disappointing to note in the column marked “Expected Funding Gap” that the contribution of all of the third-party agencies is given as “TBC”. Residents and businesses cannot see how the DLP can be considered credible and deliverable without an IDP specifying core infrastructure assets being in place and ready by construction or occupation of the first phase of house-building. f. Given the situation with the IDP, we would urge TWBC to quantify the impact of the proposed developments on the residents and businesses in Brenchley and Matfield. In particular: the prospect of increased congestion at the junction of A21 and the B2160 at Kippings Cross; the B2160 through Matfield; and other roads that would be affected by proposed developments in Paddock Wood and Horsmonden. g. The most significant consequence of the policy of dispersed growth is that the area covered by five local councils in the north-east of the borough would take the lion’s share of housing development. An arc, roughly comprising Horsmonden, Brenchley and Matfield, Paddock Wood, Capel, and Pembury, has been allocated in excess of 7,000 units. However, we cannot find any acknowledgement in the DLP that this “quadrant” is to be the focus of the proposed development strategy, or, if so, that it is the priority area for infrastructure investment. Nor is there any indication of the cumulative impact of development across the arc. Whilst it is recognized that a master-planning approach would be taken in the development of the strategic sites, this does not go far enough in dealing with such issues as the social, economic, and environmental infrastructure needed to support development on that scale. h. There is also no indication that the potential coalescence of settlements and parishes has been properly addressed. An obvious example of this is the proposed extension of Paddock Wood into Capel. Within Brenchley and Matfield we are concerned that it appears (on a map on p.174) that Mile Oak, one of the historic hamlets in the parish, and a section of Chantlers Hill, would coalesce with new development in Paddock Wood – both of which would be vigorously resisted. We are also concerned that the extent of development to the south of Paddock Wood could erode the size of the gap in the landscape which separates it from Matfield. The development strategy must include the provision of a landscape policy to prevent the coalescence of settlements. i. In addition to being contrary to the aims of the AONB designation, the proposed development strategy also rides roughshod over policy aimed at protecting the Metropolitan Green Belt. It is not clear to us what the “exceptional circumstances” are that would warrant such an approach. The intention not to replace land lost to development runs counter to the conclusions of TWBC’s own review of the Green Belt, for which no convincing evidence is offered. j. Given the foregoing, it is clear to us that an adopted policy of dispersed growth would cause the irreversible loss of character and separate identity of some of our villages and hamlets. This will also loosen the bonds of vibrant localities that promote cohesive social interaction and which underpins the well-being of communities. We therefore do not think that the proposed development strategy would be in the public interest and, if implemented, would cause significant harm to both the AONB and Green Belt designations. TWBC is strongly urged to consider retaining a development strategy which continues to recognize the need to protect the rural areas, and which concentrates development in sustainable locations, either in or adjacent to the main urban area (Royal Tunbridge Wells and Southborough), or along transport corridors with high capacity. 3. Mitigating the Impact of Development a. Should the proposal to concentrate development within the north-east quadrant be taken forward, the Council would argue strongly that it be conditional on significant improvements to the A228 – indeed, we would press for a re-alignment of the road to support the scale of development. It should also be conditional on all other forms of infrastructure, such as water supply, and sewerage disposal and treatment, to be delivered in tandem with development. b. We would also press for significant development contributions from the strategic sites in Paddock Wood and Tudeley, to all five parishes within the quadrant. This would be to compensate for the individual and cumulative impact on the quality of life – particularly the substantial increase in traffic – on each parish and town. 7. Conclusion a. We wish to underline the considerable harm that would be done to the rural areas of the borough if the proposed strategy of dispersed development were to be adopted by TWBC. The traffic that it would undoubtedly generate, compared to more centralized/brownfield development in the urban areas with existing rail infrastructure, would severely exacerbate the well-documented pressures in the rural areas. Development on the scale envisaged is unlikely to be sustainable and would fly in the face of current environmental concerns about climate-change and global-warming. [TWBC: part of whole comment number DLP_1683]. | ||||||||||||||||
DLP_1726 | Peter Hay | The failure to consider the NPPF paragraph 11b i and ii to review the Standard Housing Formula housing figures for the borough as a whole, due to the significant area of the AONB within the borough. Thus the failure to reduce the housing / development within the borough as a whole. Indeed, TWBC decided to increase it by 900 houses borough wide The failure to consider NPPF paragraph 172 to maximise the call for sites opportunities within Tunbridge Wells and Southborough prior to allocating housing / development within the AONB. Inappropriate Distribution of Development Policy The failure to consider the results of previous consultation where only 8% supported the “Distribution Development policy” proposed by the draft local plan | ||||||||||||||||
DLP_1774 | CPRE Kent | CPRE Kent – the Countryside Charity - is an independent charity, wholly funded by its members and supporters, which operates under the umbrella of the national CPRE charity. CPRE campaigns to protect, promote and enhance our towns and countryside to make them better places to live, work and enjoy, and to ensure the countryside is protected for now and future generations. In general CPRE Kent supports a development strategy which meets the following criteria:
CPRE Kent considers there are good reasons why the Tunbridge Wells Local Plan should not meet its housing requirement in full – reflecting the constraints clearly shown on the policies map accompanying the draft plan, including fact that 70% of the borough is designated AONB, 22% is Metropolitan Green Belt and there are areas of Ancient Woodland outside these protected landscape areas. Additional constraints arise from the location of flood plain, best and most versatile agricultural land, conservation areas and intrinsically dark skies. All of these factors limit the amount of land available for development in the borough, in accordance with the NPPF. Much of the borough consists of rural landscape, valued and designated as such and demonstrating a pattern of settlement and land use of great historical significance. The settings of the various settlements form part of their character and historic interest. The borough’s duties under the NPPF, read as a whole, are not to destroy or damage these features, but to protect and enhance them. The Housing Need Consultation Data Table that accompanied the Planning for the Right Homes in the Right Places 2017 consultation set out that 75% of the proportion of Local Authority land area was covered by Green Belt, National Parks, Areas of Outstanding Natural Beauty or Sites of Special Scientific Interest. Of this 93% is in the High Weald AONB. The NPPF paragraph 172 requires great weight to be given to conserving and enhancing landscape and scenic beauty in AONBs. The Council’s Development Constraints Study October 2016 that a large part of the Borough outside the Green Belt and High Weald AONB is either Ancient Woodland, which NPPF 175 identifies as irreplaceable habitat that should be protected; lies within flood zones 2 and 3, or best and most versatile agricultural land. Thus well over 75% of the Borough is constrained. The Corine Land Classification 2012 indicates that around 10% of the borough was built-up. Given that the High Weald AONB stretches across the whole length of the borough there is the potential that there will be areas of land within its setting. Planning Practice Guidance paragraph: 042 Reference ID: 8-042-20190721 (revised 21 July 2019) sets out that “land within the setting of these areas often makes an important contribution to maintaining their natural beauty, and where poorly located or designed development can do significant harm. This is especially the case where long views from or to the designated landscape are identified as important, or where the landscape character of land within and adjoining the designated area is complementary. Development within the settings of these areas will therefore need sensitive handling that takes these potential impacts into account.” The NPPF at paragraph 3 states “the framework should be read as a whole (including its footnotes and annexes).” Paragraph 11(b) expands on this by stating: “(i) the application of policies in this Framework that protects areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area.” This is explained in footnote 6 on page 6 of the NPPF as policies relating to land designated as green belt, local green space, AONB, irreplaceable habitats, designated heritage assets and areas at risk of flooding. Or “(ii) any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.” If the delivery of housing was the sole objective of the NPPF then paragraphs 3 and 11(b) would have not been included. Thus, for these paragraphs to be meaningful they will need to be given due consideration during this consultation. CPRE Kent has concerns about the number of dwellings proposed in the local plan and how these new homes will be delivered. In the 37 years since 1981/82 an average of 343 dwellings per annum have been built in the borough. This dropped to 282 for the past 10 years and has risen to 357 for the last five years. Only twice since 1981/82 have more than 686 dwellings per annum been completed – in 1988/89 (761) and 1989/90 (886). Population change should also be considered in terms of scale of future need. For the period 2001-2018 annual population change averaged 824, while for the last five years it has halved to 392. This discrepancy between the borough’s OAN and any reasonable estimate of future household formation or housebuilding capacity in the borough is hardly surprising, since the standard methodology for calculating OAN no longer lays claim to being an estimate of local need, based on up-to-date data. The Government’s published justification for the methodology is as follows: the 2014-based household projections are used within the standard method to provide stability for planning authorities and communities, ensure that historic under-delivery and declining affordability are reflected, and to be consistent with the Government’s objective of significantly boosting the supply of homes. Leaving to one side the question of whether this represents a legally sound basis for the policy, on which we reserve our position, we would suggest that the artificial and unrealistic nature of the OAN should only add relative countervailing weight to the clear and unambiguous duties of the Council to protect the AONB, green belt, irreplaceable habitats, best and most versatile agricultural land and conservation areas in the borough, and avoid inappropriate development in areas of flood risk. Research by BuiltPlace into house prices and transactions based on ONS/HMLR house price index demonstrates that falling house prices has not been matched by increased purchases.[1] CPRE Kent is of the opinion that the option of only partially meeting identified needs has not been considered sufficiently, or at all (paragraph 6.1.8 of the SA), as a reasonable alternative. The only substantive reason given for not considering this option is that sufficient sites came forward in response to the calls for sites to build this number of homes. This ignores the suitability or sustainability of such sites. Writing off this option doesn’t reflect the conclusions reached with the SA objectives. Table 8 (page 34 of the SA) demonstrates that housing meets only meets five of the 19 SA objectives, and is incompatible with nine of the 19 SA objectives – making it the only objective which is incompatible with more SA objectives, than it is compatible with. CPRE Kent considers that the borough does not have the capacity to meet its housing targets without significant harm to the green belt and AONB and other characteristics of the borough protected by, or worthy of protection under, the planning system. The Council’s OAN is 13,560 of which 1,552 dwellings have been completed, leaving a requirement of 12,008 to be provided. Some of this will be in the form of existing permissions, outstanding site allocations and windfall allowance. The remaining 7,593 will be from new allocations of which 1,900 will be at Tudeley and 4,000 at Paddock Wood. These two sites will provide 49% of outstanding new housing. In addition, the draft plan not only provides for the OAN, but also an additional 9% buffer. The justification for this is not apparent in a borough where NPPF paragraph 11(b) applies and where the Council has already taken a cautious approach to the likely yield of sites. For this reason, CPRE Kent objects to the 9% inflation of the housing need figure. The Housing Supply and Trajectory Topic Paper for Draft Local Plan (September 2019) at paragraphs 4.5.2 and 4.5.3 states that the Council will further engage with developers to review past and future progress of housing delivery; and will ask developers to comment on presumptions about lead-in times and delivery rates. This indicates that the present housing trajectory is draft. It may well change, and with reliance on just two sites for almost half of the borough’s housing requirement, may not deliver at the anticipated rates. With regard to build-out rates the Trajectory Topic Paper sets out at paragraph 4.13.4 that national studies for urban extensions in the south of England demonstrate that delivery rates have been in excess of 120 units per annum. It is not clear which studies are being referred to or when they were published, nor the location and scale of the urban extensions. Paragraph 4.13.5, again referring to national studies, states that sites will exhibit lower completions in their first and second years before construction on the site becomes established. At paragraph 4.13.9 gives a build-out rate of 128 for developments of size 1000-2000, and 299 for developments of 2,000+. Table 9 of the Trajectory Topic Paper (page 27) assumes that build-out for Tudeley will commence 2025/2026 and for the periods 2025/2026 to 2029/30 be 150 dwellings per annum and then rise to 200 dwellings per annum to the end of the plan period delivering 1,750 dwellings. On page 30 the assumptions for the 4,000 dwellings at Paddock Wood is that 333 dwellings will be delivered from 2024/25 delivering all 4,000 dwellings by the end of the plan period. CPRE Kent is concerned that if the trajectories prove to be over-optimistic and the Borough fails to meet the housing delivery test, then other precious AONB and green belt countryside will be put at risk. CPRE questions these trajectories for the following reasons:
With regard to windfalls Table 10 of the Trajectory Topic Paper [Windfall (Sites of 1-9 Units) Completions (2006-2019) Including Negative Delivery] and paragraphs 5.6.4 and 5.6.6 show that the net average annual windfall was 132 dwellings. Paragraph 5.6.4 goes on to explain that 132 dwellings per annum is unlikely to be sustained over the whole Plan period, as opportunities within LBDs are finite and many of the more achievable infills, redevelopments and conversions have been undertaken. For this reason paragraph 5.6.6 considers that 50 per annum is justifiable. Beyond this statement no evidence is provided to support the assumed windfall number of 50 per annum. Hard evidence is required. Table 9 of the Trajectory Topic Paper assumes that Tudeley will start to deliver 2025/26. This is likely to require groundworks in 2024/25. This implies three years from Local Plan adoption to first build out. It assumes that Paddock Wood will start to deliver 2024/25 and again this is likely to require groundworks in 2023/24. CPRE Kent queries whether there is sufficient time to prepare and agree a masterplan and outline application. [1] https://builtplace.com/wp-content/uploads/reports/HMLR-LA/2019-10/Tunbridge_Wells.pdf | ||||||||||||||||
DLP_2028 | Terry Everest | The Development Strategy As stated previously this strategy is overly development led and focuses too strongly on calculated targets that fit an overall metric. These projections may well prove be to be wrong when you consider multiple factors such as declining birth rates, a volatile and potentially collapsible world market, the effect of Brexit or the ultimate outcome of these national arguments and the reduction of net immigration that this nation hopes to achieve. Whilst some growth and housing is needed and therefore supported where it is done appropriately and at minimal cost to the environment, I would strongyl object to the enormous numbers proposed at tudely, Capel and Paddock Wood and argue that just one tenth of these homes should be built within this timeframe and those that are built should be located to the north and east of Paddock Wood - which does have some capacity to grow in these areas. Of the combined total of 6800 homes therefore just 680 should be given the go ahead thus preserving the unique village and halmet characters of Tudely and Capel where just up to 15 and 5 homes can reasonably be developed within the current limits of development. Although a bypass to the A228 has long been argued for it is very important that the current route remains a fast through route to north and east kent and should not therefore be surrounded by development. If a bypass is still needed it should not be simply parallel as either side of the route there are historic orchards, trees and woodlands which should be preserved. A much better work around to the east then north could be achieved using sections of other roads and less sensitve areas. Much of the need for this bypass route would be obviated by reducing these rather extreme and radical developments. | ||||||||||||||||
DLP_3200 | Mr Peter Bird | Did you look at land around Bells Yew Green. This has a main line station. Lack of public transport. The 296 bus. to. nearest main line only runs as a shopping service on Mon, Thurs & Sat. Twice a day 11:35am & 5:05pm no good for commuters. | ||||||||||||||||
DLP_3661 | Capel Parish Council | Object Tunbridge Wells Borough Council has interpreted its housing need figure to be 13,560 and then up-scaled it to 14,776. This is despite TWBC having strong grounds to lower its housing need figure due to the large amount of Green Belt and AONB land in the borough. The Ministry of Housing, Communities and Local Government has repeatedly made clear that “the housing need figure is not a mandatory target. Local Authorities should make a realistic assessment of the number of homes their communities need, using the standard method as the starting point in the process. Once this has been established planning to meet that need will require consideration of land availability, relevant constraints and whether the need is more appropriately met in neighbouring areas... The NPPF is clear that only in exceptional circumstances may a Green Belt boundary be altered, through the Local Plan process. Last year we strengthened Green Belt policy in the revised NPPF” You have chosen to accept the government’s housing need for Tunbridge Wells borough based on the standard method of calculation. You know that the ONS 2016 figures show a smaller housing need and that policy will reflect that in due course. You can protect this borough from the destruction of Green Belt and AONB by following NPPF guidelines, but this plan shows no interest in doing so, and in fact is planning for even more housing than your interpretation of the 2014 figures requires. For example, you could save the MGB land at East Capel (Policy AL / CA 3 & AL / PW 1) by choosing a different development option that would require 1,000 fewer houses. Paragraph 11 of the NPPF (revised in 2019) states: “11. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
Paragraphs 11(b)(i) and (ii) are of crucial importance. They provide for TWBC to have a choice in the provision of the objectively assessed 13,560 houses. If provision of these houses is really only possible by sacrificing Green Belt land, as TWBC concede at paragraph of the Non-Technical Summary of their Sustainability Appraisal, then the NPPF makes it perfectly possible for TWBC to say that this is not achievable. TWBC have chosen not to do so. Capel Parish Council calls for a reduction in the number of houses to be delivered by the Local Plan. | ||||||||||||||||
DLP_3664 | Capel Parish Council | Object You are proposing a development strategy based on dispersed growth, i.e. proportional distribution of development across all of the borough’s settlements. You imply that you have achieved this, but this is misleading. The Local Plan is almost entirely dependent on the successful implementation of proposed garden settlement in Tudeley (AL / CA 1) and the expansion of Paddock Wood including building on East Capel (AL / CA 3 & AL / PW 1). They form 63% of the new housing. If these sites fail to deliver, then the associated infrastructure that is entirely reliant on developer capital would also never be realised. This appears to stack risk on risk, where both areas of development are inextricably linked and the failure of one would lead to collapse of the other and as a result the whole plan would fail. You refer to Tudeley Village securing a long term option for the borough to deliver the needs of future generations. It is clear from this statement that you intend to add more and more housing to this “garden settlement” in each five year review of future Local Plans. Capel Parish Council are seriously concerned that this will be the first step in the longer term destruction of the entire MGB in this part of the Borough. It deserves to be protected and sheltered from development. A garden settlement, should there be one, would be best in the middle of the borough, to make it accessible north and south. It is totally counterproductive to put affordable housing right at the very north of the borough when so many residents live in the south. Put it in the middle of the borough or spread it right across the borough. The developments in Tudeley and East Capel are unsustainable, having a poor road infrastructure and this doing nothing for local employment needs (it will make many local farm workers redundant). It would also put an unfair burden on the residents of Tonbridge and Malling whose infrastructure the new residents will access. ‘The ‘master planning approach’ will come to a grinding halt at the boundaries of Tonbridge, a town whose infrastructure has grown slowly over the last millennium and can hardly be expected to adjust to this challenge imposed on it by the planners of the neighbouring authority. We expect this view to be reflected by TMBC in their response to the regulation 18 consultation. | ||||||||||||||||
DLP_4232 | Rother District Council | It is welcomed that the proposed Development Strategy indicates how the full development needs of the borough can be most appropriately met. | ||||||||||||||||
DLP_4233 | Rother District Council | General comment It is noted that TWBC does not propose to meet any unmet housing need from Rother. At the time of the Core Strategy, there was a shortfall in Rother of 480 dwellings over the period 2011-2028. Most of the demand stemmed from in-migration from the greater London area. Given that this information is now somewhat dated and that my Council is, in conjunction with Hastings Borough Council, in the process of undertaking a new Housing and Employment Development Needs Assessment for its respective forthcoming Local Plan Reviews, it would not seem timely or reasonable, at this juncture to expect the current TWBDLP to make provision for further housing to meet any unmet need from Rother district. | ||||||||||||||||
DLP_4395 | Mill Lane and Cramptons Residents Association | COMMENT – OBJECT INAPPROPRIATE SCALE OF DEVELOPMENT The scale of new housing planned for Sissinghurst is out of proportion. This represents a huge increase in households on the current number of households. This cannot be absorbed or integrated satisfactorily. There is also added pressure on the school, services etc plus the extra car journeys generated. As TWBC Cllr McDermott allegedly reported to the Cranbrook Parish Council meeting in August 2019 the housing numbers for Cranbrook and Sissinghurst are arbitrarily based on the number of sites which came forward under “The Call for Sites” process. He said that if no landowner had put forward sites very little housing would be allocated ! TWBC can hardly claim that this is a scientific needs based process on what Sissinghurst need in housing terms. | ||||||||||||||||
DLP_4403 | Mill Lane and Cramptons Residents Association | CULTURE: There is no mention of the significance of Sissinghurst Castle or the 3 Conservation Areas of Cranbrook, Sissinghurst and Wilsley Green. Nor is there any recognition of the many festivals and events that contribute to the character of the Weald (e.g. Apple Day, Nuts in May, Britain in Bloom etc) and which attract locals and visitors alike. | ||||||||||||||||
DLP_4604 | Keith Stockman | TWBC: the following comment was submitted by the responders on the left: 4.18 The ENS (Economic Needs Study) recommended that the Council should allocate sites to accommodate at least 14 hectares of new employment land (taking into account any residual capacity of existing employment allocations) to 2035 in order to support the creation of new employment opportunities alongside the provision of new housing, helping to reduce outcommuting from the borough over the plan period. This target will be reviewed as part of the preparation of the Regulation 19 Pre-submission version of the Local Plan There are no new employment opportunities planned alongside the provision of new housing in Cranbrook and Sissinghurst. The only employment created, will be temporary, and only during construction of the allocated sites. | ||||||||||||||||
DLP_4644 | Ann & John Furminger | local research from the NDP group indicates that the parishioners are against large scale development. According to the NPPF there should be no large scale development on AONB unless exceptional need is proven, which is not in the parish of Cranbrook and Sissinghurst. | ||||||||||||||||
DLP_4648 | Ann & John Furminger | There are no new employment opportunities planned alongside the provision of new housing in Cranbrook and Sissinghurst. The only employment created will be temporary, and only during the construction phase. The areas sighted as employment growth are mainly in the T Wells area and travel to those areas will only generate yet more traffic on already overused roads eg Goudhurst, Hawkhurst | ||||||||||||||||
DLP_4654 | CBRE Ltd for Dandara Ltd | Growth Options 3.20 The Draft Local Plan assesses five growth options as part of formulating the preferred Development Strategy:
3.21 Based on the 2017 Options Consultation, TWBC recognises that a combination of two or more of the options presented could form the preferred strategy to meet the identified growth required through the new Local Plan. 3.22 TWBC is promoting ‘Option 3’ ‘dispersed growth’ to include site allocations for new housing located at the majority of existing settlements, and ‘Option 5’ a new ‘stand-alone’ garden settlement (Tudeley Village) and the transformational expansion of an existing settlement, using garden settlement principles. 3.23 Option 3 includes the comprehensive expansion of the settlement of Paddock Wood (including land within Capel parish) following garden settlement principles. 3.24 The employment growth needs of the borough are met by a development strategy based on a combination of Option 1 (focused growth), Option 2 (semi-dispersed growth), and Option 4 (growth corridor-led approach). 3.25 Dandara supports the principle of the preferred Development Strategy, which focuses on infrastructure-led development while also addressing the identified OAN. Dandara supports the comprehensive expansion of the settlement of Paddock Wood (including land within Capel parish) as this area is considered to be suitable to support significant growth. Dandara further supports the need for dispersed planned growth through a range of site allocations for deliverable sites that can deliver new homes and be accommodated on the basis that they benefit from the support of existing infrastructure. 3.26 Dandara emphasises the importance of sustainable growth. As set out in these written representations, Dandara is supporting a series of sites which are proposed to be included as allocations for housing delivery. These sites are all allocated for new housing in the emerging Local Plan and are importantly all suitable, available and deliverable in either the short or short to medium term. 3.27 Dandara recognises that planning for strategic scale growth has the potential to make a significant contribution to meeting identified development needs. It is, however, recognised that such strategic growth is reliant on the nature and timing of infrastructure investment which typically has a long lead in period, with new homes inevitably being delivered later in the Council’s trajectory. 3.28 In respect to the expansion at Paddock Wood (AL/PW1) and housing delivery at this site, Dandara is concerned that TWBC’s housing trajectory seeks to deliver a high volume of homes (circa 333 homes per annum) relatively early in the Plan period (commencing from 2024/25 onwards until 2035/36). Whilst Dandara supports early delivery at homes at Paddock Wood, they are concerned that the annual delivery of homes forecast is consistently high. Dandara therefore suggests that in the interests of ensuring housing delivery is achievable and realistic, it would be prudent for TWBC to adopt a higher buffer to plan for any delays or underperforming years in their housing trajectory, as part of ensuring they can demonstrate a 5YHLS position. 3.29 As set out in these written representations, Dandara raises concern about the timescales of deliverability of the new garden settlement of Tudeley Village and are cautious of the reliance on this in delivering new housing within the Plan period. Tudeley Village would form an isolated ‘garden village’ and would be reliant on significant infrastructure investment to bring the site forward, as well as resolving other development challenges a scheme of this nature will likely face. 3.30 The suitability and robustness of the Tudeley Village site allocation will depend on (inter alia) reasonable confidence that the required infrastructure investment is feasible and realistic, and importantly is capable of being delivered within reasonable timescales for the Council to rely on it as part of their housing strategy and trajectory. More significantly, however, Dandara is keen to ensure the robustness of the Paddock Wood expansion by structuring this allocation such that it is not reliant on Tudeley Village for the delivery of infrastructure. The proposed allocations may need to be considered in combination, however, both allocations should be deliverable in their own right and provide all infrastructure to meets their own needs. 3.31 In order for the Plan to be robust and satisfy the appropriate policy tests to be found sound, consideration should be given to the appropriate allowance for any possible delays in housing delivery, particularly in relation to large scale strategic sites dependent upon new infrastructure to facilitate growth. 3.32 Dandara supports the approach within the Plan towards supporting more sustainable locations and concentrating growth at existing settlements, through providing urban extensions to existing settlements that benefit from a sustainable location, existing transport links and other social infrastructure, and where new growth can enhance the existing economy. Furthermore, urban extensions allow settlements to develop more organically, and typically have infrastructure capacity (which may be capable of being increased) to support sustainable new growth. 3.33 Dandara supports the allocation of the sites and planned growth at Paddock Wood, Spratsbrook Farm, Sissinghurst and Hawkhurst as part of TWBC’s growth strategy. New development in all these locations would constitute sustainable growth and combined would deliver much need housing and economic growth, whilst taking advantage of good existing infrastructure. 3.34 Accordingly, Dandara suggests TWBC should review their housing trajectory and adjust the strategy to facilitate early delivery of new homes on allocated sites wherever possible, whilst ensuring a robust position to allow for delays in strategic allocations which may require the identification of further sources of supply. 3.35 Dandara supports the overall ambitions of the Regulation 18 Local Plan in terms of responding to the scale of housing growth that needs to be accommodated within the Plan period. [TWBC: see full representation]. | ||||||||||||||||
DLP_4880 | Berkeley Strategic Land Ltd | THE DEVELOPMENT STRATEGY & STRATEGIC POLICIES * Option 1: Focused Growth: Development distribution focused as per existing Core Strategy, i.e. majority of new development directed to Royal Tunbridge Wells/Southborough, a smaller proportion to the other three main settlements of Paddock Wood, Cranbrook and Hawkhurst and limited development within the villages and rural areas. * Option 3: Dispersed Growth: Development distribution proportional across all of the borough's settlements. 4.4. The Council have outlined within the Plan at paragraph 4.38 that their proposed strategy will be a combination of Option 3 and Option 5, being dispersed growth and new settlement growth.
4.7. Although the Council are proposing to allocate housing sites that will deliver above their need we still feel there is a disproportionate split across key settlements. Based on a rough percentage split this distribution of development is set out below;
4.8. It is clear from the above evidence that the distribution of development is not evenly dispersed or proportionate to the scale of settlement as is proposed by the Council within Option 3. As such the housing provision split is not consistent with Option 3 despite being the selected option. 4.13. The smaller settlements further down the hierarchy are smaller in size, less sustainable and more constrained meaning they are not capable of delivering and supporting the same level of development as settlements that are positioned in the top tiers of the settlement groupings.
4.15. As noted above Royal Tunbridge Wells is the Primary Regional Town Centre within the Borough making it the most sustainable, however only 15% of new housing allocations have been designated to Royal Tunbridge Wells. It is our view that additional housing sites will be required due to the unsuitability and overreliance of other proposed housing allocations. The obvious rebalance of new growth is to allocate further land within Royal Tunbridge Wells. 4.25 From our own experience in dealing with major strategic sites Berkeley have produced an updated trajectory for Tudeley Garden Village, which we believe is a closer estimate to the likely build out rate for the scheme. | ||||||||||||||||
DLP_5018 | Kelli O'Brien | I am hugely concerned about the 'balance' between urban and rural life on the Weald that will be affected by increases in its population, and that the Local Plan does not appear to take this into account. What I mean by 'balance' are things: like the amount of traffic on rural roads that are widely recognised (including by the DVLA) as those which have a significantly higher likelihood of accidents; increased driving on rural roads is compensated by less traffic, but this is increasingly not the case with new development; rural noises of farming equipment and rural 'smells' are compensated by views of the countryside, which are increasing being lost to new development. Also, the Weald is comprised of interdependent townships and particularly given the proximity of them, each and every development impacts all villages and this does not appear to have been taken into account in the Local Plan. Please could the Plan include some consideration of these factors and, in particular, take a more holistic approach to the Weald, understanding the interconnectedness of the way in which all of its residents depend and use facilities in each village and town, irrespective of which village or town in which they actually live. Please can we also think about sustainable housing and wellbeing for residents including such things as safe pavements for all residents of towns and villages to walk to the town centre and connecting each village and town to the other with cycle paths for walking and riding. | ||||||||||||||||
DLP_5057 | Mrs Rosie Bishop | The calculation of the housing need target seems to be flawed: the method is opaque, but the base figure is derived from 2014 official figures for housing needs, which have been reduced in the 2016 figures. “the Government has indicated that it will be reviewing the methodology in the next eighteen months, but this has yet to be determined. This is because the current methodology relies on dated, 2014- based projections, instead of newer projections.” Nevertheless, the housing need target seems to be the driving influence in the DLP and has resulted in proposals for major development within the AONB and Green belt areas | ||||||||||||||||
DLP_5232 | Tunbridge Wells Friends of the Earth | The Development Strategy - Introduction 4.3 No mention is made of the landscape, heritage and water provision constraints on development which may well inhibit full provision of the development needs of the Borough as defined by central government. We maintain that TWBC should refuse to accept the level of development that is proposed by central government due to the constraints posed as set out above (comments on §2.40 and §2.44). Housing development 4.7 - §4.9 We would urge TWBC to follow Sevenoaks’ example and refuse to build the number of houses demanded by central government so as to protect the Green Belt, SSSI, AONB, etc. Instead, we would ask for a recalculation of truly local needs and an active search for brownfield land as a first option for development. Infrastructure and other supporting uses 4.26 and §4.27 We are concerned that the resources needed to give effect to the Infrastructure Delivery Plan’s objectives will not become available in time to mitigate problems arising from the planned development in the Borough. This particularly applies to the required development of a coherent network of active travel routes in Royal Tunbridge Wells and between settlements in the Borough. Preferred Option, Site submissions, Development Strategy for consultation 4.28 - §4.40 We consider it regrettable that a planning policy system based on a call for sites from interested landowners will not necessarily result in optimal selection of land suitable for development. We have nonetheless welcomed consultation and information workshops and meetings with TWBC Planning Policy Officers. 4.40 We propose TWBC refuses to meet the target of some 13,560 new homes in the borough over the 2016-2036 period, and we oppose to any potential loss of Green Belt land and further development in the High Weald AONB. | ||||||||||||||||
DLP_5305 | Judith Ashton Associates for Redrow Homes Ltd and Persimmon Homes South East | I write with reference to the above. I act for both Redrow Homes Limited and Persimmon Homes South East who have various interests in Tunbridge Wells, including those east and south east of Paddock Wood (SHLAA sites ‘20’, ‘374’, ‘371’, ‘344’ and ‘376’), (LPA sites PW 1_7, 1_9, 1_11 and 1_12), (parcels 7, 9, 11 and 12). Whilst, having regard to the above, Redrow and Persimmon both support the Reg 18 Plan in principle, especially the proposed allocation of the land at Paddock Wood (policies STR/PW1 and AL/PW1), they do have specific concerns about certain aspects of policies STR/PW1 and AL/PW1 and the evidence base underpinning the plan. The Housing Requirement, Supply and Trajectory. a) The Requirement Table 1 of the Reg 18 Plan identifies the housing need for the period 2016 – 2036 to be 13,560 dwellings (678dpa). This is said to be based upon the standard methodology (2014 based household projections (published July 2016)), projected household growth in Tunbridge Wells for the period 2019-2029 and the affordability ratios published in April 2019. Whilst we believe the figure to be 682dpa, we note para 3.2.1 of the Housing Topic Paper (HTP) suggests the figure of 678 is being used as it is based upon submission in 2020. This being the case the plan when submitted needs to be clear on this point and all associated calculations clarified accordingly. We also believe, for the reasons set out below, that the plan period should also be amended and start in 2020 not 2016 as drafted. b). Whether the plan should provide for more than the minimum local housing need figure The plan should, given ID: 2a-010-20190220 of PPG, consider whether it might be appropriate to plan for a higher housing need figure than the standard method indicates given issues such as local affordability. The housing needs survey 2018 identifies a net affordable housing need of 443dpa. As policy H5 looks to deliver 40% affordable provision on all greenfield sites of 9 (+) dwellings, and acknowledging that not all sites provide affordable housing, in order to meet 100% of the affordable requirement one would conservatively need to deliver circa 1,107 dpa over the plan period. This is clearly significantly greater than the figure generated by the standard method, (678/682dpa) and whilst the standard method takes into account affordability issues, this does beg the question as to whether TWBC need to consider whether it might be appropriate to plan for a higher housing need figure than the standard method indicates. If nothing else the SA should in our opinion assess this point. In the context of the above we also note that the figure of 678/682dpa is the minimum local housing need figure. It is capped at 40%. The uncapped figure is in fact 762dpa [1 Based on (1) 10-year household growth 2020-2030 in the 2014-based projections of 4,915/491.5 per annum; (2) Median workplace-based affordability ratio of 12.76 (in 2018) giving an uplift of 55% (12.76-4/4 x 0.25 +1 = 1.55) (1.55 x 491.5 = 761.83) = 762dpa uncapped]. This figure would better be described as the actual housing need, with 678/682dpa simply being the minimum Local Housing Need figure defined by the standard method. Again, given the scale of the affordable housing need the HTP and the SA should in our opinion consider the issue of the plan providing for more than the minimum local housing need figure. Finally, having regard to the issues around the Duty to Cooperate, there is the issue of Sevenoaks District Councils (SDC’s) unmet need. Whilst we note that the SA does consider a growth option that encompasses SDC’s unmet need (option 7 – see below), para 6.2.2 of the SA appears to dismiss this option on the basis that it was assumed that the additional 1,900 dwellings would essentially be located within the AONB. It is not clear how this conclusion has been reached. In addition there is nothing that allows one to undertake a like for like comparison of the SA findings on option 7 (as set out in table 14) against the options considered in the earlier SA and the chosen option – such that the rational for this decision does in our opinion require further clarification. c). The Plan Period The Government’s Planning Practice Guidance (ID: 2a-004-20190220) indicates that when setting the baseline, the projected average annual household growth over a 10 year period should be calculated and that “this should be 10 consecutive years, with the current year being used as the starting point from which to calculate growth over that period”. Thus, the plan period should start at 2020 if it is to address the OAHN identified by the Standard Method of 678 (2020-2030) rather than 682 (2019-2029). d). Supply and Trajectory Whilst not commenting upon the supply in detail, in noting the findings of the HTP on housing delivery and the phasing methodology, we are concerned that the majority of the evidence base concentrates on the period from the grant of planning permission to first completion’s and both peak and average build out rates. Little is said about the time taken to prepare and submit planning applications or the length of the determination period; both of which are crucial to the councils proposed trajectory. To whit we note that table 9 of the HTP suggests that AL/PW1 will be delivering 333dpa from 2024/25, i.e. circa 5 years from now. As the western part of the AL/PW1 allocation includes land within the Green Belt, where land can only be released once allocated for development, and where developers will thus be unlikely to progress applications to any great degree until the plans strategy is relatively safe, it is clear that to facilitate deliveries in 2024/25 the council will need to look to those promoting the land beyond the Green Belt to progress applications in tandem with the plan, if the trajectory is to be met. We say this as both the Letwin Review (2018) and Lichfields Start to Finish: How Quickly do Large Scale Housing Sites Deliver (2016) suggests lead in times for the submission and determination of applications for sites in excess of 2,000 dwellings is such that work on the component parts of the proposed AL/PW1 allocation needs to commence soon if the council’s trajectory is to be met. To this end we support policy H2 and multi developer delivery of the strategic sites as this will enable a number of smaller applications to be made thus speeding up delivery. To this end we have suggested when commenting upon policies STR3, STR/PW1 and AL/PW1 that there is no reason why a Framework Plan (rather than a Masterplan), cannot provide for the separate masterplanning and delivery of the areas to the east and west of Paddock Wood. The Framework Plan can demonstrate graphically how the requirements of policies STR/PW1 and AL/PW1 for housing, employment, schools, medical facilities and open space etc, and associated connections, can be delivered in general land use planning term; whilst a separate Strategic Infrastructure Plan can identify who is providing what, and when; and where projects such as highway improvements / drainage works are to be funded jointly, who is paying for what and when it has to be provided. In the context of the above, in progressing the land to the east of Paddock Wood, I can advise that at Persimmon would look to submit a hybrid planning application in autumn 2021. This will however be dependent on TWBC having an approved Framework Plan/ Strategic Infrastructure Plan. Assuming, from past experience that a resolution to grant takes 12 months, and that it takes a further 9 months for the S106 to be agreed, they would anticipate a planning consent in summer 2023. They would then be taking first legal completions from summer 2024 and would deliver 20 completions in 2024. Thereafter output would be 50 / 55 completions per annum including affordable. [2 Persimmon are currently struggling to reach 50 completions per year in Paddock Wood] . Similarly, Redrow would also look to submit a Hybrid planning application in autumn 2021, to achieve a consent in summer 2023 and to be taking first legal completions from summer 2024. Again, they would deliver 20 completions in 2024 and achieve output rates of circa 50 / 55 completions per annum including affordable thereafter. So, both developers combined could, in the area east of Paddock Wood, deliver circa 40 completions in 2024 and 100 -110 completions per annum including affordable thereafter. Given the above, whilst we acknowledge that on strategic sites such as AL/PW1 there will be multiple sites with multiple outlets, and that at Paddock Wood there are likely to be at least 2 further developers with outlets on the land to the west of Paddock Wood, thus providing for a greater range and choice of product; we would question whether Al/PW1 will be able to deliver 300 (+) dpa. Rather we consider that Paddock Wood will deliver circa 250 - 300dpa, and that there will be a gradual increase from 50-100dpa in yr. 1 to 200 dpa in yr. 2 and then 250 – 300dpa thereafter, such that the trajectory may in our opinion need to be reviewed in this regard. e). Gypsies and Travellers We note that whilst policy H13 of the Reg 18 plan does not explicitly identify a need to accommodate Gypsies and Travellers on the Paddock Wood sites, para 6.5.18 of the HTP suggests that there is a requirement for 3 additional pitches in the borough over the plan period and that these could be met at Paddock Wood. To avoid confusion either the HTP needs amending when issued at Reg 19 or policy H13 needs to be explicit and the implications on the proposed allocations taken into account in the Viability Appraisal. Duty to Cooperate Having reviewed the interim Duty to Cooperate Statement we note that housing is seen as a cross boundary strategic issue and that a Statement of Common Ground (SoCG) has already been signed with both Maidstone Borough Council (MBC) and Sevenoaks District Council (SDC) that look to address this issue, amongst others. In noting the above we also note that the SoCG with MBC is dated August 2016 and that with SDC is dated May 2019. We also note that the SoCG with SDC advises at paras 2.18. and 2.19 that: 2.1.8 It is understood that, at present, TWBC is unable to assist SDB with unmet housing need, due to the constraints on both local authorities, and their inability to meet housing needs beyond their own, irrespective of unmet needs elsewhere. 2.1.9 Consequently, both councils will continue to work together and identify the position as both TWBC and SDC prepare to review their Local Plan every 5 years. Actions
As the Borough Council will be aware, the Duty to Cooperate places a legal duty on local planning authorities to engage constructively, actively and on an ongoing basis to maximise the effectiveness of Local Plan preparation in the context of strategic cross boundary matters. We do not believe, given the above, that the SoCG with MBC and SDC can be seen as demonstrating active and ongoing engagement at this stage of the plan making process – we would expect there to be a rolling program of engagement to address matters as they arise through the consultation on the Reg 18 and Reg 19 plan. Thus, the SoCG would need to be updated accordingly. In addition to the above, we are mindful of the recent correspondence between SDC and their Inspector, especially documents ED37 and ED40. It is clear from the latter that the Inspector did not accept that reliance on a review of the Plan to address the issue of SDC’s unmet need was appropriate or complied with the duty, which applies specifically to plan preparation, which as the Borough Council are aware ends when the plan is submitted for Examination. Thus, this issue needs to be thoroughly examined and addressed in the SoCG that are submitted prior to submission of the Plan. Which means TWBC need to liaise with SDC about where they now are with this issue and the TWLP needs to clearly demonstrate why it cannot, if that is the case, help address SDC’s unmet need. Turning to the position with Tonbridge and Malling Borough Council (TMBC) it is clear, as is acknowledged in para 45 of the DtC paper that the proposed distribution of development in the TWLP will have a potential impact on parts of TMBC and that the two councils need to work closely with one another when it comes to infrastructure delivery associated with the proposals for development at Tudeley and Capel/Paddock Wood. To this end we would suggest that TWBC need to make available a working draft SoCG with TMBC as soon as is possible – this can, like the other draft SoCG be a life document that continues to be updated until such time as it is signed off prior to submission of the plan. In the context of the above we note that the first bullet point of criterion 1 of policy STR/PW1 (Masterplanning and Delivery) refers to the need for a strategic masterplan for the provision of infrastructure for the strategic expansion of Paddock Wood to require input from Tonbridge & Malling and Maidstone Borough Councils where it impacts on Tonbridge town centre and land to the north of Tunbridge Wells borough. This clearly requires TWBC to agree a strategy with the neighbouring authorities through the DtC. As there is no evidence within the background document to suggest that this has happened to date we would stress the need for said discussions to take place as a matter of urgency so as to facilitate the delivery of the strategic allocation at Paddock Wood and fulfil the requirements of the DtC. Finally, we note that whilst the draft Infrastructure Delivery Plan refers to LEP funding in places, especially to assist with transport infrastructure works, the interim Duty to Cooperate Statement does not appear to encompass any DtC discussions with the LEP. This is a mater we believe needs to be addressed in the next iteration of the interim Duty to Cooperate Statement. [TWBC: see full representation]. | ||||||||||||||||
DLP_5529 | Mr Paul Hewitt | 4.19 In particular, the ENS recommended that expansion of the existing Key Employment Areas would be appropriate, at North Farm/Longfield Road in Royal Tunbridge Wells, around Maidstone Road in Paddock Wood, and at Gill's Green. Additionally, it recognised the area around the A21 highway improvements as a location for significant employment growth potential, subject to further investment. The importance of Royal Tunbridge Wells town centre is also recognised in terms of existing and future office provision, and the requirement to retain existing, well located, modern office stock within the centre. If the ENS is indicating the expansion of existing key employment areas as above, why is such a large proportion of housing being targeted in Cranbrook and Sissinghurst? | ||||||||||||||||
DLP_5532 | Mr Paul Hewitt | 4.40 Sustainable development of an appropriate scale at the smaller settlements to provide opportunities at the local level to meet housing needs and sustain local services and infrastructure, as well as the support for new local facilities where required, and at all times being aware that such development is taking place on valued and (in many cases) protected landscapes. Local research from the NDP group indicates that the parishioners are against large scale development There should be no large-scale development unless exceptional need is proven, which it is not in the Parish of Cranbrook and Sissinghurst Development proposed in Cranbrook and Sissinghurst is not sustainable in terms of infrastructure and nor is it ‘aware of the valued and protected landscape.’ There is absolutely no need to put large-scale development on AONB when NDP research has shown that the housing numbers can be delivered more sensitively and appropriately in small scale, sustainably designed developments that do not impact the AONB landscape in the same way that large estates do | ||||||||||||||||
DLP_5534 | Mr Paul Hewitt | national policy allows for development to be reduced where valued landscapes can be damaged (NPPF, Paragraph 11). Why has TWBC not pushed back about housing numbers when 70% of the Borough is AONB? Is it because of the income generated for ‘projects’ by development? 62% of the Parish of Sissinghurst and Cranbrook is AONB, yet the large-scale developments being proposed are all on AONB. | ||||||||||||||||
DLP_5536 | Mr Paul Hewitt | 4.7 Based on submission of the Local Plan in 2020, the objectively assessed housing need for the borough over the plan period to 2036 is confirmed as 13,560 dwellings (678 per year), identified by the standard methodology as required by the NPPF(20) Houses are needed in the Parish of Cranbrook and Sissinghurst. An independent provider of professional support services has been used to arrive at a figure for housing in the Parish which is a bit less and can be delivered by small scale housing developments and yet this research commissioned by the NDP, has been ignored by TWBC | ||||||||||||||||
DLP_5540 | Mr Paul Hewitt | 4.40 Sustainable development of an appropriate scale at the smaller settlements to provide opportunities at the local level to meet housing needs and sustain local services and infrastructure, as well as the support for new local facilities where required, and at all times being aware that such development is taking place on valued and (in many cases) protected landscapes. The above statement is belied by the following statement 4.69 The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. | ||||||||||||||||
DLP_5541 | Mr Paul Hewitt | 4.60 As identified within the Sevenoaks and Tunbridge Wells Economic Needs Study (2016), 50% of residents in the Tunbridge Wells borough commute out of the borough to work (2011 census data). Why then are so many houses being built so far from major settlements and train stations? e.g. Maidstone: 14 miles, Tunbridge Wells 14 miles, Hastings 18 miles, Ashford 18 miles Staplehurst Station, 6 miles (car park full at peak), Marden Station 8.6 miles (car park full at peak) Whilst significant traffic jams are regularly created at Hawkhurst, Goudhurst and Flimwell when people are trying to leave the Parish of Cranbrook during peak work times. This is not infrastructure led development. | ||||||||||||||||
DLP_5542 | Mr Paul Hewitt | 4.80 Limits to Built Development (LBDs) are used to differentiate between the built-up areas of settlements and areas of countryside beyond. Generally, and subject to compliance with other policies in this Plan, there will be a presumption that proposed development such as infilling, redevelopment, and/or changes of use will be acceptable inside the LBD, while land and buildings outside the LBD will be considered as countryside where there is much stricter control over development. If the above statement is a policy, then the LBD of Cranbrook and Sissinghurst should NOT be re-drawn. Already, the largest development in the Parish for at least 40 years, has been allocated adjacent to the LBD and therefore justified. The proposal to re-draw the LBD to enclose this development then allows the next largest site to be bought forward using the same justification, against the wishes of the local residents 4.87 Although very close to the LBD boundary, the site at Turnden Farm, Hartley Road, to the south west of Cranbrook has also been excluded at this stage. However, it is anticipated that these sites will be reviewed and refined for the next stage of the Local Plan. | ||||||||||||||||
DLP_5546 | Mr Paul Hewitt | 4.64 A key aim of the Draft Local Plan is to plan for comprehensive development to a high standard in terms of design and place shaping. Little attention has been paid, thus far to high standards of design and place shaping in Cranbrook and Sissinghurst. Developments just completed or nearing Outline and Detailed applications, are a poor pastiche of local vernacular, with cost being an excuse for shoddy design and a top down approach to planning design. I have no confidence that the planning department will enforce high standards, or indeed listen to the community in this respect. | ||||||||||||||||
DLP_5547 | Mr Paul Hewitt | 4.65 Sustainable design principles make efficient use of resources through location, design, positioning, specification, and sourcing of materials, as well as improving the quality of developments and enhancing their environmental performance. The Council will encourage new development to incorporate current best practice in sustainable design and construction, incorporate mitigation and adaptation measures against the future impacts of climate change, and deliver high quality developments. Public art and active spaces will be encouraged as part of good design and place shaping to help foster a sense of place and community coherence. This is so far from what is happening in Cranbrook and Sissinghurst (which has its own design code) that I find it hard to believe that this will be enforced in any meaningful way. Developers have stated that they build to TWBC building standards and that solar panels are not economical. Lip service is paid to sustainability and adaptation to climate change with the installation of water butts and apparently very little else | ||||||||||||||||
DLP_5549 | Mr Paul Hewitt | 4.60 As identified within the Sevenoaks and Tunbridge Wells Economic Needs Study (2016), 50% of residents in the Tunbridge Wells borough commute out of the borough to work (2011 census data). It therefore follows from the above statement that 50% of the residents of new homes in Cranbrook and Sissinghurst will get into a car to commute out of the Borough to work. This cannot be sustainable. In addition, a further percentage will get into a car to leave the Parish for work again this is not sustainable The Parish has undertaken a Housing Needs Assessment which has shown how many houses need to be built to accommodate the people that live, or aspire to live in the Parish. Why is this not taken into account? | ||||||||||||||||
DLP_5553 | Mr Paul Hewitt | 4.59 In accordance with the NPPF, this Draft Local Plan will aim to facilitate all forms of sustainable transport, ranging from active travel (such as walking or cycling), public transport, car share, car club, ultra-low emission vehicles such as electric vehicles and charging points, or any provisions that arise through new technology over the course of the plan period. This should be done in all instances to reduce private car dependence in the borough where it is both feasible in relation to local circumstances, Whilst the facilitation of sustainable transport is to be applauded, building so far away from the proposed centres where employment will be targeted cannot possibly reduce private car dependence | ||||||||||||||||
DLP_5565 | Mr Paul Hewitt | 4.44 To achieve the strategic objectives of this Draft Local Plan, it is essential for development to be planned in a coordinated way and, for some of the strategic sites and locations, it will be appropriate to deliver this through a comprehensive Masterplanning process When Brick Kiln Farm in Cranbrook was allocated, the developer was told to take a Masterplanning approach. This has not happened. I have no confidence that this approach will be enforced by the Planning Department | ||||||||||||||||
DLP_5583 | Mrs Jacqueline Hewitt | 4.19 In particular, the ENS recommended that expansion of the existing Key Employment Areas would be appropriate, at North Farm/Longfield Road in Royal Tunbridge Wells, around Maidstone Road in Paddock Wood, and at Gill's Green. Additionally, it recognised the area around the A21 highway improvements as a location for significant employment growth potential, subject to further investment. The importance of Royal Tunbridge Wells town centre is also recognised in terms of existing and future office provision, and the requirement to retain existing, well located, modern office stock within the centre. If the ENS is indicating the expansion of existing key employment areas as above, why is such a large proportion of housing being targeted in Cranbrook and Sissinghurst? | ||||||||||||||||
DLP_5584 | Mrs Jacqueline Hewitt | 4.40 Sustainable development of an appropriate scale at the smaller settlements to provide opportunities at the local level to meet housing needs and sustain local services and infrastructure, as well as the support for new local facilities where required, and at all times being aware that such development is taking place on valued and (in many cases) protected landscapes. Local research from the NDP group indicates that the parishioners are against large scale development There should be no large-scale development unless exceptional need is proven, which it is not in the Parish of Cranbrook and Sissinghurst Development proposed in Cranbrook and Sissinghurst is not sustainable in terms of infrastructure and nor is it ‘aware of the valued and protected landscape.’ There is absolutely no need to put large-scale development on AONB when NDP research has shown that the housing numbers can be delivered more sensitively and appropriately in small scale, sustainably designed developments that do not impact the AONB landscape in the same way that large estates do | ||||||||||||||||
DLP_5585 | Mrs Jacqueline Hewitt | national policy allows for development to be reduced where valued landscapes can be damaged (NPPF, Paragraph 11). Why has TWBC not pushed back about housing numbers when 70% of the Borough is AONB? Is it because of the income generated for ‘projects’ by development? 62% of the Parish of Sissinghurst and Cranbrook is AONB, yet the large-scale developments being proposed are all on AONB. | ||||||||||||||||
DLP_5588 | Mrs Jacqueline Hewitt | 4.7 Based on submission of the Local Plan in 2020, the objectively assessed housing need for the borough over the plan period to 2036 is confirmed as 13,560 dwellings (678 per year), identified by the standard methodology as required by the NPPF(20) Houses are needed in the Parish of Cranbrook and Sissinghurst. An independent provider of professional support services has been used to arrive at a figure for housing in the Parish which is a bit less and can be delivered by small scale housing developments and yet this research commissioned by the NDP, has been ignored by TWBC | ||||||||||||||||
DLP_5590 | Mrs Jacqueline Hewitt | 4.40 Sustainable development of an appropriate scale at the smaller settlements to provide opportunities at the local level to meet housing needs and sustain local services and infrastructure, as well as the support for new local facilities where required, and at all times being aware that such development is taking place on valued and (in many cases) protected landscapes. The above statement is belied by the following statement 4.69 The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. | ||||||||||||||||
DLP_5592 | Mrs Jacqueline Hewitt | 4.60 As identified within the Sevenoaks and Tunbridge Wells Economic Needs Study (2016), 50% of residents in the Tunbridge Wells borough commute out of the borough to work (2011 census data). Why then are so many houses being built so far from major settlements and train stations? e.g. Maidstone: 14 miles, Tunbridge Wells 14 miles, Hastings 18 miles, Ashford 18 miles Staplehurst Station, 6 miles (car park full at peak), Marden Station 8.6 miles (car park full at peak) Whilst significant traffic jams are regularly created at Hawkhurst, Goudhurst and Flimwell when people are trying to leave the Parish of Cranbrook during peak work times. This is not infrastructure led development. | ||||||||||||||||
DLP_5594 | Mrs Jacqueline Hewitt | 4.80 Limits to Built Development (LBDs) are used to differentiate between the built-up areas of settlements and areas of countryside beyond. Generally, and subject to compliance with other policies in this Plan, there will be a presumption that proposed development such as infilling, redevelopment, and/or changes of use will be acceptable inside the LBD, while land and buildings outside the LBD will be considered as countryside where there is much stricter control over development. If the above statement is a policy, then the LBD of Cranbrook and Sissinghurst should NOT be re-drawn. Already, the largest development in the Parish for at least 40 years, has been allocated adjacent to the LBD and therefore justified. The proposal to re-draw the LBD to enclose this development then allows the next largest site to be bought forward using the same justification, against the wishes of the local residents 4.87 Although very close to the LBD boundary, the site at Turnden Farm, Hartley Road, to the south west of Cranbrook has also been excluded at this stage. However, it is anticipated that these sites will be reviewed and refined for the next stage of the Local Plan. | ||||||||||||||||
DLP_5596 | Mrs Jacqueline Hewitt | 4.64 A key aim of the Draft Local Plan is to plan for comprehensive development to a high standard in terms of design and place shaping. Little attention has been paid, thus far to high standards of design and place shaping in Cranbrook and Sissinghurst. Developments just completed or nearing Outline and Detailed applications, are a poor pastiche of local vernacular, with cost being an excuse for shoddy design and a top down approach to planning design. I have no confidence that the planning department will enforce high standards, or indeed listen to the community in this respect. | ||||||||||||||||
DLP_5597 | Mrs Jacqueline Hewitt | 4.65 Sustainable design principles make efficient use of resources through location, design, positioning, specification, and sourcing of materials, as well as improving the quality of developments and enhancing their environmental performance. The Council will encourage new development to incorporate current best practice in sustainable design and construction, incorporate mitigation and adaptation measures against the future impacts of climate change, and deliver high quality developments. Public art and active spaces will be encouraged as part of good design and place shaping to help foster a sense of place and community coherence. This is so far from what is happening in Cranbrook and Sissinghurst (which has its own design code) that I find it hard to believe that this will be enforced in any meaningful way. Developers have stated that they build to TWBC building standards and that solar panels are not economical. Lip service is paid to sustainability and adaptation to climate change with the installation of water butts and apparently very little else | ||||||||||||||||
DLP_5598 | Mrs Jacqueline Hewitt | 4.60 As identified within the Sevenoaks and Tunbridge Wells Economic Needs Study (2016), 50% of residents in the Tunbridge Wells borough commute out of the borough to work (2011 census data). It therefore follows from the above statement that 50% of the residents of new homes in Cranbrook and Sissinghurst will get into a car to commute out of the Borough to work. This cannot be sustainable. In addition, a further percentage will get into a car to leave the Parish for work again this is not sustainable The Parish has undertaken a Housing Needs Assessment which has shown how many houses need to be built to accommodate the people that live, or aspire to live in the Parish. Why is this not taken into account? | ||||||||||||||||
DLP_5600 | Mrs Jacqueline Hewitt | 4.59 In accordance with the NPPF, this Draft Local Plan will aim to facilitate all forms of sustainable transport, ranging from active travel (such as walking or cycling), public transport, car share, car club, ultra-low emission vehicles such as electric vehicles and charging points, or any provisions that arise through new technology over the course of the plan period. This should be done in all instances to reduce private car dependence in the borough where it is both feasible in relation to local circumstances, Whilst the facilitation of sustainable transport is to be applauded, building so far away from the proposed centres where employment will be targeted cannot possibly reduce private car dependence | ||||||||||||||||
DLP_5615 | Mrs Jacqueline Hewitt | 4.44 To achieve the strategic objectives of this Draft Local Plan, it is essential for development to be planned in a coordinated way and, for some of the strategic sites and locations, it will be appropriate to deliver this through a comprehensive Masterplanning process When Brick Kiln Farm in Cranbrook was allocated, the developer was told to take a Masterplanning approach. This has not happened. I have no confidence that this approach will be enforced by the Planning Department | ||||||||||||||||
DLP_5806 | Weald of Kent Protection Society | Housing: Delivery of Housing Numbers Comment on Para. 4.7 of the DLP: This Draft Local Plan proposes a total of 2,000 houses within the High Weald AONB and many more adjoining the boundaries of the AONB. The preference is for development to be located outside the AONB, but the allocated sites adjoining the AONB will have a considerable impact on the setting. The objectively assessed housing need for the borough is confirmed as 13,560 dwellings (678 per year) using the standard methodology as required by the NPPF. This calculation calls for unprecedented levels of potential development across the borough, and the draft local plan proposes a large number of housing within the AONB. Statistics from TWBC Development Constraints Study: 70% of the borough is within the High Weald AONB. 45 Historic Parks and Gardens 25 Conservation Areas 11 Scheduled Ancient Monuments 16% of the borough is Ancient Woodland 10 Sites of Special Scientific Interest (SSSI) 5 Local Nature Reserves (including one Community Woodland) 1 Regionally Important Geological Site, at Scotney Castle Quarry. These statistics show considerable constraints for development in the borough, yet despite this acknowledgement in the Constraints Study and despite the NPPF, large development sites are proposed within and adjacent to the AONB. The NPPF clearly states that new developments should be limited and small scale. Major development should only be allowed under exceptional circumstances. The allocations constitute major development which by definition will have a significant adverse impact to the character components of the landscape. The indicators are that the numbers cannot and should not be achieved. TWBC has a statutory duty to ‘have regard to the purpose of conserving and enhancing the natural beauty’ of the High Weald AONB. The Draft Local Plan fails this custodial duty because of the many proposals for developments which can have nothing other than an adverse impact on the AONB. WKPS urges TWBC to meet its statutory duty and seek a reduction in housing numbers to reflect local housing need, rather than the standard methodology for housing targets. | ||||||||||||||||
DLP_5990 | Pro Vision for Cooper Estates Strategic Land | Paragraph 4.7 of the draft Local Plan sets out the objectively assessed housing need for the Borough over the plan period. The basis of this housing need target, together with assessments of the housing needs of particular groups (including older persons), is set out in the Housing Needs Assessment Topic Paper. | ||||||||||||||||
DLP_5998 | Alexander Fisher | TWBC: the following comment was submitted by the responders on the left: TWBC has been given a housing need figure of 13,560. It should be the mission of TWBC to protect the borough from the destruction of Green Belt and AONB by following NPPF guidelines. The NPPF para 11(b) says “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless: ii. Any adverse impact of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework when taken as a whole”. The NPPF makes provision for TWBC to have a choice in the provision of the objectively assessed 13,560 houses. If provision of these houses is really only possible by sacrificing Green Belt land then the NPPF makes it perfectly possible for TWBC to say that this is not achievable. TWBC have chosen not to do so. Reduce the number of houses delivered by the Local Plan. Comments on Section 4 Paragraph 4.38 (The Development Strategy) p.39 TWBC is proposing a development strategy based on dispersed growth, i.e. proportional distribution of development across all of the borough’s settlements. You imply that you have achieved this but this is misleading. The Local Plan is almost entirely dependent on the successful implementation of a proposed garden settlement in Tudeley and the expansion of Paddock Wood including building on East Capel. They form 63% of the new housing. If these sites fail to deliver then the associated infrastructure that is entirely reliant on developer capital would also never be realised. This appears to stack risk on risk, where both areas of development are inextricably linked and the failure of one would lead to collapse of the other and as a result the whole plan would fail. Comments on Section 4 Paragraph 4.40 (The Development Strategy) p.39 You refer to Tudeley Village securing a long term option for the borough to deliver the needs of future generations. It is apparent from this statement that you intend to add more and more housing to this “garden settlement” in each five year review of future Local Plans. I fear TWBC want to flood Tudeley and East Capel with housing until it coalesces with Tonbridge and Five Oak Green and coalesces Five Oak Green and Paddock Wood, ultimately creating a massive conurbation from Tonbridge to Paddock Wood. You used NDAs to hide your plans until it was too late for residents to have a fair say. The Local Plan gives TWBC an excuse to dump its housing needs on green fields and meadows to pollute and clog up rather than addressing the needs of their residents and spreading development across the borough on brownfield sites or placing the garden settlement in the middle of the borough, to make it accessible north and south. The developments in Tudeley and East Capel are unsustainable, do nothing for local employment needs and it is totally counterproductive to put affordable housing right at the very north of the borough when so many residents live in the south of the borough. | ||||||||||||||||
DLP_6005 | Laura Rowland | Difficult to understand why a massive proportion of housing is targeted in Cranbrook and Sissinghurst when the employment opportunities are in areas listed above. | ||||||||||||||||
DLP_6006 | Laura Rowland | NDP group research and shows parishioners are against large scale development No large scale development should occur unless exceptional need is proven, which it is not the case in the Parish of Cranbrook and Sissinghurst. The infrastructure in Cranbrook and Sissinghurst is not sustainable for big housing developments. The draft local plan doesn’t show it is ‘aware of the valued and protected landscape.’ The AONB needs to be preserved at all costs and housing needs can be addressed with small scale and sustainable developments that preserve more of the landscape. “The High Weald landscape is considered to be one of the best surviving and most coherent medieval landscapes in northern Europe; it has remained a unique, distinct, and recognisable area for at least the last 700 years.” AONB management plan June 2018 It is surprising TWBC has not pushed back against the housing numbers when 70% of the Borough is AONB. Is this possibly because there is income generated for ‘projects’ by development? The above statement (paragraph 4.40) is belied by the following statement 4.69 The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. | ||||||||||||||||
DLP_6011 | Laura Rowland | Houses are needed in the Parish of Cranbrook and Sissinghurst. An independent provider of professional support services has been used to arrive at a figure for housing in the Parish which is a bit less and can be delivered by small scale housing developments and yet this research commissioned by the NDP, has been ignored by TWBC | ||||||||||||||||
DLP_6013 | Laura Rowland | Why then are so many houses being built so far from major settlements and train stations? | ||||||||||||||||
DLP_6015 | Laura Rowland | If the above statement is a policy, then the LBD of Cranbrook and Sissinghurst should NOT be re-drawn. Already, the largest development in the Parish for at least 40 years, has been allocated adjacent to the LBD and therefore justified. The proposal to re-draw the LBD to enclose this development then allows the next largest site to be bought forward using the same justification, against the wishes of the local residents 4.87 Although very close to the LBD boundary, the site at Turnden Farm, Hartley Road, to the south west of Cranbrook has also been excluded at this stage. However, it is anticipated that these sites will be reviewed and refined for the next stage of the Local Plan. | ||||||||||||||||
DLP_6170 | Dr Malcolm Butler | The current housing target for Tunbridge Wells Borough for the period 2016 – 2036 is 13,560 homes, based on the housing figures forecast in 2014 and an unexplained 40% multiplier. The use of the 2014 figures has been questioned, as the Office for National Statistics forecast for 2016 reduced the housing need figure significantly from 300,000 to 160,000. The use of the multiplier in Tunbridge Wells Borough appears to be based on the affordability ratio in the borough of 12.74 and an erroneous assumption that building more homes will make them affordable. This assumption is at odds with housing market data and national statistics and evidence is needed to substantiate this counter-intuitive correlation. The Housing Needs Study published by TWBC in July 2017 stated that the population of the borough would increase from 117,700 in 2017 to 128,800 in 2033. An increase in population of 11,100 contrasts strangely with the proposed target of 13,560 new homes over a similar time period. It would be unfortunate if this situation has been allowed to develop solely because of the additional funding that will come to TWBC for each new house built. It seems to us that there is a danger of getting into an “Irish” situation, in which the countryside is covered with half-built housing estates that can’t be sold. | ||||||||||||||||
DLP_6207 | Amanda Wells | Development Strategy 4.9, 4.9 As under my comments on the Vision in Section 3, TWBC neds to dramatically rethink the ‘objectively assessed housing need’ – the whole Local Plan is based on greatly inflated figures which do not meet the needs of the Borough. | ||||||||||||||||
DLP_6268 | Susan Heather McAuley | 4.19 Employment is proposed at the west end of the Borough (the exception being a small site at Gills Green providing limited types of jobs) – this is at the opposite end of the area to the large building projects being proposed for villages at the east end of the Borough. Employment is to be concentrated around the west end of the Borough (apart from a small increase in size to Gills Green employment areas) which large scale housing estates are proposed to be built at the east end. This automatically gives a mis-match between places to live and places to work. This plan is economically and environmentally, and to some degree socially, unsustainable because it creates long, expensive journeys, increases air pollution and separates place of work from place of residence for the majority of residents in a village. 4.26 ‘Well designed and sustainable communities’ Some people want to live in towns, others in villages. Their reasons for this choice are distinct. While extra house building in a town will not change life for most people in that town, building large numbers of extra houses in a village can take away the features that made people want to live on that village – a sense of belonging, of safety, of knowing the people that walk past your house. In a town your group of friends may be made up of people from different streets, that you know through work, or clubs or sporting activities. You may not know further than your immediate neighbours that well and usually don’t mind that. In a village you know everybody and everybody knows you. That does not suit everyone but it does suit the people who choose to live in a village. Fill the village with so many houses that you have no hope of knowing everyone, put those houses in giant cul-de-sacs (Bramling Gardens in Sissinghurst) where people have no need to mix with other parts of the village and you destroy that village and the reason for living there. Extra buses and parking spaces will not mitigate this. If you have had village people work on this Local Plan they will have explained this difference to you. Village people have the same right to a chosen way of life as town people have. You want to enhance Tunbridge Wells town by have extra work and shops and cultural activities which is wonderful for the people of Tunbridge Wells. It will create a ‘well designed and sustainable’ community that will endure into the future. For some of our villages this Local Plan will create a totally unsustainable community that will be a dormitory with no social structure. This Local Plan is socially unsustainable for our village of Sissinghurst. 4.33 The call for sites seems a seriously flawed, non-planning led approach. Instead of looking at locations and needs and suitable sites (as the relevant authorities would do if they wanted to build a strategic road or railway) the Local Plan has identified sites where people wanted to sell their gardens and land. Therefore sites that look suitable are not included because they were not put forward by the landowners. This is a piecemeal approach which para 2.44 says can have an adverse impact on the natural, built and historic environment. There is no extra housing proposed for Bidborough because no-one suggested any suitable sites? Does Bidborough not need any new houses? Compulsory purchase is mentioned in this plan but it seems it is not going to be used to identify more suitable sites for housing. 4.38 The Council is proposing a strategy based on Option 3 (dispersed growth). Option 3 in the Issues and Options stage was described as ‘proportional across all of the Borough’s settlements’. The Local Plan recommendations are not proportional – if my Maths is correct, assuming just 2.5 people to a house …
The allocation is disproportionate and this is not explained by the area of the AONB. Tunbridge Weels and its environs will get new employment and cultural and retail facilities but few new houses, Cranbrook & Sissinghurst and others will get huge amounts of new housing having a massive impact on the ‘place-shape’, but some villages get far fewer new houses. This Local Plan must fail the equality impact assessment, it is pro-urban and broadly anti-rural, certainly anti Cranbrook and Sissinghurst and goes against the wording of Option 3. 4.39 The areas chosen for employment (Options 1,2,& 4) are different from those assigned for housing (Options 3 & 5), thus increasing the need for car or public transport to Tunbridge Well, Maidstone or Staplehurst Station. This is not economically sustainable. 4.40 This paragraph is incorrect. Bullet Point 2 - there is no urban expansion in this plan (less than 5%) but there is extensive rural expansion (32%) . Bullet Point 4 – there are no significant numbers of new homes in the wider urban area – less than 5% around Tunbridge Wells town. Bullet Point 7 – the scale of building in some smaller settlements, particularly Sissinghurst, is not at an appropriate scale – 32% increase in numbers of houses – against 5% increase in the Tunbridge Wells area. It is not economically, environmentally or socially sustainable. | ||||||||||||||||
DLP_6276 | Mrs Elizabeth Simpson | The draft Local Plan sets out the policy framework in which the Borough Council will make planning decisions and deliver development to meet its housing target within the Plan period, 2016-2036. However, TWBC appear to be accepting without challenge the top-down target set by central government of 13,560 homes and indeed TWBC are proposing to set their own target at 9% above this level at 14,776 homes. This is described as being based on the objectively assessed housing need for the borough over the plan period, identified by the standard methodology as required by the NPPF. Yet this methodology is flawed, having been based on historic data, and despite there being considerable wealth of information available to argue that this is not correct. TWBC should adopt a more pragmatic approach based on local need and capacity as undertaken by many other local authorities including nearby Sevenoaks to seek a reduction of these numbers. One such piece of research which challenges the out-dated approach in setting housing targets, is a paper published by UK Collaborative Centre for Housing Evidence – entitled: Tackling the UK Housing Crisis – is Supply the Answer, written by Ian Mulhern Aug 2019. (This examines and challenges the thinking that by building more house prices will come down). The problem is not a housing shortage but a housing affordability crisis. Further to this, the Housing Needs Assessment Topic Paper (August 2019) already states that, the government will be reviewing the methodology for calculating housing numbers in the next eighteen months, because the current methodology it relies on is out of date, based on 2014 projections. The Government reasoning for continuing to use these, on an interim basis, is to provide stability and certainty to the planning system in the short-term. Thus these numbers should not be taken as a mandatory target for TWBC to plan for, but a starting point only. The standard methodology is, therefore not mandatory. The target that the Plan aims to achieve could well be far higher than necessary. It is not appropriate for the Council to adopt its ‘wait and see’ position, which could lead to its policy framework being based on a false target. The Plan needs to be based upon the most realistic assessment of need, taking into account the constraints that characterise the Borough. Further, as 70% of the borough comprises AONB or Green Belt, which are supposed to be protected landscapes, there are further reasons why the overall number should be challenged. The levels of development proposed in this draft local plan, will cause irreparable damage to the local environment. I see that Paragraph 4.8 specifically notes that Sevenoaks District Council is not proposing to wholly meet its housing need. If, as the Plan states, the constraints that apply to Sevenoaks District Council are similar to those of TWBC, why isn’t TWBC also challenging their housing target based on standard methodology and/or proposing to not wholly meet the need identified through this method? Isn’t there a case to argue that the constraints that apply to TWBC (the extent of AONB and Green Belt land in the borough and notable affordability pressures potentially causing a fall in home ownership) constitute “exceptional circumstances”, which could justify an alternative approach to assessing housing need according to NPPF paragraph 60? | ||||||||||||||||
DLP_6318 | Susan Heather McAuley | From the results of the Issues and Options Consultation I thought the preferred options (as reported from that consultation) were Option 1 and Option 5. The actual local Plan is not following this decision. Option 1 says ‘limited development within the remaining villages and rural areas’. Sissinghurst is a ‘remaining village’. It should not be treated as part of Cranbrook and therefore should have limited development. The same is true of Horsmonden. However, these preferences are not reflected in the local plan. It seems from the Local Plan that Option 3 and Option 5 have been decided upon. Option 3 is dispersed growth described as ‘proportional across all of the Borough’s settlements’. The Local Plan recommendations are not proportional – if my Maths is correct … assuming just 2.5 people to a house …
The allocation is disproportionate and this is not explained by the area of the AONB. Tunbridge Weels and its environs will get new employment and cultural and retail facilities but few new houses, Cranbrook & Sissinghurst and others will get huge amounts of new housing having a massive impact on the ‘place-shape’. This Local Plan must fail the equality impact assessment, it is pro-urban and anti-rural and goes against the wording of Option 3. | ||||||||||||||||
DLP_6422 | Hawkhurst Parish Council | p.33 para 4.6: A point is made about promotion of neighbourhood planning as a process. However, considering the intention to overwrite policies in TWBC NDP for Hawkhurst, part of the adopted TWBC statutory plan, and with no further explanation, we do not have confidence in these statements. During this process, Hawkhurst Parish Council suggested smaller sites that would comply with the TWBC NDP for Hawkhurst aims, objectives and policies. TWBC have not chosen to allocate these sites, leaving them as potential windfall sites outside of the allocation for the Parish. Why is this? We acknowledge that the TWBC NDP for Hawkhurst does not contain direct site allocations due to the fact that at the time Hawkhurst had exceed the housing number allocated to it in the existing TWBC Local plan. However, taking Counsel advice this is a moot point. The revised version does contain housing allocations to reflect today’s climate for the preferred distribution, scale and location of new development this should be considered in the next version of the draft TWBC Local Plan. para 4.35 – 4.37: Statement about the level of agreement between the Council and parish representatives about which sites form a set of draft site allocations for each parish This process is not what the Localism Act describes. It is widely understood that NDPs should allow local communities to take meaningful decisions over the location of new homes. Yet the TWBC process deliberately frustrates this, by ignoring Parish Councils suggestions and taking all such decisions on behalf of local communities. This is counter to the Localism Act. p.59: para 4.72 – 4.79 Reference to the neighbourhood planning process This is largely a “cut and paste” from the regulations and does little to explain how TWBC sees the process of preparing an NDP should contribute to the delivery of sustainable development across the borough, para 4.79: This states: “Notwithstanding the Council's support for neighbourhood plans, in view of the fact that their progress is variable and outside the direct control of the Council, as well as the pressing requirement to address under-delivery of housing against identified need, the Draft Local Plan includes draft allocations for the whole of the borough” Almost all NDPs can be produced more quickly than a LP and are much more responsive to local concerns. But rather than work with the parishes to create a strong pattern of advanced and/or made NDPs across the borough, the approach taken is to include draft allocations for the whole of the borough, thereby deliberately undermining many NDP groups. In the case of Hawkhurst, it is acknowledged that the made NDP does not contain direct site allocations but it does contain criteria for the preferred distribution, scale and location of new development yet this appears to be ignored by the draft TWBC Local Plan. | ||||||||||||||||
DLP_6428 | Hawkhurst Parish Council | p.33 footnote 19 We consider this to be a major error on the part of TWBC as it has defined the “urban area” for planning purposes as the main urban area of Royal Tunbridge Wells and Southborough, together with the rural settlements of Paddock Wood, Cranbrook, and Hawkhurst. How can it be that rural settlements of Cranbrook and Hawkhurst, both deep within the AONB, can be given the same urban status as Royal Tunbridge Wells and Southborough? This is critical because the definition of “urban area” then leads directly to a strategy that maximises development within existing built-up areas and optimised densities. While this strategy of maximisation and optimal density may be appropriate in genuine urban areas such as Royal Tunbridge Wells, it cannot be considered appropriate for rural communities in nationally protected landscape areas. It is from this mistaken assumption that much disturbing content of the draft TWBC Local Plan follows. Correct this assumption (i.e. Cranbrook and Hawkhurst will not be subject to the maximisation strategy) and a whole different approach is possible | ||||||||||||||||
DLP_6455 | Cranbrook & Sissinghurst Parish Council |
Neighbourhood Plans are the only part of the planning system that require consent through a local referendum. The Cranbrook and Sissinghurst NDP group has been a willing participant in the Local Plan process yet all its efforts to work constructively with TWBC to prepare a complementary planning document to the Local Plan (i.e. an NDP) have been rebuffed. The Parish is wondering what the future is for its emerging Neighbourhood Plan, now that fundamental decisions, such as the location and spatial distribution of housing has been taken away from it. Furthermore, there is no view expressed within the draft TWBC Local Plan about the expectations for neighbourhood planning –what exactly does TWBC want them to do to complement the Local Plan? There is almost no guidance or direction within the draft TWBC Local Plan on this matter. This omission leads many to believe that neighbourhood planning is considered marginal at best (and irrelevant at worst) by the TWBC Local Plan team. If the team in TWBC genuinely consider NDPs to be a useful and practical part of the system, there would be clear expectations set out for them. There are not. Over the last 18 months, repeated communication from the Parish to TWBC Local Plan team has made clear the wish of the Neighbourhood Plan group to make direct site allocations in the emerging NDP. We strongly believe that a Neighbourhood Plan that contains site allocations is the most effective way for the local community to “develop a shared vision” for this area and to “shape, direct and help to deliver sustainable development, by influencing local planning decisions as part of the statutory development plan” (para. 29, NPPF). Yet the draft TWBC Local Plan, as published in September 2019, includes allocations for the whole Borough, including in those areas where Neighbourhood Plans are being prepared by Parish Councils. We see no logic for this approach, an approach that fundamentally undermines the spirit and principles of localism. The damage caused to local democracy by this approach is a major cause for concern. In such a controversial period for public engagement, Neighbourhood Plans may be one of the most democratic things going on right now and yet the wishes of local people on this matter are being ignored. p.38, para 4.35: Statement that TWBC has actively engaged with NDP groups around site selection We are aware that the process has involved TWBC asking the opinion of NDP groups about the sites it intends to include in the draft TWBC LP. But at no point in the process has there been an encouragement for site allocations to be made within NDPs themselves, which is what many NDP groups want to be able to do, including Cranbrook and Sissinghurst. Repeated communications have made it clear that the NDP for the Parish wanted to directly allocate land for development to give local people the maximum control over its future. Our ambition in this area has been frustrated by TWBC at every turn. Examples of this frustration include failure to honour commitments to provide information, such as backup to ‘Call for Sites’, or providing copies of minutes of meetings. para 4.35 – 4.37: Statement about the level of agreement between the Council and Parish representatives about which sites form a set of draft site allocations for each Parish This process is not what the Localism Act describes. It is widely understood that NDPs should allow local communities to take meaningful decisions over the location of new homes. Yet the TWBC process deliberately frustrates this, by taking all such decisions on behalf of local communities. This is counter to the Localism Act. Despite a request to TWBC first made in June 2018 to prepare a “Memorandum of Understanding”, to better define the relationship between the TWBC Local Plan and neighbourhood plans, none has been forthcoming. This has left many NDP groups, including Cranbrook and Sissinghurst, unsure how to proceed on key matters. p.59: para 4.72 – 4.79 Reference to the neighbourhood planning process This is largely a “cut and paste” from the regulations and does little to explain how TWBC sees the process of preparing an NDP should contribute to the delivery of sustainable development across the Borough, para 4.79: This states: “Notwithstanding the Council's support for neighbourhood plans, in view of the fact that their progress is variable and outside the direct control of the Council, as well as the pressing requirement to address under-delivery of housing against identified need, the Draft Local Plan includes draft allocations for the whole of the borough” This approach and statement deliberately frustrates those NDP groups that have been willing and able to make direct site allocations through the NDP process for some time. Indeed, several NDP groups have been able to accelerate the delivery of new homes (when compared to the LP process) if only they had been given the information and required support from TWBC at the right time. Almost all NDPs can be produced more quickly than a LP and are much more responsive to local concerns. But, rather than work with the parishes to create a strong pattern of advanced and/or made NDPs across the Borough, the approach taken is to include draft allocations for the whole of the Borough, thereby deliberately undermining many NDP groups. [TWBC: see full response]. | ||||||||||||||||
DLP_6463 | DHA Planning for Cedardrive Ltd | 3.3 Development Strategy and Strategic Policies Context 3.3.1 The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the borough and where that development will be located. 3.3.2 In terms of the amount of housing, paragraph 59 of the NPPF states that to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient quantum and variety of land can come forward where it is needed. Furthermore, to determine the number of homes needed, strategic policies should be informed by a local housing needs assessment conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. 3.3.3 The Council confirm that their housing need target for the plan period 2016-2036 is 13,560 dwellings (678 dwellings per annum), which is calculated using the Government’s standard method and the 2014-based household projections. 3.3.4 In terms of the different supply components, the Council considers that the Local Plan must (as a minimum) include additional allocations to accommodate 7,593 homes. This figure was formulated taking into account: * completions since April 2016 (1,552); 3.3.5 The Council has applied a 10% non-delivery rate to these figures to err on the side of caution and consider that the plan would exceed the minimum housing requirement if all of the supply components were achieved. 3.3.6 We commend TWBC for seeking to meet their need in full and support this positive approach to plan-making. Likewise, we support the general thrust of the development strategy, which proposes a strategy to meet the housing needs of the borough with a dispersed growth approach. [TWBC: see full representation]. [TWBC: see also Comment Numbers DLP_6461-6472]. | ||||||||||||||||
DLP_6534 | Diana Badcock | Object Policy Number: 4.7 If TWBC’s housing figures of 13.560 are based on NPPF guidelines (4.7), why did TWBC accept them without challenge. The ‘standard methodology’ allows for exceptions. Why did TWBC not argue for a smaller number given that 70% of the borough is in an AONB? THE ANOB and national policy allows for development to be reduced where valued landscapes can be damaged (NPPF paragraph 11). For Cranbrook - these are entirely inappropriate numbers and the plans for several sites far too extensive, for an area set completely within an AONB, where development should only be allowed in exceptional circumstances, and if allowed, should be small scale. | ||||||||||||||||
DLP_6535 | Diana Badcock | Object ‘….‘It will be appropriate to deliver this through a comprehensive masterplanning process’. | ||||||||||||||||
DLP_6570 | Myrtle Newsom | Policy Number: Section 4 Strategic Policies Para 4.39 The areas destined for employment do not match those assigned for housing, thus increasing the need for car or public transport to Tunbridge Well, Maidstone or Staplehurst Station. This is not economically sustainable. | ||||||||||||||||
DLP_6572 | Myrtle Newsom | Policy Number: Section 4 Strategic Policies Para 4.60 This ignores the fact that there needs to be better transport from rural areas into Tunbridge Wells or people will continue to use their own cars. | ||||||||||||||||
DLP_6574 | Myrtle Newsom | Policy Number: Section 4 Strategic Policies Para 4.86 Point 3 | ||||||||||||||||
DLP_6600 | Michael Lloyd | The DLP says: Sustainable development of an appropriate scale at the smaller settlements to provide opportunities at the local level to meet housing needs and sustain local services and infrastructure, as well as the support for new local facilities where required, and at all times being aware that such development is taking place on valued and (in many cases) protected landscapes. This is laughable when one considers the Brick Kiln Farm and Turnden developments in Cranbrook, which will have the effect of joining Cranbrook to Hartley by eliminating the green space between. What happened to Limits to Built Development? | ||||||||||||||||
DLP_6609 | AAH Planning for Future Habitat Ltd | SECTION 4 – THE DEVELOPMENT STRATEGY AND STRATEGIC POLICIES This section of the Consultation Draft sets out the housing and economic development targets for the plan period to 2036 and describes the Council’s approach to the spatial distribution of development. It comprises a Development Strategy, at Policy STR 1, and other strategic policies that fulfil the expectations of the NPPF. The Development Strategy With regard to housing need, this section identifies that the objectively assessed housing need for the Borough over the plan period to 2036 is confirmed as 13,560 dwellings (678 per year), identified by the standard methodology as required by the NPPF. Discounting completions up to March 2019, extant planning permissions, outstanding site allocations, and a windfall allowance of 700 dwellings, this equates to at least 7,593 new additional allocations to meet housing need. The basis of this housing need target, together with assessments of the housing needs of particular groups, is set out in the Housing Needs Assessment Topic Paper. Whilst our Client generally supports this, the identified housing need should be a minimum requirement in line with national policy. In addition, it is considered that suitable windfall sites and additional site allocations made through the plan will be required in order to meet the identified need and assist in significantly boosting the supply of housing. It is noted that the Council has prepared a Strategic Housing and Economic Land Availability Assessment (SHELAA) to identify a future supply of land that is suitable, available, and achievable for all housing and economic development needs over the plan period. This is welcomed by our Client and it is noted that previous representations have been prepared to support the allocation of the site for housing in the emerging Local Plan. [TWBC: see full representation and site plan attached]. [TWBC: see also Comment Nos. DLP_6606-6620, 6622-6627]. | ||||||||||||||||
DLP_6644 | Mr Steve Gasson | Paragraph 4.3 states that ‘in preparing this Draft Local Plan, the Council has to be mindful that national planning policy, as set out in the NPPF (2019), expects local plans to meet the identified level of development needs for their area in full, unless there are good planning reasons why this is not possible. Accordingly, the proposed Development Strategy indicates how the full development needs of the borough can be most appropriately met.’ This presumption that the full development needs as derived formulaically using the new Standard Method must be met goes against NPPF paragraph 11, which makes clear that AONB designation may provide a strong reason for restricting the overall scale, type or distribution of development in the plan, and ignores the Planning Policy Guidance updated in July 2019 which specifically comments that in order to protect such areas it may not be possible to meet the formulaically derived needs. TWBC should carry out a transparent assessment demonstrating that in deciding the level of housing provision proposed, the type of homes and the distribution of those homes, great weight has been given to conserving and enhancing landscape and scenic beauty in the AONB; the conservation and enhancement of wildlife and heritage has been taken into account; and the scale and extent of development within the AONB has been limited. | ||||||||||||||||
DLP_6787 | G M Whitehead | Cranbrook and Sissinghurst. Section 2.32 states that new development should make efficient use of the land while it should not have an unacceptable adverse impact on the character and setting of the natural and built environment of the borough. In Section 4.7 it says the assessed housing needs for the borough is 678 per year. ALL Cranbrook’s TWBC site allocations lie within the AONB including several large allocations. 70% of the Borough is protected as an AONB and national policy allows for development to be reduced where valued landscapes could be damaged. (NPPF Para.11). Why hasn’t TWBC assessed the harm that cumulative development can do to the AONB landscape and its communities and argued for lower housing numbers as a result? | ||||||||||||||||
DLP_6793 | Kember Loudon Williams for Wedgewood (New Homes) Ltd | It is noted and supported that opportunities to deliver housing in villages outside the AONB should be maximised. Horsmonden is one of the larger villages in the Borough and the settlement is one of the few villages in the Borough that is outside the AONB (noting that part of the Parish is within it). It is queried whether the emphasis placed on this approach at 4.38 and 4.40 has followed through with sufficient emphasis on this consideration within the various Strategic and Allocation Policies. This is referred to in more detail below, and in the attached KLW Supporting Statement. [TWBC: see Supporting Statement and Comment Numbers DLP_6793, 6797-6799, 6801, 6803-6804] | ||||||||||||||||
DLP_6802 | G M Whitehead | 4.40 final para. You say - Sustainable development of an appropriate scale at the smaller settlements to provide opportunities at the local level to meet housing needs and sustain local services and infrastructure, as well as the support for new local facilities where required, and at all times being aware that such development is taking place on valued and (in many cases) protected landscapes. One reason for allowing Brick Kiln Farm estate to be built was that it was only just outside the LBD. The intention of this plan seems to be to move the LBD so BKF is inside, thus allowing the same reasoning to be used again to allow an increase of the site coming all the way down to the Crane Valley. You seem not to be sufficiently aware of this protected site and its value to the setting of the Wealden Town of Cranbrook. | ||||||||||||||||
DLP_6817 | Persimmon Homes South East | 2.0 DRAFT LOCAL PLAN - DEVELOPMENT STRATEGY 2.1 As noted above Persimmon Homes are supportive of the draft Plan and the allocation AL/HO3 in particular. We are thereby keen that the Plan progresses successfully through the Local Plan process including examination. To this end we set out below a number of observations and recommendation concerning the emerging Development Strategy. Housing Requirement 2.2 Table 1 of the Reg 18 plan identifies the housing need for the period 2016 – 2036 to be 13,560 dwellings (678dpa). This is said to be based upon the standard methodology (2014 based household projections (published July 2016)), projected household growth in Tunbridge Wells for the period 2019-2029 and the affordability ratios published in April 2019. Whilst we believe the figure to be 682dpa, we note para 3.2.1 of the Housing Topic Paper (HTP) suggests the figure of 678 is being used as it is based upon submission in 2020. This being the case the plan when submitted needs to be clear on this point and all associated calculations clarified accordingly. We also believe, for the reasons set out below, that the plan period should also be amended and start in 2020 not 2016 as drafted. Whether the Plan should provide for more than the minimum local housing figure 2.3 The plan should, given ID: 2a-010-20190220 of the PPG, consider whether it might be appropriate to plan for a higher housing need figure than the standard method indicates given issues such as local affordability. 2.4 The housing needs survey 2018 identifies a net affordable housing need of 443dpa. As policy H5 looks to deliver 40% affordable provision on all greenfield sites of 9 (+) dwellings, and acknowledging that not all sites provide affordable housing, in order to meet 100% of the affordable requirement one would conservatively need to deliver circa 1,107 dpa over the plan period. This is clearly significantly greater than the figure generated by the standard method, (678/682dpa) and whilst the standard method takes into account affordability issues, this does beg the question as to whether TWBC need to consider whether it might be appropriate to plan for a higher housing need figure than the standard method indicates. If nothing else the SA should in our opinion assess this point. 2.5 In the context of the above we also note that the figure of 678/682dpa is the minimum local housing need figure. It is capped at 40%. The uncapped figure is in fact 762dpa . This figure would better be described as the actual housing need, with 678/682dpa simply being the minimum Local Housing Need figure defined by the standard method. Again, given the scale of the affordable housing need the HTP and the SA should 634/B1/CC/TA 4 November 2019 in our opinion consider the issue of the plan providing for more than the minimum local housing need figure. 2.6 Finally, having regard to the issues around the Duty to Cooperate, there is the issue of Sevenoaks District Councils (SDC’s) unmet need. Whilst we note that the SA does consider a growth option that encompasses SDC’s unmet need (option 7 – see below), para 6.2.2 of the SA appears to dismiss this option on the basis that it was assumed that the additional 1,900 dwellings would essentially be located within the AONB. It is not clear how this conclusion has been reached. In addition there is nothing that allows one to undertake a like for like comparison of the SA findings on option 7 (as set out in table 14) against the options considered in the earlier SA and the chosen option – such that the rational for this decision does in our opinion require further clarification. The Plan Period 2.7 The Government’s Planning Practice Guidance (ID: 2a-004-20190220) indicates that when setting the baseline, the projected average annual household growth over a 10 year period should be calculated and that “this should be 10 consecutive years, with the current year being used as the starting point from which to calculate growth over that period”. Thus, the plan period should start at 2020 if it is to address the OAHN identified by the Standard Method of 678 (2020-2030) rather than 682 (2019-2029). Duty to Cooperate 2.8 Having reviewed the interim Duty to Cooperate Statement we note that housing is seen as a cross boundary strategic issue and that a Statement of Common Ground (SoCG) has already been signed with both Maidstone Borough Council (MBC) and Sevenoaks District Council (SDC) that look to address this issue, amongst others. We also note that the SoCG with MBC is dated August 2016 and that with SDC is dated May 2019. 2.9 As the Borough Council will be aware, the Duty to Cooperate places a legal duty on local planning authorities to engage constructively, actively and on an ongoing basis to maximise the effectiveness of Local Plan preparation in the context of strategic cross boundary matters. We do not believe, given the above, that the SoCG with MBC and SDC can be seen as demonstrating actively and ongoing engagement at this stage of the plan making process – we would expect there to be a rolling program of engagement to address matters as they arise through the consultation on the Reg 18 and Reg 19 plan. Thus, the SoCG would need to be updated accordingly. 2.10 In addition to the above, we are mindful of the recent correspondence between SDC and their Inspector, especially documents ED37 and ED40. It is clear from the latter that the Inspector did not accept that 634/B1/CC/TA 5 November 2019 reliance on a review of the Plan to address the issue of SDC’s unmet need was appropriate or complied with the duty, which applies specifically to plan preparation, which as the Borough Council are aware ends when the plan is submitted for Examination. Thus, this issue needs to be thoroughly examined and addressed in the SoCG that are submitted prior to submission of the Plan. Which means TWBC need to liaise with SDC about where they now are with this issue and the TWLP needs to clearly demonstrate why it cannot, if that is the case, help address SDC’s unmet need. Sustainability Appraisal 2.11 TWBC must comply with Directive 2001/42/EC (the SEA Directive) and the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA Regulations) as required by the Planning and Compulsory Purchase Act 2004 while preparing the Local Plan. 2.12 TWBC are required under Article 4 of the SEA Directive to ensure that their environmental assessment is carried out “during the preparation of the plan”. Therefore, any changes or modifications to the emerging Local Plan prior to its adoption must be considered as part of the environmental assessment. 2.13 Regulation 12(2) SEA Regulations provide that the Sustainability Appraisal of the Local Plan must identify, describe and evaluate the likely significant effects on the environment of implementing the particular development plan and reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme. 2.14 Section 6 of the Sept 2019 SA reviews the growth strategy. It demonstrates that six options were considered at Issues and Options:
2.15 Para 6.2.4 of the Sept 2019 SA suggests that Growth Strategy 5 had the highest number of positive scores and lowest number of negative scores. It also explains that: ‘This option, which has been taken to embrace an enlarged town or village based on garden settlement principles as well as a new freestanding garden settlement, is therefore proposed to be integral to the preferred development strategy for the borough.’ 2.16 Notwithstanding the above the Sept 2019 SA also explains at para 6.2.6 that it would neither be reasonable in SA terms, nor practical, to focus unduly on new or expanded settlements as the solefocus of meeting the housing needs of the borough. And that as such, as set out in para 6.2.8 and 6.2.9 the growth strategy incorporates both growth strategies 3 and 5. 2.17 In order to fully understand the rationale behind the growth strategy, one has however to refer back to the Sustainability Appraisal Issues and Options Report May 2019, as it is chapters 4 and 5 of this documents that appraises each of the proposed growth options against the Sustainability Objectives, considers how one could mitigation adverse effects and maximise the beneficial effects, and recommends the further investigation of growth options 5 and 4. Whilst para 5.3.1 goes on to advise that: ‘it is pertinent to note that this recommendation is subject to locational constraints’ we are concerned that not only does one have to go on a paper chase to fully understand the rationale behind the chosen growth/ spatial strategy, but that the findings of the May 2019 SA differ from those of the Sept 2019 SA without any explanation. This needs to be rectified in the Reg 19 SA. 2.18 Whilst the SA does in our opinion review the reasonable alternatives to the growth options/ spatial strategy, and the associated options for the scale and location of growth proposed within the new settlement/ enlarged town it does in some areas require a paperchase and in others is not perhaps as clear and robust as it could be, such that we believe the SA should be reviewed and updated when the Reg 19 plan is published. [TWBC: See full representation] | ||||||||||||||||
DLP_6837 | John Gibson | The paragraph refers to employment areas within the Borough but makes no reference to any in Sissinghurst despite the high number of new homes being proposed. | ||||||||||||||||
DLP_6838 | John Gibson | As there is no exceptional need for more houses in Sissinghurst the proposed development is not appropriate. It is also not sustainable in terms of infrastructure and because it is a valued and protected landscape being adjacent to the Weald AONB. | ||||||||||||||||
DLP_6841 | John Gibson | The elected Parish Council for Cranbrook and Sissinghurst commissioned an independent assessment of the local housing needs as part of the generation of the local NDP. The conclusion was that the TWBC figure was higher than required and that the local needs could be met by small scale housing developments. | ||||||||||||||||
DLP_6842 | John Gibson | As so many people will commute to work why is this development even being considered being so away from local towns and railway stations? | ||||||||||||||||
DLP_6843 | John Gibson | The LBD has been redrawn by TWBC against the wishes of the local Parish Council in order to make it possible to consider developments outside the existing limits to built. This appears to me to be a subversion of the Policy and an abuse of democratic power. It would seem that the Policy is meaningless if it can be altered whenever it suits. | ||||||||||||||||
DLP_6845 | John Gibson | The planning application for this site shows little or no regard for the high standards of design and place shaping. I would expect the planning department to insist on the high standards decreed. | ||||||||||||||||
DLP_6846 | John Gibson | The provision of sustainable transport is to be welcomed. However, allowing so many developments away from centres of employment will only increase car dependency. | ||||||||||||||||
DLP_6856 | John Gibson | Section 4 Paragraph 18 The economic needs study (ENS) recommends that the TWBC allocates at least 14 hectares of new employment land in order to support new employment alongside the proposed new housing. No provisions at all have been planned in parallel with the extra houses being proposed in Sissinghurst. The extra commuting this will generate will result in a further failure to meet the sustainability objectives. | ||||||||||||||||
DLP_6944 | Hallam Land Management Ltd | Housing Development | ||||||||||||||||
DLP_7153 | Kay Margaret Goodsell | 4.19 New jobs aer going in Tunbridge Wells so that is where the houses should be. Jobs are going in Tun Wells and houses at our end of the county. This does not make sense. The houses should go in Tun Wells there is plenty of space around the town. 4.26 ‘Well designed and sustainable communities’ How is Sissinghurst being well designed by this Plan? The houses are just being dumped where people want to make a bit of money by selling their land. 4.39 The areas chosen for employment (Options 1,2,& 4) are different from those chosen for housing (Options 3 & 5), so more people will be driving everywhere. 4.40 Where is the major urban expansion – there are no great changes to our main town – TWells, all the houses are being put at the other end of the county. | ||||||||||||||||
DLP_7191 | John Gibson | The paragraph refers to new employment areas within the Borough but makes no reference to any in Sissinghurst despite the high number of new homes being proposed. | ||||||||||||||||
DLP_7192 | John Gibson | As there is no exceptional need for more houses in Sissinghurst the proposed development is not appropriate. It is also not sustainable in terms of infrastructure, extra need for transport and because it is a valued and protected landscape adjacent to the Weald AONB. | ||||||||||||||||
DLP_7194 | John Gibson | The elected Parish Council for Cranbrook and Sissinghurst commissioned an independent assessment of the local housing needs as part of the generation of the local NDP. The conclusion was that the TWBC figure was higher than required and that the local needs could be met by small scale housing developments. | ||||||||||||||||
DLP_7195 | John Gibson | As so many people will commute to work why is this site even being considered being so far away from local towns and railway stations? | ||||||||||||||||
DLP_7196 | John Gibson | The LBD has been redrawn by TWBC against the wishes of the local Parish Council in order to make it possible to consider developments outside the existing limits to built. This appears to me to be a subversion of the Policy and an abuse of democratic power. It would seem that the Policy is meaningless if it can be altered whenever it suits. | ||||||||||||||||
DLP_7197 | John Gibson | The provision of sustainable transport is to be welcomed. However, allowing so many developments away from centres of employment will only increase car dependency. | ||||||||||||||||
DLP_7206 | DHA Planning for Inter-Leisure Ltd | 1 Local Plan Representation 1.1 Introduction 1.1.1 This representation has been prepared on behalf of Inter-Leisure Ltd in response to the Tunbridge Wells Borough Council (‘TWBC’) Draft Local Plan Consultation, which runs until an extended deadline of 15th November 2019. 1.1.2 Our client controls Paddock Wood Garden Centre, Maidstone Road (herein ‘the Garden Centre’ or ‘the Site’) and it is their intention to promote it for allocation in the finalised draft of the Local Plan. 1.1.3 The site was not put forward as part of the Call for Sites process, however it is available and adjoins the proposed extension to Paddock Wood (Policy AL/PW1). It therefore represents a logical location to extend the allocation boundary and contribute toward meeting identified development needs. In particular, the associated additional retail needs that will arise from the increased population. 1.1.4 This representation therefore comments on the content of the draft plan, outlines why the site represents a suitable location for growth and how development could be delivered on site. 1.2 The Tunbridge Wells Draft Local Plan Overview 1.2.1 The TWBC Draft Local Plan (herein referred to as ‘the plan’) sets out the spatial vision, strategic objectives, and overarching development strategy for the borough. It details overarching place shaping policies for each parish and settlement, as well as site specific allocations to deliver the strategy and detailed policies to be applied to all new development. 1.2.2 The plan will set the agenda for development across the borough to 2036 and replace the current Development Plan, which comprises the Local Plan 2006 (saved policies), the Core Strategy 2010, and the Site Allocations Local Plan 2016. 1.2.3 This representation comments on the following elements of the plan: [TWBC: see full representation. See also Comment No. DLP_7205 (Policy STR/PW 1]. Development Strategy and Strategic Policies 1.2.4 The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the borough and where such development will be located. 1.2.5 In terms of economic and retail development, the National Planning Policy Framework (‘NPPF’) states that planning policies should help create the conditions in which businesses can invest expand and adapt. Moreover, planning policies should set out a clear economic vision and strategy that plans positively, and proactively encourages sustainable economic growth. 1.2.6 The Sevenoaks and Tunbridge Wells Economic Needs Study (‘ENS’) was produced in 2016 to inform the plan and make recommendations for the future provision of employment land (use classes B1, B2, and B8). It recommended that the Council should plan positively to facilitate economic growth by allocating news sites, and identified a need of circa 14 hectares of new employment land to support new opportunities alongside the provision of new housing. Specifically it recommends the extension of existing employment areas, including those around Maidstone Road in Paddock Wood. 1.2.7 Moreover, the retail and leisure needs of the borough have been determined through the Retail and Leisure Study (2017), which identified a need for between 21,700 and 34,000 square metres of additional comparison floorspace and between 7,500 and 9,500 square metres of additional convenience floorspace. 1.2.8 The strategy for meeting identified development needs is consolidated by Policy STR1, which sets out the quantum of development that will be allocated within or around settlements to meet the identified needs over the plan period. 1.2.9 In this respect, the strategy seeks to expand Paddock Wood - following garden settlement principles - to deliver housing and employment growth, new and expanded education facilities and provide strategic flood risk solutions. 1.2.10 A new garden village at Tudeley is also proposed, which would deliver circa 2,500 - 2800 new houses (1,900 homes within the plan period) as well as a package of infrastructure measures. The remaining growth would be dispersed proportionately to settlements in the borough. 1.2.11 We support the overall principle of the strategy and consider that Paddock Wood represents a sustainable location to deliver housing and other development needs, through a comprehensive master-planned approach. 1.2.12 Nonetheless, given Paddock Wood Garden Centre’s geographical location to the proposed allocation boundaries, to exclude it from the masterplan area would have a negative impact upon the long term viability of the site. Instead, it should be included within the Paddock Wood site allocation, identified for intensified or new employment/retail provision. | ||||||||||||||||
DLP_7207 | Elizabeth Daley | Local research from the NDP group indicates that the parishioners are against large scale development | ||||||||||||||||
DLP_7209 | Elizabeth Daley | If the ENS is indicating the expansion of existing key employment areas as above, why is such a large proportion of housing being targeted in Cranbrook and Sissinghurst? | ||||||||||||||||
DLP_7210 | Elizabeth Daley | Local research from the NDP group indicates that the parishioners are against large scale development The above statement (TWBC Comment - refers to para 4.40) is belied by the following statement 4.69 The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. | ||||||||||||||||
DLP_7211 | Elizabeth Daley | Why has TWBC not pushed back about housing numbers when 70% of the Borough is AONB? Is it because of the income generated for ‘projects’ by development? | ||||||||||||||||
DLP_7213 | Elizabeth Daley | Houses are needed in the Parish of Cranbrook and Sissinghurst. An independent provider of professional support services has been used to arrive at a figure for housing in the Parish which is a bit less and can be delivered by small scale housing developments and yet this research commissioned by the NDP, has been ignored by TWBC | ||||||||||||||||
DLP_7215 | Elizabeth Daley | Why then are so many houses being built so far from major settlements and train stations? It therefore follows from the above statement that 50% of the residents of new homes in Cranbrook and Sissinghurst will get into a car to commute out of the Borough to work. This cannot be sustainable. | ||||||||||||||||
DLP_7217 | Elizabeth Daley | If the above statement is a policy, then the LBD of Cranbrook and Sissinghurst should NOT be re-drawn. Already, the largest development in the Parish for at least 40 years, has been allocated adjacent to the LBD and therefore justified. The proposal to re-draw the LBD to enclose this development then allows the next largest site to be bought forward using the same justification, against the wishes of the local residents 4.87 Although very close to the LBD boundary, the site at Turnden Farm, Hartley Road, to the south west of Cranbrook has also been excluded at this stage. However, it is anticipated that these sites will be reviewed and refined for the next stage of the Local Plan. | ||||||||||||||||
DLP_7219 | Elizabeth Daley | Little attention has been paid, thus far to high standards of design and place shaping in Cranbrook and Sissinghurst. Developments just completed or nearing Outline and Detailed applications, are a poor pastiche of local vernacular, with cost being an excuse for shoddy design and a top down approach to planning design. I have no confidence that the planning department will enforce high standards, or indeed listen to the community in this respect. | ||||||||||||||||
DLP_7220 | Elizabeth Daley | This is so far from what is happening in Cranbrook and Sissinghurst (which has its own design code) that I find it hard to believe that this will be enforced in any meaningful way. | ||||||||||||||||
DLP_7222 | Elizabeth Daley | Whilst the facilitation of sustainable transport is to be applauded, building so far away from the proposed centres where employment will be targeted cannot possibly reduce private car dependence | ||||||||||||||||
DLP_7224 | Elizabeth Daley | There is mention of a landscape gap ‘between the two LBDs’. I assume, although it is not stated, that the second LBD is the one around Cranbrook. | ||||||||||||||||
DLP_7238 | Elizabeth Daley | When Brick Kiln Farm in Cranbrook was allocated, the developer was told to take a masterplanning approach. This has not happened. I have no confidence that this approach will be enforced by the Planning Department | ||||||||||||||||
DLP_7239 | Elizabeth Daley | There are no new employment opportunities planned alongside the provision of new housing in Cranbrook and Sissinghurst. The only employment created, will be temporary, and only during construction of the allocated sites. | ||||||||||||||||
DLP_7260 | DHA Planning for Barth-Haas UK Ltd | 2.2 Development Strategy and Strategic Policies The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the borough and where such development will be located. In terms of economic development, the National Planning Policy Framework (herein the ‘NPPF’ or ‘the framework’) states that planning policies should help create the conditions in which businesses can invest expand and adapt. Moreover, planning policies should set out a clear economic vision and strategy that plans positively and proactively encourages sustainable economic growth. The Sevenoaks and Tunbridge Wells Economic Needs Study (‘ENS’) was produced in 2016 to inform the plan and make recommendations for the future provision of employment land (Use Classes B1, B2, and B8). It recommended that the Council should plan positively to facilitate economic growth by allocating new sites and identified a need of circa 14 hectares of new employment land to support new opportunities alongside the provision of new housing. It also recommended that the expansion of existing Key Employment Areas would be appropriate. In addition, the retail and leisure needs of the borough have been determined through the Retail and Leisure Study (2017), which identified a need for between 21,700 and 34,000 square metres of additional comparison floorspace and between 7,500 and 9,500 square metres of additional convenience floorspace. The strategy for meeting identified development needs is consolidated by Policy STR 1, which sets out the quantum of development that will be allocated within or around settlements over the plan period. The strategy seeks to expand Paddock Wood by following garden settlement principles, to deliver a significant level of housing and employment growth, new and expanded education facilities and strategic flood risk solutions. It also states that the town centre will be regenerated to provide a vibrant and viable new centre for the communities it will serve. Table 3 of the plan (included as Table 1 below) summarises how the plan will allocate land to meet these identifies needs. In terms of Paddock Wood, it states that retail and other town centre uses will be determined as part of the masterplanning process, and will include convenience and comparison retail provision. Employment uses will also be determined as part of the master-planning process, with Key Employment Areas safeguarded and intensified to provide additional B1/B2 and B8 floorspace.
