Section 5: Place Shaping Policies Brenchley and Matfield

DLP_644

Janet Mitchell

In the introduction to the Local Plan for Brenchley & Matfield it is clear that the services and amenities provided in Brenchley greatly exceed those at Matfield yet all the housing is centred at Matfield. In this parish there is no doctor's surgery, no dentist, no Primary School or nurseries and one butcher's shop. There is no Post Office and that meant to be provided three times a week at the Village Hall are often closed. There are very few pavements, except in the centre of the village alongside the Maidstone Road and about q100 yards each side of Chestnut Lane and Brenchley Road.

DLP_946

Mrs Karen Stevenson

The over-riding strategy for Brenchley & Matfield, is to identify 4 specific sites, all within Matfield, rather than Brenchley, for the siting of between 91-150 dwellings.  Rather surprisingly and as referred to earlier under the heading Development Strategy (STR1), whilst all sites selected are in Matfield, when looking at measures of sustainability of each village, carried out by TWBC themselves as part of the Issues and Options Research outcome in 2017, Brenchley was assessed as having better services and facilities more appropriate to accepting additional development. Brenchley was classified in Group B, whereas Matfield, had significantly fewer services and facilities and was classified in Group D. Further on the “semi-dispersed growth” plan, Brenchley was proposed for development but not Matfield. Only on the “dispersed growth” plan did Matfield get an allocation, and even then, Brenchley also had some development allocated. Now we see a draft plan where it is all allocated to Matfield?

Further, from an infrastructure and transportation viewpoint, KCC Highways have already publicly stated, in commenting on a current planning application for the BM1 site, that “sites in Matfield would not be a favoured in a plan-led approach due to the lack of key facilities within the village and the resultant high dependence of residents on car borne trips”. I don’t believe this concern expressed by KCC Highways has been properly taken into account, it is in my view unequivocal and this view should be listened to in preparing the local plan.

DLP_1696

Brenchley and Matfield Parish Council

5. Development Proposals for Brenchley and Matfield

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

[TWBC: part of whole comment number DLP_1683 - SEE SECTION 1].

DLP_6811

Matfield Village Hall Management Committee

An observation, from the parish overview section page 4 in Parish Council version, page 277 in PC publication ( apparently page 280 in original main draft.)

In the ‘services’ in Matfield it lists 2 Village Halls, in ‘recreational facilities’ it also lists 1 sports pavilion.

There is one main village hall in Matfield and one Pavilion that is multi purpose, there is not a third building.

DLP_348

C R W Mitchell

My general comments on all the applications for development in the Borough's Draft Local Plan correspond with those I made on the Island site in Matfield, viz employment opportunities in Matfield are minimal; the primary school in Brenchley is full to capacity; the medical and dental surgeries are fully stretched which inevitably means that a larger number of cars will be coming onto the village roads where traffic accidents and speeding are a matter for alarm and concern.

As a resident of Chestnut Lane I am particularly concerned that the application for development in Matfield House Orchards and Land, which has only recently been published, now brings an increase to three sites which are encroaching on Chestnut Lane. In other words out of five sites scheduled for development three are little more than 100 yards from Chestnut Lane. (1) the Rydon Homes site adjacent to the Poet (2) the Island site and (3) the Matfield House Orchard site.

This is not just one site "in my back yard", but two and yet another just a little further away. What I am trying to stress is that there is an unevenness in the areas of the village chosen for development - the preponderance being around Chestnut Lane - and the only road into the Matfield House site emerging into Chestnut Lane which is already beginning to rival the Maidstone Road as regards speeding traffic, and will only become worse if more houses, with their accompanying cars, are built on the Matfield House Orchard site.

The Borough Council's statutory duty to conserve and enhance the A.O.N.B. of the High Weald will not be achieved it it insists on planting estates of houses whose design and architecture do not accord with the style of traditional village houses.

[TWBC: see also comment number DLP_823].

DLP_416

Rona Hogan

Methodology of calculating the housing target is incorrect

The borough Council should challenge its housing target given by the governments in general. The standard methodology uses out of date data and there are exceptional circumstances (the high proportion of the Borough including all Matfiled sites fall within AONB and Green Belt designation) to warrant using an alternative approach to access housing need, as permitted by the NPPF (paragrapgh 60). In addition, the house already built in Marden have not been sold therefore showing there is no shortage of housing stock. All houses built should be included in the total not just developments over a certain figure. The current development of 20 houses should be included within the total attributed to the number to be built in Matfield.

Developments are detrimental to road safety leading to more crashes and pedestrians being injured

The increase in traffic from the 91 to 150 homes to be located in Matfield in addition to the 20 houses currently under construction in the centre of Matfield, plus the traffic coming through from the developments in Paddock Wood and Horsmonden will be more than Matfield can cope with.

Matfields roads are already full at peak morning times, with queuing at all the major junctions and can't be made wider in all places. Maidstone Road is already dangerous where numerous crashes have occurred already in the centre of the village, and will mean road safety will be considerably worse if the developments are allowed. The current level of traffic is dangerous to pedestrians (cars have veered off the road across the pavement into fences/walls) and head on crashes have occurred at the Poet cross roads and outside Marchants as cars will not give way when trying to get past the parked cars. Maidstone Road running through the centre of Matfield is not designed for the volume of cars that will be generated with the planned developments, as it struggles now. The bus services are terrible and as this is a rural area they will not stop people using their cars as the buses only go along the main routes and are very infrequent and do not go directly to the station.

Having run speed watch in Matfield, the police are unable to stop people speeding what ever the signs state, as they have said they do not have sufficient resources to assist. TW Borough council have said to me personally at a meeting that Matfield could not have a speed camera. Having spoken to Kent Highways the road is not suitable for self policing speed humps due to ambulances coming through from Paddock Wood. There is no easy fix to slow people down, the major increase in traffic will reduce road safety and increase car crashes, not only on Maidstone Road but around the surrounding back roads as people try to find routes to around the hold ups.

Traffic calming is impossible along Maidstone Road whatever calming measures are considered in this plan, Highways have said it is not possible and obviously have not been consulted.

Re-drawn the 'Limits to Built Development' & detrimental impact on AONB

The Limits to Built Development exist to protect rural settlements from intrusive development. Matfield should be protected from the proposed developments and the destruction of its surrounding countryside as the Limits to Built Development (LBD) have been extended to include 3 of the 4 proposed sites, which cannot be allowed to occur when it has a detrimental impact to the High Weal Are of Outstanding Natural Beauty (AONB) which Matfield lies in and the TW Council has a duty to protect. The Local Plan also allows for further expansion of the LBD as part of the Plan review cycle. The policy regarding LBD does not achieve its underlying principle and should be strengthened to serve its purpose. LBD expansion should not be allowed.

The 4 developments will mean our dark skies will be affected as new developments will require lights, there will be a loss of wildlife habitats and run off for water. The 4 developments will have a extremely detrimental impact on the rural character of Matfield, as the developments are estates that are out of character with the rest of the village. The Council are supposed to be protecting rural landscape in the ANOB and not allow anything that is detrimental to the rural character. The increase in cars will also lead to an increase in pollution.

There is a conflict between the Council's statutory duty to conserve and enhance the High Weal AONB and the pressure to build sufficient houses to meet an untested target. The policies and language relating to the conservation and enhancement of the AONB must be strengthened and clarified with regards to the AONB tests in the NPFF (paragraph 172) and the required contribution to the objectives of the High Weald AONB Management Plan.

Creating so much housing in MAtfield Parish will require the destruction of woodland, hedgerows, meadows, and farmland that is Green Belt land and should be protected. It will spoil the landscape and kill wildlife that is very special to the area.

Matfield should remain rural with agricultural land that can be used to provide food and enhance the well being of its population. The 4 site will npt enhance AONB and will not contribute to the setting of the designated landscape.

Increased strain on the minimal infrastructure

Developments were supposed to be in areas where the infrastructure existed and could cope with increased housing. Matfield does not have any infrastructure, no schools, no doctors, no dentist only a butchers and a couple of pubs, plus mobile post office which is only open a couple of days a week. Matfield has minimal bus services.

The TW council has adopted its preferred approach of 'dispersed growth'. This area should remain rural with agricultural land that can be used to provide food. This is contrary to the principle of focussed growth in sustainable locations, which was central to the Core Strategy (2010), which the Local Plan replaces. The fundamental change in approach lacks robust justification and would lead to development that fails to meet the tests for sustainable development, as specified in the NPPF (paragraph 8).

The Plan proposes 'proportional development distribution' across the Borough. The 'Key Diagram' (fig.4 page 38) illustrates the development distribution, which is far from proportional. Without a rational that is consistent with the NPPF, this approach appears illogical, inappropriate and contrary with other policies in the framework.

Paddock Wood trains or parking will not cope with the substantial increase in passengers

Train will not cope witht he planned number of houses in Matfield, Paddock Wood and Horsmonden and the parking at the station is already difficult.

Final comment

TW Council is using rural villages including Matfield to dump their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the borough on brownfield sites (which the plan does not detail what has been reviewed) or placing small developments directly off of the A21 avoiding congestion in the small villages which will be unable to cope. The expected contributions will not mitigate the impact of the 4 developments proposed on Matfield, as the doctors in Brenchley have stated they cannot cope with any more patients and the landscape and rural feel of Matfield will be lost for future generations.

DLP_568

Margaret Charrington

I write in response to the Local Plan for Matfield and would ask you to reject any plan for housing/development which increases the traffic through the village of Matfield.  Before any such development takes place, consideration needs to be given to the appalling congestion where the Matfield road meets the Kippings Cross roundabout.  The traffic is backed up in both directions (North and South) on the A21 at most times of the day, turning a three mile journey into Tunbridge Wells into a three quarters of an hour traffic jam (as Radio Kent Traffic will testify daily). It cannot be right to add to the traffic congestion without agreeing an alternative route out of the village (and not one which results in speeding traffic on narrow country lanes, turning all surrounding byways into "rat runs").