Table 1: Scale and Distribution of Development within and around Paddock Wood We support the general thrust of the strategy and consider that Paddock Wood is a suitable and sustainable location to deliver housing and other development needs. Further, our client’s site is well placed to contribute toward meeting these needs – in particular the associated retail and employment needs that will arise from an increased population. Therefore, BarthHaas would like to participate throughout the master-planning process. However, the wording of policy STR 3 (Master Planning and Use of Compulsory Purchase Powers) does not make clear whom qualifies as a ‘relevant stakeholder’, and this confusion is compounded further by the wording of the place shaping policies for Capel and Paddock Wood - AL/CA 3 and AL/PW 1. For example, the policy wording (for both policies) states that land is allocated for “ additional employment provision - including expansion of Key Employment Areas ” . It states that the makeup of this employment provision will be informed by the master-planning process. However, it does not make clear whether the use of the term ‘allocation’ refers to the expansion of existing Key Employment Areas (listed by policy ED 1) or newly created development parcels that are earmarked for economic development – parcels 5 (North) and 6 (North East), or both of the above. If the latter is intended, we would urge the Council to reconsider by involving stakeholders like BarthHaas in the master-planning process, particularly where redevelopment can benefit wider plan objectives - such as the revitalisation of the town centre. Not only this, the positive wording of policy ED1 has a similar affect as an allocation, in that it provides in-principle acceptance to redevelopment subject to wider criteria being met. With this in mind, it would seem logical to involve these stakeholders in the master-planning process to ensure development is delivered comprehensively and harmoniously. If the Council intends for landowners in Key Employment Areas to take part, the policy wording should be updated to provide greater clarity on this point. [TWBC: see full representation. See also Comment No. DLP_7242 (Policy STR/PW 1]. | ||||||||||||||||
DLP_7350 | Wealden District Council | Paragraph Number(s): 4.7 to 4.17 (Housing Development) Paragraph 4.7 of the draft Tunbridge Wells Borough Local Plan confirms that based on the projected submission of the Local Plan in 2020, the objectively assessed housing needs for the borough over the plan period to 2036 is 13,560 dwellings (equivalent to 678 dwellings per annum (dpa)), identified by the standard methodology as required by the NPPF. The Plan confirms at paragraph 4.16 that the total capacity of all identified sites (completed houses since 2016, extant planning permissions, retained Site Allocations Local Plan allocations, development through windfall sites, together with new allocations proposed in the draft Local Plan) provides for some 14,776 (net) additional dwellings. Paragraph Number(s): 4.18 – 4.23 (Economic Development) Paragraphs 4.18 – 4.19 of the draft Tunbridge Wells Borough Local Plan states that the Sevenoaks and Tunbridge Wells Economic Needs Study (ENS) recommends that the Council should allocate sites to accommodate at least 14 hectares of new employment land in order to support the creation of new employment opportunities over the Plan period. It is noted that the target of 14 hectares will be reviewed as part of the preparation for the Regulation 19 stage of the Local Plan. | ||||||||||||||||
DLP_7504 | Sarah Parrish | Why use out of date figures? | ||||||||||||||||
DLP_7507 | Sarah Parrish | Why is the distribution of Housing Allocation so uneven throughout the Borough? Why not build on areas of land with no Green Belt, No Flood Plain, No AONB locality and not next to Tonbridge? | ||||||||||||||||
DLP_7508 | Sarah Parrish | Why does TWBC want to ribbon-develop from Tonbridge to Paddock Wood? How can the TWBC ensure agreed levels of affordable housing to Local Resisdents – especially if Hadlow Estates controls the development? | ||||||||||||||||
DLP_7526 | Charterhouse Strategic Land Ltd | Charterhouse Strategic Land Limited (“Charterhouse”) is promoting the land edged ‘red’ on the enclosed site plan. Accordingly, this letter contains our response to the published Tunbridge Wells Borough Council Draft Local Plan: Regulation 18 Consultation. Our representation responds on the emerging Vision and Objectives, the Development Strategy and Strategic Policies and the specific Place Shaping Policies for Paddock Wood. Section 4: The Development Strategy and Strategic Policies We applaud the council for actively seeking to meet their OAN housing figure of 13,560 dwellings (678 dwellings per year) and being proactive in the allocation of strategic sites in order to deliver this. Charterhouse supports the development strategy for Paddock Wood within Policy STR 1. However wish to emphasise the importance of the garden settlement principles and betterment of the community through infrastructure, schools and the creation of strategic flood solutions to reduce flood risk around Paddock Wood. Such considerations have a large influence on how the strategic allocation for Paddock Wood will come forward. And it is essential the Council’s management of the comprehensive approach to masterplanning and the equalisation of land is implemented. In the wider context we fully support the allocation at Paddock Wood and the inclusion of our landholding as part of the allocation. Charterhouse trusts that the above comments will be taken into account and considered constructive in assisting the council to move forward to the next phase of the Local Plan preparation. Charterhouse are pleased to be taking part in the Strategic Site Working Group and masterplanning exercise and look forward to more constructive discussion on this matter with the council and other landholder parties. [TWBC: see site location plan]. | ||||||||||||||||
DLP_7619 | Mr J Boxall | 4.38 The Local Plan states that the development strategy for housing growth needs are based on Option 3 (dispersed growth) and Option 5 (stand alone garden settlement). I agree with this strategy overall but the dispersed growth option does not appear to have been applied fairly or proportionately across the borough. The eastern area of the borough, in particular Cranbrook and Sissinghurst, has much more housing allocated to it compared to a proportionally very small number of houses to be developed in Tunbridge Wells. This is contrary to policy ED 8 which states the hierarchy of development. The Local Plan states that Tunbridge Wells is to be the economic and cultural centre so it should take more housing proportionate to its current population and additional housing due to its economic opportunities than is currently proposed. Given there will no longer be a new theatre then this area could be used to supply affordable housing. Sissinghurst has poor connectivity with Tunbridge Wells due to a slow, infrequent no. 267 daytime only bus service that does not even directly serve the village, or via the infrequent No. 5 bus service and 2 trains via Staplehurst station or via the congested A21 through the often gridlocked village of Goudhurst. 4.39 If housing is to be developed on a dispersed growth basis then employment opportunities through the economic growth strategy should also be on a dispersed growth basis to match increases in population and to minimise additional journeys, via public transport or car. TWBC should not put such large quantities of housing in Sissinghurst and Cranbrook without additional economic opportunities and should have a policy to provide additional business sites, other than those already shown in the Local Plan, in The Weald. This particularly important due to the poor public and road transport system for this area in getting to Tunbridge Wells. 4.40 This states that the growth strategy is based on the premise of infrastructure-led development. Key infrastructure required for additional housing in Sissinghurst includes greater accessibility to Tunbridge Wells on a dualled A21 between Lamberhurst and Blue Boys. This infrastructure is not in place and will not be in place before the housing in this plan is developed so the Local Plan is obviously not infrastructure led. To be an infrastructure led Plan then much more development should be around Tunbridge Wells and the already dualled A21. | ||||||||||||||||
DLP_7621 | Mr James Peace | If the ENS is indicating the expansion of key employment in Tunbridge Wells and Maidstone why is such a large proportion of housing being proposed for Cranbrook and Sissinghurst. | ||||||||||||||||
DLP_7623 | Mr James Peace | Local NDP research indicates that parishioners are against large scale development. The need for such large scale development is not proven. Proposed development in Cranbrook and Sissinghurst is not sustainable in terms of infrastructure and there is no awareness of the valued and protectced landscape. Housing numbers can be delivered with small scale, sustainably designed developments that do not impact AONB landscape. | ||||||||||||||||
DLP_7645 | John Gibson | Section 4 Paragraph 18 The economic needs study (ENS) recommends that the TWBC allocates at least 14 hectares of new employment land in order to support new employment alongside the proposed new housing. No provisions at all have been planned locally for the extra houses being proposed in Sissinghurst. The extra commuting this will generate will result in a further failure to meet the Sustainability objectives. | ||||||||||||||||
DLP_7729 | Peter Smart | Response to para. 4.69 Response to para. 4.70 My above arguments applies to all areas within the borough sitting within the High Weald AONB, area which seem to be disproportionately expected to provide a large number of new homes for the borough, without thought for the where people might work, the impact on the landscape and surrounding roads which are already heavily congested. | ||||||||||||||||
DLP_7755 | Annie Hopper | The description above of intimate, small scale settlements which are characteristic of AONB’s components of natural beauty goes completely against the proposal for large scale development. There should be NO large scale development on AONB to retain its natural beauty. | ||||||||||||||||
DLP_7757 | Annie Hopper | The ENS is recommending no key employment areas in Cranbrook and Sissinghurst therefore why is such a large proportion of housing being targeted there? | ||||||||||||||||
DLP_7758 | Annie Hopper | The draft allocations for Cranbrook and Sissinghurst do not take into account local need which according to the AECOM housing needs assessment 2017 is considerably less than 900 houses. | ||||||||||||||||
DLP_7759 | Annie Hopper | This statement from the NPPF clearly indicates that development numbers can be reduced if there is a risk to valued landscapes – why has TWBC not pursued this in relation to housing numbers given that 70% of the Borough is AONB? 62% of the Parish of Sissinghurst and Cranbrook is AONB yet the large scale developments being proposed are all on AONB. | ||||||||||||||||
DLP_7764 | Annie Hopper | Why are so many houses being built so far from major settlements and train stations? | ||||||||||||||||
DLP_7765 | Annie Hopper | Despite the above statement – there are several sites that could be redeveloped and infilled within the current LBD that are not in the LP draft allocations – instead TWBC have chosen large scale developments to help achieve their numbers as quickly as possible and ignored the opportunity to masterplan the town centre. | ||||||||||||||||
DLP_7766 | Annie Hopper | Para 4.64 There is no evidence in the draft LP that any attention has been paid high standards of design and place shaping in Cranbrook and Sissinghurst. Planning decisions appear to involve many people with no detailed knowledge of the requirements and needs of Cranbrook and Sissinghurst – it is time to listen to the community in this respect. Para 4.65 There is again no evidence that this is being carried out in Cranbrook and Sissinghurst – this sounds like an ‘aspiration’ only intended to tick another box in what is required when writing a local plan. | ||||||||||||||||
DLP_7768 | Annie Hopper | How is this possible when TWBC is advocating building so far away from the proposed employment centres? This cannot possibly reduce private car dependence. | ||||||||||||||||
DLP_7796 | Robert Saunders | General Comment I recognise the need for new dwellings in the parish, and welcome appropriately scaled, high quality developments that respect the intimate settlement pattern of the High Weald AONB, based on Dens and Hursts. Object National planning policy allows for development to be reduced where valued landscapes will be damaged, (NPPF, Para 11.) 62% of the civil parish is designated AONB. Why has TWBC not argued for lower housing allocations to protect the AONB landscape and its communities? Object Cranbrook and Sissinghurst Parish Council have evaluated the parish’s housing need and arrived at a lesser figure than that proposed, and further have evaluated the sites and need for affordable housing. TWBC appear to have ignored these assessments – why is this the case? It appears to be profoundly anti-democratic. | ||||||||||||||||
DLP_7803 | John Bancroft | Paragraph 4.10 - Has a full appraisal taken place of all brownfield sites in the Borough to examine what housing need these can provide? Paragraph 4.09 - Housing need should address both number of new homes and type of new homes. Recent development in rural areas has favoured larger 4/5 bed homes which are out of the reach of local people. This in turn causes migration from the Borough particularly of younger people. | ||||||||||||||||
DLP_7847 | Judith Williams | I find that the "Local Plan" makes terrifying and bewildering reading. | ||||||||||||||||
DLP_7969 | Sharon Pickles | There are no new employment opportunities planned alongside the provision of new housing in Cranbrook and Sissinghurst. The only employment created, will be temporary, and only during construction of the allocated sites. | ||||||||||||||||
DLP_7998 | Richard Pickles | There are no new employment opportunities planned alongside the provision of new housing in Cranbrook and Sissinghurst. The only employment created, will be temporary, and only during construction of the allocated sites. | ||||||||||||||||
DLP_8014 | 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. 4.7 Housing Development. The figures given propose that from 2016 - 2036 a target of 13,560 dwellings (678 per year) should be built. It is stated that this target is based on standard methodology as required by NPPF. I would like to raise a number of points:
4.8 Why does Tunbridge wells not follow the example of Sevenoaks District Council in being not prepared to meet their targets? 4.38 Plan Options. The Council proposes a development strategy to meet housing growth based on: Option 3 - development distributed proportionately across all boroughs, settlements and Option 5 a new freestanding garden settlement. More specifically, this covers 4.40:
Referring to Option 3 which is the part that covers most of the borough and the point just made above about ‘sustainable development of an appropriate scale of smaller settlements’, how can the following be acceptable: Tunbridge Wells Population 48,324 (2011 Census) allocated av 1,271 dwellings Hawkhurst Population 4,991 (2011 Census) allocated av 668 dwellings Here we have a situation where a town with 10 times the population allocates itself less than 2 times the number of dwellings. This is NOT proportionate or appropriate to scale and is even more outrageous when you consider that in terms of all forms of infrastructure and access to rail, road and bus networks, Tunbridge Wells is infinitely more advantaged. How is it also proportionate when Speldhurst which has a population similar to Hawkhurst (4,978 - 2011 Census) has only been allocated 15 - 20 dwellings? | ||||||||||||||||
DLP_8032 | Rose May McAuley | 4.19 You are going to put the new jobs in Tunbridge Wells but we need new jobs here in Sissinghurst especially if there are going to be more people. Where are we supposed to work? There are bar jobs at the Milk House pub, a few paid jobs at Sissinghurst Castle which is a bike ride away along a very dangerous road – we are not allowed to cycle through the woods to get there – the two business in The Street employ their family members. I have to go a mile to work and do not drive. On the money I earn I cannot afford anywhere to live so am still at home aged 30 but there are no other jobs to move on to. We need more work in the village. You are assuming that everyone drives and is happy to travel 40 miles each day for work or go to London and not actually be a part of this village at all. The jobs are going in Tun Wells and the houses are going in Cranbrook and Sissinghurst and Hawkhurst. I do not work in a planning office but this does not make sense to me. 4.38 Cranbrook and Sissinghurst and Hawkhurst are given an unfair burden of new housing estates in this Draft plan and I cannot see why this is. We are at the end of the Borough on the map so well out of the way of Tun Wells and it feels as though we don’t matter. We love where we live and have had many new houses while I have lived here (all my life) but this Plan is simply unfair. Tun Wells as a town should take far more – it will not make much difference there but it will totally change the place we love in Sissinghurst. | ||||||||||||||||
DLP_8096 | Ashley Saunders | Tunbridge Wells Borough Council has interpreted its housing need figure to be 13,560 and then up-scaled it to 14,776. This is despite TWBC having strong grounds to lower its housing need figure due to the large amount of Green Belt and AONB land in the borough. The Ministry of Housing, Communities and Local Government has repeatedly made clear that “the housing need figure is not a mandatory target. Local Authorities should make a realistic assessment of the number of homes their communities need, using the standard method as the starting point in the process. Once this has been established planning to meet that need will require consideration of land availability, relevant constraints and whether the need is more appropriately met in neighbouring areas... The NPPF is clear that only in exceptional circumstances may a Green Belt boundary be altered, through the Local Plan process. Last year we strengthened Green Belt policy in the revised NPPF” You have chosen to accept the government’s housing need for Tunbridge Wells borough based on the standard method of calculation. You know that the ONS 2016 figures show a smaller housing need and that policy will reflect that in due course. You can protect this borough from the destruction of Green Belt and AONB by following NPPF guidelines, but this plan shows no interest in doing so, and in fact is planning for even more housing than your interpretation of the 2014 figures requires. For example, you could save the MGB land at East Capel (Policy AL / CA 3 & AL / PW 1) by choosing a different development option that would require 1,000 fewer houses. Paragraph 11 of the NPPF (revised in 2019) states: “11. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
Paragraphs 11(b)(i) and (ii) are of crucial importance. They provide for TWBC to have a choice in the provision of the objectively assessed 13,560 houses. If provision of these houses is really only possible by sacrificing Green Belt land, as TWBC concede at paragraph of the Non-Technical Summary of their Sustainability Appraisal, then the NPPF makes it perfectly possible for TWBC to say that this is not achievable. TWBC have chosen not to do so. I call for a reduction in the number of houses to be delivered by the Local Plan. | ||||||||||||||||
DLP_8098 | Ashley Saunders | You are proposing a development strategy based on dispersed growth, i.e. proportional distribution of development across all of the borough’s settlements. You imply that you have achieved this, but this is misleading. The Local Plan is almost entirely dependent on the successful implementation of proposed garden settlement in Tudeley (AL / CA 1) and the expansion of Paddock Wood including building on East Capel (AL / CA 3 & AL / PW 1). They form 63% of the new housing. If these sites fail to deliver, then the associated infrastructure that is entirely reliant on developer capital would also never be realised. This appears to stack risk on risk, where both areas of development are inextricably linked and the failure of one would lead to collapse of the other and as a result the whole plan would fail. You refer to Tudeley Village securing a long term option for the borough to deliver the needs of future generations. It is clear from this statement that you intend to add more and more housing to this “garden settlement” in each five year review of future Local Plans. I am seriously concerned that this will be the first step in the longer term destruction of the entire MGB in this part of the Borough. It deserves to be protected and sheltered from development. A garden settlement, should there be one, would be best in the middle of the borough, to make it accessible north and south. It is totally counterproductive to put affordable housing right at the very north of the borough when so many residents live in the south. Put it in the middle of the borough or spread it right across the borough. The developments in Tudeley and East Capel are unsustainable, having a poor road infrastructure and this doing nothing for local employment needs (it will make many local farm workers redundant). It would also put an unfair burden on the residents of Tonbridge and Malling whose infrastructure the new residents will access. ‘The ‘master planning approach’ will come to a grinding halt at the boundaries of Tonbridge, a town whose infrastructure has grown slowly over the last millennium and can hardly be expected to adjust to this challenge imposed on it by the planners of the neighbouring authority. We expect this view to be reflected by TMBC in their response to the regulation 18 consultation. | ||||||||||||||||
DLP_8158 | Myriam Ruelle | Development Strategy: Strongly object The housing need figure of 13,560 is incorrect as based on old ONS figures from 2014, and has even been upped to 14,776. The current (2016) figures are about half of the previous (wrong methodology used in 2014) figures and MUST be revised down. The 2016 figures themselves are also likely to be over what real needs are. The figures must be amended. The NPPF also clearly states the right for the Borough to reject the housing figures: there are very evident adverse impacts that do significantly outweigh any benefits. | ||||||||||||||||
DLP_8159 | Myriam Ruelle | Development Strategy, Section4, paragraph 4.40: Strongly object. Tudeley village must not be considered as a viable option. Firstly, it is surplus to requirement. Secondly it is on Green Belt AND AONB and there are NO exceptional circumstances. Thirdly, it would create a conurbation that would entirely destroy the character of the area. Fourthly, it would destroy rural landscape, local cultural heritage and make environmental concerns worse. It would also be a grave danger to local biodiversity. | ||||||||||||||||
DLP_8260 | Ann Gibson | 4.19 If the ENS is indicating the expansion of existing key employment areas as above, why is such a large proportion of housing being targeted in Sissinghurst? 4.40 There should be no large-scale development unless exceptional need is proven, which it is not in the parish of Sissinghurst. Development proposed in Sissinghurst is not sustainable in terms of infrastructure nor is it “aware of the valued and protected landscape”. | ||||||||||||||||
DLP_8341 | Joe Matthews | TWBC: correspondent submitted the following comments on 20/11/19, after the close of consultation on 15/11/19: Paragraph 4.18 The ENS (Economic Needs Study) recommended that the Council should allocate sites to accommodate at least 14 hectares of new employment land (taking into account any residual capacity of existing employment allocations) to 2035 in order to support the creation of new employment opportunities alongside the provision of new housing, helping to reduce out-commuting from the borough over the plan period. This target will be reviewed as part of the preparation of the Regulation 19 Pre-submission version of the Local Plan There are no new employment opportunities planned alongside the provision of new housing in Cranbrook and Sissinghurst. The only employment created, will be temporary, and only during construction of the allocated sites. | ||||||||||||||||
DLP_8369 | DHA Planning for Mr and Mrs B Gear | 2.3 Development Strategy and Strategic Policies (Policy STR1) 2.3.1 The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the borough and where that development will be located. 2.3.2 In terms of the amount of housing, paragraph 59 of the NPPF states that to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed. Further, to determine the number of homes needed, strategic policies should be informed by a local housing needs assessment conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. 2.3.3 The Council confirm that their housing need target for the plan period 2016-2036 is 13,560 dwellings (678 dwellings per annum), which is calculated using the Governments standard method and the 2014-based household projections. 2.3.4 In terms of the different supply components, the Council consider that the Local Plan must (as a minimum) include additional allocations to accommodate 7,593 homes. This figure was formulated taking into account; completions since April 2016 (1,552); extant planning permissions (3,127); outstanding site allocations (588) and a windfall allowance (700 dwellings). The Council have applied a 10% non-delivery rate to these figures to err on the side of caution and consider that the plan would exceed the minimum housing requirement if all of the supply components were achieved. 2.3.5 We agree that TWBC is capable of meeting its need in full and support this approach to plan-making. Likewise, we support the general thrust of the development strategy, which proposes a strategy to meet the housing needs of the borough with a dispersed growth approach. Nonetheless, we have concerns regarding the deliverability of the strategy and the potentially over optimistic housing trajectory, particularly in respect of the delivery from key strategic sites (as outlined below). 2.3.6 We note that the emerging strategy is consolidated by Policy STR1, which sets out the quantum of development that will be allocated within or around settlements to meet the identified needs of the borough over the plan period. This strategy would seek to meet the majority of the Council’s housing need through the strategic extension of Paddock Wood and via a new Garden Village at Tudeley. The remaining growth would then be dispersed proportionately to other settlements in the borough. 2.3.7 We support the general principle of proportionately spreading the benefits of growth. Adopting a pattern of dispersed growth approach would allow a number of sites to be developed at the same time, serving different segments of the local housing market, which is preferable to saturation of the market in a single area. 2.3.8 Nonetheless, we have some concerns regarding the balance between strategic and non-strategic scale allocations and the anticipated delivery trajectory. For example, 65% of new allocations would be delivered as part of the strategic extension to Paddock Wood (4,000 homes) and the new Garden Village at Tudeley (1,900 homes within the plan period), both of which require a fully master-planned approach, which is a time-consuming process. Furthermore, there are a significant number of existing commitments within Paddock Wood that have been slower at coming forward than had originally been envisaged. A cautious approach is therefore needed. 2.3.9 In this regard, we would draw the Council’s attention back to the 2016 document published by Nathaniel Lichfield’s and Partners (NLP) - ‘Start to Finish: How Quickly do Large-Scale Housing Sites Deliver’, which provides evidence pertaining to the speed and rate of delivery of large-scale housing, based on a large number of sites across England and Wales. It identifies that the average lead in time for the submission of a planning application is 3.9 years, from the date the site is first identified. In terms of the planning approval period, for larger scale sites (2,000 + homes) this is circa 6 years. After planning permission is granted, larger sites start to deliver within a year and the average build out rate thereafter is 161 dwellings per annum, although it can be as high as 301 dwellings per annum. 2.3.10 On the basis of this research, if the Local plan is adopted by 2021, planning permission approved by 2023 and delivery commences within 6 years (2029), the likely deliver for the plan period would be no more than 966 homes. 2.3.11 Despite this evidence, TWBC has set a much more optimistic trajectory for delivery of Tudeley Garden Village and the strategic extension of Paddock Wood, which is detailed in the Housing Trajectory Paper. The Council forecast that the Tudeley Garden Village will begin to deliver homes from 2025/26 onward, with an initial build out rate of 150 dwellings per-annum, rising to 200 dwellings per annum from year 6 onward. Likewise, the Council suggests that the extension to Paddock Wood will start to deliver in 2024/25 at an average build out rate of 333 dwellings per annum – which is nearly double the average rate for larger schemes identified in the NLP document. This higher build out trajectory is predicated on an assumption that there would be a number of house builders involved the construction of different parts/phases. However, by their own admission, TWBC do not currently know who or how many housebuilders will be involved. 2.3.12 Taking the above into account, our view is that the Council have applied overly optimistic development trajectory for the delivery of strategic sites, both in terms of the start date for completions and the expected build out rates. Accordingly, we would encourage the Council to increase the balance of small and medium sized sites, which can deliver quickly and usually require limited intervention to infrastructure. Furthermore, it is essential that draft allocations such as our clients are retained and encouraged given the advancement of planning applications emphasises the deliverability of the land. 2.3.13 Given the absence of any similar scale strategic sites in Tunbridge Wells Borough as a point of comparison, one could have regard to similar scale delivery in neighbouring authority Tonbridge and Malling Borough. In this respect, we provide evidence below of its three key strategic sites and the associated delivery rates (derived from the Tonbridge and Malling BV Annual Monitoring Report 2017). 2.3.14 Kings Hill is an extremely prudent example to consider in the context of the Paddock Wood extension and new garden village at Tudeley, how deliverable this would be. Indeed, Kings Hill was a new village started in 1989 near land previously occupied by RAF West Malling. The concept was for a multipurpose site of both residential and office business space. The development is still being delivered some 30 years later, despite having multiple national housebuilders delivering different phases concurrently. Based on the most up-to-date delivery data for the last decade, Kings Hill has only delivered 131 dwellings per annum, despite multiple developers delivering concurrently. Furthermore, the earlier delivery phases we delivered at lower rates given the need to front load infrastructure. 2.3.15 Therefore, we consider that whilst some development may come forward in the plan period from the two proposed strategic sites, in reality these strategic allocations are longer terms aspirations that will extend beyond 2036. 2.3.16 Accordingly, we would encourage the Council to increase the balance of small and medium sized sites, which can deliver quickly and usually require limited intervention to infrastructure, particularly settlements such as Benenden and to reduce the reliance upon Tudeley within this current plan period. |
Table 1 Housing Need 2016-2036 (as at 01 April 2019)
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_2552 | Ms S Daniels | The time has surely come to object in the strongest terms to the amount of housing expected of this area. We are in an area of outstanding natural beauty with a high degree of green belt designation (which you are ignoring at Capel/Tudeley). There are limits to growth and are fast approaching them. Just how much of the expected housing need is coming from local people? And I do not mean "just" social housing. Most of the drivers for housing demand is in fact from Londoners looking to cash in on our housing market. Why should we have to supply their demands? The housing that has been built in the town in recent years is over-weighted to flats or "town houses" that have tiny gardens and are cheek-by-jowl with their neighbours. Quality is fair to poor, insufficient detail is paid to climate-proofing these dwellings for the future, and few have any architectural merit. Even if the town had the space to accommodate this quanity of new dwellings, the necessary infrastructure to support these new residents from cradle to grave, to enable them to move easily around town and its environs, and to have sufficient clean water and clean air is not sufficiently factored in to the local plan. |
DLP_4653 | CBRE Ltd for Dandara Ltd | Housing Need 3.11 The Draft Local Plan sets out an Objectively Assessed Need (‘OAN’) for the borough of 678 dwellings per annum (based on the 2014-based population projections using the standard methodology), which over the 20-year Plan period amounts to 13,560 dwellings. Of this housing target, taking into account completions, extant permissions, existing allocations and a windfall allowance, it confirms that additional allocations are needed – as a minimum – to provide 7,593 new homes as set out in Table 1 below: [TWBC: see Table 1 on page 35 of Draft Local Plan]. 3.12 It is noted that TWBC’s latest housing target is double the existing Core Strategy target of 300 dwellings per year, and therefore represents a significant challenge in terms of needing to markedly increase housing delivery. 3.13 To ensure delivery of the outstanding requirement for some 12,000 dwellings (as at 1st April 2019), TWBC considers it appropriate to make some allowance for the delay and/or nondelivery of a proportion of the identified sites. 3.14 TWBC considers that the total capacity of all identified sites (outstanding planning permissions, retained Site Allocations, together with new allocations proposed in the Draft Local Plan) provides for 14,776 net additional dwellings (as shown in the Cumulative Housing Completions 2016/17 to 2035/36 column of TWBC’s housing trajectory). This compares to a minimum requirement of 13,560 dwellings, thereby amounting to an oversupply of 1,216 homes (8.23% not 9% as incorrectly stated in the Draft Local Plan: paragraph 4.16 [2 Tunbridge Wells Borough Council: Tunbridge Wells Borough Local Plan: Draft Local Plan Regulation 18 Consultation Draft (September 2019) Pg. 35.]). 3.15 Dandara considers that the OAN should be clearly expressed as minimum target, consistent with paragraph 73 of the NPPF. 3.16 TWBC’s Housing Supply and Trajectory Topic Paper (September 2019), confirms that independent of TWBC recently updating its 5 year housing land supply position (5YHLS) for 2018/19 which identified that the Council, inclusive of a 5% buffer as determined by the Housing Delivery Test, does not have a 5 year housing land supply, but rather 4.69 years. 3.17 In applying the housing delivery test, TWBC has applied a 9% buffer as part of the total delivery target of 14,776 dwellings to be delivered up to 2036. In the interests of managing housing delivery uncertainty, and building in more resilience over time into the new Plan, Dandara suggests that TWBC should build in a larger buffer, closer to 20%, which may be particularly important if there are delays to delivery, not least relating to Tudeley Village as a garden village settlement. This will ensure the Plan has been “positively prepared” and the housing strategy is robust in accordance with Paragraph 35(a) of the NPPF. 3.18 Dandara acknowledges TWBC’s position in terms of its identified housing need, which brings into sharp focus the importance of including new allocated sites in order to contribute to the scale of growth required, in a way that is sustainable. Dandara further emphasises the importance of including a range of sizes and types of allocated sites in the interests of spreading growth throughout the borough, and to ensure continued delivery of housing supply across the Plan period. 3.19 Dandara will support TWBC by promoting their sites in which they hold a land interest for the delivery of new homes to contribute towards meeting their housing targets. [TWBC: see full representation]. |
DLP_3685 | Lynne Bancroft | The housing need (row 1) is based on the 2014 household projections. It is now 2019 so this may already be out of date. What would the projections be with updated figures and the estimate of population change given the forthcoming Brexit? What is the calculation used by TWBC to get to Row 1? The planning permission for the 60 homes at Bloomsbury Gardens, Common Road, Sissinghurst was only given on appeal on 21st March 2016 so these properties should be within the number in Row 2 – completions April 2016 to March 2019 and therefore should be discounted from the number of homes (100-115) required in Sissinghurst in this Local Plan. The 9 houses to be developed in Cobnut Close has also not been deducted from these numbers. |
DLP_2867 | Chris Gow | Economic development My previous comments apply: The studies that underpin the strategy are out dated and the current economic climate is changing rapidly, and assertions from the studies should be regarded with suspicion. A look at the economy in other areas demonstrates the idea of perpetual growth is a flawed concept, and future projections should be based on zero growth or even a contraction of the economy. Earmarked retail areas should be considered for housing development, which better serves the community. |
DLP_7671 | Mr J Boxall | The housing need (row 1) is based on the 2014 household projections. It is now 2019 so this may already be out of date. What would the projections be with updated figures and the estimate of population change given the forthcoming Brexit? What is the calculation used by TWBC to get to Row 1? The planning permission for the 60 homes at Bloomsbury Gardens, Common Road, Sissinghurst was only given on appeal on 21st March 2016 so these properties should be within the number in Row 2 – completions April 2016 to March 2019 and therefore should be discounted from the number of homes (100-115) required in Sissinghurst in this Local Plan. The 9 houses to be developed in Cobnut Close has also not been deducted from these numbers. |
DLP_6190 | Turley for Bellway Homes Strategic | Housing Requirement and Supply Table 1 of the draft Local Plan indicates that a total of 13,560 dwellings are required in the Borough between 2016 2036. Paragraph 4.7 of the Plan explains that this is calculated on the basis of 678 dwellings per annum to reflect the ‘standard method’. The requirement is to be achieved via the following sources:
The draft Local Plan indicates that these sources of supply leave a minimum still to be identified of 7,593 dwellings. We agree that the ‘standard method’ should be used to calculate the Local Housing Need figure (unless an alternative approach could be justified) in accordance with paragraph 60 of the NPPF 2019. It is clear from the ‘Housing Needs Assessment’ Topic Paper (August 2019) that the Council has applied a ‘cap’ to reflect the Planning Practice Guidance when calculating the Local Housing Need Figure. The Topic Paper indicates that if this cap were not applied then the Local Housing Need figure would equate to 749 dwellings per annum in order to reflect an uplift to reflect affordability. The Housing Needs Assessment Topic Paper itself therefore acknowledges that the level of growth planned in the emerging Local Plan is not at a level which would address the inherent issues of affordability. The Topic Paper acknowledges that house prices continue to increase and are relatively high for Kent, with affordability ratios also “relatively high”. On this basis, Bellway consider that the housing requirement should be increased in order to help tackle the identified issues of housing affordability in the Borough. In the event that the housing requirement is not increased in this manner then this only heightens the imperative of ensuring that the Local Plan establishes a planning policy context, by virtue of the sources of supply, allocations and distribution strategy which ensures that the planned level of growth can be achieved. Notwithstanding the comments set out above, Bellway have significant concerns regarding the approach which the Council is pursuing to meet the housing needs in the Borough. Windfalls Irrespective of whether or not a windfall allowance is justified, and the extent of the allowance, Bellway note that the Council expects 700 dwellings (50 per annum) to be delivered from this source. This equates to nearly 10% of all the remaining housing to be delivered once existing commitments have been discounted. Since the total supply envisaged by the Local Plan exceeds the requirement by 9%, this reliance on windfall sites represents a significant risk to the overall requirements being achieved if any other sources of supply were to slip or be delayed. Given the concern set out above, we consider that the Council should plan for greater flexibility in the event that sites/sources of supply do not deliver as expected. Housing Trajectory The ‘Housing Supply and Trajectory’ Topic Paper explains that the Local Plan makes provision for 14,776 dwellings during the Plan period (including existing commitments) (a buffer of 1,216 compared to the standard method requirement of 13,560). On the basis of Table 18 in that Topic Paper, we assume that this figure is calculated on the assumption that all extant permissions, existing site allocations, windfall sites and new allocations deliver as expected in the trajectory. The ‘Housing Supply and Trajectory’ Topic Paper indicates that the 4,000 dwellings at Paddock Wood/Capel are expected to be delivered from 2024/2025 and at a consistent rate of between 333/334 dwellings per annum until 2036. We consider that the Council has been overly optimistic over the lead in time before this scheme is delivered and then the subsequent rate of housing completions for the reasons set out below:
The Lichfield report ‘From Start to Finish’ identifies average ‘lead in times’ of close to 7 years for sites larger than 2,000 dwellings. The LPA’s assumptions are that the site delivers less than 4 years from when they expect the Local Plan to be adopted. This lead in time is extremely optimistic and fails to reflect the complexities of delivering large scale strategic residential sites including land assembly, the preparation of SPDs, the preparation and determination of (complex) applications, reserved matters, conditions and infrastructure delivery. In opinion, the lead in time should therefore be extended. If the delivery of housing from the Paddock Wood/Capel allocation were delayed until 7 full years after the adoption of the Plan, that would suggest the first dwellings would be completed in 2027/28, three years later than expected by the Council. The effect of this would be to remove 1,000 dwellings from the supply. Removing 1,000 from the housing trajectory would decrease supply to 13,776, representing a buffer of 256 against the overall housing requirement.
The fact that there is such uncertainty regarding the deliverability and timescales for the strategic scale development envisaged at Paddock Wood/Capel is of significance since 4,000 dwellings represents more than a quarter (27.08%) of the total expected supply to 2036. Our comments in relation to the lead in time and average completion rates both result in 1,000 dwellings being removed from the supply in their own right (i.e. without regard to wider considerations). Combining these two considerations (applying a more reasonable assumption to delivery rates, with commencement in 2027/28 at the earliest, and a more reasonable approach of 250 dwellings per annum) would result in 2,250 dwellings (1,750 fewer than the Council envisages) delivered from this allocation by 2036. This could have very severe consequences for the achievement of the housing requirement overall. Removing 1,750 dwellings from the Paddock Wood/Capel allocation by 2036 would result in 13,026 dwellings being delivered in that period (assuming all other allocations and sources of supply deliver as expected). This would represent a shortfall of 534 dwellings against the overall planned housing requirements. The ‘Housing Supply and Trajectory’ Topic Paper indicates that 1,900 dwellings at Tudeley Village are expected to be delivered from 2025/2026 and at a rate of between 150 – 200 dwellings per annum until 2036. We consider that the Council has been overly optimistic over the lead in time before this scheme is delivered and then the subsequent rate of housing completions for the reasons set out below:
The Lichfield report ‘From Start to Finish’ identifies average ‘lead in times’ of close to 7 years for sites larger than 2,000 dwellings. The LPA’s assumptions are that the site delivers less than 5 years from when they expect the Local Plan to be adopted. This lead in time is extremely optimistic and fails to reflect the complexities of delivering large scale strategic residential sites including land assembly, the preparation of SPDs, the preparation and determination of (complex) applications, reserved matters, conditions and infrastructure delivery.. In opinion, the lead in time should therefore be extended. If the delivery of housing from the Tudeley Village allocation were delayed until 7 full years after the adoption of the Plan, that would suggest the first dwellings would be completed in 2027/28, two years later than expected by the Council. The effect of this would be to remove 300 dwellings from the supply.
In isolation the alterations referred to above to Tudeley Village scheme may not result in housing delivery falling below the overall requirements, assuming that it does indeed come forward and at the rate envisaged by the Council. More significant alterations to those referred to above could have dramatic consequences on the achievement of the overall housing requirement (irrespective of any other alterations made to supply). In combination the reduction in supply from Paddock Wood/Capel (1,750 dwellings) and Tudeley Village (300 dwellings) would remove 2,050 dwellings from the overall housing trajectory and lead to a shortfall of 800 dwellings against the planned housing requirement of 13,560 dwellings (without any other alterations and without any consideration being given to the suitability/sustainability of those allocations). These comments demonstrate that, without evidence to support the claimed lead in times or completion rates, the Council is overly reliant upon two sites to achieve the planned housing requirement to 2036. Additional flexibility and sources of supply are therefore required. Revising the current housing trajectory to reflect fairly modest amendments (delaying Paddock Wood/Capel by three years and Tuneley Village by two years and more realistic delivery rates) alone results in a significant undersupply of housing against the capped figure derived from the standard method. Other alterations, such reductions in the windfall allowance or reductions in the supply from other allocations/commitments would increase the extent of that shortfall. As currently prepared, the Local Plan does not represent a vehicle by which the planned housing requirements will be achieved. In contrast, the Plan will result in an undersupply of housing. This is likely to have severe consequences for the Council’s ability to demonstrate a rolling five year supply of deliverable housing sites. This is compounded by the reliance on two large sites (1,900 at Tudeley Village and 4,000 at Paddock Wood delivering 5,900 in combination) represents 77% of the remaining level of housing expected during the Plan period (7,593 dwellings). Accordingly, we consider that it is essential that the Council allocate a greater range and diversity of sites for residential development to ensure that the housing requirement of the Plan can be achieved. Bellway reserve the opportunity to comment on the Council’s housing trajectory, including the other sites proposed for residential allocation, in more detail as the Local Plan progresses. Meeting Affordable Housing Needs The Housing Needs Assessment Topic Paper (paragraph 45) explains that: “The Council’s SHMA, 2015 found that the borough would need 341 affordable homes per annum to meet their housing needs and be eligible for affordable housing.” The Housing Needs Assessment Topic Paper (paragraph 47) explains that: “A separate Housing Need Study, in 2018, assessed affordable requirements by taking into account the need from existing and newly forming households within sub areas of the borough of Tunbridge Wells, and comparing this with the supply of affordable housing. Against a gross need for affordable housing of 662 dwellings each year, when the likely annual affordable supply is taken into account, the overall net imbalance is 443 affordable dwellings each year.” Paragraph 48 of the Topic Paper concludes that: “The corrected affordable housing need over a 15 year period, based on the HNS estimate, is actually 391 dwellings/year.” Over a fifteen year period from 2021 – 2036, an affordable housing need of 391 dwellings per annum would equate to 5,865 dwellings. Policy H5 of the draft Local Plan expects all greenfield sites over more than 9 dwellings to deliver a minimum of 40% affordable housing. For the sake of ease, if 40% of all 7,593 dwellings required to achieve the overall housing requirement (13,560) were delivered as affordable housing, that would provide 3,037 affordable dwellings (significantly fewer than need acknowledged by the Council). However that approach misrepresents the supply of affordable housing bearing in mind the different requirements applied by Policy H5. In addition to the comments set out above, we note that the draft Plan does not establish the level of affordable housing to be delivered from the Paddock Wood/Tudeley Village allocations, with this left to a later stage (Regulation 19 of the Local Plan being prepared) and based on the Local Plan and CIL Stage 2 Viability Assessment. These two sites (alone and in combination) represent by far the greatest sources of housing supply envisaged in the Borough to 2036 and as such the Local Plan should clarify the quantum of affordable housing that they are expected to provided. Without such information conclusions cannot be reached about the extent to which the Local Plan will meet affordable housing needs. On the basis of these comments alone, we consider that the Local Plan fails to represent a positive approach to addressing the need for affordable housing in the Borough. It should also be noted that the provision of affordable housing to 2036 would also be reduced in the event that the strategic allocations at Paddock Wood/Capel or Tuneley are delayed, do not achieve the delivery rates envisaged by the Council or if the further work in support of the Local Plan/CIL indicates that the sites themselves should provide fewer affordable dwellings than might otherwise be expected. [TWBC: see full representation and Comment Numbers DLP_6189-6198]. |
DLP_6822 | Persimmon Homes South East | Housing Requirement 2.2 Table 1 of the Reg 18 plan identifies the housing need for the period 2016 – 2036 to be 13,560 dwellings (678dpa). This is said to be based upon the standard methodology (2014 based household projections (published July 2016)), projected household growth in Tunbridge Wells for the period 2019-2029 and the affordability ratios published in April 2019. Whilst we believe the figure to be 682dpa, we note para 3.2.1 of the Housing Topic Paper (HTP) suggests the figure of 678 is being used as it is based upon submission in 2020. This being the case the plan when submitted needs to be clear on this point and all associated calculations clarified accordingly. We also believe, for the reasons set out below, that the plan period should also be amended and start in 2020 not 2016 as drafted. |
Table 2 Local Plan Options (Issues and Options consultation 2017)
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_113 | Catherine Catchpole | The plan gives 5 options which make some sense. However it gives no justification for the option chosen - it appears that the options chosen have been driven by the availability of the call for sites rather than any sensible objective assessment. The dualling of the A21 to Tunbridge Wells has massively improved the traffic issues especially heading north to London. It would make logical sense to capitalise upon this improvement by focusing development on the A21 corridor north of Kippings Cross (where the A21 reverts to single carriageway again). |
DLP_1728 | Peter Hay | I find the process mandated by the Council for commenting on the Draft Local Plan to be extremely poor and ill thought out. 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 or by those who are competent 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. Failure to consult The limited consultation - in Hawkhurst only one weekday session between 4 - 7pm when many residents could not attend to offer their views The limited access to the online consultation – not on TWBC home page and hidden “four clicks” away buried in planning section of website A complex consultation form to complete that many residents have found baffling |
DLP_2215 | Rosanna Taylor-Smith | Option 1 I disagree with the classification by TWBC that Hawkhurst is classified by as a MAIN SETTLEMENT. It is a VILLAGE. The failure by TWBC to correctly identify Hawkhurst as a 'Village' results in the incorrect implementation of urban planning policies. |
DLP_2029 | Terry Everest | Table 2 Local Plan Issues and Options Option 3 is clearly the best approach ( and this has been recognised I note) However Option 5 should not be included as per my response to the vision, in addition I will say this - when it is recognised that Green Belt and AONB needs to be protected and is becoming scarce - why plan to take 5% and build on it at all? That approach will result ultimately in the destruction of all green belt land within around 340 years. Future generations will look back and see how successive portions of precious countryside were nibbled and bitten away by the arbitrary demands of government housing need and local authorities trting to be progressive - when instead a truly sustainable balanced approach with reduced development could still deliver on the true needs of the borough whilst actually safeguarding the environment and countryside for future generations. |
DLP_2446 | Tracy Belton | I do not agree that the allocation of dwellings has been spread evenly across settlements. Horsmonden has far more than the villages surrounding it. Horsmonden is not on a main train line, or have better transport links or facilities than any of the surrounding villages. Horsmonden has been allocated nearly as much as Penbury which is a much bigger settlement. Paddock Wood is not on the A21, Lamberhurst is and much more housing has been allocated to Paddock Wood. Lamberhurst has not ben allocated much at all, so the focus cannot be around the A21! |
DLP_2351 | Sarah Coulstock | There is too much development in the Local Plan for a rural area with much of it in AONB – TWBC should challenge the housing target it has been given in view of this & get it reduced. The number of new dwellings proposed for the parish of Brenchley & Matfield is too high. All of proposed development is in Matfield – Brenchley should share the burden & take at least half, especially as has a school, 2 shops, a post office, a doctor’s surgery & a dentist. The Limits to Build Development should not be changed; it should be strengthened to prevent or severely restrict any more intrusive inappropriate development within the Parish. The dark skies, wildlife, landscape & rural character need to protected against the destruction of the surrounding countryside & the detrimental impact on the High Weald AONB. The amount of development suggested in the AONB is contrary to the objectives of the High Weald AONB Management Plan & the TWBC’s statutory duty to conserve & enhance the High Weald AONB. The proposed extra housing would put additional pressure on already stretched infrastructure & services, both within the parish of Brenchley & Matfield, & in the borough. I understood that TWBC had previously favoured focused growth in sustainable locations, however, the Local Plan is for dispersed growth in places with poor infrastructure & facilities, which are therefore not sustainable. The proportional development distribution proposed in the Local Plan is unfairly distributed, with some areas expected to suffer a higher volume of development than is appropriate. |
DLP_2869 | Chris Gow | Green Belt land must be preserved for the benefit of everyone. It is an easy option for a developer, and should be resisted. Once Green Belt land is released for development, it will be hard to restrict wholesale loss of this valuable amenity land. The benefits are not just for amenity of locals, but for eco preservation, and should be preserved to meet the Plan Vision and Objectives 2 in paragraphs 6 and 8, and Paragraph 2.40. |
DLP_2868 | Chris Gow | The "call for sites" is led by the developer motive for profit, and not for the benefit of borough residents, and so should be treated with some suspicion. The need for development should be led by the members of the community for the benefit of the community, rather than the need for profit. |
Figure 4 Key Diagram
Comment No. | Name/Organisation | Response |
|---|---|---|
DLP_46 | Thomas Weinberg | Comments on The Key Diagram (Figure 4, Section 4) p.41 |
DLP_128 | Gregg Newman | Comments on The Key Diagram (Figure 4, Section 4) p.41 The scale of your drawings is questionable at best, manipulative and misleading at worst. Note again that Horsmonden would have better suited the actual size of the planned development. |
DLP_723 | Dr P Whitbourn | Given that some 75% of the borough is within an Area of Outstanding Natural Beauty or Green Belt or both; that its only large town is a major historic town of natural significance; that a number of smaller settlements and villages are of historic interest too; that some of the areas outside the AONB and Green Belt are within flood plains; and that some parts of the borough are not well served by public transport, the Borough of Tunbridge Wells is an exceptionally difficult one in which to locate new housing and other development without causing serious harm. Thus the council is, in effect, faced with an impossible task of attempting to devise a Local Plan on the basis of large new housing numbers, dictated to it by central government, without resulting in serious damage to an outstanding environment. One might hope that central government might be mindful of this problem, and adjust housing requirements so that higher numbers can be absorbed where harm will not be caused, and lower numbers allocated to those areas where serious environmental damage would otherwise be caused. The starting point of the Plan should therefore be a thorough questioning of any housing figures handed down by central government, to ensure that environmental damage or irresponsible development in a flood plain is kept to an absolute minimum. Previous Local Plans have sought to defend the countryside by directing new development to the town of Royal Tunbridge Wells. Such a policy did make a certain amount of sense in times past, when "brown field" sites such as the former gas works and hospital sites were becoming available. However, as sites of that kind have now been used up, such a policy clearly cannot be expected to continue, and the time has come for a fresh approach to this intractable problem. I think, therefore, that there is now a case for seriously considering the adoption of the proposed "dispersed growth" option 3. The "garden village" option 5 could be an interesting one, although it is hard to see an uncontroversial location, in view of the many constraints just mentioned. The Key Diagram (Figure 4) illustrates the way in which the preferred option 3 might work, together with option 5, but on the basis of a very high housing figure that ought to be vigorously challenged. |
DLP_855 | Ian Pattenden | Comments on The Key Diagram (Figure 4, Section 4) p.41 The circle representing housing on Tudeley is misleading, it should show a circle representative of 1,900 new houses but is only a little bigger than the key circle showing 1,000 housing units. Another example of TWBC Planners being economical with the truth. The depiction of Green Belt land and AONB land on this map is very helpful. It demonstrates, yet again, that the garden settlement should be in Horsmonden. Tudeley should not have been shortlisted when you have a suitable site outside of the AONB and Green Belt. Furthermore, there are areas to the NE of the borough without any AONB or green belt restrictions. You use the excuse that the land did not come forward in the call for land; but so far as I know there was no proactive effort to talk to landowners, or consideration to apply CPOs yet CPOs are considered likely in the Tudeley plans. |
DLP_881 | Anna | Difficult to understand the granular level impact (i.e. in terms of exact geographic divisions). |
DLP_1026 | Mr and Mrs Copping | We spent a great deal of time and effort trying to find Figure 4 within The 545 page draft Local Plan Regulation 18 consultation draft 20th September to 1st November 2019 So cannot comment on it |
DLP_1028 | Liz Copping | I couldn’t find Figure 4 within the 544 page Draft Local Plan – Regulation 18 Consultation Draft - 20 September to 1 November 2019. |
DLP_1627 | Maggie Fenton | The Key Diagram (Figure 4, Section 4) p.41 The depiction of Green Belt land and AONB land on this map is very helpful. It demonstrates, yet again, that the garden settlement should be in Horsmonden or Frittenden. North East of the borough is served by less congested A roads & is free of MGB, AONB and flood risk constraints |
DLP_1792 | Sacha Reeves | I am very concerned about the impact of the property developments proposed for the Tudeley area, as shown on the "Key Diagram". The "Draft Local Plan" makes inadequate propoasls to deal with the additional strain that would be placed on nearby services and infrastructure. In particular, road traffic and rail passenger volumes are not adequately considered. The plan should include specific, detailed provision for addressing these issues to ensure that a very significant negative impact on the Tonbridge area is avoided. |
DLP_2008 | Dr David Parrish | The Key Diagram (Figure 4, Section 4) p.41 There are no detailed plans – TWBC cannot be sure of enough land being available The TGV site is out of scale. The required housing will need much larger area. The map also shows the larger North, North East swathe of land that should be the Plan A of choice – where no flood plain, no Green Belt, no AONB exist. Capel has all of these restrictions. It also shows the lack of fairly dispersed allocations. |
DLP_2069 | Canterbury Diocesan Board of Finance Ltd | The Vicarage site is a highly sustainable location for development which relates to the built- up part of Cranbrook, unlike a number of new housing allocations which are entirely separate from the settlement. The Key Diagram should be amended to include Cranbrook Vicarage as a formal allocation for housing development within the defined Limits to Built Development as shown on the existing Proposals Map adopted formally by TWBC in July 2016. The removal of the current housing site allocation at Cranbrook Vicarage cannot be justified having regard to the principles of sustainable development as set out in the National Planning Policy Framework. The housing allocation should be reinstated to reflect the sustainability credentials of the locality which are vastly superior to some of the Draft allocations which lie in open countryside remote from community services and facilities and public transport provision. The retention of the Vicarage within the Limits to Built Development (see above) on the Draft Proposals Map is entirely appropriate but the removal of the housing allocation cannot be justified on planning grounds. So, the allocation in the current local Plan should be retained. |
DLP_2350 | Sarah Coulstock | There is too much development in the Local Plan for a rural area with much of it in AONB – TWBC should challenge the housing target it has been given in view of this & get it reduced. The number of new dwellings proposed for the parish of Brenchley & Matfield is too high. All of proposed development is in Matfield – Brenchley should share the burden & take at least half, especially as has a school, 2 shops, a post office, a doctor’s surgery & a dentist. The Limits to Build Development should not be changed; it should be strengthened to prevent or severely restrict any more intrusive inappropriate development within the Parish. The dark skies, wildlife, landscape & rural character need to protected against the destruction of the surrounding countryside & the detrimental impact on the High Weald AONB. The amount of development suggested in the AONB is contrary to the objectives of the High Weald AONB Management Plan & the TWBC’s statutory duty to conserve & enhance the High Weald AONB. The proposed extra housing would put additional pressure on already stretched infrastructure & services, both within the parish of Brenchley & Matfield, & in the borough. I understood that TWBC had previously favoured focused growth in sustainable locations, however, the Local Plan is for dispersed growth in places with poor infrastructure & facilities, which are therefore not sustainable. The proportional development distribution proposed in the Local Plan is unfairly distributed, with some areas expected to suffer a higher volume of development than is appropriate. |
DLP_2832 | Helen Parrish | Cross-referenced, detailed, reasons for my Objection: The Key Diagram (Figure 4, Section 4) p.41 There are no detailed plans – TWBC cannot be sure of enough land being available |
DLP_2968 | Michael Alder | Comment already made in earlier sections should be reviewed. [TWBC: See comments DLP_2962-2967] |
DLP_3033 | Jacqueline Prance | Too big a site - too vague a proposal |
DLP_3722 | Capel Parish Council | The Key Diagram (Figure 4) is misleading. The circle representing proposed housing in Tudeley (Policy AL / CA 1) is not big enough. It should show 1,900 new houses and is only a little bigger than the key circle showing 1,000 housing units. It is understood that the large blue arrows are intended to signify options for a ‘Proposed Link Route’ between the proposed site at Tudeley (AL / CA 1) and either the A228 between the Badsell Roundabout and the Hop Farm (the higher arrow) or the proposed offline A228 strategic link or ‘Colts Hill bypass’ (the lower arrow). This diagram suggests that either option is being considered, which is what we were told by TWBC Head of Planning, however, it is clear from the SWECO Transport Map with proposed Local Plan Mitigation Interventions (Table 9.2 and Figure 9.2 of the Local Plan Transport Evidence Base which forms part of the supporting documents that Transport Strategy) that Scheme No. 203 comprises a ‘Link road to new Colts Hill Bypass’ (p.138) and that it has already been planned. The depiction of Green Belt land and AONB land on this map is very helpful. It demonstrates that the garden settlement should be outside land with these designations. Tudeley should not have been shortlisted when you have suitable sites outside of the AONB and Green Belt. |
DLP_4220 | Tunbridge Wells District Committee Campaign to Protect Rural England | This diagram fails to show fully how much of the Green Belt will be built over, since the pink dots obscure the Green Belt in Paddock Wood and around RTW , and the large new hotel planned for Southborough is not shown. It does, however, illustrate the huge amount of new development that is planned for the AONB and its setting. |
DLP_4294 | Changing Cities for 42 Leisure PLC | The Key Diagram could be clearer in its presentation of the distribution of housing and other new development and key areas for regeneration and change including the southern part of the Town Centre. |
DLP_4386 | Mill Lane and Cramptons Residents Association | Key Diagram and Policy STR1. We do not agree with Sissinghurst (Item 5) having so much proposed new growth. We have already had a large development of 60 new houses off Common Road and other new dwellings in Cobnut Close and Church Mews in this small village that has minimal facilities. |
DLP_5885 | Ms Sally Moesgaard-Kjeldsen | I object. Does it really matter if I object or not, I wangt |
DLP_6001 | Alexander Fisher | TWBC: the following comment was submitted by the responders on the left: Comments on The Key Diagram (Figure 4, Section 4) p.41 |
DLP_6031 | Mr C MacKonochie | Forgetting designations of land, land use etc. it is obvious that expansion of housing driven by transport links in any significant numbers can only happen along the A21 corridor, expansion of Tunbridge Wells / Southborough (two railway stations). A similar comment can be made about internet connectivity driving housing locations The adopted Core Strategy recognises that rural settlements are least able to support sustainable development |
DLP_6054 | Kember Loudon Williams for Cranbrook School | The amount of development proposed within Cranbrook as shown on the Key Diagram, is sought to be increased and therefore the content of this map will slightly alter. Please see Chapters 3, 6 & 7 of the attached Report for more details. [TWBC: see full supporting statement. For Chapters 3, 6 & 7 please see Comment Numbers DLP_6026/6027 (Chapter 3), DLP_6028 (Chapter 6), and DLP_6046 (Chapter 7)]. |
DLP_6255 | Anne Trevillion | The transport links are completely unclear. The main road from Paddock Wood to Tonbridge has been left off the map, yet this is the road that potentially will take a huge amount of extra traffic. Tonbridge is the town to which people go for most of the sporting and cultural activities, not Tunbridge Wells, simply because of the transport. For example, the Park Run in Tonbridge is accessible from Paddock Wood; that in Tunbridge Wells is not. The swimming Pool in Tonbridge is accessible; that in Tunbridge Wells (St Johns) is not. So the B2017 is a key route. It would be helpful to show exactly how the roads are to be changed and how buses /cycle routes / new train stations are to be planned to mitigate against a huge and damaging increase in traffic congestion. |
DLP_6260 | Kember Loudon Williams for Mr R Barnes | These representations are seeking to allocate an additional site (Stone Court Farm) at Pembury for residential development. The site is considered entirely suitable for development and would make a logical extension to the east of this settlement. It is therefore proposed that the Key Diagram is altered to include site number 354 (Stone Court Farm). |
DLP_6317 | Susan Heather McAuley | The diagram clearly indicates the imbalance in this Local Plan with so much building planned for the east end, so far away from all the new facilities (except large numbers of new houses) being put in at the west end. The purple dots on Sissinghurst, Cranbrook and Hawkhurst far outweigh those on Tunbridge Wells. This is disproportionately impacting on the people of Cranbrook and Sissinghurst who do not want to live in large towns. The people of Tunbridge Wells have chosen to live in a large town and there will be minimal impact on them and their way of life by putting more of the housing allocation in RTW. |
DLP_6799 | Kember Loudon Williams for Wedgewood (New Homes) Ltd | The amount of development proposed within Horsmonden as shown on the Key Diagram, is sought to be increased by 35 housing units and therefore the content of this map will slightly alter to reflect this. Please see Chapters 3, and 4 of the attached KLW Supporting Statement for more details. [TWBC: see Supporting Statement and Comment Numbers DLP_6793, 6797-6799, 6801, 6803-6804] |
DLP_6858 | John Gibson | I do not believe that Sissinghurst should have such a proportionately large expansion. The small rural village already has absorbed many new houses recently. (TWBC Comment - duplicate comment received 13/11/2019 as below) I disagree that Sissinghurst should suffer such a disproportionately large expansion. The small rural village already has absorbed many new houses recently. |
DLP_6945 | Hallam Land Management Ltd | Key Diagram |
DLP_6975 | Mrs Beryl Bancroft | Most of the improvements are being made in the centre of Tunbridge Wells which already has good transport and employment facilities. No plans seem to be in place to get people from areas such as Cranbrook, Sissinghurst and Frittenden and other rural Weald villages which are getting more housing but nothing else. |
DLP_6982 | Nigel Tubman | The map (Key Diagram Figure 4) is clear but the distribution of development is clearly out of balance between the east and west parts of the borough. The borough is a long and narrow strip of Kent with the main part of the population residing in the western part of TWBC requiring a more appropriate response that addresses the needs of the whole borough and the people who live there bearing in mind the difficulty in travel east to west and vice versa. It also illustrates rather starkly how much the plan benefits and addresses the needs of the town of Tunbridge Wells to the detriment of the rural areas. |
DLP_7000 | Kember Loudon Williams for Mr Anthony Whetstone | These representations are seeking to allocate an additional site (Tudeley Brook Farm) within the strategic growth allocation for Paddock Wood. A detailed planning report has been prepared to support these representations. It finds that the site is entirely suitable for development and should be included as part of the comprehensive redevelopment of Paddock Wood. Accordingly, we therefore respectfully request that the Key Diagram is altered to include the Tudeley Brook Farm site. |
DLP_7361 | Wealden District Council | Paragraph 23 of the NPPF (February 2019) confirms that broad locations for development should be indicated on a key diagram, and land-use designations and allocations identified on a policies map. The key diagram within the draft Tunbridge Wells Local Plan (page 41) includes all housing allocations within the plan, including the two proposed garden settlements, the location of both Green Belt and the High Weald AONB, as well major transport routes and settlements. |
DLP_7509 | Sarah Parrish | Without detailed plans – how can TWBC be sure of enough land being available? |
DLP_7542 | William Fisher | TWBC: the following comment was submitted by the responders on the left: The circle representing housing on Tudeley is misleading, it should show a circle representative of 1,900 new houses (the minimum in the intial plan period) but is only a little bigger than the key circle showing 1,000 housing units; another example of the draft plan being inaccurate and misleading. It also demonstrates that there is no coherent plan for for a proper spread of development across the borough; something that is meant to be part of the TWBC strategy. The depiction of Green Belt land and AONB land on this map is very helpful. It demonstrates, yet again, that the garden settlement should be in Horsmonden. Tudeley should not have been shortlisted when TWBC has a suitable site outside of the AONB and Green Belt. Furthermore, there are areas to the NE of the borough without any AONB or green belt restrictions. |
DLP_7809 | Mr Colin Sefton | I think this is “broadly correct”, with the majority of proposed development around Paddock Wood; however, I am concerned that proposed new infrastructure to serve proposed development looks significantly insufficient (please see comments on section 2.57 above) [TWBC: See comment 7802]. |
DLP_7838 | Andrew Chandler | The proposed allocation for Cranbrook and Sissinghurst seems to completely change the settlement hierarchy without explanation. You have explained the approach for other locations, but not ours. See further comments on Table 3. |
DLP_8144 | Ashley Saunders | The Key Diagram (Figure 4) is misleading. The circle representing proposed housing in Tudeley (Policy AL / CA 1) is not big enough. It should show 1,900 new houses and is only a little bigger than the key circle showing 1,000 housing units. It is understood that the large blue arrows are intended to signify options for a ‘Proposed Link Route’ between the proposed site at Tudeley (AL / CA 1) and either the A228 between the Badsell Roundabout and the Hop Farm (the higher arrow) or the proposed offline A228 strategic link or ‘Colts Hill bypass’ (the lower arrow). This diagram suggests that either option is being considered, which is what we were told by TWBC Head of Planning, however, it is clear from the SWECO Transport Map with proposed Local Plan Mitigation Interventions (Table 9.2 and Figure 9.2 of the Local Plan Transport Evidence Base which forms part of the supporting documents that Transport Strategy) that Scheme No. 203 comprises a ‘Link road to new Colts Hill Bypass’ (p.138) and that it has already been planned. The depiction of Green Belt land and AONB land on this map is very helpful. It demonstrates that the garden settlement should be in Horsmonden or Frittenden. Tudeley should not have been shortlisted when you have suitable sites outside of the AONB and Green Belt. |
DLP_8213 | Mrs Suzi Rich | I object to the Key Diagram (Figure 4) because it is misleading. It is understood that the large blue arrows are intended to signify options for a ‘Proposed Link Route’ between the proposed site at Tudeley (AL/CA 1) and either the A228 between the Badsell Roundabout and the Hop Farm (the higher arrow) or the proposed offline A228 strategic link or ‘Colts Hill bypass’ (the lower arrow). This diagram suggests that either option is being considered, which is what we were told by TWBC Head of Planning, however, it is clear from the SWECO Transport Map with proposed Local Plan Mitigation Interventions (Table 9.2 and Figure 9.2 of the Transport Assessment Report which forms part of the supporting documents that Transport Strategy) that Scheme No. 203 comprises a ‘Link road to new Colts Hill Bypass’ (p.138) and that it has already been planned. [TWBC: See comments DLP_8189-8214 for full representation] |
DLP_8248 | Jan Pike | Comments already made above should be reviewed [TWBC: See comments DLP_8236-8248] |
Policy STR 1: The Development Strategy
Comment No. | Name/Organisation | Object/support/support with conditions/general observation | Response | ||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
DLP_47 | Thomas Weinberg | Object | Comments on Policy STR 1 (The Development Strategy) p.42 This policy does not include any reference to development on Brownfield sites, but does refer to the release of Green Belt. | ||||||||||||||||
DLP_7769 | Annie Hopper | General Observation | No employment space has been identified in Cranbrook and Sissinghurst. This means that many new residents of the Parish of Cranbrook and Sissinghurst will be travelling to work, (14 miles away) entirely unsupported by appropriate infrastructure. | ||||||||||||||||
DLP_68 | The Access Group | My members having looked at the proposed Draft Local Plan have instructed me to make the following observations and legal demands: 2. THE MAJOR CONCERNS 2.1 Whilst my members appreciated "the need for housing etc" and "government targets imposed on local government", the concerns expressed were as follows: Us of green field sites such as those in Capel, Paddock Wood, Matfield, Brenchley, Cranbrook and Tudeley must be minimised as they impinge on the High Weald AONB. | |||||||||||||||||
DLP_97 | A W Samson | Object | I am simply appalled by the proposed development that is planned in our local rural areas, which include Green Belt designations and the High Weald Area of Outstanding Natural Beauty (AONB). Yes we need housing to meet our housing targets, but this must only be planned and provided where proper and correct infrastructure and services are put in place. In addition I can see no detailed analysis of the impact these new developments will have on our rural communities. Firstly, the impact of the extra traffic that will be generated on our narrow roads, together with the parking problems that will be inevitable, not only on the estates themselves but also at our stations and on our high streets. Secondly, many of the developments are on flood plains with not only the obvious known problem of flooding, but also and most importantly the need for very careful planning and construction that is necessary regarding services, such as drainage, water, electricity and gas utilities. Thirdly, the impact of these new developments on our existing facilities, which are already at maximum capacity, such as schools and health services will be devastating, unless these facilities are built before the new development. If development, to the magnitude you are suggesting on the Draft Local Plan, is seriously being considered, then the impact of the above serious problems need not only to be properly considered but action taken to implement in advance of any development being allowed to proceed. Your observations and views would be appreciated, as I feel very strongly that there is a need to review your planning and policy framework in order that the public be satisfied that all factors have been taken into consideration before planning applications are allowed to be even considered, let alone decisions made. | ||||||||||||||||
DLP_129 | Gregg Newman | Object | This policy does not include any reference to development on Brownfield sites, but does refer to the release of Green Belt. You have a moral and civic duty to identify and exploit Brownfield sites before bulldozing (literally) Greenbelt and AONB. There is no their way to say this! | ||||||||||||||||
DLP_237 | Mr Graham Clark | The development strategy as set out in the Policy STR1 and the Key Diagram is flawed. The National Planning Policy Framework (NPPF) makes it clear that the primary purpose of the planning system is to achieve a future development pattern that is sustainable. Tunbridge Wells and Southborough is by far the largest urban area in the Borough with the widest range and concentration of services and facilities. The town is a sub-regional shopping centre with a wide range of shops, pubs, restaurants and places of entertainment. There are numerous primary and secondary schools and excellent medical facilities. It is located on the Hastings to London railway line, with two well connected railway stations. The strategy should be to focus more of the housing development in Tunbridge Wells and Southborough and significantly less in Paddock Wood and Tudeley Village. It is accepted that Tunbridge Wells faces challenges, particularly in managing traffic congestion and pollution levels. The Council should however, be seeing this as an opportunity to improve the environment of the town by linking new housing development to major and transformative infrastructure improvements. The proposal to allocate land for housing development to the west of Paddock Wood flies in the face of Government advice contained in the NPPF. Much of this land is in Flood Zone 3. Indeed, it forms part of one of the largest alluvial flood plains in Kent, where the rivers Teize, Medway and Beult converge. The NPPF is clear that development in areas at risk of flooding should be avoided. The NPPF advises that all plans should apply a risk-based approach to the location of development and consider current and future impacts of climate change so as to avoid flood risk to people and property. To put it bluntly, the aim of the sequential test is to steer new development to areas with the lowest risk of flooding. It is true that if enough money is thrown at an engineering problem there will usually be a solution. In the case of the land to the west of Paddock Wood this will involve flood compensation measures, which will probably involve huge amounts of ground recontouring. This will fundamentally change the landscape of this area and it is doubtful that many of the existing trees and hedgerow will survive. There must also be a question mark about the financial viability of this approach. In addition, has the Council consulted with lenders and insurers to see whether this proposal is acceptable from their perspective. There is also a question about how sustainable a new garden village at Tudely will be. A development of 2,500 houses will not sustain a wide range of facilities. Network Rail have confirmed that they will not permit a station in this location. This will invariably mean that new residents will be reliant upon the car to access most services. This is not the most sustainable of approaches. In addition, the new road links back to the A228 will have a huge impact upon the landscape. There must also be a question mark over whether a development of this scale could finance these major pieces of infrastructure. To conclude, the strategy is flawed and does not accord with government advice contained in the NPPF. The Council needs to withdraw this Plan and think again about its overall approach. | |||||||||||||||||
DLP_7862 | Peter Felton Gerber | Object | TWBC: the standard response was submitted by the list of responders on the left: Policy Number: STR 1 I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects: 1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan; 2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point. Hawkhurst The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course. The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village. The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan. There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development. Non-compliance with Hawkhurst Neighbourhood Development Plan Lack of adequate infrastructure The proposed development would impact unacceptably on an AONB The proposed development would not constitute sustainable development Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. There are very limited local employment opportunities and no secondary schools within walking distance. The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution. The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it. TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103). The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate. The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF. There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF. The “relief road” will not work The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny. As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes. | ||||||||||||||||
DLP_7864 | Andrew Hues | Object | TWBC: the standard response was submitted by the list of responders on the left: I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents. I believe that the Council’s conclusion (for example, at Paragraph 4.34) that such sites are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:
It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point. | ||||||||||||||||
DLP_7892 | Barry Chamberlain | Policy STR1 – The Development Strategy Furthermore, the total identified supply is however based on an average figure whereby sites and settlements are identified to deliver ranges/parameters of development. For example, Hawkhurst is identified for development of 643 – 693 dwellings during the Plan period. Within this quantum, Hawkhurst Golf Club (AL/HA 1) is allocated for c. 400 – 450 units and thereby an average of 425 units for this site is used in the housing supply for the Local Plan. [TWBC: see Comment Number DLP_7894 Appendix 6] | |||||||||||||||||
DLP_384 | Mr Terry Cload | Object | STR1 I do not agree with the release of Green Belt land for housing over and above the needs of the indigenous population. There are ample brown field sites in the UK that should be used first. National Government insists that the Green Belt will be protected from development but the proposals amount to driving a fleet of mechanised destroyers of irreplaceable countryside through beautiful areas of Tunbridge Wells. National government is taking more and more power away from local communities to make planning decisions. Sevenoaks District Council is making a stand against goverment imposed housing targets Tunbridge Wells Borough Council should do the same. | ||||||||||||||||
DLP_7902 | Fiona Dagger | Object | Firstly – this review comes just 9 years after the last review and claims to take us through to 2036 – but has the opportunity for a five year review – making it just a five year review and the policies proposed are totally inappropriate for this time frame. I consider the scale and distribution of the allocation housing being imposed upon Hawkhurst and Cranbrook, within the AONB (2300 houses over 59 sites) as not consistent with its duty for protection as a national important landscape. The designations lie within the High Weald AONB and paragraph 11 of the NPPF (footnote 6) suggests that AONB designation should constrain levels of housing provision. This is supported by Planning Practice Guidance (Paragraph: 041 Reference ID: 8-041-20190721) which makes it clear that development should be limited in AONBs, and that it may not be possible to meet ‘objectively assessed needs’ in these areas. In the Distribution of Development Topic Paper (Para 3.11), TWBC accepts that strategic-scale urban extensions, would ‘almost certainly not be appropriate’ in the AONB under national policy, and that the statutory purpose of conserving and enhancing the AONB is ‘likely to limit its capacity to absorb new development’. However, in allocating housing numbers to the AONB, no distinction has been made between the proportion of housing allocated to the borough as a whole, and that allocated to two key AONB settlements – Cranbrook and Hawkhurst. The current district-wide allocation of 14776 represents approx. 13 houses/ 100 head of population. With less than two hundred dwellings in Hartley today and a proposal for over two hundred in the future it would be a far higher ratio in certain localities. This is inconsistent with the local plan’s stated policy and with the NPPF. In addition, these AONB settlements appear to be meeting need from elsewhere, most likely from outside of the AONB. Cranbrook and Sissinghurst Neighbourhood Plan assessed the local housing need of these settlements as 610, of which 250 are met by the allocation in the previous local plan at Brick Kiln Farm. This leaves a further 360 to be delivered across both settlements to meet local need. The draft Local Plan allocates 918 to these settlements in Cranbrook. The difference between these two figures suggests need from the wider borough, and potentially nationally as other boroughs have scaled back their proposalis in AONBS (notably Sevenoaks), so with requirements for houses outside of the AONB, is being met in the AONB. This figure amounts to approximately the numbers allocated to the three largest ‘major’ sites which are likely to cause the most harm to the landscape and natural beauty of the AONB. These major allocations are not necessary and should be dropped. The allocations for Hawkhurst, Benenden and Matfield are similarly inflated above what is required to meet local need. Even if the need to allocate development within the AONB has been demonstrated, it does not mean that such provision should be in the form of major development sites. The AONB Management Plan, adopted by Tunbridge Wells Borough Council in March 2019, explains that the High Weald is a small-scale landscape built by hand. The Plan commits authorities to ‘seek to deliver new housing primarily through small-scale developments that meet local need’ (Objective S2, page 34). Paragraph 172 of the NPPF says that ‘Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest’. The tests associated with this policy have not been properly considered and the exceptional circumstances have not been justified. Alternatives to the large allocations have not been properly considered – sites outside the AONB have been dismissed, and the option of reduced allocations on the larger sites offered in the SHELAA has not been properly examined. The Glover Review of designated landscapes recognises the threats to AONBs, particularly in the South East, of excessive development, recommending a stronger role for AONBs in the planning system as a result. The Review highlights the damage done to AONBs through locating major development on its boundaries and within its setting. Planning Practice Guidance also highlights the need to take potential impacts on the AONB into account when considered development in its setting (Paragraph: 042 Reference ID: 8-042-20190721, revised 21 07 2019). Consideration of the new settlement at Capel and the proposed development at East End both on the boundary of the AONB have not involved proper consideration of impacts on the AONB, including the impact of cars, visitors and the impact of the loss of cultural associations with the AONB. | ||||||||||||||||
DLP_410 | W Gibson | Object | TWBC: the standard response was submitted by the list of responders on the left: I challenge the need for so many houses to be built over the plan period of 2016-2036. The Office for National Statistics estimates borough population growth of 13,952 people, and with an average house occupancy rate of 2.35 people (117,140 people living in 49,880 houses), the need is for 5,937 houses (of varying sizes). TWBC must challenge the government on the number genuinely needed in the borough. | ||||||||||||||||
DLP_7930 | Wendy Owen | Object | 1b states “An enhanced town centre development at RTW, including... the provision of flexible retail, leisure, and cultural uses, as well as new office provision…”. | ||||||||||||||||
DLP_457 | Evolution Town Planning for Hams Travel | Support with conditions | Please find attached our representations on behalf of Hams Travel in relation to the Local Plan policy and allocations around Benenden. As part of these representations, we are promoting an excellent Brownfield Site, which has only just been confirmed as available for redevelopment. Unlike many of the sites proposed to be allocated, this is a brownfield site and we consider that it has the potential to support local facilities within Benenden. The site hasn’t previously been put forward in the Call for Sites, because it is only recently that the business’s plans to enlarge their other yard (in Flimwell) and relocate the Benenden part of the business to that site have been put forward as a planning application (currently live). That application is progressing well (certainly in relation to the yard expansion at Flimwell and proposals to relocate the Benenden operations to Flimwell). On this basis, we are confident that the Benenden site will be available for development in the near future. It offers an excellent opportunity to delivery housing on a brownfield site and provide visual improvements to the ANOB. We would be grateful if the Policy Team would now consider the benefits of this site, in addition to (or in preference of) some of those allocated. We would welcome opportunity to discuss this site with you. We are happy to submit a Call for Sites form if you would include it in that process as well? In addition, it could be added to the Brownfield register. Hams Coach Yard, Benenden Representations made on behalf of the Hams Travel 1.0 Introduction 1.1 These representations are submitted by Evolution Town Planning Ltd on behalf of our client and site owners, Hams Travel in response to consultation on the Draft Tunbridge Wells Local Plan Consultation (Regulation 18) 2019. 1.2 The representations relate to their site at Benenden, which has not previously been submitted in the ‘Call for Sites’ process (due to uncertainty about whether it would become available). However, as we will set out in this report, Hams Travel are now confident that this site can be released for development as it will shortly be surplus to requirements in the business. We consider that there are substantial benefits in developing this site over the other sites currently allocated and we therefore seek the allocation of this site in preference to, or in addition to, the other sites included around Benenden in the draft Local Plan. The extent of the site available is set out in Appendix 1. 1.3 These representations set out that we:
2.0 POLICY STR 1 (Development Strategy) 2.1 Having reviewed the broad strategy contained in this policy, we note that the Council is relying heavily on delivery of housing around Paddock, which includes an entire new settlement at Tudeley Village on the Hadlow Estate, between Tonbridge and Paddock Wood. Tunbridge Wells, the largest settlement in the district, is only allocated 1222 to 1330 new homes. Meanwhile allocations in smaller sustainable settlements are restricted even more significantly. Benenden has received allocations for just 53-57 new homes, whereas the relatively remote site of Benenden Hospital at East End, a significant distance from Benenden, has received allocations for up to 66-72 new homes. 2.2 We object to this strategy as set out in policy STR1 since we consider it has an over- reliance on large sites at a time when economic downturns are predicted and the proposed policy does not include sufficient flexibility to guard against non-delivery. Objections - policy STR1 2.3 The Consultation Draft Local Plan policy STR1 identifies development allocations as follows:
2.4 We are not persuaded that this strategy is likely to ensure delivery at the levels the NPPF requires. NPPF states at paragraph 59 that the government’s objective is to ‘significantly boost the supply of homes’ and elsewhere the NPPF makes clear that it is not just the allocation of sites, but their delivery which is crucial. In this regard we have concerns that such a large proportion of the Borough’s housing allocations have been concentrated in such a small part of the Borough and on large sites. Since large sites are known to be vulnerable and volatile to non-delivery in economic down turns, this approach seems to be flawed and likely to place the strategy at risk. 2.5 The NPPF (paragraph 68) states that ‘small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built-out relatively quickly.’ In supporting small and medium sites to come forward, the NPPF requires LPAs to ensure that (a) at least 10% of their housing requirement is on sites no larger than one hectare; and (c) ‘support the development of windfall sites through their policies and decisions – giving great weight to the benefits of using sustainable sites within existing settlements for homes’. 2.6 By relying on a few large sites for such a large proportion of the housing supply in the Paddock Wood market (over 50% of the Borough’s 7,593 housing allocations required), we are concerned that this strategy is likely to prove highly vulnerable to obstacles to delivery, should the market experience a downturn or volatility. This is not consistent with the aims of NPPF. 2.7 Whilst we do not object to the allocation of these larger sites, to guard against non- delivery the Council should consider allocating far more small and medium sized sites and scheduling to expect a slower rate of delivery on these large sites. This will effectively program in some dips in the market and downturns, in such a way that delivery of the overall housing target is not compromised. We consider that the Local Plan is comprised and at risk of being found to be unsound, without an increase in small and medium sized sites being allocated and less reliance on the large sites around Paddock Wood. 2.8 We also object to paragraph 6 of the policy, which states that development will be supported on the following basis: ‘Development at the other settlements across the borough within their respective Limits to Built Development boundaries and through the delivery of allocations as per Table 3 below, and other suitable windfall developments;’ 2.9 Since this policy only restricts development to ‘within their respective Limits to Built Development boundaries’; on allocated sites and ‘other suitable windfall sites’ the policy could be improved with greater clarity as to what ‘other suitable windfall sites’ will be considered to be. We believe that, in the light of the Council’s heavy reliance on large sites in the Paddock Wood area for the vast majority of housing delivery, this clause should be expanded to state the following: ‘Development at the other settlements across the borough within their respective Limits to Built Development boundaries and through the delivery of allocations as per Table 3 below, and other suitable windfall developments including brownfield sites outside of the Limits to Built Development;’ 2.10 This would open up development options on brownfield sites in accordance with NPPF’s preference for brownfield delivery and would assist against concerns regarding the non-delivery of large allocated sites in an economic downturn. 2.11 Regarding paragraph 8 of policy STR1, we note that it states development will be supported: ‘Where major development is provided for at specific identified sites in the AONB, this is only where the tests set out in the NPPF are met’. 2.12 Given the scale of the housing crisis and the need to ensure delivery of housing across the Borough, we consider that this clause needs to be amended to be more flexible and to be explicitly supportive of developments which are not ‘major’ developments (especially where such proposals are on brownfield land) and where the proposals would result in visual improvements to the ANOB. We suggest a revision as follows: ‘Where major development is provided for at specific identified sites in the AONB, this is only where the tests set out in the NPPF are met. Proposals for housing developments which are not ‘major’ developments will be supportive especially on brownfield sites where there are opportunities for enhancements for the AONB’. 2.13 We consider that these suggested revisions will bring the plan more into line with the NPPF which requires Local Plans to support brownfield development, ensure the delivery of housing (not simply allocated sufficient sites) and be ‘positively prepared’, ‘justified’, ‘effective’ and ‘consistent with national policy’ (paragraph 33). Such amendments will place the plan in a better position for its Examination. 2.14 We would support policy STR1, if it were amended to include less reliance on the new settlement and Paddock Wood sites and a greater proportion of smaller sites across the Borough. However, in addition we have also recommended the following amendments, to ensure that the plan is positively prepared and effective, even if the Council continues to rely on such large sites to deliver its housing strategy: ‘(6) Development at the other settlements across the borough within their respective Limits to Built Development boundaries and through the delivery of allocations as per Table 3 below, and other suitable windfall developments including brownfield sites outside of the Limits to Built Development;’ ‘(8) Where major development is provided for at specific identified sites in the AONB, this is only where the tests set out in the NPPF are met. Proposals for housing developments which are not ‘major’ developments will be considered positively and constructively, especially on brownfield sites where there are opportunities for enhancements for the AONB’. 2.14 Both of these amendments would help guard against non-delivery of the larger sites that the plan relies on, should there be a downturn in the housing market. These suggestions will improve the deliverability of the Council’s housing targets. [TWBC: see Appendix 1 Land Registry document and site location plan in full representation]. | ||||||||||||||||
DLP_7955 | Sharon Pickles | Object | TWBC: the standard response was submitted by the list of responders on the left: 1. C. *If the ENS has identified the above areas for development, this is surely where many new residents of the Parish of Cranbrook and Sissinghurst will be travelling to work, (14 miles away) entirely unsupported by appropriate infrastructure I object to placing so much development in Ctranbrook and Sissinghurst when employment is targeted so far away | ||||||||||||||||
DLP_8008 | Hobbs Parker Property Consultants Ltd for The Hedges Family Accumulation and Maintenance Trust | Support | 3 DEVELOPMENT STRATEGY 3.1 We endorse the approach and the findings in respect of the Objectively Assessed Need (OAN) as set out the Housing Needs Assessment Topic Paper. We also consider that it is vital that sufficient land is identified and allocated to enable delivery of the full OAN rather than place a reliance on an arbitrary windfall allowance. 3.2 The character of The Borough is such that it is subject to high level environmental constraints such as an expansive AONB and Green Belt and some areas of Flood Zone 3b land. These factors influence and inhibit the ability to bring speculative windfall development forward. For this reason, the certainty of allocated housing land should be an integral component of the Local Plan policy framework to ensure delivery of the full OAN. 3.3 Policy STR 1 Development Strategy identifies that: “New development at Hawkhurst to provide a range of new homes, as well as the delivery of significant infrastructure improvements in the form of a relief road from Cranbrook Road to Rye Road, providing significant improvements to the crossroads in the centre of Hawkhurst (Highgate), and associated public realm improvements. A package of other community benefits will also be provided in the form of new health and other local facilities, as well as employment growth by way of an extension to the existing Key Employment Area at Gill's Green”. 3.4 The policy approach is supported. 5 HOUSING 5.1 It is noted that the plan states that total capacity of all identified sites (completed houses since 2016, outstanding planning permissions, retained Site Allocations Local Plan allocations, development through windfall sites, together with new allocations proposed in this Draft Local Plan) provides for some 14,776 net additional dwellings. This compares to a minimum requirement of some 13,560 dwellings. The council’s approach provides for a modest oversupply equivalent to some 9% in order to ensure delivery of the full OAN. Where a range of housing numbers is provided in a policy for the outstanding site allocations and proposed allocations, the figure used in the above calculations the council state that this is the mid-point of this range. 5.2 However, table 1 Housing, sums to 13,560. It is therefore unclear as to where the additional 1,216 dwellings (14,776) are identified in the components of supply. This matter requires clarification. 5.3 The planned housing target for Hawkhurst is shown as a range. This approach is not supported. The target should be the specific figure of 731 dwellings as minimum. The plan allowance of windfall (equivalent to 5.16%) should be in excess the planned target for the reason set above. 5.4 Notably the implementation of allocations has often yielded less dwellings than originally planned for. By way of an up to date example, the recently submitted planning application presented to the council on site HA 1 (Land forming part of the Hawkhurst Golf Course to the north of the High Street) is proposed for 400 dwellings as opposed to the 400-450 dwelling as envisaged in the draft allocation. This demonstrates the potential fragility of the supply when relying on density assumptions on allocations in this area with identified national level environmental and policy constraints. There is need to allocate more sites in Hawkhurst to ensure delivery of the full OAN. A sensible approach would be to identify land for 10% above the 731 housing target to ensure delivery of the full OAN. Further, reserve sites should be identified to cover the eventuality, later on in the plan period, of allocations under delivering. | ||||||||||||||||
DLP_8017 | Penny Ansell | Object | I would like to reiterate my comments made at the end of the previous section that if as they had said, the Council proposes a development strategy to meet housing growth based on: Option 3 - development distributed proportionately across all of the boroughs and settlements and Option 5 - a new freestanding ‘garden village’ then Option 3 is NOT demonstrated in the draft plan. As I have said previously, how can Tunbridge Wells (pop’n 48,324) allocate itself only 1,271 houses while it expects Hawkhurst (pop’n 4,991) to build 668. (In fact, once existing building from 2016 is taken into account, the number will be way above this). This is particularly unacceptable considering Tunbridge Wells has infinitely superior infrastructure and road and rail networks. Also, for comparison, Speldhurst with a population more or less identical to Hawkhurst is allocated only 15 - 20 dwellings These figures are neither proportionate nor appropriate to scale. This is particularly so since in terms of landscape characteristics (Section 5, Place Shaping Policies) Tunbridge Wells is mainly ‘urban’ and Hawkhurst is ‘wooded farmland and forested plateau’. Of interest, Speldhurst is ‘urban and wooded farmland’. The Draft Local Plan reveals that TWBC prefers to meet its assessed housing needs primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. It is clear that little real consideration is given to the consequences of such developments for the towns and villages concerned nor for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). I would add that 100% of Hawkhurst lies within the AONB! Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. In fact, it is extremely unclear from the figures given in the ‘Key Diagram and Main Proposals’ shown in the LOCAL magazine how much has already been built in each area. Given that the target for the borough is 13,560 and the number of dwellings shown in LOCAL is only about 10,700 (which refers to future plans plus a few which have permission but not yet built), how are the remaining 3,000 of already built dwellings distributed? That needs to be stated. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in three respects:
It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point. | ||||||||||||||||
DLP_8037 | Rose May McAuley | Object | Policy Number: Section 4 Strategic Policies Policy STR 1 The Development Strategy Point 1 - Tunbridge Wells is going to receive all the new facilities and the employment but Tunbridge Wells is receiving getting far fewer houses than Sissinghurst . The number the Draft Plan wants in Sissinghurst are not justified. They should be lower, more like has been suggested for Frittenden. We already have loads of new houses that are expensive and not helping people around here who want to buy houses, no-one here can afford them. | ||||||||||||||||
DLP_540 | Catherine Catchpole | Object | The policy states that development will be carried out within the limits to build, and yet for all 3 of the main sites in Horsmonden, the development requires the limits to build to be extended. What is the point of setting limits to build if you just ignore them? | ||||||||||||||||
DLP_8102 | Ashley Saunders | Object | This policy does not include any reference to development on Brownfield sites but does refer to the release of Green Belt. There should be a strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites. You repeatedly refer to the Eastern part of Capel parish as part of Paddock Wood when it is not, and unlike Paddock Wood is in the Green Belt. It has a completely different heritage and culture from Paddock Wood. Badsell Manor is the oldest continuously inhabited houses in the parish and its historic environs would be destroyed by this proposal. | ||||||||||||||||
DLP_8137 | Hume Planning Consultancy Ltd for Meadow View Construction Ltd | Policy STR 1 – The Development Strategy Housing Targets Distribution of Development Furthermore, looking at the housing trajectory which accompanies the local plan consultation, it is anticipated by the Council that completions on the site will begin at the Tudeley Village allocation in 2025. At present, the site does not appear to benefit from planning permission, nor is there an application under consideration. In the Paddock Wood allocation (4,000 homes) it is anticipated that completions will begin in 2024, and again the site does not appear to benefit from planning permission, nor is there an application under consideration. Given the size of these schemes and the supporting information which will be required, in our view the delivery of homes this early on in the plan period is considered to be unlikely. Summary We have set out above our comments, on behalf of Meadow View Construction, on the Regulation 18 consultation draft of the Tunbridge Wells Borough Local Plan (September 2019), and we welcome the opportunity to work collaboratively with the Council to identify a sound development strategy. We support the intention to meet the identified housing needs of the Borough, and to accommodate a portion of this housing need at Cranbrook, which represents a sustainable and suitable location for growth. | |||||||||||||||||
DLP_8192 | Mrs Suzi Rich | Object | Why does the Development Strategy contain no reference to development on Brownfield sites but instead refers to the release MGB? There should be a strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites. [TWBC: See comments DLP_8189-8214 for full representation] | ||||||||||||||||
DLP_8204 | Home Builders Federation | Thank you for consulting the Home Builders Federation (HBF) on the draft Local Plan. The HBF is the principal representative body of the housebuilding industry in England and Wales and our representations reflect the views of discussions with our membership of national and multinational corporations through to regional developers and small local housebuilders. Our members account for over 80% of all new housing built in England and Wales in any one year. Outlined below are our comments on the approach taken by the Council to increasing the supply of land for residential development and the policies being proposed with regard to the management of new development in future.