DLP_598

Sport England

Policy STR/BM 1

Sport England supports bullet point e the new sports hub at Paddock Wood as it is in line with the adopted Playing Pitch Strategy.

DLP_879

Paul and Janet Dyer

Comments re TWBC draft local plan AL/BM1, AL/BM2, AL/BM3 and AL/BM4

The Historic Look

Matfield is an area of outstanding natural beauty, with a popular village green and duck pond, surrounded by historic 18c houses, which include Matfield House, a Georgian grade 1 listed building.

We believe that the proposed four new housing sites will overwhelm the Matfield we know and love, which attracts tourists to the area.

The proposed 91 to 150 new houses in Matfield will alter the rural picturesque look and spoil the village for future generations.

Insufficient facilities

Matfield is a small rural village and public transport is limited. Four development sites, in addition to the ones currently under construction, have been allocated to Matfield and none to Brenchley, which enjoys better facilities.

Traffic and Maidstone Road

Currently Maidstone Road Matfield is used as a transport link to the A21 and to the railways station in Paddock Wood. The new properties in Matfield, and in the surrounding areas, would greatly increase the traffic on this road. Maidstone Road joins the A21 at Kippings Cross roundabout, where the A21 goes from two lanes into one, and where traffic regularly queues and blocks the roundabout.

[TWBC: see comment number DLP_882 for specific comments on AL/BM3]

Impact on Wildlife and Green Spaces round Oakfield Road

This area is rich in wildlife including badgers, foxes, birds of prey, grass snakes, lizards, dormice, pheasants, woodpeckers etc and their habitat will be minimalized and disrupted.

Summary

We do not believe that the proposed increase in housing and population is proportionate to the size and facilities of Matfield.

We believe that the four proposed sites are too central for Matfield and would adversely affect the historic feel of the village.

We believe that Oakfield Road will not be fit for the purpose of access to The Ashes development.

DLP_892

Mr Peter Coombes

I would like to file my objections to the significant development included in the TWBC Draft Local Plan for the village of Matfield. I would also like to specifically object to the inclusion of sites AL/BM3 and AL/BM4 in the plan which both affect our property.

General Comments

The village of Matfield is an attractive village with its picturesque green and surrounding area. I feel the developments proposed will completely spoil the village both for its residents and for the many visitors, walkers and riders enjoying the views and footpaths around the village. It is very disappointing to see that TWBC have changed the Limits to Build line around the village. It has obviously been changed to accommodate the proposed building sites in the Draft Plan. This line was a protection for the village and should not have been changed.

I realise the current house building targets which TWBC are required to plan for the future by the current government but see no reason why there is a need for up to 150 houses to be built in a small rural village like Matfield changing the whole character of the village. The number of houses planned is huge as a percentage of the total number of houses located in the centre of the village and would overwhelm the existing properties within the centre. The proposed developments for Matfield and Brenchley have not been distributed evenly across the parish and will specifically affect residents living in Matfield at either end of the village. Development in the Parish for the future should be small scale and distributed evenly across the Parish. Surely the extra houses proposed for Matfield could be added to the vast housing development proposed for the surrounding areas around Paddock Wood. Why not leave our picturesque villages for future generations to enjoy and find more appropriate sites for development. It should be questioned whether these houses are actually needed. Is there a queue of people waiting for houses in the village? Surely throughout the country, houses should be planned for areas where there is a shortage of housing and where they are needed.

The development which has taken place in Matfield in the past, has to a large extent, been acceptable.  It has had minimum effect on residents and in some cases significantly improved the look of specific sites. The new draft plan is pushing building into fields and orchards surrounding the village and spoiling vistas, hedgerows and wildlife.

Matfield has virtually no facilities to support extra development with only a part-time post office in the Village Hall 3 mornings a week and a butcher’s shop. The main pub has now closed and is being converted into houses. The doctors’ surgery, dentist, school and post office/store are all in Brenchley where no future development is planned. I am sure that 150 extra houses which one assumes will mean around 500 +additional residents will surely have a major effect on these facilities and which are not even in our village. We have the village school in Brenchley which needs major repair and upgrading and which would surely have difficulty coping with the extra numbers from the increased population. Bus services in the village are totally infrequent and only go to limited destinations.

I have lived at my current address for over 40 years. Other residents along Maidstone Road are long standing residents. We live in the village because we like village life. We now find ourselves in retirement and have proposed developments to front and to the rear of us. Surely this can’t be right and shows a total lack of consideration for current residents by planners in order to meet government targets. Why should one section of the village be affected by two of the four proposed developments?

Traffic is a major concern to the residents of Matfield. We have over recent years seen a significant increase in general traffic and heavy vehicles coming through the village. The noise affects all residents living on Maidstone Road where houses are generally built close to the road. The volume and speed of traffic is a major safety concern for all residents throughout the village. There have been no positive moves over the years by Councils to restrict heavy vehicles coming through the village, extending the 30mph on Maidstone Road or discuss traffic calming measures. Any further development in the village should be halted until this issue is resolved. Another 150 houses would mean at least 250 extra cars in the centre of the village making daily journeys. This will have a significant effect on traffic in the village. Since the ambulance station came to Paddock Wood we also seem to be a major gateway for ambulances travelling to the A21 through the village on a regular basis with sirens sounding.