However, even without a cap the Government require Councils to give consideration as to whether more homes are needed to take account of:
Unmet housing needs in neighbouring area “…any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for” The inclusion of this statement within the NPPF means that the Government are not merely requiring Council to consider whether they should address any unmet needs from neighbouring areas but that they must address these needs where possible and where it would be consistent with other policies in the NPPF. In preparing the local plan it is therefore vital that the Council establishes whether there are any areas that are not meeting housing needs in full. The Council have, to some extent, considered this matter within the Housing Needs Assessment Topic Paper. In this paper the Council acknowledges that there is an under supply within at least one neighbouring authority – Sevenoaks – but that the Council does not consider itself to be in a position to increase its own housing requirement to meet any unmet needs arising in Sevenoaks due to the constraints present across Tunbridge Wells. Conclusion | |||||||||||||||||
DLP_721 | Dr P Whitbourn | Paragraph 1a of Development Strategy Policy STR 1 envisages for Royal Tunbridge Wells "extensive infrastructure" including "Public Realm enhancements" and "transport provision". We have been living for some time now, and still are while putting together this consultation response, with the very disruptive consequences of "extensive infrastructure" works in the "public realm" on Mount Pleasant. Earlier works at the Five Ways were bad enough, but those currently taking place in the vicinity of the War Memorial are causing even more chaos, with the town centre effectively divided into two; traffic congestion confusing and dire; vital bus routes re-routed in a very un-clear and highly inconvenient way; traders hit by road closures; and s chopped down , leaving a general sense of devastation at the heart of the town, leaving a general impression to some that Royal Tunbridge Wells is a somewhat disagreeable place no longer worth coming to. This is all most regrettable especially as, although the intention behind the works was good, its execution turned out to be excessively heavy-handed and over-elaborate civil engineering that was not well managed from the point of view of the general public. I strongly support aspects of this phase II scheme, such as widening the stretch of footpath in front of the war memorial which has long been a source of congestion, with pedestrian flows obstructed by passengers waiting for, or alighting from the many buses that are so important to the life of the town centre. The town needs to learn from this salutary experience and, in particular, not to cause even worse chaos if any stage III initiative is planned in the vicinity of Great Hall and the Central Station. Royal Tunbridge Wells is not a town in need of "extensive" infrastructure for the sake of it. Instead, it needs a more gentle approach, with "appropriate", sensitive and well-thought-out measures to address genuine problem areas, such as being able to get from the Central Station from the High Street without risking life and limb, or making a lengthy detour. I suggest therefore that word "appropriate" be substituted for "extensive" in policy STR 1. The same policy goes on to raise the subject of "transport provision". This could, of course be very welcome if it meant, for example, delivering better organised , more frequent and more reliable bus services in the urban area. As matters stand, however, I find it unclear what form that "transport provision" might take, and I have not found section 6 particularly enlightening on the subject. | |||||||||||||||||
DLP_8273 | Ann Gibson | Object | STR1c A prestigious new business park will be located to the north of North Farm/Kingstanding Way that is well connected to the improved A21, providing a range of employment floorspace and jobs to meet identified needs. The site will make a substantial contribution to the need for new employment space over the plan period. Other employment, including leisure development, will be encouraged at North Farm/Kingstanding Way. If the ENS has identified the above areas for development, this is surely where many new residents of Sissinghurst will be travelling to work, (14 miles away), entirely unsupported by appropriate infrastructure. They will be forced to use private cars thereby increasing carbon emissions. I object to placing development in Sissinghurst when employment is targeted so far away. | ||||||||||||||||
DLP_856 | Ian Pattenden | Object | Comments on Policy STR 1 (The Development Strategy) p.42 This policy does not include any reference to development on Brownfield sites, but does refer to the release of Green Belt. You should have a strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites. Your comment that brown field sites must be registered by the owner is yet another example of a poor excuse not to pursue these sites for development. As rate payers we expect our officers to work hard and to take the right decisions, not easy and unsound ones. | ||||||||||||||||
DLP_937 | Mrs Karen Stevenson | Object | The Development Strategy for the delivery of the Local Plan adopts a combination of growth strategies proposed in the Issues and Options document. Prominent in this mix is proportional distribution of growth across all existing settlements this is despite the fact that the consultation recorded a less positive response to this approach than the other strategies. Also in the mix is growth within a new, free-standing settlement, however the feedback in the Issues and Options consultation, which recorded a slight preference this growth strategy , specified that the new settlement should not be in the Metropolitan Green Belt or the AONB. The ‘Distribution of Development Topic Paper’ presents the justification for the proposed Development Strategy, including how the Issues and Options consultation informed the Strategy. However, the outcome is at odds with the feedback and, in several instances, goes directly against the views expressed. We oppose the proposed approach of dispersed growth across the Borough. It is inconsistent with the NPPF, which advocates focusing development in the most sustainable locations, allocating land with the least amenity value and conserving and enhancing the AONB, where the scale and extent of development within such designated areas should be limited (NPPF paragraphs 171 and 172). It is also contrary to the Council’s previous Local Plan and Core Strategy, which focussed growth in towns, recognising that villages and rural settlements are the least sustainable locations for development. So many of the proposed development sites allocated in the draft local plan go against these views expressed and are contrary to protections that should be afforded to AONB and Green Belts under the NPPF procedure. Dispersed growth with proportional development distribution is not consistent with the three objectives of sustainable development. Looking at our own village of Matfield, this is one of the least sustainable settlements in the borough. It lacks the services and amenities to support significant growth (up to 37.5% in the number of dwellings). There is no evidence of scope for the village to become more sustainable as a result of growth, despite the Council’s untested hope in that it may. Development of this scale in settlements with low sustainability is contrary to the NPPF (paragraphs 7 and 8) and is not in the public interest. What was the rationale for adopting the preferred approach of dispersed growth, in favour of the focused growth used in the Core Strategy? How was the ‘proportional’ aspect of ‘proportional development distribution’ determined under the ‘dispersed growth’ model applied in the Development Strategy? What methodology was applied and how has this been tested? More should be done to promote a greater proportion of housing development on Brownfield land, particularly, in the existing urban centres. The current Brownfield Register for Royal Tunbridge Wells contains provision for only up to 950 homes, which is an incredibly small provision for a town of this scale. How exhaustive has the search been to identify land that could be redeveloped rather than building over rural areas, both in rural villages and the countryside? Why can’t more development be allocated to such Brownfield sites, within existing towns, where transport services are already in place, rather than destroy more of the AONB countryside? Development of brownfield sites often has the benefit of removing local eyesores and breathing new life into areas of towns which are run-down and further providing homes where most young people actually want to live, near to existing infrastructure, amenities and services. Brownfield site development should be prioritised over building in idyllic rural villages and a greater search of potential sites made in not only Tunbridge Wells but other towns in the borough. | ||||||||||||||||
DLP_939 | Tom Clarke MRTPI | Support with conditions | The Trust has had extensive engagement with the Council regarding the proposed new theatre for Royal Tunbridge Wells. We continue to support the delivery of a new theatre for the town as articulated within our formal comments in response to application 18/00076/FUL which we submitted in early 2018. We acknowledge the current site for the new theatre, which forms part of a wider Civic and commercial development, has been subject to challenge. Therefore our continued support for a new theatre for Tunbridge Wells is conditional upon the Assembly Rooms being retained and operational until such time as a replacement is operational so there is no break in provision. We urge the Council to continue to engage with the Trust. | ||||||||||||||||
DLP_1077 | Mr John Hurst | Object | Policy STR1 - Development Strategy The numbers of dwellings proposed is excessive, and based on outdated methodology. Notwithstanding that it is a Government edict, it must be challenged. 1. The timeline that gave rise to this is as follows: - Government made a political statement that 300k houses are needed nationally - Government required the ONS' "2014" methodology for calculating housing need be used (NB this results in about 240k houses nationally) 2. Impact of using updated ONS methodology - ONS produced a revised "2016" methodology, which in the case of Tunbridge Wells would require only 67% of the 2024" figure, according to consultants Barton Willmore, see The nett new dwellings to be added are shown in the DLP in Table 1 in section 4:12, on page 35. If the 67% factor is applied to line 1., the resulting nett new dwellings in line 6 goes down from 7,593 to 3,115, ie to much less than half. This, together with additional brownfield developments first (see comments to Policy STR4) could obviate the need for use of Green Belt land. Hence the importance of challenging the numbers basis. | ||||||||||||||||
DLP_1309 | Mrs Gillian Smith | Object | Dear Tunbrdge Wells Borough Council (Local Plan Team), Please take into account the following objection with regards to Policy STR1: - The Development Strategy (Item 2, 3 & 7 [extracts below]): Item 2 'Capel': "Expansion at the settlement of Paddock Wood (including land in the eastern part of Capel parish) following garden settlement principles to deliver housing and employment growth, new and expanded education facilities, and provide strategic flood risk solutions to reduce flood risk and provide betterment to particular existing areas. Regeneration of the town centre to provide a vibrant and viable new centre for the communities it will serve, as well as the delivery of a range of other community facilities and infrastructure, including new health facilities, a sports hub, new primary schools, expansion of the existing secondary school, and potentially the 'offline' A228 strategic link (i.e. the Colts Hill bypass)" Item 3 'Tudeley Village' : "A new garden settlement at Tudeley Village of 2,500-2,800 houses, to deliver approximately 1,900 new homes during this plan period, as well as a package of infrastructure measures, including new education facilities to serve the settlement itself and the wider catchment area, and strategic flood risk solutions to reduce existing flood risk and provide betterment to particular areas" Item 7 'Capel' "The release of Green Belt around the settlements of Royal Tunbridge Wells, Southborough, Paddock Wood, Pembury, and in the parish of Capel, to deliver development allocated in this Local Plan;" I would like to express my concerns and strong objections over the Tunbridge Wells Borough Council proposal to build over 4000 homes in the Parish of Capel. As a resident of south Tonbridge, I am well aware that our roads are already uncomfortably congested and polluted; with long tailbacks on the High Street and at the Vauxhall roundabout along Woodgate Way and Pembury Road, during both morning and evening rush hours. Tonbridge High Street which has already been identified as an Air Quality Management Area with levels of Nitrogen Dioxide above the Council’s annual objective, must suffer further detrimental impact with the inevitable addition of extra vehicles from the excessive number of proposed homes. Along with increased air pollution must come more noise pollution. We already have to tolerate the noise of speeding vehicles on Woodgate Way, which is clearly audible from our back garden. Heavier traffic carrying children and staff to the proposed secondary school, shoppers to the industrial estate and High Street, commuters to Tonbridge station and the A21 will impact negatively upon the quality of life and health of the residents of south Tonbridge. The building of homes in these excessive numbers must also increase the risk of flooding in the locality, parts of which already have a history of vulnerability. Only a few years ago, despite the flood barrier, Tonbridge was flooded in several different areas – Barden Road, Tonbridge recreational grounds, the Angel area and industrial estate. At the moment, we are lucky enough to live in an area of outstanding beauty. The Green Belt fields where the developments are proposed are both beautiful and productive and should be protected for the future benefit of all. This land provides a rich diversity of natural habitats for insects, birds and mammals which are already nationally in serious decline. The proposal to build such a substantial number of homes would have a significant and negative impact on the rural landscape, environment, wildlife and health & wellbeing of the existing community. It would cause the loss of the all important green belt buffer from Tonbridge, which would result in an urban sprawl development from Tonbridge to Paddock Wood. | ||||||||||||||||
DLP_3584 | Ashford Borough Council | Ashford Borough Council welcome the invitation to comment on the Tunbridge Wells Borough Draft Local Plan. Further we acknowledge that both this consultation process and the conference phone call held between representatives of the Local Plan teams on Wednesday 30th October provides an opportunity to not only discuss strategic and cross boundary planning issues, but also to formally cooperate as required. A full review has been undertaken of the draft Tunbridge Wells Borough Local Plan, it is noted with interest that you intend to meet your housing requirement of 13,560 in the plan period to 2036 through a planned urban extension of Paddock Wood, the establishment of a new garden settlement named Tudeley Village, and a policy of dispersed growth with site allocations for housing growth located in close proximity to the majority of existing settlements. Ashford Borough Council are pleased to observe that Tunbridge Wells Borough Council are capable of meeting its identified housing needs within its borough boundaries. Our review of the draft plan confirms there are no cross boundary issues, infrastructure proposals or strategic issues that require any comments or a statement of common ground at this time. All planning matters that exist in proximity of the mutual borough boundary can continue to be managed under Local Development Plan policies as is the current situation. It is acknowledged that both authorities continue to meet the statutory duty to cooperate throughout the Plan making process and I look forward to further discussions with you in due course. | |||||||||||||||||
DLP_1732 | Horsmonden Parish Council | Thank you for the opportunity to comment on the draft Tunbridge Wells Local Plan. This letter sets out the comments of Horsmonden Parish Council (HPC), agreed at a public meeting of the parish council held on Monday 4 November. The comments have been formulated with input from the Horsmonden Neighbourhood Plan Steering Group, which has been working on developing a neighbourhood plan for the parish, in parallel with work on the draft Local Plan. We would like to make comments on three areas of the draft Local Plan. These are:
In draft policy STR1, TWBC have chosen an overall development strategy based on Option 3 (dispersed growth) and Option 5 (new settlement), which were two of the options aired in the “Issues and Options” consultation in June 2017. At that time, HPC objected to a dispersed growth strategy. We continue to object to the “dispersed growth” strategy for housing development as the basis for the Local Plan’s development strategy. We consider that this strategy is inherently unsustainable. This is because it directs a disproportionate amount of growth to rural settlements with limited facilities and jobs, and with poorer access to public transport. These settlements have higher dependence on the private car and access to them is generally along low capacity rural roads and lanes. In our view, it would be better to direct more growth to the main urban area of Tunbridge Wells/Southborough, where by far the best range of jobs, facilities and public transport are available and opportunities for higher density development, or along a growth corridor –such as the A21 or railway lines- where there is high capacity transport by road, rail or bus. This provides new households with more sustainable access to facilities and jobs. (Options 2 and 4) Our concerns over the “dispersed growth” strategy in the draft Local Plan are based in both the National Planning Policy Framework and the Borough Council’s own evidence base for the draft Local Plan. The NPPF states that “planning policies and decisions should play an active part in guiding development towards sustainable locations” (paragraph 9) and that “growth … should be focused on locations which are, or can be made, sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions and improve air quality and public health” (paragraph 103). These extracts are also quoted on pages 5 and 6 of the TWBC Local Plan Transport Evidence Base: Transport Assessment Report (September 2019) TWBC’s Transport Strategy Review: Context and Way Forward, in its section on “Rural Transport Issues” (Page 16) leads with the two following quotes (box below) which, in our view, eloquently make the case against a “dispersed growth” planning strategy which directs large scale development to rural settlements:
Policy STR1 sets out the proposed development strategy for the Borough, but this is disconnected in some important respects with the settlement hierarchy identified earlier in local plan work. In the Issues and Options document (page 13), TWBC appear to identify a four-tier hierarchy of settlements:
In many local plans (for example, Mid Sussex, Maidstone, Dover) this hierarchy then forms the basis of the development strategy, or a specific planning policy, where the future pattern of growth reflects the place of settlements within the hierarchy. This means that larger scale development is focused in the higher level settlements best suited to accommodate it, with lesser amounts of development as one progresses down the hierarchy. There is a significant disconnect in the draft Local Plan, in that some tier 2 settlements (such as Paddock Wood) and some tier 3 settlements (such as Horsmonden) have significantly more growth allocated to them than would be expected from their place in the hierarchy. In addition, some rural settlements in tier 3 have much higher levels of growth allocated to them than others at the same level (again Horsmonden), even though some of the others at this level are in much closer proximity to the main town of Tunbridge Wells with all its facilities, job opportunities and access to public transport. We would like policy STR1 to have a clearer and more explicit relationship between the settlement hierarchy and the scale of development proposed in different parts of the borough. Whilst HPC accepts that Horsmonden should accept some growth appropriate to its location, the range of facilities available , local infrastructure capacity and the sensitive rural environment, we consider that the level of growth proposed for Horsmonden in the draft Local Plan (225 -305 dwellings) is excessive and unsustainable. This represents a 25% -30% expansion in the size of the village in a period of less than twenty years up to 2036, much higher than our neighbours in Lamberhurst, Goudhurst, Brenchley and Matfield. Our main concerns on the scale of growth proposed for Horsmonden are:
Our concerns are that developers will plead “lack of viability” to avoid financial contributions through section 106 agreements or that, if TWBC introduces a Community infrastructure Levy, funds raised through development in Horsmonden will not all be spent there. It is frequently the case that such developer contributions do not realise all the funds necessary to achieve timely infrastructure investment in step with development, and local authorities are usually in no position to make good any deficiencies.
The Local Plan sometimes has a tendency to see the landscape in a binary form (AONB= safeguard from development / other areas = negotiable). This puts parishes like Horsmonden, where parts are in the AONB and parts are on the edge of it, in a difficult position. The areas beyond the designated area contribute to the setting of the AONB and are, in themselves, attractive and locally valued landscape with a very distinctive character. The majority of the parish forms part of “The Fruit Belt” with its orchards, hop gardens, vineyards, shelter belts and twisting country lanes). TWBC’s background document (above) concludes that the Horsmonden landscape has a sensitivity of “High” or “Medium High/High” for even small-scale developments. All the proposed development allocations in Horsmonden involve loss of green field sites around the edge of the village. [TWBC: see image taken from Borough Landscape Character Assessment]. They are by no means “small sites”, with two of the three proposed allocations delivering potentially 100 houses or more. These allocations are in addition to the 17 new houses currently under construction adjacent to Kirkin’s Close. For all these reasons, we ask TWBC to look again at its development strategy and to reduce the scale of housing development proposed for Horsmonden. | |||||||||||||||||
DLP_3670 | Capel Parish Council | Object | This policy does not include any reference to development on Brownfield sites but does refer to the release of Green Belt. There should be a strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites. You repeatedly refer to the Eastern part of Capel parish as part of Paddock Wood when it is not, and unlike Paddock Wood is in the Green Belt. It has a completely different heritage and culture from Paddock Wood. Badsell Manor is the oldest continuously inhabited houses in the parish and its historic environs would be destroyed by this proposal. | ||||||||||||||||
DLP_1462 | Mrs Wendy Coxeter | Object | The Draft Local Plan is indicating that TWBC prefers to meet its housing needs by the approval of large-scale developments in Wealden Towns and Villages. Why are you not prepared to consider the small scale developments first? Is it because the temptation of S106 Contributions are irresistible and small scale developments won’t attract such large contributions? The consequences of such developments for the AONB and the villages concerned are very real. You are selling the family silver and the damage will last forever. I understand from our Parish Council that depending upon which set of calculations are used the Housing Needs Allocation could be halved. TWBC have chosen to exceed the allocation requirements across the borough compounding the excessive allocations not just for Hawkhurst but other parishes across the borough. We also have concerns over the definition of windfall development which could lead to large scale sites being excluded from our Parish Allocation but being used by the TWBC to meet its own targets. This Draft Local Plan will not be preserving the AONB that represents 70% of our borough. There will be no character or charm or countryside left in our borough. We will all become ‘copy and pasted’ versions of the developers’ little book of architecture. Paragraph 4.36 suggests that there is agreement with the Parish Councils on development sites. Central Government led us down a path to develop our Neighbourhood Development Plan (at considerable expense in time and money). Now, armed with this document, the Parish Councils’ comments are being completely ignored. It’s as if you have forgotten you asked us to prepare this document and this layer of ‘consultation’ is now very inconvenient and very boring that we keep reminding you about it! This is TWBC’s NDP for Hawkhurst - you are voting against your own policy. Hawkhurst Parish Council have decided not to comment upon their preferred sites as they feel that this would compromise the planning process at a later date. The reason for not choosing preferred sites at the time of submitting the NDP was that the Parish was already delivering ahead of allocation. 4.2 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. TWBC have approved applications in the face of huge local opposition and in direct contravention of our Neighbourhood Development Plan. Our population, number of houses and properties has overwhelmed the capacity of services to cope. Hawkhurst has been playing a part in the allocations and suffered the consequences. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected. in Hawkhurst, we are constipated and we have indigestion. In targeting the larger sites you have not maximised the smaller sites before biting into the AONB. As I understand the NPPF gives TWBC the opportunity to reduce your allocation due to a high percentage of the borough being AONB. You have chosen to increase your allocation. The sites illustrated in your Draft Plan are not appropriate in scale for the AONB. Paragraph 4.4- claims that the growth strategy is based upon the premise of infrastructure-led development. This is misleading as the Council has no control over the provision of infrastructure, services and facilities on the scale that we require to support developments of the size proposed. A perfect illustration is the provision of sewerage services by Southern Water. Southern Water have admitted that the infrastructure is inadequate to support further housing development and recommended that no further development should be approved until the necessary improvements are made. The fouling of waterways by Southern Water was entirely foreseeable to local residents. Improvements are not made when they should be made, if at all and residents suffer the consequences. The development plans for Heartenoak are already non-compliant and there is no provision for the Golf Course development at all. The development of Fieldways/Westfield will displace water down a steep valley and in the vicinity of historic buildings. On the south side of the village water courses are being changed by the landscaping and concreting of developments near the centre of the village. The development strategy outlined from paragraph 4.41 onwards is flawed in two respects:
Hawkhurst The remaining comments on this policy relate to the proposed mass developments at Hawkhurst and in particular the proposal to allow the building of over 400 houses on the present Golf Course. TWBC cannot misunderstand the local opposition to this development and the destruction of the character of our village which this would cause. We have experience of TWBC pushing for approval of a large scale near us of 49 houses. We are aware of how undemocratic and oppressive TWBC and KCC Highways can be when they ‘decide’ on a plan. There is an opportunity with this consultation to listen to our community. I have already stated that this and many other large scale developments are not compliant with our Neighbourhood Development Plan. We have no need for this quantity of housing or this type. Lack of adequate infrastructure Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. For many years there has been a requirement to merge the 2 doctors surgeries for reasons of economy and to attract doctors to rural practices with specialisms that would save patients traveling. This is obviously a desirable plan but burdening our village with 120 additional houses as suggested by the Fowlers Field plans is too heavy a price to pay. Southern Water suggests that it would take 2 years for them to improve our sewerage system adequately. This has been discussed in Parliament. The proposed development would impact unacceptably on an AONB The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that the great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And, that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019. The proposed development would not constitute sustainable development. The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment. Existing facilities and services are scaled for the needs of a village; they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. There are limited local employment opportunities and no secondary schools within walking distance. Building on the Golf Course removes two of the very few local sports facilities and I suggest that a sports facility should have been included in the plans. Our Parish Council make it clear that roadside air pollution is already breaching guidelines and that where traffic is static at the traffic lights there are health implications for residents even at first floor level. They are making a request for better monitoring and you should wait for reliable data before ignoring this factor. There are few viable transport alternatives to the car which means Hawkhurst would not be an appropriate location for a development of this size. Public transport services are limited and expensive. They do not match with demand for rail services at commute times and certainly do not adequately provide for young people to travel socially or for those on a limited income to access cheaper sources of food or better employment. Travelling East to West by bicycle would perhaps be fine (if you didn’t die in the process) but the topography is a deterrent for the developers idealistic view of us all popping to the shops on bicycles. Maybe in 20 years time electric bicycles will be so cheap that we can all afford them but for the moment this is not realistic. As a community we feel that KCC Highways have provided incorrect data for traffic modelling and have relied heavily upon the traffic surveys of the developers. The traffic data for the Golf Course development included March readings during the ‘Beast from the East’ and ignores the seasonal variations of coast bound Camber traffic. Traffic at a standstill does not add economically to our space paired as it is with inadequate central parking facilities. The relief road merely moves the issue down the road (quite literally) and shoppers will not use a car park so far from the centre. This road is being relied upon in the Sustainability Assessment but it is just a road that would have to be provided to service the properties and is substandard in terms of width and construction. It is a residential road and not fit to take the volume of heavy goods vehicles that will use it. It will crumble. Upon the closure of the top end of Cranbrook Road there is no allocation for a turning space further along if a vehicle should take a wrong turn. Only recently there was a well documented incident of a lorry trying to turn around at the top of Cranbrook Road at the junction with Peter Buswell’s office. There appears to be no plans for buses returning to the village centre via the relief road and Cranbrook Road residents will be marooned from the centre of the village by the closure of the Cranbrook Road at the top of the hill. Kent Fire and Rescue have also commented upon the impact that this road closure would have on them. This development is contrary to the NPPF which requires significant development should be focused on locations that are or can be made sustainable, by limiting the need to travel and offering a genuine choice of transport modes. Congestion, emissions and public health concerns over them will be raised by this development. There is no environmental benefit to the proposed development. The removal of mature trees and habitats are of concern to the Woodland Trust who say that there is no wholly exceptional reason for the development as required by the NPPF. The ‘relief road’ will not work. The road would not provide the benefits which have been claimed. The adverse impact would extend beyond the boundaries of TWBC into Rother DC and beyond KCC into East Sussex CC. None of this seems to have been considered. The displacement of traffic across minor lanes is already a cause for concern in our village and Slip Mill, Delmonden, Whites, Water and Stream Lane all suffer damage, accidents and flooding due to poor management. Unless Highways England have substantial plans for reclassification of the major haulage routes taking HGV’s down from Maidstone to the A21 and not via Cranbrook and Hawkhurst south the road does not provide relief. Major alterations are required to the junction with the A21 at Flimwell to enable HGV’s to turn left to travel south. There are fears otherwise that HGV’s would turn left out of the relief road and turn right at the crossroads in the centre of the village to travel south down Highgate Hill and join the A21 at Coopers Corner/Hurst Green. This is likely to make the crossroads in the centre of the village more congested and less safe for the pedestrians. | ||||||||||||||||
DLP_2509 | Mr Guy Dagger | Object | I consider the scale and distribution of the allocation housing being imposed upon Hawkhurst and Cranbrook, within the AONB (2300 houses over 59 sites) as not consistent with its duty for protection as a national important landscape. The designations lie within the High Weald AONB and paragraph 11 of the NPPF (footnote 6) suggests that AONB designation should constrain levels of housing provision. This is supported by Planning Practice Guidance (Paragraph: 041 Reference ID: 8-041-20190721) which makes it clear that development should be limited in AONBs, and that it may not be possible to meet ‘objectively assessed needs’ in these areas. In the Distribution of Development Topic Paper (Para 3.11), TWBC accepts that strategic-scale urban extensions, would ‘almost certainly not be appropriate’ in the AONB under national policy, and that the statutory purpose of conserving and enhancing the AONB is ‘likely to limit its capacity to absorb new development’. However, in allocating housing numbers to the AONB, no distinction has been made between the proportion of housing allocated to the borough as a whole, and that allocated to two key AONB settlements – Cranbrook and Hawkhurst. The current district-wide allocation of 14776 represents approx. 13 houses/ 100 head of population. With less than two hundred dwellings in Hartley today and a proposal for over two hundred in the future it would be a far higher ratio in certain localities. This is inconsistent with the local plan’s stated policy and with the NPPF. In addition, these AONB settlements appear to be meeting need from elsewhere, most likely from outside of the AONB. Cranbrook and Sissinghurst Neighbourhood Plan assessed the local housing need of these settlements as 610, of which 250 are met by the allocation in the previous local plan at Brick Kiln Farm. This leaves a further 360 to be delivered across both settlements to meet local need. The draft Local Plan allocates 918 to these settlements in Cranbrook. The difference between these two figures suggests need from the wider borough, and potentially nationally as other boroughs have scaled back their proposalis in AONBS (notably Sevenoaks), so with requirements for houses outside of the AONB, is being met in the AONB. This figure amounts to approximately the numbers allocated to the three largest ‘major’ sites which are likely to cause the most harm to the landscape and natural beauty of the AONB. These major allocations are not necessary and should be dropped. The allocations for Hawkhurst, Benenden and Matfield are similarly inflated above what is required to meet local need. Even if the need to allocate development within the AONB has been demonstrated, it does not mean that such provision should be in the form of major development sites. The AONB Management Plan, adopted by Tunbridge Wells Borough Council in March 2019, explains that the High Weald is a small-scale landscape built by hand. The Plan commits authorities to ‘seek to deliver new housing primarily through small-scale developments that meet local need’ (Objective S2, page 34). Paragraph 172 of the NPPF says that ‘Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest’. The tests associated with this policy have not been properly considered and the exceptional circumstances have not been justified. Alternatives to the large allocations have not been properly considered – sites outside the AONB have been dismissed, and the option of reduced allocations on the larger sites offered in the SHELAA has not been properly examined. The Glover Review of designated landscapes recognises the threats to AONBs, particularly in the South East, of excessive development, recommending a stronger role for AONBs in the planning system as a result. The Review highlights the damage done to AONBs through locating major development on its boundaries and within its setting. Planning Practice Guidance also highlights the need to take potential impacts on the AONB into account when considered development in its setting (Paragraph: 042 Reference ID: 8-042-20190721, revised 21 07 2019). Consideration of the new settlement at Capel and the proposed development at East End both on the boundary of the AONB have not involved proper consideration of impacts on the AONB, including the impact of cars, visitors and the impact of the loss of cultural associations with the AONB. | ||||||||||||||||
DLP_3049 | Mr Adrian Cory | Object | Policy Number: STR 1 I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents. I believe that the Council’s conclusion (for example, at Paragraph 4.34) that such sites are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (vide: the Council’s behaviour over the Neighbourhood Development Plan – see above and below – and recent planning decisions taken in the face of legitimate local objections). Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. Paragraph 4.35, in claiming that the Council has encouraged the production of Neighbourhood Plans, surely evidences bad faith on the part of TWBC, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. To the extent that this means anything it is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. This is exemplified in relation to the provision of sewage services by Southern Water, which was the subject of an adjournment debate in Parliament on 28 October (Hansard Vol. 667) in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. We may, therefore, assume, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. Furthermore, we can expect developers to play the old game of submitting amendments to plans, once approved, to dilute their commitments (and associated expense) and that the Council will, as usual, accede to their demands. Later in paragraph 4.40, the Draft Local Plan refers to the need for “Sustainable development of an appropriate scale at the smaller settlements”. I argue below that the proposals relating to Hawkhurst ignore this principle. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects: 1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan; 2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point. Hawkhurst The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course. The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village. There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development. Non-compliance with Hawkhurst Neighbourhood Development Plan The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan which provides that: Larger developments of 10 or more houses will only be supported if it can be demonstrated that there are exceptional circumstances as prescribed by the NPPF and if it can be demonstrated that their impact on the sensitive landscape setting and the considerable environmental constraints of Hawkhurst can be effectively mitigated. There are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment. Lack of adequate infrastructure Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament (see above). The proposed development would impact unacceptably on an AONB The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019. The proposed development would not constitute sustainable development The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment. Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. There are very limited local employment opportunities and no secondary schools within walking distance. The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution. The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it. TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103). The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate. The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF. There is no environmental benefit to the proposed development. It would involve the removal of many mature trees and damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF. The “relief road” will not work As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes. | ||||||||||||||||
DLP_2540 | Mr Graham Clark | Object | In my view the Plan fails to comply with paragraph 38 of the NPPF. This requires that that at least 10% of the housing need should be provided on sites of no larger than one hectare. These small and medium sized sites make a very important contribution to meeting the overall housing requirement of an area and have the benefit of being built out relatively quickly. Instead, the Plan is over reliant on a number of very large strategic allocations. There must be a question mark over the deliverability of some of these sites within the time frame of the Plan. | ||||||||||||||||
DLP_2716 | St. John's Road Residents association | Support with conditions | Development Strategy We believe that non-designated heritage buildings should be preserved with particular reference to Policy AL/RTW 2A and AL/RTW 6: the Civic Complex, Town Hall, Assembly Hall Theatre in the Town Centre in order to preserve the architectural integrity of the Civic Quarter. 1b We support an enhanced town centre development of Royal Tunbridge Wells including a theatre, although not necessarily a new theatre where it is economically viable to refurbish and improve the present Assembly Hall Theatre as we feel that it does provide cultural amenity to the town appropriate to the catchment area and tastes of the audience. It is flexible and is located within the Civic/Cultural Quarter alongside the new Amelia Scott Centre. This provides the town with "a resilient and vibrant town centre to endure over the plan period.". 1c We agree with the development of a new business park giving much needed new employment space at North Farm/Kingstanding Way. 2. and 3. Whilst we support the garden village development in principal we think it is important to weigh the environmental factors as outlined in Section 4.3 and 4.7 with regard to development on Green Belt land and flood defences. | ||||||||||||||||
DLP_2870 | Chris Gow | Object | Paragraph 1b and 1c I object to statements contained in these paragraphs. I contest and object to the need for the new theatre and associated development. I contest and object to the need for wholesale provision of office space and retail space for the town centre, and I think the provision of housing would suit re-generation more in line with realistic economic predictions, and promote residential communities in the town centre. I contest and object to prestigious new business park development in the North Farm retail park. The loss of the motor sales franchise in the near future as the decline in the motor trade as the population realise the continued use of the motor vehicle is unsustainable in the face of global economics and especially the face of global energy consumption will leave vacant retail space. The local Plan must contain a new radical way to examine our future, and must make commitments to a different priority for local community. The A21, in spite of the dual carriage way improvements is a congested route, and adding to the burden of extra traffic movements is not responsible for the local community. If you encourage new employment you have to supply further housing requirements, and the entry into an endless circle of supply and demand. | ||||||||||||||||
DLP_2871 | Chris Gow | Object | Paragraph 2 The development of housing in flood plains is a policy that should be abandoned immediately. The cost of flood defences is very high, and never completely secure against the risk. Climate change is a factor that should cause concern, and completely preclude any development on flood plains. | ||||||||||||||||
DLP_2872 | Chris Gow | Object | Paragraph 7 The use of Green Belt should not be allowed under any circumstances. | ||||||||||||||||
DLP_3410 | High Weald AONB Unit | Object | TWBC: the following comment was submitted by the responders on the left: We object to the scale and distribution of development, particularly within the AONB and its setting. NPPF paragraph 11 says that Councils should provide for objectively assessed needs for housing and other uses, as well as any unmet needs from neighbouring areas, unless “the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area”. The assets referred to are listed in footnote 6 and include Areas of Outstanding Natural Beauty (AONBs). The most relevant policy in the Framework for AONBs is paragraph 172, the first part of which states: a) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy; b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated”. The High Weald AONB Management Plan has been adopted by all the Councils with land in the AONB as their policy for the management of the area and for the carrying out of their functions in relation to it. The Management Plan defines the natural beauty of the AONB in its Statement of Significance and identifies the key landscape components of the High Weald. The Management Plan then sets objectives for these components and identifies actions that could conserve and enhance the AONB. * Objective S1: To reconnect settlements, residents and their supporting economic activity with the surrounding countryside; | ||||||||||||||||
DLP_1960 | Mr Jeremy Waters | Object | I object to the proposal for dispersed growth across rural villages and settlements in the Borough. Horsmonden in particular has fared much worse than other local settlements in this area such as Goudhurst, Lamberhurst and Brenchley, presumably purely the reason that it is mostly outside the AONB and a large acreage of farm land was submitted in the Call for Sites. The Local Plan allocates growth of approximately 28% which is far in excess of historic organic growth levels and would substantially add to traffic levels, infrastructure and quality of life for village populations, thereby destroying the amenity value for everyone. | ||||||||||||||||
DLP_2985 | Mr Keith Lagden | Object | The Draft Local Plan reveals that TWBC prefers to meet its assessed housing needs primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. It is clear that little real consideration is given to the consequences of such developments for the towns and villages concerned nor for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). I would add that 100% of Hawkhurst lies within the AONB! I believe that the Council’s conclusion (for example, at Paragraph 4.34) that such sites are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Neighbourhood Development Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects: 1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the Draft Plan; 2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point. Hawkhurst The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course. The proposed development on the Hawkhurst Golf Club site would destroy the character of an important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development have simply not been properly considered in the Draft Local Plan. Non-compliance with Hawkhurst Neighbourhood Development Plan As mentioned above the proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment. I would repeat Hawkhurst is a village and not an urban area. Lack of adequate infrastructure Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament. The proposed development would impact unacceptably on an AONB The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues, and that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019. The proposed development would not constitute sustainable development The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment. Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. There are very limited local employment opportunities and no secondary schools within walking distance. The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution. The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it. TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103). The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF. There is no environmental benefit to the proposed development. It would involve the removal of many mature trees and damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF. The “relief road” will not work The so-called “relief road” would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes. I would further add that on 24/1019 Mr James Finch Assistant Director - Corporate Services Kent Fire & Rescue Service wrote on the TWBC planning portal regarding his serious concerns for his organisations ability to provide fire and rescue services to the area around Hawkhurst should the Golf Course proposal be granted. When are TWBC planners going to realise what is glaringly obvious to all but themselves that Hawkhurst cannot entertain the numbers of houses being put forward in this ill thought out Draft Local Plan. | ||||||||||||||||
DLP_2009 | Dr David Parrish | Object | Policy STR 1 (The Development Strategy) p.42 Existing, idle, Brown Field Sites are not being compulsorily purchased as a priority - neither Empty Properties too This policy does not include any reference to development on Brownfield sites, but does refer to the release of Green Belt. There is no strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites. | ||||||||||||||||
DLP_2785 | Mrs Karen Langston | Object | The Development Strategy for the delivery of the Local Plan adopts a combination of growth strategies proposed in the Issues and Options document. Prominent in this mix is proportional distribution of growth across all existing settlements (growth strategy 3). This is despite the fact that the consultation recorded a less positive response to this than the other strategies. Also in the mix is growth within a new, free-standing settlement (growth strategy 5). However, the feedback in the Issues and Options consultation, which recorded a slight preference for growth strategy 5, specified that the new settlement should not be in the Metropolitan Green Belt or the AONB. The ‘Distribution of Development Topic Paper’ presents the justification for the proposed Development Strategy, including how the Issues and Options consultation informed the Strategy. However, the outcome is at odds with the feedback and, in several instances, goes directly against the views expressed. The views of the community, particularly when expressed through formal public consultation, should be fairly considered and fully taken into account. The proposed development strategy does not reflect the feedback in the Issues and Options consultation and is highly likely to lack community support. I strongly oppose the proposed approach of dispersed growth across the Borough. It is inconsistent with the NPPF, which advocates focusing development in the most sustainable locations, allocating land with the least amenity value and conserving and enhancing the AONB, where the scale and extent of development within such designated areas should be limited (NPPF paragraphs 171 and 172). It is also contrary to the Council’s previous Local Plan and Core Strategy, which focussed growth in towns, recognising that villages and rural settlements are the least sustainable locations for development. Dispersed growth with proportional development distribution is not consistent with the three objectives of sustainable development, as required by the NPPF (paragraph 8). Matfield is one of the least sustainable settlements in the Borough. It lacks the services and amenities to support significant growth (up to 37.5% in the number of dwellings). There is no evidence of scope for the village to become more sustainable as a result of growth, despite the Council’s untested hope in that it may. (Distribution of Development Topic Paper, paragraph 2.8) Development of this scale in settlements with low sustainability is contrary to the NPPF (paragraphs 7 and 8) and is not in the public interest. | ||||||||||||||||
DLP_1955 | Ms Jacqueline Stanton | Object | Policy STR1 - this policy has chosen a plan which directs development to dispersed growth which is unsustainable because rural settlements cannot support this due to inadequate local infrastructures, lack of jobs and little or no access to public transport. Local roads are not adequate for the volume additional development would create and the vnumber of cars required for these settlements without adequate public transport would make this unsustainable. The settlement hierarchy is also contradicted by this strategy because it shows rural settlement as less appropriate than main and rural towns for the planned volume of growth. | ||||||||||||||||
DLP_1714 | Peter Hay | Object | The Draft Local Plan reveals that TWBC prefers to meet its assessed housing needs primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. However, little real consideration is given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). I believe that the Council’s conclusion (for example, at Paragraph 4.34) that such sites are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its Policy Number: STR 1. The Draft Local Plan reveals that TWBC prefers to meet its assessed housing needs primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. However, little real consideration is given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The entirety of Hawkhurst parish is within the AONB. This means that all sites in Hawkhurst are within the AONB. STR /HA1 includes a worrying mistake from the TWBC LP team who consider that some sites may not be in the AONB and reveals a deeper problem with the way TWBC consider the parish as suitable for large scale development. I believe that the Council’s conclusion (for example, at Paragraph 4.34) that such sites are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and the lack of recognition of the updated NDP for Hawkhurst March 2019 and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. The lack of conformity with, and recognition afforded by the TWBC draft Local Plan for the made TWBC Neighbourhood Development Plan for Hawkhurst (NDP) and the lack of any coordinated support through the TWBC draft Local Plan for the neighbourhood planning process as a means of delivering the aims and aspirations of the TWBC draft Local Plan on the ground. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and the Home Office Minister recommended that no further developments should be approved until the necessary infrastructure is in place. It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:
It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point. | ||||||||||||||||
DLP_2931 | Garry Pethurst | Object | Policy STR1 If most economic development is proposed for the west of the borough and a disproportionate amount of residential development is proposed for the east of the borough, there will inevitably be greater traffic movement but no mention of improved public transport for either Hawkhurst or Cranbrook. There is only a limited increase in economic development proposed for Cranbrook - where does TWBC expect the increased population will work? Is there a strategy for retail development? | ||||||||||||||||
DLP_1591 | Maggie Fenton | Object | Section 4 Paragraph 4.16 (The Development Strategy) p.35 TWBC has been given a housing need figure of 13,560. TWBC has taken the housing need figure of 13,560 and increased it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. The Ministry of Housing, Communities and Local Government have repeatedly made clear via their Ministers and the Secretary of State for Housing that ““the housing need figure is not a mandatory target. Local Authorities should make a realistic assessment of the number of homes their communities need, using the standard method as the starting point in the process. Once this has been established planning to meet that need will require consideration of land availability, relevant constraints and whether the need is more appropriately met in neighbouring areas... The NPPF is clear that only in exceptional circumstances may a Green Belt boundary be altered, through the Local Plan process. Last year we strengthened Green Belt policy in the revised NPPF”. It is clear in the NPPF that housing need alone DOES NOT constitute exceptional circumstances. You have chosen to accept the government’s housing need for Tunbridge Wells borough based on the standard method of calculation. The ONS 2016 figures show a smaller housing need and that policy will be reflected in due course and yet you persist on using outdated statistics. You know that you can protect this borough from the destruction of Green Belt and AONB by following NPPF guidelines. The NPPF para 11(b) says “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless: i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or ii. Any adverse impact of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework when taken as a whole”. The NPPF makes provision for TWBC to have a choice in the provision of the objectively assessed 13,560 houses. If provision of these houses is really only possible by sacrificing Green Belt land then the NPPF makes it perfectly possible for TWBC to say that this is not achievable. TWBC have chosen not to do so. Reduce the number of houses delivered by the Local Plan. Section 4 Paragraph 4.27 p.38 This states that proposed infrastructure is to be delivered alongside development. Given that 63% of your planned development is totally dependant on the building of the Colts Hill Strategic Link (which hasn’t happened in the past 40 years!) makes this a Daft Local Plan & not a draft one. Without the bypass, the so-called Five Oak Green bypass cannot be built and the B2017 will be completely gridlocked. This of course also applies to the flood risk “betterment”, water (both waste & potable), utilities etc. If this plan is approved the infrastructure MUST be provide BEFORE a single new dwelling is constructed. Section 4 Paragraph 4.38 (The Development Strategy) p.39 The Local Plan is almost entirely dependent on the successful implementation of proposed garden settlement in Tudeley and the expansion of Paddock Wood including building on East Capel. They form 63% of the new housing. If these sites fail to deliver then the associated infrastructure that is entirely reliant on developer capital would also never be realised. This appears to stack risk on risk, where both areas of development are inextricably linked and the failure of one would lead to collapse of the other and as a result the whole plan would fail. The plan is therefore unsustainable and unsound. Section 4 Paragraph 4.40 (The Development Strategy) p.39 You refer to Tudeley Village securing a long term option for the borough to deliver the needs of future generations. It is clear from this statement that you intend to add more and more housing to this “garden settlement” in each five year review of future Local Plans. TWBC want to flood Tudeley and East Capel with housing until it coalesces with Tonbridge and Five Oak Green and coalesces Five Oak Green and Paddock Wood, ultimately creating a massive conurbation from Tonbridge to Paddock Wood that will dwarf Tunbridge Wells town centre and turn a grubby, dreary, semi-derelict TW Town Centre in to a ghost town (it’s almost there already) with a Disney style playground for the Hadlow Estate. You have used NDAs to hide your plans until it was too late for residents to have a fair say. Hadlow Estate have offered one letter to residents and a range of evictions to raise funds to pay their masterplanning consultants as their form of “community engagement”. The needs of existing residents have not been met nor apparently considered. The developments in Tudeley and East Capel are unsustainable and do nothing for local employment needs (it will make many local farm workers redundant). | ||||||||||||||||
DLP_1613 | Maggie Fenton | Object | Strategic Objective 1 P.42 At the heart of all dev in the borough will be the timely delivery of infrastructure which will have been funded by development: this infrastructure will have mitigated the impact of development and wherever possible, resulted in “betterment’ for existing residents. YOU CANT USE THE WORD “WILL” & THEN USE THE CAVEAT “WHEREVER POSSIBLE”. HOW IS IT POSSIBLE TO USE THE TERM MITIGATION TO DESCRIBE HUGE INCREASES IN TRAFFIC, NEW ROADS, NOISE & OTHER POLLUTION, LOSS OF OUR BEAUTIFUL COUNTRYSIDE, CPO’S, PRESSURE ON UTILITIES, EDUCATION & HEALTH SERVICES? ANY NEW FACILITIES WILL BE WITHIN THE NEW DEVELOPMENTS. THERE IS NO CONSIDERATION AT ALL FOR EXISTING RESIDENTS. EXACTLY HOW IS THIS “BETTERMENT?” This policy does not include any reference to development on Brownfield sites, but does refer to the release of Green Belt. You should have a strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites. TWBC does not encourage the registration of brownfield sites. Why not? Because its easier to deal with single large landowners. The excuse that piecemeal development does not provide the necessary infrastructure is weak. Section 4 Paragraph 4.49 (The Green Belt) p.49 Exceptional Circumstances do not exist to justify releasing any land from the Green Belt in Tudeley and East Capel. Options for the expansion of Paddock Wood need not include East Capel. One option not taken by TWBC was expansion to the EAST of Paddock Wood …this land is not constrained by MGB. WHY was it not taken forward to feasibility? The release of Green Belt for Tudeley New Town is totally unjustifiable. The 1,900 houses delivered there in this plan period are either not required by TWBC (who can easily reduce their plan to provide 13,560 rather than 14,776 new houses) or can be provided elsewhere outside of the Green Belt and AONB (for example at Horsmonden and Frittenden). Innovative use of Brownfield sites may also provide the housing that TWBC would like to provide by punching a massive, 400 acre hole in the Green Belt. | ||||||||||||||||
DLP_3553 | Lynne Bancroft | Support with conditions | TWBC: the standard response was submitted by the list of responders on the left: The housing need numbers in Cranbrook and Sissinghurst which have been assessed by the Cranbrook and Sissinghurst Parish Council are lower than the housing numbers included in the Local Plan by TWBC for this parish. The number of houses to be developed in Sissinghurst should therefore be reduced as this development is unsustainable with inadequate facilities, poor public transport and connectivity to key employment areas and no employment opportunities in the village. If TWBC wishes to develop a garden village it must ensure that is its proposed location is close to fast transport links, both road and rail, and to economic opportunities. So adjacent to Tunbridge Wells or the dualled A21 corridor would meet this criteria. The east of the borough has poor transport links and poor employment opportunities so such a development would be unsustainable in the eastern area of the Borough. Sissinghurst’s proposed numbers of housing developments outweighs the size of the village and is unsustainable development. Development can only be sustainable if it is done close to existing urban sites due to lack of employment, transport and the destruction of the rural nature of the villages. If housing is to be developed on a dispersed growth basis then employment opportunities through the economic growth strategy should also be on a dispersed growth basis to match increases in population and to minimise additional journeys, via public transport or car. TWBC should not put such large quantities of housing in Sissinghurst and Cranbrook without additional economic opportunities and should have a policy to provide additional business sites, other than those already shown in the Local Plan, in The Weald. | ||||||||||||||||
DLP_2030 | Terry Everest | Object | 1a is ok 1b is ok but not on the site currently proposed, other sites are available nearby such as the old cinema site. 1c is not ok, expansion at North Farm has been rampant and uncontrolled (seemingly) in recent years and the infrastructure has lagged behind by over a decade. The case for a large new business park on land which should be retained as a buffer between the town and the A21 is not as strong as supposed. Hundreds if not thousands of square feet of business space lies unused in and around the town. The land proposed contains multiple ponds, trees and scrub habitats which should be left alone as vital habitats and an environmental buffer for the enlarged A21. 2 needs severe reduction in the housing numbers to make it sustainable and balanced. To triple the size of a town should be unthinkable really, and to massivley develop around a tiny hamlet or village is totally unnacceptable. 3 is totally unacceptable and needs removing from the proposal 4 needs reduction by between 50 and 75% to achieve a more balanced and sustainable development 5 needs reduction by between 60 and 75% to achieve a more balanced and sypathetic development considering how many historic buildings exist in Cranbrook and its special character 6 is ok 7 is unnaceptable, Green Belt is precious and needs protection, if subsequent plans used Green Belt at the same rate as this one it would all be developed and gone by 2360 - which is not that long in the scheme of things. This should not happen. 8 should not be needed if my other recommendations are followed | ||||||||||||||||
DLP_1775 | CPRE Kent | Object | STR1 sets out the Council’s development strategy. In accordance with paragraph 21 of the NPPF there should be a clear distinction between strategic and non-strategic policies. Table 3 lists the scale and distribution of development (by parish/settlement). For clarity it is considered that the strategic allocations should be identified separately. Furthermore, it would be helpful to understand the distribution of development in terms of its relationship to the Council’s settlement hierarchy for confirmation that development is being planned in the most sustainable locations across the borough – in accordance with policy STR2. In terms of the development strategy the Settlement Role and Function Study (February 2017) hasn’t assessed the need for new development at settlements to support or enhance existing facilities. Going through such an exercise would help inform whether the proposed strategy for growth is the most appropriate in terms of keeping existing settlements alive. As such, it is considered that it hasn’t been clearly demonstrated that the balance of growth between the main urban areas of Tunbridge Wells and Southborough; Paddock Wood, Cranbrook, Hawkhurst, Rusthall and Pembury; and the smaller villages is appropriate. A development strategy based on options 3 and 5 for housing (dispersed and new settlement) does not sit well with the stated strategy for employment being based on options 1, 2 and 4 (focussed growth, semi-dispersed and growth corridor). This means that the spatial distribution of future housing and employment needs are not matched – which will result in unsustainable patterns of development as movement takes place between home and work. Of the 7,593 dwellings to be allocated in the plan 1,900 are to be delivered within the plan period at Tudeley Village (better described as a new town than a “village”, given that it is planned to grow up to [2,800] homes and support a population comparable to that of Cranbrook) and 4,000 at Paddock Wood. Relying on two sites to yield 49% of the borough’s housing requirement (after completions, existing permissions, outstanding allocations and windfalls have been taken into account) places a lot of pressure on delivering these sites. Lead-in time for large sites are long, compared to small and medium sized sites. As such the Council’s development strategy should be reviewed. It is difficult to understand how the Council’s stated aims of optimising density (to minimise loss of green belt) has been applied across the proposed allocations. Will schemes be built out at low, medium or high density in the interests of minimising green belt release? In addition to the yield ranges listed in table 3 (scale and distribution of development) these figures have been averaged. Has this average been used to calculate the contribution of allocations towards the Council’s housing requirement? If so, then this figure should be used as an indication of the likely yield. It would be clearer if yields were identified as a minimum dwelling figure. Paragraph 3.29 of the Council’s SHELAA explains that housing yield has been calculated on developable site area using a standard yield of 30dpa. It goes on to say that “a more refined density calculation will be used at a later stage in plan making to inform site allocation policies”. This is lower than the density usually associated with suburban development (40dph) – there appears to be no explanation of what this more refined density calculation is with regard to individual allocations. With 5.35% of green belt in the borough being released for development, CPRE Kent is concerned that the Council does not intend to designate additional land as replacement green belt – and seeks clarification as to why this is. Assurances are also sought as to how compensatory improvements to environmental quality and accessibility of the remaining green belt will actually be delivered (policy STR4). In actual fact this 5.35% figure is not a true reflection of the amount of green belt that will be built on. Several sites are allocated for development but, according to the Distribution of Development topic paper, are not to be released from the green belt – for example: AL/PE6 (land at Tunbridge Wells hospital); AL/RTW13 (Colebrook House); AL/CA2 (secondary school Capel/Tonbridge); AL/SO3 (Mabledon/Nightingale) and AL/SO4 (hotel at Mabledon House). Nor does it include green belt to be taken by the A228 Colts Hill bypass or the new road from Tonbridge to the A228 via Tudeley. Exceptional circumstances The Council has set out in its evidence base the exceptional circumstances for releasing 5.35% of its green belt (see paragraph 6.48 of Distribution of Development Topic Paper), which can be summarised as follows:
The fallacy in accepting such matters as constituting ‘exceptional circumstances’ is they have the consequence that, the greater the proportion of a district that comprises protected areas, the weaker their protection under the planning system. The correct conclusion under the NPPF, properly construed, is that the greater the proportion of a district that consists of protected areas, the less scope there is for development in that district. Tests of ’exceptional circumstances‘, whether in relation to the designation of green belt, or major development in the AONB, should be used only in relation to very specific circumstances affecting a particular development on a particular site, not general issues relating to the district or region as a whole. CPRE Kent considers that there are good reasons why the Tunbridge Wells Local Plan should not meet its housing requirement in full - reflecting the fact that 70% of the borough is designated AONB (and 22% is green belt). Furthermore, if for instance, the proposed secondary school at Tudeley was provided at the proposed Tudeley Village and/or Paddock Wood this would perhaps reduce the amount of green belt land to be developed as well as locating the new school closer to the new development and hence being more sustainably. Moreover CPRE Kent remains to be convinced that the Council has placed sufficient emphasis on increasing density within the towns or on insisting on high density development on green field sites. The result is that far too much AONB and Green Belt countryside is allocated for development. AONB With regard to the AONB, paragraph 172 of the NPPF states: “Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest”. Planning Practice Guidance, July 2019, states: “The National Planning Policy Framework makes clear that the scale and extent of development in these areas should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty. Its policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas. [CPRE Kent emphasis] Paragraph: 041 Reference ID: 8-041-20190721. AONBs together with National Parks have the highest status of protection in relation to landscape and scenic beauty. For National Parks “the Government recognises that the Parks are not suitable locations for unrestricted housing and does not therefore provide general housing targets for them. The expectation is that new housing will be focused on meeting affordable housing requirements, supporting local employment opportunities and key services”[1]. This principle equally applies to AONBs - through paragraph 11(b)(ii) of the NPPF – which seeks to ensure that the scale and extent of development proposed does not harm the purposes for which these areas were nationally designated. On this point the Glover Review (Landscapes Review 2019) sets out how important it is that the “needs and requirements of the local community will be met within the broader context of achieving sustainable development appropriate to these nationally important landscapes” and how AONBs “should not be the place for major intrusive development” (pages 62/63). Building homes in the AONB isn’t ruled out completely, with the report acknowledging that “we need more homes in the countryside, including in national landscapes, but in small numbers, built beautifully and made affordable” (page 105). Dark Skies The rural areas of the borough, including within the High Weald AONB benefit from dark skies [https://www.nightblight.cpre.org.uk/maps/]. Paragraph 180(c) of the NPPF requires plans to limit the impact of light pollution from artificial light on local amenity, intrinsically dark landscapes and nature conservation. Sustainability and climate change The NPPF sets out at paragraph 7 that “the purpose of the planning system is to contribute to the achievement of sustainable development. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without comprising the ability of future generations to meet their own needs.” Footnote 4 to this paragraph refers to Resolution 42/187 of the United Nations General Assembly. This is often referred to as the Brundtland Report of 1987. Whilst it was intended as a response to the conflict between the nascent order promoting globalized economic growth and the accelerating ecological degradation occurring on a global scale it can also relate to climate change. Paragraph 9 continues: “So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development (paragraph 11).” Whilst 11(b) states: “Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas5, unless:
Where footnote 5 states “As established through statements of common ground (see paragraph 27)’ and footnote 6 ‘The policies referred to are those in this Framework (rather than those in development plans) relating to: habitats sites (and those sites listed in paragraph 176) and /or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty: …; irreplaceable habitats; designated heritage assets (and other heritage assets of archaeological interest referred to in footnote 63); and areas at risk of flooding or coastal change.” The NPPF at paragraph 149 requires plans to take a proactive approach to mitigation and adapting to climate change. On 12 June 2019 the Prime Minister announced that the UK will eradicate its net contribution to climate change by 2050. A statutory instrument was laid in Parliament which amended the net UK carbon account target from 80% to 100%[2]. The foreword to the recent Committee on Climate Change (July 2019) points out tougher targets do not in themselves reduce emissions – new plans must be drawn up to deliver them, that climate change will continue to warm in the short-term, and sea level will continue to rise and that we must plan for this reality[3]. The recent House of Commons Science and Technology Committee report[4] in its conclusions and recommendations encourages the Government “to develop and act on policies to ensure that the UK is on track to meet a 2050 net-zero emissions target” and that “it must seek to achieve this through, wherever possible, domestic emissions reduction.”[5] With regard to decarbonising transport the Committee state “The Government’s current long-term for decarbonising transport focus heavily on reducing exhaust emissions and increasing sales of low-emissions vehicles, rather than delivering a low-emissions transport system. In the long-term, widespread personal vehicle ownership does notappear to be compatible with significant decarbonisation. The Government should not aim to achieve emission reductions simply by replacing existing vehicles with lower-emission vehicles.” And continues “it must develop a strategy to stimulate a low-emissions transport system, with the metrics and targets to match. This should aim to reduce the number of vehicles required, for example by: promoting and improving public transport; reducing its cost relative to private transport; encouraging vehicle usership in place of ownership; and encouraging and supporting increased levels of walking and cycling.”[6] [CPRE Kent emphasis]. Siting new development in locations well supported by, or that will support, sustainable transport will help achieve this. This local plan should promote development in locations well served by regular public transport services and social and community facilities, that are in safe walking and cycling distance or would support, or result in, sustainable settlement. Such routes need to feel safe, be well lit, especially for children and women who have to use them after dark - otherwise cars will be the preferred mode of transport. With regard to the Council’s development strategy it appears that it is primarily roads-led, with development securing provision of the Colts Hill bypass, new roads at Tudeley Village and the Hawkhurst relief road, rather than genuinely seeking to achieve sustainable development and less reliance on the private car. Housing delivery The Council’s OAN is 13,560 of which 1,552 have been completed, leaving the need for 12,008 to be provided. Some of this will be in the form of existing permissions, outstanding site allocations and windfall allowance. The remaining 7,593 will be from new allocations of which 1,900 will be at Tudeley and 4,000 at Paddock Wood. These two sites will provide 49% of outstanding new housing. The Housing Supply and Trajectory Topic Paper for Draft Local Plan (September 2019) at paragraphs 4.5.2 and 4.5.3 states that the Council will further engage with developers to review past and future progress of housing delivery; and will ask developers to comment presumptions about lead-in times and delivery rates. This indicates that the present housing trajectory is draft. It may well change, and with reliance on just two sites for almost half of the borough’s housing requirement, may not deliver at the anticipated rates. With regard to build-out rates the Trajectory Topic Paper sets out at paragraph 4.13.4 that national studies for urban extensions in the south of England demonstrate that delivery rates have been in excess of 120 units per annum. It is not clear which studies are being referred to or when they were published, nor the location and scale of the urban extensions. Paragraph 4.13.5, again referring to national studies, states that sites will exhibit lower completions in their first and second years before construction on the site becomes established. At paragraph 4.13.9 gives a build-out rate of 128 for developments of size 1000-2000, and 299 for developments of 2,000+. Table 9 of the Trajectory Topic Paper at page 27 assumes that build-out for Tudeley will commence 2025/2026 and for the periods 2025/2026 to 2029/30 be 150 dwellings per annum and then rise to 200 dwellings per annum to the end of the plan period delivering 1,750 dwellings. On page 30 the assumptions for the 4,000 dwellings at Paddock Wood is that 333 dwellings will be delivered from 2024/25 delivering all 4,000 dwellings by the end of the plan period. CPRE Kent questions these trajectories for the following reasons:
With regard to windfalls Table 10 of the Trajectory Topic Paper [Windfall (Sites of 1-9 Units) Completions (2006-2019) Including Negative Delivery] and paragraphs 5.6.4 and 5.6.6 show that the net average annual windfall was 132 dwellings. Paragraph 5.6.4 goes on to explain that 132 dwellings per annum is unlikely to be sustained over the whole Plan period, as opportunities within LBDs are finite and many of the more achievable infills, redevelopments and conversions have been undertaken. For this reason paragraph 5.6.6 considers that 50 per annum is justifiable. Beyond this statement no evidence is provided to support the assumed of 50 per annum. Hard evidence is required. Table 9 of the Trajectory Topic Paper assumes that Tudeley will start to deliver 2025/26 this is likely to require groundworks in 2024/25. This implies three years from Local Plan adoption to first build out. It assumes that Paddock Wood will start to deliver 2024/25 and again this is likely to require groundworks in 2023/24. CPRE Kent queries whether there is sufficient time to prepare and agree a masterplan and outline application. [1] English national parks and the broads: UK government vision and circular 2010 https://www.gov.uk/government/publications/english-national-parks-and-the-broads-uk-government-vision-and-circular-2010 [2] The Climate Change Act 2008 (2050 Target Amendment) Order 2019: 2.—(1) Section 1 of the Climate Change Act 2008 [3] Committee on Climate Change 2019 Progress Report to Parliament July 2019 [4] House of Commons Science and Technology Committee 20th Report – Clean Growth: Technologies for meeting the UK’s emissions reduction targets. https://publications.parliament.uk/pa/cm201719/cmselect/cmsctech/1454/145402.htm [5] Ibid Conclusions and recommendations paragraph 3 [6] Ibid Conclusions and recommendations paragraph 31 | ||||||||||||||||
DLP_1369 | Mr and Mrs Leach | Object | Re: Draft Local Plan (Regulation 18 Consultation) - Adjoining Resident Comment It was good to meet you at the SaveCapel Public Meeting, on 18th September 2019. We wish to comment on the Draft Local Plan (LP), in relation to certain policies outlined under the headings stated below. We are specifically concerned about the negative impacts of the proposed garden villages will have to our town, especially without adequate public transport provisions, and with such a large loss of the countryside and Green Belt. 2. Policy STR 1 - The Development Strategy We do not believe that the development strategy, including the massive expansion of villages within Capel parish, is justified, in our opinion, and we specifically object to Paragraphs 3, 7 and 8 of this Policy. We also object to the proposed garden settlement in Paragraph 2. Our concerns and comments are further outlined, as follows: 2.1 With regard to Paragraph 35 of the NPPF (2019), another of the criteria that Local Plans are assessed against is whether it is justified, as stated below. Justified - an appropriate strategy, taking into account reasonable alternatives, and based on proportionate evidence. 2.2 With references to Figure 4 Key Diagram, in the Draft Local Plan, it shows the massively enlarged Tudeley Village extending over land presently designated as Green Belt and as part of the High Weald Area of Outstanding Natural Beauty (AONB). Whereas, other northern areas of the Borough, further east, are outside both the Green Belt and the AONB have relatively very little development proposed. 2.3 The justification for allocating a quarter of the Borough's allocation, for this Plan period, at an enlarged Tudeley village is questionable and appears unsound in our opinion. Since other compatible villages outside the AONB and Green Belt, only have small portion of new the housing, for instance Horsmonden only has c.2% of the allocation. 2.4 We cannot see how there is a justification for building on the Green Belt, when alternative suitable sites were put forward earlier in the process. Also, this Policy is not consistent with National planning policy that seeks to protect established Green Belts. For instance, Paragraph 136 of the NPPF (2019) states: Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, ... Green Belt boundaries ... [should] ... endure beyond the plan period. 2.5 Due to there being other suitable sites, within the Borough that can be developed outside the Green Belt; these sites should be taken forward before releasing the Green Belt land and currently as such, it is unlikely that exceptional circumstances exist. 2.6 In addition, it is not clear whether the proposed Green Belt encroachment and the Sustainability Appraisal3 reflect the larger post-Plan (even more unsustainable) Tudeley settlement, with the possible coalescence of villages/towns, as noted in 1.11di. If not, this would be at odds with the NPPF (2019), i.e. Paragraphs 134 and 136. The former lists the Green Belt purposes that this LP might be inconsistent with, including:
Although, a Sustainability Appraisal3 has been prepared, as part of the process, we do not agree with the specific scoring/conclusions that support this Policy and the Plan. 2.8 Our points in-relation to the Sustainability Appraisal Table 25 (Capel Parish Sites): a) We have the view that some of the Sustainability Objective scores are questionable and may not take account of wider impacts. For instance, Employment - there will be a loss of local rural employment, with relatively little new retail/service jobs created at in Tudeley and so the outcome is more likely to be neutral on this basis. However, when you consider the impact on Tonbridge, with the resulting congestion likely to harm the viability of many local businesses (see Section 1) that offsets increased commuter trade, this score could actually be slightly negative. b. Travel should not be shown as positive, since it is a car reliant development (1.11c). c. We agree that the Capel parish Environmental Objectives have mostly negative scores, with some of these issues highlighted above (in item 1.11diii). However, when considering the wider impact of the development, for instance air quality limits likely to be exceeded in Tonbridge - with the loss of trees and resulting town centre congestion; a more realistic outcome should be a double negative score (i.e. "--"). d. Due to the poor scoring of the Environmental Objectives, such a large development in the Capel parish is questionable; as it could be argued that there are insufficient net gains across the two other overarching Objectives (economic and social) to offset the immense environmental harm of the current proposals. Thus, we do not believe that the proposed massive village expansions can be considered as being sustainable developments and so are contrary to the NPPF (2019), Paragraph 8. e. In addition, these garden village proposals are also incompatible with the strategic objectives set out in this Draft Local Plan, including Objective 8 (see item 1.11). f. Land use rightly scores the worst (typically double / triple negative, i.e. "--/--"). This helps to both highlight how unsustainable this development is and shows that the proposed development strategy is at odds with National planning policy, which promotes brownfield development and the protection of the Green Belt (item 2.6). g. Some of these comments also apply to the other garden village in Paddock Wood. 2.9 We also note that in this Policy (STR 1) there is the absence of a specific Borough wide approach for developing brownfield sites. Conversely, reference is made to releasing land for development that is presently designated as Green Belt or an AONB. 2.10 The apparent Borough-wide greater emphasis for promoting Green Belt development, over proactively encouraging brownfield redevelopment, is completely at odds with National planning policy (see item 2.6) and is certainly not the basis of a sound Plan. 2.11 In light of the Policy (STR 1) shortcomings identified, which do not appear to favour the Borough-wide brownfield redevelopment, and with the poor land/environmental scores obtained for many of the proposed sites, in the Sustainability Appraisal3. We would advocate that the all sites originally put forward are re-apprised on the basis of favouring the reuse of brownfield land and then sites outside the Green Belt. In addition, this Policy, should set out the approach for positively encouraging the release of brownfield land for development within this Plan period. Without such a strategy and site re-appraisal, the basis of this Local Plan and the justification for the developments might be considered fundamentally flawed and unsound in terms of the NPPF (2019). 2.12 A strategy and site appraisal that may not promote the development of derelict and non-Green Belt land, could have resulted in an approach that favoured unsustainable large scale village developments; instead of smaller developments, equitably spread across the Borough, to unlock the greatest amount of brownfield re-development. By giving developers the nod to build on the easier Green Belt sites, they are likely to keep ignoring other more sustainable brownfield sites that may require remediation. 2.13 We believe that is not sound nor sustainable, with a questionable basis (Items 2.11-12_, for building ober-half (61%, 2,800 + 4,000 new homes at Tudeley and Paddock Wood respectively) of the housing allocation, in two large nearby village developments, at the edge of the Borough with poor public transport links. It is also not fair to push the brunt of the development impacts on to an adjoining Borough Council and its residents. 2.14 We are also concerned about the deliverability of the Local Plan, with such a large amount housing proposed in these garden villages. In Tudeley it is proposed that 1,900 of the 2,800 homes will be built during the Plan period. However, as noted above (in item 1.11a) the average build-out rate2, for this period of 15 years, is just 1,000 houses. This is likely to result in a short-fall of around 1,000 homes built in this period. 2.15 In addition, a further 4,000 homes proposed in nearby Paddock Wood, within same Plan period, so it is likely that the local housing market will be super-saturated with new builds. Thus, in reality there is likely to be a short-fall of c.5,000 homes built and so it would be better to disperse new houses across the Borough, to reduce the local market saturation. It is also questionable how many buyers would choose these houses in developments; with such poor public transport links and limited local facilities, considering the forecast economic downturn and the current over-supply of houses. 2.16 Futhermore, with a possible 45% (c.5,000) of the housing proposed potentially undeliverable, due to the limited build-out rates (see Items 1.11a, 2.14-2.15), there apepars to be a significant risk that the Borough council will to fail demonstrate it's five housing supply within a decade. As such the proposed Plan is unlikley to meet the requirements of the NPPF (2019), including Plan-making in paragraph 16 that states. Plans should: ...b) be prepared positively, ... aspirational but deliverable; 2.17 Additionally, if there was a large shortfall in house sales, this might undermine the viability of delivering the Masterplans and the required infrastructure improvements, including a station. This is also likely to compound the issues highlighted in Section 1. 2.18 In summary and in light of the apparent short-fall in deliverable housing (Item 2.16), and the short-comings that favour Green Belt developments (Item 2.11), we are of the opinion that Paragraph 3 (Policy STR 1) should be removed and replaced with more sustainable polices that are more deliverable, with a better spread of housing across the Borough. Otherwise, we strongly contest that this Draft Local Plan is unsound. 2.19 Our objection to Paragraph 7 (Policy STR 1) relates to the release of Green Belt, as we do not believe that exceptional circumstances exist, with alternative sites available. This is contrary to the NPPF (including Para. 136 and 137 - as other sites are available to meet this need) and this will erode the countryside buffers between settlements. 2.20 Our objection to Paragraph 8 (Policy STR 1) relates to permitting development on land designated as an AONB, with alternative sites available. The large scale of the Tudeley development, within AONB and 1km buffer zone, is likely to harm the landscape setting. In conclusion, we do not consider that the Draft Local Plan is sound, in relation to the proposed large garden settlements, with inadequate infrastructure connecting nearby towns. The current proposal for such a substantial loss of the Green Belt and countryside, as part the massive village expansions, is not sustainable development and nor is it consistent with National planning policy. This will cause immense environmental harm, including a heavy reliance on car use with poor public transport links. The justification for building on the Green Belt is unsound, as there are alternative brownfield and non-Green belt sites available. We are also concerned about the deliverability of the Draft Local Plan, with the local market saturation of nearly 6,000 new houses allocated for two nearby villages within one local area. In light of these concerns and the potentially flawed approach in favouring Green Belt development, over other suitable sites and as no exceptional circumstances exist, alternative sites should be considered. A more sustainable development approach might be to spread the allocation across the Borough, reducing the concentrated development pressures and local market saturation, whilst helping to unlock the greatest amount of brownfield re-development. | ||||||||||||||||
DLP_2760 | Cllr Keith Obbard | Object | WEALDEN GREEN PARTY RESPONSE TO TWBC DRAFT LOCAL PLAN We wish to register our objections to the TWBC Draft Local Plan for the following reasons. Policy STR1 - Development Strategy We object to the scale and distribution of development, particularly within the Area of Outstanding Natural Beauty (AONB) and its setting. Levels of housing provision The National Planning Policy Framework (NPPF) paragraph 11 says that Councils should provide for objectively assessed needs for housing and other uses. The most relevant policy in the Framework for AONBs is paragraph 172, the first part of which states: “Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within these designated areas should be limited”. Seventy percent (70%) of Tunbridge Wells borough lies within the AONB, and it is our view that the extent of national protected landscape should constrain levels of housing provision in the borough. TWBC should carry out a transparent assessment demonstrating that in deciding the level of housing provision proposed, the type of homes and the distribution of those homes, great weight has been given to conserving and enhancing landscape and scenic beauty in the AONB; the conservation and enhancement of wildlife and heritage has been taken into account; and the scale and extent of development within the AONB has been limited. In our view TWBC has failed to limit the scale and extent of development proposed in the AONB, contrary to the guidance. Furthermore, the numbers of dwellings proposed is excessive, and based on outdated methodology. The Office for National Statistics has produced a revised "2016" methodology, which in the case of Tunbridge Wells would require only 67% of the stated figure, If this factor is applied the resulting net number of new dwellings required goes down from 7,593 to 3,115, ie. to much less than half. This, together with additional brownfield developments first could obviate the need for use of Green Belt land. | ||||||||||||||||
DLP_1640 | Richard Bysouth | General Observation | STR 1: | ||||||||||||||||
DLP_2019 | Penelope Ennis | Object | The Draft Local Plan is indicating that TWBC prefers to meet its housing needs by the approval of large-scale developments in Wealden Towns and Villages. Why are you not prepared to consider the small scale developments first? Is it because the temptation of S106 Contributions are irresistible and small scale developments wont attract such large contributions? The consequences of such developments for the AONB and the villages concerned are very real. You are selling the family silver and the damage will last forever. I understand from our Parish Council that depending upon which set of calculations are used the Housing Needs Allocation could be halved. TWBC have chosen to exceed the allocation requirements across the borough compounding the excessive allocations not just for Hawkhurst but other parishes across the borough. We also have concerns over the definition of windfall development which could lead to large scale sites being excluded from our Parish Allocation but being used by the TWBC to meet its own targets. This Draft Local Plan will not be preserving the AONB that represents 70% of our borough. There will be no character or charm or countryside left in our borough. We will all become 'copy and pasted' versions of the developers' little book of architecture. Paragraph 4.36 suggests that there is agreement with the Parish Councils on development sites. Central Government led us down a path to develop our Neighbourhood Development Plan (at considerable expense in time and money). Now, armed with this document, the Parish Councils' comments are being completely ignored. It's as if you've forgotten you asked us to prepare this document and this later of 'consultation' is now very inconvenient and very boring that we keep reminding you about it! This is TWBC's NDP for Hawkhurst - you are voting against your own policy. Hawkhurst Parish Council have decided not to comment upon their preferred sites as they feel this would compromise the planning process at a later date. The reason for not choosing preferred sites at the time of submitting the NDP was that the Parish was already delivering ahead of allocation. 4.2 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. TWBC have approved applications in the face of huge local opposition and in direct contravention our Neighbourhood Development Plan. Our population, number of houses and properties has overwhelmed the capacity of services to cope. Hawkhurst has been playing a part in the allocations and suffered the consequences. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected. in Hawkhurst, we are constipated and we have indigestion. In targeting the larger sites you have not maximised the smaller sites before biting into the AONB. As I understand the NPPF gives TWBC the opportunity to reduce your allocation due to a high percentage of the borough being AONB. You have chosen to increase your allocation. The sites illustrated in your Draft Plan are not appropriate in scale for the AONB. Paragraph 4.4- claims that the growth strategy is based upon the premise of infrastructure-led development. This is misleading as the Council has no control over the provision of infrastructure, services and facilities on the scale that we require to support developments of the size proposed. A perfect illustration is the provision of sewerage by Southern Water. Southern Water have admitted that the infrastructure is inadequate to support further housing development and recommended that no further development should be approved until the necessary improvements are made. The fouling of waterways by Southern Water was entirely foreseeable to local residents. Improvements are not made when they should be made, if at all and residents suffer the consequences. The development plans for Heartenoak are already non-compliant and there is no provision for the Golf Course development at all. The development of Fieldways/Westfield will displace water down a steep valley and in the vicinity of historic buildings. On the south side of the village water courses are being changed by the landscaping and concreting of developments near the centre of the village. The development strategy outlined from paragraph 4.41 onwards is flawed in two respects: 1. It treats each proposed development in isolation from all the others and ignores the consequences for sustainability and infrastructure, of their combined effects. Developments in Cranbrook, Sissinghurst, Sandhurst and Hawkhurst impact on the infrastructure which you have not represented in your plan. We already have experience that traffic surveys conveniently do not factor in a half-finished development near us, swaying the count. We really need some reliable data based upon the Site Allocations in these Parishes and how they join to impact upon each other. For example 300 houses at Hartley on the south side of Cranbrook is bound to to generate traffic into Hawkhurst. We hope that our Parish Council will challenge you to look at the Allocations in Rother and East Sussex and Ashford Borough Council to see what the overall impact from each direction might be. 2. TWBC - have no control over the developments in neighbouring counties neither can they press neighbouring local authorities to address infrastructure needs that are generated by a TWBC decision. | ||||||||||||||||
DLP_2145 | Michael O'Brien | Object | The Draft Local Plan is indicating that TWBC prefers to meet its housing needs by the approval of large-scale developments in Wealden Towns and Villages. Why are you not prepared to consider the small scale developments first? Is it because the temptation of S106 Contributions are irresistible and small scale developments wont attract such large contributions? The consequences of such developments for the AONB and the villages concerned are very real. You are selling the family silver and the damage will last forever. I understand from our Parish Council that depending upon which set of calculations are used the Housing Needs Allocation could be halved. TWBC have chosen to exceed the allocation requirements across the borough compounding the excessive allocations not just for Hawkhurst but other parishes across the borough. We also have concerns over the definition of windfall development which could lead to large scale sites being excluded from our Parish Allocation but being used by the TWBC to meet its own targets. This Draft Local Plan will not be preserving the AONB that represents 70% of our borough. There will be no character or charm or countryside left in our borough. We will all become 'copy and pasted' versions of the developers' little book of architecture. Paragraph 4.36 suggests that there is agreement with the Parish Councils on development sites. Central Government led us down a path to develop our Neighbourhood Development Plan (at considerable expense in time and money). Now, armed with this document, the Parish Councils' comments are being completely ignored. It's as if you've forgotten you asked us to prepare this document and this later of 'consultation' is now very inconvenient and very boring that we keep reminding you about it! This is TWBC's NDP for Hawkhurst - you are voting against your own policy. Hawkhurst Parish Council have decided not to comment upon their preferred sites as they feel this would compromise the planning process at a later date. The reason for not choosing preferred sites at the time of submitting the NDP was that the Parish was already delivering ahead of allocation. 4.2 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. TWBC have approved applications in the face of huge local opposition and in direct contravention our Neighbourhood Development Plan. Our population, number of houses and properties has overwhelmed the capacity of services to cope. Hawkhurst has been playing a part in the allocations and suffered the consequences. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected. in Hawkhurst, we are constipated and we have indigestion. In targeting the larger sites you have not maximised the smaller sites before biting into the AONB. As I understand the NPPF gives TWBC the opportunity to reduce your allocation due to a high percentage of the borough being AONB. You have chosen to increase your allocation. The sites illustrated in your Draft Plan are not appropriate in scale for the AONB. Paragraph 4.4- claims that the growth strategy is based upon the premise of infrastructure-led development. This is misleading as the Council has no control over the provision of infrastructure, services and facilities on the scale that we require to support developments of the size proposed. A perfect illustration is the provision of sewerage by Southern Water. Southern Water have admitted that the infrastructure is inadequate to support further housing development and recommended that no further development should be approved until the necessary improvements are made. The fouling of waterways by Southern Water was entirely foreseeable to local residents. Improvements are not made when they should be made, if at all and residents suffer the consequences. The development plans for Heartenoak are already non-compliant and there is no provision for the Golf Course development at all. The development of Fieldways/Westfield will displace water down a steep valley and in the vicinity of historic buildings. On the south side of the village water courses are being changed by the landscaping and concreting of developments near the centre of the village. The development strategy outlined from paragraph 4.41 onwards is flawed in two respects: 1. It treats each proposed development in isolation from all the others and ignores the consequences for sustainability and infrastructure, of their combined effects. Developments in Cranbrook, Sissinghurst, Sandhurst and Hawkhurst impact on the infrastructure which you have not represented in your plan. We already have experience that traffic surveys conveniently do not factor in a half-finished development near us, swaying the count. We really need some reliable data based upon the Site Allocations in these Parishes and how they join to impact upon each other. For example 300 houses at Hartley on the south side of Cranbrook is bound to to generate traffic into Hawkhurst. We hope that our Parish Council will challenge you to look at the Allocations in Rother and East Sussex and Ashford Borough Council to see what the overall impact from each direction might be. 2. TWBC - have no control over the developments in neighbouring counties neither can they press neighbouring local authorities to address infrastructure needs that are generated by a TWBC decision. | ||||||||||||||||
DLP_2431 | J Coleman | Object | The development in the eastern part of the Borough is too high and is disproportional to that taken by Tunbridge Wells. The development in the eastern area of the borough is not sustainable due to the distance to key employment sites and poor public transport links. It will also damage the high sensitivity landscape around Cranbrook and Sissinghurst. | ||||||||||||||||
DLP_2470 | G Baker | Object | The proposed new housing numbers in Sissinghurst is too high and is disproportional to that taken by Tunbridge Wells. There are a lack of facilities in the area and the developments are not sustainable due to the distance to key employment sites and poor public transport links. | ||||||||||||||||
DLP_2674 | Rebecca Cubitt | Object | I challenge the need for so many houses to be built over the plan period of 2016-2036. The Office for National Statistics estimates borough population growth of 13,952 people, and with an average house occupancy rate of 2.35 people (117,140 people living in 49,880 houses), the need is for 5,937 houses (of varying sizes). Other comments: Traffic in Tunbridge Wells is bad enough. Why add to the problem? Air quality will become terrible and ruin this beautiful area. | ||||||||||||||||
DLP_2833 | Helen Parrish | Object | Existing, idle, Brown Field Sites are not being compulsorily purchased as a priority - neither Empty Properties too | ||||||||||||||||
DLP_2965 | Michael Alder | Object | The Draft Local Plan emphasises that TWBC prefers to meet its assessed housing needs by approving large-scale developments. It is clear that no consideration had been given to the consequences of this when related to the preservation of the ANOB where Hawkhurst is 100% covered by the ANOB criteria. The claim by TWBC ( para 4.36 ) that there is a level of agreement with Parish Councils on development sites is incorrect, certainly in the case of Hawkhurst. The NDP for Hawkhurst submitted in March 2019 has been ignored by TWBC -- if read at all -- although it has be "made" and must be taken into account when preparing the Local Plan. There has been much speculative housing development recently in Hawkhurst despite the fact that numbers of properties identified in earlier Neighbourhood Development Plans have already been exceeded. The calculations for the TWBC Draft Local Plan assume a zero base which is a basic error. Hawkhurst has already been seriously impacted by this. Paragraph 4.40 claims that the growth strategy is based on infrastructure-led development. The experience in Hawkhurst is that statutory think otherwise. Sewage and transport provision for the existing demand of Hawkhurst is failing dismally. Southern Water themselves have admitted that their infrastructure is inadequate for further development. Transport, education and health services are facing the same situation. | ||||||||||||||||
DLP_3089 | Tony Fullwood | Object | Policy STR 1 - The Development Strategy is a key strategic policy in the draft Local Plan. Criterion 6 applies to a large number of smaller settlements in the Borough:
Policy STR/BE 1 - The Strategy for Benenden Parish is dependent on Policy STR 1, which makes the definition of other suitable windfall developments even more imperative: Policy STR/BE 1 - The Strategy for Benenden Parish is a key policy for Benenden Parish. Criterion 2 states: Additional housing may be delivered through the redevelopment of appropriate sites and other windfall development in accordance with Policy STR 1; The draft Local Plan therefore contains two inter-related policies which employ different wording. Importantly, the draft Local Plan does not clearly define the terms ‘other suitable windfall developments’ (though by definition criterion 6 of Policy STR 1 indicates that it must be on sites outside the LBD) or ‘other windfall development’. The NPPF states:
c) support the development of windfall sites through their policies and decisions – giving great weight to the benefits of using suitable sites within existing settlements for homes; Policy STR 1 criterion 6 partially follows this approach but without a definition of ‘other suitable windfall developments’, it is not clear whether Policy STR 1, or by association Policy STR/BE, is consistent with national policy. In this respect, provided a number of criteria are met, the draft Local Plan already permits the following types of windfall development outside the LBDs:
The NPPF also allows limited infilling or the partial or complete redevelopment of previously developed land in the Green Belt (Para 145) and this would presumably apply elsewhere in the Borough. This would facilitate Policy AL/BE 4 where there is no existing LBD. The draft Local Plan makes it clear that the definition of LBDs is an established policy tool to provide both certainty and clarity on where new development would generally be acceptable in principle. By drawing LBDs around settlements (including land to meet growth needs), LBDs help focus growth to sustainable locations/settlements, while protecting the surrounding, more rural areas from inappropriate and intrusive development (Para 4.81). As set out in the Council's Limits to Built Development Topic Paper, the following principle is one which is used to define LBDs:
It is therefore implied, given 70% of the Borough is covered by the High Weald Area of Outstanding Natural Beauty (AONB) and 22% is within the Metropolitan Green Belt (MGB), that greenfield sites outside the LBDs do not constitute ‘other suitable windfall developments’. This is contradicted by the paragraph in Policy STR/BE1 which permits major development larger than approximately 100 residential units on greenfield windfall sites anywhere in Benenden Parish. Given that there is no spatial precision to this policy, or any limit to the number of times it could be applied, as worded this policy is not consistent with national policy (Para 172 or draft Local Plan Policy EN 21 - High Weald Area of Outstanding Natural Beauty) in respect of most of the parish which is within the High Weald AONB. Nor is Policy STR/BE1 justified (an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence) and would lead to unsustainable development. Policy STR 10 - Limits to Built Development Boundaries states: ..Outside the Limits to Built Development, development will normally be limited to that which accords with specific policies of this Plan and/or that for which a rural location is demonstrated to be necessary. However, without a clearer definition of ‘other suitable windfall developments’ it is not clear whether proposed development would accord with Policy STR 1 and Policy STR BE1 or not. Change required Policy STR 1 requires greater clarity by defining the term ‘other suitable windfall sites’. The following are given as a definition which would be consistent with other policies in the draft Local Plan (see Objection to STR BE1) and the NPPF:
Policy STR1 should make it clear that other suitable windfall development does not include greenfield sites unless it involves Rural Exception Sites; Rural Workers' Dwellings or a house of exceptional design quality in accordance with Local Plan policies and the NPPF. The following Paragraph should be deleted from Policy STR/BE 1: Any major development larger than approximately 100 residential units on greenfield windfall sites is expected to provide suitable employment floorspace, to be discussed with the Local Planning Authority and Benenden Parish Council through pre-application discussions. | ||||||||||||||||
DLP_3168 | Kent County Council (Growth, Environment and Transport) | Object | Highways and Transportation The County Council, as Local Highway Authority objects to the policy. | ||||||||||||||||
DLP_3169 | Kent County Council (Growth, Environment and Transport) | General Observation | Provision and Delivery of County Council Community Services Paragraph 5 - The County Council would welcome more specific commentary about the social care and community facilities requirement within this policy | ||||||||||||||||
DLP_3423 | Sally Marsh | Object | TWBC: the standard response was submitted by the list of responders on the left: Policy Number: STR 1 The Development Strategy I object to the scale and distribution of development within the AONB, and particularly within Cranbrook and Hawkhurst. An additional 2300 houses across 50 sites within the AONB is not consistent with its protection as a national important landscape. Seventy percent (70%) of Tunbridge Wells borough lies within the High Weald AONB and paragraph 11 of the NPPF (footnote 6) suggests that AONB designation should constrain levels of housing provision. This is supported by Planning Practice Guidance (Paragraph: 041 Reference ID: 8-041-20190721) which makes it clear that development should be limited in AONBs, and that it may not be possible to meet ‘objectively assessed needs’ in these areas. In the Distribution of Development Topic Paper (Para 3.11), TWBC accepts that strategic-scale urban extensions, would ‘almost certainly not be appropriate’ in the AONB under national policy, and that the statutory purpose of conserving and enhancing the AONB is ‘likely to limit its capacity to absorb new development’. However, in allocating housing numbers to the AONB, no distinction has been made between the proportion of housing allocated to the borough as a whole, and that allocated to two key AONB settlements – Cranbrook and Hawkhurst. The current district-wide allocation of 14776 represents approx. 13 houses/ 100 head of population. Similarly, the allocations within the AONB in Cranbrook and Benenden ward, and Hawkhurst and Sandhurst ward also represent 13 houses/ 100 head of population, respectively. This is inconsistent with the local plan’s stated policy and with the NPPF. In addition, these AONB settlements appear to be meeting need from elsewhere, most likely from outside of the AONB. Cranbrook and Sissinghurst Neighbourhood Plan assessed the local housing need of these settlements as 610, of which 250 are met by the allocation in the previous local plan at Brick Kiln Farm. This leaves a further 360 to be delivered across both settlements to meet local need. The draft Local Plan allocates 918 to these settlements. The difference between these two figures suggests need from the wider borough, most likely outside of the AONB, is being met in the AONB. This figure amounts to approximately the numbers allocated to the three largest ‘major’ sites which are likely to cause the most harm to the landscape and natural beauty of the AONB. These major allocations are not necessary and should be dropped. The allocations for Hawkhurst, Benenden and Matfield are similarly inflated above what is required to meet local need. Even if the need to allocate development within the AONB has been demonstrated, it does not mean that such provision should be in the form of major development sites. The AONB Management Plan, adopted by Tunbridge Wells Borough Council in March 2019, explains that the High Weald is a small-scale landscape built by hand. The Plan commits authorities to ‘seek to deliver new housing primarily through small-scale developments that meet local need’ (Objective S2, page 34). Paragraph 172 of the NPPF says that ‘Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest’. The tests associated with this policy have not been properly considered and the exceptional circumstances have not been justified. Alternatives to the large allocations have not been properly considered – sites outside the AONB, for example at Colliers Green, have been dismissed, and the option of reduced allocations on the larger sites offered in the SHELAA has not been properly examined. The Glover Review of designated landscapes recognises the threats to AONBs, particularly in the South East, of excessive development, recommending a stronger role for AONBs in the planning system as a result. The Review highlights the damage done to AONBs through locating major development on its boundaries and within its setting. Planning Practice Guidance also highlights the need to take potential impacts on the AONB into account when considered development in its setting (Paragraph: 042 Reference ID: 8-042-20190721, revised 21 07 2019). Consideration of the new settlement at Capel and the proposed development at East End both on the boundary of the AONB have not involved proper consideration of impacts on the AONB, including the impact of cars, visitors and the impact of the loss of cultural associations with the AONB. | ||||||||||||||||
DLP_3761 | Martin Robeson Planning Practice for Tesco Stores Ltd | Support with conditions | STR1 – The Development Strategy (support with conditions) Tesco broadly supports the Council’s development strategy, particularly the intention to make provision for all development needs inside the Borough boundary (ie, without the assistance of neighbouring authorities). Tesco also supports the proposed growth of Paddock Wood (see later) but questions, in terms of the scale of new development to be directed there, and to Capel/Tudeley, whether the full potential of existing settlements to accommodate growth has been explored, and in so doing, enhancing their sustainability. Indeed, there appears to be an imbalance between the scale of development directed to certain settlements relative to their scale and sustainability. Such distribution must be fully justified and, if maintained as currently proposed, accompanied by proposals for commensurate improvements in local infrastructure, including convenience retail facilities. | ||||||||||||||||
DLP_4234 | Rother District Council | Paragraph 4.38 and Policy STR1 Support The proposed development strategy for the borough, and specifically the way in which it takes account of the need to maximise the amount of major development outside of the High Weald AONB, is consistent with this Council’s approach. | |||||||||||||||||
DLP_4360 | British Horse Society | Support with conditions | The major new settlements and the borough’s green infrastructure network should include new and generous provision for horse riding. This should be an integral part of the new infrastructure that is planned to mitigate the impact of development and to result where possible in “betterment”. The new developments at Hawkenbury, particularly the new sports hub, should provide horse riding routes that link to the existing public bridleways nearby. In some London Boroughs, horse riding routes have been created around the perimeter of playing fields and the same could be done here. | ||||||||||||||||
DLP_4381 | Frant Parish Council | Object | Frant Parish Council (herein after referred to as ‘the Council’) has considered in depth the content of the Draft Local Plan (‘the Plan’) and the accompanying documents and wishes to make the following representations. As a neighbouring parish to the Borough, the Council is only too aware of the way in which, over time, built development has made its steady march toward the parish boundary (which marks the change in county), outwards from Tunbridge Wells. Para 2.44 of the Plan states that “the cumulative impact of minor piecemeal development and small changes in land use can have a significant overall adverse impact on the natural, built and historic environment, and on the character and settlement patterns within, and adjacent to, the High Weald AONB”. A very good example of this increasing encroachment, in part comprised of piecemeal development, is that which has been occurring adjacent to Bells Yew Green in recent years, with ongoing residential development. A significant by-product of this is the deleterious effect on the local road network, of which much lies within the parish. This road network is made up of C- and D-class roads. They are by their nature narrow, mostly single-track country lanes, peppered with sharp turns and bends, historic features such as an old bridge and walling, overhanging vegetation, no road markings, wildlife and so on. These roads, particularly Dundale Road, Hawkenbury Road, Benhall Mill Lane and Ivy Lane are suffering immeasurably already from the excessive number of vehicles using these routes as a way to access the A21; many of these vehicles are large, articulated lorries that simply cannot navigate these C- and D-class roads, regularly making the roads impassable as they attempt to reverse away from or squeeze past other road users. New development simply adds to the burden on these local roads – roads that were never designed to or anticipated to accommodate this load of traffic. A high concentration of traffic on these types of roads also detracts from their rural quality and character, particularly where they lie within the AONB. The Plan appears to be relying on developer contributions to improve the more major roads to accept the consequences of new development, rather than to establish the capacity of the roads first to in turn then help to inform what level of development would be acceptable. Para 2.9 acknowledges highway capacity as a constraint to future growth. Para 2.23 identifies “…the significant transport challenges, particularly in terms of managing existing congestion and future growth…” and lists the various A-class roads, including those which affect the parish – the A21, A267 and A26. As above, the parish is used as a ‘cut through’ to the A21; para 2.23 again acknowledges the problems in and around this location where it states “…congestion on the A21 at Kippings Cross… remain(s) unresolved”. This situation reflects the current, baseline scenario and further development can only worsen this. Turning to infrastructure more generally, para 2.18 states that a “…new Infrastructure Delivery Plan will identify all infrastructure requirements as a result of the new development proposed”. This methodology suggests that rather than the level of infrastructure required to sustain a development inform the extent of the development that can be achieved, it would appear to be the other way round - the level of development is decided upon and then the extent of infrastructure required is then determined. The reality for many areas in both Wealden and Tunbridge Wells is that the provision of effective and sufficient infrastructure is often an after-thought and, as above, relies on several providers delivering the infrastructure in a timely way and on budget, on delivering infrastructure that will be sustainable and on the input of developer contributions. A case in point is the new development proposed at land to the west of Eridge Road at Spratsbrook Farm at Policy AL/RTW 18 (SHELAA Site Number 137). The doctors’ surgery serving the Ramslye Estate has now closed. While the Council is not privy to the reasons why, it suspects the ever-growing decline in GP numbers may well be one reason. Thus, in reality, a new surgery building can be provisioned for in a new scheme, but the commitment of GPs for the surgery cannot be assured. A significant shortfall in infrastructure delivery of a key service thus immediately becomes a problem. In 2017, Wealden District Council made a call for sites and Dandara (housebuilders) submitted a ‘SHELAA’ for the site in question. After consideration of the sites submitted, Wealden District Council did not include the 176-acre site as a development site in its draft Local Plan. At that time, the Council submitted comments dated January 2018 to TWBC, raising concerns about the prospect of future development in this area. The Council wrote: “There are a number of constraints related to the site, including that parts of it are located within the AONB, the Green Belt and a designated SSSI. It is also sited within near proximity of the Ashdown Forest and you will be aware of the ongoing issues surrounding any development that exacerbates those issues. For the reasons set out above, the Parish Council are concerned about the impact that such a development would have on the environment within which it is located. The Council is also concerned about the impact and pressure this scale of new development would pose on the local infrastructure, particularly the local road network, the local school and other amenities”. The Council would reiterate those comments now, in relation to Policy AL/RTW 18 and would note that this new development will be in close proximity to Eridge (within the parish) and will be served in part by the A26. Traffic along the A26 is already excessive and this new development, as well development ongoing in Crowborough, will add to this significantly. The existing hotspot around Sainsburys and onto the roundabout at Major York’s Road will not be able to cope with further demands on it arising out of new development. The site is within the 15k Ashdown Forest zone and thus an increase in traffic can only have a negative impact on the Forest’s already vulnerable ecology. There will be negative consequences for the neighbouring SSSIs at High Rocks and Eridge Park, itself registered as an Historic Park and Garden, and the Broadwater Warren Reserve, which is within one mile of the site. The site is located on an exposed ridge and a vast development such as that which is proposed will be readily discernible in this AONB landscape. Despite the requirements contained in the Interim Duty to Cooperate Statement for the Draft Local Plan (Regulation 18) September 2019 for local authorities to ‘engage, collaborate and cooperate’ with one another (para 2), the above allocation of the site at Spratsbrook suggests that the problems with encroaching on a rural parish from either side (Crowborough at one end and the south side of Tunbridge Wells at the other) have not been considered in a joined-up way by the neighbouring authorities involved. Setting aside the obvious pressures arising from new development, particularly on roads and wider infrastructure, the very qualities that make up the parish (as an example) and, indeed, the Spratsbrook site itself, are clearly at risk – those qualities that define the AONB, the Green Belt, agricultural land and rural areas in general. The Council considers that the premise asserted at para 2.44 of the Plan (below) cannot be adequately met through such allocations: “A challenge for the new Local Plan will therefore be to provide for, and balance, the competing pressures of housing, employment and other development with the preservation and enhancement of local character and distinctiveness” Indeed, the release of Green Belt land is of particular concern and the Council would wish to see evidence of how exceptional circumstances for the release of such land, in accordance with the NPFF at paras 136 and 137, have been demonstrated by the Borough Council. Again, taking the Spratsbrook development as an example, the Council does not consider that the proposals accord with the NPFF at paras 170 and 172, whereby great weight is given to the preservation (at the very least) and enhancement (as a gain) of the AONB. In summary, the Council considers that the Plan allows for the further encroachment of development on the borders of the parish, compromising its unique character and distinctiveness, affecting its rural quality and character, all in the absence of a coherent and coordinated approach between the neighbouring authorities. The Council considers the approach to the provision of new development and the necessary infrastructure is short-sighted and, ‘on the ground’, will simply add to the already congested road network and over-burdened services in the wider area. | ||||||||||||||||
DLP_4534 | Historic England | Policy STR 1: The Development Strategy – while we respect the Council’s determination to achieve its projected growth needs via the preferred options set out in the policy, it is not clear that these have been arrived at following an assessment of the likely or effects, as far as they are measurable at the strategic scale, of the distribtuion of development under this scenario on the historic environment and the significances of heritage assets. Historic England cannot give support to this policy unless is is made clear that it has been framed in the light of such assessments, and that these are reflected in the wording of the policy to the effect that harm can be avoided or mitigated, or enhancement achieved, through its implementation. | |||||||||||||||||
DLP_3803 | Natural England | Natural England advises that this strategy is not justified because insufficient evidence has been provided to demonstrate that the strategy is deliverable without resulting in an adverse impact on the High Weald Area of Outstanding Natural Beauty (AONB), considered against reasonable alternatives. The allocation is not consistent with national policy with regard to conserving landscape and scenic beauty within a nationally protected landscape (NPPF para 172). Natural England has significant concerns regarding the proposed development strategy and the quantum of development which this plan proposes within the AONB. Natural England has an in- principle objection to major development within designated landscapes proposed within this draft local plan. The inclusion of 17 allocation sites within the AONB which are considered to constitute major development is of significant concern. Further advice on the Distribution of Development Topic Paper which underpins this strategy, is contained in Appendix 2. Comments on individual allocations are provided in Appendix 3. The NPPF advises (in paragraph 11 and footnote 6) that AONBs are areas of particular importance that provide a strong reason for restricting the overall scale, type or distribution of development in the plan area. The NPPF also provides clear guidance (paragraph 172) that 'Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues.' Paragraph 172 further states that ‘The scale and extent of development within these designated areas should be limited’ and that ‘Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.’ The NPPF then states that consideration of such applications should include an assessment of: a) The need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy; b) The cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and c) Any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated Given the quantum of development proposed within the AONB, we do not consider that the development strategy is in accordance with above criteria to limit the scale and extent of development and to conserve landscape and scenic beauty of the AONB. Point 8 of the strategy indicates that the tests set out in the NPPF must be met for major development sites in the AONB. Taking this to mean the abovementioned criteria in paragraph 172, Natural England does not consider that adequate evidence has been provided to demonstrate how these sites meet the criteria. Subject to the provision of further information to support the proposed site allocations, namely in terms of impacts to the AONB, and assessment against the criteria set out in paragraph 172 of the NPPF, Natural England objects to Development Strategy STR 1. Advice on specific allocations, including major development sites, is provided in Appendix A. With regard to the exceptional circumstances criteria set out in NPPF para 172, Natural England advises the following: Natural England cannot provide advice on meeting housing needs, delivery of housing numbers or affordability of housing in the borough. However as the statutory adviser for protected landscapes, we advise that major development is located outside of the AONB, and that designated landscapes should not be relied upon for the provision of significant contributions towards the Borough’s housing needs. We further advise that impacts to the setting of the AONB are also avoided. We advise that the Development Strategy, which proposes considerable direct and permanent change to a nationally important designated landscape, cannot be mitigated to reduce adverse impacts to an acceptable level. We therefore strongly advise that the proposed Development Strategy does not meet the exceptional circumstances criteria set out in NPPF para 172. | |||||||||||||||||
DLP_3902 | 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; ii. in view of the planned provision of development at Tudeley beyond 2036; and iii. to consider the possibility that development proposed at Paddock Wood/east Capel could similarly be phased over a longer time frame. This would allow for a reduction to be made in the allocations proposed under AL/PW1 – there is the additional point, in light of the physical constraints referred to elsewhere in Paddock Wood/east Capel, whether any unmet need in the borough could be more sustainably located within the Tonbridge and Malling and Maidstone boroughs under a jointly prepared Plan? 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. a. the SFRA has been carried out on a borough wide basis. As the Plan has evolved, cross boundary issues have become more prominent. The impact of the strategy proposed at this stage, beyond the boroughs boundary, in flood risk terms, appears not to have been assessed; e. the Stage 2 SWMP for Paddock Wood noted that the town’s susceptibility to flooding is influenced by the existing surface water network being at capacity (para. 2.4.2, Level 1 Report); Comment on individual parcels under AL/PW1 follow. PWTC’s concern is the extent to which the allocations made under that policy accord with the NPPF/PPG. 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. In addition – Policy STR 1: 2 – there needs to be clarity that the sports centre is an outdoor sports centre, as opposed to Putlands, which is an indoor sports hub which requires development, including a swimming pool. | |||||||||||||||||
DLP_5602 | Mrs Jacqueline Hewitt | General Observation | TWBC: the standard response was submitted by the list of responders on the left: Policy STR1 c. A prestigious new business park will be located to the north of North Farm/Kingstanding Way that is well connected to the improved A21, providing a range of employment floorspace and jobs to meet identified needs. The site will make a substantial contribution to the need for new employment space over the plan period. Other employment, including leisure development, will be encouraged at North Farm/Kingstanding Way; If the ENS has identified the above areas for development, this is surely where many new residents of the Parish of Cranbrook and Sissinghurst will be travelling to work, (14 miles away) entirely unsupported by appropriate infrastructure I object to placing so much development in Cranbrook and Sissinghurst when employment is targeted so far away | ||||||||||||||||
DLP_3991 | Lamberhurst Parish Council | STR1 – Development Strategy: Delivery of Housing Numbers The DLP is considering a total of 2000 houses within the AONB and many more along the boundaries with a great impact on its 'setting'. The new housing calculator has pushed TWBC to have an unprecedented level of potential building across its borough. Evidence suggests a major part of the requirement is for more affordable and local needs housing for the young and elderly people including those wanting to downsize. The Glover recommendations from the reviews of AONB's & National Parks also reflects the need for real affordable housing. Building more houses will not equate to more affordable accommodation, especially in desirable areas within Rural Parishes such as Lamberhurst. In common with other Local Councils in the borough, this parish is engaged upon preparation of a Neighbourhood Plan and has conducted its own housing needs survey which clearly reflected that there is a local requirement for smaller affordable units, rural exception and social housing. The NPPF clearly states that new building within the AONB should be limited and small scale. Major development should only be allowed under exceptional circumstances, which again has not been evidenced in the many major developments in the Draft Plan. Therefore only genuine housing needs should be met within the AONB. If the numbers allocated can only be achieved by major development, which by definition will have a significant adverse impact on the character components of the landscape, this is an indicator that the numbers proposed cannot and should not be achieved. LPC therefore supports a more realistic and sustainable approach which recognises the constraints of the AONB and ask that TWBC takes on its responsibilities not to put forward these volumes and look to the Government to reduce its numbers in line with sustainable local housing need. | |||||||||||||||||
DLP_4869 | DHA Planning for Berkeley Homes (Eastern Counties) Ltd | 2.3 Development Strategy and Strategic Policies (Policy STR1) 2.3.1 The purpose of the Development Strategy is to outline how much development will be provided to meet the needs of the Borough and where that development will be located. 2.3.2 In terms of the amount of housing, paragraph 59 of the NPPF states that to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed. Further, to determine the number of homes needed, strategic policies should be informed by a local housing needs assessment conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. 2.3.3 The Council confirm that their housing need target for the plan period 2016-2036 is 13,560 dwellings (678 dwellings per annum), which is calculated using the Governments standard method and the 2014-based household projections. 2.3.4 In terms of the different supply components, the Council consider that the Local Plan must (as a minimum) include additional allocations to accommodate 7,593 homes. This figure was formulated taking into account; completions since April 2016 (1,552); extant planning permissions (3,127); outstanding site allocations (588) and a windfall allowance (700 dwellings). The Council have applied a 10% non-delivery rate to these figures to err on the side of caution and consider that the plan would exceed the minimum housing requirement if all of the supply components were achieved. 2.3.5 We commend TWBC for seeking to meet their need in full and support this positive approach to plan-making. Likewise, we support the general thrust of the development strategy, which proposes a strategy to meet the housing needs of the borough with a dispersed growth approach. Nonetheless, we are concerned that the strategy is too heavily reliant on the Tudeley Garden Village and the Strategic Expansion of Paddock Wood. Furthermore, the Council have made optimistic assumptions about the delivery of these sites, which we expand upon below. 2.3.6 The strategy is consolidated by Policy STR 1, which sets out the quantum of development that will be allocated within or around settlements to meet the identified needs of the borough over the plan period. This strategy would seek to meet the majority of the Councils housing through the strategic expansion of Paddock Wood and via a new Garden Village at Tudeley. The remaining growth would then be dispersed proportionately to settlements in the borough, to areas including but not limited to Sissinghurst, Cranbrook, Matfield and Benenden. 2.3.7 We support the principle of the strategy, given that it would proportionately spread the benefits of growth and recognises the opportunity to direct a greater level of growth to Cranbrook than in previous plan periods. Further, adopting a pattern of dispersed growth approach would allow a number of sites to be developed at the same time, serving different segments of the local housing market, which is preferable to saturation of the market in a single area. 2.3.8 Nonetheless, we have some concerns regarding the balance between strategic and non-strategic scale allocations and the anticipated delivery trajectory. For example, 65% of new allocations would be delivered as part of the strategic extension to Paddock Wood (4,000 homes) and the new Garden Village at Tudeley (1,900 homes within the plan period). Both require a fully master-planned approach, which is a timely process. Furthermore, there are a significant number of existing commitments within Paddock Wood that have been slower at coming forward than had originally been envisaged. A cautious approach is therefore needed. Likewise, a number of the allocated sites in Paddock Wood are located within flood zone 3 and the NPPF states that development should be directed away from these sequentially undesirable areas. 2.3.9 To further emphasise our concerns about housing delivery, we would draw the Council’s attention back to the 2016 document published by Nathaniel Lichfield’s and Partners (NLP) - ‘Start to Finish: How Quickly do Large-Scale Housing Sites Deliver’, which provides evidence pertaining to the speed and rate of delivery of large-scale housing, based on a large number of sites across England and Wales. It identifies that the average lead in time for the submission of a planning application is 3.9 years, from the date the site is first identified. In terms of the planning approval period, for larger scale sites (2,000 + homes) this is circa 6 years. After planning permission is granted, larger sites start to deliver within a year and the average build out rate thereafter is 161 dwellings per annum - although it can be as high as 301 dwellings per annum. 2.3.10 On the basis of this research, if the Local plan is adopted by 2021, planning permissions approved at Paddock Wood by 2023 and delivery commences within 6 years (2029), the likely delivery for the plan period would be circa 966 homes. This highlights that the Council would fall short of their projections for Paddock Wood by more than 3,000 homes. Similarly, delivery at Tudely would fall short by approximately 1,000 homes. 2.3.11 Figure 1 below is taken from the NLP report, which shows the average planning approval period and delivery of first dwelling by site size. [TWBC: for Figure 1, see page 6 of full representation]. 2.3.12 Whilst the NLP report does not represent practice guidance, it is widely accepted as being a reliable and credible source of evidence and it is referenced by TWBC in their Housing Trajectory Paper. 2.3.13 Despite evidence elsewhere, TWBC has set a very optimistic trajectory for delivery of Tudeley Garden Village and the strategic extension of Paddock Wood, which is detailed in the Housing Trajectory Paper. 2.3.14 The Council forecast that the Tudeley Garden Village will begin to deliver homes from 2025/26 onward, with an initial build out rate of 150 dwellings per-annum, rising to 200 dwellings per annum from year 6 onward. Likewise, they suggest that the extension to Paddock Wood will start to deliver in 2024/25 at an average build out rate of 333 dwellings per annum – which is nearly double the average rate for larger schemes identified in the NLP document. This higher build out trajectory is predicated on the basis that there would be a number of house builders involved the construction of different parts/phases. However, by their own admission, TWBC do not currently know how many housebuilders will be involved. 2.3.15 With the above in mind, our view is that the Council have applied an overly optimistic development trajectory for the delivery of strategic sites, both in terms of the start date for completions and the expected build out rates. Accordingly, we would encourage the Council to increase the balance of small and medium sized sites around higher tier settlements, which can deliver quickly and usually require limited intervention to infrastructure. This would also provide a greater degree of flexibility for the plan in the event that strategic sites are delayed. 2.3.16 Given the absence of any similar strategic sites in Tunbridge Wells Borough, as a point of comparison one could have regard to similar scale delivery in neighbouring authority Tonbridge and Malling Borough. In this respect, we provide evidence below of its three key strategic sites and the associated delivery rates (derived from the Tonbridge and Malling BV Annual Monitoring Report 2017). 2.3.17 Kings Hill is an extremely prudent example to consider in the context of the Paddock Wood extension and new garden village at Tudeley, how deliverable this would be. Indeed, Kings Hill was a new village which started in 1989, near land previously occupied by RAF West Malling. The concept was for a multipurpose site of both residential and office business space. The development is still being delivered some 30 years later, despite having multiple national housebuilders delivering different phases concurrently. Based on the most up-to-date delivery data for the last decade, Kings Hill has only delivered 131 dwellings per annum. Furthermore, the earlier delivery phases were delivered at lower rates given the need to front load infrastructure. 2.3.18 Therefore, we consider that whilst some development may come forward in the plan period from the two proposed strategic sites, in reality these strategic allocations are longer terms aspirations that will extend beyond 2036. 2.3.19 Accordingly, we would encourage the Council to allocate additional sites, which can deliver quickly and usually require limited intervention to infrastructure, particularly sustainable settlements such as Cranbrook and to reduce the reliance upon Tudeley within this current plan period. 2.3.20 Within section 3.5 we illustrate opportunities within our client’s land to deliver more homes than currently permitted by the draft allocation. These homes would deliver early in the plan period and help to ensure the plan is effective. [TWBC: see full representation and separate Appendix (a) and Appendix (b)]. | |||||||||||||||||
DLP_6032 | Mr C Mackonochie | Object | Policy Number: STR1 1. c ‘A prestigious new business park will be located north of North Farm/ Kingstanding Way etc.’ this is in AONB. Yet elsewhere in the Plan it is stated that AONB is the last type of land to be considered for development Also there is a presumption that no building should be carried out in the AONB and yet guidelines are produced for building in the AONB 2. No mention is made preventing the coalescence of Paddock Wood and Five Oak Green nor that building on the east side would require less flood measures than the west side or East Capel 3. Mention is made of flood-risk measures, at present the only flood measures required in Tudeley is ensuring the highways’ gullies are cleaned. However housing may well producing flooding that will required measures 6. This is in contradiction to the adopted Core Strategy recognises that rural settlements are least able to support sustainable development 7. However this release of Green Belt can/will lead to the creation of a city with Tunbridge Wells, Southborough becoming suburbs 8. A similar statement should be made about Green Belt | ||||||||||||||||
DLP_4261 | RTW Civic Society | Support with conditions | Para 4.38 We support the adoption of Option 3 – dispersed growth across the borough. Our remit is to the town of Tunbridge Wells so we feel it is for others to comment on where non-town developments should be. para 1a. Subject to the reservation re Vision, we welcome the intention to achieve “extensive infrastructure, including public realm enhancements”. We believe there is already a substantial deficit in basic infrastructure and the state of the public realm requiring to be addressed, in addition to needs arising from increases in population and employment under the Plan. The implementation of the high standards described here will require much better integration and attention to detail than we have seen recently (eg. in the public realm works in the town centre). Para 1b needs amendment to reflect recent Council decisions. For example “new theatre” should be reworded as “new or upgraded theatre, or community performance space”, or similar. | ||||||||||||||||
DLP_4316 | Town and Country Planning Solutions for Gleeson Strategic Land | Object |
List of Appendices | ||||||||||||||||
DLP_5807 | Weald of Kent Protection Society | Object | Policy STR 1 The Development Strategy: Development will be provided across the borough on the following basis: 8 paragraphs containing specifics about where development is to be delivered. Para. 6 (page 43 of the PDF) ‘Development at the other settlements across the borough within their respective limits to built development boundaries and through delivery of allocations as per Table 3 below, and other suitable windfall developments.’ ’Other suitable windfall developments’ is not defined anywhere in the Local Plan. As written, any piece of land anywhere could be regarded as a suitable windfall development site. We request a definition of the term ‘other suitable windfall developments’ within the Local Plan. Policy STR 1 The Development Strategy: Para 8 (page 43 of the PDF): ‘Where major development is provided for at specific identified sites in the AONB, this is only where the tests set out in the NPPF are met.’
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DLP_5995 | Pro Vision for Cooper Estates Strategic Land | Object | Policy STR1 sets out the scale of development required across the plan period to meet the identified needs of the borough but does not contain an explicit numerical housing requirement for C2 use development. | ||||||||||||||||
DLP_6026 | Kember Loudon Williams for Cranbrook School | Support | This submission is made in response to the Tunbridge Wells Borough Council’s (TWBC) Consultation Draft Local Plan (Regulation 18). It is made by Kember Loudon Williams on behalf of the Trustees and Governors of Cranbrook School. A separate report has been prepared to accompany these representations (See Chapter 3), which supports Cranbrook town as a suitable and sustainable location for a modest amount of additional housing to that which is currently allocated. [TWBC: see full supporting statement. Chapter 3 is copied below]: 3 Strategic Growth Relevant Policies: STR1, STR/CRS 1 and Key diagram 4. Housing 3.1 Policy STR1 of the Tunbridge Wells Borough Council Local Plan Regulation 18 Consultation details the development strategy for the Borough. Part 5 of the Policy lists the Parish of Cranbrook and Sissinghurst as being suitable for further housing development and table 3 lists the proposed allocations for housing as a maximum of 803. 3.2 For the reasons set out in Chapters 6 & 7 (Big Side and Rammell Field), we consider there is the potential to increase the total housing allocations in Cranbrook in the region of 50-60 more dwellings. The first opportunity is to extend the proposed housing allocation at Big Side Playing Field to the north of the town by 10 dwellings in order to accommodate up to 25 units; and the second is to reconsider part of Rammell Field as a suitable housing site for 40-50 units. 3.3 The development strategy (STR1) has already recognised Cranbrook as being a sustainable location for new housing due to the range of services and facilities offered within the town. In addition, being located outside of the Green Belt, Cranbrook is considered more suitable for new development than many other locations in the Borough. 3.4 Rammell Field is considered well suited in terms of its central location to accommodate new local needs housing, particularly in light of the surrounding residential character to the site and, potentially, playing a key role in supporting local housing needs – discussed more fully in Chapter 7. Although the site is proposed as a Local Green Space designation under the Regulation 18 consultation we are objecting to this classification for the entire site, and would argue that a part green space allocation and part housing allocation, to include affordable and local needs housing, would make more efficient use of land within this central location, whilst representing an overall gain to the local community. 3.5 The north/east corner of Big Side Playing Field, to the north of the town, has already been considered as a suitable site for a housing allocation of up to 15 units. However, given the proposed location of housing has already been accepted here within the Draft Local Plan and would already involve the partial loss of a playing field, in our view, it would make sense to expand the housing allocation to reach a capacity of up to 25 dwellings. Chapter 6 considers this proposition in more detail in relation to draft allocation AL/CRS 2 and the option of being able to replace the displaced playing pitch in a more suitable location closer to the School. 3.6 The Key Diagram Figure 4 of the Draft Local Plan illustrates the spatial strategy and broad distribution of housing development across the Borough. In light of the above comments, we propose this Diagram be updated to reflect the additional growth proposed at the Big Side and Rammell Field sites. We also seek an amendment to Table 3, which follows Policy STR1 and identifies the scale and distribution of development. To account for the additional development in Cranbrook being sought through our representations we seek an increase to the current maximum number of allocations provided for the settlement of Cranbrook of up to 863 units. 3.7 In line with the above proposals we recommend Part 1 of draft Policy STR/CRS 1 (The Strategy for Cranbrook and Sissinghurst Parish) also be updated to reflect the 50-60 additional housing units proposed to be accommodated in Cranbrook. We refer to part two of the policy which acknowledges that additional housing to the draft allocations may be delivered through the redevelopment of appropriate sites and other windfall development. Given the number of additional units proposed at Rammell Field, we consider it appropriate to include this site as an additional allocation, under Part 1 of the Policy. Playing Fields 3.8 Cranbrook School has a rich sporting heritage and the School is committed to ensuring that sport continues to thrive in the future. The School continues to successfully compete with the best locally available School opposition (including larger independent Schools) and the keen intent, high quality facilities and teaching is a major contributing factor to the School’s appeal for boarders. It is therefore vital that the School continues its commitment to improve the existing sports equipment and facilities. 3.9 Three of the sites we are promoting/supporting through this Local Plan process involve existing playing fields, two of which are already proposed to be allocated in part for some housing development in addition to the retention of the majority of the respective sites as playing fields. It is therefore important we consider the national guidance relating to proposals which affect existing playing fields, as part of our representations for these sites. 3.10 It should be noted that Sport England’s policy is to oppose the granting of planning permission for any development which would lead to the loss of, or prejudice the use of, all or any part of a playing field, unless one or more of the five exceptions stated in its policy apply: Sport England Policy
3.11 In this case of Rammell Field, Jaegers Field and Big Side Field the main exceptions are likely to fall under ‘E1’ or ‘E4’. 3.12 The school is committed to improving its facilities including the quality of sports provision. Currently playing fields are dispersed and fragmented which is not ideal in terms of overall efficiency, pupil safety and maintenance. There are opportunities to consolidate and improve the quality and quantity of pitches and for pitches to be provided more centrally within the campus. This may include opportunities to create additional levelled playing pitches on land adjacent to the ‘grounds maintenance complex’ as well as potential opportunities to look to expand the land available in these locations. 3.13 In the case of Rammell Field, our proposal will result in the loss of a playing pitch which may need to be relocated elsewhere subject to further analysis. However, there will be general recreational provision provided in the form of the open space to be retained at the north of the field, fronting Bakers Hill. This recreational space will now be publicly accessible which will be a major benefit to the community. 3.14 The school intends to produce a comprehensive Playing Fields Assessment and Strategy in due course that would inform future planning applications on all three sites. | ||||||||||||||||
DLP_4657 | CBRE Ltd for Dandara Ltd | Draft Local Plan Policy STR1: ‘The Development Strategy’ 3.39 Policy STR1 sets out TWBC’s broad development strategy for development within the Plan period. Dandara supports the general borough-wide release of suitable Green Belt land to provide new housing, employment opportunities and social infrastructure. 3.40 In relation to Part 1 of Policy STR1, Dandara supports the planned expansion of the Main Urban Area of Royal Tunbridge Wells and the opportunity to deliver new homes at Spratsbrook Farm, on the south-western periphery of the Town. 3.41 With regard to Part 2 of Policy STR1, comprising the expansion of Paddock Wood, Dandara supports this and welcomes the opportunity for housing and employment growth. 3.42 With regard to Part 3 of Policy STR1, and the proposed new garden settlement at Tudeley Village, as explained above Dandara is concerned about the extent to which it is being relied upon to contribute to meeting identified development needs within the Plan period, and the timing of delivery as set out in TWBC’s housing trajectory. 3.43 It is considered that the policy and trajectory in relation to Tudeley Village needs to be robust and demonstrable of delivery. It may therefore be necessary to amend the yield within the Plan period as part of ensuring that any allocation for Tudeley Village satisfies the appropriate policy tests in accordance with paragraph 23 of the NPPF. 3.44 Dandara supports Part 4 of Policy STR1 and the proposed new housing growth and social infrastructure at Hawkhurst. 3.45 Dandara welcomes Part 5 of Policy STR1 and the proposed growth around Cranbrook itself, Sissinghurst, and at Hartley. 3.46 Further comments in respect of Policy STR1 are provided in Section 4 within the Site Specific Representations. [TWBC: see full representation]. | |||||||||||||||||
DLP_4464 | 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. 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. Building upon sites presently prone to flooding is not sustainable - it absorbs 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. In addition – Policy STR 1: 2 – The Sports &Recreation group welcome the inclusion of the sports hub but it should be explicit that this is an outdoor sports hub & should be called just that, as the NP proposes development of Putlands to include indoor sports and a swimming pool. In 4.41 Table it identifies a swimming pool in the Paddock Wood/Capel area, but this is not reflected in the policies specific to Paddock Wood. Under Paddock Wood Overview it explicitly states there is no swimming pool – this has been the number one facility requested by PW residents for many years past, which we have included in the Neighbourhood Plan and we would like to see it identified explicitly in the Local Plan. A 2-4-6 athletics training track is also located on the Putlands Field. The Neighbourhood Plan group supports the development of this to 6 lanes all round to enable athletic competitions to be held. | |||||||||||||||||
DLP_5108 | Mr Peter Brudenall | I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents. I believe that the Council’s conclusion (for example, at Paragraph 4.34) that the sites identified for mass housing estates are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:
[TWBC: see also Comment Number DLP_5110 - Policy STR/HA 1]. | |||||||||||||||||
DLP_5176 | Bloomfields for Fernham Homes | Development Strategy and Strategic Policies (Policy STR1) (1) Ancient Woodland (approximately 16% of the borough) The nearby Ashdown Forest is a designated Special Area of Conservation (SAC) and Special Protection Area (SPA). Although not an environmental constraint, the Metropolitan Green Belt covers 22% of Tunbridge Wells Borough. Given these constraints, it is acknowledged that planning for housing requires the need to balance a number of core environmental and planning matters in order to reach a sensitive future development strategy. [TWBC: see Comment Numbers DLP_5171, 5174, 5176, 5177 and 5180] | |||||||||||||||||
DLP_3772 | Mary Jefferies | Object | Policy Number: STR 1 It appears that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019).. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects: 1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan; 2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point. Hawkhurst The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course. The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village. The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan. There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development. Non-compliance with Hawkhurst Neighbourhood Development Plan The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment. Lack of adequate infrastructure Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament The proposed development would impact unacceptably on an AONB The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019. The proposed development would not constitute sustainable development The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment. Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. There are very limited local employment opportunities and no secondary schools within walking distance. The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution. The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it. TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103). The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate. The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF. There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has objected to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF. The “relief road” will not work The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny.The TWBC Local Plan has not considered the wider impact on Hawkhurst’s traffic problems with the propsed development in neighbouring areas such as Hartley and Cranbrook. As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes. | ||||||||||||||||
DLP_3833 | Liane & Alan Chambers | Object | Policy Number: STR1 The policy sets out the intention to provide for the predicted development need of the Borough. However given the NPPF policy set out in para 1.29, there does not appear to be sufficient justification for this approach given the landscape and infrastructure constraints of the Borough. Paragraph 4.8 points out that Sevenoaks Borough, with similar constraints, is not seeking to meet its own housing needs. Tunbridge Wells Borough Council should take a similar approach and encourage the Government to seek a housing strategy that is less dependent on significant further house building in the South East. We do not agree with the proposals for Hawkhurst. The village cannot cope with the housing allocation put forward in the plan. The proposals for a relief road would add to traffic congestion, air pollution and adversely affect the quality of life of the residents. Both the proposed housing and road would significantly affect the Area of Outstanding Natural Beauty (AoNB) and is contrary to provisions set out in the national guidance. Paragraph 172 of the National Planning Policy Framework (NPPF) states that major development in an AoNB should be refused “other than in exceptional circumstances”. Please note that unlike Paddock Wood and Cranbrook, Hawkhurst is a village not a town. | ||||||||||||||||
DLP_3981 | B Draper | Object | TWBC: the standard response was submitted by the list of responders on the left: Policy Number: STR 1 I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents. I believe that the Council’s conclusion (for example, at Paragraph 4.34) that the sites identified for mass housing estates are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is totally disingenuous. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. This is exemplified by the omission to mention sewage treatment under topics of infrastructure provision on the display boards used in the recent exhibitions. Those responsible for producing this information should be severaly censured for this omission. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects: 1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan; 2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point. Hawkhurst The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course. The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village. The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan. There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development. Non-compliance with Hawkhurst Neighbourhood Development Plan The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment. Lack of adequate infrastructure Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament. The proposed development would impact unacceptably on an AONB The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019. The proposed development would not constitute sustainable development The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment. Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. There are very limited local employment opportunities and no secondary schools within walking distance. The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution. The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it. TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103). The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate. The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF. There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has objected to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF. The “relief road” will not work The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny. If the ‘relief road’ is planned as a standard 7.3m single carriageway then any parking or other temporary obstruction will result in no improvement whatsoever. The suggestion that HGVs etc will turn right at the roundabout at the southern end and then proceed westwards towards Flimwell cross roads will be exposed as totally flawed unless significant property appropriation is made. It should not be forgotten that this section of road lies within a different county boundary who may hold higher priorities for road improvement provision. As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes. | ||||||||||||||||
DLP_4387 | Mill Lane and Cramptons Residents Association | Object | Key Diagram and Policy STR1. We do not agree with Sissinghurst (Item 5) having so much proposed new growth. We have already had a large development of 60 new houses off Common Road and other new dwellings in Cobnut Close and Church Mews in this small village that has minimal facilities. | ||||||||||||||||
DLP_4406 | Alison Adams | Object | I am a resident of Horsmonden and have lived here for the last 6 years. During my time I have been the Chair of the local Horsmonden Kindergarten and I have been very busy renovating my home and garden. I love living in this village with its community spirit and feel very involved and integrated in the society here. Although I appreciate that new housing is inevitable and do not object to sensitive and structured new building I am concerned greatly by the idea of large scale new development which does not take into account the requirements of the existing community or the actual requirements of the prospective purchasers of the homes. Horsmonden like most villages provides a mixture of housing and there are many residents living here who do not foresee living anywhere else. Houses however do come onto the market and at present there are a number in the village that have been up for sale for over a year. My question is therefore, how have the “powers that be” come up with the decision that we need to create 13,560 new homes (Para 4.7)? If we do need these homes I sincerely hope that the main priority is to create homes that will fulfil the specifications that these new prospective owners are looking for. In my view one of the biggest problems that we face is that large family homes continue to be occupied by parents well after their children have left, couples in their 60s, 70s and 80s are reluctant to downsize due to the lack of smaller but prestigious, spacious, convenient houses/apartments/bungalows that also offer attractive outside space. This creates a barrier to the upward movement of younger families who wish to gain more space. Space in the South East is at a premium so there needs to be some incentive to free up these family homes for the new generation. I would also like to be 100% certain that the companies that are employed to build all these new homes are actually controlled so that the new homes are good quality and sustainable with eco-friendly initiatives being used. Why is it not compulsory to have solar panels, permeable paving, grey water storage? All these design features are available and if every builder was enforced to use them there would be economies of scale so the price of these technologies would ultimately come down. In terms of the Consultation I would like to comment on the following: STR1 - The Development Strategy – In particular HO1 Horsmonden Parish Para 4.38 talks about dispersed growth – this option however will put an enormous strain on minor country roads which are already dangerous and have very limited public transport. The essence of village life is that the community should feel comfortable walking to the village shop, to school, to meet with friends and to take dogs for walks. With the increasing number of cars and lorries on the road this pleasure turns to a nightmare. In May this year an elderly lady, my neighbour, was knocked down by a car outside my house. She spent 5 months recovering. Such incidents will only increase with the increased volume of traffic. Despite the seriousness of this incident nothing has been done to promote new pavements and make the village centre safer. How are we supposed to feel confident about future development when problems that already exist are not taken seriously or mitigated by the local authority It is not just the cars owned by the people moving into the new properties that put a strain on the roads. Horsmonden is not on mains gas so most householders require oil to be delivered for heating. The 265 proposed extra homes will need more oil tankers to name but one of the many knock-on effects rural housing will create. I appreciate the opportunity to comment and hope that the Borough Council will take into account the many and varied views of the people of the borough. Maybe building thousands of new homes will boost the economy in the short term but once built these homes cannot be removed so let’s hope there is a real demand and that the houses built actually satisfy that demand. | ||||||||||||||||
DLP_4443 | James Whitehorn | Object | a] I disagree with the fundamental assumption that we need another 13,560 houses in the borough over the 20 year plan period, 678 per annum. From the Housing Needs Assessment Topic Paper there were evidently 47,174 households in 2011 [Census figure] and Dr Bullock [Housing Needs Study 2018] assumed a total of 49,442 households and 48,559 dwellings in 2018, an increase of 4.8%. However an extra 13,560 houses represents a massive 28% increase over the 18 years from 2018-36. b] According to Dr Bullock, the population of the borough was estimated to be 117,700 in 2017 and projected to increase by 9.4% to 128,800 in 2033. He also projects the total number of households will increase by 15.5% from 49,904 to 57,661 in 2033. More recent Govt data suggests a potential 6.4% population increase in the South East from 2016-26, but there is no reliable data available for the next decade up to 2036. The Local Plan should acknowledge this uncertainty and include a range of options for future housing provision rather than attempting to meet an unproven demand. c] There is no explanation offered in Dr Bullock’s report to justify the assumed population increase or to explain where all these extra people will be coming from. It can partly be attributed to a larger number and increasing proportion of older people, but if we build many more houses at the right size and price then, in addition to addressing a backlog need, we will also attract more people into the borough. If on the other hand we allow an incremental rise in housing stock primarily through windfall sites we could potentially meet much of the internal and backlog need without encouraging net migration into the borough. d] Our highway infrastructure especially on the primary routes through Royal Tunbridge Wells is already way over capacity for much of the day. If we build an extra 13,560 houses over the Local Plan period with a typical 1.4 cars per household in the South East, we could be adding around 19,000 extra cars to our already overloaded network. The additional car trips would create misery for existing and new residents alike. | ||||||||||||||||
DLP_4590 | Keith Stockman | General Observation | Policy STR1 c. A prestigious new business park will be located to the north of North Farm/Kingstanding Way that is well connected to the improved A21, providing a range of employment floorspace and jobs to meet identified needs. The site will make a substantial It is ridiculous that, given the location of the new employment, large scale development is proposed for Cranbrook & Sissinghurst, which is 15 miles or more from the new employment areas. Inevitably, it will lead to a huge increase in car usage on a road system which is already struggling to cope. I object most strongly to the proposed development for this and other reasons. | ||||||||||||||||
DLP_4646 | Ann & John Furminger | Object | Policy Number: STR1 c Areas for development of employment opportunites to serve the housing in Cranbrook and Sissinghurst are 14miles away and are supported by completely inadequate infrastructure, This does not make sense as puts more strain on already stretched infrastructure. | ||||||||||||||||
DLP_4728 | Mike & Felicity Robinson | Object | Policy Number: STR 1 We understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects: 1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan; 2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point. Hawkhurst The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course. The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village. There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development. Non-compliance with Hawkhurst Neighbourhood Development Plan Lack of adequate infrastructure The proposed development would impact unacceptably on an AONB The proposed development would not constitute sustainable development Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. There are very limited local employment opportunities and no secondary schools within walking distance. The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution. The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it. The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate. The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF. There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF. The “relief road” will not work As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes. | ||||||||||||||||
DLP_4765 | DHA Planning Ltd for Caenwood Estates and Dandara | Comments on Policy STR1 3.3.7 The strategy is consolidated by Policy STR1, which sets out the quantum of development that will be allocated within or around settlements to meet the identified needs of the borough over the plan period. This strategy would seek to meet the majority of the Council’s housing need through the strategic extension of Paddock Wood and via a new Garden Village at Tudeley. The remaining growth would then be dispersed proportionately to other settlements in the borough. 3.3.8 We have no objection to the overall thrust of the strategy and adopting a pattern of dispersed growth given that it would spread the benefits of growth to more locations than in previous plan periods. Furthermore, adopting a pattern of dispersed growth approach would allow a number of sites to be developed at the same time, serving different segments of the local housing market, which is preferable to saturation of the market in a single area. 3.3.9 However, we are concerned that the overall balance of this strategy is wrong, and that a greater proportion of development should be directed towards the Borough’s main settlement at Royal Tunbridge Wells. This is a sustainable location for growth, being the main focus in the borough, and indeed the wider region, for employment, retail, education, services and local public transport. 3.3.10 We agree that the strategic growth proposals at Paddock Wood are also sustainable, but the proposals at Tudeley are much less so. In our view the development quantum proposed at Tudeley should instead be reallocated elsewhere, with a large proportion going to Royal Tunbridge Wells. 3.3.11 Whilst we recognise the wish to make various improvements to strategic transport links and education provision at Tudeley, these are complex, high cost items that will not be quick or easy to deliver. These include:
3.3.12 Despite the railway running through the site, there are no plans for a railway station to serve the new settlement. The reality is that the garden village at Tudeley is in danger of being an unsustainable suburban development without the benefit of good connections to existing development and services. There are also substantial concerns in relation to flood risk. 3.3.13 In this regard, we question whether the proposed settlement at Tudeley meets the tests set out in NPPF paragraph 138, in particular the requirement that: “Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.” 3.3.14 Unlike the A26 corridor, which Caenwood Farm is located on, Tudeley is not currently well-served by public transport. Whilst it is recognised that the Local Plan intends public transport improvements to be brought forward, at present at Tudeley there is usually only one bus per hour in each direction during the daytime, and no rail services. By contrast, there are nine bus services per hour serving the nearest bus stops to Caenwood on the A26 corridor, whilst High Brooms station is also within walking distance. Just like at Tudeley, there would be opportunities to further enhance public transport to serve the site. However, given the requirements of NPPF paragraph 138, we believe that if Green Belt is to be released, sites such as Caenwood Farm that are already close to a good public transport corridor should be prioritised over sites like Tudeley where there is little existing provision. 3.3.15 In any event, we have some concerns regarding the balance between strategic and non-strategic scale allocations and the anticipated delivery trajectory. For example, 65% of new allocations would be delivered as part of the strategic extension to Paddock Wood (4,000 homes) and the new Garden Village at Tudeley (1,900 homes within the plan period), both of which require a fully master-planned approach, which is a time-consuming process. Furthermore, there are a significant number of existing commitments within Paddock Wood that have been slower at coming forward than had originally been envisaged. A cautious approach is therefore needed. 3.3.16 In this regard, we would draw the Council’s attention back to the 2016 document published by Nathaniel Lichfield’s and Partners (NLP) - ‘Start to Finish: How Quickly do Large-Scale Housing Sites Deliver’, which provides evidence pertaining to the speed and rate of delivery of large-scale housing, based on a large number of sites across England and Wales. 3.3.17 It identifies that the average lead in time for the submission of a planning application is 3.9 years, from the date the site is first identified. In terms of the planning approval period, for larger scale sites (2,000 + homes) this is circa 6 years. After planning permission is granted, larger sites start to deliver within a year and the average build out rate thereafter is 161 dwellings per annum, although it can be as high as 301 dwellings per annum. 3.3.18 Figure 1 below is taken from the NLP report, which shows the average planning approval period and delivery of first dwelling by site size. [TWBC: for Figure 1 seefull representation]. 3.3.19 Whilst the NLP report does not represent practice guidance, it is widely accepted as being a reliable and credible source of evidence and is referenced by TWBC in their Housing Trajectory Paper. 3.3.20 Despite evidence elsewhere, TWBC has set a very optimistic trajectory for delivery of Tudeley Garden Village and the strategic extension of Paddock Wood, which is detailed in the Housing Trajectory Paper. 3.3.21 The Council forecasts that the Tudeley Garden Village will begin to deliver homes from 2025/26 onward, with an initial build out rate of 150 dwellings per-annum, rising to 200 dwellings per annum from year 6 onward. Likewise, they suggest that the extension to Paddock Wood will start to deliver in 2024/25 at an average build out rate of 333 dwellings per annum – which is nearly double the average rate for larger schemes identified in the NLP document. This higher build out trajectory is predicated on the basis that there would be a number of house builders involved the construction of different parts/phases. 3.3.22 Taking the above into account, our view is that the Council have applied an overly optimistic development trajectory for the delivery of strategic sites, both in terms of the start date for completions and the expected build out rates. 3.3.23 Given the absence of any similar strategic sites in Tunbridge Wells Borough as a point of comparison, one could have regard to similar scale delivery in neighbouring authority Tonbridge and Malling Borough. In this respect, we provide evidence below of its three key strategic sites and the associated delivery rates (derived from the Tonbridge and Malling BV Annual Monitoring Report 2017). 3.3.24 Kings Hill is an extremely prudent example when considering potential delivery at the Paddock Wood extension and the new garden village at Tudeley. Kings Hill was effectively a new village started in 1989 near land previously occupied by RAF West Malling. The concept was for a multi-purpose site of both residential and office business space. The development is still being delivered some 30 years later, despite having multiple national housebuilders delivering different phases concurrently. Based on the most up-to-date delivery data for the last decade, Kings Hill has only delivered 131 dwellings per annum, despite multiple developers delivering concurrently. Furthermore, the earlier delivery phases were delivered at lower rates given the need to front load infrastructure. 3.3.25 Therefore, even if the Council was to pursue Tudeley Garden Village, we consider that whilst some development may come forward in the plan period from the two proposed strategic sites, in reality these strategic allocations are longer term aspirations that, at best, are not likely to begin to deliver housing until well into the Plan period and will inevitably extend beyond 2036. This is likely to be exacerbated by the fact that, by virtue of their proximity, Tudeley Garden Village and an expanded Paddock Wood would be serving similar markets and therefore allocations there will, to some extent, be competing with each other. 3.3.26 Accordingly, we would strongly encourage the Council to make more efficient use of other medium-sized sites around the borough, such as our client’s site. As set out elsewhere in these representations, Caenwood Farm is in a highly sustainable and logical location, which can be delivered early within the plan period. [TWBC: seefull representation]. | |||||||||||||||||
DLP_4853 | Robin & Diana Morton | Object | STR1 We strongly object to the’dispersed growth’ strategy for housing development on which the Local Plan’s development is based. There is totally disproportionate growth planned in rural v. urban areas. Horsmonden appears to have been viewed alongside other small rural villages, simply because potential sites were put forward, without our unique central crossroads being considered properly. KCC and experts can find no solution to the problem of two heavily used main roads crossing in the centre of the village, where there is no space to widen the roads, nor provide proper pavements. Neither is there opportunity to avoid the centre crossroads. The problem is major, and would be greatly exacerbated by large housing development, with the accompanying local traffic adding to the existing heavy through traffic, which has no alternative route. At best, a much smaller, mixed development, might be possible under AL/ HO 3 (sites 82, 108, 297 and 324) if safe access to the main road can be found, but this should only be maximum 100, and only that if the HO2 site falls With windfall sites at a maximum of 10% the village could grow over time, but not disproportionately. | ||||||||||||||||
DLP_4985 | Kristina Edwards | Policy Number: STR 1 I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents. I believe that the Council’s conclusion (for example, at Paragraph 4.34) that the sites identified for mass housing estates are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:
Hawkhurst The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course. [TWBC: see Comment Number DLP_4988]. | |||||||||||||||||
DLP_5127 | Alistair Nichols | I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents. I believe that the Council’s conclusion (for example, at Paragraph 4.34) that the sites identified for mass housing estates are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:
[TWBC: see also Comment Number DLP_5128 - Policy STR/HA 1]. | |||||||||||||||||
DLP_5157 | Cushman Wakefield for Ministry of Justice | Policy Number: STR 1 The Development Strategy [TWBC: see Comment Numbers DLP_5154, 5157-5159, 5161, and 5163-5164. See also full representation]. | |||||||||||||||||
DLP_5263 | Tunbridge Wells Friends of the Earth | Object | Policy Number: STR 1 The Development Strategy Object , Support with conditions We request a new calculation is made of the net “Minimum additional allocations to meet housing need” as set out in §4.12 above, as we have been made aware that these are likely too high an estimate and that when one applies the revised and updated 2016 ONS methodology, only 67% of total new development (i.e. 13,560 indicated in row 1 of table 1, §4.12) is required. This would bring down the net number of houses needed from 7,593 to 3,118. We object to point 7 as we object to the release of Green Belt land for development. If a recalculation is done of housing needs and brownfield sites are actively located and developed as a priority, one should not need to build in the Green Belt. Even if there is no recalculation, we would still object to new development in the Green Belt. | ||||||||||||||||
DLP_5776 | Rose Harrild | Object | I am deeply concerned with many aspects of the proposed Local Plan. First the calculations made of the number of new homes needed by 2036 in the Borough. Apparently the borough will require 13,560 new dwellings by 2036.Where did this figure come from? The council should robustly resist this as there are sound planning reasons to do so. Indeed Sevenoaks District Council has done just that and is not proposing to wholly meet the figure put forward for its housing needs. Government wording on this issue is quoted in the Development Strategy and Strategic Policies -Section 4 of the draft local plan.It states that 4.3 " In preparing this draft local plan the council has to be mindful that national planning policy expects local plans to meet the identified level of development needs for their area in full UNLESS there are good planning reasons why this is not possible." In other words if there are sound planning reasons, this figure may not be met. And there are sound planning reasons in the borough. - there is Green Belt, High Weald AONB and villages with Limits to Built Environment. However the next sentence does not follow on from this "Accordingly the proposed Development Strategy indicates how the FULL development needs of the borough can be appropriately met." The Council should not be looking to meet the full development needs because of the many constraints. One constraint on village development and enlargement is LBDs (lLimits to Built Development) - These have very successfully ensured villages do not grow too big and swamp areas of countryside. However it is proposed in many cases to change these boundaries to allow more development to occur. .This is in nearly every case completely unacceptable. The High Weald AONB has its own restrictive policies. Yet new housing is proposed within the AONB for example at Matfield. Again totally unacceptable. Green Belt too has restrictive policies which have very successfully limited sprawl into the countryside and in some cases prevented the joining of settlements. Again building in the green belt should not be sanctioned. Many of the sites put forward for possible development by the Council are therefore totally unsuitable. [TWBC: see also Comment Numbers DLP_5777 (Brenchley) and DLP_5778 (Horsmonden). To conclude, as it stands the Draft Local Plan is unacceptable. There are planning policies in place to resist development on the scale that is proposed. They must be used. | ||||||||||||||||
DLP_5932 | Rachel Jones | Object | TWBC: the standard response was submitted by the list of responders on the left: We writing to you to register our concerns and objections to the following:
Planning Strategy 1) The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that 60% of respondents would like to see housing growth along “growth corridors”, whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents. Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. The Council would need to be able to demonstrate that it has reacted appropriately to the consultation feedback so a far greater emphasis on growth in established centres rather than rural locations would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on private cars as a means of travel – which surely must be of paramount importance given climate change commitments. 2) With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the Limits to Build Development boundary, but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a clear and consistent manner. Lamberhurst as a Location for Additional Housing (Policy STR/LA1) As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage. With this conflict in mind, we question the viability of the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages). In addition, the strategy to create relatively large developments which are not connected to the centre of the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern. Lamberhurst is a very small traditional village that has evolved and developed slowly over time and has a limited range of services as a result. The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal. These are summarised below: Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield. Shops: There is only one shop in the village. The shop is very small and useful only for essentials like milk and a newspaper. The Post Office only opens for 2 short mornings a week. The nearest supermarket for a bigger shop is being Tesco which is 7.8 miles away and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service. Bus service: There is only a very limited bus service for the village with irregular times. In the mornings, the bus is always full with school children which has been a topic of much public debate with support from local MPs. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work. New residents are therefore likely to be using private cars for both work and transporting children to school (as the current bus is already over capacity). In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Lamberhurst Neighbourhood Plan. The Neighbourhood Plan is promoting developments that are well designed and reflect local character. The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst. | ||||||||||||||||
DLP_6855 | Barton Willmore for Crest Nicholson | i) Policy STR1: The Development Strategy 5.5 Policy ST1 sets out the broad development strategy for the Borough and how it intends to provide for its identified housing requirement. This focusses development in and around existing urban centres at Royal Tunbridge Wells, Southborough, Paddock Wood and Hawkhurst, with provision made for a new Garden Settlement at Tudeley – plus at smaller rural (AONB) settlements (i.e. Cranbrook, Sissinghurst). 5.6 TWBC’s “Distribution of Development Topic Paper” (TWBC, Sept 2019) provides a comprehensive overview as to the basis (and “justification”) for the spatial development strategy being pursued and helps in reinforcing the soundness of this policy. 5.7 From a transport perspective, Policy STR 1 will minimise the need to travel by increasing the capacity of Paddock Wood to serve its residents with a range of facilities which best meet local needs. 5.8 Having reviewed the housing need and supply, along with the Draft Local Plan housing trajectory [4 Housing Supply and Trajectory Topic Paper: TWBC – Reg 18 Consultation (Sept 2019)], we support the above assessment and agree that the need can largely be met within the Plan period through sites presently allocated in the Draft Local Plan, windfalls and extant permissions. 5.9 Whilst housing need is set out in Table 1, identified economic need is set out in paras 4.18- 4.23, and the means by which these will be delivered set out in Table 3 (p.43). We consider the housing and economic needs should also be specified within the text of Policy STR1 which is something which has previously been raised by Inspector’s such as in relation to Aylesbury Vale District Council’s emerging Local Plan which also had text setting out information better placed to be in the policies themselves. This is a simple change that should be readily able to be accommodated in the Regulation 19 version of the Draft Local Plan. 5.10 Table 3 of the Draft Local Plan regarding the Allocation Sites’ responsibilities under Policy STR1 states that the sites allocated around Paddock Wood are expected to make a “contribution to link to Tudeley Village”. Indeed according to the same table, development at Tudeley is not expected to contribute to highway infrastructure in its vicinity but in Paddock Wood, which suggests that this is a drafting error. We recommend that TWBC remove this requirement from the Paddock Wood area sites. 5.11 In the Draft Infrastructure Delivery Plan (TWBC, August 2019), the Five Oak Green by-pass is presented as either “a link road to the Colts Hill bypass” or “a route to Paddock Wood to the north”. It is considered that TWBC should clarify which option(s) has been modelled in the Transport Assessment Report (SWECO, Sept 2019), as the effects on the local road network and, in particular, the Colts Hill roundabout may be significantly different. It is requested that TWBC clarifies this. 5.12 The potential for the strategic growth of Paddock Wood to also contribute towards other off- site infrastructure schemes will deliver further benefits for existing and new residents, which Policy STR1 lists as including potentially the 'offline' A228 strategic link (ie. the Colts Hill bypass). Given the location of the proposed Tudeley Garden Village (Policy AL/CA1), it is considered more appropriate for the Tudeley Garden Village development to deliver the A228 strategic link scheme in its entirety given that it will serve as Tudeley Garden Village’s primary means of strategic access. 5.13 The Distribution of Development Topic Paper (TWBC, Sept 2019) outlines the sustainability scores of each settlement as outlined in the Settlement Role and Function Study carried out by TWBC in 2017 and identifies key environmental constraints, including the AONB, Green belt, flood risk, and environment and heritage designations. The document then sets out TWBC’s housing and employment land need and the five development options that were considered in the Issues and Options consultation. Taking into account the outcome of the Issues and Options in balance with the outcome of the ‘Call For Sites’, TWBC has adopted an approach that includes elements of both Option 3 (dispersed growth) and Option 5 (standalone new settlement and the expansion of an existing settlement). For employment growth the strategy has drawn from Options 1, Option 2 and option 4. 5.14 In allocating land at Paddock Wood as a town suitable for significant expansion, TWBC considered the strategy against the NPPF (para 72). The assessment concludes that Tunbridge Wells is significantly constrained by landscape and flooding designations, and that development at Paddock Wood, whilst resulting in some Green Belt release, provides a sustainable location for settlement growth that is capable of delivering a larger scale development that will meet the requirements of the NPPF (para 71), whilst not conflicting with NPPF Green Belt policy (Para 136). We agree with the conclusion of that report and support the inclusion of Paddock Wood and the associated Green Belt release. Appendix 2 contains our own detailed Green Belt Review of the sites around Paddock Wood. 5.15 With the exception of a small number of minor clarifications, we support the overall development strategy outlined in Policy STR1, which seeks to deliver the majority of new dwellings in sustainable locations with a focus on established settlements well served by public transport, or developments of a scale capable of delivering sustainable development. The Development Strategy meets the requirements of NPPF (para 103), which states that “significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes”. [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_6403 | Hawkhurst Parish Council | Object | STR1 - The Development Strategy Hawkhurst Parish Council has significant concerns in terms of the Development Strategy. We have already outlined concerns regarding the calculation of housing numbers, the decision to adopt a dispersed growth strategy, and the lack of weight given to the AONB status of much of the borough. We believe that TWBC could significantly reduce its proposed housing numbers, whilst still meeting its obligations, and in doing so, would protect the sensitive landscape of the borough. Throughout the many documents produced in support of the Draft Local Plan, it is repeatedly emphasised that the potential for development outside the AONB has been maximised prior to allocating sites within the AONB. It is hard to see how this can be the case when Cranbrook, Hawkhurst and Sandhurst have allocations totalling 1089 to 1561 dwellings on sites that are wholly within the AONB (not just within the parishes) compared to allocations of 1222 to 1320 and 135 to 205 for the urban areas of Royal Tunbridge Wells and Southborough respectively. | ||||||||||||||||
DLP_6989 | Sigma Planning Services for Rydon Homes Ltd | Support with conditions | The reference to the Tudeley Village new garden settlement will need to be removed if, as is likely, it is withdrawn or delayed beyond the current plan. [TWBC: See full representation]. | ||||||||||||||||
DLP_6972 | Mrs Beryl Bancroft | Object | Good policy for Tunbridge Wells Town Centre but no real policy for the Rural areas. More houses planned for Cranbrook and Sissinghurst than Tunbridge Wells but no plans for more businesses in this area. No infrastructure plans and no transport plans so that people can get to areas with increased business facilitiesfrom Rural areas. Our local school in Sissinghurst is over subscribed so children cannot walk to school. The needs of older people in Rural areas have not been recognised. Lack of affordable and smaller bungalows. No footpaths on rural roads, and no safe way of road crossing due to speed of traffic in the villages. | ||||||||||||||||
DLP_6257 | Kember Loudon Williams for Mr R Barnes | Support with conditions | This submission is made in response to the Tunbridge Wells Borough Council’s (TWBC) Consultation Draft Local Plan (Regulation 18). It is made by Kember Loudon Williams on behalf of a private landowner, Mr R Barnes, who is seeking to promote his site at Stone Court Farm (identified as Site Number 354 in the Council’s Strategic Housing and Economic Land Availability Assessment). Strategic Policy STR1 details the development strategy for the Borough and includes the release of Green Belt around Pembury and a number of other settlements. The release of Green Belt land around Pembury is supported. However, we believe that an additional housing site should also have its Green Belt designation removed (Site number 354: Stone Court Farm). With the release of this additional site, the housing allocation given to Pembury should be therefore increased by a further 50 units. (For further details about the Stone Court Farm site and why it is considered suitable for development please refer to the representations provided in Comment Box 9). The emerging Local Plan recognises that the High Weald Area of Outstanding Natural Beauty (AONB) has the highest status of protection nationally in relation to landscape and scenic beauty. The supporting text to Strategic Policy STR 1 explains at Paragraphs 4.38 to 4.40 that the preferred strategy for growth (based on Option 3 - dispersed growth - and Option 5 - new settlements) has taken account of the need “to maximise the amount of major development outside the High Weald (AONB)”. In other words, a sequential approach to site selection has been adopted and sites that lie outside the AONB have been considered first. It is important to recognise that the Stone Court Farm Site is not located in the AONB yet some of the other sites identified for housing in Pembury in the emerging Local Plan are affected by this designation. It is not clear therefore why the site has been dismissed, whilst others with stronger landscape designations have been allocated as land suitable for housing. In order to ensure to ensure consistency with the sequential approach, an urgent review of all the sites in Pembury should be carried out and the subject site should be re-examined. This will ensure that the Plan is ‘sound’ and has been positively prepared in accordance with the requirements of the National Planning Policy Framework (NPPF). | ||||||||||||||||
DLP_7313 | Mr Richard Gill | Object | TWBC: the standard response was submitted by the list of responders on the left: Policy Number: STR 1 The Development Strategy I object to the scale and distribution of development within the AONB and its setting with reference to NPPF paragraph 172 “Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within these designated areas should be limited”. TWBC has failed to limit development and contrary to PPG it has sought to meet the needs of adjoining non-designated areas within the borough through allocating increased housing numbers to the AONB. In the Parish of Cranbrook and Sissinghurst the Housing Need Assessment completed by an independent assessor AECOM for the emerging NDP was 610, of which 250 were met by the Brick Kiln Farm allocation in the previous local plan leaving a further 360 to be delivered. The Draft Plan allocates 918 to these settlements. With reference to NPPF Paragraph 173 that major development should only be permitted in an AONB “in exceptional circumstances, and where it can be demonstrated that the development is in the public interest”, the Draft Plan also fails. There are chronic affordability issues in the Parish of Cranbrook and Sissinghurst and the developments are not going to meet these affordable housing requirements. | ||||||||||||||||
DLP_7351 | Wealden District Council | General Observation | The scale and distribution of development within Tunbridge Wells Borough is set out in Table 3 (associated with Policy STR 1). This identifies the three main locations for housing development in Royal Tunbridge Wells and Southborough, Paddock Wood and Tudeley Village. Further development will be located in other settlements across the Borough and will largely be provided on a proportional basis relative to the size of each settlement. Wealden District Council supports the North Farm/Longfield Road allocation in principle, as the approach is similar in nature to the A22 Employment Sector in the Submission Wealden Local Plan (January 2019) and is associated with the major settlement in the Tunbridge Wells Borough. | ||||||||||||||||
DLP_7627 | Mr James Peace | Object | Policy Number: STR1 Para 5 Reference is made to the need to provide new homes based on growth around Cranbrook, Sissinghurst and Hartley. What evidence supports this statement? There is a need to provide affordable homes for local families but the plan makes little or no provision for genuinely affordable homes within these parishes. | ||||||||||||||||
DLP_7245 | Mr John Telling | Object | What proportion of the projected extra houses is to be for young local people? The lowest price I saw for the new Hawkenbury 'Hollyfields' development was £580,000. These are not starter homes for local people, they are for incomers selling up in even more expensive areas (London). The town is full of mansions. Why do we need more? Why does the Council permit this sort of development? It leads one to speculate on the relationship between the Council and developers. The scale of housing proposed will destroy the town/countryside interface we currently have, reduce Greenbelt land, impact on the AONB and informal wildlife habitats. The character of the SE, in our location characterised by the distinctive landscapes of the Weald and Medway Valley, is under enormous threat as it is nibbled away. I therefore challenge the need for so many houses to be built over the plan period of 2016-2036. On the basis of the Office for National Statistics estimates of borough population growth of 13,952 people with an average house occupancy rate of 2.35 people (117,140 people living in 49,880 houses), the projected need is for 5,937 houses. TWBC must challenge the government on the methodology of the NPPF (Ref para 4.7) and the number genuinely needed in the borough. I also suggest that more consideration is given to building ‘upwards’ within the existing developed area rather than ‘out’ at the expense of farmland and natural habitats. Clearly this should not be to the detriment of historic areas of significant architectural value. But it would be a way of coping with the increasing population whilst preserving the Greenbelt, agricultural land and habitats. It would also make the provision of convenient public transport more viable. | ||||||||||||||||
DLP_7063 | Bloomfields for Giles MacGregor | Development Strategy and Strategic Policies (Policy STR1) The Council have applied a 10% non-delivery rate to these figures to err on the side of caution and consider that the plan would exceed the minimum housing requirement if all of the supply components were achieved. (1) Ancient Woodland (approximately 16% of the borough) The nearby Ashdown Forest is a designated Special Area of Conservation (SAC) and Special Protection Area (SPA). Although not an environmental constraint, the Metropolitan Green Belt covers 22% of Tunbridge Wells Borough. Given these constraints, it is acknowledged that planning for housing requires the need to balance a number of core environmental and planning matters in order to reach a sensitive future development strategy. [TWBC: for Policy AL/HO 2 see Comment No. DLP_7061. For Vision & Strategic Objectives see Comment No. DLP_7062. For Policy STR1 The Development Strategy see Comment No. DLP_7063. For Policy STR/HO 1 The Strategy for Horsmonden Parish see Comment No. DLP_7064. The full report is attached to this representation, along with supporting documents; Transport Statement, Site Layout Plan, Existing Site Layout Plan, Schedule of Accommodation, Preliminary Ecological Appraisal and Highways Definition Team Letter]. | |||||||||||||||||
DLP_7103 | Williams Gallagher for Canada Life Ltd | Support with conditions | Policy STR1 – The Development Strategy The strategy to ensure that the development needs are met through the local plan provisions is welcomed, particularly the proposals for enhanced town centre development in Royal Tunbridge Wells that seek to enable flexible retail, leisure, and cultural uses as well as new office and residential use as part of mixed-use developments. In order to be consistent with NPPF guidance (para 60), the amount of new housing proposed should be identified as the minimum requirement. We trust that you find these comments constructive and look forward to on-going dialogue with the Council. Please keep us informed of progress with the local plan preparation. Should you have any queries, please do not hesitate to contact us. [TWBC: see also Comment Nos. DLP_7102-7117]. | ||||||||||||||||
DLP_6997 | Kember Loudon Williams for Mr Anthony Whetstone | Support | Policy Number: Policy STR 1 The Development Strategy | ||||||||||||||||
DLP_6645 | Mr Steve Gasson | Object | Policy Number: Development Strategy STR1 Paragraph 4.3 states that ‘in preparing this Draft Local Plan, the Council has to be mindful that national planning policy, as set out in the NPPF (2019), expects local plans to meet the identified level of development needs for their area in full, unless there are good planning reasons why this is not possible. Accordingly, the proposed Development Strategy indicates how the full development needs of the borough can be most appropriately met.’ This presumption that the full development needs as derived formulaically using the new Standard Method must be met goes against NPPF paragraph 11, which makes clear that AONB designation may provide a strong reason for restricting the overall scale, type or distribution of development in the plan, and ignores the Planning Policy Guidance updated in July 2019 which specifically comments that in order to protect such areas it may not be possible to meet the formulaically derived needs. TWBC should carry out a transparent assessment demonstrating that in deciding the level of housing provision proposed, the type of homes and the distribution of those homes, great weight has been given to conserving and enhancing landscape and scenic beauty in the AONB; the conservation and enhancement of wildlife and heritage has been taken into account; and the scale and extent of development within the AONB has been limited. | ||||||||||||||||
DLP_6752 | Mrs Carol Richards | STR 1 (The Development Strategy) This policy does not include any reference to development on Brownfield sites, but does refer to the release of Green Belt. You should have a strategy of identifying suitable Brownfield sites and developing innovative ways to deliver housing on those sites. Does TWBC have a Brownfield Register and if so is every site planned to be built on? Point 2 Paddock Wood The Colt’s Hill bypass has been an issue for the last 20 years and should have been sorted years ago- rather like the A21 which took 40years. I suppose it is ’potential’ as you need developer funding to build it. Point 3 Tudeley A Garden Village is totally unsuitable for the Tudeley site and unsound. It should be withdrawn from the plan. Points 4-6 other settlements I hope you are planning development for the older person in towns and villages around the borough Point 7 I would like to note at this point that TWBC have not prepared a landscape sensitivity report for the area covering the area they are planning to build 7000 homes on, as can be seen from the study area boundary depicted on Figure 1.1 of the Landscape Sensitivity Assessment of Countryside around Tunbridge Wells (Feb 2017) – see also: Exhibit 1 (TWBC comment - see attachment) Para 1.3 of that report states its identified purpose “to help to inform the preparation of the Local Plan and, alongside consideration of other aspects of development potential such as feasibility, viability and availability, will assist in Development Management decisions regarding potential development areas or sites for allocation”. The report fails to cover the areas of Tudeley (and its floodplain), Five Oak Green and Paddock Wood as part of the process for deciding if these areas were suitable. The absence of this vital evidence renders STR/1 unsound. Table 3 (Scale and Distribution of Development) p.43 Entry in Table 3 - Main Urban areas - RTW I note under “Employment” there is provision for up to 90000 sqm. I presume this is to be sited on the 14 hectares set aside. It would be useful to plan to build homes along this corridor as is a far better area than Tudeley/Capel/ Paddock Wood. The policy of concentrating the bulk of the development in one area is not sound. TWBC need to spread the building requirement throughout the borough. Choosing option 3/ 4 and directing to some of the larger villages as in option 2. Entry in Table 3 - Paddock Wood/ Capel/ Tudeley I note here columns titled ‘Retail and other town uses and Employment’ all seem to be TBC part of the ‘Masterplan’. It is very strange that a Reg 18 Draft Plan to be consulted on seems to have ‘to be confirmed- TBC- at its heart. I am beginning to wonder if the whole idea of this cobbled together LP has come about to build the Colt’s Hill by pass with developers contributions, and the late windfall site of Hadlow Estate Land at Tudeley and Capel has made option 5 very attractive for all the wrong reasons. Maybe TWBC would like to rewrite their Reg 18 plan again? This Draft Plan is completely unsatisfactory and unsound. Entry in Table 3 - Other Parish settlements- Cranbrook to Speldhurst Many of these Parishes have small increases to the housing numbers which I am pleased to see-at least some tiny amount of ‘spatial distribution’. What I am not seeing is a plan to develop a larger Parish settlement (with Transport Bus links and local shops) perhaps more, away from the main urban areas of Tunbridge Wells/ Pembury/ Paddock Wood/ Tonbridge (I put in Tonbridge as TWBC seem to think it is part of their fiefdom to run rough shod over) that will provide the appropriate housing for the over 60+. More generally, I am not convinced the needs of an increasingly elderly population have been taken into account in terms of the type of housing needed. Specifically: * The joint Sevenoaks and Tunbridge Wells Strategic Housing Market Assessment (Sep 2015) (Table 14) identifies a projected 37% increase in the size of the 60-74 age group and an 83% increase in the size of the over 75 age group (both for the TWBC area). By 2033, those over 60 will account for just over 30% of the population (joint area) In conclusion, more consideration should be given to developing appropriate housing – typically bungalows - to accommodate the over 60s in more rural locations, as retired persons often contribute to volunteer work within a community and make a very valuable contribution. Building large greenfield settlements is the wrong answer to this problem. I don’t see any consideration of the above population issues in Policy STR1. If you follow the train of thoughts above, there is no sound reason to develop along the Tudeley / Capel/ Paddock Wood corridor, as all you are accommodating are dormitory towns for London and not addressing the really big local issues of providing for your LOCAL POPULATION! | |||||||||||||||||
DLP_7269 | Mrs Katie Lee-Amies | Comments on Section 2 & 3 I object to the proposed Vision and Strategic Objectives, the provisions of STR1 and STR/PW1, AL/PW1, AL/PW2, AL/PW3, AL/PW4, STR/CA1, AL/CA2, AL/CA3, for the reasons explained above [TWBC: See comments DLP_7265-7267]. To summarise:
Tudeley Garden Village is a vague outline on a plan in the Reg 18 Draft Local Plan. A schematic or zoning diagram indicating transport links, railway crossings, footpaths and green infrastructure should be included for a large new settlement comprising 63% of TWBC’s new homes. Too much information has been held back for the ‘masterplanning phase’ to enable objective assessment. TWBC are seeking comments on an incomplete Draft. | |||||||||||||||||
DLP_6213 | Amanda Wells | Object | Policy Number: STR1 Paragraphs 2 and 3 talk about establishing large housing developments following garden settlement princples. Garden settlements look to the past not the future – with climate change at the top of the agenda, land use planning determines that development should be in compact settlements where all housing is within walking distance of frequent public transport -not spread out over 600 acres, as in the case at Tudely, taking up precious agricultural land which has an important carbon sequestration function and plays an important role in flood prevention. These settlements will also almost certainly be creating housing estates where there will be intensive reliance on private cars. Paragraph 7 talks about releasing Green Belt land to deliver this development and paragraph 8 mentions the use of AONB sites where the tests in the NPPF are met. The NPPF is clear that only in exceptional circumstances may a Green Belt boundary be altered, through the Local Plan process – “unmet housing need alone will not amount to these special circumstances”. (Brandon Lewis – Housing Minister 2015) Para 137 of the NPPF states that before changes to GB boundaries are proposed, councils should examine fully all other options, make as much use of brownfield as possible and optimise the density of development. There is no evidence that TWBC has an up to date brownfield register and has thoroughly examined the use of brownfield sites or empty properties which could be brought back into residential use within the borough. It seems that instead of making a case for constraint based on much of the district being Green Belt and AONB, TWBC has attempted to meet unrealistic housing figures by altering the existing Green Belt status of large tracts of countryside. | ||||||||||||||||
DLP_7225 | Elizabeth Daley | Support with conditions | If the ENS has identified the above areas for development, this is surely where many new residents of the Parish of Cranbrook and Sissinghurst will be travelling to work, (14 miles away) entirely unsupported by appropriate infrastructure | ||||||||||||||||
DLP_7236 | Elizabeth Daley | Support with conditions | STR1 point 5 The statement is made that new healthcare and other facilities (which are?????) will be provided, despite the fact that no land has been allocated for a medical centre. | ||||||||||||||||
DLP_7560 | Mark Beales | General Observation | Policy STR1 c.A prestigious new business park will be located to the north of North Farm/Kingstanding Way that is well connected to the improved A21, providing a range of employment floorspace and jobs to meet identified needs. The site will make a substantial contribution to the need for new employment space over the plan period. Other employment, including leisure development, will be encouraged at North Farm/Kingstanding Way If the ENS has identified the above areas for development, this is surely where many new residents of the Parish of Cranbrook and Sissinghurst will be travelling to work, (14 miles away) entirely unsupported by appropriate infrastructureI object to placing so much development in Ctranbrook and Sissinghurst when employment is targeted so far away | ||||||||||||||||
DLP_6282 | Mrs Elizabeth Simpson | Object | Policy Number: STR1 The Development Strategy for the delivery of the Local Plan adopts a combination of growth strategies proposed in the Issues and Options document. Prominent in this mix is proportional distribution of growth across all existing settlements, despite the fact that the consultation recorded a less positive response to this approach than the other strategies. Also in the mix is growth within a new, free-standing settlement - however the feedback in the Issues and Options consultation, which recorded a slight preference for this growth strategy , specified that the new settlement should not be in the Metropolitan Green Belt or the AONB. The ‘Distribution of Development Topic Paper’ presents the justification for the proposed Development Strategy, including how the Issues and Options consultation informed the Strategy. However, the outcome is at odds with the feedback and, in several instances, goes directly against the views expressed. I oppose the proposed approach of dispersed growth across the Borough. It is inconsistent with the NPPF, which advocates focusing development in the most sustainable locations, allocating land with the least amenity value and conserving and enhancing the AONB, where the scale and extent of development within such designated areas should be limited (NPPF paragraphs 171 and 172). It is also contrary to the Council’s previous Local Plan and Core Strategy, which focussed growth in towns, recognising that villages and rural settlements are the least sustainable locations for development. So many of the proposed development sites allocated in the draft local plan go against these views expressed and are contrary to protections that should be afforded to AONB and Green Belts under the NPPF procedure. Dispersed growth with proportional development distribution is not consistent with the three objectives of sustainable development. Looking at our own village of Matfield, this is one of the least sustainable settlements in the borough. It lacks the services and amenities to support significant growth (up to 37.5% in the number of dwellings). There is no evidence of scope for the village to become more sustainable as a result of growth, despite the Council’s untested hope in that it may. Development of this scale in settlements with low sustainability is contrary to the NPPF (paragraphs 7 and 8) and is emphatically not in the public interest. What was the rationale for adopting the preferred approach of dispersed growth, in favour of the focused growth used in the Core Strategy? Was it simply a case of spreading the misery? How was the ‘proportional’ aspect of ‘proportional development distribution’ determined under the ‘dispersed growth’ model applied in the Development Strategy? What methodology was applied and how has this been tested? More should be done to promote a greater proportion of housing development on Brownfield land, particularly, in the existing urban centres. The current Brownfield Register for Royal Tunbridge Wells contains provision for only up to 950 homes, which is an incredibly small provision for a town of this scale. How exhaustive has the search been to identify land that could be redeveloped rather than building over rural areas, both in rural villages and the countryside? Why can’t more development be allocated to such Brownfield sites, within existing towns, where transport services are already in place, rather than destroy more of the AONB countryside? Development of brownfield sites often has the benefit of removing local eyesores and breathing new life into areas of towns which are run-down and further providing homes where most young people actually want to live, near to existing infrastructure, amenities and services. Brownfield site development should be prioritised over building in idyllic rural villages and a greater search of potential sites made in not only Tunbridge Wells but other towns in the borough. | ||||||||||||||||
DLP_6984 | Nigel Tubman | Object | I object to this policy because it is not about the whole of the borough with the focus on Tunbridge Wells and Southborough. Paddock Wood and Tudeley get mentioned in some detail but not the rest of the borough. The infrastructure improvements are minimal compared to the intention to build large housing estates in rural areas. | ||||||||||||||||
DLP_7198 | Mr Michael Armitage | Object | Sewage services are under scrutiny, as they are already unable to cope with demand. New development is therefore out of the question. | ||||||||||||||||
DLP_7200 | John Gibson | Object | Policy Number: STR1 5.5 Infrastructure is intended to precede the development, which is clearly not the case at present. | ||||||||||||||||
DLP_6848 | John Gibson | General Observation | Policy Number: STR1 c | ||||||||||||||||
DLP_6850 | John Gibson | General Observation | Policy Number: STR1 5.5 Inadequate infrastructure is in place to allow approval of the Dandara planning application for AL/CRS13. The infrastructure is intended to precede the development, which is clearly not the case. | ||||||||||||||||
DLP_7641 | John Gibson | General Observation | Policy Number: STR1 c By expanding North Farm/Kingstanding Way as an area for employment it follows that many of the proposed new residents in the Cranbrook and Sissinghurst Parish will be traveling by private cars. More employment opportunities need to be planned closer to the Parish. Also, better public transport options need to be provided. | ||||||||||||||||
DLP_6144 | Turley for Taylor Wimpey UK Ltd | Second Paragraph For transparency and clarity, it is recommended the Policy defines what the ‘identified needs of the borough over the Local Plan period’ are. This is set out in the preceding paragraphs, but not in the policy itself. Housing Development Preceding paragraphs 4.7 to 4.17 of Policy STR1 set out the Council’s proposed definition of ‘identified needs’ for housing over the plan period. Whilst we would broadly agree with the conclusions reached in respect of the baseline housing requirement or starting point, we would suggest further work is needed to quantify the contribution TWBC is able to make towards the unmet needs of adjoining authorities; and to addressing more of the shortfall in the borough’s supply of affordable housing. Unmet Needs Whilst the Council acknowledge the unmet needs of Sevenoaks (1900 homes), no further assessments appear to have been undertaken to assess whether some or all of this could be met through the emerging Local Plan. Paragraph 4.8 of the Draft Local Plan does not reference robust evidence to conclude no contribution can be made to such needs, only that TWBC has a ‘limited ability to meet any unmet housing needs from other Councils.’ To accord fully with NPPF paragraph 60 and justify the emerging Development Strategy in Policy STR1, we would suggest further work and statements of common ground are progressed on the ability or otherwise to address unmet needs of adjoining authorities; and importantly the strategy and implications for those needs that cannot be met. In addition, TWBC will be aware of the significant unmet needs identified in the recent examiners report for the new London Plan. No mention is made of this by TWBC in either the Draft Local Plan or the Housing Needs Assessment Topic Paper (TWBC, 2019). This merits further consideration in our opinion to accord with paragraph 60 of the NPPF. As paragraphs 28-35 of the Housing Needs Assessment Topic Paper (TWBC, 2019) outline, there is also a number of adjoining authority draft Local Plans at various stages of production at present. As acknowledged at para 33 of that document, some submitted plans may be subject to change. In addition emerging plans at Maidstone and Rother may also reveal needs that are still to be quantified. These merit further monitoring and cooperation to facilitate the drafting of statements of common ground on such matters. Affordable Housing Paragraph 6.1.5 of the Housing Supply and Trajectory Topic Paper (TWBC, 2019) indicates the Council are forging a plan that will fail to meet affordable housing needs identified in paragraph 48 of the Housing Needs Assessment Topic Paper (TWBC, 2019). A supply of 249 homes a year is planned against a conservative need for 341 dwellings per year. However, ten of the 249 units per year are proposed to be delivered from financial contributions secured from sites under 10 units. This is contrary to paragraph 63 of NPPF which states that “affordable housing should not be sought for residential developments that are not major developments”. This paragraph was introduced by the government as a signal of support for SME developers who tend to deliver such sites; and whom would otherwise struggle to deliver such sites viably. Further viability evidence is required in our view to support such a requirement against paragraph 63 of the NPPF. Nevertheless, even if this were to be evidenced, affordable housing provision will still significantly undershoot need. This provides compelling evidence in our opinion, in addition to that which may arise from assessments of unmet needs of adjacent authorities, to justify testing a higher borough housing requirement through the emerging Draft Local Plan. Higher than the 14,776 proposed to be delivered through Policy STR1. As our clients site submission herein has shown, there are sites that may have been overlooked in error, sites that are available, suitable and deliverable and could be making a contribution to affordable housing provision. Development Distribution and Delivery As set out in Policy STR1 and Table 18 of the Housing Supply and Trajectory Topic Paper (TWBC, 2019), the Council are seeking to deliver around 67% of total new site allocations at or adjacent to Capel Parish, largely around the areas of Tudeley and Paddock Wood. Whilst centred on a rail line, the garden settlement proposal is not served by an existing or it seems proposed safeguarded rail station. Instead reliance is placed on the delivery of significant strategic road infrastructure to service this alongside that proposed at Paddock Wood. It is not clear how this serves to reduce the need to travel by car, a key sustainability objective, nor is it clear what the implications of this are for the delivery rates proposed for both sites. Particularly as the routes, funding and delivery timetable of such significant infrastructure, including an offline A228 strategic link, has not been determined as yet. The implications of delivering this and other associated infrastructure in areas of flood risk pose significant engineering and viability challenges; and with them potential for reduced capacities and delays. Further analysis of this is therefore suggested to determine the implications for site delivery rates. We would therefore wish to reserve the right to comment further on this as more detail emerges. Turning to delivery rates assumed for these two large growth areas. The proximity of these proposals to each other may well have an impact on the speed with which such sites come forward and the rate at which homes are delivered and absorbed into the market. The absorption rate of development in such a small market area and competition between the two sites for sales may significantly impact delivery rates. The Housing Supply and Trajectory Topic Paper (TWBC, 2019) does not appear to assess the implications of absorption rates or the proximity of these sites to each other. Instead, reliance appears to be placed on national delivery rates on sites that do not mirror the characteristics of delivering such large sites in proximity to each other and in this borough. TWBC rely on an assumed delivery rate for the allocations proposed in Capel/Paddock Wood of 333 homes a year. The Council acknowledge at paragraph 5.5.14 of the Housing Supply and Trajectory Topic Paper (TWBC, 2019), that this is higher than the evidenced national average of 299 homes. Whilst the latter may well be the case nationally, it does not account for the specific circumstances arising from the proximity of two large scale proposals in Tunbridge Wells Borough. Particularly the implications of expected absorption rates on delivery rates, given the proximity of these two large growth areas in such a small market area. We would suggest therefore further work is undertaken on such matters; and that a more cautious approach to delivery is taken than that proposed accordingly. TWBC acknowledge the proposed delivery rates for both Tudeley and Paddock Wood is also dependent on the number of developers and sales outlets, which are as yet unknown. In addition, Draft Local Plan Policy STR/CA1 (‘Masterplanning and Delivery’ bullet points 3 and 4) indicate a need for potential equalisation agreements and potentially even compulsory purchase orders, to deliver planned growth. All of which contribute to a need for a more cautious approach to delivery than using uplifted national average site delivery rates. We would suggest further work is undertaken on such matters to build in a greater level of certainty; alongside the allocation of additional smaller, more deliverable sites as necessary, to help maintain a rolling five year supply of housing land. Our client’s site being an example of one such opportunity, one we would welcome further discussion with TWBC on. The above serves to highlight the importance and exceptional need for delivering the smaller allocations around other sustainable settlements, such as Cranbrook. We support, as a minimum, the quantum of growth directed to Cranbrook through Policy STR1 in this context. Indeed, an argument could be made in light of the above for further modest growth at this settlement. The population of Cranbrook is rapidly ageing. Since 2011, the number of residents aged 50 plus has increased by 14% while other cohorts have reduced by 10% [ONS (2019) Population estimates for small areas, Cranbrook - Cranbrook BUASD]. In parallel, average house prices in Cranbrook having risen at a faster rate (39%) than the wider borough (32%) over the past five years (2013-2018). The average price paid for housing in Cranbrook last year was the highest in at least a decade [Turley analysis of Land Registry price paid data, based on postcodes in built-up area of Cranbrook]. A failure to retain and replenish the younger population could therefore threaten the long-term vitality of the settlement if such trends continue. In light of this, we support the proportion of growth directed to Cranbrook, as a minimum, but recommend a reassessment of our client’s lands (SHELAA Site ref: 25) alongside proposed allocations CRS6, CRS7 and CRS4. As outlined in the introduction to our letter, our client’s site appears to have been scored incorrectly against the Council’s own SA criteria and in the Council’s SHELAA (2019). Our initial analysis suggests the site is a suitable opportunity for a modest allocation (circa 70 homes); and is superior in many respects to proposed allocations CRS6, CRS7 and CRS4. We therefore respectfully commend this site for allocation in addition to or instead of one of these allocations. We provide further comments on the allocations proposed in the Cranbrook section of the draft Local Plan below. [TWBC: see full representation and supporting document A, supporting document B, supporting document C, and supporting document D]. | |||||||||||||||||
DLP_6191 | Turley for Bellway Homes Strategic | Policy STR1 is accompanied by Table 1 of the draft Local Plan which sets out the scale and distribution of development. That table identifies Tunbridge Wells as the Main Urban Area where allocations are expected to deliver 1,222-1,320 dwellings (average 1,271). Notably Tunbridge Wells is expected to accommodate significantly fewer dwellings than Tudeley Village during the Plan period despite the clear and obvious disparity between the two settlements/areas. Fundamentally, Tunbridge Wells is a sustainable location for growth now, Tudeley Village is not and will never be in a position where it exhibits the same overall sustainability credentials as Tunbridge Wells. Overall we note that the quantum of development directed to Tunbridge Wells is disproportionately low compared to the levels of development expected to be provided at other, less sustainable, settlements within the Borough. This is despite the availability of sites at Tunbridge Wells which have been assessed as being suitable, sustainable and logical. Whilst we note that the consultation is accompanied by a Topic Paper on the ‘Distribution of Development’, this appears to be an explanation as to why sites have been selected, rather than an explanation why other approaches, such as a wider distribution of development without reliance on a garden settlement, or a refocus towards Tunbridge Wells have been excluded. In addition, we consider that the Policy should define the ‘identified needs of the borough over the Local Plan period’. This is set out in the preceding paragraphs, but not in the policy itself. [TWBC: see full representation and Comment Numbers DLP_6189-6198]. | |||||||||||||||||
DLP_6250 | Anne Trevillion | Object | Policy Number: STR1 The Development Strategy | ||||||||||||||||
DLP_6290 | Susan Heather McAuley | Object | Policy Number: Section 4 Strategic Policies Policy STR 1 The Development Strategy Point 1 - Tunbridge Wells is going to receive all the new facilities and the employment but Tunbridge Wells is receiving proportionately far fewer houses than Sissinghurst (5% in TWells compared to 32% for Sissinghurst). The numbers for Sissinghurst make no sense based on the current size of the settlements, transport facilities and infrastructure – the numbers for Sissinghurst should be reduced. Point 5 – says there are high numbers proposed for Sissinghurst because of the growth in the area – what growth is that? There is no employment locally and no high pressure on housing at the moment. Point 6 – other settlements are to get new housing within their Limits to Build boundaries whereas the LBD in Sissinghurst has been specifically altered by TWBC to allow extra new housing. | ||||||||||||||||
DLP_6321 | Susan Heather McAuley | Table 3 Scale and Distribution of Development For Sissinghurst – 108 houses is totally out of scale and this allocation should be reduced. This would increase the size of the village by one third. There is absolutely no justification for doing this to Sissinghurst. There is no great pressure on housing in Sissinghurst; the recently built new estate is taking ages to sell and even the shared ownership on it has not sold. Sissinghurst seems to be being penalised here, 108 more houses, but zero increase in employment. This is economically, environmentally and socially unsustainable. | |||||||||||||||||
DLP_6323 | Persimmon Homes South East | 3. Development Strategy Summary 6. Summary and Conclusion These representations have been prepared by Persimmon Homes in respect of the Land West of Freight Lane, Cranbrook, Kent. These representation have demonstrated that the Site is a situated in a sustainable location on the edge of Cranbrook which is the most sustainable settlement in the Borough outside of the Main Urban Area. These representation have shown that, whilst the Site is subject to some limited environmental constraints, these can be mitigated through careful design and the delivery of a comprehensive green infrastructure scheme. Whilst the Council have taken a proactive approach to accommodating the housing requirement over the plan period, the development strategy as current conceived is subject to several shortfalls which make is ‘unsound’. These representations have highlighted that, these issues can be addressed by directing additional growth toward sustainable locations around Cranbrook, most notably toward the Site. [TWBC: see full representation. Also see Comment Nos. DLP_6319, 6323-6326, 6328, 6830-6835, 6837-6839]. | |||||||||||||||||
DLP_6427 | Gary Birch | Object | Policy Number: STR 1 I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is not applicable to Hawkhurst Parish Council, which (I understand) doesn’t supports the development proposed in the Draft Local Plan. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects: 1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan; 2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point. Hawkhurst The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course. The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village. The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan. There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development. Non-compliance with Hawkhurst Neighbourhood Development Plan Lack of adequate infrastructure Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament. The proposed development would impact unacceptably on an AONB The proposed development would not constitute sustainable development The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment. Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. There are very limited local employment opportunities and no secondary schools within walking distance. The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution. The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it. TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103). The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate. The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF. There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF. The “relief road” is not a proven means of mitigating traffic As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes. | ||||||||||||||||
DLP_6452 | L Noakes | Object | The Development Strategy I am disappointed that our Borough Council has so easily accepted the figures produced and imposed by Central government. The figures produce a scale of housing which, given the constraints with AONB, Metropolitan Green Belt and considerations to the likely effects on the Special Protection Area of the Ashdown Forest; pays no regard to the unique character of many of the rural villages and will cause considerable harm to the protected status of the landscape in the Borough. As the Council has admitted through its own documentation that trying to allocate housing within these restrictions has been difficult task, and clearly understands the problems it will cause, I am at a loss to understand why the allocation for the Borough has been so easily accepted and why a case to try and reduce the numbers has not been brought forward by TWBC. Instead TWBC seem to be allowing for an ‘over supply’ of around 9% in their allocations, which given the difficulty in finding suitable sites, seems very inappropriate. The NPPF, paragraphs 102&103 state that there is a need to locate development so as to reduce travel and increase the scope for walking, cycling and public transport. The climate change emergency which we are also facing would indicate this is a good response to planning. Paragraphs 171 & 172 seek to conserve and enhance AONB’s by limiting the scale and extent of development in such designated areas. Unfortunately, as the Draft Plan itself explains, in the Borough of Tunbridge Wells this leaves very little land available for large scale development and pushes a disproportionate amount of development in to our rural settlements. These same rural areas have very little in the way of public transport and infrastructure. The BC’s attempts to solve this problem with the ‘expectation’ for developer contributions to assist with this and promised liaison with KCC Highways and other infrastructure bodies, does little to allay my personal fears that this is an inadequate solution to this problem. The BC held a consultation in June 2017 to seek public opinion on the preferred option with regards to the placing new development in the Borough. Since this early consultation, they have chosen to follow a ‘dispersed growth strategy’ which promises to put the majority of the development in rural areas, rather than directing it towards urban areas such as Tunbridge Wells, Southborough and/or along a growth corridor such as the A21, where there is better access to road and rail networks. This again seems contradictory to the NPPF which tries to encourage development in more sustainable areas. The most significant consequence of the policy of dispersed growth is that the area covered by five local councils in the north-east of the borough would take most of this housing development. An area, roughly comprising Horsmonden, Brenchley and Matfield, Paddock Wood, Capel, and Pembury, has been allocated in excess of 7,000 units. However, despite this, there seems to be no indication in the Plan, that it is the priority area for infrastructure investment. Nor is there any indication of the cumulative impact of development across this area. Whilst I understand that a master-planning approach would be taken in the development of the strategic sites, this does not go far enough in dealing with such issues as the social, economic, and environmental infrastructure needed to support development on that scale. The large-scale development of this area will have a knock-on effect on all the surrounding villages and settlements, residents of whom will suffer the consequences of blocked roads, overcrowded schools and doctors’ surgeries. As plans and timescales for any increase in infrastructure is unclear, it cannot be assumed that these facilities will be expanded quickly enough to cope with the increased demands. The resultant increase in population in this area will have a major impact on the already overstretched train services to London as well as the resultant car parking facilities required at local stations, many of which already operate a waiting list for spaces. | ||||||||||||||||
DLP_6480 | Woolf Bond Planning for Millwood Designer Homes Ltd | Site 2: Chittenden Fields, adjacent to High Street and Slip Mill Road, Hawkhurst Policy STR 1: The Development Strategy Representation The Council has followed the Standard Method approach to identifying the housing need for the Plan period. This approach is supported as it is compliant with the requirements set out in the NPPF. The resulting minimum housing requirement of 13,560 dwellings (678 per year) is therefore considered to be appropriate in terms of plan-making. However, the housing requirement needs to be embedded into the actual policy wording, i.e. within the green policy box. As presently drafted it is located in the supporting text and within tables 1 and 3. This will provide for greater clarity and certainty in relation to the policy requirements. Additionally, to be in accordance with the NPPF and the Government’s objective to significantly boost the supply of homes (para. 59, NPPF, 2019), the housing requirement should be highlighted as a minimum figure, and not a ceiling target. In respect of Table 1, we note that the table sets out the requirement for 13,560 dwellings to be met in the period 2016 – 2036. This should be clearly expressed as a minimum target. The components of supply in Table 1 suggest the need to allocate a minimum of 7,593 dwellings to meet the remaining requirement (after taking into account of completions, commitments and windfalls). The deliverability of the other elements of supply depends upon whether the sites within rows 3, 4 and 5 come forward. Their deliverability has yet to be tested through the examination process. Paragraph 4.15 of the draft Local Plan refer to the need to make an allowance for the delay and/or non-delivery of a proportion of the identified sites. This approach is supported. Paragraph 4.16 states that the total capacity of all of the identified components of supply, including the proposed allocations, could deliver around 14,776 dwellings during the plan period. It is said that this is 9% in excess of the 13,560 minimum target requirement. If realised during the plan period, the purported delivery of 14,776 net additional dwellings would be 1,216 dwellings in excess of the minimum requirement. However, and with reference to pages 27 and 30 of the Housing Supply and Trajectory Topic Paper, even if delivery at Tudeley (AL/CA1) and Paddock Wood (AL/PW1) is delayed by only 2 years the ‘surplus’ against the minimum requirement would be reduced to less than 200 dwellings. This assumes all of the other components of supply deliver at the point envisaged. Given the inherent delays with the planning for and delivery of strategic sites, the approach to site allocation cannot be said to be justified and is likely to fail to provide for a flexible supply of housing land. In any event row 6 in Table 1 should be re-worded to increase the allocations required, in order to provide not only for the planned housing requirement, but also to identify additional sites for choice, flexibility and competition in the market in line with national policy. We agree with the approach to disperse housing allocations across the Borough and allocate land for additional housing at many of the smaller (and sustainable) settlements. As a general note, it is unclear from the wording of the draft site allocations, where a range of dwellings is indicated, how many dwellings are required to be delivered from each site in order to meet the housing requirement. Suggested Change The housing requirement needs to be embedded into the actual policy wording, i.e. within the green policy box. As presently drafted it is located in the supporting text and within tables 1 and 3. This will provide for greater clarity and certainty in relation to the policy requirements. The 13,560 dwelling housing target should be clearly expressed as a minimum. The Council should review the delivery assumptions for and of the strategic sites. [TWBC: see full representation, site plan and Landscape and Visual Statement]. [TWBC: see also Comment Numbers DLP_6479-6484] | |||||||||||||||||
DLP_6487 | Woolf Bond Planning for Millwood Designer Homes Ltd | Policy STR 1: The Development Strategy Representation Site 222: Land on the west side of Iden Green Road, Benenden, TN17 4ES The Council has followed the Standard Method approach to identifying the housing need for the Plan period. This approach is supported as it is compliant with the requirements set out in the NPPF. The resulting minimum housing requirement of 13,560 dwellings (678 per year) is therefore considered to be appropriate in terms of plan-making. However, the housing requirement needs to be embedded into the actual policy wording, i.e. within the green policy box. As presently drafted it is located in the supporting text and within tables 1 and 3. This will provide for greater clarity and certainty in relation to the policy requirements. Additionally, to be in accordance with the NPPF and the Government’s objective to significantly boost the supply of homes (para. 59, NPPF, 2019), the housing requirement should be highlighted as a minimum figure, and not a ceiling target. In respect of Table 1, we note that the table sets out the requirement for 13,560 dwellings to be met in the period 2016 – 2036. This should be clearly expressed as a minimum target. The components of supply in Table 1 suggest the need to allocate a minimum of 7,593 dwellings to meet the remaining requirement (after taking into account of completions, commitments and windfalls). The deliverability of the other elements of supply depends upon whether the sites within rows 3, 4 and 5 come forward. Their deliverability has yet to be tested through the examination process. Paragraph 4.16 states that the total capacity of all of the identified components of supply, including the proposed allocations, could deliver around 14,776 dwellings during the plan period. It is said that this is 9% in excess of the 13,560 minimum target requirement. However, including for the reasons set out in our representations upon Policies STR/CA1 and STR/PW1, we have concerns about the Council’s housing trajectory and the assumptions in relation to the timing for and delivery of dwellings from certain of the strategic site allocations. If realised during the plan period, the purported delivery of 14,776 net additional dwellings would be 1,216 dwellings in excess of the minimum requirement. However, and with reference to pages 27 and 30 of the Housing Supply and Trajectory Topic Paper, even if delivery at Tudeley (AL/CA1) and Paddock Wood (AL/PW1) is delayed by only 2 years the ‘surplus’ against the minimum requirement would be reduced to less than 200 dwellings. This assumes all of the other components of supply deliver at the point envisaged. Given the inherent delays with the planning for and delivery of strategic sites, the approach to site allocation cannot be said to be justified and is likely to fail to provide for a flexible supply of housing land. In any event row 6 in Table 1 should be re-worded to increase the allocations required, in order to provide not only for the planned housing requirement, but also to identify additional sites for choice, flexibility and competition in the market in line with national policy. We agree with the approach to disperse housing allocations across the Borough and allocate land for additional housing at many of the smaller (and sustainable) settlements. As a general note, it is unclear from the wording of the draft site allocations, where a range of dwellings is indicated, how many dwellings are required to be delivered from each site in order to meet the housing requirement. Suggested Change The housing requirement needs to be embedded into the actual policy wording, i.e. within the green policy box. As presently drafted it is located in the supporting text and within tables 1 and 3. This will provide for greater clarity and certainty in relation to the policy requirements. The 13,560 dwelling housing target should be clearly expressed as a minimum. The Council should review the delivery assumptions for and of the strategic sites. Additional small scale deliverable sites at sustainable locations should be allocated for housing development in order to ensure an adequate and flexible supply of deliverable housing land. [TWBC: see full representation, Figure 3 Landscape Strategy, Heritage & LGS Assessment, and site location plan]. [TWBC: see also Comment Numbers DLP_6485, 6487-6489, 6491-6494] | |||||||||||||||||
DLP_6550 | Woolf Bond Planning for Millwood Designer Homes Ltd | Site 60: The Paddocks, Home Farm, 92 Lower Green Road, Rusthall TN4 8TT Policy STR 1: The Development Strategy Representation The Council has followed the Standard Method approach to identifying the housing need for the Plan period. This approach is supported as it is compliant with the requirements set out in the NPPF. The resulting minimum housing requirement of 13,560 dwellings (678 per year) is therefore considered to be appropriate in terms of plan-making. However, the housing requirement needs to be embedded into the actual policy wording, i.e. within the green policy box. As presently drafted it is located in the supporting text and within tables 1 and 3. This will provide for greater clarity and certainty in relation to the policy requirements. Additionally, to be in accordance with the NPPF and the Government’s objective to significantly boost the supply of homes (para. 59, NPPF, 2019), the housing requirement should be highlighted as a minimum figure, and not a ceiling target. In respect of Table 1, we note that the table sets out the requirement for 13,560 dwellings to be met in the period 2016 – 2036. This should be clearly expressed as a minimum target. The components of supply in Table 1 suggest the need to allocate a minimum of 7,593 dwellings to meet the remaining requirement (after taking into account of completions, commitments and windfalls). The deliverability of the other elements of supply depends upon whether the sites within rows 3, 4 and 5 come forward. Their deliverability has yet to be tested through the examination process. Paragraph 4.15 of the draft Local Plan refers to the need to make an allowance for the delay and/or non-delivery of a proportion of the identified sites. This approach is supported. Paragraph 4.16 states that the total capacity of all of the identified components of supply, including the proposed allocations, could deliver around 14,776 dwellings during the plan period. It is said that this is 9% in excess of the 13,560 minimum target requirement. If realised during the plan period, the purported delivery of 14,776 net additional dwellings would be 1,216 dwellings in excess of the minimum requirement. However, and with reference to pages 27 and 30 of the Housing Supply and Trajectory Topic Paper, even if delivery at Tudeley (AL/CA1) and Paddock Wood (AL/PW1) is delayed by only 2 years the ‘surplus’ against the minimum requirement would be reduced to less than 200 dwellings. This assumes all of the other components of supply deliver at the point envisaged. Given the inherent delays with the planning for and delivery of strategic sites, the approach to site allocation cannot be said to be justified and is likely to fail to provide for a flexible supply of housing land. In any event row 6 in Table 1 should be re-worded to increase the allocations required, in order to provide not only for the planned housing requirement, but also to identify additional sites for choice, flexibility and competition in the market in line with national policy. We agree with the approach to disperse housing allocations across the Borough and allocate land for additional housing at many of the smaller (and sustainable) settlements. As a general note, it is unclear from the wording of the draft site allocations, where a range of dwellings is indicated, how many dwellings are required to be delivered from each site in order to meet the housing requirement. Suggested Change The housing requirement needs to be embedded into the actual policy wording, i.e. within the green policy box. As presently drafted it is located in the supporting text and within tables 1 and 3. This will provide for greater clarity and certainty in relation to the policy requirements. The 13,560 dwelling housing target should be clearly expressed as a minimum. The Council should review the delivery assumptions for and of the strategic sites. Additional small scale deliverable sites at sustainable locations should be allocated for housing development in order to ensure an adequate and flexible supply of deliverable housing land. [TWBC: see full representation, site context plan, access improvements and site location plan]. [TWBC: see also Comment Numbers DLP_6548-6450, 6452-6453, 6456-6457, 6459] | |||||||||||||||||
DLP_6490 | Clare Govan | Object | TWBC: the standard response was submitted by the list of responders on the left: I object to the excessive number of dwellings proposed within the AONB at Cranbrook and at Hawkhurst. No distinction has been made between the proportion of housing allocated to the borough as a whole, and that allocated to Cranbrook and Hawkhurst. Moreover, the proposal is not in accordance with the requirements for strategic policies applicable to AONBs specified in paragraph 11 of the NPPF: “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
Planning Practice Guidance (Paragraph: 041 Reference ID: 8-041-20190721[1]) supports the principle that development within AONBs should be limited in view of the importance of conserving and enhancing their landscapes and scenic beauty: “Its [the NPPF’s] policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas” [1] https://www.gov.uk/guidance/natural-environment The proposal is also inconsistent with the AONB Management Plan, adopted by Tunbridge Wells Borough Council in March 2019. The Plan explains that the High Weald is a small-scale landscape built by hand. It commits authorities to ‘seek to deliver new housing primarily through small-scale developments that meet local need’ (Objective S2, page 34). Paragraph 172 of the NPPF says that ‘Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest’. The tests associated with this policy have not been properly considered and the exceptional circumstances have not been justified. Alternatives to the large allocations have not been properly considered and the option of reduced allocations on the larger sites offered in the Strategic Housing and Economic Land Availability Assessment has not been properly examined. I specifically object to the statement at item no.5 (new homes based on growth around Cranbrook itself, Sissinghurst, and at Hartley). This statement is unclear and potentially misleading so as to conceal the reality that growth generated by Royal Tunbridge Wells is proposed to be accommodated by a hugely disproportionate number of new dwellings in Cranbrook & Sissinghurst Parish. Furthermore, the statement “Further development at Cranbrook to provide new homes based on growth around Cranbrook itself, Sissinghurst, and at Hartley” is ambiguous. It isn’t clear whether “and at Hartley” is referring to the location of further development, or to growth around Hartley. This policy item should make it clear that the extent of any development around Cranbrook & Sissinghurst Parish should be limited to local needs and that the multiple listed buildings and nature of the topography at Hartley mean that major development there would unavoidably cause irreversible damage to the character of the AONB which would not be forgiven by the community or future generations. | ||||||||||||||||
DLP_6541 | Diana Badcock | Support with conditions | Policy Number: STR1 1.5 I support the need for a new medical centre in Cranbrook although the need is not determined merely by further population growth, as the need for a modern centre exists now. | ||||||||||||||||
DLP_6571 | Myrtle Newsom | Object | Policy Number: Section 4 Strategic Policies Policy STR 1 The Development Strategy Tunbridge Wells is going to receive all the new facilities and the employment but Tunbridge Wells is receiving proportionately far fewer houses than Sissinghurst. The numbers for Sissinghurst make no sense based on the current size of the settlements, transport facilities and infrastructure – the numbers for Sissinghurst should be reduced. | ||||||||||||||||
DLP_6610 | AAH Planning for Future Habitat Ltd | Policy STR 1 – The Development Strategy Policy STR 1 sets out the overarching Development Strategy for the Local Plan. The Key Diagram illustrates the spatial strategy and the broad distribution of development. The supporting table to the policy identifies a range of 643-693 housing allocations, as well as other infrastructure for Hawkhurst. It is considered that the wording in the supporting text in relation to the number of new homes should specify “at least” or “a minimum of”, rather than an approximate range, in order to boost significantly the supply of housing in accordance with the NPPF. Furthermore, Policy STR/HA 1 sets out specific requirements for development within Hawkhurst and identifies that approximately 681-731 new dwellings will be delivered through site allocations. It is unclear as to why these ranges differ and some clarity is required to explain this. In addition, in order to ensure that the overall aims and objections of the Local Plan can be met, it is important that the development strategy allows for future expansion and flexibility. This is essential to ensure that the [TWBC: see full representation and site plan attached]. [TWBC: see also Comment Nos. DLP_6606-6620, 6622-6627]. | |||||||||||||||||
DLP_6669 | Gladman | Support | 5 SUPPORTING HOUSING GROWTH 5.1 Policy STR 1: The Development Strategy Spatial Strategy 5.1.1 Policy STR1 sets the overarching strategy to meet development needs over the plan period for the Local Plan. Supporting text to the policy confirms that a strategy of distribution (Option 3) has formed the basis for the Council’s approach in Policy STR1. Gladman supported this strategy in its submitted representations to the Issues and Options consultation, and as such welcomes the Council’s decision. This approach promotes delivery across a broad area, and best supports the development needs of each settlement in the District including its rural areas. 5.1.2 The concentration of growth at Paddock Wood and new settlement at Tudeley represents a sound approach at which to deliver a large part of the future development needs of the District. Both sit outside the High Weald AONB and as such are unlikely to result in harmful effects on special and valued landscapes in line with the NPPF. The concentrated of development in these locations also ensures that other areas of Green Belt considered to fulfil an important function is safeguarded from development, promotes higher rates of housing delivery, and provides the opportunity to secure the delivery of new infrastructure necessary to secure this growth in accordance with the Plan’s vision and objectives. 5.1.3 Notwithstanding this, there is a need for the Council to ensure that identified housing needs are met consistently through the plan period and as such smaller sites distributed across the wider Borough are necessary. The Local Plan demonstrably secures this with sites identified at sustainable and suitable settlements for growth such as Horsmorden and Pembury. This approach will help secure delivery in the earlier part of the plan period before strategic sites with longer lead-in times commence delivery and ensures that the Local Plan is better equipped to deal with locally arising housing need. 5.1.4 As part of this, Gladman welcomes the Council’s decision to release land from within the Green Belt within the Borough and the allocation of major sites within the AONB. Gladman agree that the extensive development needs of the District and associated economic, social and environment impacts of failing to accommodate this in full, combined with the extent and constraining nature of the Green Belt and AONB to some of the Borough’s most sustainable locations, provide the exceptional circumstances and public interest case required to develop the Green Belt and AONB in accordance with the tests of national planning policy. 5.1.5 Gladman therefore support the Council’s spatial strategy as drafted. 5.1.6 Supporting text to Policy STR1 confirms the Local Housing Needs of Tunbridge Wells for the period 2016 to 2036 is 13,560 dwellings. The basis for this need is set out in the Housing Needs Assessment Topic Paper. 5.1.7 The Housing Needs Assessment Topic Paper confirms that the housing needs of Tunbridge Wells have been derived applying the Standard Method as advocated in national planning policy [2 PPG Paragraph 002 Reference ID: 2a-002-20190220 ]. In common with PPG, to determine the level of demographic housing need, the 2014-based household projections have been used [3 PPG Paragraph 004 Reference ID: 2a-004-20190220 ]. This has been assessed over the period 2020 to 2030 to respond to PPG that a housing needs figure can be fixed for a 2-year period following submission [4 PPG Paragraph 008 Reference ID: 2a-008-20190220 ]. The overall effect on housing need of rebasing this 10-year period from 2019-2029 to 2020-2030 is marginal given the limited change in demographic need and the fact that the adjustment made in response to affordability in the authority is capped. 5.1.8 Noting the above and based on current evidence, Gladman consider that the Council’s approach in establishing the minimum level of local housing needs is sound. However, as set out in Paragraph 4.1.3 of this representation (and as recognised by the Council in the associated Topic Paper), both the approach to defining housing needs and data informing this calculation is subject to change within the next 12 months and as such should be subject to review ahead of consulting on the Submission version of the Local Plan. 5.1.9 The NPPF and PPG both confirm that the standard method represents the minimum housing needs of an area and confirms the circumstances where housing needs may be higher than the standard method indicates. [5 PPG Paragraph 010 Reference ID: 2a-010-20190220] This includes, but is not limited to: * Growth Strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals); * Strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; * An authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground; and * On occasion, situations where previous levels of housing delivery in an area, or previous assessments of need are significantly greater than the outcome from the standard method. Housing Requirement 5.1.11 To aid the transparency and clarity of the Local Plan, Gladman consider that the housing requirement should be set out within Policy STR1. The adoption of this approach will improve the accessibility and legibility of the document and allow for more effective plan monitoring (see Section 7 of this representation). Housing Supply 5.1.12 Table 1 of the Local Plan provides a breakdown of housing land supply as of 1st April 2019. Table 1 confirms: * There have been 1,552 dwellings completed in the District between April 2016 and March 2019; * There is a residual requirement of 12,008 dwellings at 1st April 2019 to meet the current identified local housing need; * At 1st April 2019 there were commitments for 3,127 dwellings; * This excludes a further 580 dwellings at existing allocated sites; * A windfall allowance of 700 dwellings is made for the remaining plan period; and * There is a need to identify allocations sufficient to deliver 7,593 dwellings to meet needs not already committed, allocated or accounted for. 5.1.13 The position set out in Table 1 is supported by evidence provided within the Housing Supply and Trajectory Topic Paper. This Paper provides the Council’s rationale for the sources of supply referenced above including existing site allocations and windfall. 5.1.14 For site allocations, the Paper sets out that these have been subject to review by the Council, with sites considered deliverable retained in the supply as part of the new Local Plan. Sites found undeliverable have been removed. Whilst Gladman welcome and endorse the Council’s approach, it is unclear where this assessment is, and as such the Council’s conclusions cannot be examined. Gladman request that this is made available before the Local Plan is submitted to the Secretary of State for examination. 5.1.16 The overall level of supply provided by allocations identified within the local plan combined with commitments, completions and other sources of supply is outlined in Paragraph 4.16 of the Local Plan to amount to 14,776 dwellings (a 9% buffer). 5.1.17 The decision made by the Council to identify a surplus of land in comparison to the housing requirement is welcomed. This is necessary to ensure that the Local Plan is resilient to change and continues to be effective over the plan period should sites not deliver as expected. 5.1.18 Gladman is however concerned that a 9% buffer in housing land supply is insufficient and should be increased to around 20% (an equivalent uplift of 1,496 dwellings against that currently planned by the Council). This is of increased importance in the case of Tunbridge Wells noting: * The absence of any carried forward safeguarded land within the District, and need set out within national planning policy to ensure that Green Belt boundaries set out in a Local Plan endure beyond the end of the plan period [6 See Paragraph 136 of the 2019 NPPF.]; * The proportion of the District located within the High Weald Area of Outstanding Natural Beauty amounts to 70% (overlapping with Green Belt in some areas). This designation significantly restricts the delivery of major development in a large part of the District with a requirement to meet the tests of Paragraph 172 of the NPPF for any major development proposal brought forward in the area; and * The Plan contains several large-scale strategic sites which are identified to contribute significantly in response to residual housing needs in this plan period (circa 5,000 dwellings). If assumed timescales and delivery rates are not achieved at these sites, the Local Plan will quickly fail based on the current supply position. [TWBC: see full representation]. [TWBC: see also Comment Nos. DLP_6656-6695] | ||||||||||||||||
DLP_6788 | G M Whitehead | Object | Policy Number: STR1 ‘Sustainable development of an appropriate scale at the smaller settlements to provide opportunities at the local level to meet housing needs and sustain local services and infrastructure, as well as the support for new local facilities where required, and at all times being aware that such development is taking place on valued and (in many cases) protected landscapes.’ Just how appropriate is the development soon to be foisted on Cranbrook? 5. New Healthcare Centre – When? Where? What other local services for 761 new houses in Cranbrook and 108 in Sissinghurst? | ||||||||||||||||
DLP_6797 | Kember Loudon Williams for Wedgewood (New Homes) Ltd | General Observation | This submission is made in response to the Tunbridge Wells Borough Council’s (TWBC) Consultation Draft Local Plan (Regulation 18). It is made by Kember Loudon Williams on behalf of Wedgewood (New Homes) Limited. A separate, fully detailed Supporting Statement has been prepared to accompany these representations (See Chapter 3 of the Statement), which supports Horsmonden as a suitable and sustainable location for a modest amount of additional housing to that which is currently proposed to be allocated, particularly given the stated importance elsewhere in the draft Plan (including at paras. 4.38 and 4.40) of only considering development within AONB areas ‘having first maximised potential outside the AONB’. Horsmonden is one of the larger villages in the Borough and unlike the great majority of villages in the Borough sits outside the AONB, and is unencumbered by Green Belt designation. Submissions in the KLW report demonstrate that the settlement is perfectly capable of accommodating a further 35 homes, which is a modest 11 per cent uplift in the number currently proposed to be allocated to the Settlement in the first Draft Local Plan. We propose to increase the current housing allocation given to Horsmonden Parish by 35 residential units. This can be accommodated on land South of Goudhurst Road, Horsmonden. This will not require amendment to STR1 itself, but will require amendment to Table 3 which is referred to in STR1 – see comment box 6 below. [TWBC: see Supporting Statement and Comment Numbers DLP_6793, 6797-6799, 6801, 6803-6804] | ||||||||||||||||