Another major traffic issue currently affecting Matfield is the build-up of traffic from the village trying to access the A21. When the Sevenoaks and Pembury bypasses were joined traffic congestion on the A21 was simply pushed on to the roundabout at  Kippings Cross. This now causes long tailbacks on the A21 especially at peak times and at weekends. It is made made worse by the second roundabout at the BP station. Traffic will not give way at the roundabout to traffic coming from Matfield heading North causing tailbacks from the village. Coming from Matfield recently I queued for 15 minutes just to get onto the A21. This issue will only get worse and until the next stage of the A21 is complete no  further development in Matfield should be considered.  Traffic travelling South is now turning off the A21 at Kippings Cross into Matfield to try and get around the queues on the A21. They are using Matfield as rat run causing additional traffic through the village.

DLP_947

Mrs Karen Stevenson

Policy AL/BM 1 –Land between Brenchley Road, Coppers Lane and Maidstone Road (Island site). Allocated for a mixed-use scheme including approximately 30-45 (C3) residential dwellings, allotments and play space. Single point of vehicle access could be via Maidstone Road or Brenchley Road. Proposals are to include a crossing point opposite site AL/BM 2, provision of a children’s playground on the northern part of the site and provision of allotments in south west corner, adjacent to existing allotments, including off-street parking for this use.

This site falls wholly within the AONB, and wholly outside the existing LBD. It is a significant piece of land very prominent when viewed from B2160 Maidstone Road, a significant visual amenity when approaching to the village from Paddock Wood to the North. The proposed access is off the main through the village, which is already at significant risk of becoming much busier if the Paddock Wood proposals come to fruition.

Development of this very high profile site would be totally contrary to the High Weald AONB management strategy.

DLP_985

Janet Harman

re: TWBC DRAFT LOCAL PLAN

I make the following objections to the above:

I consider all the proposed development sites ie Matfield House, Orchards: The Island Site: Land at Maidstone Road: Ashes Plantation to be too intensive in a small area coverage. They are not sustainable as I do not think that the village has have enough infrastructure now and that the existing services do not meet the needs of the community now and if these housing developments are built even more strain will be put on the existing services. For example there are only one Medical Practice in Brenchley which serves Matfield as well and Woddlands Medical Centre in Paddock Wood is struggling with lack of GPs and are already relying on locums. There are many other examples of inadequate infrastructure already and the village over the years has lost its post office and shop, the existing primary and secondary school are already are working at full capacity and more housing developments will only add to the already pressures on the roads, water supply and electricity supply. There is only one dental practice and that already serves a wide area, All these proposed housing developments as the one proposed will bring more people which would add strain to the existing services.

The development will have a negative impact on an Area of Outstanding Natural Beauty.

The impact on the character of the village and its rural setting will be jeopardised and become one big building complex. Also, the disruption it will cause to residents whilst under construction

The impact on the environment which these developments will cause would have detrimental effect on the area including dark skies and air pollution.

Traffic issues are already a problem in the area, the roads have become heavily congested with more traffic using roads and many are still country lanes and would have an impact on highway safety.

The Council should be taking into consideration these important facts which obviously it has chosen to ignore.

Matfield is in the High Weald Area of Outstanding Natural Beauty (AONB).

The Council has a statutory duty to conserve and enhance the High Weald AONB.

The National Planning Policy Framework (NPPF) says that great weight should be given to conserving Areas of Outstanding Natural Beauty.

The NPPF says that planning permission should be refused for major developments in an AONB except in exceptional circumstances and where it is shown it is in the public interest which none of these are it would seem.

These proposed development sites are outside of the Limits to Built Development. Ordinarily, these 'limits' are set to prevent the sprawl of villages into the surrounding countryside.

The Council's Local Plan says that villages are considered to be inappropriate if there are certain issues and these developments do not follow the guidelines given..

Kent Highways have already advised that sites in Matfield would not be favoured in plan led approach due to lack of facilities within the village and the resultant dependence of residents on car borne trips. The Kent Highway remains of this view and will comment accordingly on any planning applications which come forward

Council Study found Matfield is one of the least sustainable villages in the Borough (February 2017) which now with this Draft Local Plan has been disregarded.

DLP_1695

Brenchley and Matfield Parish Council

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

c. Regarding STR/BM1:

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

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

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

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

[TWBC: part of whole comment number DLP_1683 - SEE SECTION 1].

DLP_1742

Clare Kember

Object 

The strategy for Brenchley and Matfield Parish (91-150 homes)

* There were 24 sites put forward for consideration within Brenchley and Matfield. The proposed developments have not been proportionately dispersed around Brenchley and Matfield. All 4 proposed plots are situated in Matfield with no new developments proposed in Brenchley. This is addition to the 22 new Rydon Homes already being built in Matfield.

* Brenchley has a stronger infrastructure to support additional homes as it already provides services such as a school, a doctor’s surgery, a dentist and a permanent Post Office and shop. In an earlier proposal it was decided that Brenchley was more likely to be chosen to develop homes because it was more sustainable than Matfield. This seems to have been disregarded in the latest plan.