DLP_6875 | Rosemary Cory | Object | Policy Number: STR 1 The Plan does not seem to follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The quick and easy option pursued by the Council involves identifying land which owners are prepared to offer for development regardless of the impact on the landscape, sustainability or local communities. This is despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents. I believe that the Council’s conclusion (for example, at Paragraph 4.34) that the sites identified for mass housing estates are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects: 1. It treats each proposed development in isolation from all the others and ignores the consequences, for sustainability and infrastructure, of their combined effects. Thus, the proposed major developments in the neighbouring settlements of Cranbrook & Sissinghurst, Sandhurst and Hawkhurst (total 1,676 houses) will, together, impact upon the local infrastructure in a way which has simply not been taken into account in the draft plan; 2. It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point. Hawkhurst The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course. The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village. The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan. There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development. Note, also, that Natural England have stated that they will ask the Secretary of State to “call in” any such application which is approved by the Council. Non-compliance with Hawkhurst Neighbourhood Development Plan Lack of adequate infrastructure The proposed development would impact unacceptably on an AONB Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. There are very limited local employment opportunities and no secondary schools within walking distance. The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution. The village is already a congestion black spot and subject to unacceptable levels of pollution – results of formal pollution monitoring in the village will be available shortly. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it. TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103). The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate. The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF. There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF. The “relief road” will not work As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes. | ||||||||||||||||
DLP_6947 | Hallam Land Management Ltd | Table Number: STR 1 | |||||||||||||||||
DLP_7090 | Brown & Co Planning Ltd for The Hendy Group | General Observation | COMMENTS ON THE STRATEGIC OBJECTIVES (SECTION 4) Policy STR 1 - The Development Strategy; General Observation 1.125 Policy STR 1 states that ‘Where major development is provided for at specific identified sites in the AONB, this is only where the tests set out in the NPPF are met’. 1.126 Our Client would like to highlight that through the allocation of a site in the AONB, the Council is recognising that the site is suitable for development. 1.127 In order to ensure that allocations are brought forward in line with the Local Plan, allocated sites should not have to go through the process of demonstrating that the proposal will make a positive contribution toward achieving the AONB Management Plan objectives as the site has already been assessed against national policy tests (see comments on EN 21 above). 1.128 To ensure that these areas can be effectively protected whilst still ensuring that the Council meet their growth targets it is essential that full and proper use is made of all other potential locations for growth. The identification of Site Allocations RTW 8 and PE 7 support this policy objective and the Council are urged to ensure that maximum productive use is made of these sites. [TWBC: see full representation and supporting documents; Park and Ride Feasibility Review and Site Location Plan]. | ||||||||||||||||
DLP_7158 | Kay Margaret Goodsell | Object | Policy STR 1 The Development Strategy Tunbridge Wells should get the housing, not small villages. And why have you chosen Sissinghurst to get so many, this is unequal treatment. | ||||||||||||||||
DLP_7187 | Sue Nuttall | Object | The “Local Plan” is a complete nightmare, demonstrating a total lack of concern for the environment, local people, the green belt, transportation, education and health. Build first infrastructure later does not work and inflicts misery on residents. It does not take into account the already over stretched and underfunded schools, GP surgeries or the hospitals. The lack of water with threats of water rationing to come. The sewerage system is at breaking point and many proposed new homes are to be built on flood plains. The wrong type of houses are being proposed, too expensive for first time buyers and not meeting the needs of those who wish to down size which in itself would free up family homes. The needs of local people are just ignored. Lack of consultation between authorities means that villages such as Capel will not only be destroyed by Tunbridge Wells proposed housing but may also be over run by Maidstone proposals. Structures such as the Hendy City development proposed on the Pembury Road is completely misplaced and again shows lack of concern for Tunbridge Wells and its residents. The economy of Tunbridge Wells will be severely effected as people will no longer wish to go there as the traffic problems means more people are seeking alternative places to travel to. The trains are already over crowded and expensive with no hope of improvement. I could go on but expect it will not be read and I will be repeating others remarks. Please reconsider and draw up decent plans for the sake of residents and the environment. | ||||||||||||||||
DLP_7302 | Kylie Brudenall | I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents. I believe that the Council’s conclusion (for example, at Paragraph 4.34) that the sites identified for mass housing estates are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:
[TWBC: see also Comment Number DLP_5110 - Policy STR/HA 1]. | |||||||||||||||||
DLP_7327 | Campaign to Protect Hawkhurst Village | Object | STR1 sets out the Council’s overarching Development Strategy. First, the Council has given no consideration to whether the Borough is capable of providing for it OAN housing requirements. The NPPF (paragraph 11b) specifically sets out circumstances where this is an acceptable approach. Given the key environmental and landscape constraints within the Borough this option should have been given proper consideration. This is the approach taken by Sevenoaks District Council which suffers from similar environmental constraints. Secondly, the Council has chosen to allocate sites to provide a 9% overprovision of housing. The Council proposes to release land providing over 1000 dwellings that are not required to meet the OAN. Thirdly the Council has failed to adequately assess the comparative benefits and disadvantages of different growth options. By way of one example, Option 4 for Paddock Wood proposed an additional 6000 units as part of the town extension. This was discounted and the DLP proposes the 5000 unit option. Nowhere in the SA or anywhere else in the application is there any comparative analysis of the maximum growth option at Paddock Wood against the release of land of the AONB at Hawkhurst and elsewhere. By way of one example if the maximum option had been pursued at Paddock Wood there would be no need to release any greenfield land in the AONB at Hawkhurst. One consequence of these decisions is that it will entirely unnecessarily result in the loss of a considerable amount of greenfield land within the AONB. This places the Council directly in contravention of its statutory duty to preserve and enhance the AONB and national policy providing that AONB should be given the highest degree of protection. In turn by unnecessarily releasing sites away from employment and key services in the rural eastern part of the borough with poor public transport provision, the Council will cause significant additional traffic on the local highway network resulting in detrimental impacts regarding air quality, noise and climate change in particular. This specific impact has not been considered or comparatively assessed in the Sustainability Appraisal. Paragraph 4 of STR1 refers to significant infrastructure improvements in the form of a relief road providing significant improvements to the crossroads in the centre of the village. This draft policy has been prepared on the assumption that the relief road will provide significant improvements. There is no evidence whatsoever in the supporting topic papers and reports to substantiate this assertion. It has not been considered in the specific TWBC Local Plan Transport Evidence Base prepared by SWECO. The Council will appreciate that the proposed relief road is comprised within a current Planning Application for the Golf Course site. The Transport Assessment submitted with the application illustrates that the relief road will in no way provide “significant improvements’ to the village crossroads as asserted in the draft policy. In many ways it will make the current situation materially worse. By way of but two points, it will result in a direct 98% increase in traffic along the High Street (in comparison to a situation where the relief road is not provided) and it is predicted that queue lengths along the High Street will quadruple – these are on the applicant’s own figures. Finally, the policy fails to reflect or consider the impact on the Flimwell crossroads and the consequential hugely detrimental impact on the A21 and Strategic Road Network – notwithstanding the reference to contributions towards mitigation works in paragraph 6 of policy STR/HA1. | ||||||||||||||||
DLP_7347 | Andrew Winser | Object | I wish to object to the strategy being adopted by TWBC as stated in their overall draft policy STR1 which looks to adopt Option 3 (dispersed growth) as well as others. A significant issue with dispersing the growth which TWBC is seeking to establish lies in the rural infrastructure. I note that the TWBC current Transport Plan is based on 57 new homes in villages – whilst it is stated that this plan is to be updated there is a very large difference between 57 new homes in the villages of the TWBC area and even just the up to 305 dwellings being considered for Horsmonden. The draft policy should be reconsidered on the basis of a more coherent Transport plan. STR1 is disconnected from the development hierarchy in the Issues and Options document page 13 where four tiers of settlements are identified with Rural Settlements at teir 3 – although not all those Rural Settlements are being considered equally with some such as Horsmonden being allocated much higher growth levels. | ||||||||||||||||
DLP_7420 | Neill Scott | Object | We writing to you to register our concerns and objections to the following:
Planning Strategy
Conclusions The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan. Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments. The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB. We trust that these comments will be taken into account. | ||||||||||||||||
DLP_7511 | Sarah Parrish | Object | Why are existing, idle, Brown Field Sites not compulsorily purchased as a priority? And Empty Properties too? | ||||||||||||||||
DLP_7499 | Mr and Mrs A J Herbert | Object | The Draft Local Plan fails to preserve the character of the AONB (which accounts for about 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from development. The Draft Local Plan also fails to reference and draw on the recent recommendations from the DoE’s review of the management of AONB’s. (Glover Review) Specifically in relation to Hawkhurst. The proposed development on the Hawkhurst Golf Club site would severely damage the character of an important Wealden village. It would be one of the largest developments imposed on an AONB and would increase the population of the village by about 20%. The resulting burden would overwhelm local services, which are already under pressure from unplanned development. There is considerable local opposition to the golf club development as evidenced by the number of objections submitted in response to the recent application for outline planning approval. Posters saying “No” to such a development are in evidence throughout the area. The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of this size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment. Hawkhurst has already seen a considerable amount of development and the infrastructure and services will not cope. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament. The proposed golf club development would impact unacceptably on the AONB. The CPRE and the High Weald AONB Unit have stated that the proposed golf course development would be inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues - and that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019. The proposed development on the golf course would result in the destruction of large numbers of mature trees. The Woodland Trust has objected to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland. The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment. Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore add to the volume of traffic on local and regional roads. When commuting on the A21 there are already serious delays and traffic jams in the morning and evening rush hours. The proposed “relief road” would not provide the benefits which have been claimed for it and is really just an access road to enable the development. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course would severely impact on traffic flows through the village and the surrounding area. | ||||||||||||||||
DLP_7589 | Victoria Dare | Object | I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents. I believe that the Council’s conclusion (for example, at Paragraph 4.34) that the sites identified for mass housing estates are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:
Hawkhurst The remaining comments on this policy relate to the proposed mass developments at Hawkhurst, and in particular the proposal to allow the building of over 400 houses on the present Golf Course. The village of Hawkhurst lies entirely within the Wealden AONB. All of the observations in relation to preserving the character of AONBs therefore apply with added force to proposed developments in the village. The proposed development on the Hawkhurst Golf Club site would destroy the character of this important Wealden village. It would constitute one of the largest ever developments imposed on an AONB and would increase the population of the village by 20% at a stroke. The resulting burden would clearly overwhelm local services, which are already under severe pressure from substantial unplanned development in recent years. The implications for the village and the local area of a new mass development (and of neighbouring mass developments) have simply not been properly considered in the Draft Local Plan. There is considerable local opposition as evidenced by the number of objections submitted in response to the recent application for outline planning approval for the proposed golf course development. Posters saying “No” to such a development are in evidence throughout the area. It would be undemocratic and oppressive to ignore overwhelming local opposition to such a development. Non-compliance with Hawkhurst Neighbourhood Development Plan The proposed development is not compliant with Hawkhurst’s Neighbourhood Development Plan and there are no exceptional circumstances to justify this development. There is no local need for a development of such a size in Hawkhurst. The village has exceeded its housing quota set out in previous local plans and it would not be possible to mitigate effectively the adverse consequences on the landscape and the local environment. Lack of adequate infrastructure Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament. The proposed development would impact unacceptably on an AONB The CPRE and the High Weald AONB Unit have previously argued that the proposed golf course development would be entirely inappropriate for an Area of Outstanding Natural Beauty. Paragraph 172 of the NPPF indicates that great weight should be given to enhancing and conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection in these issues. And that the scale and extent of development within these designated areas should be limited. The Draft Local Plan fails to show how the proposed development would meet the objectives of the High Weald AONB Management Plan adopted in March 2019. The proposed development would not constitute sustainable development The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment. Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. There are very limited local employment opportunities and no secondary schools within walking distance. The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution. The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it. TWBC has recently declared a climate emergency. In this context, there is no justification for a development of this size in a location so poorly served by public transport. The future occupants of the proposed development would be reliant on their cars for work, shopping and recreation. This is contrary to the NPPF which requires that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion, emissions, and improve air quality and public health (paragraph 103). The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate. The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF. There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF. The “relief road” will not work The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny. As Hawkhurst lies close to County and District Council boundaries, the adverse impact would extend beyond the boundaries of TWBC into Rother DC, and beyond KCC into East Sussex CC. These considerations do not appear to have been taken into account in the Draft Local Plan. The surrounding Wealden areas would also be directly affected by the increased traffic flow along local rural lanes. | ||||||||||||||||
DLP_6003 | Laura Rowland | Object | Paragraph 4.69 The NDP steering group found that parishioners do not want large scale developments. It is only unless there is exceptional need for this that large scale developments should be built on AONB. This is not the case in the Parish of Cranbrook and Sissinghurst. | ||||||||||||||||
DLP_4398 | Mill Land and Cramptons Residents Association | Object | Paragraphs 4.39 and 4.59 NON SUSTAINABLE DEVELOPMENT Too much of the growth in housing is being targeted at small towns and villages like Cranbrook, Sissinghurst and Hawkhurst. This is not sustainable in transport terms under the NPPF, as people will need to commute to larger towns for employment and other activities. As buses are limited and expensive, this means inevitably more travelling by car on already clogged roads. Growth should be concentrated in larger towns. The small hub of economic activity proposed for Hawkhurst is not likely to meet the employment needs of many existing or new residents, who would have to use their cars to access it in any case. The housing targets proposed for rural areas under this Plan are NOT based on local needs, which could be integrated but exceed it substantially, as discussed under 4 4.7. | ||||||||||||||||
DLP_8317 | Pam Wileman | Object | TWBC: Comment was submitted on 19/11/19 after close of consultation (on 15/11/19). I understand that the Plan does not properly follow the provisions in the National Planning Policy Framework (2019). NPPF paragraph 11(b)(i) provides that strategic policies should take account of the need to protect “areas … of particular importance” and that this includes AONBs. Not only does the Plan fail to address this requirement, which should result in a reduction in the Standard Housing Formula housing figures for the Borough as a whole (as most of the Borough comprises AONB land), but it actually proposes to increase building plans by an additional 900 houses Borough-wide. The Draft Local Plan reveals that TWBC prefers to meet this artificially inflated housing target primarily by approving large-scale developments in Wealden towns and villages. The Council has gone for the quick and easy option by identifying land which owners are prepared to offer and which developers are interested in developing. This despite the fact that only 8% of respondents supported the “Distribution Development Policy” underpinning the Plan. Nowhere in the Plan is any real consideration given to the consequences of such developments for the towns and villages concerned and for the AONB. If it implemented this Draft Local Plan, the Council would be failing in its duty to preserve the character of the AONB within its charge (which, according to the Draft Local Plan accounts for 70% of the borough). The Plan appears largely to ignore the provisions in the National Planning Policy Framework designed to protect Areas of Outstanding Natural Beauty from ruinous development. Indeed, it is hard to believe that the Council has any appreciation of its responsibilities towards the preservation of the AONB environment, or the welfare of its residents. I believe that the Council’s conclusion (for example, at Paragraph 4.34) that such sites are “suitable for development” prejudge issues which properly fall to be considered during the planning approval process, and that this is improper. The Council’s claim (paragraph 4.36) that there is a level of agreement with Parish Councils on development sites is, I believe, false. The recent experience in Hawkhurst is that TWBC take little notice of the views and concerns of the Parish Council (for example, the Council’s behaviour over the Neighbourhood Development Plan and recent planning decisions taken in the face of legitimate local objections). I understand that Hawkhurst Parish Council in no way supports the development proposed in the Draft Local Plan. I do not see how the Council can justify the statement in paragraph 4.35 that it has encouraged the production of Neighbourhood Plans, given that the Council has failed to adopt, and to recognise, the Hawkhurst Neighbourhood Development Plan submitted in March 2019, and has regularly failed to take account of the previous Neighbourhood Development Plan in reaching its planning decisions. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. Although the table at paragraph 4.12 refers to housing already completed across the borough, and counts it against the borough-wide allocation, it takes no account of the impact of levels of development recently permitted in individual Wealden villages such as Hawkhurst. A rash of speculative development, approved by TWBC, usually in the face of local opposition and in contravention of the Neighbourhood Development Plan, has already seen the village grow by a significant percentage in recent years, overwhelming the capacity of local services to cope with such an expansion. We are not, as the Plan implies (and as Table 3 on page 46 might be taken to indicate), starting at zero base where consideration of development impact is concerned. The village has already been seriously impacted. The Draft Local Plan has, therefore, not taken proper account of the impact of recent housing development on the villages affected by the new proposals for mass housing developments. Paragraph 4.40 claims that the growth strategy is based on the premise of infrastructure-led development. This is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. For example, the provision of sewage services by Southern Water was the subject of an adjournment debate in Parliament on 28 October in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. It seems likely, therefore, given recent experience in Hawkhurst, that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. The development strategy outlined from paragraph 4.41 onwards is seriously flawed in two respects:
It fails to take account of the effects of developments in neighbouring local authorities (in particular, East Sussex) and of the effects of the developments proposed in the Tunbridge Wells plan on infrastructure services in neighbouring boroughs. Hawkhurst (Tunbridge Wells) and Flimwell (Rother) provide a case in point. | ||||||||||||||||
DLP_8336 | Joe Matthews | Object | TWBC: correspondent submitted the following comments on 20/11/19, after the close of consultation on 15/11/19: A prestigious new business park will be located to the north of North Farm/Kingstanding Way that is well connected to the improved A21, providing a range of employment floorspace and jobs to meet identified needs. The site will make a substantial contribution to the need for new employment space over the plan period. Other employment, including leisure development, will be encouraged at North Farm/Kingstanding Way; If the ENS has identified the above areas for development, this is surely where many new residents of the Parish of Cranbrook and Sissinghurst will be travelling to work, (14 miles away) entirely unsupported by appropriate infrastructure I object to placing so much development in Ctranbrook and Sissinghurst when employment is targeted so far away |
Table 3 Scale and Distribution of Development
Comment No. | Name/Organisation | Response | ||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
DLP_7931 | Wendy Owen | We challenge the need for such a large number of new dwellings in the Borough. Office for National Statistics data predicts the population of Tunbridge Wells will grow from 117,140 in 2016 to 131,092 in 2036 (the planning period). TWBC reports that housing stock in 2016 was 49,880. If the occupancy rate of dwellings remains at the 2016 level (i.e. 2.35 people per dwelling) then the need by 2036 will be a further 5,937 dwellings to the stock. Even if one were to allow for a decrease in the occupancy rate to two people per dwelling, the need would still be lower than 7,000, i.e. less than half of the number of dwellings the plan allows for. The Housing Supply and Trajectory Topic paper (September 2019) reports “Between 1st April 2016 and 31st March 2019, 1,552 dwellings were completed and, as of 31st March 2019, 3,127 dwellings have extant planning permission.” This leaves a need of 1,258 (@ 2.35 occupancy) to 2,297 (@ 2 occupancy) new dwellings between now and 2036. | ||||||||||||||
DLP_164 | Ms Jacqueline Stanton | Scale and Distribution The volume of new housing for Horsmonden equates to more than 25% which is unreasonable. | ||||||||||||||
DLP_48 | Thomas Weinberg | Comments on Table 3 (Scale and Distribution of Development) p.43 Repeated use of the phrase “To be determined as part of masterplanning” in reference to Paddock Wood, Capel and Tudeley is ridiculous when it refers to 63% of the houses in this Local Plan. | ||||||||||||||
DLP_91 | Roger Bishop | Table 3 (Scale and Distribution of Development) p43 Use of the phrase “To be determined as part of masterplanning” in reference to Paddock Wood, Capel and Tudeley is concerning, since this means that consultation relating to 63% of the planned houses is based on an incomplete Local Plan. [TWBC: see also Comment Numbers DLP_81 to 93]. | ||||||||||||||
DLP_130 | Gregg Newman | Comments on Table 3 (Scale and Distribution of Development) p.43 Repeated use of the phrase “To be determined as part of masterplanning” in reference to Paddock Wood, Capel and Tudeley is again an abrogation of your duties. This is frankly a cop out and says you do not know the answers, hence you are not prepared to put them in front of residents to be able properly to evaluate. | ||||||||||||||
DLP_7840 | Andrew Chandler | Table Number: 3 How can it be appropriate for rural Cranbrook and Sissinghurst parish (c. 2,781 households in 2017, according to the electoral register) to have to take an average allocation of nearly 900 new dwellings i.e. households (on top of many more imposed in the last couple of years due to the non-compliant TWBC local plan), when urban Tunbridge Wells (c. 22,094 households in 2017) will only take an average allocation of 1,271 new dwellings/households and urban Southborough (c. 5,037 households in 2017) will only take an average allocation of 170 new dwellings/households? Why would you not continue your policy of concentrating development in urban and commuter areas, with employment opportunities, transport and no dramatic change to the character of the area? This is makes so much more sense that the proposals for rural Cranbrook & Sissinghurst. Even within Cranbrook and Sissinghurst, how can it be appropriate to treat Cranbrook (rated top in your 2017 Settlement Role and Function Study) and Sissinghurst (rated near bottom, with only four settlements scoring lower) in the same way? Sissinghurst is a small, world-famous rural village that attracts vast numbers of tourists to the area, but will be hugely and disproportionately adversely affected by the proposed development without any justification being advanced. The fact that lots of developers have proposed development here while TWBC had a non-compliant plan, due to your failure to appeal the Planning Inspector’s decision in the Gladman application for 60 houses on Common Road, should not be the justification. I submit that if you intend to proceed with the proposed allocations in Cranbrook and Sissinghurst - and in Sissinghurst in particular - you need to actually articulate why this is the right choice, particularly when the Sustainability Appraisal notes (even before any adjustment for comments received) that the impacts are “mixed” (i.e. not positive). This is even more so for Sissinghurst considered in isolation. I submit that is particularly important to minimise further development in Sissinghurst, as what is proposed is very clearly urban sprawl in a rural settlement with very limited amenities, very limited transport and no prospect of local employment and coalescence with the neighbouring settlement of Wilsely Pound. | ||||||||||||||
DLP_335 | Residents Against Ramslye Development | [TWBC: comments made by petition signed by 669 local residents. Please note the names on the petition are in the process of being scanned and personal details redacted. They will be uploaded as a supporting document in due course. See also Comment Number DLP_339 (Policy AL/RTW 18: Land to the west of Eridge Road at Spratsbrook Farm]. We challenge the need for such a large number of new dwellings in the Borough. Office for National Statistics data predicts the population of Tunbridge Wells will grow from 117,140 in 2016 to 131,092 in 2036 (the planning period). TWBC reports that housing stock in 2016 was 49,880. If the occupancy rate of dwellings remains at the 2016 level (i.e. 2.35 people per dwelling) then the need by 2036 will be a further 5,937 dwellings to the stock. Even if one were to allow for a decrease in the occupancy rate to two people per dwelling, the need would still be lower than 7,000, i.e. less than half of the number of dwellings the plan allows for. The Housing Supply and Trajectory Topic paper (September 2019) reports “Between 1st April 2016 and 31st March 2019, 1,552 dwellings were completed and, as of 31st March 2019, 3,127 dwellings have extant planning permission.” This leaves a need of 1,258 (@ 2.35 occupancy) to 2,297 (@ 2 occupancy) new dwellings between now and 2036. While we appreciate the housing requirement is set by national policy, we do not consider TWBC has appropriately represented the interests of its residents. By accepting the allocation, it has not acted to protect the rural nature and the associated landscape of the borough that is valued by its residents and is protected under law. The approach to date has been supine and cavalier with our environment and interests. TWBC must take steps to challenge the allocation on our behalf so as to protect our interests. | ||||||||||||||
DLP_355 | Yvonne Savage | I challenge the need for so many houses to be built over the plan period of 2016-2036. The Office for National Statistics estimates borough population growth of 13,952 people, and with an average house occupancy rate of 2.35 people (117,140 people living in 49,880 houses), the need is for 5,937 houses (of varying sizes). TWBC must challenge the government on the number genuinely needed in the borough. | ||||||||||||||
DLP_7971 | Sharon Pickles | TWBC: the standard response was submitted by the list of responders on the left: To say that employment will be created during the construction phase is to mislead the long term employment effect of developments | ||||||||||||||
DLP_8059 | Sophie Foster | TWBC: the standard response was submitted by the list of responders on the left:The Housing Allocations to Cranbrook & Sissinghurst, and to Hawkhurst, are hugely in excess of local needs. The maximum allocation to Cranbrook & Sissinghurst is 918 dwellings against a population of 6,700, which is 13.7%. For Hawkhurst the allocation is 731 dwellings against a population of 4,991, which is 14.6%. This compares with the allocation to Royal Tunbridge Wells which generates the vast majority of the housing need: 1,320 dwellings against a population of 48,324,which is only 2.7%. | ||||||||||||||
DLP_8280 | Ann Gibson | Table 3 Scale and Distribution of Development Indicates that there will be limited increase of employment through “mixed use place shaping policies” in Cranbrook and NO increase employment in Sissinghurst despite the intention to allocate 100-115 houses there. | ||||||||||||||
DLP_8342 | Joe Matthews | TWBC: correspondent submitted the following comments on 20/11/19, after the close of consultation on 15/11/19: indicates that there will be limited increase of employment through ‘mixed use place shaping policies’ in Cranbrook and NO increase in employment in Sissinghurst despite the intention to Allocate 718 – 803 houses in Cranbrook and 100 – 115 houses in Sissinghurst | ||||||||||||||
DLP_857 | Ian Pattenden | Repeated use of the phrase “To be determined as part of masterplanning” in reference to Paddock Wood, Capel and Tudeley is ridiculous when it refers to 63% of the houses in this Local Plan. You are asking us as residents of Capel parish to consult on a largely incomplete draft; conversely other regions in the Borough have more detailed Local Plans. This is another indication that Tudeley and East Capel proposed developments were a last-minute easy option presented by one very willing land owner that was snatched at by TWBC officers. The original landowner’s proposal has not been made public, despite Freedom of Information requests, which raises concerns that process may have been manipulated to accommodate the proposal and due process swept aside. The draft plan as presented is incomplete and not fit for consultation. | ||||||||||||||
DLP_1518 | Broadlands Planning Ltd for Kent Woodware Company Ltd | Policy Number: | ||||||||||||||
DLP_1971 | Mr Jeremy Waters | Since a large proportion of the proposed new housing is centred on Paddock Wood where there are excellent rail and road connections, I would have thought that it would be possible to increase the allocation by another 500 houses to take the pressure off the villages around and let them continue to develop organically as has been the case in the past. Villages like Horsmonden would be substantially affected by adding another 225-305 dwellings representing a growth of 28%, when compared with Paddock Wood where 4,000 new houses are to be built but the infrastructure can be upscaled. 4,000 or 4,250 houses hardly makes a difference to Paddock Wood. | ||||||||||||||
DLP_2010 | Dr David Parrish | Table 3 (Scale and Distribution of Development) p.43 There no details provided (or researched) This shows there is no complete planning – leaving the concept to be determined in the “Master-planning” stage – which the land Owner – Hadlow Estate – wishes to control – despite not being an experienced land planner or developer. 63% of the Local Plan is Unplanned! | ||||||||||||||
DLP_1091 | Mr John Hurst | Scale and Distribution of Development Same comments as made for STR1, viz: The numbers of dwellings proposed is excessive, and based on outdated methodology. Notwithstanding that it is a Government edict, it must be challenged. 1. The timeline that gave rise to this is as follows: - Government made a political statement that 300k houses are needed nationally - Government required the ONS' "2014" methodology for calculating housing need be used (NB this results in about 240k houses nationally) 2. Impact of using updated ONS methodology - ONS produced a revised "2016" methodology, which in the case of Tunbridge Wells would require only 67% of the 2024" figure, according to consultants Barton Willmore, see The nett new dwellings to be added are shown in the DLP in Table 1 in section 4:12, on page 35. If the 67% factor is applied to line 1., the resulting nett new dwellings in line 6 goes down from 7,593 to 3,115, ie to much less than half. This, together with additional brownfield developments first (see comments to Policy STR4) could obviate the need for use of Green Belt land. Hence the importance of challenging the numbers basis. | ||||||||||||||
DLP_1713 | Mr Paul Spedding | POLICY STR1 Table 3 I believe that the numbers proposed are arbitary. They are based on out of date government housing numbers (2014) that have been superceded. There is also an arbitrary 40% premium added. The allocation of sites seems based on the availability of sites with single owners (eg the Teachers estate). TWBC has chosen easy options focusing primarily on delivering a number. Key issues - such as AONB status, sustainablity and deliverability of infrastucture of all types (road, rail, parking, health and education) - have been given secondary status. The allocation to villages and hamlets in rural areas without reliable, regular public transport cannot be regarded as sustainable. Even in those areas with frequent public transport options (Paddock Wood for example), there appears little planning for expanding the rail network for example. The Tudely Garden village seems unlikely to gain a new station. This means that there will be more road traffic. Much of this is likely to be private vehicles using roads which already see stationary traffic during rush hours. Additional bus services might move more people but will only add to congestion. Given the time it took to plan/build the A21 dualling project, any infrastructure project is likely to lag housing increases by decades. | ||||||||||||||
DLP_2234 | Tracy Belton | Table 3 The distributions of dwellings does not seem consistent with the services/facilities available in the villages. Horsmonden appears to be allocated many more houses than surounding villages put together. If green belt land doesn't matter, why does it matter if a village is within the AONB as to how many dwellings a village has been allocated? Surely a fairer allocation should be given to all villages? I don't see how this number of dwellings can be supported and how this will make it a better place to live. Local communities will be ruined. | ||||||||||||||
DLP_2352 | Sarah Coulstock | There is too much development in the Local Plan for a rural area with much of it in AONB – TWBC should challenge the housing target it has been given in view of this & get it reduced. The number of new dwellings proposed for the parish of Brenchley & Matfield is too high. All of proposed development is in Matfield – Brenchley should share the burden & take at least half, especially as has a school, 2 shops, a post office, a doctor’s surgery & a dentist. The Limits to Build Development should not be changed; it should be strengthened to prevent or severely restrict any more intrusive inappropriate development within the Parish. The dark skies, wildlife, landscape & rural character need to protected against the destruction of the surrounding countryside & the detrimental impact on the High Weald AONB. The amount of development suggested in the AONB is contrary to the objectives of the High Weald AONB Management Plan & the TWBC’s statutory duty to conserve & enhance the High Weald AONB. The proposed extra housing would put additional pressure on already stretched infrastructure & services, both within the parish of Brenchley & Matfield, & in the borough. I understood that TWBC had previously favoured focused growth in sustainable locations, however, the Local Plan is for dispersed growth in places with poor infrastructure & facilities, which are therefore not sustainable. The proportional development distribution proposed in the Local Plan is unfairly distributed, with some areas expected to suffer a higher volume of development than is appropriate. | ||||||||||||||
DLP_2605 | Sue Sands | The distribution of the allocation of dwellings is not even amoungst the villages. Horsmonden is not a large village and yet it has been allocated more dwellings than it's neighbouring villages put together! The distribution should be more even. Many villages, including Horsmonden, would benefit from having accommodation suitable for the elderly. This would give the opportunity for downsizing and would then free up family homes elsewhere in the village. Private car use is generally less amoungst the elderly and so building this type of dwelling would help with the overall environmental impact. It has been said that there are many empty propeties in the borough. Surely it would be of greater benefit to make use of these rather than building on green belt/green field land? If landlords simply hold properties as investments, but are not putting them to use, then they should be made to put them to use. It is a nonsense to have empty propeties if they are needed. Any properties that are built should be for people who are from the area/village/town first. This is what affordable housing should be about - providing places for the next generation to be able to afford and in the villages/towns they grew up in as opposed to bringing in outsiders who do not understand how the local communities work. | ||||||||||||||
DLP_3723 | Capel Parish Council | TWBC: the standard response was submitted by the list of responders on the left: | ||||||||||||||
DLP_4326 | Environment Agency | Scale and distribution of development table (page 44) | ||||||||||||||
DLP_4262 | RTW Civic Society | We question the need for an extra 30,000 sqm of A1 retail (comparison) and up to 7,500 retail (convenience), at least until the present difficulties in the high street are resolved. We would welcome policies to deal with the current level of retail vacancies. | ||||||||||||||
DLP_2719 | St. John's Road Residents association | See comments in Sections 4, 5 and 6. | ||||||||||||||
DLP_2834 | Helen Parrish | There no details provided (or researched) 63% of the Local Plan is Unplanned! | ||||||||||||||
DLP_3157 | Nigel Bell | Table Number: Table 3 Scale and Distribution of Development Plan does not anticipate significant increase in employment opportunities being created in Cranbrook [limited increase through mixed use place shaping policies]. Hence, there appears to be no case for increasing housing in Cranbrook by 718-803 units based on local demand- this will invariably mean that those dwellings are bought by people working outside the borough. For example, London commuters. I object to development for this purpose. | ||||||||||||||
DLP_4388 | Mill Lane and Cramptons Residents Association | Cranbrook & Sissinghurst: The housing allocation for Sissinghurst is excessive for this small village which has had a total of some 69 new houses (Common Road and Church Mews) built recently - and up to another 9 already planned in Cobnut Close. | ||||||||||||||
DLP_4605 | Keith Stockman | Table 3 Scale and Distribution of Development | ||||||||||||||
DLP_4649 | Ann & John Furminger | There is no evidence of long term employment opportunities being created in the Cranbrook and Sissinghurst parish | ||||||||||||||
DLP_7072 | Sigma Planning Services for Rydon Homes Ltd | 5. The reference to flood mitigation for Five Oak Green as part of the infrastructure requirement for the remainder of Capel Parish is confusing because it is not related to any housing, retail or employment development. It is unclear why there is any reference to it in a table that relates to the scale and distribution of development. [TWBC: See full representation]. | ||||||||||||||
DLP_6261 | Kember Loudon Williams for Mr R Barnes | Table Number: 3 (Scale and Distribution of Development) These representations are seeking to allocate an additional site (Stone Court Farm) at Pembury for 50 residential units. Table 3 should therefore be altered to reflect this additional growth and the table should now be seeking 350 units in Pembury over the plan period (i.e. up until 2036). | ||||||||||||||
DLP_7012 | Kember Loudon Williams for Mr and Mrs John & Sarah Garthwaite | Policy STR/BM1 and Table 3 on page 43 Whilst it is acknowledged that criterion 1 of this strategic policy for Brenchley and Matfield identifies a range of housing for delivery over 4 allocated sites, this criterion should not be set as a limit or a narrow band. If proposals come forward which include a suitable mix and at a suitable density to reflect the character of the area then it may be possible to accept more than the 150 upper limit. The National Planning Policy Framework notes that the Government’s objective is to ‘significantly boost the supply of homes’. Paragraph 60 of NPPF references housing need in the context of the “minimum number of homes needed” having regard to a housing needs study. Criterion 1 of Policy STR/BM 1 does not accord with this advice as currently drafted. Criterion 1 requires a narrow band with an upper threshold of new dwellings. It should be reworded to express a minimum number of homes with no upper threshold. The other objection to this criterion is more practical. If 2 or 3 sites come forward early in the process and they are able to deliver near the upper end of the threshold, then it means that the final site would have to be artificially kept at a low density in order to comply with criterion 1. This could produce a development that is out of character with the area and contrary to Section 11 of the NPPF which seeks to make effective use of land. Finally, we are aware that the Council is relying on two very large sites at Capel and Paddock Wood to deliver the bulk of their new homes. Delivering housing of this scale into a geographically constrained local market is not easy and will take a long time. The Council will find a gap in its housing trajectory which smaller sites will need to fill. The Housing White Paper emphasised the point that smaller sites offer choice and can be brought forward quicker. By making the policy express the ‘minimum’ it will be possible to ensure the efficient use of allocated land. | ||||||||||||||
DLP_6059 | Kember Loudon Williams for Cranbrook School | A separate report has been prepared to accompany these representations (See Chapter 3), which supports Cranbrook town as a suitable and sustainable location for a modest amount of additional housing to that which is currently allocated. We propose to increase the current housing allocation given to the Cranbrook and Sissinghurst Parish by 60 residential units (an additional 10 units at Big Side Playing Fields and an additional 40-50 units at Rammell Field). [TWBC: see full supporting statement. Chapter 3 is copied below]: 3 Strategic Growth Relevant Policies: STR1, STR/CRS 1 and Key diagram 4. Housing 3.1 Policy STR1 of the Tunbridge Wells Borough Council Local Plan Regulation 18 Consultation details the development strategy for the Borough. Part 5 of the Policy lists the Parish of Cranbrook and Sissinghurst as being suitable for further housing development and table 3 lists the proposed allocations for housing as a maximum of 803. 3.2 For the reasons set out in Chapters 6 & 7 (Big Side and Rammell Field), we consider there is the potential to increase the total housing allocations in Cranbrook in the region of 50-60 more dwellings. The first opportunity is to extend the proposed housing allocation at Big Side Playing Field to the north of the town by 10 dwellings in order to accommodate up to 25 units; and the second is to reconsider part of Rammell Field as a suitable housing site for 40-50 units. 3.3 The development strategy (STR1) has already recognised Cranbrook as being a sustainable location for new housing due to the range of services and facilities offered within the town. In addition, being located outside of the Green Belt, Cranbrook is considered more suitable for new development than many other locations in the Borough. 3.4 Rammell Field is considered well suited in terms of its central location to accommodate new local needs housing, particularly in light of the surrounding residential character to the site and, potentially, playing a key role in supporting local housing needs – discussed more fully in Chapter 7. Although the site is proposed as a Local Green Space designation under the Regulation 18 consultation we are objecting to this classification for the entire site, and would argue that a part green space allocation and part housing allocation, to include affordable and local needs housing, would make more efficient use of land within this central location, whilst representing an overall gain to the local community. 3.5 The north/east corner of Big Side Playing Field, to the north of the town, has already been considered as a suitable site for a housing allocation of up to 15 units. However, given the proposed location of housing has already been accepted here within the Draft Local Plan and would already involve the partial loss of a playing field, in our view, it would make sense to expand the housing allocation to reach a capacity of up to 25 dwellings. Chapter 6 considers this proposition in more detail in relation to draft allocation AL/CRS 2 and the option of being able to replace the displaced playing pitch in a more suitable location closer to the School. 3.6 The Key Diagram Figure 4 of the Draft Local Plan illustrates the spatial strategy and broad distribution of housing development across the Borough. In light of the above comments, we propose this Diagram be updated to reflect the additional growth proposed at the Big Side and Rammell Field sites. We also seek an amendment to Table 3, which follows Policy STR1 and identifies the scale and distribution of development. To account for the additional development in Cranbrook being sought through our representations we seek an increase to the current maximum number of allocations provided for the settlement of Cranbrook of up to 863 units. 3.7 In line with the above proposals we recommend Part 1 of draft Policy STR/CRS 1 (The Strategy for Cranbrook and Sissinghurst Parish) also be updated to reflect the 50-60 additional housing units proposed to be accommodated in Cranbrook. We refer to part two of the policy which acknowledges that additional housing to the draft allocations may be delivered through the redevelopment of appropriate sites and other windfall development. Given the number of additional units proposed at Rammell Field, we consider it appropriate to include this site as an additional allocation, under Part 1 of the Policy. Playing Fields 3.8 Cranbrook School has a rich sporting heritage and the School is committed to ensuring that sport continues to thrive in the future. The School continues to successfully compete with the best locally available School opposition (including larger independent Schools) and the keen intent, high quality facilities and teaching is a major contributing factor to the School’s appeal for boarders. It is therefore vital that the School continues its commitment to improve the existing sports equipment and facilities. 3.9 Three of the sites we are promoting/supporting through this Local Plan process involve existing playing fields, two of which are already proposed to be allocated in part for some housing development in addition to the retention of the majority of the respective sites as playing fields. It is therefore important we consider the national guidance relating to proposals which affect existing playing fields, as part of our representations for these sites. 3.10 It should be noted that Sport England’s policy is to oppose the granting of planning permission for any development which would lead to the loss of, or prejudice the use of, all or any part of a playing field, unless one or more of the five exceptions stated in its policy apply: Sport England Policy
3.11 In this case of Rammell Field, Jaegers Field and Big Side Field the main exceptions are likely to fall under ‘E1’ or ‘E4’. 3.12 The school is committed to improving its facilities including the quality of sports provision. Currently playing fields are dispersed and fragmented which is not ideal in terms of overall efficiency, pupil safety and maintenance. There are opportunities to consolidate and improve the quality and quantity of pitches and for pitches to be provided more centrally within the campus. This may include opportunities to create additional levelled playing pitches on land adjacent to the ‘grounds maintenance complex’ as well as potential opportunities to look to expand the land available in these locations. 3.13 In the case of Rammell Field, our proposal will result in the loss of a playing pitch which may need to be relocated elsewhere subject to further analysis. However, there will be general recreational provision provided in the form of the open space to be retained at the north of the field, fronting Bakers Hill. This recreational space will now be publicly accessible which will be a major benefit to the community. 3.14 The school intends to produce a comprehensive Playing Fields Assessment and Strategy in due course that would inform future planning applications on all three sites. | ||||||||||||||
DLP_6983 | Nigel Tubman | Table Number: 3 Again, it is all about Tunbridge Wells which has less than half the current population of the borough and if all these proposals come to fruition the population of Tunbridge Wells will be a lot less than half the population of the borough. The section talks about infrastructure development. For example, a community centre for Cranbrook. Who is TWBC kidding having sold a valuable site in the town that was originally in the ownership of the RDC and yet nothing from the sale has been spent in Cranbrook and area. Where and who would fund a new medical centre and find extra GPs to staff it? Minimal extra school places are hardly a benefit to Cranbrook and other areas. No proposals for jobs, transport or economic development and no evidence to back up any of these proposals. | ||||||||||||||
DLP_6861 | John Gibson | The housing allocation for Sissinghurst is disproportionate for such a small village. Seventy odd new houses have recently been assimilated within this small rural village and more planning applications are in the pipeline. No increase in local employment is forecast despite the significant increase in housing. This is not sustainable. (TWBC Comment - duplicate comments received 13/11/2019 as below) Table Number: 3 Scale and Distribution of Development The housing allocation for Sissinghurst is disproportionate for such a small village. Around seventy new houses have recently been assimilated within this small rural village and more planning applications are in the pipeline. No increase in local employment is forecast despite the significant increase in housing. This is not what I would regard as sustainable planning. | ||||||||||||||
DLP_7558 | Richard Fisher | TWBC: the standard response was submitted by the list of responders on the left: The plan is not fit for consultation. It is flawed, incomplete and unsound in certain aspects. TWBC must address the fact that one single Councillor (Alan McDermott) has been allowed to Chair the Planning Policy Working Group, the Planning & Transportation Cabinet Advisory Board and Cabinet. This suggests a degree of conflict, and a failure of impartiality, objectivity and governance. | ||||||||||||||
DLP_6801 | Kember Loudon Williams for Wedgewood (New Homes) Ltd | Table 3 should be amended to reflect the modest uplift of 35 housing units proposed to be accommodated within Horsmonden. This reflects the aim of the Plan (as per paras. 4.38 and 4.40) to maximise potential outside of the AONB, and reflecting the detailed submissions within the KLW Supporting Statement – particularly Chapters 3-5. [TWBC: see Supporting Statement and Comment Numbers DLP_6793, 6797-6799, 6801, 6803-6804] | ||||||||||||||
DLP_7513 | Sarah Parrish | Why are there no details? 63% of the Local Plan is Unplanned! |
Policy STR 2: Presumption in favour of sustainable development
Comment No. | Name/Organisation | Object/support/support with conditions/general observation | Response |
|---|---|---|---|
DLP_7866 | Andrew Hues | Object | TWBC: the standard response was submitted by the list of responders on the left: Paragraph 4.42 again cites the need to take account of policies in local plans without mentioning that TWBC has ignored the Hawkhurst Neighbourhood Development Plan in its previous planning decisions, and has failed to give effect to the 2019 Neighbourhood Development Plan. In relation to the proposed developments at Hawkhurst, the sustainability objections are set out under STR 1 above. [TWBC: See corresponding comment under STR 1 above]
|
DLP_7932 | Wendy Owen | Object | “4.42 As set out within the NPPF, the role of the Local Plan is to plan for development over the plan period in a sustainable way in accordance with the Development Strategy. Accordingly, in planning for new development, consideration should be given to all three elements of sustainable development; the economic, social, and environmental objectives.” |
DLP_8193 | Mrs Suzi Rich | Object | STR 2 Presumption in favour of sustainable development [TWBC: See comments DLP_8189-8214 for full representation] |
DLP_8208 | Home Builders Federation | Thank you for consulting the Home Builders Federation (HBF) on the draft Local Plan. The HBF is the principal representative body of the housebuilding industry in England and Wales and our representations reflect the views of discussions with our membership of national and multinational corporations through to regional developers and small local housebuilders. Our members account for over 80% of all new housing built in England and Wales in any one year. Outlined below are our comments on the approach taken by the Council to increasing the supply of land for residential development and the policies being proposed with regard to the management of new development in future. STR2 – Presumption in favour of sustainable developmentWhen the presumption in favour of sustainable development was first introduced the Planning Inspectorate recommended that a policy reflecting this approach should be included in all local plans. This approach is no longer considered necessary by the Inspectorate. Given this position and the fact that paragraph 16(f) of the NPPF states that policies in local pans should serve a clear purpose and avoid any unnecessary duplication we would suggest this policy is deleted. | |
DLP_938 | Mrs Karen Stevenson | Object | STR 2 commits to the, “desire to deliver sustainable development” that, “brings benefits for the environment and all sectors of the community.” STR 2 (2) states that, “Planning applications that accord with the policies in the adopted Local Plan (and, where relevant, with policies in made neighbourhood plans) will be approved without delay, unless material considerations indicate otherwise. I would question whether any development t in rural areas can really be described as “sustainable”. In today’s world, challenging to limit environmental impact of climate change, any development where the only practical means of the resident getting to from work, school, shops and health services, is by car, cannot surely be sustainable? To be truly sustainable, development t should take place where either journeys can be made on foot, by bicycle, or public transport. This again supports the policy of doing more to find brownfield sites in towns with train stations. I do not believe this policy is being pursued by the development proposals set out in the draft local plan. |
DLP_1095 | Mr John Hurst | Object | Policy STR2 - Presumption in favour of sustainable development Fully support the presumption, but it is not reflected in the DLP, which appears more aligned to the outdated "jobs and growth" philosophy, at the expense of the precious Green Belt, and the concreting over of open green spaces to the north west of Paddock Wood in particular. Many of the detailed sheets in the DLP refer to negative climate impacts of the respective proposal. |
DLP_3385 | Mrs Lucy Howells | Object | Policy Number: STR 2 Paragraph 4.42 again cites the need to take account of policies in local plans without mentioning that TWBC has ignored the Hawkhurst Neighbourhood Development Plan in its previous planning decisions and has failed to give effect to the 2019 Neighbourhood Development Plan. In relation to the proposed developments at Hawkhurst, the sustainability objections are set out under STR 1 above. (comments taken from STR 1) The proposed development would not constitute sustainable development The proposed development would contravene the presumption in favour of sustainable development at paragraph 11 of NPPF as a development of this size cannot be adequately accommodated in this relatively isolated rural environment. Existing facilities and services are scaled for the needs of a village: they have already been put under strain by recent development and would not be able to accommodate such a large influx of residents. There are very limited local employment opportunities and no secondary schools within walking distance. The absence of viable transport alternatives to the car means that Hawkhurst cannot be considered an appropriate location for a development of this size. Public transport services in Hawkhurst are very limited. There is no railway station and buses run infrequently and – in many cases - during peak hours only. Residents of Hawkhurst have little choice but to use their cars to travel to population centres and additional development would therefore simply add to the volume of traffic on local roads, adding to congestion and pollution. The village is already a congestion black spot and subject to unacceptable levels of pollution. The proposed “relief road” (see below) would merely exacerbate the problem rather than mitigating it. The proposed development on the golf course would result in the destruction of large numbers of mature trees – this should be regarded as unconscionable in today’s climate. The effect would be to undermine the move to a low carbon future as required by Paragraph 95 of the NPPF. There is no environmental benefit to the proposed development. As well as removing many mature trees it would damage the habitat for local wildlife. The Woodland Trust has object to the recent application for outline planning permission on the basis of potential deterioration and disturbance to two areas of ancient woodland; a concern which is shared by many Hawkhurst residents. They, too, argue that there is no wholly exceptional reason for the development as required by the NPPF. |
DLP_2934 | Garry Pethurst | Object | Policy STR2 The policy states 'a desire to deliver...growth that is not for its own sake'. I object to this on the basis that a Housing Needs Assessment produced by AECOM in 2017 on behalf of Cranbrook Parish Council identified a need for between 263 and 610 dwellings in the Parish between 2017 and 3033. Even at the highest figure this is only two-thirds of the 923 proposed by TWBC. The numbers proposed in the Draft Local Plan appear to be on the basis of 'suitable' land put forward in the Call for Sites and not at all on the basis of need. This conclusion is supported by the statement made by Cllr Alan McDermott to Cranbrook and Sissinghurst Parish Council on 8th August 2019, to the effect that if no0one had put forward any sites, then none would have been allocated, and no houses would have been built. |
DLP_3555 | Lynne Bancroft | Support with conditions | Development should be sustainable but that proposed in the Local Plan is not sustainable. Much more development should be put in Tunbridge Wells and the bigger towns and directly adjacent to the dualled A21 and much less than that proposed in the villages and small towns in the eastern side of the Borough. Further development in Sissinghurst is not sustainable due to the lack of facilities, employment and poor transport links. Approval of planning applications should be made in line with draft Parish neighbourhood development plans, as well as approved ones. TWBC should ensure that current planning permissions are decided based on their draft Local Plan policies and the draft Parish neighbourhood development plans. |
DLP_2734 | Rosanna Taylor-Smith | General Observation | 2. TWBC must have due regard and take into consideration when determining planning applications and giving pre-planning guidance all adopted Neighbourhood Plans such as the Hawkhurst Village NDP. This has not been seen to be the case in the case of Hawkhurst. 1. General Statement 3. Areas such as those with special classifications and implied protection such as AONB should not generally have major development allowed - e.g. Hawkhurst Golf Club application which offers a so- alley 'Relief Road' as an incentive to TWBC and KCC to allow development in the AONB, |
DLP_2032 | Terry Everest | This policy needs to be taken much more seriously than at present, you cannot replace or recreate ancient woodland, wildflower meadows, heathland, forest or river and pond environments once they are developed or disrupted by roads or building works. The best mitigation of development is not to develop on greenfield sites. | |
DLP_2762 | Cllr Keith Obbard | Support | WEALDEN GREEN PARTY RESPONSE TO TWBC DRAFT LOCAL PLAN Policy STR2 - Presumption in favour of sustainable development We fully support the presumption, but it is not reflected in the TWBC Draft Local Plan, which appears more aligned to the outdated "jobs and growth" philosophy, at the expense of the precious Green Belt and AONB with the concreting over of open green spaces throughout the Borough, and to the north west of Paddock Wood in particular. |
DLP_2235 | Tracy Belton | Object | STR2 I cannot see how this will be of benefit to the villages. Roads will be congested, journey times will increase, medical appointments will be even less readily available and I cannot see how increased traffic will be of any benefit to the environment (carbon emissions, wildlife, etc). Village communities are lovely, but increasing the number of residents will not necessarily mean that it will improve the local community. Many village residents are never seen in local shops, pubs, social clubs, etc. |
DLP_2465 | Mr Geoffrey Robbins | Object | As a resident of Sissinghurst, I strongly object to any further large-scale developments on this small village. The village has had nearly 100 new dwellings built in the last 2-3 years despite little or no infrastructure to support these developments, yet TWBC is proposing that Sissinghurst take another 100-115 dwellings. Traffic in the small village can be dire at times, the primary school is oversubscribed, there is no doctor's surgery, and there is a single village shop. Any requirement for schooling, medical facilities and shopping means travelling to Cranbrook, and with limited public transport, more car journeys will result.As for employment, there is precious little resulting yet again in travel. I urge TWBC to re-think the strategy concerning Sissinghurst. |
DLP_2108 | Robert Tillotson | Object | STR 2 STR2 Policy in favour of sustainable development. I have read with deepening sadness the Sustainability Review document of over 200 pages. I aim to get out more ! Simply repeating in various forms the key word “sustainable”does not make any of this plan so.The word is repeated hundreds of times throughout and becomes meaningless against the 19 categories of sustainability that you list. We have a climate crisis right now,and your plan is to cover great swathes of Green Belt and Areas of outstanding natural beauty with concrete,roads and housing. This is not sustainable in the wider and most crucial meaning of the word: This plan will reduce biodiversity. It will reduce air quality. It will increase global warming. Attempting to balance these or mitigate them by adjusting objectives,and scoring as you have done is fiddling whilst Rome burns.It will be seen as laughable in future generations,if we survive. The only thing sustained in this plan is the future of the construction industry,and planning jobs that attempt to square impossible, opposed objectives. This is plan is business as usual,and with the only given to hit a fairly random target of house builds |
DLP_3170 | Kent County Council (Growth, Environment and Transport) | Support | Highways and Transportation The Local Highway Authority supports the policy. |
DLP_3804 | Natural England | Support | Natural England welcomes a policy of sustainable development that brings benefits for the environment. |
DLP_3908 | IDE Planning for Paddock Wood Town Council | Support | SUPPORT |
DLP_4658 | CBRE Ltd for Dandara Ltd | Support | Draft Local Plan Policy STR2: ‘The Presumption in favour of sustainable development’ 3.47 Dandara supports the focus of Policy STR2, and TWBC’s desire to deliver sustainable development and growth that benefits the environment and addresses social impacts. This policy is considered to be consistent with paragraph 8 of the NPPF, and sound in accordance with paragraphs 31 and 35 of the NPPF. [TWBC: see full representation]. |
DLP_4466 | Paddock Wood Neighbourhood Plan Steering Group | Support | Support |
DLP_5070 | Tally Wade | Object | Policy STR 2 (page 47) I object to the numbers of houses planned for the parish of Cranbrook and Sissinghurst and the large scale nature of developments (718-803 new dwellings on nine sites). They are 50% higher than identified in the Housing Need Assessment done by an independent assessor (AECOM) in 2017 as part of the Neighbourhood Plan process for the parish. Policy STR 2 (page 47) I object to Sissinghurst taking more development than any other village in the borough. It is already a pinch point for traffic, has three shops and no designated parking for any of them. Policy STR 2 (page 47) I object to such large scale developments in AONB as it is contrary to policy EN21, which states that the High Weald AONB “is considered one of the best surviving medieval landscapes in Northern Europe.” The Neighbourhood Development Plan (2017-2019) has evidence that landscape and the rural nature of the parish is of the utmost importance. The NPPF states: “great weight should be given to conserving and enhancing landscape and scenic beauty in…the Area of Outstanding Natural Beauty…The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances.” The area’s history is one of dispersed settlement of small farmsteads and hamlets - large scale developments are simply not appropriate. I want to see more development of a farmstead type. Policy STR 2 (page 47) I object to the number of houses the borough is being asked to take. With 70% in AONB, a protected landscape, the borough should push back on numbers like Sevenoaks is. Policy STR 2 (page 47) I object to the process used for allocating development to the sites at Turnden and Golford Road, neither appeared in the SHELLA meaning that their selection has not been properly justified as required by NPPF paragraph 35. Environment Policy STR 2 (page 47) I object to such large scale developments in AONB as it is contrary to policy EN21, which states that the High Weald AONB “is considered one of the best surviving medieval landscapes in Northern Europe.” The Neighbourhood Development Plan (2017-2019) has evidence that landscape and the rural nature of the parish is of the utmost importance. The NPPF states: “great weight should be given to conserving and enhancing landscape and scenic beauty in…the Area of Outstanding Natural Beauty…The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances.” The area’s history is one of dispersed settlement of small farmsteads and hamlets - large scale developments are simply not appropriate. I want to see more development of a farmstead type. |
DLP_3774 | Mary Jefferies | Object | Paragraph 4.42 again cites the need to take account of policies in local plans without mentioning that TWBC has ignored the Hawkhurst Neighbourhood Development Plan in its previous planning decisions, and has failed to give effect to the 2019 Neighbourhood Development Plan. |
DLP_5977 | Steve Rix | Object | Policy STR 2 (page 47) I object to the number of houses planned for the parish of Cranbrook and Sissinghurst and the large scale nature of developments (718-803 new dwellings on nine sites). They are 50% higher than identified in the Housing Need Assessment done by an independent assessor (AECOM) in 2017 as part of the Neighbourhood Plan process for the parish. Policy STR 2 (page 47) I object to Sissinghurst taking more development than any other village in the borough. It is already a pinch point for traffic, has three shops and no designated parking for any of them. Policy STR 2 (page 47) I object to such large scale developments in AONB as it is contrary to policy EN21, which states that the High Weald AONB “is considered one of the best surviving medieval landscapes in Northern Europe.” The Neighbourhood Development Plan (2017-2019) has evidence that landscape and the rural nature of the parish is of the utmost importance. The NPPF states: “great weight should be given to conserving and enhancing landscape and scenic beauty in…the Area of Outstanding Natural Beauty…The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances.” The area’s history is one of dispersed settlement of small farmsteads and hamlets - large scale developments are simply not appropriate. I want to see more development of a farmstead type. Policy STR 2 (page 47) I object to the process used for allocating development to the sites at Turnden and Golford Road, neither appeared in the SHELLA meaning that their selection has not been properly justified as required by NPPF paragraph 35. Policy STR 2 (page 47) I object to the number of houses the borough is being asked to take. With 70% in AONB, a protected landscape, the borough should push back on numbers like Sevenoaks is. Policy STR 2 (page 47) I object to such large scale developments in AONB as it is contrary to policy EN21, which states that the High Weald AONB “is considered one of the best surviving medieval landscapes in Northern Europe.” The Neighbourhood Development Plan (2017-2019) has evidence that landscape and the rural nature of the parish is of the utmost importance. The NPPF states: “great weight should be given to conserving and enhancing landscape and scenic beauty in…the Area of Outstanding Natural Beauty…The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances.” The area’s history is one of dispersed settlement of small farmsteads and hamlets - large scale developments are simply not appropriate. I want to see more development of a farmstead type. |
DLP_6859 | Barton Willmore for Crest Nicholson | ii) Policy STR2: Presumption in Favour of Sustainable Development 5.16 The NPPF requires that sustainable development lies at the heart of any Local Plan strategy and should be delivered through adopting a “positive approach to planning” and meeting the development needs of an area. The NPPF (para 11) also prescribes how the presumption should be incorporated into decision-taking. This policy accords with the NPPF and is therefore “sound” for the purposes of the NPPF (para 35). [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_7631 | Mr J Boxall | Support with conditions | Policy Number: STR 2 Point 1 Development should be sustainable but that proposed in the Local Plan is not sustainable. Much more development should be put in Tunbridge Wells and the bigger towns and directly adjacent to the dualled A21 and much less than that proposed in the villages and small towns in the eastern side of the Borough. Further development in Sissinghurst is not sustainable due to the lack of facilities, employment and poor transport links. Tunbridge wells green belt should be released for sustainable development as green belt is a historic landscape protection adjacent to towns far better to protect villages and small towns within the AONB where housing is unsustainable. Policy Number: STR 2 Point 2 Approval of planning applications should be made in line with draft Parish neighbourhood development plans, as well as approved ones. TWBC should ensure that current planning permissions are decided based on their draft Local Plan policies and the draft Parish neighbourhood development plans. |
DLP_6771 | Mrs Carol Richards | Object | Policy STR 2 (Presumption in favour of sustainable development) Exceptional Circumstances do not exist to justify releasing any land from the Green Belt in Tudeley and East Capel. |
DLP_7278 | Mrs Katie Lee-Amies | Object | Strategic Policies (comments already included above) [TWBC: See comments DLP_7265-7267 and 7269-7277] STR 1 – object. STR 2 – object. STR 3 – object. The masterplan excuse! STR 4 – object. Strongly. STR 5 – support with conditions. Insufficient information. STR 6 – object. STR 7 – object. STR 8 - object. STR 9 – object. There are no LBD details for Tudeley STR 10 – object. |
DLP_6215 | Amanda Wells | Object | Policy Number: STR2 The presumption in favour of sustainable development - planning applications in accord with the policies in the LP will be approved without delay…. The Sustainability Assessment is based on incorrect calculations of housing need which TWBC should be rigorously opposing. The definition of ‘sustainable development’ needs to be completely rethought in relation to the declaration of a climate emergency. The Committee on Climate Change’s new report “UK housing Fit for the future?” warns that the government is in danger of missing its legally binding climate change targets unless the UK urgently adapts its existing housing stock and slashes emissions from new homes. Although this is an issue at government level, TWBC has the ability to impose tougher building standards and should be requesting immediate action from Government for legislation to back this up. |
DLP_6287 | Mrs Elizabeth Simpson | Object | Policy Number: STR2 STR 2 commits to the, “desire to deliver sustainable development” that, “brings benefits for the environment and all sectors of the community.” STR 2 (2) states that, “Planning applications that accord with the policies in the adopted Local Plan (and, where relevant, with policies in made neighbourhood plans) will be approved without delay, unless material considerations indicate otherwise”. Can any development in rural areas really be described as “sustainable”? In today’s world, globally, nationally and locally seeking to limit the environmental impact of climate change, any development where the only practical means of travelling to and from from work, school, shops and health services, is by car, cannot surely be sustainable? To be truly sustainable, development should take place where either journeys can be made on foot, by bicycle, or public transport. This again supports the policy of doing more to find brownfield sites in towns with train stations. I do not believe this policy is being pursued by the development proposals set out in the draft local plan. |
DLP_6985 | Nigel Tubman | Object | The opening paragraph gives the game away. ‘At the heart of the development strategy for Tunbridge Wells Borough is a desire to deliver sustainable development growth that is not for its own sake but growth that brings benefits for the environment and all sectors of the community etc.’ There is nothing sustainable about this if a large amount of housing is placed in the eastern part of the borough but no attempt to put in any additional and appropriate infrastructure or conditions to create local jobs etc. |
DLP_7199 | Mr Michael Armitage | Object | Paragraph 4.42 Hawkhurst’s plan is being ignored. |
DLP_6543 | Diana Badcock | General Observation | Policy Number: STR 2 I support the presumption in favour of sustainable development, but if this is to mean more than just fine words, TWBC must take account of the Cranbrook NDP’s view on the scale of development proposed. Large scale development is not acceptable in this historic settlement which is entirely within an AONB. We need small scale housing development, maintaining the green spaces between built areas; growth consistent with the historic heritage. |
DLP_6611 | AAH Planning for Future Habitat Ltd | Policy STR 2 – Presumption in favour of sustainable development Policy STR 2 reflects the presumption in favour of sustainable development contained in the Framework. Our Client supports the general essence of this policy which closely aligns with the contents of the Framework. However, our Client would welcome the additional acknowledgement that the Council will work proactively with applicants to find solutions rather than problems which mean that proposals can be approved wherever possible as emphasised in the Framework. [TWBC: see full representation and site plan attached]. [TWBC: see also Comment Nos. DLP_6606-6620, 6622-6627]. | |
DLP_6670 | Gladman | 5.2.1 Gladman is supportive of Policy STR2. The policy confirms the Council’s commitment to secure the delivery of sustainable development consistent with the approach as set out in Paragraph 11 of the NPPF and is key in demonstrating compliance with national planning policy. [TWBC: see full representation]. [TWBC: see also Comment Nos. DLP_6656-6695] | |
DLP_7328 | Campaign to Protect Hawkhurst Village | Object | Given the fundamental tension in the Local Plan between the environmental constraints and meeting the Borough’s development needs, this policy should set out clearly what the Council considers Sustainable Development to be, by applying the three limbs in the NPPF to the Borough’s specific circumstances. This is not about purely growth that “brings benefits for the environment and all sectors of the community” but making clear the need to ensure sufficient land is available in the right places. As currently drafted the policy fails to adequately place enough emphasis of the environmental objective of sustainable development which is of equal importance to the economic and social objectives. |
DLP_7503 | Mr and Mrs A J Herbert | Object | Paragraph 4.42 cites the need to take account of policies in local plans without mentioning the Hawkhurst Neighbourhood Development Plan. The draft Local Plan does not take account of the Hawkhurst NDP. |
DLP_7696 | Alison Nicholls | Object | Policy Number: STR2 The NPPF clearly states that “great weight should be given to conserving and enhancing landscape and scenic beauty in…. the Area of Outstanding Natural Beauty… The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances” I object to the large scale of the development being put forward with over 800 houses being allocated on nine sites between the parish of Cranbrook and Sissinghurst. Living close to Sissinghurst, the traffic, particularly during the morning and afternoon is a problem which will only be exacerbated by such large scale development. Scant regard seems to have been given to the existence of the AONB, the proximity to this of Sissinghurst and and the irrevocable impact development of this size would have on this area. I do not objct to the principle of some development here but it should be of a limited nature to maintain the rural and historical aspect of the area and should be in keeping with the existing farmstead type rather than large scale. |
Policy STR 3: Masterplanning and use of Compulsory Purchase powers
Comment No. | Name/Organisation | Object/support/support with conditions/general observation | Response |
|---|---|---|---|
DLP_257 | Chris Sutton | Object | Masterplanned approach (in context of AL/PW1) The Local Plan makes extensive references to the concept of Masterplanned approach but there is no definition of it in the Glossary (Appendix 4). Appendix 3 simply states that Masterplanning is an enabling policy with no specific targets but progress to be monitored regularly. It appears that the use of the word “Masterplanning” (together with words such as “Garden Settlement” and “Exemplar” which are also not defined in the Glossary) are used in the Local Plan document to create a sense that TWBC will be working with Developers to ensure exceptionally well managed development, and thereby to try to allay concerns from local residents who are impacted by the very substantial nature of the proposed developments, particularly in Tudeley Village and around Paddock Wood. But none of these words are defined in the Glossary. They are therefore assumed to be Public Relations spin. The use of Masterplanning in particular seems to be an excuse for TWBC to say “we don’t need to provide detail now, because it will come later once the Local Plan has been approved”. Given the very extensive impact of these developments on the local communities, surely we should expect substance rather than spin from TWBC. We need to know now what we are being asked to support. This should include much more detail about local community involvement in the proposals. Perhaps TWBC could point the residents of Paddock Wood to the implementation of recent developments in Paddock Wood, because presumably at least some of the concepts of Masterplanning would have been used in those? Could they perhaps cite Mascalls Grange as an example, where executive homes have been built with cesspits because the sewage infrastructure is simply not there? Only a very small number of the proposed homes there have been built, and the developer has closed the show house because of lack of interest by potential homebuyers. Perhaps those potential homebuyers have been put off by all the ugly steel fencing that has been placed around the perimeter of the development site south of Badsell Road, with no construction started there after many months. The Local Plan talks of the importance of good landscaping at the entrances to our communities to create a positive impression for visitors – which is absolutely not the case with steel fencing enclosing what now looks like acres of wasteland. There is absolutely no mention of the piecemeal development of the Mascalls Grange and Badsell Road sites in the Local Plan, nor of the fact that potential homebuyers are showing so little interest. Has TWBC not paused to reflect that the proposed additional new development will create even more concern for potential homebuyers on the current development sites? The Local Plan sets off huge alarm bells for anyone thinking of moving to Paddock Wood, because of its lack of infrastructure and wave after wave of new development proposed by the distant Planning Office in leafy Royal Tunbridge Wells. Perhaps TWBC could also point to the proposed community centre for Paddock Wood (5.69 in the Local Plan). The Local Plan is completely silent on the fact that PWTC arranged a ballot of local residents on whether this site was appropriate for a community centre, and the result was that local residents said no. This may be an item that TWBC feels does not strictly need to be mentioned in the Local Plan – but surely it must be mentioned in the context that TWBC are claiming in the Local Plan that local communities will be fully involved and engaged as Paddock Wood future development will be under a “Masterplanning” approach. The reality is that over the course of successive Local Plans TWBC has subjected Paddock Wood residents to a totally disjointed, piecemeal approach, and, given residents’ experience, it stretches all credibility to suggest that TWBC Planners have got it right this time round, both with regard to design and implementation of new developments. We are told that Councillors and Officers in the TWBC have felt serious personal stress because of the challenges of working with private developers to firstly demolish and now build on the old cinema site opposite the Town Hall. Given that they know what this stress feels like, TWBC Councillors and Officers should be wary about exporting such stress to the current residents of Paddock Wood and Capel. |
DLP_7933 | Wendy Owen | General Observation | Compulsory Purchase Orders (CPOs) must only be used in very exceptional circumstances. The bar must be set an appropriately high level. Where a CPO is used, the market rate must be paid to the land owner. The use of CPOs must be monitored, to ensure particular individuals are not hounded over a period of time. |
DLP_7967 | Sharon Pickles | Object | The following comment was submitted by the list of responders on the left: 4.44 When Brick Kiln Farm in Cranbrook was allocated, the developer was told to take a “master planning” approach. This has not happened. I have no confidence that this approach will be enforced by the Planning Department |
DLP_8194 | Mrs Suzi Rich | Object | This strategy states that “In order to bring forward development of the sites allocated in a timely and comprehensive way, the Council will, where appropriate, use its Compulsory Purchase Order powers to enable the sites and development to be delivered to achieve the strategic objectives and development strategy set out within the Local Plan. It will also, where appropriate, work with other authorities that are using their Compulsory Purchase Order powers” These documents show the route of the proposed A228 strategic transport link (Colts Hill bypass) (Policy TP 6) intersecting with the unclassified Alders Road with a roundabout! Alders Road is a single track rural lane with two weight restricted bridges at either end. The roundabout is situated close to a sharp bend in the road (which is an accident blackspot) and at the location of several residential properties. It would be completely irresponsible to join a strategic link road with a road of this nature and presumably the residents of these properties would be subjected to the compulsory purchase powers of Kent County Council or TWBC in order to deliver this route. I object to the use of CPOs to build either the Colts Hill bypass or the Five Oak Green Bypass, both of which the dLP suggests are essential infrastructure required to enable the sites and development at Tudeley (AL/CA 1) and East Capel (AL/C! 3 & AL/PW 1) to be delivered. It is my view that these developments are unsustainable in any event and that they should be removed from the dLP. The Colts Hill Bypass should also be removed from the dLP as it is unrelated to housing need and therefore funding for its completion should not come from developers. Please see my comments under COMMENT BOX 2 in relation to Policies TP 1 and TP 6 and in COMMENT BOX 7 in relation to the SWECO Local Plan Transport Evidence Base. [TWBC: See comments DLP_8189-8214 for full representation] |
DLP_8340 | Joe Matthews | Object | TWBC: correspondent submitted the following comments on 20/11/19, after the close of consultation on 15/11/19: Paragraph 4.44 To achieve the strategic objectives of this Draft Local Plan, it is essential for development to be planned in a coordinated way and, for some of the strategic sites and locations, it will be appropriate to deliver this through a comprehensive masterplanning process When Brick Kiln Farm in Cranbrook was allocated, the developer was told to take a “master planning” approach. This has not happened. |
DLP_858 | Ian Pattenden | Object | Comments on Section 4 Paragraph 4.49 (The Green Belt) p.49 Exceptional Circumstances do not exist to justify releasing any land from the Green Belt in Tudeley and East Capel. The development described in this Draft Local Plan will be contrary to the aims of the Green Belt in terms of urban sprawl and coalescence of settlements. The development will be widely visible from many areas of the surrounding countryside due to the openness and topography of the landscape. It will blight many rural heritage assets such as listed buildings including iconic Oast Houses and Kentish timber framed farm houses and barns. TWBC’s own assessment of the “broad areas” in which all the Capel Parish sites lie is that there is a very strong case against allowing any land within them to be withdrawn from the Green Belt. This is based on reports commission by TWBC from “Land Use Consultants Ltd” in 2016 and 2017. Comments on Section 4 Paragraph 4.50 (The Green Belt) p.49 You state that the Distribution of Development Topic Paper (which draws on the Green Belt Strategy Study) provides evidence and justification to release land from the Green Belt at Tudeley. This is not true. There is no evidence that makes Tudeley a better site for a Garden Village than Horsmonden. The justification for not placing a garden settlement at Horsmonden is that “This would be a very large-scale strategic allocation that would be disproportionate to the size of the settlement, with concern about landscape and heritage”. Tudeley is a tiny hamlet, far smaller than Horsmonden, with 50 houses at most. The whole of the Parish of Capel has only 950 houses in it. Adding 2,800 new houses at Tudeley is a massive increase that is far higher than the proportional increase at Horsmonden. Moreover, there is even more concern about landscape and heritage at Tudeley, which is home to a world-renowned heritage asset – All Saints Church. The only church in the entire world to have a complete set of stained glass windows designed by the renowned artist Marc Chagall. Chagall was commissioned to design just one window but found the landscape and light so inspiring he designed the rest. Altering that setting will devalue the artist’s vision and impact negatively on the tourism that the church draws into the area. The only heritage asset at Horsmonden is a gun foundry. Its 13th century church is nearer to Goudhurst, well outside of the village. It has an active bus route linking it to Tunbridge Wells and Paddock Wood. It has a disused railway station. Horsmonden is not in the Green Belt or AONB. Tudeley has a beautiful, rolling landscape with abundant wildlife, fertile soil and high biodiversity scores. It is entirely within the Green Belt and the High Weald AONB is within a few yards of the proposed development site. You state that Horsmonden has severe access difficulties. The access difficulties at Horsmonden pale into insignificance when you look at the access difficulties on the B2017 and Hartlake Road. You do not have the exceptional circumstances required to justify building at Tudeley rather than Horsmonden. The only argument presented anywhere is that Tudeley has a single landowner and Horsmonden has multiple landowners. TWBC’s reluctance to deal with multiple landowners is not an “exceptional circumstance”. |
DLP_1103 | Mr John Hurst | Support | CPOs to be absolute last resort, and the need for their avoidance should be a boundary condition of the Masterplanning. |
DLP_1739 | Horsmonden Parish Council | Policy STR3- Master planning and use of CPO powers: We consider that, if allocated, the land east of Horsmonden (AL/HO3) should be subject to a master planning requirement, in view of its size and sensitivity, and the mix of different uses. The Parish Council already has work in hand as part of its preparatory work on the Horsmonden Neighbourhood Plan and its inclusion in STR3 would provide a suitable means of linking strategic and local planning policy. | |
DLP_3672 | Capel Parish Council | Object | TWBC: the standard response was submitted by the list of responders on the left: This contradicts the reasoning for favouring the proposed strategic offline link (Colts Hill Bypass – Policy TP 6) which was that there would be no need for CPO’s unlike the on-line option which would do materially less harm to the AONB. In light of this inconsistency will this plan be revisited? It is anticipated that CPO’s are likely to be necessary in the event that the proposed A228 strategic transport link (Colts Hill bypass) (Policy TP 6) and the proposed link route which is to run from the proposed development at Tudeley CA1 to the Colts Hill Bypass (Five Oak Green Bypass) go ahead as described (see Local Plan Transport Evidence Base p.138 and 142). Capel Parish Council is strongly opposed to any of its residents being subject to compulsory purchase in these circumstances. |
DLP_1891 | Royal Tunbridge Wells Town Forum | STR3 Masterplanning and use of compulsory purchase powers We strongly support the masterplanning approach as against the failed policy of “Areas of Change” under the present Local Plan. Although the Council is to have a greater input, it is still implied that the developer will be responsible for the masterplanning, which does not appear to us to be an optimal approach. The greater use of compulsory purchase powers, where appropriate, is also supported in the context of a masterplanning approach to major developments in RTW and elsewhere in the Borough. | |
DLP_2722 | St. John's Road Residents association | No comment. | |
DLP_2938 | Garry Pethurst | General Observation | Policy STR3 Do we need to have a policy to cover what happens when a site requires masterplanning, but part is already subject to a planning application? The policy should state that any pending application will be suspended until the entire masterplanning process has been completed. |
DLP_2758 | Lee Hatcher | Object | Masterplanning can only work when ALL land owner of adjacent sites are on board with that. Is there any way to force developers or land owners to enter into masterplanning? I also believe that in rural areas this shouldn't be required as sites shouldn't be so big that they require this sort of advanced planning. |
DLP_2033 | Terry Everest | Object | This is not right, there are not exceptional circumstances that justify the use of green belt in these areas. Green Belt should be sacrosanct and needs protection at all times. This part of the borough is already overdeveloped. |
DLP_3171 | Kent County Council (Growth, Environment and Transport) | Support | Highways and Transportation The Local Highway Authority supports the policy. Provision and Delivery of County Council Community Services KCC is supportive of the proposal to use Compulsory Purchase Powers if and where required to positively secure land for infrastructure development. |
DLP_4361 | British Horse Society | Support with conditions | If new bridleways cannot be created by agreement, the Borough Council should be willing to exercise its compulsory powers under Section 26 of the Highways Act 1980 to create new bridleways. |
DLP_3910 | Ide Planning for Paddock Wood Town Council | SUPPORT in principle | |
DLP_4264 | RTW Civic Society | Whilst the concept of Masterplans is sensible, past experience eg. with Vale Avenue in the SAPD suggests they don’t work in practice. How will the “active participation” of all the stakeholders actually occur? Will this be more than simply consulting? eg. which stakeholders, if any, will be part of the actual decision making process? Apart from the Calverley Square, TWBC has seemed reluctant to issue CPO powers. Why will this be different after the Local Plan is agreed? | |
DLP_4659 | CBRE Ltd for Dandara Ltd | Support with conditions | Draft Local Plan Policy STR3: ‘Masterplanning and use of Compulsory Purchase powers’ 3.48 Dandara supports the emphasis on masterplanning as set out under Policy STR3. Masterplanning is an assured way of creating well-planned and high quality developments. However, where a strategic allocation encompasses a number of separate sites and separate ownerships this should be a Strategic Framework which sets the overarching principles of development, against which separate area or site masterplans can be prepared and submitted alongside a planning application. It is important to differentiate that a Strategic Framework is different to a masterplan, with a Strategic Framework being adopted, if necessary, and a masterplan providing more detail to support a planning application. The Strategic Framework should provide principles to guide development proposals and infrastructure delivery but should not seek to replicate the details required by a planning application. This will ensure a comprehensive and coordinated approach, but not unduly restrict delivery. Both Strategic Frameworks and masterplans should be clearly defined within the Plan. 3.49 Dandara will proactively work with TWBC as well as adjacent landowners, developers, the local community, town or parish councils, service providers, environmental organisations, and other interested parties where necessary to ensure any overarching Strategic Frameworks and site masterplans, as appropriate, are comprehensive and achieve the objectives of Policy STR3. 3.50 In respect of Compulsory Purchase Order (‘CPO’) powers, Dandara welcomes TWBC’s stance and encourages these to be used more readily where necessary to unlock sites and address complex land-ownership challenges. The principle of this is consistent with paragraph 119 of the NPPF. [TWBC: see full representation]. |
DLP_4467 | Paddock Wood Neighbourhood Plan Steering Group | Support | SUPPORT in principle but does TWBC have the capacity and will to develop this fully? |
DLP_4602 | Keith Stockman | Object | 4.44 To achieve the strategic objectives of this Draft Local Plan, it is essential for development to be planned in a coordinated way and, for some of the strategic sites and locations, it will be appropriate to deliver this through a comprehensive masterplanning process |
DLP_5316 | Judith Ashton Associates for Redrow Homes Ltd and Persimmon Homes South East | General Observation | Policy STR3 In noting the substance of policy STR3 and the desire to plan the development of the strategic and larger scale developments through a comprehensive masterplanning process we do believe, as set out elsewhere in these reps, that there is in fact a greater need to initiate a Strategic Infrastructure Plan for Paddock Wood to enable the strategic sites to come forward and for that to be bought forward between all interested parties concurrently with the Masterplanning process. To whit we would suggest a Framework Plan rather than a Masterplan as this will be swifter to agree and more flexible in its approach. It’s also imperative that these documents are drafted in such a way that enables sites to come forward individually as anticipated by policy H2 and that they are not used to stall development, as this will prejudice the housing trajectory – as discussed elsewhere in these reps. To this end, as indicated above, we see no reason why a Framework Plan cannot provide for the separate masterplanning and delivery of the areas to the east and west of Paddock Wood. The Framework Plan can demonstrate graphically how these areas interrelate in terms of the requirements of policies STR/PW1 and AL/PW1 for housing, employment, schools, medical facilities and open space etc, and associated connections in a general land use planning way; whilst the Strategic Infrastructure Plan can show who is providing what, and when, and where projects such as highway improvements / drainage works are to be funded jointly, who is paying for what and when it has to be provided. We also note the fact policy STR3 provides for the use of CPO powers in order to bring forward development of the sites allocated in a timely and comprehensive way. We are concerned that the acknowledgment that CPO powers may be necessary highlights the fact that certain works may be more difficult to deliver than anticipated – hence the need for the Strategic Infrastructure Plan and the recognition that certain sites can be delivered in advance if not directly linked to certain requirements. This approach would we believe be aligned with policy STR5 which also provides for in lieu financial contributions. These and their relationship to works required under CPO need, we believe, to be investigated further. [TWBC: see full representation]. |
DLP_6860 | Barton Willmore for Crest Nicholson | iii) Policy STR3: Masterplanning and Use of Compulsory Purchase Powers 5.17 The first part of this policy identifies that some developments within the Borough will come forward through a comprehensive masterplanning process, which should take a collaborative approach to include local interested parties. The supporting text states this masterplan may come forward as an SPD or site-specific planning brief. 5.18 The supporting text lists the major developments expected to come forward as a master- planned scheme. The second part of the policy relates to TWBC’s ability to compulsorily purchase land where it is necessary to bring forward sites in a timely manner. We interpret this as being that TWBC will use its CPO powers where a small element of an allocation might hold up delivery of a wider allocation scheme. TWBC should clarify that it will not be intending any wholesale acquisition of land to deliver allocations in their entirety. 5.19 As presently drafted, this section of the policy is not wholly “justified” or not necessarily “consistent with National policy” and clarification is required of the circumstances in which TWBC intends to use such powers. [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_7104 | Williams Gallagher for Canada Life Ltd | Policy STR3 – Masterplanning and use of Compulsory Purchase Powers The use of masterplans to help guide the development of strategic sites is acknowledged. Their timely preparation is a key consideration to ensure that proposed development envisaged by the Council is not unduly delayed. The status of the proposed masterplans remains unclear in the policy; are they proposed to be adopted Supplementary Planning Documents or are they to be informal documents? If the former, the timescale for their preparation may be delayed due to the statutory process and timescales involved. Similarly, it is not fully clear who the Council is proposing to take the lead on the preparation of masterplans. Is it to be the Council or the proposed developer? The inference in the policy is that developers will take the lead role. This should be clarified for certainty. It should also be clarified for which of the proposed sites that a masterplan will be required. In some instances, the circumstances of the strategic allocations may be such that a masterplan is no longer necessary (see comments on AL/RTW 4 below). The list in para 4.46 may should therefore be amended. The potential use of CPO powers is noted. The circumstances in which the Council may consider use of these powers will need to be explicitly identified. We trust that you find these comments constructive and look forward to on-going dialogue with the Council. Please keep us informed of progress with the local plan preparation. Should you have any queries, please do not hesitate to contact us. [TWBC: see also Comment Nos. DLP_7102-7117]. | |
DLP_7527 | Charterhouse Strategic Land Ltd | Support with conditions | Charterhouse broadly agrees with the Policy STR3 making the provision of the use of CPO powers to achieve the delivery of the Paddock Wood expansion. However, Charterhouse are of the view that Policy STR3 should explicitly state the Council is leading the masterplanning process and they will ensure that the strategic site will be masterplanned comprehensively and retain the right to use CPO if necessary to ensure the deliverability of the allocations. |
DLP_6998 | Kember Loudon Williams for Mr Anthony Whetstone | Support with conditions | Policy Number: Policy STR 3 We support the requirement to prepare a masterplan in relation to the development at Capel and Paddock Wood (Policies AL/CA 3 and AL/PW1). It is imperative to ensure that the site comes forward in a comprehensive way for the proper planning of the area. On behalf of our client, we would like to know more about how to get involved in this process. |
DLP_7279 | Mrs Katie Lee-Amies | Object | Strategic Policies (comments already included above) [TWBC: See comments DLP_7265-7267 and 7269-7277] STR 1 – object. STR 2 – object. STR 3 – object. The masterplan excuse! STR 4 – object. Strongly. STR 5 – support with conditions. Insufficient information. STR 6 – object. STR 7 – object. STR 8 - object. STR 9 – object. There are no LBD details for Tudeley STR 10 – object. |
DLP_6293 | Susan Heather McAuley | Support with conditions | Policy Number: Section 4 Strategic Policies STR3 Masterplanning and use of Compulsory Purchase Powers This seems like a good policy but I think planning skills should be used in all areas not just ‘strategic and larger scale developments’. Compulsory purchase is mentioned in the policy but TWBC seems to not want to use it even when their ‘call for sites’ approach has not worked e.g. Bidborough. |
DLP_6671 | Gladman | 5.3.1 It is unclear to Gladman what this policy is seeking to achieve. Confirmation of masterplanning requirements is provided in relation to each relevant site allocation as set out through subsequent parts of the Local Plan. It is most appropriate for masterplanning to be dealt with on a site by site basis because requirements and key issues for each site to be taken into account through the planning process are likely to vary. The policy therefore unnecessarily duplicates these later parts of the Local Plan. 5.3.2 It is also unclear to Gladman why the Council is making reference to its CPO powers. It is commonly known that Councils have this power available to them, to apply where circumstances require it. It is however a lengthy and costly process and all other means possible should be taken before turning to CPO. Reference to CPO in the policy would appear to set out a ready willingness to use these, which sends out the wrong signals to landowners/developers about the Council’s commitment to work cooperatively. 5.3.3 Reflecting on the above, Gladman do not consider that this policy is necessary and should be removed from the Local Plan. [TWBC: see full representation]. [TWBC: see also Comment Nos. DLP_6656-6695] |
Policy STR 4: Green Belt
Comment No. | Name/Organisation | Object/support/ support with conditions/general observation | Response |
|---|---|---|---|
DLP_51 | Thomas Weinberg | Object | The release of Green Belt described in this plan in Tudeley and East Capel is not justified in any way and is certainly not the result of “exceptional circumstances”. |
DLP_92 | Roger Bishop |
| Comments on Policy STR 4 (Green Belt) p42 TWBC’s own assessment of the “broad areas” in which all the Capel Parish sites lie is that there is a very strong case against allowing any land within them to be withdrawn from the Green Belt. This is based on reports commission by TWBC from “Land Use Consultants Ltd” in 2016 and 2017. [TWBC: see also Comment Numbers DLP_81 to 93]. |
DLP_131 | Gregg Newman |
| Comments on Section 4 Paragraph 4.49 (The Green Belt) p.49 Exceptional Circumstances do not exist to justify releasing any land from the Green Belt in Tudeley and East Capel. There are simply no exceptional circumstances that justify the destruction (there is no their word) of Greenbelt land when other land does exist but is not being put forward as a viable alternative. Please explain how you can possibly think or justify otherwise The development described in this Local Plan will be contrary to the aims of the Green Belt, for example in terms of urban sprawl and coalescence of settlements. It will result in the development of highly valued countryside and the erosion of this buffer between settlements. The development will be widely visible from the surrounding countryside and landscape and from existing residential areas and heritage assets in Capel. It will be visually prominent and urbanise this attractive rural area. I am advised that yours own assessment of the “broad areas” in which all the Capel Parish sites lie is that there is a very strong case against allowing any land within them to be withdrawn from the Green Belt. This is based on reports commission by TWBC from “Land Use Consultants Ltd” in 2016 and 2017. Yet you appear simply to be ignoring this. |
DLP_132 | Gregg Newman |
| Comments on Section 4 Paragraph 4.50 (The Green Belt) p.49 Please provide the detailed evidence that makes Tudeley a better site for a Garden Village than Horsmonden, not what is nothing more than an opinion, unsubstantiated by facts. Some facts for you to consider:
By contrast
The truth of the matter is that the only “exceptional circumstance the TWBC can honesty use to justify this plan is that there is a willing seller (the very wealthy landowner) whilst the multiple small landowners in Horsmonden will make it a much more laborious affair and will not line the pockets of the wealthy few again. I would also point out that there is a potential conflict of interest which should be made public. As I understand it the Leader and Deputy Leader of the Council both have personal interests in avoiding the garden settlement in Horsmonden due to the impact on their wards (they both represent Brenchley and Horsmonden). The Deputy Leader lives in Horsmonden at Swigs Hole Farm. |
DLP_133 | Gregg Newman | Object | The release of Green Belt described in this plan in Tudeley and East Capel is not justified in any way and is certainly not the result of “exceptional circumstances”. See my comments above The Green Belt Strategic Study commissioned by TWBC states that building houses at Tudeley and East Capel would cause the maximum level of harm possible to the Green Belt. In the face of this very damning assessment, how can you in all conscience claim this a justifiable plan? |
DLP_241 | Giles Kirby | STR 4 - Green Belt, Pages 92, 95, 99, 101, 105, 111, 115, I wish to raise some concerns with regards to your local planning policy. The National Planning Policy Framework (NPPF) under section 13 paragraph 136, states that the Green Belt “should only be altered under exceptional circumstances!” I fail to see how the destruction of the green belt and ancient woodland for the construction of housing is an exceptional circumstance when there are brownfield sites that could be used to facilitate some of the proposed housing. I am surprised that in this current climate with concerns regarding the climate, especially with the two week protest by extinction rebellion in London and other cities around the world, that the council plan to increase the carbon emissions by the destruction of the green belt and ancient woodland. It is also troubling that it appears the council want to build on every single playing field in the town and only replace it with a single sports hub that some people will not be able to get to easily. | |
DLP_7854 | Phillip Tew | Object | I do understand that the Borough is under Government pressure to free land for housing. However it needs to do it in such a way that minimises the impact on the environment and communities on a per house created basis. This then means that you should seek to build on Brownfield sites. This may be more expensive but what price is our environment. It is irreplaceable.I do not believe that you need to look further than Brownfield sites for your housing needs. Our Green Belt needs protecting for the good of the environment and for future generations who cannot make comments on your Draft New Local Plan as they have either not been born or are too young to do so. Once Green Belt land is built upon, it is lost forever. As residents, we should be relying on the Tunbridge Wells Borough Council to protect the Green Belt for us. Instead we find that you are planning on destroying it. The Council sought to act recently on its own development plans against the wishes of residents and received a bloody nose in the most recent local election. I think it would be unwise to do so again. Building should be confined to non Green Belt projects. Development should also be confined to significant projects ( many hundreds of houses/flats on a site ). Otherwise you cause huge disruption in each small site for frankly an almost imperceptible impact on the general housing situation. |
DLP_7934 | Wendy Owen | Object | “The release of Green Belt land has been undertaken through this Local Plan, and is detailed where relevant in the place shaping policies in Section 5. |
DLP_505 | Allyson Spicer | Object | It has been brought to my attention that Royal Tunbridge Wells Council is attempting to ignore a significant part of the current version of the National Planning Policy Framework (Item 13 - paragraphs 133-47) over protection of the Green Belt! It’s clearly unacceptable to ignore parts of the NPPF, and I would urge the Council NOT to allocate green belt for housing. You will have to provide substantial evidence to support such a blatant disregard for the NPPF, and that there is NO LAND OF LESSER VALUE! Whilst I am not a resident in Royal Tunbridge Wells, I am not aware of any restrictions that would bar my comments from being included in your consultation. I object most strongly to the inclusion of Green Belt for housing. |
DLP_8106 | Ashley Saunders | Object | The release of Green Belt described in this plan in Tudeley and East Capel is not justified in any way and is certainly not the result of “exceptional circumstances”. See our comments above re Section 4 para 4.5 The Green Belt Strategic Study commissioned by TWBC states that building houses at Tudeley and East Capel would cause the maximum level of harm possible to the Green Belt. CPC believe that there is a suitable alternative site for the Tudeley development outside the Green Belt (for example in Horsmonden) and the East Capel development is not required to expand Paddock Wood. In the commentary from paragraph 4.49 (p.49), you state that “the Council considers that there are the exceptional circumstances to alter the boundaries of the Green Belt to remove land from the designation for the proposed development at Tudeley Village, land at Capel and Paddock Wood […] Overall, some 5.35% of the Green Belt within the borough is being de-designated” I do not believe the exceptional circumstances exist to justify releasing land from the Green Belt in Tudeley and East Capel. As you will see from our comments on the Sustainability Appraisal, options for the expansion of Paddock Wood need not include East Capel. The release of Green Belt for Tudeley New Town (AL / CA 1) is totally unjustifiable. The 1,900 houses delivered there in this plan period are either not required by TWBC (who can easily reduce their plan to provide 13,560 rather than 14,776 new houses) or can be provided elsewhere outside of the Green Belt and AONB (for example at Horsmonden or Frittenden). Innovative use of Brownfield sites may also provide the housing that TWBC would like to provide by removing 400 acres from the Green Belt in Tudeley (AL / CA 1) plus another over 200 in East Capel (AL / CA 3). 5.35% of the land is being ‘de-designated’ (by which the plan means removed) from the Green Belt. But this is disproportionately concentrated in Capel parish where it will have a huge impact on the community and lead to the convergence of settlements. One of the main reasons for the Green Belt in the first place. Comments on paragraph 4.50 (p.49) You state that the Distribution of Development Topic Paper (which draws on the Green Belt Strategy Study) provides evidence and justification to release land from the Green Belt at Tudeley (AL / CA 1). This is not true. There is no evidence that makes Tudeley a better site for a Garden Village than Horsmonden (Site 144). The justification for not placing a garden settlement at Horsmonden is that “This would be a very large scale strategic allocation that would be disproportionate to the size of the settlement, with concern about landscape and heritage”. Tudeley is a tiny hamlet. It has 50 houses at most. The whole of the Parish of Capel has only 950 houses in it. Adding 2,800 new houses at Tudeley is a massive increase that is far higher than the proportional increase at Horsmonden. Tudeley is home to a world renowned heritage asset – All Saints Church. The only church in the entire world to have a complete set of stained glass windows designed by the renowned artist Marc Chagall. There is no equivalent heritage asset at Horsmonden. The proposal at AL / CA 2 would also impinge on the views from and towards Somerhill a Grade 1 listed building. Tudeley has a beautiful, rolling landscape with abundant wildlife, fertile soil and high biodiversity scores. It is entirely within the Green Belt and the High Weald AONB is within a few yards of the proposed development site. You state that Horsmonden has severe access difficulties. The access difficulties on the B2017 and Hartlake Road are at least as severe and the impact of the extra traffic on Tonbridge’s overloaded road infrastructure will have severe impact there too. Capel Parish Council does not believe exceptional circumstances exist to justify building at Tudeley rather than Horsmonden. The only argument presented anywhere is that Tudeley has a single landowner and Horsmonden has multiple landowners. TWBC’s reluctance to deal with multiple landowners is not an “exceptional circumstance”. The Capel Parish SHEELA states there will be compensatory Green Belt elsewhere in the Borough. This is clearly not the case. I deplore the loss of MGB as a result of this plan. |
DLP_8160 | Myriam Ruelle | Object | Section 4, paragraph 4.49: strongly object. As previously stated: THERE ARE NO EXCEPTIONAL CIRCUMSTANCES TO JUSTIFY BUILDING ON GREEN BELT! |
DLP_8195 | Mrs Suzi Rich | Object | This strategy states that “The release of Green Belt land has been undertaken through this Local Plan, and is detailed where relevant in the place shaping policies in Section 5” The Green Belt Strategic Study commissioned by TWBC states that building houses at Tudeley and East Capel would cause the maximum level of harm possible to the Green Belt. [TWBC: See comments DLP_8189-8214 for full representation] |
DLP_8209 | Home Builders Federation | Thank you for consulting the Home Builders Federation (HBF) on the draft Local Plan. The HBF is the principal representative body of the housebuilding industry in England and Wales and our representations reflect the views of discussions with our membership of national and multinational corporations through to regional developers and small local housebuilders. Our members account for over 80% of all new housing built in England and Wales in any one year. Outlined below are our comments on the approach taken by the Council to increasing the supply of land for residential development and the policies being proposed with regard to the management of new development in future. STR4 – Green Belt | |
DLP_8332 | Andrew Richards | Object | INTRODUCTION I am not a resident of Tunbridge Wells Borough, but I live near to the Borough boundary just outside Tonbridge. I visit the Borough regularly and enjoy the benefits of its countryside, notably the Green Belt and the Areas of Outstanding Natural Beauty, which need to be preserved in line with National Planning Policy. I also drive around Tonbridge regularly and am shocked at the impact the proposals in your draft Local Plan (LP) would have on Tonbridge and its environs. The LP is vast and complex and has clearly consumed a significant amount of effort; I congratulate the officers for their diligence in seeking to balance the various competing demands of policy, legislation and local constraints. As a private individual I do not have similar resources or expertise; I have therefore confined my comments to a small number of topics. This is not to say I endorse the remainder of the LP and its associated material; I am aware of some of the concerns raised by others and support many of them. Notwithstanding the level of effort that has gone into the LP, I’m afraid my overall assessment is that the Borough has fallen short of the diligence needed. Sadly, it seems to have taken the easy way out of its obligations in a number of areas. It has:
I conclude that the Borough has failed to meet the required standard for a Regulation 18 consultation and should repeat the exercise, having first addressed some of the fundamental concerns raised. I believe this plan requires too substantial a series of amendments to proceed directly to a Regulation 19 consultation. My comments are in relation to a number of documents identified below. Policy STR 4 – Green Belt 35. I object to strategy STR 4, which is weak and takes the easy way out. It relies on provisions such as “they should set out ways I which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land” (NPPF 138), without considering the more challenging but responsible alternative of expanding areas of Green Belt elsewhere. Conclusion 39. In conclusion, to reiterate the point made in opening, I conclude that the Borough has failed to meet the required standard for a Regulation 18 consultation. It should therefore repeat the exercise, having first addressed some of the fundamental concerns raised. [TWBC: See full representation] |