* Matfield residents have to drive or use public transport to utilise services in Brenchley. If new residents could walk to services this would facilitate access for more of the community and also better protect the environment.

* Access to and from the very large proposed developments in Paddock Wood and Capel (4000 homes) and Tudeley (2500 homes) to the A21 is currently served by the busy A228 ‘Colts Hill’. This road has dangerous bends and junctions and ends in congested ‘traffic light’ approaches to Tunbridge Wells and Pembury. The alternative route, often accessed via Crittenden Road and Chestnut Lane, is the B2160 Maidstone Road passing through Matfield. This also has dangerous bends and junctions and becomes congested at the A21 Kippings Cross roundabout. The transport infrastructure would require a vast improvement before such large developments could be sustainable.

DLP_2347

Sarah Coulstock

Object & General Observation

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_2480

Ruth Baker

I am writing to you in support of the excellent submission made to your Council by the Brenchley and Matfield Parish Council. It is sobering to reflect that our "amateur" parish council has had to call the Borough Council professionals to account on so many issues.

First and foremost, it appears that the Borough Council's assessment of housing needs is based on unsound figures. For those of us who live in the South East, and who, every day, experience the pressure of already creaking infrastructure in the hospital, the schools, the roads, further wholesale development, of the kind proposed, is intolerable. We have no option but to ask the Borough Council to review urgently the figures on which the Draft Local Plan is based.

Secondly, I urge the Council reviews the area designated for "dispersed growth": it seems to be based on the route of the railway line between London and Ashford through Paddock Wood. We can only conclude that we are destined to become a dormitory area for London commuters. The vitality of villages is lost when the majority of residents only contribute to the life of the local community at weekends. The choice of a concentrated arc through Horsmonden, Brenchley, Matfield, Capel and Pembury means that a significant step will have been taken towards the death of these villages and a descent into suburbia.

On the specific case of development in Matfield, The Ashes Plantation site is unsuitable for 50 houses. The problem is the access: the proposed development would be a cul-de-sac bolted onto an existing cul-de-sac, via a bottleneck onto the Maidstone road, which is already overcrowded at peak times.

The present Limit to Built Development seems to be an arbitrary boundary, which has not been revised to accommodate the new policy of dispersed growth. It does not correspond to the actual line of existing houses and has the effect of concentrating the development of new housing into a higher density than the historic houses of the village which circle the Green, such as Matfield House, Maycotts, etc., most of which have extensive gardens and grounds. The LBD boundary should be extended outwards to allow for lower density in the sites already identified as suitable for development.

The "island" site, beside Coppers Lane and the Brenchley Road should be limited to bungalows along the Brenchley Road to prevent any new houses there towering over the cottages below, to take full account of the fall of the land from the Maidstone Road to the Brenchley Road.

DLP_2546

R Hornby

I wholeheartedly support the response of Brenchley and Matfield Parish Council to the draft local plan regarding the growth of housing across the borough and there argument that the figures produced for housing need are unsound in particular I wish to comment on the draft plans for Matfield especially the Ashes Plantation site, my objection is based on the access and how it will impact on Oakfield Road residents and also the loss of orchards and the woodland.

My experience of the traffic in Maidstone Road, when I each week volunteer at Tunbridge Wells Hospital to visit from Friars Lane to the Hospital at 8 o clock in the morning it takes at least 10 minutes to get out onto Maidstone Road. I proceed about 330 yds to Matfield Church and then join the cue to get up to Kipping Cross Roundabout, which then means a 3 mile journey can take up to 30 mins which then means its sometimes a problem to park in the Staff Car Park this is before any development in either Paddock Wood or Brenchley and Matfield

DLP_3331

Kent County Council (Growth, Environment and Transport)

Highways and Transportation

The Local Highway Authority conditionally supports this policy. The following change is requested:

Paragraph 6 - “Maintenance and enhancement of, and/or linkages to, public footway network and public rights of way and the local strategic cycle network in accordance with Policy TP 2: Transport Design and Accessibility”

Public Rights of Way and Access Service

The specific reference to PRoW in paragraph 6 is supported. It is requested that PRoW enhancements are included in the list of expected contributions, to mitigate the impact of future development.

DLP_4052

Roberta Neale

Strategy for Brenchley and Matfield p281 onwards

Again I support fully the reservations set out in Brenchley and Matfield Parish Council’s submission which are well articulated.

I do, however, support the concept of part of the orchard at Matfield House being safeguarded as a green space and landscape buffer.  This will allow views of the house to be retained and the orchard itself which is attractive could usefully be used as a community asset for both young and old to enjoy and participate in its preservation.

In the case of this village I believe that sustainable development is unrealistic and a more overarching view of the impact of the plan as a whole on this village has not been assessed.

DLP_4134

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

The proposed major developments in allocations BM1 to 3 have not been adequately justified under NPPF paragraph 172.  We are particularly concerned about the effect allocation BM1 will have on the perception of the AONB landscape as you enter it from the Low Weald.

Under paragraph 5 the car park outside the Recreation Ground at Market Heath ought also to be retained as it is a vital public facility, providing parking for parents and visitors to the school as well as visitors to the Scout Hut and the children’s playground and the one remaining local business there.

We question whether the proposed extension of the Limit to Built Development at Brenchley to include most gardens to their full extent complies with criteria c, d and e in paragraph 7.6 of the Topic paper on LBDs.  The landscape aspect of the built environment here looking from the south is  an important feature of the AONB and extending the LBD here could allow building which would seriously damage it.

We also question how the proposed new LBD at Market Heath (west of Brenchley) complies with criteria c and d of paragraph 7.6 of the Topic Paper, given that it refers to a relatively small area of (mostly) ribbon development in the AONB, including housing that was built as a Rural Exceptions Site.

We are concerned that the part of this policy referring to developments larger than 100 residential units could encourage applications for major developments which are thoroughly unsuitable in the AONB and its setting.  Arguably, for sustainability, any development of more than 20 dwellings in villages and the rural area ought at least to provide some employment possibilities, for example through live/work units.

DLP_4558

Historic England

Policy STR/BM 1: The Strategy for Brenchley and Matfield Parish et seq - as with the foregoing comments, we would expect the allocation of sites following on from this Strategy policy to be subject to appropriately robust and detailed heritage impact assessment prior to the allocations being adopted.

DLP_5058

Mrs Rosie Bishop

Object

Matfield is one of the least sustainable communities in the borough and lacks most of the services & amenities required for development on the scale proposed (NPPF paragraphs 7 & 8).

The proposal for 91 to 150 new houses is unsustainable and seems to be based mainly on the sites put forward by landowners in the call for sites rather than objective criteria.

Contributions to be required from developers will be used to help fund, amongst other things, improvements along the Hop Pickers Line and sports facilities and play space in Paddock Wood.  Why?

Is it true that item h (new children’s playground at Matfield) has already fallen at the first hurdle?

I do not support the extension of LBD in either Matfield or Brenchley; the proposed Matfield extension seems merely to be there to accommodate three of the four allocated sites and, as well as resulting in the loss of the declared protective purpose of green belt, seems at odds with the policy objective to protect & enhance the AONB.

DLP_5653

Ann and Richard Lengkeith

With regard to the Draft Local Plan for Brenchley and Matfield, we have serious concerns regarding the infrastructure around our villages.  We live in Brenchley and we are concerned about the increase in traffic that the proposed developments would cause, and also the impact on our already stretched GP surgery.

We therefore do not feel that the proposals are in the public interest.

DLP_5777

Rose Harrild

Matfield

The village  is within the High Weald AONB. It has special historic interest and a beautiful village green.

The proposal is for 121 dwellings on four new sites. This in addition to 20 dwellings already under construction on Maidstone road on the edge of the village. The proposed sites for housing are unacceptable.

Traffic Generation in this area - Matfield, Horsmonden

Apart from the complete unwelcome alteration of the villages, there is the serious question of traffic generation.

The roads serving these villages already carry a great deal of traffic, which has greatly increased over the last few years.  There already queues on B2160 to join A21 in the rush hour.

The road between Matfield and Horsmonden passes through the centre of Brenchley village. It is narrow with dangerous sections, particularly at the Fairmans lane bend and the crossroads in Horsmonden. It is quite unsuitable to plan for this road to take more traffic.

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_5887

Mr and Mrs Jonathan & Nicola Marriott

We wish to OBJECT to Policy 5 of the draft Local Plan, with particular reference to the village of Matfield, part of the parish of Brenchley and Matfield, on the following grounds:-

1) The proposal to put between 91 and 150 houses on four sites in Matfield, which is on the edge of the High Weald AONB, will irrevocably change the character of the village, both in terms of population percentage and in terms of housing density.

2) The two principal villages in Brenchley and Matfield Parish, Brenchley and Matfield, have very distinct and different characteristics. Brenchley is a tightly built village, centred around its church, with a separate area of built development around Market Heath. Both of these areas of built development are comparatively dense, even where individual houses sit on larger plots. Matfield, on the other hand, is characterised by its spread out, more diffuse nature, centred on a large village green with an Arcadian Area, but stretching as far as Dundle Road to the South, to Badsell Farm to the West and to Gedges Hill to the North. It has broad verges, its houses being well set back, many behind hedges and an open character On the northern side, the area of land bounded by Maidstone Road, Brenchley Road and Copper’s Lane (AL/BM1), provides an open green space typical of the village, with views across to Copper’s Lane and Brenchley Road from Maidstone Road. The southern approach to the village from the A21 passes scattered older houses, open fields and high hedges, so that one comes upon the village green quite suddenly, with its pleasing houses, primarily of eighteenth century or earlier origin. The Landscape and Biodiversity Officer, when responding to a consultation on Planning Application Number 19/01099, made in respect of Site BM1, commented that Matfield is “an area of very loose knit development with a strong rural character”. That character will be irrevocably changed by the proposed developments.