DLP_859 | Ian Pattenden | Object | Comments on Policy STR 4 (Green Belt) p.42 The release of Green Belt described in this plan in Tudeley and East Capel is not justified in any way and is certainly not the result of “exceptional circumstances”. See comments above re Section 4 para 4.5 [TWBC: DLP_858] The Green Belt Strategic Study commissioned by TWBC states that building houses at Tudeley and East Capel would cause the maximum level of harm possible to the Green Belt. There is a suitable alternative site for the Tudeley development outside of the Green Belt (in Horsmonden or NE of the Borough near Frittenden – both outside of the Green Belt (and AONB)) and the East Capel development is not required to expand Paddock Wood. |
DLP_913 | Nigel Stratton | Object | Once Green Belt is lost, the reality is that it will never be replaced either at all or satisfactorily. There must be a presumption against building in the Green Belt and alternative land needs to be found. |
DLP_1032 | Mr John Hurst | Object | Policy STR4 - Green Belt 1. There is no justification for using any Green Belt land. The NPPF guidelines say it should only be used in "exceptional circumstances" which these are not. A recent (public) letter of 2 Oct from Housing Minister Esther McVey to Broxstowe Council underlined the obligation to use brownfield opportunities first before considering Green Belt incursion. The TWBC website's 2019 Brownfield Register is little different from the 2017 version, indicating there has been little attempt to identify the potential. TWBC should produce a thorough and up-to-date brownfield sites analysis before proposing to use the Green Belt - otherwise it will fail at the Planning Inspectorate review. 2. In the light of the 14 July declared Climate Emergency, TWBC should be making efforts to further green its area - including the Green Belt - not concrete over valuable areas that could better now be re-forested. |
DLP_2201 | Mr Terry Cload | Support with conditions | STR4 If we have to lose some of our irreplaceable countryside currently designated as MGB then the remainder as shown on the proposals map should be protected for the duration of the plan full stop and not be subject to any current or future NPPF or national planning policies. |
DLP_3673 | Capel Parish Council | Object | The release of Green Belt described in this plan in Tudeley and East Capel is not justified in any way and is certainly not the result of “exceptional circumstances”. See our comments above re Section 4 para 4.5 The Green Belt Strategic Study commissioned by TWBC states that building houses at Tudeley and East Capel would cause the maximum level of harm possible to the Green Belt. CPC believe that there is a suitable alternative site for the Tudeley development outside the Green Belt (for example in Horsmonden) and the East Capel development is not required to expand Paddock Wood. In the commentary from paragraph 4.49 (p.49), you state that “the Council considers that there are the exceptional circumstances to alter the boundaries of the Green Belt to remove land from the designation for the proposed development at Tudeley Village, land at Capel and Paddock Wood […] Overall, some 5.35% of the Green Belt within the borough is being de-designated” Capel Parish Council does not believe the exceptional circumstances exist to justify releasing land from the Green Belt in Tudeley and East Capel. As you will see from our comments on the Sustainability Appraisal, options for the expansion of Paddock Wood need not include East Capel. The release of Green Belt for Tudeley New Town (AL / CA 1) is totally unjustifiable. The 1,900 houses delivered there in this plan period are either not required by TWBC (who can easily reduce their plan to provide 13,560 rather than 14,776 new houses) or can be provided elsewhere outside of the Green Belt and AONB (for example at Horsmonden or Frittenden). Innovative use of Brownfield sites may also provide the housing that TWBC would like to provide by removing 400 acres from the Green Belt in Tudeley (AL / CA 1) plus another over 200 in East Capel (AL / CA 3). 5.35% of the land is being ‘de-designated’ (by which the plan means removed) from the Green Belt. But this is disproportionately concentrated in Capel parish where it will have a huge impact on the community and lead to the convergence of settlements. One of the main reasons for the Green Belt in the first place. Comments on paragraph 4.50 (p.49) You state that the Distribution of Development Topic Paper (which draws on the Green Belt Strategy Study) provides evidence and justification to release land from the Green Belt at Tudeley (AL / CA 1). This is not true. There is no evidence that makes Tudeley a better site for a Garden Village than Horsmonden (Site 144). The justification for not placing a garden settlement at Horsmonden is that “This would be a very large scale strategic allocation that would be disproportionate to the size of the settlement, with concern about landscape and heritage”. Tudeley is a tiny hamlet. It has 50 houses at most. The whole of the Parish of Capel has only 950 houses in it. Adding 2,800 new houses at Tudeley is a massive increase that is far higher than the proportional increase would be elsewhere in the Borough. Tudeley is home to a world renowned heritage asset – All Saints Church. The only church in the entire world to have a complete set of stained glass windows designed by the renowned artist Marc Chagall. There is no equivalent heritage asset at Horsmonden. The proposal at AL / CA 2 would also impinge on the views from and towards Somerhill a Grade 1 listed building. Tudeley has a beautiful, rolling landscape with abundant wildlife, fertile soil and high biodiversity scores. It is entirely within the Green Belt and the High Weald AONB is within a few yards of the proposed development site. You state that Horsmonden, for example, has severe access difficulties. The access difficulties on the B2017 and Hartlake Road are at least as severe and the impact of the extra traffic on Tonbridge’s overloaded road infrastructure will have severe impact there too. Capel Parish Council does not believe exceptional circumstances exist to justify building at Tudeley. The only argument presented anywhere is that Tudeley has a single landowner and other sites multiple landowners. TWBC’s reluctance to deal with multiple landowners is not an “exceptional circumstance”. The Capel Parish SHEELA states there will be compensatory Green Belt elsewhere in the Borough. This is clearly not the case. Capel Parish Council deplores the loss of MGB as a result of this plan. |
DLP_1892 | Royal Tunbridge Wells Town Forum | Policy STR 4 Green Belt The release of Green Belt land around RTW should only occur in exceptional circumstances but may prove legally impossible to avoid altogether given the targets for development imposed by the Central Government. Insofar as releases of Green Belt do prove unavoidable to meet Plan objectives, we favour an approach that results in the release of the least damaging parcels of land in landscape, heritage and nature/wildlife conservation terms, taking full account of the evidence base. In that context we strongly support the Council’s decisions against allocation of the most damaging sites as set out in Appendix 6. If there should be any change in government policy, or developments in interpretation of the NPPF provisions, prior to the Regulation 19 Draft going out to consultation, we hope that a review of the proposed releases from Green Belt would take place, in case they may be minimised further. With regard to remaining Green Belt land, the proposed policy that the Council will merely “consider” a development proposal in the remaining Green Belt against GB policy in the NPPF seem weak and should be strengthened to the maximum extent which can be upheld at Examination. The present wording contrasts with the aspiration to “enhance” remaining Green Belt expressed elsewhere in the Draft. | |
DLP_2724 | St. John's Road Residents association | Support with conditions | STR 4 Release of Green Belt As already recognised in the NPPF, green belt land is to be respected and should not be built upon only upon exceptional circumstances. Paragraph 2.40-2.44 mentions the constraints that Green Belt and AONB imposes but due regard must be paid to 2.10 of the balancing effect of landscape which we need to value in terms of tourism and environmental benefits, not least of which is air quality and flood defences. |
DLP_2011 | Dr David Parrish | Object | Section 4 Paragraph 4.49 (The Green Belt) p.49 There no Exceptional Circumstances referred to. They do not exist to justify releasing any land from the Green Belt in Tudeley and East Capel. TWBC’s own assessment of the “broad areas” in which all the Capel Parish sites lie is that there is a very strong case against allowing any land within them to be withdrawn from the Green Belt. This is based on reports commission by TWBC from “Land Use Consultants Ltd” in 2016 and 2017. A contradiction due to poor planning? There is no evidence to release Green Belt land justifiably? The LP states that the Distribution of Development Topic Paper (which draws on the Green Belt Strategy Study) provides evidence and justification to release land from the Green Belt at Tudeley. This is not true. There is no evidence that makes Tudeley a better site for a Garden Village than Horsmonden. The justification for not placing a garden settlement at Horsmonden is that “This would be a very large scale strategic allocation that would be disproportionate to the size of the settlement, with concern about landscape and heritage”. Tudeley is a tiny hamlet. It has 50 houses at most. The whole of the Parish of Capel has only 950 houses in it. Adding 2,800 new houses at Tudeley is a massive increase that is far higher than the proportional increase at Horsmonden. Another Contradiction TWBC’s reluctance to deal with multiple landowners is not an “exceptional circumstance”. Leading to a garden village planned at Tudeley. I would like to ask if the Leader and Deputy Leader of the Council both have personal interests in keeping the garden settlement out of Horsmonden due to the impact on their wards (they represent Brenchley and Horsmonden). Policy STR 4 (Green Belt) p.42 The plan will allow building where maximum harm to the Green Belt is already acknowledged by TWBC The Green Belt Strategic Study commissioned by TWBC states that building houses at Tudeley and East Capel would cause the maximum level of harm possible to the Green Belt. There is a suitable alternative site for the Tudeley development outside of the Green Belt (i.e. in Horsmonden) and the East Capel development is not required to expand Paddock Wood. Another Contradiction |
DLP_1614 | Maggie Fenton | Section 4 Paragraph 4.50 (The Green Belt) p.49 You state that the Distribution of Development Topic Paper (which draws on the Green Belt Strategy Study) provides evidence and justification to release land from the Green Belt at Tudeley. This is not true. There is no evidence that makes Tudeley a better site for a Garden Village than Horsmonden or Frittenden. The justification for not placing a garden settlement at Horsmonden is that “This would be a very large scale strategic allocation that would be disproportionate to the size of the settlement, with concern about landscape and heritage”. Tudeley is a tiny hamlet. It has 50 houses at most. The whole of the Parish of Capel has only 950 houses in it. Adding 2,800 new houses at Tudeley is a massive increase that is far higher than the proportional increase at Horsmonden. Tudeley is home to a world renowned heritage asset – All Saints Church. The only church in the entire world to have a complete set of stained glass windows designed by the renowned artist Marc Chagall. The only heritage asset at Horsmonden is a gun foundry, with a model of a cannon that was made in the village. Not exactly world-renowned. Tudeley has a beautiful, rolling landscape with abundant wildlife, fertile soil and high biodiversity scores. It is entirely within the Green Belt and the High Weald AONB is within a few yards of the proposed development site. You state that Horsmonden has severe access difficulties. The access difficulties at Horsmonden pale in to insignificance when you look at the access difficulties on the B2017 and Hartlake Road. You do not have the exceptional circumstances required to justify building at Tudeley rather than Horsmonden. The only argument presented anywhere is that Tudeley has a single landowner and Horsmonden has multiple landowners. TWBC’s reluctance to deal with multiple landowners is not an “exceptional circumstance”. Strategic Objective 4 (Green Belt) p.50 The release of Green Belt described in this plan in Tudeley and East Capel is not justified in any way and cannot be classed as “exceptional circumstances”. The Green Belt Strategic Study commissioned by TWBC states that building houses at Tudeley and East Capel would cause the maximum level of harm possible to the Green Belt. There is a suitable alternative site for the Tudeley development outside of the Green Belt (in Horsmonden) and the East Capel development is not required to expand Paddock Wood. | |
DLP_2166 | Mr Don Kent | Object | The boundary between Capel and Paddock Wood along Badsell road should be retained with a green wedge as there will be no dividing line between both councils. The divide should be where the east Peckham paddock wood bypass is, it would be the most logical and give a defining line between both councils. If not then a large field between the old peoples bungalows in Paddock Wood and the farmhouse FUTHER down towards Five Oak Green on the Badsell road would need to be retained or you will have a sign we coming you to Paddock Wood on one side of the road and on the other side welcome to Five Oak Green which will look silly. Furthermore the house rates would go to Capel but the residents would effect Paddock Wood. |
DLP_2036 | Terry Everest | Object | Green Belt must be protected not developed, it must not be developed and destroyed. These areas are vital for the environment, wildlife and people alike and certainly should not be sacrificed just to meet arbitrary government targets or line the pockets of developers. |
DLP_1776 | CPRE Kent | Object | With 5.35% of green belt in the borough being released for development (and additional green belt land being built on), CPRE Kent is concerned that the Council does not intend to designate additional land as replacement green belt – and seeks clarification as to why this is. Assurances are also sought as to how compensatory improvements to environmental quality and accessibility of the remaining green belt will actually be delivered. There are a number of site allocations for development which are NOT being released from the green belt, which means that a higher percentage of green belt land will be developed. This policy should set out rationale for sites remaining within the green belt. While there is some detail set out in the Distribution of Development topic paper it would improve transparency/objectivity if this reasoning was set out within the local plan itself. Where land remains washed over by green belt, the green belt policies of the NPPF will still apply. Therefore, this policy should set out that permitted development rights will be removed in the interests of safeguarding the green belt from inappropriate development. |
DLP_1376 | Mr and Mrs Leach | Object | Re: Draft Local Plan (Regulation 18 Consultation) - Adjoining Resident Comment It was good to meet you at the SaveCapel Public Meeting, on 18th September 2019. We wish to comment on the Draft Local Plan (LP), in relation to certain policies outlined under the headings stated below. We are specifically concerned about the negative impacts of the proposed garden villages will have to our town, especially without adequate public transport provisions, and with such a large loss of the countryside and Green Belt. 3. Policy STR 4 - Green Belt We do not believe that the first part of this Policy would be required, if alternative sites (outside this belt) originally put forward earlier in the process were taken forward instead of the massive village expansions within Capel parish and the Green Belt. As noted in Section 2, we do not believe that the Draft Local Plan is currently sound, with alternative sites available. In addition, to the comments made in Section 2, further points are raised as follows: 3.1 With regard to Green Belt Strategic Study and Sustainability Appraisal, both of these documents recognise the impact of such the substantial losses of the Green Belt. The later states that building houses at Tudeley and East Capel would cause the maximum level of harm possible to the Green Belt. 3.2 The release of teh countryside for developments, by definition, is harmful to the Green Belt and should not be considered sound, as exceptional circumstances do not exist. In conclusion, we do not consider that the Draft Local Plan is sound, in relation to the proposed large garden settlements, with inadequate infrastructure connecting nearby towns. The current proposal for such a substantial loss of the Green Belt and countryside, as part the massive village expansions, is not sustainable development and nor is it consistent with National planning policy. This will cause immense environmental harm, including a heavy reliance on car use with poor public transport links. The justification for building on the Green Belt is unsound, as there are alternative brownfield and non-Green belt sites available. We are also concerned about the deliverability of the Draft Local Plan, with the local market saturation of nearly 6,000 new houses allocated for two nearby villages within one local area. In light of these concerns and the potentially flawed approach in favouring Green Belt development, over other suitable sites and as no exceptional circumstances exist, alternative sites should be considered. A more sustainable development approach might be to spread the allocation across the Borough, reducing the concentrated development pressures and local market saturation, whilst helping to unlock the greatest amount of brownfield re-development. |
DLP_2447 | Tracy Belton | Object | STR4 How can you say that you will protect the remaining green belt when the green belt as it currently stands can simply be redefined when required to allow for building. On this basis, it seems the green belt can just be redefined as and when land is required for building, so the idea of protecting it seems to be a complete nonsense! |
DLP_2873 | Chris Gow | Object | Green Belt land is designed, as identified in Paragraph 4.48, to allow green open space for amenity for local residents, visitors and the general population. Green belt land provides location for trees, shrubs and vegetation to grow and provide a mechanism for some control of CO2 gasses, which make a significant contribution to combating global warming. The preservation of Green belt land is therefore essential for the well being of residents, providing space for leisure activities, prosper well being for residents, and help the fight against global warming, and climate change. The council has signed up to a committent to the climate emergency, and the council is pledged to taking action. Opposing the use of green belt land would be a clear commitment to this aim and demonstrate a serious approach to climate change emergency. These reasons completely justify a total ban on any green belt land being released for development. |
DLP_2874 | Chris Gow | Object | I object to this policy. Green Belt land must not be used for development under any circumstances. Green Belt land is designed, as identified in Paragraph 4.48, to allow green open space for amenity for local residents, visitors and the general population. Green belt land provides location for trees, shrubs and vegetation to grow and provide a mechanism for some control of CO2 gasses, which make a significant contribution to combating global warming. The preservation of Green belt land is therefore essential for the well being of residents, providing space for leisure activities, prosper well being for residents, and help the fight against global warming, and climate change. |
DLP_2121 | Robert Tillotson | Object | STR4 STR4. If we begin to make significant exceptions,as this plan does to build on Green Field land and Areas of Outstanding natural beauty,then it will all be lost in a generation. Precedent will have been set and a policy that has served us well for over 60 years will be undone and our landscape changed and messed up permanently. The housing target figures in the plan need challenging. These targets are from a Government (the latest)to fail to build houses over the last decade. It’s latest plan which cost tax payers millions of pounds failed to deliver even ONE affordable home,which must be a new record. Yes we need new homes,but for whom? New home owners,young people, and low income groups for sure. And what are we building in Kent? And who for? We know the answer. So,before we generate massive plans such as this we should decide again what the strategies objective really is. It should not be to build more over priced,non carbon neutral,fault ridden estates that the house building industry has got rich on. Let’s get to the real number of needed houses for those that really need them,an see then what land is required,and where. As a radica suggestion examine Retail Space again. In the last version of this plan,retail space was seen to expand at a linear rate as in the past. Heard of Amazon and Internet Shopping? Instead of continuous failed endeavours at reviving our High Streets let’s look at this core space which is huge to regenerate these buildings for accommodation,plus some retail. This would be keep town centres alive,”save” the high street,reduce the need for new services versus greenfield builds,and reduce transport costs and pollution. This current submittedplan will see continued central high street decline and generate high environmental and other social costs. Add up you current Blighted High Street space in the Borough,which will increase over the planning period and work out how many homes could be created here with clever planning and development. |
DLP_2424 | Peter Avgherinos | General Observation | STR4 - GREEN BELT In the criteria for evaluating sites within current Green Belt that could be re-classified to allow development, there is reference to considering natural features at boundaries between Green Belt and the adjacent settlements. I do not disagree at all with that concept. However, it is important that these features are not such as to prevent the appreciation of the Green Belt from the settlements, notably by blocking the vista. My attention is drawn to the division of site SO1 into parts 1a and 1b, as ancient woodland occurs along part of the boundary drawn between these new zones. There is then a reference to enhancing the separation of these zones by extending the wooded area along the remainder of the boundary. Since a major consequence of such an extension would be the separation of the settlement from the vista this proposal should continue to be rejected. |
DLP_2646 | John Duffy | Object | There is far to great a proposed release of MGB land around Pembury for what is a wholly unsustainable amount of housing placed upon insufficient and already over subscribed infrastructure and local services. |
DLP_2772 | Andrea Cox | Object | Policy STR 4 Green Belt The 2019 National Planning Policy Framework (NPPF) states that "A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt" (National Planning Policy Framework February 2019. 145. p 42) The draft local plan produced by Tunbridge Wells Borough Council seems to have total disregard for the purpose of Green Belt land. The building of 2,800 homes in Tudeley and 4000 homes in Capel/Paddock Wood does not take into consideration the need to protect the Green Belt. The NPPF states that the exceptions to building being inappropriate in the Green Belt include (145: e) "limited infilling in villages". The proposals for Tudeley are not "limited" nor simply filling in the village with a few houses. The building of a smaller number of dwellings in Southborough and Pembury seems more appropriate and in line with the NPPF policy. The Green Belt is there for a purpose - to prevent widespread urban growth. Tunbridge Wells Borough Council seem to have forgotten their responsibilities to maintain the integrity of the Green Belt for the health and well being of ourselves and future generations. Whilst there is indeed a need for more housing this should be met through using brownfield sites and infilling areas that are already built up. The Green Belt is there to protect us and should not be trampled on in the way this draft local plan proposes. |
DLP_2835 | Helen Parrish | Object | Section 4 Paragraph 4.49 (The Green Belt) p.49 There no Exceptional Circumstances referred to. They do not exist to justify releasing any land from the Green Belt in Tudeley and East Capel. Section 4 Paragraph 4.50 (The Green Belt) p.49 There is no evidence to release Green Belt land justifiably? Policy STR 4 (Green Belt) p.42 The plan will allow building where maximum harm to the Green Belt is already acknowledged by TWBC |
DLP_3172 | Kent County Council (Growth, Environment and Transport) | Highways and Transportation The Local Highway Authority does not have any comment on this policy. | |
DLP_4358 | British Horse Society | General Observation | Para 4.50 General observation The compensatory improvements to the accessibility of remaining Green Belt land should include the provision of a network of new public bridleways. The landowners of much of the Green Belt land at Tudeley and Southborough that is to be built on under this draft Plan have in the past been sympathetic to horse riders’ needs and have provided some permissive horse riding routes, but these can be lost at any time so they are not a suitable compensation for the permanent loss of Green Belt land. Therefore any new horse riding routes need to be secured in perpetuity through the creation of public bridleways and restricted byways or of riding routes in public open spaces. |
DLP_3912 | IDE Planning for Paddock Wood Town Council | Object | OBJECT as per STR1 |
DLP_6034 | Mr C Mackonochie | Object | Policy Number: STR4 No mention is made of using Green Belt or Green Spaces in the future to prevent specifically Tonbridge, Tudeley, Five Oak Green, Paddock Wood, Southborough and Tunbridge Wells coalescing into one large city; the above mentioned places then becoming suburbs |
DLP_4882 | Berkeley Strategic Land Ltd | Policy STR 4 – Green Belt Our independent assessment of the Green Belt contained within Land at Tutty's Farm, in summary, established the following ratings: -
Detrimental harm that could result from the release of the Land at Tuttys Farm was assessed as Low. 5.11 It is our opinion that the Council should re-evaluate Tutty’s Farms contribution to the Green Belt as Low combined with the need to meet their housing requirement, its sustainable location and the benefits that the development can deliver mean that exceptional circumstances exist for the removal of the site from the Green Belt. As such combined with the already identified housing shortfall and the sites suitability the site should be included as an allocation within the Local Plan. | |
DLP_5222 | Culverden Residents Association | Object | We seriously regret the proposed loss of any Green Belt land around Tunbridge Wells and elsewhere. We understand this may be unavoidable to meet excessive housing targets set by the Government but hope that the extent of loss may still be minimised. In the present unsatisfactory circumstances, it seems important to prioritise use of the least damaging parcels of land in landscape and nature/wildlife conservation terms and in terms of not adding to urban pollution. We note that this seems to have been the approach taken to our specific local area proposed by TWBC in line with the resolution passed at our 2017 AGM: “The Culverden Residents Association is opposed to any change in local green belt boundaries which would allow sprawling suburban development with inevitable increases in traffic, noise and pollution in our area.” but we regret that any Green Belt land should be taken elsewhere. |
DLP_4641 | CBRE Ltd for Dandara Ltd | 3.7 Dandara also welcomes TWBC’s approach to releasing appropriate land from the Green Belt, where there are exceptional circumstances to justify release of the above-mentioned sites for reasons which include the delivery of new housing in sustainable locations, providing new educational facilities, facilitating wider economic growth through a plan-led approach, and increasing public accessibility to it, as well as ensuring development protects the openness of remaining Green Belt land. 3.8 A summary of the exceptional circumstances as set out in TWBC’s Distribution of Development Topic Paper for Draft Local Plan Regulation 18 Consultation (September 2019) for each of the sites Dandara holds a specific land interest in are set out below:
3.9 Dandara considers that the above reasons are in accordance with paragraphs 135 and 136 of the NPPF insofar as these sites demonstrate exceptional circumstances – and therefore sound reasoning – exist to justify the amendments to Green Belt boundaries and release of Green Belt land for housing and new educational facilities. 3.10 Dandara also considers TWBC’s Green Belt Study (Stages 1 and 2) to be a thorough and robust report. The methodology and coverage of the Study are also considered to be sound. [TWBC: see page 7 offull representation]. | |
DLP_4661 | CBRE Ltd for Dandara Ltd | Support with conditions | Draft Local Plan Policy STR4: ‘Green Belt’ 3.51 Dandara supports the controlled release of land from the Green Belt through the Draft Local Plan under Policy STR4, in the interests of delivering much needed housing but only where exceptional circumstances are fully evidenced and justified in accordance with paragraph 136 of the NPPF. The need to change Green Belt boundaries has to be dealt with through strategic policies within the Draft Local Plan in accordance with paragraphs 135 – 136 of the NPPF. 3.52 Dandara suggests the wording of this policy should reference the need to demonstrate exceptional circumstances and the importance of ensuring development does not cause substantial harm to the openness of retained Green Belt land, to reflect the NPPF. 3.53 Dandara further highlights that TWBC need to be satisfied that any exceptional circumstance evidence is suitably robust to meet the requirements of the NPPF. It is also accepted that all applications affecting the Green Belt must adhere to the specific policy tests set out in the NPPF (paragraphs 133 -147). [TWBC: see full representation]. |
DLP_4468 | Paddock Wood Neighbourhood Plan Steering Group | Object | Objection is made to the proposed loss of green belt to the west of the town. Ref. paras. 4.47 to 4.52: it had previously been discussed that green belt would be allocated to the east of Paddock Wood to prevent coalescence in the east (with Marden, Horsmonden or Brenchley) – this is essential to prevent loss of the identity of the town and surrounding parishes and the protect the heritage and unique nature of small hamlets such as those at Old Hay & Pearsons Green. The principle of green wedges outlined in the Neighbourhood Plan are essential to retain the rural feel of the town. |
DLP_4317 | Kember Loudon Williams for Kent College Pembury | Object | We represent Kent College, Pembury and who are part of the Methodist Independent Schools Trust. The college is based on a site within the Metropolitan Green Belt. Kent College is an all girls school which caters for students from early years through to sixth form. (ages 3 to 18). It is an independent school, including boarding, catering for over 500 students. It is located just to the north of Pembury and the A228 off Old Church Road. The site comprises a significant number of school buildings surrounding a Victorian Mansion House, including classrooms, sixth form centre, library, swimming pool, studios and school playing facilities including tennis courts and an all weather pitches. The school is extremely successful and a valued organisation locally employing 234 individuals. Within the Adopted Local Plan 2006 the Kent College, Pembury site had been identified under Policy MGB2 as a ‘major developed site within the Metropolitan Green Belt’. This policy identified previously developed land as locations where limited infilling or complete and / or partial redevelopment was considered acceptable. The policy defined a boundary within which this type of development was considered appropriate. Policy MGB2 included a variety of criteria to enable planning applications to be judged and these included: Seeking to ensure that new development did not adversely impact on the openness or visual amenity of the Metropolitan Green Belt; did not exceed the height of any existing buildings; did not result in a major increase in the developed parts of the defined area; and sought a similar footprint to the buildings to be replaced unless there were other benefits such as a reduction in height. The Draft Local Plan (Regulation 18 Consultation Draft) 2019 does not include a similar Policy. Draft Policy STR4 sets out a protectionist stance towards the Green belt unless land is released by other planning policies for the purposes of development. Draft Policy STR4 refers to the National Planning Policy Framework and explains that this will be used when determining proposals affecting the Metropolitan Green Belt. The National Planning Policy Framework (NPPF) includes a variety of planning policy paragraphs concerned with protecting the Green Belt. New buildings are considered to be inappropriate forms of development within the Green Belt. However, Paragraph 145 sets out the exceptions to this policy approach. Those relevant to Kent College, Pembury are: Criterion b) provides for an exception if the building is for outdoor sport or recreation which does not harm openness. Criterion c) allows the extension or alteration of a building provided it does not result in disproportionate additions over and above the size of the original building. Criterion d) allows the replacement of buildings where they are in the same use and not materially larger and criterion g) which allows limited infilling, partial or complete redevelopment of previously developed land (excluding temporary buildings) provided they would not have a greater impact on the openness of the Green Belt than the existing. The Council appear to be content to allow the NPPF to guide future proposals and this seems to be the reason for not including a policy similar to MGB2 in the adopted Local Plan. However, Kent College, Pembury feel that this is not an appropriate policy approach for a number of reasons. Firstly, paragraph 145 contains a variety of policy advice ranging from extensions and alterations that are not disproportionate, replacements which are not materially larger and limited infilling which has no greater impact on openness. The criteria mean slightly different things and for a large organisation like Kent College, Pembury it would be important for them to be able to understand the approach the Council would take to these different criteria. Secondly, it is important for Kent College, Pembury to understand the boundary of the previously developed land that is referenced in the NPPF. They need to understand its extent and want to be assured that the master plan which they prepared several years ago, and which the Council has used in recent planning applications, remains relevant. Often it is important for those funding the new development to have certainty that the site is consistent with the various policy sections of paragraph 145. As a result, Kent College, Pembury are seeking the inclusion of a new policy or an adjunct to Policy STR4 to list those sites which are considered to fall within the advice of paragraph 145 of NPPF, together with a set of criteria to help provide guidance for new development and a Plan identifying the extent of the previously developed part of the site. The NPPF does not prevent or guide against such an approach and it remains within the gift of the Council to include such a policy. Given the status of the school and many other similar sites, it would be important to have a clear and unambiguous policy approach. In relation to the last matter we note that the on-line Proposals Map for Policy MGB2 is not accurate and a new assessment of the previously developed land area must be undertaken. We note that some temporary buildings and classrooms have been on site for many decades and our initial review suggests that some of these portacabin classrooms to the northwest of the site have existed for over 25 years but without any recent planning permission. Location plan 502/Location B submitted under application TW/05/00604/FUL identifies these buildings. Consequently, the previously developed land boundary ought to reflect a slightly larger area than is currently shown. |
DLP_4407 | Alison Adams | Object | I am a resident of Horsmonden and have lived here for the last 6 years. During my time I have been the Chair of the local Horsmonden Kindergarten and I have been very busy renovating my home and garden. I love living in this village with its community spirit and feel very involved and integrated in the society here. Although I appreciate that new housing is inevitable and do not object to sensitive and structured new building I am concerned greatly by the idea of large scale new development which does not take into account the requirements of the existing community or the actual requirements of the prospective purchasers of the homes. Horsmonden like most villages provides a mixture of housing and there are many residents living here who do not foresee living anywhere else. Houses however do come onto the market and at present there are a number in the village that have been up for sale for over a year. My question is therefore, how have the “powers that be” come up with the decision that we need to create 13,560 new homes (Para 4.7)? If we do need these homes I sincerely hope that the main priority is to create homes that will fulfil the specifications that these new prospective owners are looking for. In my view one of the biggest problems that we face is that large family homes continue to be occupied by parents well after their children have left, couples in their 60s, 70s and 80s are reluctant to downsize due to the lack of smaller but prestigious, spacious, convenient houses/apartments/bungalows that also offer attractive outside space. This creates a barrier to the upward movement of younger families who wish to gain more space. Space in the South East is at a premium so there needs to be some incentive to free up these family homes for the new generation. I would also like to be 100% certain that the companies that are employed to build all these new homes are actually controlled so that the new homes are good quality and sustainable with eco-friendly initiatives being used. Why is it not compulsory to have solar panels, permeable paving, grey water storage? All these design features are available and if every builder was enforced to use them there would be economies of scale so the price of these technologies would ultimately come down. In terms of the Consultation I would like to comment on the following: STR4 Policy – Point 7 Release Green Belt Nothing is sacred any more! Why do we allocate Green Belt land just to ignore its categorization when it suits us? We need to be looking, at the United Kingdom as a whole, when we consider all housing needs, there are many areas in other parts of the country that could be regenerated and developed to appeal to the new generation. This could alleviate the requirement for such large-scale development in the South East. The population density in Kent already culminates in traffic congestion, accidents and loss of landscape. With the concerns around climate change and mental health issues it seems the need for trees and green space is more important than ever. Building over Green Belt land is totally at odds with this? I appreciate the opportunity to comment and hope that the Borough Council will take into account the many and varied views of the people of the borough. Maybe building thousands of new homes will boost the economy in the short term but once built these homes cannot be removed so let’s hope there is a real demand and that the houses built actually satisfy that demand. |
DLP_5190 | Adam Marsh | Object | I consider the building on green belt land to to be an absolute disgrace! There was once a very good reason why building on green belt was not permitted. Does this no longer stand? I can appreciate the need for new housing, but to tear up our beautiful countryside seems abominable. Maybe you should consider the better options of brown field sites? Is it even legal to build on green belt? I strongly disagree with TWBC of even considering such a mammoth task and the detrimental destruction of our landscape. I would be interested in your veiws as to why you think it appropriate to build on green belt and not source brown field sites? |
DLP_5264 | Tunbridge Wells Friends of the Earth | Object | Policy Number: STR 4 Green Belt Object , Support with conditions We strongly object to any further new development in the Green Belt. All efforts should be made to safeguard substantial green spaces to help combat climate change, protect wildlife and nature, and enhance physical and mental wellbeing of people. Enhancing instead of reducing the Green Belt would also be in keeping with TWBC’s Climate Emergency Declaration last July. The NPPF (2019) guidelines follow Government policy on protecting the Green Belt to prevent urban sprawl by keeping land permanently open and it urges LPAs to maximise the use of suitable brownfield sites before considering changes to Green Belt boundaries. It also sets out the conditions that must be fulfilled for justifying ‘exceptional circumstances.’ It is our view that ‘exceptional circumstances’ are not demonstrated by the LPA in the draft Local Plan and that not enough has been done to prioritise future development on previously developed (brownfield) land. |
DLP_6863 | Barton Willmore for Crest Nicholson | iv) Policy STR4: Green Belt 5.20 We support TWBC’s approach as set out in its Green Belt Assessment (LUC, 2016 & 2017) and Distribution of Development Topic Paper (TWBC, Sept 2019). In addition to these two documents, and to support these representations by Crest, Crest has also commissioned a supplementary LVIA and Green Belt Review (BW Landscape, Nov 2019) in respect of land to the north and west of Paddock Wood. A copy of this is attached at Appendix 2. 5.21 We consider that Policy STR4 is “consistent” with National policy; it states clearly that proposals will be considered against the relevant policy in the NPPF. We note that in accordance with the NPPF (para 137) the Distribution of Development Topic Paper makes clear that the strategy for the distribution of development has sought to make optimal use of suitable brownfield sites and underutilised sites, particularly within the Limits to Built Development of settlements (para 6.22), before considering the release of Green Belt land. We therefore consider this policy to be justified and positively prepared, in that it is based on a proportionate, relevant and up-to-date evidence base comprising the Stage 1 and Stage 2 Green Belt Studies (2016/2017) and the Distribution of Development Topic Paper (TWBC, Sept 2019). [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_7246 | Mr John Telling | Object | The statement under para 4.48 'The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open to maintain the character of the Green Belt' is contradicted by the housing policy, particularly as it affects Ramslye, Capel, and Land at Mabledon and Nightingale. This is at odds with Policy STR 2 Presumption in favour of 'sustainable' development. |
DLP_7699 | Ms Christine Ferguson | Object | I would like to offer the following comments on the draft local plan for the Tunbridge Wells area: 1. The plan appears to rely heavily on building on land in the Green Belt and Areas of Outstanding Natural Beauty (AONB). My understanding is that this should be done only in exceptional circumstances. It is not clear to me, from the information provided in the plan, what the exceptional circumstances are and what efforts, if any, have been made to identify brownfield sites or sites that are outside the Green Belt or AONB. Could more information be provided on the basis for the building need figures? 2. It is also not clear why there is so much proposed building around rural villages which are ill equipped in terms of infrastructure to support so many additional homes and residents, rather than building around existing conurbations such as Tunbridge Wells itself, where residents would be able to access shops, services and entertainment. Much of the proposed building will add significantly to journeys undertaken by car in between rural areas and the main conurbations (to shop, get to work/the station, access entertainment etc (given the totally inadequate rural bus services). This seems to go directly against efforts to counter climate change impacts. |
DLP_7702 | Ms Christine Ferguson | Object | 4. As a Countryside Access Warden, I am particularly concerned about the impact on existing public rights of way and footpaths. I can see no assurances in the plan that these will be properly preserved. Can the Council comment on potential impact and how this will be mitigated? I hope these comments will be helpful in giving further consideration to the Local Plan. |
DLP_6772 | Mrs Carol Richards | Object | Policy STR4 (Green Belt) and preceding paras 4.47 – 4.52 The release of Green Belt for Tudeley New Town is totally unjustifiable. The 1,900 houses delivered there in this plan period are either not required by TWBC (who can easily reduce their plan to provide 13,560 (rather than 14,776 new houses) or they could be provided elsewhere outside of the Green Belt and AONB (for example at Horsmonden or Frittenden). Innovative use of Brownfield sites may also provide the housing that TWBC would like to provide but punching a massive, 400 acre hole in the Green Belt is not a ‘Plan’. The development described in this Local Plan will be contrary to the aims of the Green Belt, for example in terms of urban sprawl and coalescence of settlements. It will result in the development of highly valued countryside and the erosion of this buffer between settlements. “The impact of light pollution is particularly harmful in the open countryside, where rural character is eroded and the distinction between town and country is blurred; likewise, light pollution can also compromise the architectural and historical character of conservation areas, and listed buildings or their settings. The full effects of artificial lighting on biodiversity are not fully understood, but nocturnal animals can be seriously affected by artificial light at even very low levels, adversely affecting their ability to feed and reproduce.” TWBC seem to be ignoring their own rules in relation to the effect on wildlife in the flood plain below Tudeley. TWBC will be- by building above the flood plain- contributing to the loss of biodiversity and committing to NOT improve the natural environment. The exact opposite to para 6.123 which states: “The borough has a rich and diverse range of habitats and species, many of which are threatened or endangered, and there is a high density of woodland, much of which has been identified as ancient woodland. While the borough contains no international sites for conservation, there are numerous national, regional, and local sites representing a broad range of lowland habitats representative of the High and Low Weald landscapes.” The development will create noise and from both traffic and the trains speeding along the rail track, in contravention of EN 30 which states: “Residential and other noise sensitive development will only be permitted where it can be demonstrated that users and occupiers of the development will not be exposed to unacceptable noise disturbance from existing or proposed uses” TWBC’s own assessment of the “broad areas” in which all the Capel Parish sites lie is that there is a very strong case against allowing any land within them to be withdrawn from the Green Belt. This is based on reports commissioned by TWBC from “Land Use Consultants Ltd” in 2016 and 2017. Under the EN 20 (Rural Landscape), development will be required to: 1. Conserve and enhance the unique and diverse variety and juxtaposition of the borough’s landscape and the special features that contribute positively to the local sense of place; and Well none of these requirements are met at Tudeley. With so many cars travelling between Paddock Wood and Tonbridge there will also be a change the air quality in this area. 4.50 There is no evidence that makes Tudeley a better site for a Garden Village than, for instance, Horsmonden. For example: * The justification for avoiding a garden settlement at Horsmonden is that “This would be a very large scale strategic allocation that would be disproportionate to the size of the settlement, with concern about landscape and heritage”. Yet Tudeley is a tiny hamlet. It has 50 houses at most. The whole of the Parish of Capel has only 950 houses in it. Adding 2,800 new houses at Tudeley is a massive increase that is far higher than the proportional increase at Horsmonden. On the basis of the above, TWBC do not have the exceptional circumstances required to justify building at Tudeley rather than Horsmonden. The only argument presented anywhere is that Tudeley has a single landowner and Horsmonden has multiple landowners. TWBC’s reluctance to deal with multiple landowners is not an “exceptional circumstance”. I would like it noted that the Leader and Deputy Leader of the Council both have personal interests in keeping the garden settlement out of Horsmonden due to the impact on their wards (they both represent Brenchley and Horsmonden). The release of Green Belt described in this plan in Tudeley and East Capel is not justified in any way and is certainly not the result of “exceptional circumstances”. This plan is unsound. The Green Belt Strategic Study Jul 2017 commissioned by TWBC states that building houses at Tudeley and East Capel (broad area BA4) would: * Cause the maximum level of harm possible (‘very high’) to the Green Belt. There is a suitable alternative site for the Tudeley development outside the Green Belt (in Horsmonden) and the East Capel development is not required to expand Paddock Wood. |
DLP_7280 | Mrs Katie Lee-Amies | Object | Strategic Policies (comments already included above) [TWBC: See comments DLP_7265-7267 and 7269-7277] STR 1 – object. STR 2 – object. STR 3 – object. The masterplan excuse! STR 4 – object. Strongly. STR 5 – support with conditions. Insufficient information. STR 6 – object. STR 7 – object. STR 8 - object. STR 9 – object. There are no LBD details for Tudeley STR 10 – object. |
DLP_6256 | Claire Penney | Object | * Targeting Green Belt land: I’m extremely concerned that this proposal, together with the St John’s proposal (area between Powdermill lane behind the primary school), target vital green spaces. In this case an Area of Natural Beauty, on Green Belt land. Surely there are other more appropriate sites that could be used for development, without building on precious green space that has until recently, been rightly protected? It’s vital that we preserve these scarce areas for future generations and the wellbeing of surrounding residents. Of course most people understand the need for new housing, but the council appears to be targeting green spaces that must be protected. |
DLP_6552 | Woolf Bond Planning for Millwood Designer Homes Ltd | Site 60: The Paddocks, Home Farm, 92 Lower Green Road, Rusthall TN4 8TT Policy STR 4: Green Belt Representation Whilst we support the need for a Green Belt review, including on the basis of the exceptional circumstances identified in the Council’s Distribution of Development Topic Paper (Sept 2019) (Section 6 refers), we nevertheless object to the approach to the Green Belt in so far as it fails to provide for sustainable urban extensions to Rusthall. “Individual (mainly smaller scale) sites have been identified as logical extensions to the existing LBD of a settlement, or as a ‘rounding off’ small local adjustment to the Green Belt boundary (and in some cases providing a stronger Green Belt boundary), and where all other planning considerations support the allocation, facilitating development in a sustainable location. For example, the release of Green Belt land at a number of locations at Pembury will provide a range of development opportunities, including housing and community facilities, in a sustainable location” In our opinion, the omission site at Home Farm, Rusthall affords a sustainable opportunity in helping to meet identified housing needs and satisfies this assessment criteria. Stage 2, Appendix A of the Council’s Green Belt Study (LUC) (July 2017) identifies the site (and adjoining land) as Parcel RU2a and confirms the site as having a moderate to weak rating when considered against the 5 purposes of the Green Belt The Assessment confirms as follows: * The parcel shares a similar topography to the adjacent settlement to the south, from which it has no significant separation * The existing Green Belt boundary is defined by back gardens of properties on the settlement edge. A boundary defined by hedgerows that border the parcel would not be any weaker. These conclusions are of particular relevance and standing in relation to assessing the soundness of the overall strategy of the Plan which fails to provide for an amendment to the Green Belt in this location. The evidence is clear in that the boundary should be revised to remove Parcel RU2a from the Green Belt. The minor amendment would have no discernable impact upon the role and function of the wider Green Belt. In the context of the Green Belt tests set out in the NPPF (Para 134 refers), the allocation of the site for housing would be acceptable in relation to the need to review boundaries pursuant to paragraph 138 of the NPPF. As such, and in the context of seeking an allocation of the site for housing: * It would not result in unrestricted sprawl of large built-up areas; * It would not lead to coalescence; * It would prevent more peripheral countryside locations from encroachment; and could strengthen the Green Belt boundary * There is no “special” character to be preserved; and Rusthall forms part of the wider environs of Royal Tunbridge Wells. As such, it represents one of the most sustainable locations in planning for housing growth during the plan period. Allocating the site for housing would provide for a mix of deliverable homes, including helping to meet the need to supply family sized dwellings to meet identified needs to complement higher density schemes for flatted forms of development on previously developed land within urban locations. Suggested Change Amend the Green Belt boundary to include Parcel RU2a, and in particular SHELAA Site 60 within a revised settlement boundary. [TWBC: see full representation, site context plan, access improvements and site location plan]. [TWBC: see also Comment Numbers DLP_6548-6450, 6452-6453, 6456-6457, 6459] | |
DLP_6672 | Gladman | 5.4.1 Gladman welcome the Council’s decision to review and release land from the Green Belt to meet identified development needs. The release of land from the Green Belt is a necessity given that the District’s largest urban area, Royal Tunbridge Wells/Southborough, as well as other key sustainable settlements such as Pembury are tightly bounded by this designation resulting in a significant restriction to further development in this area. As such, in order to provide a sustainable pattern of development, ensure that development is sited in locations where it is needed, and to maintain and develop the role of these settlements, land currently designated as Green Belt must be released for development purposes. 5.4.2 It is unclear to Gladman why “land reserve sites” as first identified through the 2006 Local Plan and then carried forward through the 2016 Site Allocations DPD have not be renewed/reviewed through the draft Local Plan. As set out in Paragraph 5.1.18 of this representation, Gladman is concerned that the overall level of housing land supply identified through the Local Plan provides insufficient flexibility should identified sources of supply not deliver as expected. The presence of safeguarded land in the plan would reduce the time necessary required to review the Local Plan should allocated sites fail to come forward as anticipated resulting in a shortfall in supply. 5.4.3 Paragraph 136 of the 2019 NPPF sets out that strategic policies should establish the need for changes to Green Belt boundaries, having regard to their intended permanence in the long term so they can endure beyond the plan period. Paragraph 139 of the 2019 NPPF confirms the role of Safeguarded Land in meeting longer-term development needs stretching well beyond the plan period. The decision to remove safeguarded land from the development plan should therefore be reconsidered. [TWBC: see full representation]. [TWBC: see also Comment Nos. DLP_6656-6695] | |
DLP_7514 | Sarah Parrish | Object | Section 4 Paragraph 4.49 (The Green Belt) p.49 Why are there no Exceptional Circumstances referred to? Is it that they do not exist to justify releasing any land from the Green Belt in Tudeley and East Capel? What are they? Section 4 Paragraph 4.50 (The Green Belt) p.49 Where is the evidence to release Green Belt land justifiably? TWBC’s reluctance to deal with multiple landowners is not an “exceptional circumstance”. Leading to a garden village planned at Tudeley. I would like to ask if the Leader and Deputy Leader of the Council both have personal interests in keeping the garden settlement out of Horsmonden due to the impact on their wards (they represent Brenchley and Horsmonden). Policy STR 4 (Green Belt) p.42 Why build where maximum harm to the Green Belt is already acknowledged by TWBC? |
DLP_2763 | Cllr Keith Obbard | Object | WEALDEN GREEN PARTY RESPONSE TO TWBC DRAFT LOCAL PLAN Policy STR4 - Green Belt We object to the scale and distribution of development, particularly within the Area of Outstanding Natural Beauty (AONB) and its setting. There is no justification for using any Green Belt land. The NPPF guidelines say it should only be used in "exceptional circumstances" which these are not. [NPPF para 136, 137] and Local Authorities have a duty to protect the AONB. [Countryside & Rights of Way Act 2000] The TWBC website's 2019 Brownfield Register is little different from the 2017 version, indicating there has been little attempt to identify the potential. TWBC should produce a thorough and up-to-date brownfield sites analysis before proposing to use the Green Belt - otherwise it will fail at the Planning Inspectorate review. |
Policy STR 5: Essential Infrastructure and Connectivity
Comment No. | Name/Organisation | Object/support/ support with conditions/ | Response |
|---|---|---|---|
DLP_52 | Thomas Weinberg | Support with conditions | Comments on Policy STR 5 (Essential Infrastructure and Connectivity) p.52 An addition is required as follows: “All infrastructure required for the garden settlements must be described in detail before the Local Plan is adopted, signed off via public consultation and a TWBC Full Council vote and delivered and inspected in full before the first house within the garden settlement is built.” |
DLP_71 | The Access Group |
| My members having looked at the proposed Draft Local Plan have instructed me to make the following observations and legal demands: 2. THE MAJOR CONCERNS
- New self contained GP & Dental Surgeries must be included as part of each development being permitted to take place. These along with the three major legal demands set out in this letter [TWBC: see Comment Numbers DLP_66-67] must be planning conditions imposed by the LPA, if they cannot be met then planning approval must be postponed or refused. [TWBC: this comment has also been placed against Policy STR/PW 1 - see Comment Number DLP_70]. |
DLP_2241 | Philip Brewer | Object | There is no need for a new secondary school in RTW. The evidence presented in the KCC Education and Infrastructure Needs and Requirements document and the TWBC Infrastructure Development Plan shows there is currently above average spare capacity (12.4%) in TW secondary schools, and with the planned expansions of existing schools, any additional need in RTW will be met in the planning period. Given that less than 10% of the planned housing development will be in RTW, siting a new school at the south west edge of the borough is not appropriate when the need will be in the north. |
DLP_7774 | Annie Hopper | General Observation | There is insufficient infrastructure currently to support any large development in Cranbrook and Sissinghurst but specifically for AL/CRS 4 Turnden, AL/CRS 6 Gate Farm, AL/CRS 7 Golford, AL/CRS 9 Brick Kiln. There does not appear to be any masterplanning approach for the infrastructure required for any development within the Parish. The current approach by TWBC whereby each development is assessed individually and developed in isolation with the rest of the Parish will not work. This is NOT infrastructure led planning policy. |
DLP_7802 | Mr Colin Sefton | Support with conditions | I strongly welcome the recognition that it is essential that:- “ It is critical that the necessary infrastructure (whether physical or social) is delivered in a timely way, to ensure that the development programme is not delayed and that built development and infrastructure is brought forward in a comprehensive approach.” I propose that this should be managed by ensuring that planning for no development is approved until ALL the necessary infrastructure has been fully approved and planned for completion BEFORE any part of the development is occupied. Necessary infrastructure should include ALL of the following (where relevant):-
Medical facilities, especially GPs |
DLP_134 | Gregg Newman | Support with conditions | As noted above, an increase in population such as that indicted will require significant additional infrastructure which you yourselves openly state are neither panned for not properly thought through. Schools, (Schools in the area are already over-subscribed at every level), hospitals, doctors’ surgeries etc., as well as fire brigades, ambulances and police. All not even considered as yet. |
DLP_7867 | Andrew Hues | Object | TWBC: the standard response was submitted by the list of responders on the left: STR 5 claims that the growth strategy is based on the premise of infrastructure-led development. To the extent that this means anything it is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. The policy claims, for example, that provision will be made for the additional education and health services necessitated by the concentrated developments. But the council has no grounds to give such assurances as they do not control the provision of these (and other) essential services. The plan then goes on to admit that these issues can only be determined through consultation with the relevant authorities. In other words there is no guarantee that the additional services will, indeed, follow the housing demands imposed upon the community. The problem is exemplified in relation to the provision of sewage services by Southern Water, which was the subject of the recent adjournment debate in Parliament (see STR 1 above). Recent experience in Wealden towns and villages indicates that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. Furthermore, we can expect developers to play the old game of submitting amendments to plans, once approved, to dilute their commitments (and associated expense) and that the Council will, as usual, accede to their demands. If TWBC wished to attach any credibility to their claims, the Plan should have committed the Council to require enforceable commitments from all relevant service and infrastructure providers to provide the relevant undertakings, in specific terms, before any large-scale developments were given planning permission. In relation to the proposed developments at Hawkhurst, the infrastructure and connectivity objections are set out under STR 1 above. [TWBC: See corresponding comment under STR 1 above] |
DLP_7935 | Wendy Owen | Object | There is no need for a new secondary school in Tunbridge Wells. |
DLP_7943 | R, A & A Angelis & K & N Lescure | Object | TWBC: the standard response was submitted by the list of responders on the left: There is no need for a new secondary school in RTW. The evidence presented in the KCC Education and Infrastructure Needs and Requirements document and the TWBC Infrastructure Development Plan shows there is currently above average spare capacity (12.4%) in TW secondary schools, and with the planned expansions of existing schools, any additional need in RTW will be met in the planning period. Given that less than 10% of the planned housing development will be in RTW, siting a new school at the south west edge of the borough is not appropriate when the need will be in the north. |
DLP_8083 | Department for Education | 12. Draft Policy STR5 clearly establishes the need for new development to be supported by infrastructure, to serve the need arising from new development. DfE supports the requirements set out in the policy to ensure that sufficient land is allocated as part of site allocations to deliver infrastructure, including new schools and school expansions. 13. DfE would be considered a service provider where delivering Free Schools directly through the ‘Central Wave’ route. KCC would be considered as such where delivering Free Schools through the Presumption Route. Accordingly, the delivery of Free Schools should be supported as per part 4 of the policy approach. The ‘Education’ section of this policy should also reflect that developers may deliver schools directly on development sites, as well as schools being able to be delivered by DfE and KCC. | |
DLP_8088 | Department for Education | Developer Contributions and Community Infrastructure Levy (CIL) 25. One of the tests of soundness is that a Local Plan is ‘effective’, meaning the plan should be deliverable over its period. In this context and with specific regard to planning for schools, there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments. DfE notes that TWBC have produced a Planning Obligations SPD which will need to be updated to reflect Local Plan priorities and the 2019 CIL Regulations. 26. Local authorities have sometimes experienced challenges in funding schools via Section 106 planning obligations due to limitations on the pooling of developer contributions for the same item or type of infrastructure. However, the revised CIL Regulations remove this constraint, allowing unlimited pooling of developer contributions from planning obligations and the use of both Section 106 funding and CIL for the same item of infrastructure. The advantage of using Section 106 relative to CIL for funding schools is that it is clear and transparent to all stakeholders what value of contribution is being allocated by which development to which schools, thereby increasing certainty that developer contributions will be used to fund the new school places that are needed. DfE supports the use of planning obligations to secure developer contributions for education wherever there is a need to mitigate the direct impacts of development, consistent with Regulation 122 of the CIL Regulations. 27. We also request a reference within the Local Plan’s policies or supporting text to explain that developer contributions may be secured retrospectively, when it has been necessary to forward fund infrastructure projects in advance of anticipated housing growth. An example of this would be the local authority’s expansion of a secondary school to ensure that places are available in time to support development coming forward. This helps to demonstrate that the plan is positively prepared and deliverable over its period. 28. DfE would be particularly interested in responding to any update to the Infrastructure Delivery Plan/Infrastructure Funding Statement, viability assessment or other evidence relevant to education which may be used to inform local planning policies and potential future CIL charging schedules should TWBC determine to proceed with CIL. As such, please add DfE to the database for future consultations on relevant plans and proposals. | |
DLP_8161 | Myriam Ruelle | Object | Policy STR5: Observation / object: Essential infrastructure needs need to be clearly defined and tackled before any possible development. This is the case with Town centre infrastructure (water / sewerage) as well as hospitals / fire / ambulance services for the whole of the borough. |
DLP_8196 | Mrs Suzi Rich | Object | This strategy states that “It is essential that all new development will be supported by the provision of the necessary infrastructure, services, and facilities that have been identified to serve the needs arising from new development” [TWBC: See comments DLP_8189-8214 for full representation] |
DLP_8274 | Ann Gibson | Object | STR5.5 New residential and commercial development will be supported if sufficient infrastructure capacity is either available, or can be provided in time to serve the development. Sufficient infrastructure capacity is not available to support development in Sissinghurst and could not possibly be provided in time to meet the development. There is no plan to provide employment in the area or to mitigate private car travel to employment in the planned areas. This is not infrastructure led planning policy. |
DLP_8320 | Andrew Richards | Object | INTRODUCTION I am not a resident of Tunbridge Wells Borough, but I live near to the Borough boundary just outside Tonbridge. I visit the Borough regularly and enjoy the benefits of its countryside, notably the Green Belt and the Areas of Outstanding Natural Beauty, which need to be preserved in line with National Planning Policy. I also drive around Tonbridge regularly and am shocked at the impact the proposals in your draft Local Plan (LP) would have on Tonbridge and its environs. The LP is vast and complex and has clearly consumed a significant amount of effort; I congratulate the officers for their diligence in seeking to balance the various competing demands of policy, legislation and local constraints. As a private individual I do not have similar resources or expertise; I have therefore confined my comments to a small number of topics. This is not to say I endorse the remainder of the LP and its associated material; I am aware of some of the concerns raised by others and support many of them. Notwithstanding the level of effort that has gone into the LP, I’m afraid my overall assessment is that the Borough has fallen short of the diligence needed. Sadly, it seems to have taken the easy way out of its obligations in a number of areas. It has:
I conclude that the Borough has failed to meet the required standard for a Regulation 18 consultation and should repeat the exercise, having first addressed some of the fundamental concerns raised. I believe this plan requires too substantial a series of amendments to proceed directly to a Regulation 19 consultation. My comments are in relation to a number of documents identified below. Policy STR 5 – Essential Infrastructure and Connectivity 23. I object to the policy on infrastructure. Specifically: a. “Plans should . . c) be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees” (NPPF 16); b. In support of which, STR 5 asserts that Southern Water have been “fully consulted” as part of the plan preparation process. 25. Whereas: b. This demonstrates the ineffectiveness of infrastructure planning, where this fails to provide the up-front investment needed to put in place the infrastructure needed in advance of development taking place. Without addressing such past poor performance the LP is unsound. Conclusion 39. In conclusion, to reiterate the point made in opening, I conclude that the Borough has failed to meet the required standard for a Regulation 18 consultation. It should therefore repeat the exercise, having first addressed some of the fundamental concerns raised. [TWBC: See full representation] |
DLP_860 | Ian Pattenden | Support with conditions | Comments on Policy STR 5 (Essential Infrastructure and Connectivity) p.52 An addition is required as follows: “All infrastructure required for the garden settlements must be described in detail before the Local Plan is adopted, signed off via public consultation and a TWBC Full Council vote and delivered and inspected in full before the first house within the garden settlement is built.” You state that hospitals at Pembury and Maidstone may need to be expanded. This is true. Everyone I know has had issues with waiting times at local hospitals and this will only become more difficult to manage if you put 4,000+ new houses in Capel. You also state that no strategies for emergency services to the new houses (ambulance, fire, police) have been identified. These services are heavily constrained and under a huge amount of pressure. The exact terms and timelines for their expansion must be defined, secured and implemented before any new houses are built. You reference an additional 8 form entry increase being required at Mascalls. This is impossible. The increase education capacity in the Local Plan is unsustainable in relation to developments in the Parish of Capel. The other proposed new school site adjacent to Tonbridge is ill conceived, being split by a main line railway and located in an area which already has numerous schools all requiring pupils to be transported into in the already congested town of Tonbridge…..madness. Roads will inevitably be needed to cope with the extra traffic the developments will produce, yet the plans for roads still remain vague and unformed, with maps showing two large arrows between the Tudeley site and the A228, one north across the Medway Valley, the other South. Without detail on the proposed routes, public consultation is meaningless at this stage in the process. |
DLP_912 | Nigel Stratton | Object | Already there is insufficient infrastructure. No thought seems to have been given as to whether medical and school provision can cope with extra demand for extra house. The Council needs to identify the increased demand and to come forward with proposals as to how this will be accommodated. In some parts of the Borough, it is clear that the existing sewerage system cannot cope with the existing level of use, let alone by further houses being built. This needs to be sorted out before any further building commences. The current lack of infrastructure will only be made worse by the proposed developments. |
DLP_940 | Mrs Karen Stevenson | Object | STR 5 sets out the ways that all necessary infrastructure, services and facilities will be provided to meet needs arising from new development. Developers will be expected to provide or contribute significantly towards additional requirements. STR 5 (5) states that, “New residential and commercial development will be supported if sufficient infrastructure capacity is either available, or can be provided in time to serve the development.” I know of many instances already, where inadequate infrastructure is in place and there appears little prospect of it being provided. The policies set out in the draft local plan do not appear to be been prepared in proper coordination with utility providers. In Paddock Wood already, new “estate style” developments are being built with inadequate drainage being in place, the developers cannot provide it as there is simply no capacity currently in the sewerage system and Southern Water are unable to advise when there will be capacity. Apparently septic tanks are being provided as a solution to each new home! This is not what I would, call sustainable development. |
DLP_1181 | Jennifer Mary Wharton | Object | I want to register my strong objection to any development on this site (the fields adjacent to Ramslye Road and beyond it/Spratsbrook farm) and I make the following points in support of my objection: 1. The land is within the High Weald Area of Outstanding Natural Beauty (AONB) and is high grade agricultural land and as such it must be protected from development: Approximately half of the site is classified as AONB. It is a fine and accessible example of the High Weald and we have AONB designations to protect this type of land. Additionally, all of it is high quality agricultural land. By putting this site forward for consideration of development, the council has failed in its duties under the Countryside and Rights of Way Act (CRoW) 2000 which says the primary purpose of AONBs is to conserve and enhance natural beauty and its protection should be given a high priority by local authorities. The crops grown in the fields include cereals, linseed and oil seed rape, which according to the government means it should be protected under the "Best and Most Versatile" (BMV) rules that are designed to ensure we keep the best and most productive farm land available so we can continue to grow the food we need. 2. The land is Green Belt and it must not be released for development: The council's own study of Green Belt in 2017 as part of the development of the local plan assessed the degree of harm caused by the potential loss of this land is high. It also assessed the contribution of this land to the national criteria for the Green Belt as relatively strong in three of the four criteria assessed. It is not apparent from the local plan that any other site has been proposed to be released from the Green Belt that would have the high degree of harm associated with losing this land. 3. The existing road network cannot support a development of the size and nature proposed: On average 23,496 motor vehicles use Eridge Road every day going into Tunbridge Wells. Only Pembury Road is busier (by c.3%). Traffic already queues on Eridge Road from Sainsbury's roundabout to Broadwater Down and sometimes further. The proposed development could add c.350 cars to the area and increase traffic up to 25% for the school runs, totalling nearly 30,000 vehicles every day. The quiet green space of Ramslye could become a congestion/parking black spot due to school traffic. It is clear the current roads and parking provision cannot handle a development of this size and the site of any new school needs to correspond to the location of the bulk of the new housing. A development of this scale in the High Weald AONB and on such high grade agricultural land sets a dangerous precedent for our rural environment, and it will have an unduly negative impact on the residents in the area in terms of traffic , noise, congestion and pollution. I have set out a compelling and reasoned case to remove this site from the draft local plan and I urge you to consider how to challenge the overall requirement for new houses to a more realistic and justified target. |
DLP_1740 | Horsmonden Parish Council | Support with conditions | Policy STR5- Essential Infrastructure and Connectivity: We strongly support timely provision of upgraded infrastructure to support growth and the general thrust of this policy to achieve that end. However, the mildly worded “expectation” in the policy should be replaced by a “requirement” in order to reduce the scope for backsliding and leaving local communities to cope with the external impacts of growth on local infrastructure. |
DLP_3675 | Capel Parish Council | Support with conditions | TWBC: the standard response was submitted by the list of responders on the left: An addition is required as follows: “All infrastructure required for the garden settlements must be described in detail before the Local Plan is adopted, signed off via public consultation and a TWBC Full Council vote and delivered and inspected in full before the first house within the garden settlement is built.” The commentary at paragraph 4.53 states that: “Infrastructure can be separated into four main categories: physical infrastructure (such as highways and public realm improvements), community infrastructure (such as schools, adult social services, and cultural facilities), and green, grey, and blue infrastructure (such as play spaces, natural and semi-natural open space, and sports pitches, as well as other essential infrastructure such as flood mitigation, utilities, and digital connectivity)” The ‘Green Infrastructure Framework’ and ‘draft Infrastructure Delivery Plan’ are highlighted as key documents. Policy STR 5 identifies the following ‘strategic priorities for infrastructure provision or improvements within the borough’ needed to deliver and support the growth set out in the dLP:
The Policy then refers to the Infrastructure Delivery Plan (IDP) which it says identifies the scope of infrastructure to be provided, the phasing of such infrastructure linked to the planned development, and the mechanisms by which the Council considers that the infrastructure will be delivered, including the use of Section 106 agreements, Community Infrastructure Levy, or equivalent policy as applicable. Health In the Infrastructure Delivery Plan (IDP) under the heading ‘Additional future requirements needed to deliver growth proposed in the Draft Local Plan’ at paragraph 3.104 (p.40) it states that “The Council has not been made aware of any specific requirements over the plan period; however, discussions with the Maidstone and Tunbridge Wells NHS Trust have highlighted potential need for extension of either the Tunbridge Wells Hospital or Maidstone Hospital to serve the West Kent Area over the Plan period” Under the heading ‘Emergency Services’ at paragraph 3.201 (p.62) it states that “Emergency services for the purposes of this IDP include Police, Fire and Rescue, and Ambulance services” before confirming under the heading ‘Related strategies and evidence’: “None identified at this stage” Several thousand houses will create huge pressures on every aspect of NHS provision – it is unacceptable to not have identified this need & just refer to a “potential need”. The TW Hospital at Pembury is already at capacity, the site is not capable of being extended, and there is already a serious issue with car parking. Handover times between ambulance & hospital have historically been a scandal due to acute bed shortage. Education Policy STR 5 states that “Provision will be made for sufficient school places in the form of expanded or new primary and secondary schools, together with early years and childcare facilities”. There is more information about what the specific provision will be under Policies STR 1, AL / CA 1, AL / CA 3 & AL / PW 1, however, the IDP does not give any certainty that the required provision can ever be realised. Please see our comments in Comment Box 8 under the heading ‘Infrastructure Delivery Plan’ |
DLP_1471 | Mrs Wendy Coxeter | Object | TWBC: the standard response was submitted by the list of responders on the left: Policy Number STR 5 STR 5 Claims that the growth strategy is based upon the premise of infrastructure-led development. To the extent that this means anything, it is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. The policy claims, for example, that the provision will be made for the additional education and health services necessitated by the concentrated developments. But the council has no grounds to give such assurances as they do not control the provision of these (and other) essential services. The plan then goes on to admit that these issues can only be determined through consultation with the relevant authorities. In other words there is no guarantee that the additional services will, indeed, follow the housing demands imposed upon the community. The problem is exemplified in relation to the provision of sewage services by Southern Water, which was the subject of the recent adjournment debate in Parliament (See STR1 above). Recent experience in Wealden towns and villages indicates that statutory and other service providers will do little or nothing to improve local services e.g. transport, sewage, education, health services, and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. Furthermore, we can expect developers to play the old game of submitting amendments to plans, once approved, to dilute their commitments (and associated expense) and that the Council will, as usual accede to their demands. If TWBC wished to attach any credibility to their claims, the Plan should have committed the Council to require enforceable commitments from all relevant service and infrastructure providers to provide the relevant undertakings, in specific terms, before any large-scale developments were given planning permission. Section 106 Contributions now have replaced proper Government funding and create an illusion of prosperity but the countryside is paying the price. In relation to the proposed developments at Hawkhurst, the infrastructure and connectivity objections are set out under STR 1 above. |
DLP_1893 | Royal Tunbridge Wells Town Forum | Policy STR 5 Essential Infrastructure and Connectivity The requirement that developers should contribute sums satisfactory to the Council when their development creates a need for new or improved infrastructure is strongly supported though we have doubts as to how adequate contributions will be in practice. The policy provision for effective monitoring paid for by the developer seems a considerable improvement over current practice. Provisions on education, health and water appear imprecise. Although it is recognised that TWBC is not the lead authority in respect of any of these services, we believe that it should draw attention to the lack of joined up thinking by some responsible Authorities such as KCC, for example by continuing to follow school siting policies that substantially increase traffic congestion in RTW with the resulting damage to public health and the urban environment. The new provisions on green, grey and blue infrastructure are supported but It will be essential for adequate funds to be secured from all available sources, including from developers, to make these provisions a reality. | |
DLP_3052 | Mr Adrian Cory | Object | STR 5 claims that the growth strategy is based on the premise of infrastructure-led development. To the extent that this means anything it is misleading as the Council has little authority to mandate the provision of infrastructure, services and facilities on the scale required to support developments of the size proposed. The policy claims, for example, that provision will be made for the additional education and health services necessitated by the concentrated developments. But the council has no grounds to give such assurances as they do not control the provision of these (and other) essential services. The plan then goes on to admit that these issues can only be determined through consultation with the relevant authorities. In other words there is no guarantee that the additional services will, indeed, follow the housing demands imposed upon the community. The problem is exemplified in relation to the provision of sewage services by Southern Water, which was the subject of an adjournment debate in Parliament on 28 October (Hansard Vol. 667) in which Greg Clark M.P. drew attention to the statutory undertaker’s failure to provide the necessary infrastructure to support existing and new housing, and the failure of local authorities to hold developers to account in relation to their corresponding obligations. The M.P. recalled Southern Water’s admission that the infrastructure is inadequate to support further housing development and recommended that no further developments should be approved until the necessary infrastructure is in place. Recent experience in Wealden towns and villages indicates that statutory and other service providers will do little or nothing to improve local services (e.g. transport, sewage, education, health services) and that TWBC will continue to allow developers to pay no more than lip service to the few obligations imposed upon them. Furthermore, we can expect developers to play the old game of submitting amendments to plans, once approved, to dilute their commitments (and associated expense) and that the Council will, as usual, accede to their demands. If TWBC wished to attach any credibility to their claims, the Plan should have committed the Council to require enforceable commitments from all relevant service and infrastructure providers to provide the relevant undertakings, in specific terms, before any large-scale developments were given planning permission. In relation to the proposed developments at Hawkhurst, the infrastructure and connectivity objections are set out under STR 1 above. Lack of adequate infrastructure (taken from STR 1 comments) Hawkhurst has seen a great deal of development recently and the infrastructure is already struggling to cope. The primary school is nearing capacity. The GP surgeries are full. Hawkhurst’s sewage treatment plants are over capacity, resulting in sewage spilling into the streams and a regular requirement for sewage to be taken away from the treatment works by tanker. Southern Water have recognised that there is insufficient capacity in the public sewer network for this development and the local M.P. has very recently raised the issue in Parliament (see above). |
DLP_2726 | St. John's Road Residents association | General Observation | Mentioned in paragraph 5.7, mitigation of transport impact from new development is required. In practice this will prove very difficult to achieve to the required extent in the case of major developments. Mentioned is the failure of mitigation policy in relation to the Berkeley Homes site at Hawkenbury., It requires a more robust policy in the new Local Plan to improve on the present lack of effective mitigation on major development. |
DLP_2875 | Chris Gow | Object | Any notion of betterment and the development on flood plains must be abandoned. Flood defence are very expensive and will never be a complete defence against flood waters. The advancement of climate change and global warming should be a clear warning to avoid any proposed development on flood plains, despite any reports that claim the risk is low and manageable. |
DLP_2876 | Chris Gow | Object | Water This paragraph is not clearly identifying the problem of fresh water supply in the borough, and in the South of England in general. It places insufficient importance on the lack of water for new developments. |
DLP_1975 | Mr Jeremy Waters | Support with conditions | I support all of these aspirations but in reality if TWBC decides to pursue "dispersed growth" across the villages, it is highly unlikely that the majority of these will be realised as the smaller scale developments needed will not provide the impetus or funding. In contrast a larger development would justify developers funding infrastructure improvements as required. |
DLP_2012 | Dr David Parrish | Object | Policy STR 5 (Essential Infrastructure and Connectivity) p.52 There no Infrastructure Plans or Infrastructure Risk Assessments The effect on Capel and Tonbridge will be immense – traffic, parking, doctors, roads, quarry traffic, carbon-neutrality, air pollution, water (waste and potable), other neighbouring BCs and their wards (Yalding, Snodland, Medway, Maidstone etc.) There are no emergency services plans The LP also states that no strategies for emergency services to the new houses (ambulance, fire, police) have been identified. These services are already heavily constrained and under a huge amount of pressure. The increased Potable and Waste Water demands have not had identified how they will be met It is not clear where the extra potable drinking water increased demand will come from – nor where the increased waste water will go to. Where will it be treated? Over 2,000 homes with septic tanks will require 10 lorries a day all year to ensure annual emptying. There is no infrastructure at all for this requirement. Local knowledge (I personally have seen fields flooded like lakes) shows the areas in discussion to be very high flood risks. They are not ditch overflows (due to blockages) as Hadlow Estate stated at the Solar Farm consultation. |
DLP_1957 | Ms Jacqueline Stanton | Support with conditions | STR 5: The improvement of infrastructure listed is positive but should be more strongly enforced to avoid developers finding a "way out". |
DLP_2940 | Garry Pethurst | General Observation | Policy STR5 Item 1 - There should be a definition of what constitutes a significant contribution. Surely, any requirement for new infrastructure must be paid for by the developer creating that need, rather than spread the cost over the nearby community, who may not have wanted the development in the first place. In any case, who decides what the significant contribution is - developer, planners, local council? Item 5 - It needs to be made clear what restrictions will be put in place to ensure that sufficient infrastructure is in place in time to serve a development. It will be too late if the development is built and, then, the infrastructure need is identified. Health - With the high number of dwellings being proposed for the Hawkhurst/Cranbrook area, should there be a specific policy for the upgrade of Hawkhurst Cottage Hospital? Water - Flooding is a very real threat across many parts of the borough - mitigation should be in place before any major development takes place, before it is too late. A robust sewage management system must be in place before major development occurs. Developers must be obliged to take responsibility, rather than leave it solely to the regulatory bodies. Green, Grey, and Blue Infrastructure - This is very necessary, but local communities must be involved in playing an active part in the strategic planning. They must be provided with what they need, rather than what somebody is prepared to give them. |
DLP_1616 | Maggie Fenton | Object | Strategic Objective 5 p.51 IN THE IDP REGARDING HEALTH PROVISION IT STATES RE HOSPITAL PROVISION TWBC “HAVENT BEEN MADE AWARE OF ANY SPECIFIC REQUIREMENTS BUT THERE IS A POTENTIAL NEED TO EXTEND THE HOSPITALS AT PEMBURY AND MAIDSTONE.” RE EMERGENCY SERVICES, AMBULANCE, FIRE & POLICE “NO STRATEGIES IDENTIFIED AS YET.” Several thousand houses will create huge pressures on every aspect of NHS provision – it is unacceptable to not have identified this need & just refer to a “potential need”. The TW Hospital at Pembury is already at capacity, the site is not capable of being extended, and there is already a serious issue with car parking. Handover times between ambulance & hospital have historically been a scandal due to acute bed shortage. EDUCATION. ‘TO MEET EXISTING NEED ONE FORM ENTRY EXPANSION OF MASCALLS IS SCHEDULED FOR 2021/22’. HOWEVER UNDER PW SECTION IDP REFERS TO AN EIGHT FORM ENTRY INCREASE WITHIN PW/CAPEL AS AN EXPANSION OF MASCALLS. Mascalls capacity can only be increased by a finite amount due to location constraints. This therefore makes the development of 4,000 houses in east Capel unsustainable as the only extra capacity will have to be provided by travel to the planned new school at Tudeley. TWBC acknowledge that there are serious constraints as in the DLP it states ‘DEVELOPMENT AT AL/CA3 “IS SUBJECT TO THE PROVISION OF LAND FOR THE EXPANSION OF MASCALLS” Location of this land appears unknown and is therefore unsustainable. An addition is required as follows: “All infrastructure required for the garden settlements must be described in detail before the Local Plan is adopted, signed off via public consultation and a TWBC Full Council vote and delivered and inspected in full before the first house within the garden settlement is built.” |
DLP_3556 | Lynne Bancroft | Support with conditions | Section 106 monies from developments should be kept within the specific town, village or ward to which the development relates. For example, monies from developments within Sissinghurst village should be kept to improve facilities within Sissinghurst village only, not passed to Cranbrook and Sissinghurst Parish generally. The TWBC growth strategy is based on the premise of infrastructure-led development. Key infrastructure required for additional housing in Sissinghurst includes greater accessibility to Tunbridge Wells on a dualled A21 between Lamberhurst and Blue Boys. This infrastructure is not in place and will not be in place before the housing in this plan is developed so much more development should be in Tunbridge Wells or adjacent to the already dualled A21. Cranbrook has greater infrastructure and facilities than Sissinghurst so any new development for this parish should be focussed there but overall all the Local Plan should be amended to put more housing development in Tunbridge Wells and areas adjacent to the already dualled A21 rather than unsustainable development in the eastern side of he Borough. Public transport must be improved in the evenings as well as the day for all villages connecting to towns, including those outside of the Borough such as Sissinghurst to Tenterden as well as Sissinghurst to Tunbridge Wells and Maidstone. The Borough should encourage cheaper and more frequent public transport to encourage additional useage, especially in the rural eastern areas of the Borough. Strategic bus and rail services should be improved firstly for those residents who wish to travel within the Borough. |
DLP_2735 | Rosanna Taylor-Smith | General Observation | Water In light of the extremely heavy rainfall experienced recently and flooding being experienced by many areas and with the future climate change uncertainties, TWBC must be very aware of not permitting development in any known flooding zones or those with potential to flood as well as those with extensive underground water systems such as in Hawkhurst. There are significant issues with Souther Water and its seeming lack of investment and failure to provide adequate sewerage treatment facilities for current housing, especially in Paddock Wood and Hawkhurst. SouthernWater has a legal duty to provide this essential infrastructure but in many instances, it simply has not done so to date and in its own future 5 year capital spending report, simply does not attempt to address these issues. It cannot be right in 2019 that sewerage works regularly overflow into nearby fields and that multiple tankers are required to regularly dispose of surplus waste. |
DLP_2037 | Terry Everest | General Observation | A greatly reduced development schedule will greatly reduce the pressure and requirment for essential supporting infrastructure which would be a double win for the environment. |
DLP_1778 | CPRE Kent | Object | Education The Council needs to be more proactive in reserving sites for new primary schools to ensure this service is delivered at the point of need in order to avoid, and where possible reverse, the consequences that short term planning by KCC has had on town traffic, air quality and wellbeing. Water More than just full consultation with Southern Water is needed to ensure that the necessary infrastructure for foul drainage will be provided. Past and present experience of their ability to ensure new development does not result in sewage overflows is not encouraging. Evidence is needed that the necessary infrastructure will be provided by Southern Water before the new dwellings are occupied. Infrastructure Delivery Plan Too much of the infrastructure delivery plan shows funding “TBC”. This does not give confidence that it will actually be provided. |
DLP_1366 | Mr and Mrs Leach | Support with conditions | Re: Draft Local Plan (Regulation 18 Consultation) - Adjoining Resident Comment It was good to meet you at the SaveCapel Public Meeting, on 18th September 2019. We wish to comment on the Draft Local Plan (LP), in relation to certain policies outlined under the headings stated below. We are specifically concerned about the negative impacts of the proposed garden villages will have to our town, especially without adequate public transport provisions, and with such a large loss of the countryside and Green Belt. 1.9 Our points in relation to Policy STR 5 are as follows: a. We support this Policy, but believe an additional requisite should be included stating: All the infrastructure required for the garden settlements must be delivered prior to any housing being built (or similar), to minimise the development impact. b. The necessary jobs, services and facilities, such as all the shops and other business that people will require, are unlikely to be provided within the proposed garden settlements. As such people will need to travel to other towns for these. c. The lack of public transport both limits people's options, with a greater reliance of private car usage, and is not consistent with National policy (see Items 1.4 to 1.7). d. In light of this, we believe that thousands of new residents opting to commute by train (to London, etc), or to go shopping, are likely to drive to Tonbridge; as this is the nearest main town, due to no railway station being provided as part of the proposed development, despite the enlarged Tudeley village straddling a mainline. This will add to existing acute congestion in town and increase bus journey times. In conclusion, we do not consider that the Draft Local Plan is sound, in relation to the proposed large garden settlements, with inadequate infrastructure connecting nearby towns. The current proposal for such a substantial loss of the Green Belt and countryside, as part the massive village expansions, is not sustainable development and nor is it consistent with National planning policy. This will cause immense environmental harm, including a heavy reliance on car use with poor public transport links. The justification for building on the Green Belt is unsound, as there are alternative brownfield and non-Green belt sites available. We are also concerned about the deliverability of the Draft Local Plan, with the local market saturation of nearly 6,000 new houses allocated for two nearby villages within one local area. In light of these concerns and the potentially flawed approach in favouring Green Belt development, over other suitable sites and as no exceptional circumstances exist, alternative sites should be considered. A more sustainable development approach might be to spread the allocation across the Borough, reducing the concentrated development pressures and local market saturation, whilst helping to unlock the greatest amount of brownfield re-development. |
DLP_2457 | Tracy Belton | Object | STR5 It is all very well saying that improved infrastructure will be put in place where needed, but most roads in villages and even towns cannot simply be made wider or moved to accomodate extra traffic. Education - It is all very well expanding schools, but in my view, I wanted to send my children to a village primary school so that they are in a small school where everyone knows everyone else and there is a sense of community. Bigger schools do not have the same feel to them and building a sense of community from a young age is important so that this follows through for years to come. The whole sense of a community that is built on for periods of decades does not appear to matter to those deciding on these planning applications. Village life is very different to town/city life and not everyone wants a town/city life. Many families remain in villages for generations. This is how village communities work and I don't think this is being taken into consideration. Health - Pembury/Tunbridge Wells hospital has only recently been redeveloped. Already we are struggling to find parking spaces at the hospital making attending appointments id very difficult. Waiting times at A&E are still hours long and waiting rooms are still full. I am happy that the NHS is doing it's best, but an extra 13,000 dwellings in the area will only add to the oversreatched hospital. Are there plans to redevelop the site again? Green, grey & blue infrastructure - This seems a nonsense as why build on green spaces and then say you are going to provide green spaces |
DLP_1991 | S Barrett | Object | Nothing in the draft plan is likely to reduce private car dependence, when there is no provision for new employment opportunities in Cranbrook. Also the town is the centre of a local rural road network unfit for the large influx of new vehicles. Every new home has at least two cars nowadays - So some moderation in new housing allocations would seem reasonable |
DLP_1995 | S Barrett | Object | The policy states community benefits will be provided to include new healthcare facilities - Yet there is no provision in the draft plan for a site for a new medical centre. The current medical facilities are already stretched to their limit. Most of the doctors are nearing retirement. when new doctors have been appointed to our practice they have barely lasted 6 mths to 1 year. The pharmacy also is under great stress. They have been days when it hasn't opened at all, as no pharmacist is available. |
DLP_2421 | H G Gentry | Object | I want to register my strong objection to any development on this site (the fields adjacent to Ramslye Road and beyond it/Spratsbrook farm) and I make the following points in support of my objection: 1. The land is within the High Weald Area of Outstanding Natural Beauty (AONB) and is high grade agricultural land and as such it must be protected from development: Approximately half of the site is classified as AONB. It is a fine and accessible example of the High Weald and we have AONB designations to protect this type of land. Additionally, all of it is high quality agricultural land. By putting this site forward for consideration of development, the council has failed in its duties under the Countryside and Rights of Way Act (CRoW) 2000 which says the primary purpose of AONBs is to conserve and enhance natural beauty and its protection should be given a high priority by local authorities. The crops grown in the fields include cereals, linseed and oil seed rape, which according to the government means it should be protected under the "Best and Most Versatile" (BMV) rules that are designed to ensure we keep the best and most productive farm land available so we can continue to grow the food we need. 2. The land is Green Belt and it must not be released for development: The council's own study of Green Belt in 2017 as part of the development of the local plan assessed the degree of harm caused by the potential loss of this land is high. It also assessed the contribution of this land to the national criteria for the Green Belt as relatively strong in three of the four criteria assessed. It is not apparent from the local plan that any other site has been proposed to be released from the Green Belt that would have the high degree of harm associated with losing this land. 3. The existing road network cannot support a development of the size and nature proposed: On average 23,496 motor vehicles use Eridge Road every day going into Tunbridge Wells. Only Pembury Road is busier (by c.3%). Traffic already queues on Eridge Road from Sainsbury's roundabout to Broadwater Down and sometimes further. The proposed development could add c.350 cars to the area and increase traffic up to 25% for the school runs, totalling nearly 30,000 vehicles every day. The quiet green space of Ramslye could become a congestion/parking black spot due to school traffic. It is clear the current roads and parking provision cannot handle a development of this size and the site of any new school needs to correspond to the location of the bulk of the new housing. A development of this scale in the High Weald AONB and on such high grade agricultural land sets a dangerous precedent for our rural environment, and it will have an unduly negative impact on the residents in the area in terms of traffic , noise, congestion and pollution. I have set out a compelling and reasoned case to remove this site from the draft local plan and I urge you to consider how to challenge the overall requirement for new houses to a more realistic and justified target. Other comments: These fields are some of the only remaining formed fields in Kent lets please keep them that way Please show us proof that Tunbridge Wells needs another school? |
DLP_2602 | Sue Sands | Object | Green, grey & blue infrastructure - as the houses that are planned in Horsmonden are going to be built on green spaces, this policy does not make sense. We already have green, open spaces so why build on them? Education - in the villages where many dwellings have been planned, the feel of a small village school will be ruined by the extending of the school to accomodate the extra children. Currently, many village schools have one form entry meaning that all children in all years get to know each other. With multiple form intake schools, the idea of the school being a community in itself is disipated and everyone no longer knows everyone else making school a less friendly place, particularly for young children. Health - I agree that the healthcare in villages needs to be increased. Will the new surgery be placed within the centre of the village and in walking distance to residents? Will funds be enough to actually provide this extra facility? |
DLP_2836 | Helen Parrish | Object | There no Infrastructure Plans or Infrastructure Risk Assessments There are no emergency services plans The increased Potable and Waste Water demands have not had identified how they will be met |
DLP_3173 | Kent County Council (Growth, Environment and Transport) | Support with conditions | Highways and Transportation The Local Highway Authority conditionally supports this policy. The following amendments should be made: Provision and Delivery of County Council Community Services The County Council is supportive of references to essential infrastructure and connectivity. Waste Management The County Council requests the inclusion of Waste in this policy, suggested text is as follows: Provision will be made for sufficient waste capacity in the form of expanded or new waste infrastructure, with all relevant developments contributing to these through land and/or contributions and strategic developments providing land and contributing to the cost of delivering new waste infrastructure. Any new provision will be determined through consultation with KCC. |
DLP_4362 | British Horse Society | Support with conditions | Under the list of proposed green, grey and blue infrastructure, public bridleways should also be mentioned. |
DLP_4535 | Historic England | Policy STR 5: Essential Infrastructure and Connectivity – consder the inclusion of reference to heritage assets within Cultural infrastructure section of this policy. | |
DLP_3913 | Ide Planning for Paddock Wood Town Council | Object | OBJECT as per STR1 In addition –
The existing surface and foul water systems are inadequate, with frequent surface water flooding across the town and leakage of sewage onto roads and gardens – discussions are taking place with Southern Water but there is some reluctance on the part of Southern Water to commit to a fool proof solution to this problem. Additional building on the flood plain around Paddock Wood will exacerbate surface water flooding within the town centre as there will be less open space for water to run off into. Will the proposed Tudeley Village be serviced by PW or Tonbridge sewage treatment works – Paddock Wood WWTW will not cope with an additional 1800-2800 houses and the Station Road pumping station is barely able to cope with existing flows from PW and Five Oak Green/Capel. |
DLP_5605 | Mrs Jacqueline Hewitt | General Observation | TWBC: the following response was submitted by the responders on the left: Policy STR 5 5. New residential and commercial development will be supported if sufficient infrastructure capacity is either available, or can be provided in time to serve the development. Sufficient infrastructure capacity is not available to support large scale allocations AL/CRS 4 Turnden, AL/CRS 6 Gate Farm, AL/CRS 7 Golford, AL/CRS 9 Brick Kiln, in Cranbrook and Sissinghurst and could not possibly be provided in time to meet such large-scale allocations. This is NOT infrastructure led planning policy. |
DLP_3998 | Lamberhurst Parish Council | Support | STR5 – Essential Infrastructure & Connectivity Generally supported |
DLP_6035 | Mr C Mackonochie | Support with conditions | The appropriate infrastructure must be put in place prior or keep pace with the needs of the occupiers of the new developments. For instance Transport, Water and digital infrastructure needs to be in place at the day 1 whilst others such as Education can be actioned when the need arises |
DLP_5675 | Mr Martin Burgess | Object | I find it inconceivable that local planning authorities are not coordinated with a regional development planning for infrastructure of roads services, etc and KCC budget. There are towns and villages now that experience traffic congestion from through traffic, transient population for schools and business, plus, parking that obstructs the same arteries carrying most traffic. In the present economic climate, affordable housing in these semi remote areas needs some form of public transport. Not all planning is located to take advantage of transport service links. Is the bulk of developments servicing private land lords or buyers. Already some small developments can't attract enough interest in what is presently being developed. I can only look forward to all the inconvenience further development will cause without the necessary infrastructure up grades needed. Viewed dispassionately there seems to be a drive for building houses and nothing else, with a hope that the existing infrastructure will be sufficient. . There is still a section of the A 21 between Lamberhurst and Pembury that still needs up grading from a two lane A road. |
DLP_4883 | Berkeley Strategic Land Ltd | Support | Policy STR 5 – Essential Infrastructure and Connectivity |
DLP_4303 | White Young Green Planning for Standard Life Investments UK Real Estate Fund | Object | Policy ST 5 Essential Infrastructure & Connectivity
In view of the above, it is advised that Policy ST 5 (Essential Infrastructure and Connectivity) is revised to read, as follows: “Essential infrastructure provision and improved connectivity w ill be coordinated to ensure that growth is supported by appropriat e infrastructure, services and facilities needed to maintain and improve quality of life and respo nd to the needs of local peopl e and businesses. |
DLP_5223 | Culverden Residents Association | General Observation | Although TWBC is not the lead authority in respect of any of the main infrastructure, we think it should do more to develop joined up thinking by some responsible Authorities such as KCC. For example KCC still favours school siting policies that lead to motor traffic congestion in our area with adverse effects on our members and on KCC in its highways policies. |
DLP_4662 | CBRE Ltd for Dandara Ltd | Support with conditions | Draft Local Plan Policy STR5: ‘Essential Infrastructure and Connectivity’ 3.54 Dandara welcomes the intentions of Policy STR5 and the importance of the delivery of necessary infrastructure, services and facilities to serve the needs arising from new development. It is further noted that new infrastructure can positively act as a catalyst for new development. It is suggested, however, that Policy STR5 refers to ‘improvement’ rather than ‘betterment’ to reflect the objectives of STR5, and not to be confused with ‘betterment’ in a land value sense. 3.55 Dandara urges TWBC to ensure that any financial contributions that may be needed, to be secured by way of Section 106, are fair and proportionate to the scale of the proposed development. Furthermore, such moneys must be invested as intended and within set timescales so as not to halt new development, in the interests of delivering new homes and jobs. 3.56 In respect of education and school places, Dandara supports the provision of sufficient school places in the form of expanded or new primary and secondary schools, together with early years and childcare facilities, and acknowledges that new developments should contribute through land and/or contributions towards school provision. 3.57 Dandara is committed to helping to facilitate delivery of a new secondary school at Spratsbrook Farm through the provision of land for Kent County Council to construct the school. 3.58 Dandara further supports the provision of new health, water infrastructure, digital infrastructure and utilities, green, grey and blue infrastructure and cultural infrastructure under Policy STR5. [TWBC: see full representation]. |
DLP_4469 | Paddock Wood Neighbourhood Plan Steering Group | Object | The roads are already congested in the mornings particularly the main Maidstone Road through Paddock Wood, adding an additional 4000 homes would significantly increase traffic through the town, even if some developments are accessed from the A228. The additional houses to the east would be served by narrow country roads, encouraging traffic through the town and over the single bridge over the railway to go north. There are plans to bypass Five Oak Green/Colts Hill, whilst there is no mention of a road to relieve the centre of Paddock Wood. It cannot be expected to add 4000 houses to a B road through the town. This volume of housing would need a new road from the east of the town to the north to prevent congestion in the centre of town. Maidstone Road which is the spine and through road of the current town is a B road, rendered in places single way by parked cars. There should also be a road from the East of the town south of the railway to the North of the railway line emerging close to or through Transvesa to connect with the northern portion of the Maidstone Road. The bridle way leading from Maidstone Road at Eastlands should be upgraded and extended to connect with the A228 North of the Badsell roundabout The railway is already at capacity & with additional houses being built downline at Headcorn, Staplehurst & Marden, there will be further overcrowding and travel difficulties – doubling the size of the town will make it impossible to get on to a train during traditional commuting hours. The existing surface and foul water system are inadequate, with frequent surface water flooding across the town and leakage of sewage onto roads and gardens – discussions are taking place with Southern Water but there is some reluctance on the part of Southern Water to commit to a fool proof solution to this problem. Additional building on the flood plain around Paddock Wood will exacerbate surface water flooding within the town centre as there will be less open space for water to run off into. Will the proposed Tudeley Village be serviced by PW or Tonbridge sewage treatment works – Paddock Wood WWTW will not cope with an additional 1800-2800 houses and the Station Road pumping station is barely able to cope with existing flows from PW and Five Oak Green/Capel. |
DLP_4906 | Woodland Trust | About the Woodland Trust The Woodland Trust (“the Trust”) is the UK's leading woodland conservation charity, and wants to see a UK that is rich in native woods and trees, for people and wildlife. We aim to achieve this by restoring and improving woodland biodiversity and increasing people's understanding and enjoyment of woods and trees. We own over 1,275 sites across the UK, including Friezland Wood in the Borough. In total our sites cover over 23,580 hectares and we have around 500,000 members and supporters. The Trust is recognised as a national authority on woods and trees and a protector of the benefits and values that they deliver for society. We welcome the opportunity to comment on the draft Tunbridge Wells Local Plan 2035. We welcome the inclusion of green infrastructure as part of essential infrastructure and connectivity. We would recommend adding explicit reference to hedgerows and street trees, in addition to the existing welcome inclusion of woodland and community orchards, in the section headed Green, grey and blue infrastructure. Hedgerows and trees outside woods provide vital connectivity between habitats, contribute shelter and shade, and assist with water management, among other green infrastructure benefits. | |
DLP_3776 | Mary Jefferies | Object | The TWBC Local Plan fails to address the Hawkhurst and surrounding areas infrastructure and services required for this overwhelming number of additional dwellings. The vast increase in the local population will require healthcare support, educational facilities and an efficient sewage disposal system. |
DLP_4592 | Keith Stockman | Object | Policy STR 5 5. New residential and commercial development will be supported if sufficient infrastructure capacity is either available, or can be provided in time to serve the development. Sufficient infrastructure capacity is not available to support large scale allocations AL/CRS 4 Turnden, AL/CRS 6 Gate Farm, AL/CRS 7 Golford, AL/CRS 9 Brick Kiln, in Cranbrook and Sissinghurst and could not possibly be provided in time to meet such large scale allocations. This is NOT infrastructure led planning policy. |
DLP_5646 | Michael Vos | Object |
There is no need in the plan period for a new secondary school there being ample capacity available already. If such need were to exist (which is not accepted) then it is in the North of Tunbridge Wells not on the south side of the town. |
DLP_6865 | Barton Willmore for Crest Nicholson | v) Policy STR5: Essential Infrastructure and Connectivity 5.22 We largely support the objectives and aspirations of this policy in respect of: * Essential Infrastructure and Connectivity; 5.23 We note that “Transport” is dealt with separately under “Policy STR6”. 5.24 In respect of the above matters, our only query relates to the use and inclusion of the words “to provide betterment” (in the “Essential Infrastructure and Connectivity” section). These words can depict a number of meanings – certainly in the “planning world” – and the Draft Local Plan’s Glossary fails to provide any greater understanding of such words. 5.25 These words are also repeated in subsequent sections of the Local Plan. It is therefore requested that TWBC provides specific clarification in respect of the use of these words. [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_6404 | Hawkhurst Parish Council | Support with conditions | STR5 - Essential Infrastructure and Connectivity |
DLP_7632 | Mr J Boxall | Support with conditions | Section 106 monies from developments should be kept within the specific town, village or ward to which the development relates. For example, monies from developments within Sissinghurst village should be kept to improve facilities within Sissinghurst village only, not passed to Cranbrook and Sissinghurst Parish generally. The TWBC growth strategy is based on the premise of infrastructure-led development. Key infrastructure required for additional housing in Sissinghurst includes greater accessibility to Tunbridge Wells on a dualled A21 between Lamberhurst and Blue Boys. This infrastructure is not in place and will not be in place before the housing in this plan is developed so much more development should be in Tunbridge Wells or adjacent to the already dualled A21. Cranbrook has greater infrastructure and facilities than Sissinghurst so any new development for this parish should be focussed there but overall all the Local Plan should be amended to put more housing development in Tunbridge Wells and areas adjacent to the already dualled A21 rather than unsustainable development in the eastern side of he Borough. Public transport must be improved in the evenings as well as the day for all villages connecting to towns, including those outside of the Borough such as Sissinghurst to Tenterden as well as Sissinghurst to Tunbridge Wells and Maidstone. The Borough should encourage cheaper and more frequent public transport to encourage additional useage, especially in the rural eastern areas of the Borough. Strategic bus and rail services should be improved firstly for those residents who wish to travel within the Borough. |
DLP_7701 | Ms Christine Ferguson | Object | 3. The otherwise very welcome dualling of the A21 at Castle Hill has relieved congestion at Tonbridge and at North Farm but shifted it southwards towards Kippings Cross where we regularly encounter significant delays (heading south, traffic is often queuing back to the Pembury turn off). Further building along the A21 south of Tunbridge Wells and in the surrounding villages such as Matfield and Pembury which have to access the A21 to get to shops/work etc will simply exacerbate this problem. I would therefore urge the Council to pause plans to build in these areas until the A21 is dualled, at least as far as the Lamberhurst bypass. |