3) There is no local housing need for 120-150 new houses in Matfield. There is a need for some houses, particularly smaller houses, for local people with local connections, who wish to live in the same village as their family, or who wish to downsize within the neighbourhood where they have always lived, but there are not 120+ such households. The proposed allocation results in an increase in population of nearly 40%.

4) Whilst the density of housing proposed for Sites BM 1, BM 2 and BM3 might have the laudable aim of “best land use”, that density is completely out of keeping with the existing pattern of development in the village. The impact of comparatively high density housing can already be seen at the Rydons’ Homes development, now named Marchant’s Lea, on Maidstone Road, opposite Site BM1. The twenty homes on that site are at odds with their neighbours and are much more plainly visible from some distance than residents had been led to believe. This is partly because of the necessarily wide visibility splays at the entrance to the site and partly because they are much closer to the road than other properties. The new development does impact on the setting of the Listed public house and restaurant The Poet, despite assurances that it would not.

5) If Site BM1 is developed at the density proposed in the Draft Local Plan (DLP), the Northern approach to the village will be totally altered. This contravenes the stated policy of para 6.197 of the DLP which states:- “The first view of any town or village is important in forming an impression, particularly for visitors and tourists. Consequently, development such as a high, close-boarded fence or solid wall, a new access and visibility splays, the introduction of a dominant new building, or through the loss of soft landscaping, are likely to detract from the approaches identified by, for example, obscuring views of the vegetation. The retention, protection, and enhancement of these landscape approaches will therefore be given priority by the Local Planning Authority in the assessment of any such development proposals, and landscaping should remain the prevalent feature.”

6) Equally, Site BM4, on the Southern approach to the village will of necessity require very wide visibility splays, with consequent loss of trees and hedges, because of the bend in Maidstone Road between Court Farm and Matfield Village Hall. Again, this will completely change the approach to the Village Green from the Southern side. We have, in regard to this site, been unable to find a list of the historic and traditional farmsteads in the Borough, which presumably exists in connection with the Farmsteads Assessment Guidance for Tunbridge Wells 2016. This site is immediately adjacent to the historic Court Farm House, as well as the Conservation Area (CA) and is proximate to the village’s Arcadian Area. As the site has been excluded from the revised LBD, might it not be better if it were designated an Exception Site for a small number of affordable housing units around the Village Hall (say five or six), as was proposed over twenty five years ago? The site entrance could be through the Hall’s car park, particularly if it is intended to use the land to the rear of the Village Hall for additional car parking. That latter proposal is in itself not free from criticism – Community use has not been defined, beyond car parking, and use as a car park would require mitigating planting and screening from the CA. It should also be noted that this site is within the water catchment area and, after years of neglect, it has become an area for wildlife, including dormice and many wild birds.

7) Housing Site BM2, although not visible from the main approaches, will have its access from Chestnut Lane, a residential area, already used as a primary route from Horsmonden and Brenchley to travel to Tonbridge and the A21. This use has intensified with the traffic bottleneck that is the Kipping’s Cross roundabout on the A21. Queues of traffic can reach back from the roundabout to the village outskirts during the morning rush hour or in the event of any problems on the A21. With extra development at Horsmonden, as well as Matfield, traffic use of Chestnut Lane and Crittenden Road is likely to intensify. These roads are narrow and not designed for heavy traffic. At Five Wents, very close to that site, the road is reduced to a single lane, with poor visibility through from each end.

8) Similarly, Site BM3, Ashes Plantation, will see potentially up to 60 houses sited to the rear of Oakfield Road, a narrow residential road, where cars park on both sides. As well as the fact that the density of housing is out of keeping with the pattern of development in this AONB village, the site access is inadequate for the proposed development. It will deliver a substantial number of vehicles onto the already congested Maidstone Road, very close to the exits from Matfield Green, the village hall and any development of Site BM4. It is noted that it is intended that car parking will be provided on the new development for Oakfield Road residents but, in practice, how will this be enforced? The proposal amounts to urbanisation of this rural area.

9) Besides the adverse impact upon the character of Matfield and the traffic implications of the additional housing, the Borough’s own Evidence Studies do not support development of this scale in Matfield. The Role and Function of Settlements Study 2017 specifically put Matfield in one of the lowest bands of sustainability for development, because of the lack of infrastructure and facilities. Since that Study was completed, further facilities have been lost from the village. The DLP states in para 4.40 that there should be “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.” Development of this scale does not comply with these criteria, in a village that lacks most of the basic facilities. The Borough’s own Sustainability Appraisal issued in support of the DLP, states “The policies in this parish represent a reasonable score for the housing objective. However, the scores are diminished by the fact that Matfield (where most development is proposed) lacks many facilities and services, thus making the housing less suitable for the elderly or disabled. That being said, travel to Paddock Wood is easiest from Matfield and thus there is an advantage in this proposed pattern of growth.” One of the major requirements for housing in the village is suitable homes for the elderly to “downsize” to. Public transport from Matfield is only marginally better than from other villages and it is fantasy to believe that most journeys will be by anything other than car, adding to the congestion on Maidstone Road and in and out of Paddock Wood. Logically, the rational plan would be to put the majority of the possible 150 houses in Paddock Wood, where it is anticipated the additional residents will go for their basic needs, whilst providing affordable housing in Matfield.