DLP_6773 | Mrs Carol Richards | Object | STR 5 (Essential Infrastructure and Connectivity) and preceding paras 4.53-4.58 It would be helpful to add to the opening paragraph “All infrastructure required for the garden settlements must be described in detail before the Local Plan is adopted, signed off via public consultation and a TWBC Full Council vote and delivered and inspected in full before the first house within the garden settlement is built.” TMBC cannot surely believe that future infrastructure will mitigate the impact of future development. You cannot mitigate against a flood plain you can’t mitigate the impact of the traffic along the B2017, even with a dual carriageway here it would come to a grinding halt at the Woodgate roundabout ( near the proposed school)and just tail back towards Tudeley. I will say AGAIN TONBRIDGE CENTRE will have queues on every artery into the town. There are clear issues here that need cross-boundary co-operation, in line with NPPF paras 24-27, for instance: “Local planning authorities and county councils (in two-tier areas) are under a duty to cooperate with each other, and with other prescribed bodies, on strategic matters that cross administrative boundaries”. However, there have been no details of this proposal anywhere in Tonbridge for the local population to consider and examine. I had to ask for a copy of the Draft Plan to come to Tonbridge Library w/c 21/10/19. I therefore conclude that the LP is unsound as it fails to address this key requirement within the NPPF for effective cooperation, ie informing the residents of Tonbridge. Policy STR 5 (Water) “If we do not increase water supply, reduce demand, and cut down on wastage. Many areas will face significant water deficits by 2050, particularly in the south east“ Kent is one of the driest regions in England and Wales and use of water is already at capacity and in some cases exceeding it. This water stress will be exacerbated by a growing population.( Water efficiency Background Paper/National and Regional Legislation/Policy and Guidance p 6) This is another reason why TWBC should be building no more than 13,560 not 14,776 new homes. South East Water consider there will be no deficits in service as a result of the growth planned- so I presume there will be no hose pipe bans. I think I trust the Environment Agency Assessment here. |
DLP_7281 | Mrs Katie Lee-Amies | Support with conditions | Strategic Policies (comments already included above) [TWBC: See comments DLP_7265-7267 and 7269-7277] STR 1 – object. STR 2 – object. STR 3 – object. The masterplan excuse! STR 4 – object. Strongly. STR 5 – support with conditions. Insufficient information. STR 6 – object. STR 7 – object. STR 8 - object. STR 9 – object. There are no LBD details for Tudeley STR 10 – object. |
DLP_7227 | Elizabeth Daley | Support with conditions | Sufficient infrastructure capacity is not available to support large scale allocations AL/CRS 4 Turnden, AL/CRS 6 Gate Farm, AL/CRS 7 Golford, AL/CRS 9 Brick Kiln, in Cranbrook and Sissinghurst and could not possibly be provided in time to meet such large scale allocations. This is NOT infrastructure led planning policy. |
DLP_6291 | Mrs Elizabeth Simpson | Object | Policy Number: STR5 STR 5 sets out the ways that all necessary infrastructure, services and facilities will be provided to meet needs arising from new development. Developers will be expected to provide or contribute significantly towards additional requirements. STR 5 (5) states that, “New residential and commercial development will be supported if sufficient infrastructure capacity is either available, or can be provided in time to serve the development.” There are many instances already, where inadequate infrastructure is in place and there appears little prospect of it being provided. The policies set out in the draft local plan do not appear to be been prepared in proper coordination with utility providers. For example, as reported in the Courier newspaper on 8 November 2019 the Paddock Wood new “estate style” developments are being built with inadequate drainage being in place, the developers cannot provide it as there is simply no capacity currently in the sewerage system and Southern Water are unable to advise when there will be capacity. Apparently septic tanks are being provided as a solution to each new home! This is hardly sustainable development |
DLP_6986 | Nigel Tubman | Support with conditions | A fine policy if backed up by action. But, the plan does not go nearly far enough in providing essential infrastructure and connectivity. Providing additional infrastructure needs to be across the whole of TWBC geographical area and not concentrated on the western part. |
DLP_6086 | Christopher Wallwork | Support with conditions | Infrastructure in the area is already dangerously overstretched; it is essential that new infrastructure be completed prior to the start of any new developments. This includes schools, GP surgeries, the new A228 route, improved slip roads on the A21, new cycle routes and bus lanes, increased sewerage capacity and others. |
DLP_6296 | Susan Heather McAuley | General Observation | Essential Infrastructure and Connectivity Point 1 - I think in earlier parts of the Local Plan it was stated that developers should provide any necessary infrastructure. This Policy says they should ‘provide or contribute’ to it. Given that the history of getting money from developers for infrastructure has been poor where I live, this seems like a softening of TWBC’s stance already. Green, grey and blue infrastructure – ‘Community Orchards’ is developers’ language and I do not think belong in this policy. ‘Community Orchards’ are created to make up for the green space, allotments, open fields and informal footpaths lost to new buildings. They are no longer taken seriously? |
DLP_6583 | Myrtle Newsom | Object | Policy Number: STR5 Neither Sissinghurst nor Cranbrook have the necessary infrastructure and facilities to warrant the amount of proposed housing development. What date is planned for the dual Carriageway on the A21 between Lamberhurst and Blue Boys? |
DLP_6602 | Michael Lloyd | Support with conditions | Policy Number: STR 5.5 ‘New residential and commercial development will be supported if sufficient infrastructure capacity is either available, or can be provided in time to serve the development.’ A pious claim more honoured in the breach in Cranbrook, where 900-plus houses are planned with no provision for improved roads, services or other infrastructure. |
DLP_6612 | AAH Planning for Future Habitat Ltd | Support with conditions | Policy STR 5 – Essential Infrastructure and Connectivity Our Client is broadly supportive of this policy but would like to reiterate that the requirements must be subject to viability to ensure that new development can be deliverable. Our Client is committed to ensuring that new development is supported by suitable infrastructure to ensure that schemes are highly accessible and sustainable long-term. This needs to be set against viability and our Client therefore seeks flexibility in the wording of the policy. [TWBC: see full representation and site plan attached]. [TWBC: see also Comment Nos. DLP_6606-6620, 6622-6627]. |
DLP_6789 | G M Whitehead | Object | STR5.5 ‘New residential and commercial development will be supported if sufficient infrastructure capacity is either available, or can be provided in time to serve the development.’ Cranbrook is lacking in basic infrastructure. There are few buses and none linking with trains at Staplehurst where the car park is already at about capacity. Some development providing employment would be good but the types of houses the developers want to build are too expensive for people working locally. So does that mean you will refuse the development being offered? I suspect not! |
DLP_6948 | Hallam Land Management Ltd | Table Number: STR 5 | |
DLP_7091 | Brown & Co Planning Ltd for The Hendy Group | Support with conditions | Policy STR 5 - Essential Infrastructure and Connectivity; support with conditions 1.129 Policy STR 5 states that it is “essential that all new development will be supported by the provision of the necessary infrastructure”. 1.130 The Council cannot rely solely on new development to meet infrastructure needs and both the Council and statutory providers will also need to contribute in order to address existing deficiencies in infrastructure in Tunbridge Wells (see comments above on the Vision and Objectives 1). 1.131 Our Client would like to highlight that it is not financially viable for every new development to provide infrastructure and that the level of infrastructure ‘necessary’ should be proportionate to the merits of the individual site. Support subject to the following amendments: * The wording should change to “where financially viable all new development will be supported by the provision of the necessary infrastructure”. [TWBC: see full representation and supporting documents; Park and Ride Feasibility Review and Site Location Plan]. |
DLP_7096 | Richard Hopkinson Architects for J Murphy & Sons and SGN | Support with conditions | Policy Number: STR 5 – Essential Infrastructure and Connectivity Policy STR 5 addresses how necessary infrastructure, services and facilities will be delivered to support new development in the Borough. It confirms that, where a need is identified, … “developers will be expected to provide and/or contribute significantly towards the additional requirements”. It further states that detailed specifications of the site-specific contributions required are included in the overarching place shaping policies and individual site allocation policies (in Section 5). J Murphy & Sons (JMS) and SGN agree that developers must contribute to providing the infrastructure necessary to mitigate the impacts of particular developments, where they meet the tests set out in regulations that planning obligations must be necessary, directly related to a development and fairly and reasonably related in scale and kind to the development. They are, however, concerned that neither Policy STR 5 nor the site allocation policies provide any flexibility in their application that would ensure that sites remain viable and deliverable through the life of the Local Plan. The draft Local Plan is accompanied by the ‘Local Plan and CIL Stage 1 Viability Assessment’, which considers the impact of the development costs associated with the draft Local Plan policies on the deliverability of the Local Plan strategy. Viability is tested against a range of site and development ‘typologies’, which are considered typical and representative but, by their nature, are not exhaustive. The Stage 1 assessment finds that, broadly speaking, the draft Local Plan is deliverable from a viability perspective. Further testing is, however, required. Amongst its recommendations, the report makes clear that the viability of larger / strategic site allocations should be tested through Stage 2 Assessment. The requirement for further testing is then confirmed in supporting text to Policy STR 5 of the draft Local Plan at paragraph 4.55. The Viability Assessment also recommends that … “TWBC continues to consider, monitor and keep under review the potential cumulative impact and rigidity of expectations related to policy costs and obligations, however, alongside the AH policies and bearing in mind the wide range of influences on viability and on the other aspects of delivery – e.g. varying market, locations, sites and schemes.” This is particularly relevant to sites that face abnormal development costs, over and above those tested in the Viability Assessment, where rigid expectations may ultimately undermine whether a site is deliverable. The NPPF states that policies setting out the contributions expected from development should not undermine the deliverability of the Plan (para.34). In light of the scope of the viability evidence provided to support the draft Local Plan and its recommendations, and the range of influences on development viability over the life-time of the Local Plan, it is right that Policy STR 5 and the accompanying text (see also comment box relating to para.4.55) incorporate some flexibility to ensure that key sites remain viable and deliverable. JMS and SGN therefore request that the following additional wording be added to Policy STR 5: “For the site allocations, the policies set out in this Plan may be applied flexibly to ensure that the sites are viable and deliverable.” This is an approach that has recently been recommended by the Inspector appointed to examine the Tower Hamlets Local Plan, where the need to incorporate flexibility in relation to policy expectations for particular site allocations was supported, particularly in relation to the development of former gas works sites (see Tower Hamlets Local Plan Report of Examination, 20 September 2019). Paragraph 4.55 (Essential Infrastructure and Connectivity) Please see comments in relation to Policy STR 5. JMS and SGN request that the following text be added to Paragraph 4.55 to ensure that policy expectations do not undermine the viability or deliverability of the allocated development sites: “When determining a planning application, flexibility may be applied to the policies relating to the site allocation requirements and expected contributions based on an up-to-date assessment of need and the agreed viability position of the scheme to ensure the site allocation is deliverable in the context of the principles of sustainable development.” This paragraph also confirms that a Phase 2 viability assessment will assess the strategic site allocations, albeit these are not defined. JMS and SGN consider that further testing of the former Gas Works Site on Sandhurst Road, as identified by draft Local Plan Policy AL/RTW 29, should be undertaken. |
DLP_7329 | Campaign to Protect Hawkhurst Village | Object | Paragraph 5 of STR5 provides that new residential and commercial development will be supported if sufficient infrastructure capacity is either available of can be provided in time to serve the development. The east of the borough (and in particular Hawkhurst) is poorly served by public transport and has limited services. The Policy should make clear that the priority should be for necessary infrastructure to be delivered in accessible locations to new development to avoid reliance on the use of private cars and the consequential impacts in traffic, air quality, noise and climate change. As currently drafted the implication is the infrastructure could be delivered anywhere in the Borough which fails to reflect the stated sustainability objectives elsewhere in the DLP. The policy should place far greater emphasis on the need for development to be located in areas genuinely accessible to key services. This is particularly relevant in Hawkhurst where by way of one example even the proposed one form increased capacity at the Primary School will be insufficient to meet the need generated by all the proposed housing allocations within the village. This will also ensure consistency with STR6 |
DLP_7517 | Sarah Parrish | Object | Why are there no Infrastructure Plans or Infrastructure Risk Assessments? Why are there no emergency services plans? How will increased Potable and Waste Water demands be met? |
DLP_7505 | Mr and Mrs A J Herbert | Object | STR 5 states that the growth strategy is based on the premise of infrastructure-led development. Decisions on infrastructure projects rest with other public and private authorities. In planning for new housing sites should only be progressed when there is certainty over the provision of the required infrastructure and public services to support the new development. The Draft Local Plan does not give the information and detail to confirm the required infrastructure and services will be in place for a much larger community. |
Policy STR 6: Transport and Parking
Comment No. | Name/Organisation | Object/support/support with conditions/general observation | Response |
|---|---|---|---|
DLP_7745 | Mrs Susan May | Object | The so-called “relief road” at Hawkhurst is a nonsense and will not relieve the traffic congestion at the traffic lights. It appears the Highways department had not realised that traffic will still be turning right from the Rye Road down Highgate Hill and therefore still requiring three phases as now, plus the pedestrian phase when activated. Moreover, it includes a roundabout to the west of the traffic lights, and this is anathema to the High Weald AONB since roundabouts are not in keeping with this as explicitly mentioned in their HWAONB-Building-Design-Guidance-2019: “Roundabouts are uncharacteristic of street patterns within High Weald settlements and should not be used in new housing schemes in the area.” Para 3: This relies on the relief road being effective, which it won’t be, and also that the development on the golf course will go ahead, ignoring the people who live here. |
DLP_53 | Thomas Weinberg | Object | Comments on Policy STR 6 (Transport and Parking) p.54 The closest rail station in Tonbridge which is already heavily used and accessible by one road. Bus lanes along Woodgate Way, Pembury Road up to Station Approach would be needed requiring the demolition of hedgerow and housing. |
DLP_7779 | Annie Hopper | General Observation | Policy STR6 8 b. How does TWBC propose to do this? |
DLP_7792 | Robert Saunders | Object | But where will residents of the new dwellings work, and how will they get there? P53 Section 4 – 4.59 ‘In accordance with the NPPF, this draft local plan will aim to facilitate all forms of sustainable transport, ranging from active travel, public transport, car share, car club, ULEV….should be done in all instances to reduce private car dependence in the borough’. Given the serious congestion that already afflicts the A21, A26, A264 and A228 and the pinch points at Goudhurst, Flimwell and Hawkhurst, and taking into account that Staplehurst and Marden station car parks already operate at capacity at peak times, the impact of additional private car use must be carefully evaluated and either strongly discouraged or alternatively catered for – and rapidly. |
DLP_7804 | Mr Colin Sefton | Support with conditions | I welcome the statement that:- “a sufficient level of car parking facilities will be provided for both residential and non-residential purposes at suitable standards within all settlements of the borough, and particularly where private car or van ownership and travel is especially high.” In practice I believe that new developments should incorporate within the development outside parking for at least 1 vehicle for 1 bedroom properties and at least 2 vehicles for all other properties. |
DLP_135 | Gregg Newman | An addition is required as follows: “All sustainable transport services, with proven capacity to hold the entire population of the garden settlement, must be provided and active before the first house within the garden settlement is built.” The roads are simply not able to provide the capacity to allow for this. As noted many times above, the nearest town is actually Tonbridge. It is impossible to think that the necessary road changes can be achieved to allow this to happen – or if you believe they can then absolutely no evidence to this effect has been provided. Also as noted above, every family nowadays has at least two cars – this would add at least 5,000 more cars requiring access, plus all of the hoe deliveries, etc. that go with modern living. To make this viable to young families (obviously the goal) it must be realised that they will mostly work in London or other centres. How will they get there? Either by bus (see above) or by car to stations which are already at capacity in terms of parking and carriages. Present roads are rural, they have no pavements nor lighting. If you are expecting children to commute to school there will be deaths. There can be no gainsaying this. Your plan is dangerous in the extreme. You have simply not met this requirement and hence this plan fails | |
DLP_7848 | Judith Williams | Object | I find that the "Local Plan" makes terrifying and bewildering reading. |
DLP_7868 | Andrew Hues | Object | TWBC: the standard response was submitted by the list of responders on the left: In relation to the proposed developments at Hawkhurst, the transport objections are set out under STR 1 above. [TWBC: See corresponding comment under STR 1 above] |
DLP_8033 | Rose May McAuley | Object | You are going to improve buses in eth town of Tun Wells. We are not included in this over in Sissinghurst. Tun Wells is going to get every good, we are going to get everything not good. We cannot have safe cycling routes as the roads are too busy. |
DLP_566 | Road Haulage Association Ltd | Summary of the Consultation
General Comments
Final Comments. The RHA is willing to meet policy and decision makers at any time to enable road freight issues to be resolved. | |
DLP_8109 | Ashley Saunders | Support with conditions | An addition is required as follows: “All sustainable transport services, with proven capacity to hold the entire population of the garden settlement, must be provided and active before the first house within the garden settlement is built.” Note that you can only provide rapid bus links if you provide dedicated bus lanes. For Tudeley, the closest rail station in Tonbridge, it will require bus lanes along Woodgate Way, Pembury Road and all the way up to Station Approach. CPC support the ambition regarding sustainable travel but the only way to do that will be to provide limited car parking and limited car access into the new development at Tudeley. This may conflict with the ambitions of the landowner. CPC insist transport services are provided before the houses are built as part of the master planning approach. |
DLP_8162 | Myriam Ruelle | General Observation | Policy STR 6: Observation. Unclear as to what is being done with public transport companies to enhance bus and rail links. Unclear as to what is being done to tackle the parking problems for existing residents. It is a fallacy to think that people buying new homes will not have their own private transport. |
DLP_8168 | Highways England | Highways England notes that ‘Traffic and car parking will be carefully managed through developing innovative strategies that will both provide a sufficient level of parking in the borough as well as encourage sustainable travel’. In order to minimise the impact of additional development on the already congested SRN, it is vital to avoid an over-provision of car parking spaces. An oversupply of parking is likely to limit the effectiveness of demand management measures, which, in accordance with the NPPF and local policies, are important in encouraging a reduction in travel and the use of sustainable modes. Consequently, in accessible locations the Council should seek to reduce the number of car parking spaces where appropriate and to encourage the provision and use of sustainable transport modes. TWBC: see Technical Note. See also full representation]. | |
DLP_8197 | Mrs Suzi Rich | Object | I support some elements of this policy, in particular point 1. ‘Continue to develop and provide an integrated strategic cycle network…’, point 6. ‘Incorporate electric car charging points (or any new technology requirements) into new developments, and where possible into existing public and private car parks and street furniture;’ The proposed offline A228 strategic transport link (Colts Hill bypass) is NOT the best way to mitigate the impact of development proposed in the dLP. The plans to bypass the existing A228 are almost 40 years old and need to be reconsidered and all options i.e. widening etc. investigated. It is unclear why TWBC considers that residents of the new settlement at Tudeley will want to travel to Colts Hill via a link road which runs almost parallel to the newly dualled A21. I am of the view that the A228 strategic transport link (Colts Hill bypass) has been included in the Draft Local Plan as a sweetener to a minority of Capel residents who have campaigned for the bypass for a number of years simply because they live on that stretch of road. It appears that the highways issues in Capel Parish have been misrepresented to TWBC for a number of years by individuals with a conflict of interest. [TWBC: See comments DLP_8189-8214 for full representation] |
DLP_722 | Dr P Whitbourn | Support with conditions | Although public transport is seen in paragraph 6.506 as an essential objective, there does not seem to be a great deal in the Plan on the subject, especially on the key topic of bus services. Royal Tunbridge Wells is an important bus node, with routes radiating to Brighton, Eastbourne, Maidstone, Tonbridge, Crawley and many other destinations. Rural routes are vital to many villages in the area, and people depend upon these services to get to and from work and to shop or to attend schools. Vital too are the bus links within the town centre and with the North Farm area and the Hospital. I realise, of course, that the Borough Council is not the Highway Authority and that much of the responsibility for the organisation of bus services rests with commercially minded bus operators. Nevertheless, I would hope that the Local Authority would be doing whatever it can to look after the public interest in relation to bus services. Tunbridge Wells has no bus station comparable with those at Canterbury and some other towns, nor does it necessarily need one if upper Mount Pleasant efficiently fulfils that role, with clear boarding points convenient interchange facilities, travel and timetable information, shelters and so on. While, therefore, I support Policy STR6 as far as it goes, I feel that more could feature in the plan on this highly important aspect of public transport. |
DLP_8262 | Ann Gibson | Object | It therefore follows from the above statement that at least 50% of the residents of new houses in Sissinghurst will get into a car to commute out of the borough to work. Why then are so many houses being built so far from major settlements and train stations? eg.Maidstone: 14 miles, Tunbridge Wells 14 miles, Hastings 18 miles, Ashford 18 miles Staplehurst Station, 6 miles (car park full at peak), Marden Station 8.6 miles (car park full at peak) Significant bottlenecks and traffic jams are regularly created at Hawkhurst, Goudhurst and Sissinghurst when people are trying to leave the Parishes of Sissinghurst and Cranbrook during peak work times. This is not infrastructure led development. This cannot be sustainable. |
DLP_8275 | Ann Gibson | General Observation | STR 6.8b Retain and improve the strategic rail network by increasing rail capacity, reliability, and punctuality , as well as overall journey times by rail. The train service from Staplehurst was very nearly reduced within the last few years and that was only prevented due to public outcry. Are Network Rail and the Train Operating Companies answerable to TWBC in terms of timetables,increasing capacity, reliability, and punctuality? |
DLP_861 | Ian Pattenden | Comments on Policy STR 6 (Transport and Parking) p.54 An addition is required as follows: “All sustainable transport services, with proven capacity to hold the entire population of the garden settlement, must be provided and active before the first house within the garden settlement is built.” Note that you can only provide rapid bus links if you provide dedicated bus lanes. For Tudeley, the closest rail station is Tonbridge, so you’ll need bus lanes all along the B2017, Woodgate Way, Pembury Road and all the way up to Station Approach at Tonbridge, an impossible dream. The ancient town of Tonbridge cannot sustain infrastructure changes of the sort inferred in your plan and I am sure that any attempt to do so will be robustly opposed by TMBC. | |
DLP_911 | Nigel Stratton | Object | It does not seem to me that sufficient effort has been put into determinig whether the existing infrastructure will be able to support any new house building. At the moment, as I understand it, a new Borough Transport Policy is to be prepared. The contents of this are vital. As a resident of Pembury I would specifically comment on the following: 1. It is proposed to safeguard the land needed for the Colts Hill Bypass. If built this would simply accelerate the traffic arriving at Woodsgate Corner and the already bad congestion there. There is no proposal as to how this can be dealt with. 2. The existing local roads cannot come with the existing parking or traffic. There is no proposal at to how this will be dealt with. 3. The proposal for the development of part of the Tescos site by Hendy should be stopped. 4. This site should be safeguarded for a future park and ride scheme. 5. The Borough Council should also be looking for other sites around Tunbridge Wells for park and ride. Possibly one at the Industrial Estate and one south of Tunbridge Wells. We need to stop the congestion and pollution of so many cars trying to access the centre of Tunbridge Wells. 6. This could lead to more electric public service vehicles in the long term; cutting pollution and cutting congestions. Perhaps the centre of Tunbridge Wells should only be accessed by public service vehicles during certain hours in the morning and in the evening. 7. There is a need to continue the dualling of the A21 from Kippings Cross to Lamberhurst. |
DLP_941 | Mrs Karen Stevenson | Object | STR 6 makes the commitment to facilitate sustainable modes of transport to reduce dependence on private car use. The policy states that provision will be made to maintain and improve transport infrastructure, working with partners to e.g.: increase rail capacity; reduce rail journey times; improve rail station infrastructure where necessary; improve the strategic highways network, including projects to improve the A21from Kippings Cross to Lamberhurst and the A228 Colts Hill bypass, and to enhance existing bus services. Yet, as already referred to under “Language” there is no substance to support these stated intentions. There is no clear agreement with Network Rail to enhance train services. Bus services are currently deteriorating rather than being improved, e.g. the 297 from Tunbridge Wells to Tenterden recently being outsourced by Arriva to a smaller local company to run. There are no bus services serving the villages after 6pm, so whilst from Matfield it is possible get a bus to catch a train at Paddock Wood it is not possible to get one back after a working day in London. Developing in rural areas and villages, with inadequate public transport and which is never likely to be truly sustainable, it certainly will be at odds with environmental concerns about tackling global warming. A government strategy to be carbon neutral by 2050, does not sit well with proposals to develop where car use will be necessary for every resident journey. |
DLP_1027 | Liz Copping | “Traffic and car parking will be carefully managed through developing innovative strategies that will both provide a sufficient level of parking in the borough as well as encourage sustainable travel. The Council, as Local Planning Authority, will be closely involved with the Council's forthcoming Parking Strategy, to ensure an integrated approach to parking, transport, and land use planning. Development proposals that have significant transport implications will be required to be accompanied by a transport assessment and travel plan showing how car based travel can be minimised (see Table 8).” What happens when the, on average, 761 houses are built within Cranbrook and each household has in 2017/2018, on average, 1.4 vehicles per household in the South East*. No matter how innovative and carefully managed a parking strategy is, the fact is people will still move into the area, into their new home, with on average, 1.4 vehicles. I am glad a parking strategy will be developed and that larger developments need to provide a travel plan to minimise car based travel, but what is going to be done about the surrounding roads and infrastructure that is already at maximum capacity, without the additional, on average 1065 vehicles???? *https://www.statista.com/statistics/314912/average-number-of-cars-per-household-in-england/ “All developments will be of high quality design, having responded to the distinctive and particular character of their locations: in some instances the development will have taken place within valued and protected landscapes, and this will be recognised in the quality of the design of the development, the protection and enhancement of the exceptional quality of the built, natural, and historic environment, and the provision and protection of landscape features and green spaces” If this is true, can we expect that all new developments will be within keeping of the surrounds areas and not ‘modern’, ‘stand-out’, or ‘architecturally’ different? | |
DLP_1029 | Liz Copping | Table 8 refers to transport assessment and travel plan thresholds. If new development proposals have to enter into legal agreements to secure the delivery of mitigation to address both their direct and cumulative impacts on the transport networks, what size ‘new development’ will be signed up legally, as the current state and usage of the roads is at maximum capacity now? | |
DLP_1108 | Mr John Hurst | Support | Strongly support proposals to enhance cycling and walking, but the glacial speed of such improvements within Tunbridge Wells and around leads to doubt they will be realised in practice. It is currently impossible to walk along many stretches of the A228 near Paddock Wood, for example. Propose that the developments of the key towns of Cranbrook and Hawhurst include the condition of dedicated regular electric bus services between them and local villages and Tunbridge Wells - otherwise more cars (and stranded/lonely non-drivers) will result. |
DLP_1741 | Horsmonden Parish Council | STR6 -Transport and Parking: This policy is badly undermined by the “dispersed growth” strategy in the draft Local Plan. We are concerned that the central thrust of the transport strategy - reducing the need to travel - is negated by directing large amounts of new development to rural settlements with limited facilities and poor public transport, and making such development highly car dependent. This is contrary to NPPF paragraphs 102 and 103. | |
DLP_3677 | Capel Parish Council | Support with conditions | An addition is required as follows: “All sustainable transport services, with proven capacity to hold the entire population of the garden settlement, must be provided and active before the first house within the garden settlement is built.” Note that you can only provide rapid bus links if you provide dedicated bus lanes. For Tudeley, the closest rail station in Tonbridge, it will require bus lanes along Woodgate Way, Pembury Road and all the way up to Station Approach. CPC support the ambition regarding sustainable travel but the only way to do that will be to provide limited car parking and limited car access into the new development at Tudeley. This may conflict with the ambitions of the landowner. CPC insist transport services are provided before the houses are built as part of the master planning approach. |
DLP_1894 | Royal Tunbridge Wells Town Forum | Policy STR 6 Transport and Parking While broadly supporting the modal priorities set out, we would take issue with the implication that non-commercial electric vehicles may be considered a sustainable mode of transport. This is currently open to much doubt as they may merely perpetuate existing modal choice at a quite high environmental cost in terms of electricity generation and air pollution from tyres. In Paragraph 3 mention should be made also to rail access to Brighton, the South Coast and Croydon to take account of possible development of the BML2 route proposal. In relation to Paragraph 8, the Rural Lane network is inherently unsuitable for intensive use by motorised transport and, in stating that the network should be enhanced to ensure that it is convenient and safe for users, the first priority should be given to pedestrian, cyclist and equestrian users, other traffic being discouraged and subject to traffic calming. We broadly support the more specific objectives set out under points a to f in particular improvement of the cycle network, the retention and improvement of the strategic rail network and of existing bus services, the introduction of new bus services to serve the increases in population at Paddock Wood and environs and the use of infrastructure improvements to enhance the historic and green environment and an integrated parking, transport and land use policy. Specific mention should also be made of improvements to pedestrian routes including safe crossing of major roads, because increases in walking within the urban area of RTW represent the fastest and cheapest way of securing substantial growth in active travel. | |
DLP_3053 | Mr Adrian Cory | Object | The “relief road” will not work The so-called “relief road” (which is the brainchild of those who wish to develop the Golf Course) simply would not provide the benefits which have been claimed for it. The case presented by the Campaign to Protect Hawkhurst Village in relation to the recent application for outline planning permission provides ample evidence that it would not resolve the existing problem of congestion at the Hawkhurst crossroads and that developing the golf course – with or without a relief road - would severely impact on traffic flows through the village and the surrounding area. A detailed examination of the proposals, and their potential consequences for traffic flow in and around the village, and on the neighbouring A21, reveals too many shortcomings to be listed here: the proposal is little more than a device by the developers to secure planning approval which has simply not been properly thought through by the authorities. It is not acceptable that the Plan should follow the developer’s agenda by presenting it as any kind of solution to Hawkhurst’s traffic problems without having subjected it to proper independent scrutiny. |
DLP_2728 | St. John's Road Residents Association | General Observation | We completely endorse Paragraph 4.59 which promotes active travel. We agree that bicycle infrastructure needs to be put into place so that residents can be confident that cycling is safe. Only then can we increase cycling usage on our roads and thereby reduce air pollution on our most polluted roads, the A26 being one of the most polluted in the county. Transport is the biggest source of green house gas in the UK. We need to see this fall by 20-60%. We also need to see the proportion of journeys by public transport double. In Tunbridge Wells 19% of people commute by public transport; 16% walk and only 1% cycle. We urge the council to keep to their targets on their Air Quality Action Plan and reduce poor emissions in their Air Quality Management Areas. We endorse the adoption of proposals in the Kent and Medway Energy and Low Emission Strategy. However, we would like to see the roll out of the cycle routes identified in the Tunbridge Wells Cycling Strategy and/or its reinstatement of the cycle path on the A26 route from Tonbridge to Tunbridge Wells where parking spaces have been allowed near Southfield Road. We need to reach a target of 50% of commuters either cycling or walking by 2030. According to research in April 2019, Tunbridge Wells area has only 12 Electric Vehicle (EV) charging points. The Committee on Climate Change recommends 1 EV charging point for every 1,000 vehicles by 2030. We would like to see many more roadside Electric Vehicle (EV) charging points in Tunbridge Wells because many residents do not have driveways or live in flats, therefore, would not be able to install their own EV charging points. In order to encourage many more motorists to use electric vehicles or E-bikes, the council needs to take the right action to help to increase their usage. |
DLP_1976 | Mr Jeremy Waters | Support | I support the sustainable transport and parking aspirations, particularly those relating to cycle paths and electric charging points. |
DLP_2013 | Dr David Parrish | Object | Policy STR 6 (Transport and Parking) p.54 The requirement should be to provide the transport services before the houses are built. |
DLP_1958 | Ms Jacqueline Stanton | Object | I do not support this policy for rural settlements because it does not reduce the need to travel or use cars. The rural settlements, including Horsmonden, have limited facilities and inadequate public transport. The increase in dwellings could increase the need for ownership and use of cars. |
DLP_1720 | Peter Hay | Object | It is pure fantasy to think that development in cycle ways will help reduce the use of public transport and private cars. Whilst I support improvements, these should not form part of a decision making process for high impact traffic congestion as a result of major develpoments |
DLP_2943 | Garry Pethurst | General Observation | Policy STR6 With the high levels of proposed development in rural areas, the lack of a viable public transport system and the distance to rail links, reducing the need to travel and the use of private cars will be impossible to achieve. The only way this policy will be feasible will be to develop in urban areas, or rural areas served by a nearby (walking distance) rail station. Item 1 - This is very centred on Tunbridge Wells and its neighbours. It seems to fail to recognise that development is proposed across the borough. I would expext to see specific mention of, for example, an additional Public Right of Way connecting the significant tourist attractions of Bedgebury Forest and Sissinghurst Castle. Item 6 - This must be made compulsory, if we are to achieve our targets for carbon reduction. |
DLP_1617 | Maggie Fenton | Object | Policy STR 6 (Transport and Parking) p.54 An addition is required as follows: “All sustainable transport services, with proven capacity to hold the entire population of the garden settlement, must be provided and active before the first house within the garden settlement is built.” Note that you can only provide rapid bus links if you provide dedicated bus lanes. For Tudeley, the closest rail station in Tonbridge, so you’ll need bus lanes along Woodgate Way, Pembury Road and all the way up to Station Approach. |
DLP_3557 | Lynne Bancroft | Support with conditions | TWBC Local Plan is proposing to focus culture and employment on TWBC but proportionally more houses for the villages in the eastern area of the borough than Tunbridge Wells itself. There are already many transport issues for these rural areas. The A21 between Lamberhurst and Blue Boys needs dualling as it is congested now without further housing put into eastern area of the Borough in The Weald. Sissinghurst and Goudhurst village centres also have unresolved congestion issues on the roads causing air quality issues. Rural lanes need protecting with no further development near them Public transport is infrequent and expensive. For residents in Cranbrook and Sissinghurst, the buses do not co-incide with train times from Staplehurst station and this should be reviewed. The last bus from Maidstone does not wait if the late train from London is a little late which leaves people unable to get home. There should be an improvement in public transport in the evenings, as well as in the day, for all villages connecting to towns, including those outside of the Borough such as Sissinghurst to Tenterden, as well as Sissinghurst to Tunbridge Wells and Maidstone. The Borough should encourage cheaper and more frequent public transport to encourage additional useage, especially in the rural eastern areas of the Borough. TWBC wants the cultural and economic centre to be Tunbridge Wells but it must provide better transport systems for the rural areas. Sissinghurst wants a frequent and rapid bus/transport link to Tunbridge Wells as the current bus route goes “round the houses” to get there and doesn’t even come into Sissinghurst village. How can residents of Sissinghurst enjoy a cultural night out when there is no bus to come home on? I agree with increasing the cycle network, particularly with a cycle route between Bedgebury Forest and Sissinghurst Castle, connecting two key tourist/economic facilities in the rural eastern area of the Borough, and an existing strategic national cycle route. This strategic proposed cycle route should be included within this policy STR 6 as well as the Hop Pickers Line between Paddock Wood and Hawkhurst, which links the settlements of Horsmonden, Goudhurst, Cranbrook and Hartley to Paddock Wood and Hawkhurst. |
DLP_2736 | Rosanna Taylor-Smith | Object | C. Hawkhurst Relief Road This is NOT a relief road! It is simply an ince give by a developer to attempt to get planning permission in a highly valued area of AONB within Hawkhurst. It simply moves traffic from one road to another and will not relieve anything, I cannot believe that KCC Highways is supporting this road and would like to see evidence from KCC and TWBC to show how this proposal can be justified and explained. 1. Cycling If you are resident in Tunbridge Wells, cycling may well be an option but living in Hawkhurst, a rural village with overcrowded narrow roads, cycling is a dangerous choice. Safe Cycle routes are needed to link Hawkhurst to Sandhurst and to Bedgebury and Cranbrook. |
DLP_2038 | Terry Everest | General Observation | Generally this policy sounds good, however the route of any A228 bypass needs much more creative thought and should as previously stated involve existing routes and less sensitive areas further away from Capel and not plough through woodland or orchards in a simple parallel as currently proposed. |
DLP_2877 | Chris Gow | Object | More must be done in policy to discourage car use as the level of congestion and therefore the high levels of air pollution, and the continued use of non renewable energy sources continues to be a concern to local residents. Use of local side streets as a car park for the 50% of residents who work in the town is a problem. The use of the pavement as a car park for commuter workers (into town employment as well as near the train stations) is a problem for the elderly, the infirm and young families using buggies, and children walking to school. Pavement parking must be prohibited. Policy in the Local Plan must encourage residents to use alternative methods to go about their business, and policy must discourage multiple car ownership in families as this positively adds to congestion. The alternative must be attractive and affordable and make the choice to use alternative transportable the obvious choice. In this case vehicle ownership will decrease, and there will be “traffic evaporation” and congestion and associated problems reduced. Provision of cycle lanes, walking routes, car sharing schemes, “pool car” schemes and good and affordable public transport must be the priority. The streets must be configured to make "rat-running" difficult and thus perceived to be no advantage to a driver. Vehicle speed controls must be in place, and congestion in the main through routes improved. This will happen as there is a change in the driver and transport movement culture. |
DLP_1777 | CPRE Kent | Object | In paragraph 1 of the policy the phrase “particularly in the urban areas” should be removed. As a strategy, the prioritising of active travel (walking and cycling) should apply equally to both urban and rural development, albeit that the ability to implement this priority may be more limited in rural areas. The climate emergency, increasing concern about air pollution and the damaging effects on people’s health of sedentary lifestyles should make this a very high priority. The Council needs to prioritise avoiding the need for parking and creation of traffic in the first place and by all means necessary. This needs to be done proactively. Remedying is reactive, more expensive in the long run and not always possible. The Council should commit to locating services at the point of need that can realistically be reached by active travel for all residents. This must be achieved by protecting optimal sites for infrastructure and services while they are still available. This is especially important for services and infrastructure accessed by many on a daily basis, such as schools, see CPRE’s Tunbridge Wells Committee’s response to STR/RTW1. The allocation of land for Tudeley Village (policy AL/CA1) is not in accordance with this policy, which seeks to ensure that “future development will be delivered within close proximity to accessible locations of existing settlements across the borough to help reduce the need to travel.” Policy STR 6(d) states “establish rapid bus/transport links, including from Paddock Wood to Tunbridge Wells, and Paddock Wood to Tonbridge (via Tudeley Village), and Tunbridge Wells to Tonbridge, and retain and enhance existing bus services”. It is unclear if the Council has had discussions with bus operators to see if the scale and density of development will be sufficient to support such a service as well as one that needs to be regular to encourage people to use public transport rather than using their car. The Maidstone Borough Council Local Plan Review Scoping Themes & Issues Consultation July 2019 at page 52 states: “Research has shown that travel habits develop very quickly in new developments and once people have chosen their travel mode, they tend to stick to it.” It will be important for rapid bus links/transport links to be provided early to prevent/reduce additional vehicular traffic on existing roads. As well as safeguarding land for the dualling of the A21 from Kippings Cross to Lamberhurst, three major new County roads are proposed to serve and partly be paid for by the proposed new developments:
Very little information has been provided about the environmental effects of, or justification for, these new roads. |
DLP_1367 | Mr and Mrs Leach | Support with conditions | Re: Draft Local Plan (Regulation 18 Consultation) - Adjoining Resident Comment It was good to meet you at the SaveCapel Public Meeting, on 18th September 2019. We wish to comment on the Draft Local Plan (LP), in relation to certain policies outlined under the headings stated below. We are specifically concerned about the negative impacts of the proposed garden villages will have to our town, especially without adequate public transport provisions, and with such a large loss of the countryside and Green Belt. 1.10 Our points in relation to Polict STR 6 are as follows: a. Again we support this policy but believe an additional requisite should be included stating: All sustainable transport services, with a proven capacity to cater for the planned populations, at any given time, must be provided before any more houses in a garden settlement are built (or similar), to minimise the development impact. b. Further to Item 1.9d, without a new railway station at Tudeley, the proposed garden settlement at Capel cannot be viewed as being in accordance with Policy STR 6 that requires "All sustainable modes of transport ... will be facilitated to reduce dependence on emission-producing private car use". Although, bus services are promoted to nearby towns; the increased levels of congestion, resulting from the huge developments, will reduce the attractiveness of any new bus services and so people are more likely to opt for the convenience of their own cars. c. Polict STR 6 also requires improvements in public trasnport, including in-terms of rail access. Thus, Policy STR/CA 1 and the associated Infrastructure Delivery Plan1 must include the requirement for a mainline railway station at Tudelely, which has frequent train services, to be built as part of any garden settlement. Although, this proposal will not alleviate the significant impact this development will have on Tonbridge; having a railway station option might minimise it, if such huge unsustainable settlements have to be built around our communities. In conclusion, we do not consider that the Draft Local Plan is sound, in relation to the proposed large garden settlements, with inadequate infrastructure connecting nearby towns. The current proposal for such a substantial loss of the Green Belt and countryside, as part the massive village expansions, is not sustainable development and nor is it consistent with National planning policy. This will cause immense environmental harm, including a heavy reliance on car use with poor public transport links. The justification for building on the Green Belt is unsound, as there are alternative brownfield and non-Green belt sites available. We are also concerned about the deliverability of the Draft Local Plan, with the local market saturation of nearly 6,000 new houses allocated for two nearby villages within one local area. In light of these concerns and the potentially flawed approach in favouring Green Belt development, over other suitable sites and as no exceptional circumstances exist, alternative sites should be considered. A more sustainable development approach might be to spread the allocation across the Borough, reducing the concentrated development pressures and local market saturation, whilst helping to unlock the greatest amount of brownfield re-development. |
DLP_2764 | Cllr Keith Obbard | Support with conditions | WEALDEN GREEN PARTY RESPONSE TO TWBC DRAFT LOCAL PLAN Policy STR6 – Transport and Parking We strongly support proposals to enhance cycling and walking, and the rapid provision of electric vehicle charging points. However, the large numbers of new homes envisioned will result in a huge increase in motor vehicle traffic throughout the borough and into the adjoining Districts. The existing road network struggles to cope with current levels of traffic at peak times, and cannot possibly support the increased traffic which will be generated by the proposed developments. Any increase in traffic will have an adverse effect on air quality, both within the Borough and in the surrounding Districts. Mitigation measures will be needed, but with the proposals to build on existing Green Belt land there would be even less opportunity for these measures. |
DLP_1638 | Richard Bysouth | Support with conditions | Policy STR 6: |
DLP_2460 | Tracy Belton | Support | STR6 I like the idea of having improved transport links from the villages, but as there is very little employment opportunities in villages, I cannot see how the use of private motor vehicles can be reduced except in town centres. Realistically I do not believe that we are actually being encouraged to stop using our private motor vehicles. If we did stop having private motor vehicles the government would loose out on so much money due to the loss in taxes on petrol and diesel sales that I cannot believe that this would be their aim. By building in villages we are being encouraged to use private motor vehicles, not discouraged. Cars are parked all along the main roads and back roads in Horsmonden as no parking is available off road for may existing houses. Parking is worse during school pick up and drop off times, especially on days when our bins are emptied, roads become grid lcoked. With more dwellings and therefore more children going to the village school, how will this problem be resolved? I cannot see that developers will be providing parking for existing properties! More dwellings will mean more delivery vehicles on the roads and lanes, more lorries delivering oil to properties, more supermarket deliveries, etc. The roads will become even more congested than they are now. Paths do not run along all of the existing roads and lanes as it is, so walking cannot be encouraged in all areas. Again, are the developers going to put in paths along existing roads to encourage walking instead of the use of private cars? Roads and lanes in villages are not wide enough to allow for cycle paths (they are barely wide enough for two cars in places). How are they actually going to encourage cycling? I do not feel safe cycling on the roads now, let alone with the extra vehicles that the 265 dwellings in Horsmonden will bring! |
DLP_2604 | Sue Sands | Object | Transport/infrastructure - in relation to Horsmonden, there isn't really the space to make most of the roads wider to accomodate the extra traffic that will be generated by the new dwellings in the village and from traffic generated from new dwellings in surrounding villages. The main roads in the village are full of parked cars, especially during school drop off and pick up. How is this going to be resolved? With more dwellings and therefore more people using the school this congestion during peak times will worsen. Where in the policy does it say how current parking issues along the main roads will be solved, along with the danger of residents who need to cross these roads in order to get their children to school? By building in villages you will be encouraging more private cars on the roads. Employment has fallen significantly in the last 20-30 years meaning existing residents have had to have private cars in order to get to work, as public transport either is not frequent enough or does not get you to the required destination. Building in urban areas would be preferable as transport links (buses/trains) are already in place, along with cycle routes and many paths. Not all houses in villages, even those near the centre, have footpath access to the village centre, and there are no cycle routes and not enough space along roads to create any. |
DLP_2837 | Helen Parrish | Object | Cross-referenced, detailed, reasons for my Objection: The requirement should be to provide the transport services before the houses are built. |
DLP_3174 | Kent County Council (Growth, Environment and Transport) | Highways and Transportation Paragraph 4.60 - KCC as Local Highway Authority agrees with the ambitions of Tunbridge Wells Borough Council, as set out in this paragraph to maintain and enhance the rail and bus networks and services and “encourage an efficient and improved strategic public transport network and safeguard any routes that may be required in the future, in places that will cater to those who commute, and will encourage a reduction in the necessity for the private car”. However, the allocation of the Park & Ride site at Woodsgate Corner (AL/PE 7) as car showrooms goes against the objectives of this paragraph. The proposed removal of this Park & Ride site from the Local Plan effectively removes the chance of an improved direct public transport service into the town. With the levels of proposed growth to the north of this site further along the A228 corridor, the safeguarding of this well located site for Park & Ride (or innovative alternative) is vital. The inability to deliver a Park and Ride site could put uncertainty on the Borough Councils ability to deliver the preferred growth strategy. Public Rights of Way and Access Service As a general statement the Kent County Council Public Rights of Way (PRoW) and Access Service is keen to ensure that their interests are represented within the local policy frameworks of the Districts and Boroughs in Kent. The team is committed to working in partnership with Local Councils to achieve the aims contained within the ‘Rights of Way Improvement Plan 2018 – 2028 (ROWIP)’ and contribute towards ‘Increasing Opportunities, Improving Outcomes: Kent County Council’s Strategic Statement (2015-2020)’. KCC seeks to promote the protection and enhancement of the network. As highway authority for the PRoW network, KCC is not seeking to have the planning system carry out those statutory duties which it performs under the various Acts relating to PRoW. However, experience shows that local planning policy support for the work it does is very helpful in both protecting the network and negotiating enhancements to it, through new development. | |
DLP_3762 | Martin Robeson Planning Practice for Tesco Stores Ltd | Support with conditions | Policy STR6 – Transport and Parking (support with conditions) Whilst the broad thrust of the policy is supported (in terms of encouraging sustainable behaviour), the rural character of the Borough cannot be overlooked and that the most effective means to reduce travel demand is through the securing infrastructure, including retail facilities, which meet the day-to-day needs of residents and businesses. We also observe that despite the policy heading including ‘parking’, the policy does not contain explicit objectives for parking in the Borough (albeit we note the provisions of Policy TP3). In this regard, we would point out that where opportunities for reduced parking provision exist, care should be taken not to rely on a formulaic approach, but to take account of the actual operational characteristics of the existing and/or proposed development (see also our response to Policy TP3 (Parking Standards)). |
DLP_4236 | Rother District Council | Support | Support Improving connectivity along the A21, and specifically between Kippings Cross and Lamberhurst, would have positive impacts for this Council and Tunbridge Wells. |
DLP_4363 | British Horse Society | Support with conditions | Under subparagraph 1, the plan to enhance routes such as public rights of way for users of non-motorised transport is welcomed. The new routes should be dedicated as public bridleways or restricted byways wherever possible. |
DLP_3916 | IDE Planning for Paddock Wood Town Council | Object | OBJECT as per STR1 In addition, it is considered essential to have a road from east PW to the north; also for a westwards link via Eastlands. |
DLP_5608 | Mrs Jacqueline Hewitt | General Observation | TWBC: the following comment was submitted by the responders on the left: Policy STR6 8 b. Retain and improve the strategic rail network by increasing rail capacity, reliability, and punctuality, as well as reducing overall journey times by rail. The train service from Staplehurst was very nearly reduced within the last few years and that was only prevented due to public outcry. Are Network Rail and the Train Operating Companies answerable to TWBC in terms of increasing capacity, reliability, punctuality? |
DLP_3999 | Lamberhurst Parish Council | STR6 – Transport & Parking New developments proposed for rural settlements with limited public transport and connectivity, within and adjacent to the AONB, undermines the policy. | |
DLP_6036 | Mr C Mackonochie | Support with conditions | See comment under STR5 about transport and also parking being in place at day 1 as well as the other transport measures [TWBC: See comment DLP_6035] |
DLP_4265 | RTW Civic Society | Policy STR 6 Para 4.60 transport infrastructure. Mentions “working with partners”. Will TWBC have any ability to make bus companies provide a particular service? If need be, will TWBC put up any money towards this? Policy STR 6 Transport and Parking i) Is the development of the Hawkenbury sports hub consistent with this policy? Re point d), are the A264 junction improvements felt to be sufficient to deal with the extra traffic to be expected from the proposed garden village? Past Local Plans have suggested improving other ways into the town eg. using Upper Grosvenor Road. Whilst we don’t necessarily think this would be a good suggestion. Might it be worth exploring other ideas – especially dedicated ways for public transport? | |
DLP_5224 | Culverden Residents Association | Support with conditions | We can broadly support most of the intention in this policy. Specific mention should also be made of improvements to pedestrian routes including safe crossing of major roads, because increases in walking within the urban area of RTW represent the fastest and cheapest way of securing substantial growth in active travel. |
DLP_4663 | CBRE Ltd for Dandara Ltd | Support with conditions | Draft Local Plan Policy STR6: ‘Transport and Parking’ 3.59 Dandara supports the approach to delivering future developments in close proximity to accessible locations and promotion of sustainable transport modes under Draft Policy STR6. 3.60 Dandara welcomes the commitment to developing and providing an integrated strategic cycle network within settlements, particularly Royal Tunbridge Wells, Southborough, Langton Green, Rusthall, Pembury, Paddock Wood, Five Oak Green, and the new garden settlement at Tudeley Village, but also between these and other settlements. 3.61 Dandara further welcomes the following planned infrastructure improvements:
[TWBC: see full representation].. |
DLP_4470 | Paddock Wood Neighbourhood Plan Steering Group | Object | The roads are already congested in the mornings particularly the main Maidstone Road through Paddock Wood, adding an additional 4000 homes would significantly increase traffic through the town, even if some developments are accessed from the A228. The additional houses to the east would be served by narrow country roads, encouraging traffic through the town and over the single bridge over the railway to go north. There are plans to bypass Five Oak Green/Colts Hill, whilst there is no mention of a road to relieve the centre of Paddock Wood. It cannot be expected to add 4000 houses to a B road through the town. This volume of housing would need a new road from the east of the town to the north to prevent congestion in the centre of town. Maidstone Road which is the spine and through road of the current town is a B road, rendered in places single way by parked cars. There should also be a road from the East of the town south of the railway to the North of the railway line emerging close to or through Transvesa to connect with the northern portion of the Maidstone Road. The bridle way leading from Maidstone Road at Eastlands should be upgraded and extended to connect with the A228 North of the Badsell roundabout The railway is already at capacity & with additional houses being built downline at Headcorn, Staplehurst & Marden, there will be further overcrowding and travel difficulties – doubling the size of the town will make it impossible to get on to a train during traditional commuting hours. With the planned expansion of Paddock Wood the provision of additional public car parking is essential. The NP group supports the idea of double storey car park at the Station and that the railway station area should be made into a transport hub. The Group supports the idea of an additional large car park north of the railway bridge to prevent people coming to the town centre just to park. |
DLP_5516 | Peter Bourne | Support with conditions | RURAL LANES: These are precious to the Borough and are at grave risk of being destroyed. Policy TWBC Planning Policy on “Rural Lanes” dates back to 1998. Traffic volumes have hugely increased since then (and that is before the impact of additional traffic created by the proposed new developments). The guidance must be updated in order to protect and enhance a key element of the character of the Borough rural areas. The current policy has been totally ineffective in this respect and cannot be relied upon to support the policy for the future. Verges are given no protection or respect, and no effort is being made to slow traffic speeds on rural lanes for wildlife, walkers, riders and cyclists. The draft does not recognise the link that Rural Lanes provide for walkers and cyclists. Unless an effective means of limiting vehicle movements on Rural Lanes, they will often be deemed unsafe for other users. It is insufficient to suggest that the Policy will be reviewed in future. It is essential that the policy be revised before the Local Plan is adopted. |
DLP_3778 | Mary Jefferies | Object | The cross roads in Hawkhurst, A229 and A268 is a major traffic congestion blackspot due to heavy usage by HGVs in addition to local road users. This will increase exponentially due to proposed development within the village and elsewhere. The ‘relief road’ will not help this situation. Local byways will become rat runs causing traffic chaos. Emergency service vehicles will be hampered in responding to their duties. |
DLP_3837 | Liane & Alan Chambers | Object | Policy Number: STR6 This policy contains contradictions. The policy encourages development which reduces the need to travel (which we support), however it contains proposals for a Hawkhurst relief road (section c). Hawkhurst is distant from Tunbridge Wells and the main employment centres in the Borough and neighbouring Boroughs. Additional housing development in Hawkhurst (Policy STR1) will lead to more car journeys. It is this housing that is leading to the proposal for a relief road. Both the housing and the road will adversely affect the AoNB and add to the negative environmental impacts on the village and its residents. This impacts include greater noise and air pollution as well as contributions to climate change. Hawkhurst is not a sustainable location for increased development. |
DLP_4350 | Tunbridge Wells Bicycle User's Group | General Observation | Policy Number: STR 6 (transport) and supporting paragraphs 1. Unsustainable infrastructure: The required approach of this Local Plan is to prioritise new housing development and its related infrastructure to enable sustainable communities. It is not designed to consider the sustainability of existing communities and their infrastructure. As a result this ‘Local Plan’ is incomplete since it does not plan for change in existing communities which are being damaged by their historic infrastructure being built on to accommodate earlier phases of growth. 2. Mitigation but not for all: Whilst the new communities will be more sustainable than the existing ones nearby, there is a recognition that they will have a negative impact on them as witness the requirement for developer-funded ‘mitigation’ measures to reduce their impact and provide new or extended infrastructure. However, this mitigation is most likely to cover the impacts in the immediate vicinity of the development itself while the existing and often distant communities that will bear the impact of additional traffic in particular will receive proportionately less of the developers’ funds. 3. Timescale too long: Funding from developers for the necessary transport infrastructure is unlikely to be available until the housing developments are decided and the ground has been broken. It would appear that highways and cycling and walking infrastructure that may be provided in Tunbridge Wells as a direct result to the planned developments will be at least 5-10 years away even if funding can be achieved. (See IDP Timing 2.22 ). This includes those that are ‘critical‘ or ‘essential’ (see Infrastructure Delivery Schedule p87 Tunbridge Wells). What funding is available will prioritise infrastructure related to new housing developments and civic energy will be directed for the ‘new’ not ‘existing’ communities. 4. Transport revolution: The Local Plan does recognise that a transport revolution is upon us whether there are thousands of houses planned to be built or not. But it fails, because it is tied to a development, planning and construction timetable, fully to recognise the pressure of time for everyone to make changes to their modes of travel. By the end of this plan period in 2036, it is likely that sale of both diesel and petrol driven vehicles will have been banned six years earlier (recent news suggests that 2030 rather than 2040 will be the deadline). We would argue that by creating realistic and accessible opportunities for everyone in Tunbridge Wells, Paddock Wood, and other village and rural communities to make alternative travel choices where none exist now, will make more efficient use of existing road infrastructure and cut costs and pollution. 5. Wriggle room Whilst all the right noises and statements are made regarding the benefits of walking and cycling the review leaves a lot of wriggle room. The underlying tone that we take away from it is the TWBC recognise the benefits, but see them as a “nice to have extra” rather than central to their transport policy making. For example: Transport Section p54-55. 4.61 – Opportunities for sustainable transport will be facilitated where possible P486-500 6.506 – Essential to ensure sufficient opportunities for sustainable travel – but how? 6.507 – ‘LPA recognises cars will continue to play a major role’ – where’s the appetite for change? We note that the Friends of the Earth in their response to the local plan make a similar point. If we accept the inevitability of growing car usage and provide for it by building more roads and car parks, growing car usage is what we will get. Instead, the plan gives us an opportunity to do some actual planning – as opposed the discredited business-as-usual predict and provide approach. 6.509 – Parking, parking, parking, but new developments should also prioritise active travel which means dis-incentivising the use of cars. 6.526 – It is intended (not essential…) that cycle parking provision included where possible in all new schemes to minimum level (unclear what this means – why not to the level which enables everyone to park bikes easily and conveniently) 6.527 – Car parks, retain and build more 6. Pollution: This Local Plan does not take full account of the Climate Change Emergency and the need rapidly to reduce damaging air pollution arising from transport activities. (Climate Change Emergencies declared in Kent and Tunbridge Wells 2019.) This Plan needs to refocus on the NOW as well as the FUTURE. It is visionary in imagining the potential of FUTURE modes of transport to achieve sustainable communities with less pollution, traffic and parking. However, the TWBC Transport Strategy Review states: ‘Transport now accounts for 28% of the UK’s greenhouse gas emissions and is the largest emitting sector in the UK. Cars, vans and HGVs are the three main sources of emissions.’ Sadly, neither Kent nor TWBC has a clear picture of how polluted its streets are. This is particularly so in Tunbridge Wells town centre where the most people and most heavily congested traffic are in very close proximity without being monitored. 7. Peak capacity: There is plenty of evidence that Tunbridge Wells is at peak vehicle capacity and is already renowned for its traffic congestion, the generally poor quality and unsafe environment for pedestrians and cyclists, and its residential roads and pavements jammed with parked cars. Furthermore, despite all the reports commissioned in recent years to prove this, this Plan will be delivering yet more vehicles to the Pembury Road entrance into the town via the proposed Colts Hill bypass. However, a fraction of the £40m cost of this new road could spent on transforming journeys of up to 2 miles within the town and between its satellite communities to deliver significant modal change, and buses, uber-style taxi and other public transport services to provide options for longer distances. By way of supporting evidence: (i) Waltham Forest, whose population is three times that of Tunbridge Wells, has been famously transformed into a mini Holland for a lower cost than that of the proposed Colt Hill Bypass. (ii) In a seminal report published in March 2017 (‘The end of the road? Challenging the road-building consensus’) the Campaign to Protect Rural England analysed 12 such schemes promising similar results undertaken over the last 40 years. In 10 out of the 12 cases the promised benefits of reduced congestion and economic prosperity clearly failed to materialise, and in the other 2 the evidence for any benefit was weak. The lesson of the last 40 years is that building new roads and widening existing ones only attracts more traffic. It is a classic case of induced demand. 8. Outdated data: We find Tunbridge Wells Borough Council Transport Strategy Review to be useful as it paves the way for more sustainable future. However, it relies too heavily on outdated data and will be finalised before the latest 2021 data is available. Key documents include: * 2011 census for population and travel to work data This has led to assumptions in paragraph 4.61 about accommodating growing car ownership when in the same document lip service is paid to a much wider range of travel options. It would be better to see how our communities can achieve targets and timescales for reducing car use for shorter ‘in town’ journeys, or to estimate the potential take up for better and cleaner public buses serving all parts Tunbridge Wells and its feeder communities. 9. Change now not later: There are opportunities for modal change for the largest number of people if a there is a strong direction on a transport vision for the existing as well as the new communities. Change is needed and needed fast to give the most value to the whole community and to achieve carbon neutrality by 2030 (transport being far and away the largest producer of greenhouse gases). Different travel options – bus, cycling, walking, taxi/uber, club cars etc – need to be first in place so that anyone - but particularly those unable to afford to own personal vehicles in future as they have in the past - can continue to travel for leisure, work or education. The danger is that this transport revolution will bring wider social division and more isolation. Encouragement for cheap, efficient and low polluting bus services that serve local communities throughout the borough as they do in cities, together with uber style taxis, car clubs etc, must be a priority. There would be less need for huge infrastructure investment and reliance on untried, developing technologies. 10. No map: The Plan’s commitment to ‘active travel’ is to be questioned even though it would appear that every one of the new developments is to have ‘active travel’ as a priority. However, there is no picture of what in reality this will look like on the ground. The final sentence of paragraph 4.59 reads: Cycling, and the use of electric bicycles (or e-bikes), is considered to have a particularly important role in active travel, and it is recognised that the infrastructure for safe cycling needs to be in place first to bring about increased used of this mode of transport. We agree with this, so where is the map showing the network of cycle paths and walking routes linking the new and existing communities that can inspire people to change their mode of travel and for funders to provide the finance? Tunbridge Wells has a disjointed, patchy and poorly maintained selection of underused cycleways and shared paths within the town and nothing to connect them to other local villages and communities let alone the new housing that is planned. The plan needs a map showing how communities will connect to each other and to employment, leisure, education, medical and other services which already exist or are planned for the growth of the town. Without such a map it carries no conviction that the necessary infrastructure will actually be created. 11. Target for reducing the use of private cars the number of journeys under 5 miles undertaken by private or commercial vehicles should be reduced by 50% within the period covered by the plan; If Tunbridge Wells is serious about achieving carbon-neutrality by 2030 we need urgent action. Plans, strategies and words alone will not be sufficient. 12. Abolition of excess of plans and strategies All that is required is a transport policy as part of the local plan. All the other documents should be abolished. We estimate that the cost of producing them, taking into account councillors’ time, officers’ time, office overheads, printing, publication, distribution, periodic reviews etc. costs £50,000-£100,000 a year. Scrap them all and you have enough money over a five-year period to implement the same filtered permeability measures in Tunbridge Wells’s residential streets as has been implemented in Waltham Forest. 13. Local needs: This Draft Local plan deals with the housing in the Borough needed for its next phase of growth. It is a plan for the few and not the many. Furthermore, it enshrines the reality that our transport infrastructure now and in the future is not in local control and not meeting local needs. It depends on financial decisions taken by developers, government, transport authorities, county councils and others which to date have not served us well. 14. Plain English: A local plan is above all a document which should be easily understandable by all. Although the plan is mercifully free of jargon (thank you) it suffers like many such documents from motherhood-and-apple pie verbiage which should be expunged. An example is paragraph 4.65 in the transport section: ‘Sustainable design principles make efficient use of resources through location, design, positioning, specification, and sourcing of materials, as well as improving the quality of developments and enhancing their environmental performance. The Council will encourage new development to incorporate current best practice in sustainable design and construction, incorporate mitigation and adaptation measures against the future impacts of climate change, and deliver high quality developments. Public art and active spaces will be encouraged as part of good design and place shaping to help foster a sense of place and community coherence.’ Sorry, but this is frankly waffle. Does it give useful information? If so, is the information testable, measureable, and verifiable? And if it is not information but a proposal, does it include a. a budget; (If any of the above elements is missing, the proposal is meaningless) |
DLP_4582 | Keith Stockman | Object | 4.60 As identified within the Sevenoaks and Tunbridge Wells Economic Needs Study (2016), 50% of residents in the Tunbridge Wells borough commute out of the borough to work (2011 census data). The proposed development will only increase the flow of traffic out of the borough as there is no extra work to be had in Cranbrook & Sissinghurst. This will put an extra strain on already busy roads where there are significant traffic jams regularly at peak times. This is not infrastructure led development. 4.59 In accordance with the NPPF, this Draft Local Plan will aim to facilitate all forms of sustainable transport, ranging from active travel (such as walking or cycling), public transport, car share, car club, ultra-low emission vehicles such as electric vehicles and charging points, or any provisions that arise through new technology over the course of the plan period. This should be done in all instances to reduce private car dependence in the borough where it is both feasible in relation to local circumstances, If these objectives are real, it is absolutely crazy to build large scale development so far away from designated centres of employment. There is no additional employment planned for the local area so new residents will inevitably use their own cars to travel to/from work. The measures proposed may ameliorate the increase in car use somewhat but it is inevitable that car use will increase. The roads in the area simply cannot sustain such an increase in traffic. |
DLP_4595 | Keith Stockman | General Observation | Policy STR6 8 b. Retain and improve the strategic rail network by increasing rail capacity, reliability, and punctuality, as well as reducing overall journey times by rail. There were actually moves afoot recently to reduce the train service from Staplehurst station, itself only accessible by car from Cranbrook & Sissinghurst, as the (infrequent) bus service makes no attempt to coordinate with train times. TWBC have no control over Network Rail or the Train Operators in respect of their policies regarding capacity and use of the rail network and have no influence on their reliability or punctuality. |
DLP_4618 | Anne Watson | General Observation | Policy number STR6 – 8 General Observation Many rural lanes around Cranbrook (Turnden, Whitewell, Quaker etc) are quite narrow and cars only able to pass with care, as they were not made for speeding cars nor constant traffic. Policy number STR6 –b General Observation C Grayling, a former Transport Minister tried to reduce train services from Staplehurst (Cranbrook’s local station) and was only prevented by public outcry. Does TWBC now have the power to make Network Rail and SE answerable to them regarding capacity, reliability and punctuality? |
DLP_5317 | Judith Ashton Associates for Redrow Homes Ltd and Persimmon Homes South Eas | General Observation | Policy STR6 Turning to policy STR6 and the commentary about the IDP, we do not necessarily agree that the IDP does identify the phasing of infrastructure linked to the planned development. Whilst it may highlight whether something is essential, critical or just desirable, it does no more than that – hence our belief a Strategic Infrastructure Plan is required for the strategic sites in Paddock Wood. [TWBC: see full representation]. |
DLP_6866 | Barton Willmore for Crest Nicholson | vi) Policy STR6: Transport and Parking 5.26 Policy STR 6 requires developments to: Establish rapid bus/transport links, including from Paddock Wood to Tunbridge Wells, and Paddock Wood to Tonbridge (via Tudeley Village), and Tunbridge Wells to Tonbridge, and retain and enhance existing bus services. 5.27 As for the corridor between Paddock Wood and Tonbridge, the supporting Transport Assessment Report (SWECO, Sept 2019) also states that: The East West link between Paddock Wood and Tonbridge is likely to become a key corridor to upgrade with public transport interventions to support new developments in the area. 5.28 However, the Infrastructure Delivery Plan (TWBC, August 2019) goes further than is presented in the Transport Assessment Report detailed above, by suggesting a: New bus only link from Paddock Wood to Tonbridge via Tudeley, with opportunity for automation (Level 4 /Level 5). 5.29 To be “positively prepared”, “justified” and “effective” greater clarity is needed on the intention for a ‘bus-only’ link to be provided. This should include costs and expected patronage that such new public transport facilities would be expected to generate in justifying the scheme described. 5.30 Whilst we support the overall thrust of the policy and welcome the embeddedness of sustainable modes of transport within the strategy, the policy needs clarification and refinement before it can be considered “sound” for the purposes of the NPPF (para 35). 5.31 Other road infrastructure will be considered to assist with the future resilience of the road network where this is able to provide relief to local communities and support the level of growth anticipated within the borough. 5.32 The proximity of the land which Crest has an interest in to Paddock Wood Railway Station, combined with the accessibility improvement and promotion of active modes, will go a long way to ensuring its sustainability and meeting the requirements of Policy STR6 in minimising the need for additional car parking. [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_6405 | Hawkhurst Parish Council | STR6 - Transport and Parking | |
DLP_7622 | Mr J Boxall | Paragraph Number(s): 4.59 and 4.60, 4.62 I agree with the facilitation of sustainable transport for both pleasure and work requirements. This must include public transport in the evenings as well as the day for all villages connecting to towns, including those outside of the Borough such as Sissinghurst to Tenterden as well as Sissinghurst to Tunbridge Wells and Maidstone. The Borough should encourage cheaper and more frequent public transport to encourage additional useage, especially in the rural eastern areas of the Borough. Strategic bus and rail services should be improved firstly for those residents who wish to travel within the Borough. However, due to the rural nature of the eastern part of the borough, particularly Cranbrook, Sissinghurst and Goudhurst road improvements need to be made also as the A262 is congested in Sissinghurst and Goudhurst and the A21 between Blue Boys and Lamberhurst is also congested. 4.62 As most transport is by car in the rural areas of the Borough, additional car parking on any new development must be provided, over and above that shown in the Plan as walking round any recently occupied development demonstrates the inadequacy of these levels, particularly for visitors. | |
DLP_7633 | Mr J Boxall | Support with conditions | TWBC Local Plan is proposing to focus culture and employment on TWBC but proportionally more houses for the villages in the eastern area of the borough than Tunbridge Wells itself. There are already many transport issues for these rural areas. The A21 between Lamberhurst and Blue Boys needs dualling as it is congested now without further housing put into eastern area of the Borough in The Weald. Sissinghurst and Goudhurst village centres also have unresolved congestion issues on the roads causing air quality issues. Rural lanes need protecting with no further development near them Public transport is infrequent and expensive. For residents in Cranbrook and Sissinghurst, the buses do not co-incide with train times from Staplehurst station and this should be reviewed. The last bus from Maidstone does not wait if the late train from London is a little late which leaves people unable to get home. There should be an improvement in public transport in the evenings, as well as in the day, for all villages connecting to towns, including those outside of the Borough such as Sissinghurst to Tenterden, as well as Sissinghurst to Tunbridge Wells and Maidstone. The Borough should encourage cheaper and more frequent public transport to encourage additional useage, especially in the rural eastern areas of the Borough. TWBC wants the cultural and economic centre to be Tunbridge Wells but it must provide better transport systems for the rural areas. Sissinghurst wants a frequent and rapid bus/transport link to Tunbridge Wells as the current bus route goes “round the houses” to get there and doesn’t even come into Sissinghurst village. How can residents of Sissinghurst enjoy a cultural night out when there is no bus to come home on? I agree with increasing the cycle network, particularly with a cycle route between Bedgebury Forest and Sissinghurst Castle, connecting two key tourist/economic facilities in the rural eastern area of the Borough, and an existing strategic national cycle route. This strategic proposed cycle route should be included within this policy STR 6 as well as the Hop Pickers Line between Paddock Wood and Hawkhurst, which links the settlements of Horsmonden, Goudhurst, Cranbrook and Hartley to Paddock Wood and Hawkhurst. |
DLP_7323 | Mr Richard Gill | Support with conditions | Policy Number: STR 6 Transport and Parking The policy fails to address the effects of 718-803 houses in Cranbrook, 100-115 houses in Sissinghurst and 681-731 houses in Hawkhurst on traffic, congestion and road safety. The A229 is already a busy, fast and dangerous road and the impact of at least three major developments having direct access is not addressed. These developments will encourage more car use and increased road traffic brings accompanying light, noise and air pollution. There is already serious congestion in the High Street and the constriction of Stone Street can only worsen resulting in a detrimental effect on the listed buildings and shop fronts in the Conservation Area. Active and sustainable transport cannot be achieved across the borough when employment development is centred around Tunbridge Wells. Most people work outside the Parish and with only a limited increase of employment opportunities in Cranbrook and no increase in employment in Sissinghurst resulting from the new developments car dependence and commuting will perpetuate. The nearest stations for commuting to London are at Staplehurst 9.3km and Headcorn 13.7km and there are inadequate bus services. There is a lack of provision for new parking infrastructure in the centre of Cranbrook. If there is insufficient parking then people will not use the amenities and facilities of the town which undermines the policy to encourage rural business as described in Policy ED8 and it does not support Cranbrook as a tourist destination. |
DLP_7247 | Mr John Telling | Object | '...and it is recognised that the infrastructure for safe cycling needs to be in place first to bring about increased used of this mode of transport.' |
DLP_7721 | Pantiles Camera Centre | Object | I write this response as I believe these two quotes from your own plan are where you need to focus… The way people shop and use towns has changed, we all know that but the Pantiles is the oldest purpose built shopping arcade in Europe and possibly the world? This should be celebrated and embraced. Whenever anyone (including TWBC) wants to promote T/Wells they always use a picture of the Pantiles. Tunbridge Wells is a very large borough (118,000+ population), less than half live in T/Wells. Most people travel / visit using their own car as we a surrounded by many small villages and towns that do not have good public transport links. We also attract many visitors from all over the South East and much further afield. I believe that the High Street, Chapel Place and The Pantiles are the future of ‘High Streets’. Large boring faceless shopping centres are no longer the way people shop. The town needs to adapt and save what it has already, once it’s gone, I believe it’s gone for good. What is the answer? 2. Understand that the town has 2 defined shopping areas and both need the support and investment of TWBC (See parking strategy 2016-2026 11.7 Car Park Appraisal) 3. Protect our on street parking – this is an invaluable asset allowing visitors to ‘pop in’ to Tunbridge Wells. Many towns do not have this and I believe this is a real positive. I understand street parking is an area full of conflict, but if this is controlled it can be a fantastic asset, and for many customers shopping in the south end of town this is their only choice. 4. Build a large car park near the Pantiles to help the balance the parking situation and improve the on–street parking problems 5. Consider the ‘commuter’ issue. 6. Greatly improve the road signage, which currently is woeful. All traffic for the town is directed towards the top of town where all points of interest and also all main car parks are? At this point The Pantiles is directly on their right but no mention of it, at all? The Pantiles main car park is 50mtrs up on the left but unless they can read through the debris, and weeds at the bottom of the sign you’d never know. The Pantiles is a unique asset and the reason while Tunbridge Wells has the Royal prefix. Improve the signage and this will aid visitors and stop the needless driving around looking for points of interest and parking. 7. Shopping has changed and the town needs to focus on its unique attractions. Shoppers no longer want to shop in faceless centres. The internet is here for good and successful towns are adapting to these changes. The experience of shopping in TW has to improve. Here are a few suggestions: 2. Pay on exit – to allow people to stay and spend unconcerned about the ‘clock’ 3. Contactless payment, rather than App based. Many people are not tech savvy and we are all now comfortable with the ‘contactless’ concept. 4. Build a large, easily accessible car park on the south side of the town to allow easy access to some of the towns key areas including the Pantiles and Spa Valley Railway. These small changes will send the message that Tunbridge Wells is open for business and we do want you to visit. Click and collect is now massive and is well proven that these shoppers spend more once in town. Without the pressure of the car park clock, people spend in many more areas of the economy, shoppers, visit hairdressers, nail bars, restaurants and theatres. The whole economy of Tunbridge Wells benefits. Empty shops and business will soon become re-let and the downward spiral can be reversed. I would love the opportunity to discuss with TWBC the best way to improve the town and give the viewpoint of a trader. [TWBC: there were no images attached to the submitted comments]. |
DLP_6774 | Mrs Carol Richards | Object | STR 6 (Transport and Parking) An addition is required as follows: “All sustainable transport services, with proven capacity to hold the entire population of the garden settlement, must be provided and active before the first house within the garden settlement is built.” Note that you can only provide rapid bus links if you provide dedicated bus lanes. For Tudeley, the closest rail station is in Tonbridge, so you’ll need bus lanes along Woodgate Way, Pembury Road and all the way up to Station Approach. Unless you demolish houses along one side of the Pembury Road this could be difficult!? |
DLP_7282 | Mrs Katie Lee-Amies | Object | Strategic Policies (comments already included above) [TWBC: See comments DLP_7265-7267 and 7269-7277] STR 1 – object. STR 2 – object. STR 3 – object. The masterplan excuse! STR 4 – object. Strongly. STR 5 – support with conditions. Insufficient information. STR 6 – object. STR 7 – object. STR 8 - object. STR 9 – object. There are no LBD details for Tudeley STR 10 – object. |
DLP_7229 | Elizabeth Daley | General Observation | The train service from Staplehurst was very nearly reduced within the last few years and that was only prevented due to public outcry. |
DLP_7049 | Philippa Gill | Support with conditions | Policy Number: STR 6 Transport and Parking The policy fails to address the effects of 718-803 houses in Cranbrook, 100-115 houses in Sissinghurst and 681-731 houses in Hawkhurst on traffic, congestion and road safety. The A229 is already a busy, fast and dangerous road and the impact of at least three major developments having direct access is not addressed. These developments will encourage more car use and increased road traffic brings accompanying light, noise and air pollution. There is already serious congestion in the High Street and the constriction of Stone Street can only worsen resulting in a detrimental effect on the listed buildings and shop fronts in the Conservation Area. Active and sustainable transport cannot be achieved across the borough when employment development is centred around Tunbridge Wells. Most people work outside the Parish and with only a limited increase of employment opportunities in Cranbrook and no increase in employment in Sissinghurst resulting from the new developments car dependence and commuting will perpetuate. The nearest stations for commuting to London are at Staplehurst 9.3km and Headcorn 13.7km and there are inadequate bus services. There is a lack of provision for new parking infrastructure in the centre of Cranbrook. If there is insufficient parking then people will not use the amenities and facilities of the town which undermines the policy to encourage rural business as described in Policy ED8 and it does not support Cranbrook as a tourist destination. |
DLP_6294 | Mrs Elizabeth Simpson | Object | Policy Number: STR6 STR 6 makes the commitment to facilitate sustainable modes of transport to reduce dependence on private car use. The policy states that provision will be made to maintain and improve transport infrastructure, working with partners to e.g.: increase rail capacity; reduce rail journey times; improve rail station infrastructure where necessary; improve the strategic highways network, including projects to improve the A21from Kippings Cross to Lamberhurst and the A228 Colts Hill bypass, and to enhance existing bus services. However there is no substance to support these stated intentions. There is no clear agreement with Network Rail to enhance train services. Bus services are currently deteriorating rather than being improved, e.g. the 297 from Tunbridge Wells to Tenterden recently being outsourced by Arriva to a smaller local company to run. There are no bus services serving the villages after 6pm, so whilst from Matfield it is possible get a bus to catch a train at Paddock Wood it is not possible to get one back after a working day in London. Developing in rural areas and villages, with inadequate public transport and which is never likely to be truly sustainable, will certainly be at odds with environmental concerns about tackling global warming and does not sit well with Government strategy to be carbon neutral by 2050. |
DLP_6987 | Nigel Tubman | Object | There is nothing in this policy that will help rural areas in the eastern part of the borough. Many of the roads in the rural areas are inadequate for the volume of traffic that currently uses the roads. There are many dangerous corners and road surfaces contributing to a high level of serious car accidents. Large lorries and tractors and trailers add to the dangers. Most non car/van/lorry drivers have been forced off the roads in the last few years. There are far fewer horse riders using roads these days and cycling is very hazardous. Walking on roads is also dangerous. Public transport is non existent. The town car parks and local roads are already full to capacity and more parking is urgently required if the town is to maintain and grow as an important centre for finance and advisory businesses as well as retail. |
DLP_6087 | Christopher Wallwork | Support with conditions | The cycling and walking plans sound promising, but several previous schemes have been poorly implemented, giving priority to motor vehicles over cycle or pedestrian traffic. The policy should emphasise that the reverse needs to be the case. The car parking policy must apply to “windfall” or “infill” developments, not just new areas. As noted in my comment on STR 5 [TWBC: See comment DLP_6086], infrastructure in the area is already dangerously overstretched; it is essential that new infrastructure be completed prior to the start of any new developments. This includes the new A228 route, improved slip roads on the A21, new cycle routes and bus lanes. |
DLP_6238 | Andrew Fairfax Scrutton | Object | The Draft Local Plan and the Sustainability Appraisal 2019 As a retailer on The Pantiles and a resident of Tunbridge Wells for 24 years, I wish to make the following comments. The documents mentions ‘ "Local shops and services need to be protected and retained wherever possible to ensure that communities have continued access to these in years to come". I wholeheartedly agree, but similar statements have been made in TWBC plans over the decades, and yet the number one barrier between communities of the wider Borough and the Pantiles retailers, is still the lack of parking. For example the Union Square 1887’ development should be built with 266 spaces, but is going to have 214, 127 flats 127 spaces 0.2 Ratio for visitor parking 25 spaces. Before the development the Pantiles had 114 spaces towards accommodating cars for Shoppers Tourists, aside retail staff for over 100 shops and offices in the area this could now become 62! This of course excludes the reality that many of the flats are likely to have couples with more than one car which if only 1 in 4 of flats had 2 cars would half again the spaces. The Pantiles is the oldest purpose built shopping area in Europe and a Historical Attraction. The Southern End of Town with High Street, Chapel Place and The Pantiles could buck the national retail trend if not starved of customers due to insufficient parking. Not only does a sustainable retail environment make the Town an attractive place to live and visit, retail and tourism are probably the largest sector of employment in the area. The Pantiles retailers have lobbying TWBC for improvements to both Car Parking and Road Signage to the area for decades and sadly the situation regarding available on and off street parking for shoppers to the area has become worse. The area will have had years of demonstratable financial impact due to lack of parking created by the 1887 development. Rather than look for ways to provide adequate parking for he Pantiles, TWBC is looking to develop the only car park attached to The Pantiles being Linden Park car park which it has a financial interest in. |
DLP_6270 | Susan Heather McAuley | Object | 4.60 Public transport is to be improved ‘particularly in the main urban area’. Again the rural areas are not catered for. The bus network is not ‘strategic’ – it is infrequent, unreliable and expensive. The Plan’s proposal for Sissinghurst will encourage greater car use, not more cycling. There are no safe cycling routes in rural areas. The increased private transport will be environmentally unsustainable. |
DLP_6299 | Susan Heather McAuley | Object | Policy Number: Section 4 Strategic Policies STR6 Transport and Parking The Policy is OK but it is already not being adhered to and therefore has little value Point 8 – The Plan says the rural lane network will be enhanced but in Sissinghurst the plan is to build all over it e.g. Mill Lane – very ancient rural lane (2 proposed developments here - AL/CRS12 Site 54 and AL/CRS13 Site 120). |
DLP_6274 | Tunbridge Wells Constituency Labour Party | Support with conditions | Additional development proposed under the Local Plan places greater strain on existing infrastructure so it is crucial that there is a focus on making substantial investment in sustainable transport options, including walking and cycling. The plan should be more aspirational in trying to reduce dependency on the car, particularly in central locations where public transport links are better. Greater investment in needed in infrastructure to encourage cycling and encourage a shift away from modes of transport that cause congestion and air pollution. |
DLP_6573 | Myrtle Newsom | Object | Policy Number: Section 4 Strategic Policies STR6 Transport and Parking Point 8 – The Plan says the rural lane network will be enhanced but in Sissinghurst the plan is to build all over it e.g. Mill Lane – very ancient rural lane (2 proposed developments here). |
DLP_6603 | Michael Lloyd | General Observation | Policy Number: STR6 b ‘Retain and improve the strategic rail network by increasing rail capacity, reliability, and punctuality, as well as reducing overall journey times by rail.’ Is this in the gift of TWBC? |
DLP_6613 | AAH Planning for Future Habitat Ltd | Support with conditions | Policy STR 6 – Transport and Parking Our Client is broadly supportive of this policy but reiterates that any requirements for new development must be subject to viability to ensure deliverability. [TWBC: see full representation and site plan attached]. [TWBC: see also Comment Nos. DLP_6606-6620, 6622-6627]. |
DLP_7092 | Brown & Co Planning Ltd for The Hendy Group | General Observation | Policy STR 6 – Transport and Parking; support with conditions; General Observation 1.132 Our Client also supports the provision of electric car charging points. 1.133 The measures for improvements to the strategic highways network, as outlined at point C, are supported, however, in line with comments on other polices the Council should undertake further work to assess the deliverability of this infrastructure and the extent to which it can realistically be funded through developer funding. 1.134 The up-front provision of Electric Vehicle charging points should be proportionate to the scale of the development, with the option to provide the infrastructure to allow for additional units to be installed in the future as required. 1.135 Our Client also supports the encouragement of sustainable travel. In line with this, our Client supports making Policy TP 3 (Parking Standards) a maximum standard to encourage sustainable travel. [TWBC: see full representation and supporting documents; Park and Ride Feasibility Review and Site Location Plan]. |
DLP_7156 | Kay Margaret Goodsell | 4.60 Public transport is to be improved ‘particularly in the main urban area’. What about for us in Sissinghurst? | |
DLP_7330 | Campaign to Protect Hawkhurst Village | Object | This policy is in direct conflict with the proposed Site Allocations within Hawkhurst. These allocations propose a huge increase in the size of the village. In many cases these sites are not a realistic walking distance to key services and facilities. In turn the allocations are in no way in “close proximity” to employment and services or proper public transport hubs. They will dramatically increase reliance on the use of private car, contrary to the direct aims of STR6. Paragraph c sets out the aim to improve the strategic highways network. However, no reference is made to necessary works to the A21 at the Flimwell junction. As set out in comments above, whilst the Flimwell junction is out of the Borough’s administrative area, the proposed Growth Strategy will have a hugely detrimental impact on the junction (even after proposed mitigation). The need to address this impact should properly be reflected in STR6, as a huge number of current and future residents of the Borough are (and will continue to be) wholly dependent on accessing the A21 at Flimwell. [TWBC: see Comment No. DLP_7329 Policy STR 5]. |
DLP_7518 | Sarah Parrish | Object | The requirement should be to provide the transport services before the houses are built. Is this Planned? |
DLP_7506 | Mr and Mrs A J Herbert | Object | In relation to Hawkhurst – please note the objections under STR1 above [TWBC: See comment DLP_7499] |
DLP_8323 | Pam Wileman | Object | TWBC: Comment was submitted on 19/11/19 after close of consultation (on 15/11/19). In relation to the proposed developments at Hawkhurst, the transport objections are set out under STR 1 above. [TWBC: See comment No. DLP_8317 Policy STR1]. |
Policy STR 7: Place Shaping and Design
Comment No. | Name/Organisation | Object/support/support with conditions/general observation | Response |
|---|---|---|---|
DLP_54 | Thomas Weinberg | Object | Comments on Policy STR 7 (Place Shaping and Design) p.56 You state that your policy seeks to protect existing residents from a development’s “overbearing impact”. |
DLP_1479 | Mrs Wendy Coxeter | In relation to the proposed developments at Hawkhurst, the place-shaping objections concerning the effect on the local area and the existing local community are set out under STR 1 above [TWBC: see comment number DLP_1462] | |
DLP_6851 | John Gibson | Support | Policy Number: STR7.1 The objective to respond positively to local character and context to preserve and enhance the quality of existing communities and their environs is very welcome. I trust this will be at the forefront when the planning application for AL/CRS13 is being considered. |
DLP_6964 | Simon Whitelaw | Object | Policy Number: STR 7 In relation to the proposed developments at Hawkhurst, the place-shaping objections concerning the effect on the local area and the existing local community are set out under STR 1 above (TWBC comment see - DLP 6959) |
DLP_7428 | Simon Parrish | Policy Number: STR 7 In relation to the proposed developments at Hawkhurst, the place-shaping objections concerning the effect on the local area and the existing local community are set out under STR 1 above. [TWBC: see Comment Number DLP_7421 on The Development Strategy] | |
DLP_7776 | Annie Hopper | Support | How can TWBC ‘respond positively to local character and context to preserve and enhance the quality of the existing community of Cranbrook and Sissinghurst by proposing large scale development in the Parish? This will clearly have a significant negative impact rather than enhancing the environs of the Parish. |
DLP_7797 | Robert Saunders | Object | Policy Number: STR7 page 56 ‘provide buildings that exhibit individual architectural quality within well considered public and private realms’ This policy has laudable aims, which are much more easily met in small scale developments. There is no mention of involvement of the community in co-creating places. The Building Better Building Beautiful Commission interim report focusses on proactive, collaberative community engagement, without which trust in the planning system breaks down. Citizens are not fearful of development per se, but rather they are fearful of poor-quality development that does not respect the local vernacular. I propose that a requirement for collaborative community engagement is made mandatory in the Specific Site Policies for each of the allocations. |
DLP_8023 | Penny Ansell | Object | In relation to the proposed developments at Hawkhurst, the place-shaping objections concerning the effect on the local area and the existing local community are set out under STR 1 above [TWBC: see Comment No. DLP_8017 Policy STR 1]. |
DLP_136 | Gregg Newman | Support with conditions | You state that your policy seeks to protect existing residents from a development’s “overbearing impact”. Even in the current political environment where what politicians say on a daily basis bears little resemblance to reality, this is a staggering statement. How can you add 2,800 homes to 50 (or even 950) and say you are fulfilling your commitment to protect existing residents??? |
DLP_7870 | Andrew Hues | Object | TWBC: the standard response was submitted by the list of responders on the left: In relation to the proposed developments at Hawkhurst, the place-shaping objections concerning the effect on the local area and the existing local community are set out under STR 1 above. [TWBC: See corresponding comment under STR 1 above] |
DLP_7903 | Fiona Dagger | Object | Local engagement has been done conducted in a manner that would be best describe as ‘cycnical’ recognition of local communites In order to challenge poor-quality design and ensure that future building is done with consent from the public, the Government set up the Building Better, Building Beautiful Commission which published its interim report in July 2019. The report focuses on the importance of proactive and collaborative community engagement rather than what is often experienced as cynical ‘consultation’. Evidence to the Building Better, Building Beautiful Commission demonstrates concern about the failure to properly engage communities with development, and the breakdown in trust in the planning system that this generates. The Plan should set minimum standards of community engagement equivalent with best practice and set out how this will be enforced for each development. Within the area of Hartley and Cranbrrok local resident’s groups have been ignored or deprived of a voice. There is little codified community engagement. A local Community Action Group has over fifty members but is deprived ‘official recognition’ as an alternative group, populated by people who do not live in Hartley, are deemed to represent the community with developers. This is not representative and is disingenuous. |
DLP_7936 | Wendy Owen | Object | The policy as currently drafted is far too weak in respect of the requirements that will be put on developers. It is simply not enough to “aim” or “have regard” to the council’s design guidance. The policy must be strengthened to require developments to meet the adopted design guidance – this is particularly true for any development in the High Weald Area of Outstanding Natural Beauty that should be required to meet the HW AONB guidance published earlier this year. |
DLP_8050 | Sophie Foster | Object | Some of these policies are laudable but are contrary to other proposals in the draft Local Plan. The reader is led to suspect that the policies concerned are not genuinely intended to be enforced and are only included to allow the Council to argue that they are reflected in the proposals, when in fact they are not. Item no.1 (Respond positively to local character and context to preserve and enhance the quality of existing communities and their environs). For reasons explained elsewhere in this response this is impossible in most cases where the development is in an AONB. Item no.3 (Protect and enhance assets of historic, landscape, or biodiversity value). The proposals adversely affect listed buildings and other heritage assets which would look incongruous if the historic landscape with which they are associated is covered in dwellings. Other aspects of the Plan should be amended in order to accord with these policies. Furthermore, this policy statement says nothing about measures to ensure that there is genuine collaborative engagement with the local community. The Council should honour its duty to procure that any development takes place with the consent and support of the local community and be mindful of the falling public confidence in the engagement and planning process as something that can protect their place or insist on beautiful development. It is sadly notable that the draft Local Plan does not make any reference to the interim report ‘Creating space for beauty’[1] by the Building Better, Building Beautiful Commission, which highlights these concerns. The Local Plan should include measures to address the issues arising in this report. [[1] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/815493/BBBBC_Commission_Interim_Report.pdf] |
DLP_8110 | Ashley Saunders | Support with conditions | Bullet point 8 states that “All new development must use the following principles relevant to its location, scale, and use: Protect the amenity of existing and future residents and users with regard to noise, vibration, smell, loss of light, privacy, and overbearing impact”. This cannot be achieved with a proposal to build 2,800 houses at a location with less than 50 houses at present (Policy AL / CA 1). This land should be removed from the dLP in order to deliver this Policy. In the event that the site is not removed from the dLP, a clause should be included which states that, where an overbearing impact is anticipated, local residents will be consulted and have enhanced rights when planning applications are considered, including the right of veto or appeal as individuals vs. developers. |
DLP_593 | Sport England | Support with conditions | Policy STR 7 Sport England supports this policy, however we feel an additional paragraph should be added which sets out the design principles that new development will be expected to accord with to enable/encourage healthy and active lifestyles. Sport England & Public Health England’s Active Design guidance http://www.sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/active-design/ sets out established guidance on how the design and layout of new developments can be planned to make communities more active and healthier. |
DLP_8265 | Ann Gibson | Object | 4.64 Developments nearing Outline and Detailed applications, are a poor pastiche of local vernacular, with cost being an excuse for shoddy design. |
DLP_8276 | Ann Gibson | Object | STR 7.1 Respond positively to local character and context to preserve and enhance the quality of existing communities and their environs. The local character and contextural quality of the existing community of Sissinghurst is not enhanced by the proposed overdevelopment of the parish, which has been enlarged by at least 80 plus houses recently. There are not sufficient schools, doctors and facilities to cater for more development. |
DLP_862 | Ian Pattenden | Support with conditions | Comments on Policy STR 7 (Place Shaping and Design) p.56 You state that your policy seeks to protect existing residents from a development’s “overbearing impact”. This is impossible when you propose to put 2,800 houses on a site that has at most 50 houses at present. |
DLP_1109 | Mr John Hurst | Support | STR7 - Place Shaping and Design All good intentions - must ensure that whether paid for by Developers or the Council, they actually happen, and are not sacrificed to cost-cutting pressures. |
DLP_1751 | Horsmonden Parish Council | Support | STR7-Place shaping and design: we strongly support policies to deliver development which reflects, and responds to, the distinctive local character of our parish, and avoids bland “anywhere” designs. |
DLP_3678 | Capel Parish Council | Support with conditions | Bullet point 8 states that “All new development must use the following principles relevant to its location, scale, and use: Protect the amenity of existing and future residents and users with regard to noise, vibration, smell, loss of light, privacy, and overbearing impact”. This cannot be achieved with a proposal to build 2,800 houses at a location with less than 50 houses at present (Policy AL / CA 1). This land should be removed from the dLP in order to deliver this Policy. In the event that the site is not removed from the dLP, a clause should be included which states that, where an overbearing impact is anticipated, local residents will be consulted and have enhanced rights when planning applications are considered, including the right of veto or appeal as individuals vs. developers. |
DLP_1895 | Royal Tunbridge Wells Town Forum | Policy STR 7 Place shaping and design We strongly support the reference to design guidance, which we recommend should be formulated as an SPD and also the use of masterplanning for strategic and larger scale developments as well as ensuring that new development protects and enhances assets of historic landscape or biodiversity value. This will be very hard to achieve in practice as some allocated new development will tend towards the opposite effect. We strongly support Paragraphs 1-7 including Paragraph 6 which requires prioritisation of the needs of pedestrians, cyclists and public transport services within the town but Paragraph 8 should urgently be strengthened to include protection against increased atmospheric pollution. | |
DLP_2510 | Mr Guy Dagger | Object | Local engagement has been done conducted in a manner that would be best describe as ‘cycnical’ recognition of local communites In order to challenge poor-quality design and ensure that future building is done with consent from the public, the Government set up the Building Better, Building Beautiful Commission which published its interim report in July 2019. The report focuses on the importance of proactive and collaborative community engagement rather than what is often experienced as cynical ‘consultation’. Evidence to the Building Better, Building Beautiful Commission demonstrates concern about the failure to properly engage communities with development, and the breakdown in trust in the planning system that this generates. The Plan should set minimum standards of community engagement equivalent with best practice and set out how this will be enforced for each development. Within the area of Hartley and Cranbrrok local resident’s groups have been ignored or deprived of a voice. There is little codified community engagement. A local Community Action Group has over fifty members but is deprived ‘official recognition’ as an alternative group, populated by people who do not live in Hartley, are deemed to represent the community with developers. This is not representative and is disingenuous. |
DLP_3021 | Cranbrook Conservation Area Advisory Committee | Support with conditions | POLICY STR 7 (P 56) AGREE with the policy as far as it goes. However there needs to be a more pro active approach to ensuring high quality, well designed new housing if the character of Cranbrook and Sissinghurst (and other heritage settlements) are not to be diminished. The Building Better, Building Beautiful interim government report of July 2019 is a good start, advocating more proactive community engagement rather than the usual limited consultation by developers. The recent High Weald Design Guide also offers a reasonable approach to encourage better building layouts and styles more appropriate to the Weald. Design matters -stop the ‘anywhere housing schemes’ of the large developers. |
DLP_2730 | St. John's Road Residents Association | Support | As stated in other Section on Development place shaping must observe measures to avoid lack of effective mitigation on major developments. |
DLP_3415 | High Weald AONB Unit | Support with conditions | Place shaping is primarily about people, yet the involvement of the community in co-creating places is not mentioned. We recommend that all allocation policies include the requirement for community engagement, with larger allocations required to demonstrate community engagement to the standard of Enquiry by Design (EbD), identified by the Building Better, Building Beautiful Commission as an example of best practice. The Building Better, Building Beautiful Commission also expresses concern about the inability of local planning authorities to define, demand and enforce design quality. |
DLP_2014 | Dr David Parrish | Object | Policy STR 7 (Place Shaping and Design) p.56 Local residents are not planned to be protected The policy seeks to protect existing residents from a development’s “overbearing impact”. This is impossible when you propose to put 2,800 houses on a site that has at most 50 houses at present. And a narrow, single-track, road only passing under an ancient narrow arch-bridge. |
DLP_1620 | Maggie Fenton | Object | Policy STR 7 p.56 Objective 7 is wrong. It states that TWBC aims to “release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.” Releasing land from the green belt should not be a strategic objective. The NPPF clearly states in paras 133 to 147 that green belt should only be released in exceptional circumstances. Stating that you have an objective to release land from the green belt (regardless of your judgement that it is appropriate) is contrary to national guidance. Also, in the Introduction (1.6) “Protection of the Green Belt” is a key outcome from your last round of public consultation.
You state that your policy seeks to protect existing residents from a development’s “overbearing impact”. This is impossible when you propose to put 2,800 houses on a site that has at most 50 houses at present. |
DLP_2878 | Chris Gow | Object | Paragraph 6 If the needs of the pedestrian are to be prioritised, you must ban and prohibit all vehicles from parking on the pavement. If the needs of the cyclists are to be prioritised you must remove the parking bays obstructing the cycle lane on the North side of St Johns Road near Southfields Road. This is a serious hazard for cyclists who have to swerve in the path of the main traffic flow. |
DLP_3558 | Lynne Bancroft | Support with conditions | Developers must be forced to ensure that designs are in line with Neighbourhood Development Plans that are either approved or in draft form, as well as meeting TWBC design guidance, and should reflect the existing development in each village. This is key in Cranbrook and Sissinghurst due to the historic nature of many of the buildings. Buildings and development must be designed to ensure that dark skies are maintained not only in the local surroundings but from more distant view points and other settlements. I agree that the needs of pedestrians, cyclists and public transport services are prioritised. This policy should include the requirement for developments to be carbon neutral. |
DLP_2039 | Terry Everest | General Observation | This policy sounds good and needs properly enacting. Current developments at Knights Wood and at the lower end of the Pantiles could have done with this approach. Instead they are insensitive and sharply contrast with their surrounds, spoiling multiple local scenes by overlooking or being of an anti-sympathetic nature. |
DLP_1779 | CPRE Kent | Support | Support |
DLP_2765 | Cllr Keith Obbard | Support | WEALDEN GREEN PARTY RESPONSE TO TWBC DRAFT LOCAL PLAN Policy STR7 - Place Shaping and Design We strongly support the aims and objectives of this policy |
DLP_2606 | Tracy Belton | Object | STR7 Building opposite existing dwellings will not protect the privacy of existing residents. I live opposte one of the proposed sites and I am currently not overlooked at the front of our property. Our house will be completely overlooked if this site is built on. The site opposite us (Furnace Lane, Horsmonden) is currently home to much wildlife and is surrounded by hedges and trees. There is no light pollution either and we often see birds hunting in this old orchard. All of this will be lost if this site is built on. |
DLP_2838 | Helen Parrish | Object | Cross-referenced, detailed, reasons for my Objection: Local residents are not planned to be protected |
DLP_3096 | Caroline Taylor | Object | As Cranbrook is a town with a great deal of history in it's architecture, the development should take this into consideration in it's design planning. The design intended for Brick Kiln Farm show complete disregard for this is their new elevations. Local development should aspire to utilise responsibly sourced materials locally & have a low environmental impact. |
DLP_3175 | Kent County Council (Growth, Environment and Transport) | Highways and Transportation The Local Highway Authority supports the policy. KCC supports the ethos of place shaping and design as laid out in paragraph 4.63 onwards and Policy STR 7, but would further request that appropriate reference is made to the Kent Design Guide. The general commitment in this policy, to ensure that new development is well designed and is complementary to existing character, is welcomed. In attempting to “respond positively to local character” (clause 1) applicants and the Council should draw upon the Historic Landscape Characterisation for Tunbridge Wells that has been developed by the Council in partnership with the High Weald AONB Partnership and KCC. The characterisation identifies those landscape features that contribute to the historic character of the Borough such as tracks, lanes and field boundaries which can be incorporated in new development so that the new build fits into the grain of the existing settlements and landscape. Please see https://beta.tunbridgewells.gov.uk/localplan/evidence/resources/environment-and-landscape/historic-landscape-characterisation-2017 for more details. | |
DLP_3426 | Sally Marsh Laura Rowland | Support with conditions | TWBC: the following comment was submitted by the responders on the left: Policy Number: STR 7 Place making and design Place shaping is primarily about people, yet the involvement of the community in co-creating places is not mentioned. In order to challenge poor-quality design and ensure that future building is done with consent from the public, the Government set up the Building Better, Building Beautiful Commission which published its interim report in July 2019. The report focuses on the importance of proactive and collaborative community engagement rather than what is often experienced as cynical ‘consultation’. Evidence to the Building Better, Building Beautiful Commission demonstrates concern about the failure to properly engage communities with development, and the breakdown in trust in the planning system that this generates. The Plan should set minimum standards of community engagement equivalent with best practice and set out how this will be enforced for each development. The Building Better, Building Beautiful Commission also expresses concern about the inability of local planning authorities to define, demand and enforce design quality. The Plan should set out how design quality will be assessed and enforced. |
DLP_4364 | British Horse Society | Support with conditions | The plan to prioritise the needs of pedestrians, cyclists and public transport services is a good one, but the needs of equestrians should not be forgotten. |
DLP_4536 | Historic England | Support with conditions | Historic England broadly supports the intention and purposes of policies Policy STR 7: Place Shaping and Design and Policy STR 8: Conserving and enhancing the natural, built, and historic environment. The latter policy, however, should include a specific bullet relating to heritage at risk as a strategic task. While Tunbridge Wells Borough has relatively few buildings on the register it has one of the most complicated HAR cases in the County (Providence Chapel). Another long-standing asset at risk is the grade II listed church in Hawkhurst. The policy should identify Heriatge At Risk as a priority that requires a proactive approach to securing the future of the assets with collaborative work between owners, key stakeholders and the Local Authority. |
DLP_3805 | Natural England | Support | Natural England welcomes this policy which puts a firm commitment on all new developments to protect and enhance assets of historic, landscape, or biodiversity value which is a key consideration of paragraph 20 of the NPPF. |
DLP_3917 | Ide Planning for Paddock Wood Town Council | Support | SUPPORT |
DLP_5607 | Mrs Jacqueline Hewitt | Support | Policy STR7 1. Respond positively to local character and context to preserve and enhance the quality of existing communities and their environs; The local character and contextual quality of the existing community of Cranbrook and Sissinghurst is not best enhanced by proposed large scale development endorsed by the planning department |
DLP_4000 | Lamberhurst Parish Council | Support | STR7 – Place shaping & Design Strongly support policies to reflect the distinctive local character of our parish. |
DLP_6039 | Mr C Mackonochie | Support | Support |
DLP_4266 | RTW Civic Society | Policy STR 7 Para 4.63 Place shaping and design We totally agree that TW deserves high quality buildings. Who will be the judge of this? We would like to see this being extended beyond TWBC planning officers. The Civic Society feels it has much to offer here. Setting up an independent group of local architects is another possibility. | |
DLP_4884 | Berkeley Strategic Land Ltd | Support | Policy STR 7 – Place Shaping and Design |
DLP_5225 | Culverden Residents Association | Support | We support the use of master-planning carried out by the Council for strategic and larger scale developments and would like to see more attention given to keeping members of the public informed. We welcome the giving of priority to the needs of pedestrians, cyclists and public transport services within the town. |
DLP_5558 | Mr Paul Hewitt | Support | Policy STR7 1. Respond positively to local character and context to preserve and enhance the quality of existing communities and their environs; The local character and contextual quality of the existing community of Cranbrook and Sissinghurst is not best enhanced by proposed large scale development endorsed by the planning department |
DLP_4664 | CBRE Ltd for Dandara Ltd | Support | Draft Local Plan Policy STR7: ‘Place Shaping and Design’ 3.62 Dandara supports the place-making principles set out under Draft Policy STR7, and the focus on all new development achieving high standards of design. [TWBC: see full representation]. |
DLP_4471 | Paddock Wood Neighbourhood Plan Steering Group | Support | Support |
DLP_5518 | Peter Bourne | Support with conditions | PLACE SHAPING AND DESIGN Para 1 of STR 7 refers to the need for development to respond to the local character and context of the existing communities and their environs. There is little evidence that this happens in practice when applied to the immediate area. This applies particularly with large scale developers who impose their standard designs with no consideration of the vernacular architecture. Conditions in this respect must be enforceable in law. |
DLP_4404 | Mill Lane and Cramptons Residents Association | Support with conditions | AGREE with the policy as far as it goes. However there needs to be a more pro-active approach to ensuring high-quality, well-designed new housing if the character of Sissinghurst (and other heritage settlements) are not to be diminished. The Building Better, Building Beautiful interim government report of July 2019 is a good start, advocating more proactive community engagement rather than the usual limited consultation by developers. The recent “High Weald Design Guide” also offers a reasonable approach to encourage better building layouts and styles more appropriate to the Weald. Design matters - stop the “anywhere housing schemes” of many developers resulting in soul-less dreary estates that could be anywhere in the UK. |
DLP_4586 | Keith Stockman | Object | 4.64 A key aim of the Draft Local Plan is to plan for comprehensive development to a high standard in terms of design and place shaping. Following from the previous comment, it is clear that scant attention has been paid to develop to high standards of design and place shaping in Cranbrook and Sissinghurst, 4.65 Sustainable design principles make efficient use of resources through location, design, positioning, specification, and sourcing of materials, as well as improving the quality of I find it hard to believe that this will be enforced in any meaningful way. Developers pay no heed to these principles and consistently state that they build to TWBC building standards. |
DLP_4593 | Keith Stockman | Support | Policy STR7 1. Respond positively to local character and context to preserve and enhance the quality of existing communities and their environs; The large scale development proposed is inappropriate and will NOT enhance the local character and context, nor will it enhance the quality of the existing community of Cranbrook and Sissinghurst, |
DLP_6869 | Barton Willmore for Crest Nicholson | vii) Policy STR7: Place Shaping and Design 5.33 Policy STR 7 requires architecture and urban design of a high standard which complies with requirements set out in the NPPF (paras 124-132). This policy is therefore broadly considered to be sound and in accordance with the NPPF, having particular regard to Section 12 on “Achieving well-designed Places” and Section 15 on ‘Conserving and enhancing the natural Environment’. 5.34 However, to align with the NPPF (para 127) it is suggested that the wording of point 2 in Policy STR 7 (i.e. “ 2. Provide buildings that exhibit individual architectural quality within well considered public and private realms”) is updated to read: “2. Provide buildings that exhibit good architectural quality, within well considered public and private realms”. [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_7634 | Mr J Boxall | Support with conditions | Developers must be forced to ensure that designs are in line with Neighbourhood Development Plans that are either approved or in draft form, as well as meeting TWBC design guidance, and should reflect the existing development in each village. This is key in Cranbrook and Sissinghurst due to the historic nature of many of the buildings. Buildings and development must be designed to ensure that dark skies are maintained not only in the local surroundings but from more distant view points and other settlements. I agree that the needs of pedestrians, cyclists and public transport services are prioritised. This policy should include the requirement for developments to be carbon neutral. |
DLP_7314 | Mr Richard Gill | Support with conditions | Policy Number: STR 7 Place Shaping and Design The developers are not meeting the high standards of urban and architectural design that are demanded of the AONB. Developers continue to provide generic modern estate housing with ‘house types’ designed from afar and imported to the locality. There is no mention of community engagement in place shaping and design. The Building Beautiful Commission Interim Report July 2019 with its purpose to tackle the challenge of poor-quality design and build of homes and places emphasises Enquiry by Design EbD as a collaborative engagement with the community rather than as a tick box exercise. To engage as early as possible is advised so that people feel that they have meaningfully fed into the overall design and development process. Public exhibitions tend to show design decisions that have already been made between planners and developers. The Commission also highlights the failure of planners to turn down unsustainable ‘drive to cul-de-sac’ developments. They also note and there is no mention here, that “there is currently a renaissance in the potential supply of community land trust and community-led development’’ noting that empowered community residents can be incredibly wise place-makers. Masterplanning is promoted in the Draft Local Plan but it is not always carried out by developers even when recommended by the Inspector with particular reference to the Brick Kiln Farm/Cornhall site in Cranbrook. |
DLP_7105 | Williams Gallagher for Canada Life Ltd | Policy STR7 – Place Shaping and Design It is suggested that the policy should include further provisions to reflect the guidance in para 118 of the NPPF such that:
We trust that you find these comments constructive and look forward to on-going dialogue with the Council. Please keep us informed of progress with the local plan preparation. Should you have any queries, please do not hesitate to contact us. [TWBC: see also Comment Nos. DLP_7102-7117]. | |
DLP_7528 | Charterhouse Strategic Land Ltd | Support | Charterhouse supports Policy STR 7 the necessity for all new developments to achieve high standards of design through the use of design codes and sustainable design standards within the masterplanning exercise. It is anticipated that the Strategic Working Group preferred will provide a suitable means for achieving this. Furthermore we support Policy STR 8 and believe that it is crucial that the development strategy conserves and enhances both the natural, built and historic environment while using the planning balance to effectively ensure housing numbers are satisfied. |
DLP_6775 | Mrs Carol Richards | Object | STR 7 (Place Shaping and Design) p.56 TWBC state that their policy seeks to protect existing residents from a development’s “overbearing impact”. This is impossible when you propose to put 2,800 houses on a site that has at most 50 houses at present. You must add a clause to say that where an overbearing impact is anticipated, residents will be consulted and have enhanced rights when planning applications are considered, including the right of veto or appeal as individuals vs developers. |
DLP_7283 | Mrs Katie Lee-Amies | Object | Strategic Policies (comments already included above) [TWBC: See comments DLP_7265-7267 and 7269-7277] STR 1 – object. STR 2 – object. STR 3 – object. The masterplan excuse! STR 4 – object. Strongly. STR 5 – support with conditions. Insufficient information. STR 6 – object. STR 7 – object. STR 8 - object. STR 9 – object. There are no LBD details for Tudeley STR 10 – object. |
DLP_7228 | Elizabeth Daley | Support with conditions | The local character and contextural quality of the existing community of Cranbrook and Sissinghurst is not best enhanced by proposed large scale development endorsed by the planning department |
DLP_7041 | Philippa Gill | Support with conditions | Policy Number: STR 7 Place Shaping and Design The developers are not meeting the high standards of urban and architectural design that are demanded of the AONB. Developers continue to provide generic modern estate housing with ‘house types’ designed from afar and imported to the locality. There is no mention of community engagement in place shaping and design. The Building Beautiful Commission Interim Report July 2019 with its purpose to tackle the challenge of poor-quality design and build of homes and places emphasises Enquiry by Design EbD as a collaborative engagement with the community rather than as a tick box exercise. To engage as early as possible is advised so that people feel that they have meaningfully fed into the overall design and development process. Public exhibitions tend to show design decisions that have already been made between planners and developers. The Commission also highlights the failure of planners to turn down unsustainable ‘drive to cul-de-sac’ developments. They also note and there is no mention here, that “there is currently a renaissance in the potential supply of community land trust and community-led development’’ noting that empowered community residents can be incredibly wise place-makers. Masterplanning is promoted in the Draft Local Plan but it is not always carried out by developers even when recommended by the Inspector with particular reference to the Brick Kiln Farm/Cornhall site in Cranbrook. |
DLP_6988 | Nigel Tubman | Object | This policy is admirable but as a policy it fails because the strategy contradicts the policy. |
DLP_6301 | Susan Heather McAuley | Object | Policy Number: STR7 Place Shaping and Design This policy is urban-focussed. It starts by saying ‘all new development must aim to meet high standards of urban … design’ Point 4 talks about street furniture and public art. This Policy has been written to suit Tunbridge Wells town, not the villages in the Borough. Villages do not need public art etc. This Policy should be rewritten to take account of the rural areas in the Borough. |
DLP_6495 | Clare Govan | Object | Policy Number: STR 7 Place Shaping and Design Some of these policies are laudable but are contrary to other proposals in the draft Local Plan. The reader is led to suspect that the policies concerned are not genuinely intended to be enforced and are only included to allow the Council to argue that they are reflected in the proposals, when in fact they are not. Item no.1 (Respond positively to local character and context to preserve and enhance the quality of existing communities and their environs). For reasons explained elsewhere in this response this is impossible in most cases where the development is in an AONB. Item no.3 (Protect and enhance assets of historic, landscape, or biodiversity value). The proposals adversely affect listed buildings and other heritage assets which would look incongruous if the historic landscape with which they are associated is covered in dwellings. Other aspects of the Plan should be amended in order to accord with these policies. Furthermore, this policy statement says nothing about measures to ensure that there is genuine collaborative engagement with the local community. The Council should honour its duty to procure that any development takes place with the consent and support of the local community and be mindful of the falling public confidence in the engagement and planning process as something that can protect their place or insist on beautiful development. It is sadly notable that the draft Local Plan does not make any reference to the interim report ‘Creating space for beauty’[1] by the Building Better, Building Beautiful Commission, which highlights these concerns. The Local Plan should include measures to address the issues arising in this report. [1] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/815493/BBBBC_Commission_Interim_Report.pdf |
DLP_6510 | Philip Govan | Object | Policy Number: STR 7 Place Shaping and Design Some of these policies are laudable but are contrary to other proposals in the draft Local Plan. The reader is led to suspect that the policies concerned are not genuinely intended to be enforced and are only included to allow the Council to argue that they are reflected in the proposals, when in fact they are not. Item no.1 (Respond positively to local character and context to preserve and enhance the quality of existing communities and their environs). For reasons explained elsewhere in this response this is impossible in most cases where the development is in an AONB. Item no.3 (Protect and enhance assets of historic, landscape, or biodiversity value). The proposals adversely affect listed buildings and other heritage assets which would look incongruous if the historic landscape with which they are associated is covered in dwellings. Other aspects of the Plan should be amended in order to accord with these policies. Furthermore, this policy statement says nothing about measures to ensure that there is genuine collaborative engagement with the local community. The Council should honour its duty to procure that any development takes place with the consent and support of the local community and be mindful of the falling public confidence in the engagement and planning process as something that can protect their place or insist on beautiful development. It is sadly notable that the draft Local Plan does not make any reference to the interim report ‘Creating space for beauty’[1] by the Building Better, Building Beautiful Commission, which highlights these concerns. The Local Plan should include measures to address the issues arising in this report. [1] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/815493/BBBBC_Commission_Interim_Report.pdf |
DLP_6539 | Rory Govan | Object | Policy Number: STR 7 Place Shaping and Design Some of these policies are laudable but are contrary to other proposals in the draft Local Plan. The reader is led to suspect that the policies concerned are not genuinely intended to be enforced and are only included to allow the Council to argue that they are reflected in the proposals, when in fact they are not. Item no.1 (Respond positively to local character and context to preserve and enhance the quality of existing communities and their environs). For reasons explained elsewhere in this response this is impossible in most cases where the development is in an AONB. Item no.3 (Protect and enhance assets of historic, landscape, or biodiversity value). The proposals adversely affect listed buildings and other heritage assets which would look incongruous if the historic landscape with which they are associated is covered in dwellings. Other aspects of the Plan should be amended in order to accord with these policies. Furthermore, this policy statement says nothing about measures to ensure that there is genuine collaborative engagement with the local community. The Council should honour its duty to procure that any development takes place with the consent and support of the local community and be mindful of the falling public confidence in the engagement and planning process as something that can protect their place or insist on beautiful development. It is sadly notable that the draft Local Plan does not make any reference to the interim report ‘Creating space for beauty’[1] by the Building Better, Building Beautiful Commission, which highlights these concerns. The Local Plan should include measures to address the issues arising in this report. [1] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/815493/BBBBC_Commission_Interim_Report.pdf |
DLP_6601 | Michael Lloyd | Support with conditions | The policy says:
Which is all well and good but fails to mention consultation, let alone collaboration, with the local community. |
DLP_6614 | AAH Planning for Future Habitat Ltd | Support with conditions | Policy STR 7 – Place Shaping and Design Policy STR 7 seeks to ensure that all new development meets high standards of urban and architectural design and have regard to any design guidance adopted by the Council. It sets out a number of principles and requires that all new development must use the principles relevant to its location, scale, and use. Whilst our Client broadly supports this policy as currently drafted, we object to the wording of bullet point 7 which requires that development proposals are based on measures to promote environmental sustainability, including energy and water efficiency measures, sustainable design and construction techniques. The requirements of this should be better defined and not overly onerous on the developer. We therefore object on the basis that the policy wording is not effective. [TWBC: see full representation and site plan attached]. [TWBC: see also Comment Nos. DLP_6606-6620, 6622-6627]. |
DLP_6673 | Gladman | 5.5.1 Policy STR7 sets out the overarching design principles it expects to be incorporated into development proposals. Some recognition is provided within the wording of the policy that not all principles listed are relevant to each development proposal depending on its location, scale and proposed use. Whilst this flexibility is welcome, Gladman do not consider that this goes far enough. 5.5.2 The type of application and scope of matters to be considered is also a factor influencing to what level of detail design matters are covered within a planning application. For example, an outline application may only consider in detail matters of access. As such, whilst points 1 to 8 of Policy STR7 may be relevant to the proposal, it might not be relevant to the stage of the application process. The policy should be reworded to recognise and reflect this. Gladman therefore consider that the policy should be revised to set out “All new development must use the following principles relevant to its location, scale, scope and use.” [TWBC: see full representation]. [TWBC: see also Comment Nos. DLP_6656-6695] | |
DLP_6648 | Stephanie Govan | Object | Policy Number: STR 7 Place Shaping and Design Some of these policies are laudable but are contrary to other proposals in the draft Local Plan. The reader is led to suspect that the policies concerned are not genuinely intended to be enforced and are only included to allow the Council to argue that they are reflected in the proposals, when in fact they are not. Item no.1 (Respond positively to local character and context to preserve and enhance the quality of existing communities and their environs). For reasons explained elsewhere in this response this is impossible in most cases where the development is in an AONB. Item no.3 (Protect and enhance assets of historic, landscape, or biodiversity value). The proposals adversely affect listed buildings and other heritage assets which would look incongruous if the historic landscape with which they are associated is covered in dwellings. Other aspects of the Plan should be amended in order to accord with these policies. Furthermore, this policy statement says nothing about measures to ensure that there is genuine collaborative engagement with the local community. The Council should honour its duty to procure that any development takes place with the consent and support of the local community and be mindful of the falling public confidence in the engagement and planning process as something that can protect their place or insist on beautiful development. It is sadly notable that the draft Local Plan does not make any reference to the interim report ‘Creating space for beauty’[1] by the Building Better, Building Beautiful Commission, which highlights these concerns. The Local Plan should include measures to address the issues arising in this report. [1] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/815493/BBBBC_Commission_Interim_Report.pdf |
DLP_6706 | Edward Govan | Object | Policy Number: STR 7 Place Shaping and Design Some of these policies are laudable but are contrary to other proposals in the draft Local Plan. The reader is led to suspect that the policies concerned are not genuinely intended to be enforced and are only included to allow the Council to argue that they are reflected in the proposals, when in fact they are not. Item no.1 (Respond positively to local character and context to preserve and enhance the quality of existing communities and their environs). For reasons explained elsewhere in this response this is impossible in most cases where the development is in an AONB. Item no.3 (Protect and enhance assets of historic, landscape, or biodiversity value). The proposals adversely affect listed buildings and other heritage assets which would look incongruous if the historic landscape with which they are associated is covered in dwellings. Other aspects of the Plan should be amended in order to accord with these policies. Furthermore, this policy statement says nothing about measures to ensure that there is genuine collaborative engagement with the local community. The Council should honour its duty to procure that any development takes place with the consent and support of the local community and be mindful of the falling public confidence in the engagement and planning process as something that can protect their place or insist on beautiful development. It is sadly notable that the draft Local Plan does not make any reference to the interim report ‘Creating space for beauty’[1] by the Building Better, Building Beautiful Commission, which highlights these concerns. The Local Plan should include measures to address the issues arising in this report. [1] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/815493/BBBBC_Commission_Interim_Report.pdf |
DLP_6729 | James Govan | Object | Policy Number: STR 7 Place Shaping and Design Some of these policies are laudable but are contrary to other proposals in the draft Local Plan. The reader is led to suspect that the policies concerned are not genuinely intended to be enforced and are only included to allow the Council to argue that they are reflected in the proposals, when in fact they are not. Item no.1 (Respond positively to local character and context to preserve and enhance the quality of existing communities and their environs). For reasons explained elsewhere in this response this is impossible in most cases where the development is in an AONB. Item no.3 (Protect and enhance assets of historic, landscape, or biodiversity value). The proposals adversely affect listed buildings and other heritage assets which would look incongruous if the historic landscape with which they are associated is covered in dwellings. Other aspects of the Plan should be amended in order to accord with these policies. Furthermore, this policy statement says nothing about measures to ensure that there is genuine collaborative engagement with the local community. The Council should honour its duty to procure that any development takes place with the consent and support of the local community and be mindful of the falling public confidence in the engagement and planning process as something that can protect their place or insist on beautiful development. It is sadly notable that the draft Local Plan does not make any reference to the interim report ‘Creating space for beauty’[1] by the Building Better, Building Beautiful Commission, which highlights these concerns. The Local Plan should include measures to address the issues arising in this report. [1] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/815493/BBBBC_Commission_Interim_Report.pdf |
DLP_6790 | G M Whitehead | Object | STR7 Everything mentioned in this section is admirable but I somehow doubt that the actual developments you pass will live up to these high standards. The HWAONB Building Design Guidance on Responding to Site and Context, on Connecting beyond the Site and Layout and on Structuring the Site should be bed-time reading for every planner in this area. |
DLP_7093 | Brown & Co Planning Ltd for The Hendy Group | Support with conditions | Policy STR 7 - Place Shaping and Design; Support with conditions 1.136 Our Client has concerns that the use of the specific design codes on strategic and larger scale sites could restrict the development of sites which would otherwise enable the delivery of additional housing. 1.137 Point 3 is unsound as it is not consistent with national policy; there is no reference in the NPPF to protecting and enhancing historic assets. Support subject to the following amendments: * The design codes should only be applicable to large strategic sites (i.e. above 150 houses). * Reword point 3: Conserve the historic environment and the desirability of sustaining and enhancing the significance of heritage assets. [TWBC: see full representation and supporting documents; Park and Ride Feasibility Review and Site Location Plan]. |
DLP_7160 | Kay Margaret Goodsell | Object | Policy Number: STR7 Place Shaping and Design This is all about towns, not villages. It needs rewriting completely. |
DLP_7365 | Andrew Ford | Support with conditions | Place shaping is primarily about people, yet, the involvement of the community in co-creating places is not mentioned. In order to challenge poor-quality design and ensure that future building is done with consent from the public, the Government set up the Building Better, Building Beautiful Commission which published its interim report in July 2019. The report focuses on the importance of proactive and collaborative community engagement rather than what is often experienced as cynical ‘consultation’. Evidence to the Building Better, Building Beautiful Commission demonstrates concern about the failure to properly engage communities with development, and the breakdown in trust in the planning system that this generates. We recommend that all allocation policies include the requirement for community engagement, with larger allocations required to demonstrate community engagement to the standard of Enquiry by Design (EbD), identified by the Building Better, Building Beautiful Commission as an example of best practice. The Building Better, Building Beautiful Commission also expresses concern about the inability of local planning authorities to define, demand and enforce design quality. |
DLP_7519 | Sarah Parrish | Object | How will you protect local residents? |
DLP_7676 | Joe Hughes | Object | Policy Number: STR 7 Place Shaping and Design Some of these policies are laudable but are contrary to other proposals in the draft Local Plan. The reader is led to suspect that the policies concerned are not genuinely intended to be enforced and are only included to allow the Council to argue that they are reflected in the proposals, when in fact they are not. Item no.1 (Respond positively to local character and context to preserve and enhance the quality of existing communities and their environs). For reasons explained elsewhere in this response this is impossible in most cases where the development is in an AONB. Item no.3 (Protect and enhance assets of historic, landscape, or biodiversity value). The proposals adversely affect listed buildings and other heritage assets which would look incongruous if the historic landscape with which they are associated is covered in dwellings. Other aspects of the Plan should be amended in order to accord with these policies. Furthermore, this policy statement says nothing about measures to ensure that there is genuine collaborative engagement with the local community. The Council should honour its duty to procure that any development takes place with the consent and support of the local community and be mindful of the falling public confidence in the engagement and planning process as something that can protect their place or insist on beautiful development. It is sadly notable that the draft Local Plan does not make any reference to the interim report ‘Creating space for beauty’[1] by the Building Better, Building Beautiful Commission, which highlights these concerns. The Local Plan should include measures to address the issues arising in this report. [1] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/815493/BBBBC_Commission_Interim_Report.pdf |
DLP_7697 | Alison Nicholls | Object | Policy Number: STR7 Paragraph 4.69 ‘The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area’ The requirement for a further 800 plus houses within the parish of Cranbrook seems to expressly threaten the innate nature of this part of the borough as identified within the plan. By ‘filling in the gaps’ on the scale put forward, the nature of typical Wealden settlements of an “intimate, small scale, formed of dens and hursts” will be lost. |
Policy STR 8: Conserving and enhancing the natural, built, and historic environment
Comment No. | Name/Organisation | Object/support/ support with conditions/general observation | Response |
|---|---|---|---|
DLP_7733 | Peter Smart | Support | Policy Number: Policy STR8 1. The Urban and Rural landscapes of the borough, including the Designated High Weald AONB, will be conserved and enhanced. All the large scale development in Cranbrook and Sissinghurst is in, or adjacent to the AONB. Local studies show that the community does not want large scale development which is uncharacteristic of the area In fact the intention to re-draw the LBD to enclose yet more AONB landscape is to be deplored. This Policy should be rigorously supported, yet there is an intention within the plan to develop swathes of housing in the AONB, in an unsustainable manner that is not infrastructure led, while lack of infrastructure has been cited by the planning department as a reason for not putting a very small sustainably built development in an area that is not AONB. Building large scale development on AONB is NOT conserving the land and could not possibly be enhancing the Wealden landscape which is, as 4.69 states, intimate, small scale and formed of Dens and Hurst’s, characteristic of the AONB’s components of natural beauty. |
DLP_7770 | Annie Hopper | Support | This Policy should be rigorously adhered to. All the proposed large scale development in Cranbrook is in the AONB and adjacent to the AONB in Sissinghurst. Building large scale development in the AONB is NOT conserving the land and could not possibly be enhancing the Wealden landscape which is, as 4.69 states, intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. By redrawing the LBD yet more of the AONB landscape is enclosed which cannot be condoned. |
DLP_7791 | Robert Saunders | Object | Paragraph Number(s): 4.69 Object: the scale of the proposed developments around Cranbrook and Sissinghurst fail to respect the character of typical Wealden settlements, which are intimate, small scale and formed of Dens and Hursts. The proposals for the developments in the AONB AL/CRS9 (200-250 dwellings), AL/CRS4 (160-170 dwellings), AL/CRS6 (90 dwellings), AL/CRS7 (150 dwellings) appear to ignore TWBC’s own policy as outlined in the AONB Management Plan and the draft Neighbourhood Plan, one of development on small scale sites. |
DLP_7795 | Robert Saunders | Object | Object P58 Policy STR8 states that the urban and rural landscapes of the borough, including the designated High Weald AONB, will be conserved and enhanced – the scale, location and aggregate effects of the proposed developments run blatantly counter to this policy. Why? |
DLP_7816 | Robert Austen | Paragraph Number(s): 4.69 and 4.70 The south and south east of the borough contain traditional Wealden homes, which are intimate, small scale and formed of Dens and Hurst’s, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. Planning policies within this Draft Local Plan should contribute to, and enhance, the natural, built, and historic environment of the borough in accordance with the guidance set out within the NPPF. Policy should seek to ensure that the delivery of new development is balanced against the need to conserve and enhance the character and distinctiveness of the borough’s natural and built environment, in terms of the intrinsic character and diversity of the landscape, its biodiversity, and heritage assets. Response to para. 4.69 I object strongly to the development policy within the local draft plan to build 818 – 918 houses in Cranbrook and Sissinghurst and a further 681-713 in Hawkhurst village areas which sit within the High Weald Area of Outstanding Natural Beauty (AONB). Areas of Outstanding Natural Beauty are designated under the National Parks and Access to the Countryside Act (1947) and, along with National Parks, Area of Outstanding Natural Beauty (AONB) represent the finest examples of countryside in England and Wales. Their landscape beauty, including the protection of flora, fauna, and geological interests. Development affecting such areas is restricted under the National Planning Policy Framework and is contrary to Tunbridge Wells Borough Council (TWBC) adopted policy for the High Weald AONB set out in the AONB management plan 2019-2024, adopted by TWBC in March 2019. Response to para. 4.70 The scale of developments within this area of outstanding natural beauty is contrary to the National Planning Policy Framework (NPPF) para. 172 which says ‘great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, The Broads and AONB, which have the highest status of protection in relation to these issues. The NPPF para 11, makes it clear that AONB designation may provide ‘a strong reason to for restriction the overall scale, type and distribution of development in the planned area’. This is reinforced by Planning Practise Guidance updated in July 2019 which makes it clear that the protection of such areas may mean it is not possible to meet objectively assessed needs for development in full. My above arguments applies to all areas within the borough sitting within the High Weald AONB, area which seem to be disproportionately expected to provide a large number of new homes for the borough, without thought for the where people might work, the impact on the landscape and surrounding roads which are already heavily congested. Policy Number: Policy STR8 1. The Urban and Rural landscapes of the borough, including the Designated High Weald AONB, will be conserved and enhanced. All the large scale development in Cranbrook and Sissinghurst is in, or adjacent to the AONB. Local studies show that the community does not want large scale development which is uncharacteristic of the area In fact the intention to re-draw the LBD to enclose yet more AONB landscape is to be deplored. This Policy should be rigorously supported, yet there is an intention within the plan to develop swathes of housing in the AONB, in an unsustainable manner that is not infrastructure led, while lack of infrastructure has been cited by the planning department as a reason for not putting a very small sustainably built development in an area that is not AONB. Building large scale development on AONB is NOT conserving the land and could not possibly be enhancing the Wealden landscape which is, as 4.69 states, intimate, small scale and formed of Dens and Hurst’s, characteristic of the AONB’s components of natural beauty. | |
DLP_7822 | Anneke Turner | Paragraph Number(s): 4.69 and 4.70 The south and south east of the borough contain traditional Wealden homes, which are intimate, small scale and formed of Dens and Hurst’s, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. Planning policies within this Draft Local Plan should contribute to, and enhance, the natural, built, and historic environment of the borough in accordance with the guidance set out within the NPPF. Policy should seek to ensure that the delivery of new development is balanced against the need to conserve and enhance the character and distinctiveness of the borough’s natural and built environment, in terms of the intrinsic character and diversity of the landscape, its biodiversity, and heritage assets. Response to para. 4.69 I object strongly to the development policy within the local draft plan to build 818 – 918 houses in Cranbrook and Sissinghurst and a further 681-713 in Hawkhurst village areas which sit within the High Weald Area of Outstanding Natural Beauty (AONB). Areas of Outstanding Natural Beauty are designated under the National Parks and Access to the Countryside Act (1947) and, along with National Parks, Area of Outstanding Natural Beauty (AONB) represent the finest examples of countryside in England and Wales. Their landscape beauty, including the protection of flora, fauna, and geological interests. Development affecting such areas is restricted under the National Planning Policy Framework and is contrary to Tunbridge Wells Borough Council (TWBC) adopted policy for the High Weald AONB set out in the AONB management plan 2019-2024, adopted by TWBC in March 2019. Response to para. 4.70 The scale of developments within this area of outstanding natural beauty is contrary to the National Planning Policy Framework (NPPF) para. 172 which says ‘great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, The Broads and AONB, which have the highest status of protection in relation to these issues. The NPPF para 11, makes it clear that AONB designation may provide ‘a strong reason to for restriction the overall scale, type and distribution of development in the planned area’. This is reinforced by Planning Practise Guidance updated in July 2019 which makes it clear that the protection of such areas may mean it is not possible to meet objectively assessed needs for development in full. My above arguments applies to all areas within the borough sitting within the High Weald AONB, area which seem to be disproportionately expected to provide a large number of new homes for the borough, without thought for the where people might work, the impact on the landscape and surrounding roads which are already heavily congested. My day already starts with a frustratingly long wait to join the A229 so is already very busy and very polluted. Policy Number: Policy STR8 1. The Urban and Rural landscapes of the borough, including the Designated High Weald AONB, will be conserved and enhanced. All the large scale development in Cranbrook and Sissinghurst is in, or adjacent to the AONB. Local studies show that the community does not want large scale development which is uncharacteristic of the area In fact the intention to re-draw the LBD to enclose yet more AONB landscape is to be deplored. This Policy should be rigorously supported, yet there is an intention within the plan to develop swathes of housing in the AONB, in an unsustainable manner that is not infrastructure led, while lack of infrastructure has been cited by the planning department as a reason for not putting a very small sustainably built development in an area that is not AONB. Building large scale development on AONB is NOT conserving the land and could not possibly be enhancing the Wealden landscape which is, as 4.69 states, intimate, small scale and formed of Dens and Hurst’s, characteristic of the AONB’s components of natural beauty. | |
DLP_7871 | Andrew Hues | Object | TWBC: the standard response was submitted by the list of responders on the left: [TWBC: See corresponding comment under STR 1 above] |
DLP_386 | Speldhurst Parish Council | Support | Speldhurst Parish Council supports strong protection for the AONB as a nationally important landscape. |
DLP_7937 | Wendy Owen | Support with conditions | We support this policy – and as a result are mystified as to why the plan has included site 137 / AL/RTW 18 as a potential site for development given its place in the AONB, and its sensitivity and contribution to the landscape. As things stand in this plan, it is not clear TWBC has any realistic chance of meeting this policy. |
DLP_7947 | Sharon Pickles | Object | TWBC: the standard response was submitted by the list of responders on the left: Local research from the NDP group indicates that the parishioners are against large scale development According to the NPPF, there should be no large scale development on AONB unless exceptional need is proven, which it is not in the Parish of Cranbrook and Sissinghurst |
DLP_7958 | Sharon Pickles | Object | TWBC: the standard response was submitted by the list of responders on the left: All the large scale development in Cranbrook and Sissinghurst is in, or adjacent to the AONB. Local studies show that the community does not want large scale development which is uncharacteristic of the area In fact the intention to re-draw the LBD to enclose yet more AONB landscape is to be deplored. This Policy should be rigorously supported, and yet there is an intention within the plan to develop swathes of the AONB in an unsustainable manner that is not infrastructure led, while lack of infrastructure has been cited by the planning department as a reason for not putting a very small sustainably built development in an area that is not AONB. Building large scale development on AONB is NOT conserving the land and could not possibly be enhancing the Wealden landscape which is, as 4.69 states, intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. |
DLP_8071 | RSPB | Support | The RSPB supports the policy intentions to conserve and enhance the biodiversity features of the district. Explicit mention of priority habitats and species within this policy is particularly welcome and is consistent with national planning policy. |
DLP_8111 | Ashley Saunders | Support with conditions | The commentary at paragraph 4.69 (p.57) acknowledges that “Paddock Wood is a distinct settlement, which is identifiable as a historic railway-focused town, located in the transition area between the Low and High Weald, at the foot of the scarp slope” It should be noted that the “distinct settlement” of Paddock Wood does not, and should not at any point in the future, include Green Belt land at East Capel (Policy AL / CA 3 and AL / PW 1). This land should be removed from the dLP in order to deliver this Policy. |
DLP_943 | Mrs Karen Stevenson | Object | STR 8 sets out the approach by which the natural, built and historic environment will be conserved and enhanced, including protection of the landscape character of the borough and in particular complying with the objectives of the High Weald AONB Management Plan. Yet, it also gives justification for major development in the AONB on the basis of meeting need. The ‘Distribution of Development Topic Paper’ states, “The delivery of housing to meet housing need is clearly in the public interest and, together with insufficient opportunities elsewhere, is regarded as an important factor in providing exceptional circumstances to justify major residential development in the AONB.” (Paragraph 6.101) This is a sweeping statement making an assumption that prioritising housebuilding over conservation is in the public interest. I would say it is in the public interest to find solutions to the claimed housing shortage, in areas where it will not damage the natural and historic environment. This current draft, represents a conflict in the Council’s duty, coupled with the apparent prioritisation of meeting need over genuine AONB protection, consequently I do not have confidence that the draft local plan is seeking to protect the AONB at all, as it acknowledges a duty to conserve and enhance the AONB, yet also maintains major development on AONB land is unavoidable. So whilst the draft Local Plan acknowledges the Borough Council’s statutory duty to conserve and enhance the AONB, commitment to fulfil this duty is undermined by the overriding principle of meeting the untested housing target. This creates a contradiction which must be addressed in order for the LPA’s position on policies that protect the AONB to be both consistent and transparent. The NPPF is clear on the ‘great weight’ it affords the AONB. Planning Practice Guidance for the NPPF recognises that, “policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process.” (Paragraph ID: 8-041-20190721). The NPPF makes provision for LPAs to use an alternative approach to the standard methodology to assessing housing need, where “exceptional circumstances justify an alternative approach.” (Paragraph 60) I believe the fact that 70% of the borough lies within the High Weald AONB clearly represents an exceptional circumstance. |
DLP_1110 | Mr John Hurst | Support | Policy STR8 Conserving....environment Support, subject to comments raised for STR7, viz: All good intentions - must ensure that whether paid for by Developers or the Council, they actually happen, and are not sacrificed to cost-cutting pressures. |
DLP_1752 | Horsmonden Parish Council | Support | STR8 Conserving and enhancing the natural, built and historic environment: Subject to the concerns raised above about AONB/non AONB landscapes expressed above, we strongly support policies to protect the natural, built and historic environment. |
DLP_3682 | Capel Parish Council | Support with conditions | The commentary at paragraph 4.69 (p.57) acknowledges that “Paddock Wood is a distinct settlement, which is identifiable as a historic railway-focused town, located in the transition area between the Low and High Weald, at the foot of the scarp slope” It should be noted that the “distinct settlement” of Paddock Wood does not, and should not at any point in the future, include Green Belt land at East Capel (Policy AL / CA 3 and AL / PW 1). This land should be removed from the dLP in order to deliver this Policy. |
DLP_1480 | Mrs Wendy Coxeter | Object | TWBC: the following comment was submitted by the responders on the left: Policy Number: STR 8 In relation to the proposed developments at Hawkhurst, the conservation objections are set out under STR 1 above. [TWBC: see comment number DLP_1462] It is difficult to reconcile the principles set out under this policy head with the proposal for mass development in our Wealden village. Issues with water management have already damaged properties near to Hawkhurst House (formerly Babies Castle) and this will be replicated in other areas undermining historically significant properties. We have seen recent applications being facilitated by KCC Highways surrendering verges and parts of the historic street scene to enable traffic movements. |
DLP_1896 | Royal Tunbridge Wells Town Forum | Policy STR 8 Conserving and enhancing the natural, built and historic environment We strongly support the principles set out in Policy STR 8 Paragraphs 1-8 including the reference in Paragraph 8 to green corridors, green infrastructure networks and the guidance given as to development control. We also support the policy under Paragraph 8 concerning designated and non-designated heritage assets and will be pleased to work with TWBC in identifying, conserving and enhancing further non-designated heritage assets within the unparished area. | |
DLP_2738 | St. John's Road Residents association | General Observation | Reference is made to Section 4, paragraph 4.7 regarding preservation of Green Belt and AONB and comments with regard to building of "garden villages" under paragraph 4.3 and sustainability factors under Section 6. We think that the public interest exception allowed under paragraph 5 with respect to the High Weald AONB Management Plan is too subjective and could lead to a deterioration of the AONB designation. With regard to the "net gains for nature" provision in para. 6 is again too subjective and could allow substitution by a developer of the natural habitat. We belive that protection of hedgerows, fields, conservation areas, Historical Monuments must be observed for future generations and be a robust partof Conservation Area Management Plans. |
DLP_2787 | Mrs Karen Langston | Object | Whilst the draft Local Plan acknowledges the Borough Council’s statutory duty to conserve and enhance the AONB, commitment to fulfil this duty is undermined by the overriding principle of meeting the untested housing target. This creates a contradiction which must be addressed in order for the LPA’s position on policies that protect the AONB to be both consistent and transparent. I argue that the draft Local Plan promises neither. Instead, the draft Plan acknowledges its duty to conserve and enhance the AONB, yet maintains major development on AONB land is unavoidable. Policy STR 8 sets out the approach by which the natural, built and historic environment will be conserved and enhanced, including protection of the landscape character of the borough and a requirement for developers to demonstrate regard for the objectives of the High Weald AONB Management Plan. Yet, there remains an overriding justification for major development in the AONB on the basis of meeting need. As the ‘Distribution of Development Topic Paper’ states, “The delivery of housing to meet housing need is clearly in the public interest and, together with insufficient opportunities elsewhere, is regarded as an important factor in providing exceptional circumstances to justify major residential development in the AONB.” (Paragraph 6.101) This conflict in the Council’s duty, coupled with its apparent prioritisation of meeting need over genuine AONB protection, jeopardises the Council’s ability to achieve the latter. This conflict must, therefore, be scrutinised and addressed in the next iteration of the Local Plan. |
DLP_1722 | Peter Hay | Object | In relation to the proposed developments at Hawkhurst, the conservation objections are set out under STR 1 above. It is difficult to reconcile the principles set out under this policy head with the proposal for mass development at that Wealden village. Given that the Wealden AONB is recorded as comprising 70% of the borough’s land area, the vision is remarkable for its failure to recognise the importance of preserving its essential character or the borough council’s responsibilities towards it. We have seen recent applications being facilitated by KCC Highways surrendering verges and parts of the historic street scene to enable traffic movements. |
DLP_2879 | Chris Gow | Object | This policy should include a commitment to preserve the Green Belt land and prevent any development on Green Belt land. |
DLP_1621 | Maggie Fenton | Strategic Objective 8 p.58 Destroying 600 acres of fertile land in Capel, with mature trees and hedgerows in pursuit of the creation of houses will not tackle climate change. Nor will creating a new garden settlement that results in a high level of private car use. The objective should stay in, but the proposed developments in Capel should be removed immediately as they conflict with this strategy. | |
DLP_3559 | Lynne Bancroft | Support with conditions | The AONB around Sissinghurst should be expanded to protect this historic village and castle as well as protecting the landscape. This will further encourage green tourism due to the number of well known trails in the area advertised in walking books. Such trails include the High Weald Trail, The 1066 Harold’s Way and the Walk in Time series of walks as well as the “Green Book” walks. |
DLP_2739 | Rosanna Taylor-Smith | Object | 1. How can TWBC suggest they will conserve and enhance AONB when they are indicating support to schemes such as the Golf Club application in Hawkhurst, cutting right through an important part of the AONB? It should not be permitted and no benefit could be achieved by having the road through the golf course. 7/8. If protection of biodiversity, net gains for nature, etc. are to be achieved, a more robust defence must be given when planning applications arise as many recently determined planning applications would indicate otherwise e.g. The White House, Hawkhurst. Again TWBC has not demonstrated sufficient support for the protection and conservation of non-designated Heritage Assets e.g. The White House, Hawkhurst, although within this Draft Local Plan, it does suggest any future use should include the retention and improvement of this house which is likely to be demolished within the near future when full planning permission is granted - expected to be 1/2/2019. |
DLP_2040 | Terry Everest | Support | This is good, everything must adhere to this, however as stated previously you cannot overstate the value of green spaces and the countryside or indeed farmland and non developed uses of the land. |
DLP_1780 | CPRE Kent | Support | Support |
DLP_2778 | Mr Andrew McConnell | Object | Choice of site AL/AL2 directly conflicts with this policy by proposing a diversion from the traditional linear settlement pattern of typical Weald villages. Which is also in direct conflict with suggested priorities from the AONB. |
DLP_2766 | Cllr Keith Obbard | Support | WEALDEN GREEN PARTY RESPONSE TO TWBC DRAFT LOCAL PLAN Policy STR 8 - Conserving and enhancing the natural, built, and historic environment. We strongly support the aims and objectives of this policy, but doubt that the scale of development as proposed can be reconciled with these lofty objectives. |
DLP_2607 | Tracy Belton | Object | STR8 Horsmonden is not in the AONB. However, one of the planned building sites can be seen from Brenchley, which is in the AONB. If this site (Furnace Lane) is build on, it will impact the views from Brenchley. Surely this is not a good thing? The proposed sites in Horsmonden are currently fields or open spaces which are full of wildlife, areas where birds can hunt and are full of or surrounded by hedges and trees. Therefore, how can developing these sites be having any regard for the wildlife and current environment? |
DLP_2432 | J Coleman | Object | The area of AONB around Sissinghurst should be increased to protect this historic village and castle as well as protecting the landscape. |
DLP_3045 | Pamela Smart | Support | The Urban and Rural landscapes of the borough, including the Designated High Weald AONB, will be conserved and enhanced. All the large scale development in Cranbrook and Sissinghurst is in, or adjacent to the AONB. Local studies show that the community does not want large scale development which is uncharacteristic of the area In fact the intention to re-draw the LBD to enclose yet more AONB landscape is to be deplored. This Policy should be rigorously supported, yet there is an intention within the plan to develop swathes of the AONB in an unsustainable manner that is not infrastructure led, while lack of infrastructure has been cited by the planning department as a reason for not putting a very small sustainably built development in an area that is not AONB. Building large scale development on AONB is NOT conserving the land and could not possibly be enhancing the Wealden landscape which is, as 4.69 states, intimate, small scale and formed of Dens and Hurst's, characteristic of the AONB's components of natural beauty. |
DLP_3042 | Pamela Smart | Object | The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of Dens and Hurst's, characteristic of the AONB's components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. Planning policies within this Draft Local Plan should contribute to, and enhance, the natural, built, and historic environment of the borough in accordance with the guidance set out within the NPPF. Policy should seek to ensure that the delivery of new development is balanced against the need to conserve and enhance the character and distinctiveness of the borough's natural and built environment, in terms of the intrinsic character and diversity of the landscape, its biodiversity, and heritage assets. Response to para. 4.69 I object strongly to the development policy within the local draft plan to build 818 - 918 houses in Cranbrook and Sissinghurst and a further 681-713 in Hawkhurst village areas which sit within the High Weald Area of Outstanding Natural Beauty (AONB). Areas of Outstanding Natural Beauty are designated under the National Parks and Access to the Countryside Act (1947) and, along with National Parks, Area of Outstanding Natural Beauty (AONB) represent the finest examples of countryside in England and Wales. Their landscape beauty, including the protection of flora, fauna, and geological interests. Development affecting such areas is restricted under the National Planning Policy Framework and is contrary to Tunbridge Wells Borough Council (TWBC) adopted policy for the High Weald AONB set out in the AONB management plan 2019-2024, adopted by TWBC in March 2019. Response to para. 4.70 The scale of developments within this area of outstanding natural beatuy is contrary to the National PLanning Policy Framework (NPPF) para. 172 which says 'great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, The Broads and AONB, which have the highest status of protection in relation to these issues. The NPPF para 11, makes it clear that AONB designation may provide 'a strong reason to for restriction the overall scale, type and distribution of development in the planned area'. This is reinforced by Planning Practise Guidance updated in July 2019 which makes it clear that the protection of such areas may mean it is not possible to meet objectively assessed needs for development in full. My above arguments applies to all areas within the borough sitting within the High Weald AONB, area which seem to be disproportionately expected to provide a large number of new homes for the borough, without thought for the where people might work, the impact on the landscape and surrounding roads which are already heavily congested. |
DLP_3090 | Tony Fullwood | Object | The following part of Policy STR 8 appears to be inconsistent with national policy: Proposals that would harm the natural beauty of the AONB will not be permitted unless it is clearly in the public interest to do so. In such instances, effective mitigation should form an integral part of the development proposals; The wording appears not to align with the NPPF which seeks to ‘conserve and enhance landscape and scenic beauty of AONBs’. Importantly, as drafted the policy appears to accept harm to the natural beauty of the AONB. NPPF Para 172 states: ‘Great weight should be given to conserving and enhancing landscape and scenic beauty in …Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues.’ A plan which explicitly signals that it is acceptable to cause harm to such landscape and scenic beauty does not appear to be giving great weight to its conservation or enhancement. Para 172 also sets out that proposals for major development within the AONB should be refused other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:
As national policy makes clear, the test of exceptional circumstances and public interest only applies to major development and is set at a high level – amounting to national considerations; alternative locations outside the AONB and the environmental impact. NPPF Para 172 does not accept that major development may as a matter of course cause harm. As currently worded, Policy STR 8 would permit harm caused by less than major development if they are in the public interest – which is not consistent with national policy. It is also clear that the starting point for national guidance is to give great weight to conserving and enhancing the landscape and scenic beauty of the Area of Outstanding Natural Beauty and that even proposals for major development that would harm the natural beauty of the AONB will not be permitted unless exceptional circumstances apply. Following the adoption of the Local Plan, it should not be possible to meet these tests as sufficient development will be achieved without harm. Change required Delete the following Paragraph from Policy STR 8 Proposals that would harm the natural beauty of the AONB will not be permitted unless it is clearly in the public interest to do so. In such instances, effective mitigation should form an integral part of the development proposals; |
DLP_3176 | Kent County Council (Growth, Environment and Transport) | Heritage Conservation This policy is welcomed, though it needs to be strengthened by including archaeological assets in the text. Archaeological assets are also heritage assets and constitute a key component in the Borough’s historic environment providing a tangible connection with the Borough’s more distant past. The development principle that prioritises the needs of pedestrians and cyclists is supported. | |
DLP_4365 | British Horse Society | Support with conditions | Under item 8, mention should also be made of historic routeways. |
DLP_3806 | Natural England | Support with conditions | Overall, Natural England welcomes this strategic policy which gives clear commitment to conserving the natural, built and historic environment. We provide the following advice in relation to some of the points in the policy.
The green infrastructure ambitions are a positive step in securing a more biodiverse connected environment. This overarching policy could, however be strengthened further to incorporate the longer term maintenance and monitoring of existing and future green infrastructure as laid out on paragraph 171 of the NPPF. |
DLP_3920 | Ide Planning for Paddock Wood Town Council | Support | SUPPORT |
DLP_5581 | Mrs Jacqueline Hewitt | 4.69 The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. Local research from the NDP group indicates that the parishioners are against large scale development According to the NPPF, there should be no large-scale development on AONB unless exceptional need is proven, which it is not in the Parish of Cranbrook and Sissinghurst | |
DLP_5604 | Mrs Jacqueline Hewitt | Support | Policy STR8 1. The urban and rural landscapes of the borough, including the designated High Weald AONB, will be conserved and enhanced; All the large-scale development in Cranbrook and Sissinghurst is in, or adjacent to the AONB. Local studies show that the community does not want large scale development which is uncharacteristic of the area In fact, the intention to re-draw the LBD to enclose yet more AONB landscape is to be deplored. This Policy should be rigorously supported, and yet there is an intention within the plan to develop swathes of the AONB in an unsustainable manner that is not infrastructure led, while lack of infrastructure has been cited by the planning department as a reason for not putting a very small sustainably built development in an area that is not AONB. Building large scale development on AONB is NOT conserving the land and could not possibly be enhancing the Wealden landscape which is, as 4.69 states, intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. |
DLP_4001 | Lamberhurst Parish Council | Support with conditions | STR8 – Conserving & Enhancing the natural, built & historic environment LPC strongly supports this policy: Subject to the concerns raised earlier regarding AONB landscapes and expressed above |
DLP_6040 | Mr C Mackonochie | Support |
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DLP_4267 | RTW Civic Society | We feel this would benefit from specifically mentioning the TW common. Para 5.9 needs rewording following cancellation of Calverley Square. Para 5.10 mentions Camden Rd as being equivalent to the High St and the Pantiles in terms of retail. Does this mean they are all primary shopping areas? If so, will conversion to residential (on the ground floors) be prohibited in all three? | |
DLP_5226 | Culverden Residents Association | Support | We strongly support the provisions about protection of heritage assets, green corridors, green infrastructure networks and the guidance given as to development control, also the provisions to protect non-designated heritage assets such as our local brick pavements. We value the exceptional countryside landscapes which are only a few minutes’ walk from our members and act as an important “green lung” for our area which has no major parks nearer than a mile away. |
DLP_5556 | Mr Paul Hewitt | Support | Policy STR8 1. The urban and rural landscapes of the borough, including the designated High Weald AONB, will be conserved and enhanced; All the large-scale development in Cranbrook and Sissinghurst is in, or adjacent to the AONB. Local studies show that the community does not want large scale development which is uncharacteristic of the area In fact, the intention to re-draw the LBD to enclose yet more AONB landscape is to be deplored. This Policy should be rigorously supported, and yet there is an intention within the plan to develop swathes of the AONB in an unsustainable manner that is not infrastructure led, while lack of infrastructure has been cited by the planning department as a reason for not putting a very small sustainably built development in an area that is not AONB. Building large scale development on AONB is NOT conserving the land and could not possibly be enhancing the Wealden landscape which is, as 4.69 states, intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. |
DLP_5525 | Mr Paul Hewitt | 4.69 The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. Local research from the NDP group indicates that the parishioners are against large scale development According to the NPPF, there should be no large-scale development on AONB unless exceptional need is proven, which it is not in the Parish of Cranbrook and Sissinghurst | |
DLP_4665 | CBRE Ltd for Dandara Ltd | Support | Draft Local Plan Policy STR8: ‘Conserving and enhancing the natural, built, and historic environment’ 3.63 Dandara supports the focus of Draft Policy STR8 in conserving and enhancing the natural, built and historic environment. Dandara further recognises the importance of the borough’s natural landscape, its importance in place-making and opportunities for biodiversity enhancement where possible. [TWBC: see full representation]. |
DLP_4472 | Paddock Wood Neighbourhood Plan Steering Group | Support | Support |
DLP_3782 | Mary Jefferies | Object | It is difficult to reconcile the principles set out under this policy with the proposal for mass development of this Wealden village of Hawkhurst. A large scale development will destroy the AONB and the natural beauty of the area. Once lost it will never be recovered. Woodlands must be saved, wildlife habitat protected and not destroyed by additional development. |
DLP_4397 | Mill Lane and Cramptons Residents Association | Paragraphs 4.69 and 4.70 AGREE with the aims set out in these sections COMMENT Why then is TWBC planning large scale developments for Sissinghurst that are not ‘intimate and small scale’ and are totally at odds with the aspirations set out in these sections. Why is COALESCENCE of the historic and separate settlements of Cranbrook, Wilsley, Cranbrook Common, and Sissinghurst being actively encouraged with the proposed housing sites. | |
DLP_4591 | Keith Stockman | Support | Policy STR8 1. The urban and rural landscapes of the borough, including the designated High Weald AONB, will be conserved and enhanced; This Policy should be rigorously supported, and yet there is an intention within the plan to develop large tracts of AONB land in an unsustainable manner that is not infrastructure |
DLP_4567 | Keith Stockman | Object | 4.69 The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. There should be no large scale development on AONB land unless exceptional need is proven, according to the NPPF, which is most certainly not the case in the Parish of Cranbrook and Sissinghurst. Parishioners are unanimously against large scale |
DLP_6870 | Barton Willmore for Crest Nicholson | viii) Policy STR8: Conserving and Enhancing the Natural, Built, and Historic Environment 5.35 Policy STR 8 requires that the natural environment is “conserved” and “enhanced”. Specifically, it requires that the urban and rural landscapes of the Borough, including the designated High Weald AONB, will be conserved and enhanced, which is consistent with the NPPF (para 172). 5.36 However, other than that related to the AONB, the use of the term “conserve and enhance” is inconsistent with the NPPF (para 170), which states that, “Planning policies and decisions should contribute to and enhance the natural and local environment ”. 5.37 Therefore, and as presently worded, this policy goes beyond National policy requirements without any justification for this. As such it is considered to be not justified and inconsistent with National policy. It is recommended that in the introductory passage to Policy STR8 the word ‘conserve’ is replaced by the term ‘contribute to’, to better align with the NPPF (para 170). [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_7636 | Mr J Boxall | Support with conditions | The AONB around Sissinghurst should be expanded to protect this historic village and castle as well as protecting the landscape. This will further encourage green tourism due to the number of well known trails in the area advertised in walking books. Such trails include the High Weald Trail, The 1066 Harold’s Way and the Walk in Time series of walks as well as the “Green Book” walks. |
DLP_7315 | Mr Richard Gill | Object | Policy Number: STR 8 Conserving and enhancing the natural, built, and historic environment The Draft Local Plan site allocations do not support the policy of “conserving and enhancing the natural, built, and historic environment.” Large scale developments are inappropriate in the AONB and do not uphold the objectives of the High Weald Management Plan. Two main objectives are to protect the historic pattern and character of settlement and to enhance the architectural quality of the High Weald AONB and ensure that development reflects the character of the High Weald in its scale, layout and design. Prioritising the delivery of new housing primarily through small-scale development is key. TWBC should be constraining the levels of housing within this nationally protected landscape. In the Parish of Cranbrook and Sissinghurst the housing allocation exceeds the assessed local needs by about 50%. All the sites in Cranbrook are major developments and they scored highly negatively for environmental objectives to reflect the sensitive features that are at risk yet they are being promoted in the plan. It is stated in the Sustainability Assessment that the Parish of Cranbrook and Sissinghurst is one of the worst affected. The prime aim of the Draft Local Plan is to deliver housing and it is at the cost of conserving and enhancing the natural, built and historic environment. |
DLP_7620 | Mr James Peace | Object | According to the NPPF there should be no large scale developments on AONB unless exceptional need is proven. This is not the case in Cranbrook. There is little or no scope to grow local employment and residents do not wish Cranbrook to become another dormitory town. |
DLP_7248 | Mr John Telling | There should be a separate policy strategy for conserving and enhancing the natural environment. It should be the core primary strategy of the plan around which the other strategies are organised. The natural environment is ultimately all we have to sustain life into the future. | |
DLP_6776 | Mrs Carol Richards | Object | Policy STR 8 Conserving and enhancing the natural, built and historic environment and preceding paras 4.70 Well this is contradicted by the remainder of the LP, which would: STR 8 Point 8 The Historic Environment Review (Jan 2018) fails to mention the historic Church of All Saints at Tudeley, yet it is one of most significant churches in your Borough with International significance. It has more Chagall windows than Winchester cathedral. It is also in an idyllic position. Notwithstanding this, TWBC propose to surround it with- over time up to 2,800 homes? The Government Heritage Departments should be halting this development let alone anybody else! |
DLP_7284 | Mrs Katie Lee-Amies | Object | Strategic Policies (comments already included above) [TWBC: See comments DLP_7265-7267 and 7269-7277] STR 1 – object. STR 2 – object. STR 3 – object. The masterplan excuse! STR 4 – object. Strongly. STR 5 – support with conditions. Insufficient information. STR 6 – object. STR 7 – object. STR 8 - object. STR 9 – object. There are no LBD details for Tudeley STR 10 – object. |
DLP_7226 | Elizabeth Daley | Support | All the large scale development in Cranbrook and Sissinghurst is in, or adjacent to the AONB. Local studies show that the community does not want large scale development which is uncharacteristic of the area In fact the intention to re-draw the LBD to enclose yet more AONB landscape is to be deplored. This Policy should be rigorously supported, and yet there is an intention within the plan to develop swathes of the AONB in an unsustainable manner that is not infrastructure led, while lack of infrastructure has been cited by the planning department as a reason for not putting a very small sustainably built development in an area that is not AONB. Policy STR 8 point 5 This policy is to be supported wholeheartedly. |
DLP_7559 | Mark Beales | Object | 4.69 The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. 2.21 The delivery of infrastructure is key Local research from the NDP group indicates that the parishioners are against large scale developmentAccording to the NPPF, there should be no large scale development on AONB unless exceptional need is proven, which it is not in the Parish of Cranbrook and Sissinghurst All the local GP surgeries are working to capacity. No site has, as yet been identified for a Medical Centre. It is believed that new residents to Cranbrook will be expected to sign at surgeries out of the Parish (needing transport to get there) The need for a new Medical Facility is generated by development, so contrary to TWBC Plan, it is not ‘infrastructure led’ |
DLP_7563 | Mark Beales | Support | Policy Number: The urban and rural landscapes of the borough, including the designated High Weald AONB, will be conserved and enhanced; 3All the large scale development in Cranbrook and Sissinghurst is in, or adjacent to the AONB.Local studies show that the community does not want large scale development which is uncharacteristic of the areaIn fact the intention to re-draw the LBD to enclose yet more AONB landscape is to be deplored.This Policy should be rigorously supported, and yet there is an intention within the plan to develop swathes of the AONB in an unsustainable manner that is not infrastructure led, while lack of infrastructure has been cited by the planning department as a reason for not putting a very small sustainably built development in an area that is not AONB.Building large scale development on AONB is NOT conserving the land and could not possibly be enhancing the Wealden landscape which is, as 4.69 states, intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. |
DLP_7042 | Philippa Gill | Object | Policy Number: STR 8 Conserving and enhancing the natural, built, and historic environment The Draft Local Plan site allocations do not support the policy of “conserving and enhancing the natural, built, and historic environment.” Large scale developments are inappropriate in the AONB and do not uphold the objectives of the High Weald Management Plan. Two main objectives are to protect the historic pattern and character of settlement and to enhance the architectural quality of the High Weald AONB and ensure that development reflects the character of the High Weald in its scale, layout and design. Prioritising the delivery of new housing primarily through small-scale development is key. TWBC should be constraining the levels of housing within this nationally protected landscape. In the Parish of Cranbrook and Sissinghurst the housing allocation exceeds the assessed local needs by about 50%. All the sites in Cranbrook are major developments and they scored highly negatively for environmental objectives to reflect the sensitive features that are at risk yet they are being promoted in the plan. It is stated in the Sustainability Assessment that the Parish of Cranbrook and Sissinghurst is one of the worst affected. The prime aim of the Draft Local Plan is to deliver housing and it is at the cost of conserving and enhancing the natural, built and historic environment. |
DLP_6990 | Nigel Tubman | Object | Another worthy policy but as a policy it fails because the strategy contradicts the policy!. |
DLP_6849 | John Gibson | Support with conditions | Development adjacent to Areas of Natural Beauty must be avoided where possible and the re-drawing of the local LBD to facilitate this to happen must not be allowed. |
DLP_6089 | Christopher Wallwork | Support with conditions | Policy Number: STR 8 Developments positioned on the higher slopes of ridges within or adjacent to the High Weald AONB have a much greater visual impact on the landscape due to their visibility from a very wide area within the AONB. Significant development on such sites should be avoided; any small-scale development allowed must be low density, of suitable building materials, and include a requirement for tree planting to minimise visual impact from distant viewpoints. |
DLP_6496 | Clare Govan | Object | TWBC: the standard response was submitted by the list of responders on the left: Item no.1 (landscapes to be conserved and enhanced). I object to the inclusion of the words “including the designated High Weald AONB”. Para 172 of the NPPF states that “Great weight should be given to conserving and enhancing landscape and scenic beauty in … Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues.” These words could be interpreting as according equal status to non-AONB landscapes which is contrary to para 172. Item no.3 (developers required to demonstrate that any harmful effects have, where possible, been avoided) has the effect of negating item no.1 (landscape to be conserved and enhanced) and item no.2 (landscape character of the borough to be protected). Paragraph 20(d) of the NPPF unambiguously states that “Strategic policies should … make sufficient provision for … conservation and enhancement of the natural, built and historic environment, including landscapes and green infrastructure”. This will encourage developers to argue that a planning proposal should be approved notwithstanding its harmful effects in circumstances where in reality the proposal is wholly unacceptable. Item no.8 (heritage assets to be conserved and enhanced) is unclear in stating “special regard will be had to their settings”. Compliance with this nebulous obligation is impossible to verify or enforce. The Strategic Policy should state specific obligations for landowners and developers and should prohibit development in circumstances where the natural setting is fundamental to the character of heritage assets. Item no.9 (regard to be given to the Historic England Conservation Principles and the Council's Historic Environment Review) is so weak as to be virtually meaningless. If this is to have any effect it should say “Any development shall be in compliance with the Historic England Conservation Principles and the recommendations in the Council's Historic Environment Review …”. Please note that the hyperlinks to the Historic Environment Review (Part One) do not work. Item no.10 (positive management of heritage assets through partnership approaches and measures to be encouraged, including by the use of Conservation Area Management Plans) is ineffective because it places no obligation on developers or landowners. Nor does it say what action is required to be taken by anyone. There is no definition or explanation of “Conservation Area Management Plan”. |
DLP_6604 | Michael Lloyd | Support with conditions | Policy Number: STR8 1 and STR8 5 The laudable ambition to conserve and enhance the AONB in Str8 1 is badly compromised by STR8 5. It is not our experience in Cranbrook that the powers that be will have the slightest regard to the sanctity of the AONB. |
DLP_6791 | G M Whitehead | Object | Policy STR8.1 ‘The urban and rural landscapes of the borough, including the designated High Weald AONB, will be conserved and enhanced.’ This is largely negated by Policy STR8.5 ‘Within the area designated as AONB and its setting, development will be managed in a way that conserves and enhances the natural beauty of the area, and developers will be expected to demonstrate (through relevant documentation submitted as part of a planning application) how proposals have had regard to the objectives of the High Weald AONB Management Plan. Proposals that would harm the natural beauty of the AONB will not be permitted unless it is clearly in the public interest to do so. In such instances, effective mitigation should form an integral part of the development proposals.’ Either you are going to conserve and enhance the area or you are not. |
DLP_7094 | Brown & Co Planning Ltd for The Hendy Group | Support with conditions | Policy STR 8 - Conserving and enhancing the natural, built, and historic environment; Support with conditions 1.138 Points 1 and 5 of this policy states that the High Weald AONB will be conserved and enhanced, and that development in the AONB will be expected to demonstrate that the proposals have regard to the objectives of the AONB. 1.139 Our Client would like to highlight that through the allocation of a site in the AONB, the Council is recognising that the site is suitable for development and that the AONB objectives have been met. As such, proposals should not need to go through another AONB evaluation. Our Client is concerned that this policy may stifle growth on allocated sites. Support subject to the following amendment: * So as not to prejudice the delivery of allocations, the polices should be reworded to only relate to unallocated sites. [TWBC: see full representation and supporting documents; Park and Ride Feasibility Review and Site Location Plan]. |
DLP_7366 | Andrew Ford | General Observation | Item 1 states that the High Weald AONB ‘will be conserved and enhanced’, an objective we would fully support. However, from the Distribution of Development Topic Paper, SHELAA site assessments and allocation policies it is clear that TWBC has not sought to avoid harm to the AONB. |
DLP_7331 | Campaign to Protect Hawkhurst Village | Object | This policy conflates wider conservation of the natural, built and historic environment with the need to conserve and enhance the AONB. The AONB forms over 70% of the Borough’s administrative area. In contrast Green Belt forms 20% yet has its own standalone Strategic Policy. The Council is under a statutory duty to preserve and enhance the AONB. The effect of addressing AONB impacts as part of a composite policy relating to several other issues including built heritage is to dilute the importance of AONB protection. In order to adequately reflect the importance of the AONB within the Borough, a separate standalone strategic policy should be provided to mirror the approach taken to Green Belt. |
DLP_8334 | Joe Matthews | Object | TWBC: correspondent submitted the following comments on 20/11/19, after the close of consultation on 15/11/19: Paragraph 4.69 The south and south east of the borough contain typical Wealden settlements, which are intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area Local research from the NDP group indicates that the parishioners are against large scale development According to the NPPF, there should be no large scale development on AONB unless exceptional need is proven, which it is not in the Parish of Cranbrook and Sissinghurst |
DLP_8337 | Joe Matthews | Object | TWBC: correspondent submitted the following comments on 20/11/19, after the close of consultation on 15/11/19: The urban and rural landscapes of the borough, including the designated High Weald AONB, will be conserved and enhanced All the large scale development in Cranbrook and Sissinghurst is in, or adjacent to the AONB. Local studies show that the community does not want large scale development which is uncharacteristic of the area In fact the intention to re-draw the LBD to enclose yet more AONB landscape is to be deplored. This Policy should be rigorously supported, and yet there is an intention within the plan to develop swathes of the AONB in an unsustainable manner that is not infrastructure led, while lack of infrastructure has been cited by the planning department as a reason for not putting a very small sustainably built development in an area that is not AONB. Building large scale development on AONB is NOT conserving the land and could not possibly be enhancing the Wealden landscape which is, as 4.69 states, intimate, small scale and formed of dens and hursts, characteristic of the AONB’s components of natural beauty. Cranbrook, historically the centre of the wool trade in the borough, is the central settlement in this area. |
Policy STR 9: Neighbourhood Plans
Comment No. | Name/Organisation | Object/support/support with conditions/general observation | Response |
|---|---|---|---|
DLP_7834 | Andrew Chandler | General Observation | Policy Number: STR 9 I support this Policy in principle but comment that 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_7869 | Andrew Hues | Object | TWBC: the standard response was submitted by the list of responders on the left: I believe that this amounts to a material shortcoming in the draft local plan and demonstrates that the council is not prepared to listen to, or properly take account of, the views of local residents in relation to planning policy. This has been amply demonstrated in council decisions on recent planning applications in Hawkhurst, which have ignored the considered submissions of the Parish Council and the views of local residents, and have been taken without due consideration of the legitimate issues raised. |
DLP_8001 | Richard Pickles | Object | Please find below my specific objections to your proposed development plan [TWBC: See comments DLP_7991-8001]. I find the entire approach entirely reprehensible, both in ignoring the views and tireless hard work of various NDPs and imposing a lazy, self-interest driven plan which severely damages a large number of smaller communities within the TWBC area. The fact that a few greedy landowners, who clearly have no regard for their local communities, are set to benefit massively from this proposal,further justifies the rightful anger of communities. I strongly urge TWBC to re-engage with NDPs, review the district's true development requirements, ensure appropriate infrastructure is included in all developments and share the impact more fairly across all communities. |
DLP_8022 | Penny Ansell | Object | The document refers in a number of places to neighbourhood development plans. However, TWBC has – for no apparent legitimate reason – failed to “make” (recognise) the Hawkhurst Neighbourhood Development Plan submitted in March 2019 following a full local consultation and at considerable expense. Links to the Hawkhurst Neighbourhood Development Plan in the local plan point to the old, superseded Neighbourhood Development Plan. There is considerable suspicion in the community that the council has chosen deliberately to ignore the Hawkhurst Neighbourhood Development Plan because it does not accord with the Draft Local Plan. I believe that this amounts to a material shortcoming in the draft local plan and demonstrates that the council is not prepared to listen to, or properly take account of, the views of local residents in relation to planning policy. This has been amply demonstrated in council decisions on recent planning applications in Hawkhurst, which have ignored the considered submissions of the Parish Council and the views of local residents, and have been taken without due consideration of the legitimate issues raised. |
DLP_863 | Ian Pattenden | Object | Comments on Section 4 Paragraph 4.87 (Limits to Built Development) p.62 You have not provided any detailed LBD information for Tudeley or East Capel, citing “the need for further masterplanning”. This once again highlights that this plan is not ready for Public Consultation. |
DLP_1754 | Horsmonden Parish Council | Support | STR9 -Neighbourhood plans: We support this policy for support to town and parish councils preparing neighbourhood plans and the weight to be afforded to neighbourhood plans in planning decisions. |
DLP_1478 | Mrs Wendy Coxeter | Object | Policy Number STR 9 The document refers in a number of places to Neighbourhood Development Plans. However, TWBC has - for no apparent legitimate reason - failed to ‘make’ (recognise) the Hawkhurst Neighbourhood Development Plan submitted in March 2019 a full local consultation and at considerable expense. Links to the Hawkhurst Neighbourhood Development Plan in the local plan point to the old, superseded Neighbourhood Development Plan. There is considerable suspicion in the community that the council has chosen to deliberately ignore the Hawkhurst NDP because it does not sit with the narrative of the Draft Local Plan. Having ridden rough-shod over the objections to recent development by our Parish Council and residents it seems we are an inconvenience to your process. |
DLP_1897 | Royal Tunbridge Wells Town Forum | Policy STR 9 Neighbourhood plans We support this concept within the Borough although its application to the unparished area raises many issues which have so far been impractical to resolve. | |
DLP_2740 | St. John's Road Residents association | Support | Support |
DLP_2945 | Garry Pethurst | Object | Policy STR9 Being a member of a Neighbourhood Plan Steering Group, I cannot reconcile this statement with the real difficulties experienced by us when seeking collaboration from TWBC. The only word I can use to describe this is, HYPOCRITICAL. |
DLP_1622 | Maggie Fenton | Object | Strategic Objective 9 p.60 This states that TWBC would like to establish garden settlements as a model for the future delivery of development in the borough. Objective 9 should be removed. There is no evidence that garden settlements lead to any positive outcomes for communities anywhere in the UK. Objectives should have clear goals that can be proven to be positive for the inhabitants of the Borough of Tunbridge Wells. |
DLP_3560 | Lynne Bancroft | Support with conditions | TWBC should allow more weight from Neighbourhood Development Plans (NDP) at any stage of their development regardless to whether they completely line up with the TWBC Local Plan and the Local Plan should never take precedence over NDP’s as the NDPs will have greater local knowledge of the area or item concerned. |
DLP_2741 | Rosanna Taylor-Smith | Support | I totally agree that Neighburhood Plans should be respected and that weight should be given to them but TWBC has not demonstrated this in terms of the adopted Hawkhurst Neighbourhood Development Plan to date. |
DLP_1781 | CPRE Kent | Support | Support |
DLP_2779 | Mr Andrew McConnell | Object | Choice of site AL/AL2 appears to be well out of the LBD indicated on the map |
DLP_2608 | Tracy Belton | General Observation | STR9 Will regard be given for the type of housing actually required by the villages and towns? In Horsmonden, it has been shown that there is a need for housing suitable for the elderly and disabled. Will this be provided or will we simply gain more family homes with no where for elderly resident to go? If housing was provided for elderly residents, those in the village wanting to downsize but remain in Horsmonden could move to more suitable accommodation and this would free up family homes elsewhere in the village. I fear that extending Horsmonden by this may dwellings in such a short time will ruin the village community and adversely impact on village life. There seems to be little thought for those who have chosen to live in villages for reason such as being surrounded by people they know, other family members, a quiet place to bring up a family in the coutryside, etc. These reasons may not seem important to those in charge of deciding on the planning of developments in the area, but they are very important to existing residents. Villagers have chosen to live in villages for a reason and not in towns or cities and there should be some respect for the villages and their open spaces on the basis of this. |
DLP_2142 | Robert Tillotson | Object | cannot find the specific yeoSTR 9 I make my objections to specific places in this section as I cannot navigate this nightmare of a site correctly.1. Space at site 45 “camp field adjacent to Birchwood Avenue; Not currently included in plan. Please keep it so. It’s Green Belt,AONB and huge heritage and amenity site adjacent to woods and pathways providing high usage of Southborough and Bidborough residents for walking and acces to countryside. Poor access and suitability for housing. Both Mabledone sites either side of the A26 and A21. Both sites would add huge volumes to already congested A26 which cannot be mitigated. The suggestion in the plan to move air monitoring equipment further fromto A 21 is inexplicable and unforgivable if I have understood this correctly. Both sites unsuitable for development as there are few remaining open areas for air quality,biodiversity and amenity in our crowded Tonbridge to Tunbridge Wells route. The major proposed developments at Capel and Tudely. I do not buy the latest “Garden “ designation which is political nonsense like greenwashing an undesirable plan. I do not think that biodiversity studies have been made yet,and they both are on or near major flood plains. These are exactly the types of proposals that do not fit in a world of global warming and climate crisis. They may be a magic bullet for planners and house builders but breaching all previous land stewardship,green belt and environmental policy is no longer acceptable at any level of need. These plans are shocking,out of touch with the The needs of our response to the climate emergency ,and do not primarily address the overriding needs for affordable home in our Borough. I object. |
DLP_2129 | Penelope Ennis | Object | The document refers in a number of places to Neighbourhood Developments Plans. However, TWBC has - for no apparent legitimate reason - failed to 'make' (recognise) the Hawkhurst Neighbourhood Development Plan submitted in March 2019 a full local consultation and at considerable expense. Links to the Hawkhurst Neighbourhood Development Plan in the local plan point to the old, superseded Neighbourhood Development Plan. There is considerable suspicion in the community that the council has chosen to deliberately ignore the Hawkhurst NDP because it does not sit with the narrative of the Draft Local Plan. Having ridden rough-shod over the objections to recent development by our Parish Council and residents it seems we are inconvenience to your process. |
DLP_2149 | Michael O'Brien | Object | The document refers in a number of places to Neighbourhood Developments Plans. However, TWBC has - for no apparent legitimate reason - failed to 'make' (recognise) the Hawkhurst Neighbourhood Development Plan submitted in March 2019 a full local consultation and at considerable expense. Links to the Hawkhurst Neighbourhood Development Plan in the local plan point to the old, superseded Neighbourhood Development Plan. There is considerable suspicion in the community that the council has chosen to deliberately ignore the Hawkhurst NDP because it does not sit with the narrative of the Draft Local Plan. Having ridden rough-shod over the objections to recent development by our Parish Council and residents it seems we are inconvenience to your process. |
DLP_3526 | Andrew & Bronwyn Cowdery | Object | Policy Number: STR 9 The document refers in a number of places to neighbourhood development plans. However, TWBC has, for no apparent reason failed to recognise the Hawkhurst Neighbourhood Development Plan submitted in March 2019 following a full local consultation and at considerable expense. Links to the Hawkhurst Neighbourhood Development Plan in the local plan point to the old, superseded Neighbourhood Development Plan. There is considerable suspicion in the community that the council has chosen deliberately to ignore the Hawkhurst Neighbourhood Development Plan because it does not accord with the Draft Local Plan. Why have a NDP endorsed by the local community, if it is then ignored without due consideration, which seems to be the only inference you can take from the Draft Local Plan. This amounts to a material shortcoming in the Draft Local Plan and demonstrates that the council is not prepared to listen to, or properly take account of, the views of local residents in relation to planning policy. This has been amply demonstrated in council decisions on recent planning applications in Hawkhurst, which have ignored the considered submissions of the Parish Council and the views of local residents, and have been taken without due consideration of the legitimate issues raised. |
DLP_3922 | IDE Planning for Paddock Wood Town Council | Support | SUPPORT - PWTC as sponsor of the Paddock Wood NP is disappointed to note that the adopted Hawkhurst Neighbourhood Plan is disregarded in development planning, despite having been updated to address some concerns from the LPA. PWTC feels this undermines the whole of this policy and the value of NP’s. |
DLP_4002 | Lamberhurst Parish Council | Support | STR9 – Neighbourhood Plans LPC supports this policy |
DLP_6041 | Mr C Mackonochie | General Observation | As Neighbourhood Plans must adhere to strategic policies set out within the Local Plan one has to question their usefulness and financial viability over other types of plans ie Town and Parish Plans |
DLP_4666 | CBRE Ltd for Dandara Ltd | Support | Draft Local Plan Policy STR9: ‘Neighbourhood Plans’ 3.64 Dandara recognises the importance of local-level plan-making, and the importance of Neighbourhood Plans (where they are in place) in decision-making. Dandara is committed to working proactively and collaboratively with local groups, including Neighbourhood Forums, to ensure new development addresses local needs and local people can participate in development discussions. [TWBC: see full representation]. |
DLP_4473 | Paddock Wood Neighbourhood Plan Steering Group | Support | Support |
DLP_6456 | Cranbrook & Sissinghurst Parish Council | p.60, Policy STR 9: Neighbourhood Plan This policy is extremely weak in terms of describing what TWBC expects of an NDP. What should its focus be? Where and how can it complement the LP process? No information of this type is included. Yet, it is already known that NDP groups that have wanted to engage in site selection and allocation have been actively and cynically denied this opportunity through the inclusion of draft allocations for the whole of the Borough. So what do TWBC want to see from an NDP in their Borough? [TWBC: see full representation]. | |
DLP_6406 | Hawkhurst Parish Council | Object | STR9 - Neighbourhood Plans From a specific Hawkhurst perspective, how can the draft TWBC Local Plan not use the content of their own TWBC NDP for Hawkhurst as its starting point for policy STR/HA1? |
DLP_7625 | Mr J Boxall | Object | Paragraph Number(s): 4.77 and 4.78 TWBC should allow more weight from Neighbourhood Development Plans (NDP) at any stage of their development regardless to whether they completely line up with the TWBC Local Plan and the Local Plan should never take precedence over NDP’s as the NDPs will have greater local knowledge of the area or item concerned. |
DLP_7285 | Mrs Katie Lee-Amies | Object | Strategic Policies (comments already included above) [TWBC: See comments DLP_7265-7267 and 7269-7277] STR 1 – object. STR 2 – object. STR 3 – object. The masterplan excuse! STR 4 – object. Strongly. STR 5 – support with conditions. Insufficient information. STR 6 – object. STR 7 – object. STR 8 - object. STR 9 – object. There are no LBD details for Tudeley STR 10 – object. |
DLP_6277 | Tunbridge Wells Constituency Labour Party | Object | We are supportive of local neighbourhood plans developed by Parishes and other local communities. These are however often ignored at Borough Council level. If we want to value the local voice it is important to listen to parish councils and work with them on securing support for schemes identified in the Local Plan. |
DLP_6433 | Gary Birch | Object | Policy Number: STR 9 The document refers in a number of places to neighbourhood development plans. However, TWBC has – for no apparent legitimate reason – failed to “make” (recognise) the Hawkhurst Neighbourhood Development Plan submitted in March 2019 following a full local consultation and at considerable expense. Links to the Hawkhurst Neighbourhood Development Plan in the local plan point to the old, superseded Neighbourhood Development Plan. I believe that this amounts to a material shortcoming in the draft local plan |
DLP_6503 | Clare Govan | Object | TWBC: the standard response was submitted by the list of responders on the left: |
DLP_6674 | Gladman | 5.6.1 The policy attempts to set out how the Council will support and treat Neighbourhood Plans. The policy is unhelpful by failing to clarify what weight might be attached to an emerging Neighbourhood Plan at various stages. Gladman consider that this weight should be consistent with that typically attached to an emerging development plan document prepared by a local planning authority. This weighting exercise should also consider whether the Neighbourhood Plan conflicts with the strategic policies of the Local Plan where it is emerging or should it be out-of-date with a sufficiently progressed emerging Local Plan document. The role of the development proposal in meeting and responding to strategic plan requirements should also be considered. 5.6.2 It would assist the neighbourhood plan making process, if the Council could confirm through Policy ST9 which strategic policies of the Local Plan it is considered that a Neighbourhood Plan must be in conformity in order to meet the basic conditions. This will provide greater transparency and minimise the potential for delay during the plan preparation process. [TWBC: see full representation]. [TWBC: see also Comment Nos. DLP_6656-6695] | |
DLP_6880 | Rosemary Cory | Object | Policy Number: STR 9 The document refers in a number of places to neighbourhood development plans. However, TWBC has – for no apparent legitimate reason – failed to recognise the Hawkhurst Neighbourhood Development Plan submitted in March 2019 following a full local consultation and at considerable expense. Links to the Hawkhurst Neighbourhood Development Plan in the local plan point to the old, superseded Neighbourhood Development Plan. There is considerable suspicion in the community that the council has chosen deliberately to ignore the Hawkhurst Neighbourhood Development Plan because it does not accord with the Draft Local Plan. I believe that this amounts to a material shortcoming in the draft local plan and demonstrates that the council is not prepared to listen to, or properly take account of, the views of local residents in relation to planning policy. This has been amply demonstrated in council decisions on recent planning applications in Hawkhurst, which have ignored the considered submissions of the Parish Council and the views of local residents, and have been taken without due consideration of the legitimate issues raised. |
DLP_7510 | Mr and Mrs A J Herbert | Object | The document refers in a number of places to neighbourhood development plans. The Draft Local Plan does not recognise the Hawkhurst Neighbourhood Development Plan submitted in March 2019 following a full local consultation. Links to the Hawkhurst Neighbourhood Development Plan in the local plan point to the old, superseded Neighbourhood Development Plan. |
DLP_8324 | Pam Wileman | Object | TWBC: Comment was submitted on 19/11/19 after close of consultation (on 15/11/19). The document refers in a number of places to neighbourhood development plans. However, TWBC has – for no apparent legitimate reason – failed to “make” (recognise) the Hawkhurst Neighbourhood Development Plan submitted in March 2019 following a full local consultation and at considerable expense. Links to the Hawkhurst Neighbourhood Development Plan in the local plan point to the old, superseded Neighbourhood Development Plan. There is considerable suspicion in the community that the council has chosen deliberately to ignore the Hawkhurst Neighbourhood Development Plan because it does not accord with the Draft Local Plan. I believe that this amounts to a material shortcoming in the draft local plan and demonstrates that the council is not prepared to listen to, or properly take account of, the views of local residents in relation to planning policy. This has been amply demonstrated in council decisions on recent planning applications in Hawkhurst, which have ignored the considered submissions of the Parish Council and the views of local residents, and have been taken without due consideration of the legitimate issues raised. |
Policy STR 10: Limits to Built Development Boundaries
Comment No. | Name/Organisation | Object/support/support with conditions/general observation | Response |
|---|---|---|---|
DLP_96 | Stephen Farmer |
| We understand this topic is open for consultation and covered by Policy STR 10. The regulation 18 consultation document indicates the LBD for Sandhurst has some minor changes proposed to the build form of the settlement in accordance with the criteria specified under item 7.6, a to g. Our property stands at the western end of the village adjoining the LBD and is the only village house not forming part of the settlement. Can I ask that consideration is given to extending the LBD to include us as a logical extension of the LBD, as proposed elsewhere. Thank you |
DLP_137 | Gregg Newman |
| Comments on Section 4 Paragraph 4.87 (Limits to Built Development) p.62 You have not provided any detailed LBD information for Tudeley or East Capel, citing “the need for further masterplanning”. This once again highlights that this plan is not ready for Public Consultation as per my earlier comments. |
DLP_7829 | Andrew Chandler | Support with conditions | I support the principle of Limits to Built Development, but for Sissinghurst in particular you have created an entirely new “further/separate” LBD in a rural area (part of which – Mill Lane – is specifically designated by TWBC as a RURAL lane of particular historic significance) without any explanation. Paragraph 4.86 (3) and the LBD Topic Paper as it applies to Sissinghurst simply describe where you have drawn the line. In terms of the justifications advanced (in particular in Table 31 of the LBD Topic Paper), none stands up to scrutiny. See further comments on STR 10 and the Topic Paper. |
DLP_7835 | Andrew Chandler | General Observation | Policy Number: STR 10 I would comment that the justifications advanced for the proposed revised LBD for Sissinghurst do not stand up to scrutiny. The LBD derives from the draft Local Plan, so is subject to all of the same comments about site allocation as the Local Plan and the Sustainability Appraisal. Sissinghurst is a rural settlement with very limited amenities, very limited transport and no prospect of local employment. It is not the right place for extensive development. I challenge each of the justifications advanced for extending the Sissinghurst LBD. See further comments on the Topic Paper. |
DLP_7938 | Wendy Owen | Object | It is very difficult to see that there is any point to this policy. It provides no controls around the LBD, acting instead as a carte blanche to developers to ignore the LBDs through the place shaping policies. If TWBC is serious about LBDs, this policy should be strengthened to say “Outside the Limits to Built Development, development will normally be limited to that which accords with specific policies of this Plan and/or that for which a rural location is demonstrated to be undeniably necessary.” The policy should additionally say “Specific policies of this plan will include a justification and appropriate detailed mitigation in the conditions of development so as to guard against urban creep.” |
DLP_8112 | Ashley Saunders | Object | Paragraph 4.87 (Limits to Built Development) p.62 You have not provided any detailed LBD information for Tudeley or East Capel, citing “the need for further master planning”. This once again highlights that this plan is not ready for Public Consultation. |
DLP_8266 | Ann Gibson | Object | 4.80 The LBD of Sissinghurst should not be redrawn. Building should take place within the existing LBD. Sissinghurst has provided a NDP which excludes the area to the West of Mill Lane i.e east of |
DLP_8424 | Broadlands for Peter Dunlop | Object | Tunbridge Wells Borough Regulation 18 Consultation Draft Local Plan 2019. Representations in respect of;
These representations and objections are lodged on behalf of owners of the site of Chittenden Fields, Hawkhurst, Mr Peter Dunlop, and his wife, Joanna, and sons Nicholas and Thomas. They follow submissions and representations made by these parties to the Council’s Call for Sites and Strategic Housing and Economic Land Availability Assessment, as Site 2. This submission also acts alongside and in support of representations and objections made by Millwood Designer Homes, which Company has entered into a Legal Agreement with my clients to purchase the land at Chittenden Fields for the purpose of constructing a residential development.
Objection; Policy STR 10. The proposed Limits to Built Development (LBD) north of High Street, Hawkhurst. We have concerns at the approach taken to the interpretation, approach and definition and proposed revisions to the extent of the Limits to Built Development on the south western edge of Hawkhurst and north of the High Street, as;
We note that, as confirmed in Written Statement para 4.84, LBD’s are drawn around the ‘main ‘ built up areas of sustainable settlements, and enclose areas substantially developed, and not used for agriculture, woodland, lakes/ponds, outdoor sports and leisure, and need not be contiguous. Along High Street the main built up area is linear in character and appearance and does incorporate both the Higher density areas nearer the central crossroads and mixed the lower and higher density residential areas of detached and terraced houses fronting the Street as it extends to the west up to The Hawkhurst Cottage Hospital. This is part of the historic development pattern as it has grown from its hamlet origins, as is typical of most settlements, and provides an essential range of higher and lower density homes of homes for the residents of settlements, and is a part of the ‘main’ and sustainable built area of Hawkhurst. We note in particular the denser historically developed enclave of circa 12 detached houses, with more limited curtilages, on the eastern side of Slip Mill Road north of High Street, and abutting Chittenden Fields. We also note the terms of the Proposed Masterplan for the development of Hawkhurst Golf Course under the terms of planning application TW/19/0205/Hybrid, which shows the proposed access for the western crossroads bypass and this main access perimeter road for this residential development meeting High Street with a new roundabout alongside the residential properties at the junction of High Street and Slip Mill Road. We note that the Masterplan shows a block of residential apartments at this junction, and a cluster of new housing backing onto the more limited curtilages of the established detached houses fronting Slip Mill Lane at this point. We consider also note the proposed split in the residential development of the land within the golf course, with the larger part enclosing the south western corner of Hawkhurst, with access onto High Street and Cranbrook Road, which is split from a smaller estate of homes south of Gills Green by an elongated and retained open space fronting Cranbrook Road and bounded by the open land to Slip Mill Road to the west. Objection; Policy AL/HA 1. Land forming Part of Hawkhurst Golf Course. We consider that this area can reasonably be incorporated within a revised LBD within this part of the expanded settlement of Hawkhurst, and that the proposed Limit to Built Development for the Golf Course Housing allocation Policy AL/HA 1 should be revised to incorporate this land. Objection; Policy STR 10. The Proposed limits to Built Development north of High Street, Hawkhurst. In view of the above, we therefore object to;
We consider that Chittenden Fields should be allocated for residential development within the plan period to 2036. In this regard, we note and support the representations and objections lodged by Millwood Designer Homes, in particular that;
We note the inherent complications with the Draft Local Plan proposed Strategic Sites at Tudley, Capel and Paddock Wood, in their scale, the need and cross boundary consultations, for Master Planning, strategic land purchase including compulsory purchase, strategic road building and flood mitigations works, and the undoubted scale of public objection, delays for which will suggest that these proposals may not be achieved within the projected timescale of the Local Plan, and may well lead to a shortfall in meeting projected housing requirements. Chittenden Fields is part of an extended and open linear pattern of residential development fronting High Street along to the Hawkhurst Cottage Hospital. This open appearance as a ‘rural approach’ to Hawkhurst centre can be maintained within the development of this site, as we have shown in these submissions and addressed in the updated Lloyd Bore Scoping Landscape and Visual Statement prepared on behalf of and submitted by Millwood Designer Homes. The land at Chittenden Fields offers a suitable and available development opportunity for a high quality mixed density housing development, with retained open space along High Street, a suitable and achievable access to High Street with a priority junction with achievable visibility splays, with retained and enhanced landscaped boundaries, and within easy walking distance and on a public transport route to of Hawkhurst centre with its local services and facilities. Representations were submitted to the Call for Sites in respect of the prospects and availability of land at Chittenden Fields, which have been addressed in the Strategic Housing and Economic Land Availability Assessment (SHELAA) for the Draft Local Plan, as Site 2. We note the terms of the SHELAA for this site, and comment as follows;
This view would apply to the other proposed allocations. All are open AONB sites, historic to the village/town, and most are grade 3 agricultural land the loss of which would not cause material harm. This view is to be compared with the conclusion of the attached Lloyd Bore Scoping Landscape and Visual Appraisal of September 2017, supporting the Call for Sites submission, which analysed the implications for landscape impact of potential residential development of the site, as a ‘high level landscape appraisal of the area, identifying key landscape and visual principles that should be taken into consideration in bringing this site forward for development’(para 8.1)..’ This Appraisal concluded that..’The potential for landscape and visual impacts and natural resource constraints will represent important design considerations in bringing this site forward, but the site is already very well contained and screened visually from the wider landscape, and offers good opportunities for mitigation, enhancement and successful integration with the existing pattern of development of the village..’ (Para 8.5). Chittenden Fields can also be reasonably integrated into the existing linear pattern of development north of this stretch of the High Street, and, in particular with a logical and reasonable extension of the LBD as set out above. We note that Chittenden Fields;
The reasonable development of Chittenden Fields, as being a sustainable and available residential site, for a well-designed and landscaped development will assist in meeting the Council’s projected housing land requirement to 2036 and would cause no material harm to the landscape of the AONB or the character and appearance of this part of Hawkhurst. We trust that you will accept these representations and objections as being submitted in an acceptable form and would be grateful if you would confirm receipt. |
DLP_944 | Mrs Karen Stevenson | Object | STR10 should provide a measure of control to prevent spread of development outside of established built-up areas, to further protect the countryside of the AONB and to stop villages effectively merging into a larger urbanised areas. The proposed Policy Map for Matfield shows that its Limits to Built Development has been revised to include 3 of the 4 allocated sites and I strongly object to these proposed changes to the LBD for Matfield. The draft Local Plan further makes clear that LBDs could change with each 5-yearly review of the adopted Plan. Whilst the Plan states that, “LBDs help focus growth to sustainable locations/settlements, while protecting the surrounding, more rural areas from inappropriate and intrusive development,” (paragraph 4.81), the LBD of a settlement can be repeatedly redrawn to encompass additional allocated sites. The whole underlying principle of limiting areas for development, to protect sprawl, is undermined the ability to change the LBD every 5 years. This makes the whole purpose of the LBD policy of protection and restraint meaningless. I strongly object to this proposal for “flexible limits” and believe that whatever limits are ultimately set, should be fixed for the plan duration. How can LBDs protect rural areas from inappropriate and intrusive development if they have been redrawn, and can be redrawn again with each Plan review? If they can be expanded to encompass allocated sites previously outside the LBD, what real purpose do they serve? With specific regard to the proposed redrawn LBD for Matfield, I strongly object to the inclusion of allocated sites BM1 and BM 3 in particular where the proposed changes certainly do not comply with the stated criteria to be applied when amending LBDs, which state that amended LBDs must: “(a) be adjacent to and form a logical extension to the built up area and not result in harmful protrusion into the countryside; … (c) have no adverse impact on landscape character; (d) have no adverse impact on designated areas of national and local landscape, archaeological, geological, ecological or heritage importance; (e) be of a scale/nature in keeping with the form and function of the settlement and result in no harm to its character, appearance or setting…” These proposed changes also fail to achieve the principle of the LBD policy, in terms of its protection of a settlement’s rural surroundings from inappropriate and intrusive development. |
DLP_1755 | Horsmonden Parish Council | Support | STR10 -Limits to Built Development: we support the continuing definition of “limits to built development” for Horsmonden as a means of maintaining a compact and “walkable” village and protecting the surrounding countryside from the outward sprawl of development. |
DLP_3525 | National Trust | Support | The National Trust supports the removal of the whole of the Limits to Build Development at Kilndown and agrees with the findings of the Limits to Build Development Topic Paper for the Draft Local Plan which considers Kilndown to be an unsustainable settlement for further development. Removal of the whole of the LBD at Kilndown will also afford greater protection to the surrounding countryside. |
DLP_2200 | Mr Terry Cload | Support | STR10 I support the proposed LBD for Pembury. |
DLP_3684 | Capel Parish Council | Object | Paragraph 4.87 (Limits to Built Development) p.62 You have not provided any detailed LBD information for Tudeley or East Capel, citing “the need for further master planning”. This once again highlights that this plan is not ready for Public Consultation. |
DLP_1898 | Royal Tunbridge Wells Town Forum | Policy STR 10 Limits to Built Development Boundaries In our response to the Issues and Options Consultation we strongly supported the retention of a concept of Limits to Built Development for Royal Tunbridge Wells and welcome its retention under this policy. We are satisfied with the way in which the proposed new boundaries have been drawn to the same extent as we support or do not oppose the developments which have required a change to the existing boundaries. We support development in RTW being limited to the area within the LBD and would support a presumption in favour of densification within the LBD, provided this was always open to challenge in individual cases particularly when based on evidence under Policy STR 8 above. | |
DLP_2742 | St. John's Road Residents Association | Support | Support |
DLP_1977 | Mr Jeremy Waters | Object | Whilst I support the desire to contain development within the LBD, I have noted that in the case of Horsmonden, the LBD appears to have been considerably increased in size to conveniently include the sites proposed in the Call for Sites. This should not be the case as it implies that such large tracts of land are acceptable to develop, when in reality they are not. |
DLP_2015 | Dr David Parrish | Object | Section 4 Paragraph 4.87 (Limits to Built Development) p.62 There is no LBD plan for Tudeley/Capel The LP has not provided any detailed LBD information for Tudeley or East Capel, citing “the need for further master-planning”. This once again highlights that this plan is not ready for Public Consultation It us understood that the master planning of East Capel will not be completely controlled by the Council – but by Hadlow Estate The LP has a Master planning and Delivery approach within this policy that does not reference the involvement of developers and landowners. The master planning of Tudeley appears to be shared between the Council and Hadlow Estate. This is unfair and unwise. The properties they have in their care at present are generally poorly maintained with minimal regard to aesthetics and maximum regard to rental potential. Why would this change when they build to sell? |
DLP_2786 | Mrs Karen Langston | Object | I strongly object to the proposed changes to the LBD for Matfield and I have grave concerns regarding the likelihood of further expansion of the LBD in the future. The principles behind my objection also stand for the re-drawing of LBDs around other villages and rural settlements in the borough where the expansion is in order to incorporate proposed allocated sites at the high cost of the significant adverse impact on the rural character, the adverse impact on designated and protected landscapes and the irreversible impact on the settlement’s rural surroundings from inappropriate and intrusive development. The draft Local Plan makes clear that LBDs could change with each 5-yearly review of the adopted Plan. Whilst the Plan states that, “LBDs help focus growth to sustainable locations/settlements, while protecting the surrounding, more rural areas from inappropriate and intrusive development,” (paragraph 4.81), the LBD of a settlement can be repeatedly redrawn to encompass additional allocated sites. The underlying principle is undermined by other policies in the Plan, to the extent that the LBD’s general policy of protection and restraint is meaningless. With specific regard to the proposed redrawn LBD for Matfield, I object to the inclusion of allocated sites BM1, BM 2 and BM 3. This is because it fails to meet the criteria to be applied when amending LBDs, which state that amended LBDs must: “(a) be adjacent to and form a logical extension to the built up area and not result in harmful protrusion into the countryside; … (c) have no adverse impact on landscape character; (d) have no adverse impact on designated areas of national and local landscape, archaeological, geological, ecological or heritage importance; (e) be of a scale/nature in keeping with the form and function of the settlement and result in no harm to its character, appearance or setting…” It also fails to achieve the principle of the LBD policy, in terms of its protection of a settlement’s rural surroundings from inappropriate and intrusive development. |
DLP_1724 | Peter Hay | Object | Objective 10 is not credible given that TWBC ignores neighbourhood development plans. |
DLP_2767 | Lee Hatcher | Object | You are proposing a change to the LBD for Sissinghurst - A further/separate LBD at Sissinghurst; established around existing built development to the west of the settlement and incorporating residential allocations proposed in this Local Plan, with an open landscape gap retained between the two LBDs. - This was not part of the previous round of consultation and is not supported locally - it will encourage coalescence of settlements when we should be trying to maintain green spaces between them |
DLP_1618 | Maggie Fenton | Object | Section 4 Paragraph 4.87 (Limits to Built Development) p.62 You have not provided any detailed LBD information for Tudeley or East Capel, citing “the need for further masterplanning”. This once again highlights that this plan is not ready for Public Consultation and therefore unsound. |
DLP_3561 | Lynne Bancroft | Object | A further/separate Limits to Build Development (LBD) within Sissinghurst is not acceptable as it has only been put in place now to allow TWBC to put more housing in the area. The new LBD around Wilsley Pound and Mill Lane will start to connect two previously separate settlements (Mill Lane and Wilsley Pound) as TWBC policy will then allow infilling as shown in their assessment of Site 54 Policy AL/CRS 13 (land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road). This site has been assessed in the Cranbrook and Sissinghurst draft Neighbourhood Development Plan and development here is not supported by them so should not happen. This coalescence of developments is not acceptable in a newly defined LBD especially given the rural and historic nature of Mill Lane. Mill Lane is part of Sissinghurst Village and not Wilsley Pound and should not be included in the new LBD |
DLP_2041 | Terry Everest | General Observation | These should be kept to more closely, in general none should be extended or ignored. |
DLP_1782 | CPRE Kent | Support with conditions | CPRE Kent generally supports this policy but has reservations about a few of the proposed changes to LBDs, see CPRE’s Tunbridge Wells Committee’s responses concerning particular settlements. |
DLP_2839 | Helen Parrish | Object | Cross-referenced, detailed, reasons for my Objection: There is no LBD plan for Tudeley/Capel It us understood that the master planning of East Capel will not be completely controlled by the Council – but by Hadlow Estate |
DLP_3177 | Kent County Council (Growth, Environment and Transport) | Paragraph 4.82 Sustainable Urban Drainage Systems As Lead Local Flood Authority, KCC requests that the paragraph recognises all sources of flooding. Highways and Transportation The following sentence appears in many of the policies and is not acceptable to KCC Highways: | |
DLP_3807 | Natural England | Natural England has raised significant concerns regarding of the quantum of development proposed within the AONB. In relation to these issues, we have concerns regarding a number of the proposed limits to development boundaries. The following development boundaries either include large areas within the AONB, some of which are also proposed as major allocation sites themselves and/or include areas which do not relate well to existing settlement and are considered to result in significant impacts to the purposes of designation of the AONB, should they be developed.
Whilst the development boundaries are not allocations per se, they are indicated as an area within which development shall be focussed, indicating that some level of development within these areas may occur. We advise further landscape evidence is sought to demonstrate that development within these areas is appropriate in accordance with national planning policy which affords the highest level of protection to the AONB. | |
DLP_3923 | Ide Planning for Paddock Wood Town Council | OBJECT as per STR1 [see corresponding comment in Section 4: The Development Strategy] | |
DLP_4003 | Lamberhurst Parish Council | Support | STR10 – Limits to Built Development Minor changes at Lamberhurst supported |
DLP_6043 | Mr C Mackonochie | Object | Need stronger wording about new development allocations and LBD’s to limit sprawl |
DLP_4301 | White Young Green Planning for Standard Life Investments UK Real Estate Fund | Object | Proposals Map – Policy STR 10 (Proposed Limit to Built Development (land associated with Knights Park)) Standard Life Investments UK Real Estate Fund object to the current alignment of the ‘proposed limit to built development’ where it runs adjacent to the eastern boundary of the Knights Park allocation Policy AL/RTW 15 Knights Park. |
DLP_4667 | CBRE Ltd for Dandara Ltd | Support with conditions | Draft Local Plan Policy STR10: ‘Limits to Built Development Boundaries’ 3.65 Dandara supports the inclusion of Limits to Built Development and recognises the purpose of this designation as a means by which to control development. However, Dandara considers that it is necessary for TWBC to check the existing boundaries, as shown on the Local Plan Proposal Maps, in order to ensure that they are carefully and accurately drawn up, based on identified development needs, and on suitable evidence (including up-to-date OS and land registry data). 3.66 It is also suggested that TWBC build in some flexibility into this policy to allow Limits to Built Development boundaries to be amended in exceptional circumstances during the Plan period, in the interests of delivering new homes, for example where performance against 5year housing land supply targets is not being achieved. [TWBC: see full representation]. |
DLP_4474 | Paddock Wood Neighbourhood Plan Steering Group | No comment | |
DLP_3880 | Mrs June Bell | Object | Policy Number: STR 10, Limits to Built Development Topic Paper for DLP Reg 18 The wording of this policy implies a flexibility of LBD to accommodate allocation policies adjacent to or abutting existing LBDs. Reason for objection: Evidence to support this objection: |
DLP_3840 | Liane & Alan Chambers | Object | Policy Number: STR10 It is unclear from STR10 and the Inset Map 13 (Hawkhurst) whether the Limit for Built development for Hawkhurst will change. We suggest that given the AoNB setting, the LBD is retained and the Golf Course and Marlborough House School grounds are not included. Both locations (the Golf links and school playing fields) add to the landscape setting of the village and contribute to the rural character of the village edge. |
DLP_2881 | Chris Gow | Object | Limits to Built Development This should include LTD on flood plains and Green Belt Land |
DLP_2882 | Chris Gow | Object | This should include Limits to Built Development on flood plains and Green Belt Land. |
DLP_4583 | Keith Stockman | Object | 4.80 Limits to Built Development (LBDs) are used to differentiate between the built up areas of settlements and areas of countryside beyond. Generally, and subject to compliance with other policies in this Plan, there will be a presumption that proposed development such as infilling, redevelopment, and/or changes of use will be acceptable inside the LBD, while land and buildings outside the LBD will be considered as countryside where there is much stricter control over development. Development of land outside the LBD is already taking place in Cranbrook. This should not be used to justify redrawing the LBD, the current limits should be respected and development should be restricted to infilling etc within the existing LBD. The countryside outside the LBD should not be considered as ripe for development especially as much of it is AONB land. |
DLP_5159 | Cushman Wakefield for Ministry of Justice | Object | Policy STR 10 This policy reinforces the approach of Policy STR 1 and states that new development shall be focussed within existing settlements and will only be allowed outside the Limits to Built Development where it accords with specific policies of this Plan and/or that for which a rural location is demonstrated to be necessary. We consider this policy is too restrictive in that it does not appropriately follow the guidance of the NPPF because the other policies in the plan similarly are too restrictive for the same reason. We have made representations the Policy STR 1, STR/GO 1 and ED 5 accordingly and consider that if the requested changes are made, this policy becomes redundant and can be deleted. Alternatively, the Policy should be amended in respect of development outside the Limits to Built Development to include large previously developed sites which are not directly associated with the rural economy as narrowly interpreted by the ‘other policies’ referred to. [TWBC: see Comment Numbers DLP_5154, 5157-5159, 5161, and 5163-5164. See also full representation]. |
DLP_7638 | Mr J Boxall | Object | A further/separate Limits to Build Development (LBD) within Sissinghurst is not acceptable as it has only been put in place now to allow TWBC to put more housing in the area. The new LBD around Wilsley Pound and Mill Lane will start to connect two previously separate settlements (Mill Lane and Wilsley Pound) as TWBC policy will then allow infilling as shown in their assessment of Site 54 Policy AL/CRS 13 (land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road). This site has been assessed in the Cranbrook and Sissinghurst draft Neighbourhood Development Plan and development here is not supported by them so should not happen. This coalescence of developments is not acceptable in a newly defined LBD especially given the rural and historic nature of Mill Lane. Mill Lane is part of Sissinghurst Village and not Wilsley Pound and should not be included in the new LBD |
DLP_6818 | Mrs Carol Richards | Object | Policy STR 10 Limits to Build Development and preceding paras 4.80-4.89 LBD’s should be looked at to allow small developments within local communities. 4.87 Policy STR 10 fails to identify specific polices to build small groupings of bungalows to house the increasing elderly population (see comment against Table 3). Specifically, the aim should be to encourage 60+ people to leave larger family homes- in larger centres close to major transport connections to London- to move to smaller towns/villages still on a bus route and with local shops. Small hubs of 15-20 semi-detached bungalows with a small garden back and front would not imprint more than one of the boxed terraces. I will be one of these individuals by 2036 and I don’t want to be cooped up in a town centre flat. Bungalows are not high rise buildings and can be easily screened. Active 60+ persons add to a village- WI, Church Flowers, Governors to village schools, Volunteers- become members of local golf and tennis clubs. Start thinking laterally TWBC and look at what can be achieved with the LBD’s and a few extensions to LBD’s. It will take a lot more effort to achieve this, but the outcome will serve the people in your borough, a lot better than developing a Green Belt site and Flood risk site with 6,800 homes for London commuters. |
DLP_7286 | Mrs Katie Lee-Amies | Object | Strategic Policies (comments already included above) [TWBC: See comments DLP_7265-7267 and 7269-7277] STR 1 – object. STR 2 – object. STR 3 – object. The masterplan excuse! STR 4 – object. Strongly. STR 5 – support with conditions. Insufficient information. STR 6 – object. STR 7 – object. STR 8 - object. STR 9 – object. There are no LBD details for Tudeley STR 10 – object. |
DLP_6298 | Mrs Elizabeth Simpson | Object | Policy Number: STR10 STR10 should provide a measure of control to prevent spread of development outside of established built-up areas, to further protect the countryside of the AONB and to stop villages effectively merging into a larger urbanised areas. The proposed Policy Map for Matfield shows that its Limits to Built Development has been revised to include 3 of the 4 allocated sites and I strongly object to these proposed changes to the LBD for Matfield. The draft Local Plan further makes clear that LBDs could change with each 5-yearly review of the adopted Plan. Whilst the Plan states that, “LBDs help focus growth to sustainable locations/settlements, while protecting the surrounding, more rural areas from inappropriate and intrusive development,” (paragraph 4.81), the LBD of a settlement can be repeatedly redrawn to encompass additional allocated sites. The whole underlying principle of limiting areas for development, to protect sprawl, is undermined by the ability to change the LBD every 5 years. This makes the whole purpose of the LBD policy of protection and restraint meaningless. I strongly object to this proposal for “flexible limits” and believe that whatever limits are ultimately set, should be fixed for the plan duration. How can LBDs protect rural areas from inappropriate and intrusive development if they have been redrawn, and can be redrawn again with each Plan review? If they can be expanded to encompass allocated sites previously outside the LBD, what real purpose do they serve? What is the rationale for the proposed redrawn LBD for Matfield? Is it solely to include the propose allocated sites? I strongly object to the inclusion of allocated site BM1 in particular where the proposed changes certainly do not comply with the stated criteria to be applied when amending LBDs, which state that amended LBDs must: “(a) be adjacent to and form a logical extension to the built up area and not result in harmful protrusion into the countryside; … (c) have no adverse impact on landscape character; (d have no adverse impact on designated areas of national and local landscape, archaeological, geological, ecological or heritage importance; (e) be of a scale/nature in keeping with the form and function of the settlement and result in no harm to its character, appearance or setting…” These proposed changes also fail to achieve the principle of the LBD policy, in terms of its protection of a settlement’s rural surroundings from inappropriate and intrusive development. |
DLP_6991 | Nigel Tubman | Object | This is a vague policy with plenty of loopholes to extend or amend LBDs to suit the planners and undermines the whole basis of LBDs. The boundaries for LBD have been drawn for good reasons and to suggest that bordering an LBD makes the area suitable for development is plain wrong. |
DLP_6857 | John Gibson | Object | Object: |
DLP_6272 | Susan Heather McAuley | Object | Point 3 - Change to Limits to Build is being altered specifically to allow site AL/CRS13 (Mill Lane) Site 54 to be included in the Wilsley Pound settlement but Mill Lane is part of Sissinghurst Village not Wilsley Pound so does not belong in this Limits to Build. Changing the LBD in this way will remove any open landscape gap between Wilsley Pound and Sissinghurst and create coalescence. This LBD should not be changed. |
DLP_6481 | Woolf Bond Planning for Millwood Designer Homes Ltd | Object | Site 2: Chittenden Fields, adjacent to High Street and Slip Mill Road, Hawkhurst Policy STR 10: Limits to Built Development Representation We object to the Limits of Built Development in so far as they relate to the settlement of Hawkhurst. In setting out our representations we have considered the evidence base, including, but not limited to the following: Understanding the level of need and the most appropriate approach to the distribution of growth is important to assessing the appropriateness of the approach to the definition of settlement boundaries and the associated approach to site selection and allocation for development within revised built development limits. For the reasons set out in response to Policy STR1, STR/CA1, STR/PW1 and STR/HA 1, the definition of the settlement boundary for Hawkhurst is not justified as it cannot be said to represent the most appropriate strategy taking into account the reasonable alternatives. Section 19 of the LBD Topic Paper sets out the approach to reviewing the settlement boundary at Hawkhurst, with proposed amendments shown on the Map included on page 33. The dwellings to the west of Hawkhurst, north and south of High Street, to include the omission site at Chittenden Fields (Site Ref 2), extending to the west up to and including Hawkhurst Community Hospital, should be included within a revised settlement boundary. This best reflects the built environment. Along High Street, the main built up area is linear in character and appearance and does incorporate both the higher density areas nearer the central crossroads and the lower density residential areas of detached houses fronting the Street as it extends to the west. The Proposed Masterplan for the development of Hawkhurst Golf Course under the terms of planning application TW/19/0205/Hybrid shows the main access road for this residential development meeting High Street with a new roundabout alongside the residential properties at the junction of High Street and Slip Mill Road, with a block of residential apartments at this junction, and a cluster of new housing backing onto the more limited curtilages of the established detached houses fronting Slip Mill Road at this point. There is a proposed split in the residential development of the land within the golf course, with the larger part enclosing this south western corner of Hawkhurst, with access onto High Street and Cranbrook Road, which is split from a smaller estate of homes south of Gills Green by an elongated and retained open space fronting Cranbrook Road and bounded by the open land to Slip Mill Road to the west. The inclusion of this site as a housing allocation within the Local Plan will further influence the form and character of the area, further supporting an amendment to the LBD in this part of Hawkhurst. Suggested Change The inclusion of SHELAA Site Ref: 2, dwellings north and south of High Street, extending to (and including) Hawkhurst Community Hospital should be defined as being located within a revised settlement boundary. This represents a logical and sensible approach to defining the LBD at Hawkhurst. [TWBC: see full representation, site plan and Landscape and Visual Statement]. [TWBC: see also Comment Numbers DLP_6479-6484] |
DLP_6488 | Woolf Bond Planning for Millwood Designer Homes Ltd | Object | Site 222: Land on the west side of Iden Green Road, Benenden, TN17 4ES Policy STR 10: Limits to Built Development Representation We object to the Limits of Built Development in so far as they relate to the settlement of Benenden. In setting out our representations we have considered the evidence base, including, but not limited to the following: - Distribution of Development Topic Paper (Sept 2019) Understanding the level of need and the most appropriate approach to the distribution of growth is important to assessing the appropriateness of the approach to the definition of settlement boundaries and the associated approach to site selection and allocation for development within revised built development limits. For the reasons set out in response to Policy STR1, STR/CA1, STR/PW1, STR/BE1 and EN17, the definition of the settlement boundary for Benenden is not justified as it cannot be said to represent the most appropriate strategy taking into account the reasonable alternatives. Section 10 of the LBD Topic Paper sets out the approach to reviewing the settlement boundary at Benenden, with proposed amendments shown on the Map included on page 11. Map reference 1 proposes to revise the boundary to exclude Old Manor House, west of New Pond Road. It is suggested that this is because it is a listed building/heritage asset with an important landscape setting. There are any number of listed buildings (and their associated curtilages) within the built up area of Benenden. Moreover, land to the west of Old Manor House comprising dwellings north and south of the B2086 are strangely excluded from the review. These dwellings should be included within the LBD along with land west of Iden Green Road (Site Ref 222). Suggested Change The inclusion of Old Manor House, dwellings to the west and Site 222 within a revised settlement boundary represents a logical and sensible approach to defining the LBD at Benenden. [TWBC: see full representation, Figure 3 Landscape Strategy, Heritage & LGS Assessment, and site location plan]. [TWBC: see also Comment Numbers DLP_6485, 6487-6489, 6491-6494] |
DLP_6553 | Woolf Bond Planning for Millwood Designer Homes Ltd | Object | Site 60: The Paddocks, Home Farm, 92 Lower Green Road, Rusthall TN4 8TT Policy STR 10: Limits to Built Development Representation We object to the Limits of Built Development in so far as they relate to Rusthall, including on the basis that no amendments are proposed to the Green Belt (see separate representations submitted in response to Policy STR4 above). In setting out our representations we have considered the evidence base, including, but not limited to the following: - Distribution of Development Topic Paper (Sept 2019) Understanding the level of need and the most appropriate approach to the distribution of growth is important to assessing the appropriateness of the approach to the definition of settlement boundaries and the associated approach to site selection and allocation for development within revised built development limits. For the reasons set out in response to Policy STR1, STR/CA1, STR/PW1 and STR/RTW1, the definition of the settlement boundary for Rusthall is not justified as it cannot be said to represent the most appropriate strategy taking into account the reasonable alternatives. Suggested Change The LDB for Rusthall should be amended to include SHELAA Site Ref: 60 within a revised settlement boundary, and the site allocated for approximately 25 dwellings. [TWBC: see full representation, site context plan, access improvements and site location plan]. [TWBC: see also Comment Numbers DLP_6548-6450, 6452-6453, 6456-6457, 6459] |
DLP_6615 | AAH Planning for Future Habitat Ltd | Object | Policy STR 10 – Limits to Built Development Boundaries Policy STR 10 sets out that the limits to development for all settlements are shown on the draft Policies Map. It stipulates that new development will be focused within the limits to built development, where proposals accord with other relevant policies of the Plan. For development outside the limits to built development, it states that development will normally be limited to that which accords with specific policies of the Plan and/or that for which a rural location is demonstrated to be necessary. One of the key restrictions to delivering homes during the plan period is development limits of previous policies preventing any development on the ‘wrong’ side of an arbitrary boundary. Sites adjoining settlements can be equally if not more sustainable than those within settlements. It is therefore considered that this policy should be revised to allow flexibility for appropriate developments to come forward on sustainable sites that are well related to existing settlements. In addition, in order to ensure that the overall aims and objections of the Local Plan can be met, it is important that the settlement development limits are logical and allow for future expansion and flexibility. This is essential to ensure that the identified housing need can be delivered should some allocations not come forward. The identified development limits should therefore not be overly restrictive and should allow for future development in and around the existing and proposed urban area. Our Client therefore objects to Policy STR 10 in its current form and would suggest that the proposed settlement boundaries are amended to ensure that the identified development limits are appropriate, justified and defensible, as required by national planning policy. Furthermore, it is considered that our Client’s site at Heartenoak Road should be included within the proposed boundary to ensure that suitable and appropriate sites are not dismissed unnecessarily. It is noted that the site was submitted as part of the Local Plan Call for Sites exercise (Site Reference: 167). It is also considered that the wording of Policy STR 10 should be amended to ensure appropriate guidance relating to development outside of the development limits is provided. [TWBC: see full representation and site plan attached]. [TWBC: see also Comment Nos. DLP_6606-6620, 6622-6627]. |
DLP_6675 | Gladman | 5.7.1 Gladman consider that the approach taken by the collective policies of the Local Plan towards development within the open countryside to be too restrictive and actively harms the sustainability of rural areas. A criteria based approach enabling proportionate and sustainable development are met, will be of benefit in enabling rural areas to continue to function and grow in a sustainable manner, which is not captured through proposed allocations, will diversify the range of development that can come forward in compliance with the development plan enhancing the and will provide added flexibility should sites identified not come forward as expected. 5.7.2 Gladman’s favoured approach is provided by Policy HOU5 of the adopted Ashford Local Plan. The wording of Policy HOU5 is set out overleaf and should be adapted to be relevant to Tunbridge Wells. a) The scale of development proposed is proportionate in size to the settlement and level, type and quality of day to day service provision currently available, and commensurate with the ability of those services to absorb the level of development in combination with any planned allocations in the Local Plan and committed development in liaison with service providers; i) It sits sympathetically within the wider landscape; ii) It provides or enhances the setting of the nearest settlement; iii) It includes an appropriately sized and designed landscape buffer to the open countryside; iv) It is consistent with the local character and built form, including scale, bulk and the materials used; 5.7.3 In recognition of the landscape constraints of the Borough, it is recognised that an added criterion is necessary to reflect the policy position of the 2019 NPPF in relation to development within the AONB. [TWBC: see full representation]. [TWBC: see also Comment Nos. DLP_6656-6695] | |
DLP_7333 | Campaign to Protect Hawkhurst Village | Object | This Policy needs to make far clearer that the presumption is that further development on sites not allocated with the DLP outside the LBD will be resisted. The Council’s Distribution of Development Topic Paper provides [para 6.48 page 33] that: “A conclusion has been reached that there is no further capacity within the AONB to deliver additional development capacity beyond that which is already proposed in the Local Plan” The current drafting of STR10 in unnecessarily permissive given this conclusion. It should make clear that development outside LBDs in the AONB will be resisted unless exceptional circumstances can be demonstrated. |
DLP_7520 | Sarah Parrish | Object | Where is the LBD plan for Tudeley/Capel? Is the master planning of East Capel to be completely controlled by the Council? |