10) Matfield does not have a school or a doctor’s surgery, both these facilities being in neighbouring Brenchley. The lack of a pavement means that it is not possible to walk safely to either from Matfield, which will increase car usage in the village. Even if there were safe pavements, the time constraints of modern life make it unlikely that the majority of parents would walk their children to school from Matfield and unwell people are not going to walk over two miles to a doctor.

11) The Landscape Assessment makes much of the distinct and separate characters of Matfield and Brenchley and the proliferation of traditional farmsteads and historic buildings and, in particular, the dark skies of the area – “Calm, colourful and vibrant rural landscape with relatively dark skies across the whole area Small scale development and a lack of lit roads create relatively dark skies extending across the whole area. Rural activity in the working farms and orchards, and the villages of Matfield and Brenchley, results in a landscape full of texture and interest. Access to the countryside via a good network of public rights of way including the High Weald Landscape Trail and large private gardens with visitor facilities, makes the area a popular destination for visitors and walkers to experience the High Weald landscape. “  The substantial proposed developments will alter the character of this for ever and threaten the dark skies.

12) The proposed development is of a scale and intensity that totally changes the character of this area and, further contravenes, the stated intention of paras 6.221 and 6.222 0f the DLP:-

“6.221 This SPD will be used as a key tool to guide decisions in the preparation of all plans and strategies, planning applications, and other decisions bearing on the management of land. While conserving and enhancing the key characteristics, it is important that developments should also have regard to the opportunities for enhancement identified within each character area and should support the landscape strategy for the character area.

6.222 While a dispersed settlement pattern, built upon the dispersed pattern of historical farmsteads and ancient routeways, is a key characteristic of the landscape across the borough, it does not in itself justify further new dispersed settlement that replicates this, as it may undermine the historical integrity of the landscape and erode the historic character.” All of this places the proposed developments in contravention of the DLP’s EN21 Policy, which states (inter alia) that ”Development will be required to

a) Conserve and enhance the unique and diverse variety and juxtaposition of the Borough’s landscape and special features that contribute positively to the local sense of place

b) Not cause significant harm to the landscape setting of settlements, including historic farmhouses and hamlets

c) Preserve intrinsically dark landscapes in accordance with Policy EN10: Outdoor Lighting and Dark Skies."

13) In the DLP, it is plainly stated that the Borough is a popular tourist destination, visitors being drawn to the area by not only the historic town centre with its green areas and the Pantiles, but also by the rural landscapes (DLP 2.39), the particular attractions of the rural areas being extolled in further detail in DLP 2.40.  By extensive building, the Borough is killing its own geese that lay the golden eggs.  This is particularly true of villages such as Matfield, which are situated in the AONB. It is notable that the Historic Environment Review uses two large photos of Matfield as its first illustrations as well as two further colour pictures in its subsequent gallery of photos.

14) Matfield has been allocated the highest number of houses of any village that is within the rural area of the High Weald AONB, resulting in a population increase of nearly 40%, which is quite disproportionate. This is inappropriate when the impact on the character of the village, the sustainability of the village, the lack of infrastructure and the traffic implications are taken into account. The fact that sites have been offered by landowners should not make the village a soft target for development. With all due respect, the motivation is more likely to be financial than philanthropic and does not mean that all residents want to see development on this scale. Also, the fact that sites are close to the boundary of the AONB should not be used to justify development. There has to be a boundary somewhere and to allow this to be eroded by intensive development on the basis that it is close to the boundary means that boundaries become irreleant.

15) It is difficult to see how proposed development of this scale can in anyway comply with the requirements of the DLP Policy EN21 governing the AONB.

15) It is difficult to see how proposed development of this scale can in anyway comply with the requirements of the DLP Policy EN21 governing the AONB.

Policy EN 21 

High Weald Area of Outstanding Natural Beauty (AONB) 

All development within, or affecting the setting of, the High Weald AONB shall seek to conserve and enhance its landscape and scenic beauty, having particular regard to the impacts on its character components, as set out in the High Weald AONB Management Plan.   

Major development in the AONB is defined in the NPPF paragraph 172 and footnote 55 (or subsequent revision). Proposals for major development in the AONB will need to demonstrate exceptional circumstances and be assessed against the three tests in the NPPF (or subsequent revisions), including the possibility of alternatives to meet the identified need. 

NPPF para172 states 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. 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. “ Whether the development constitutes “major development” is under Footnote 55, a matter for the “decision maker”, presumably the Borough.

Development on this scale cannot conserve and enhance the landscape and scenic beauty of the High Weald AONB nor does it have regard to the character components of Matfield. Each of the proposed sites may not amount to major development in the view of the Borough but the total number of units across the four sites, in proportion to the population, represents very major development. The Borough cannot look at each site in a vacuum.

16) Traffic will be a major consideration in Matfield given the proposed additional housing in the village and the proposed developments at Paddock Wood and Tudeley/Capel. Even at the current levels of traffic, it is frankly dangerous to provide access points from three new sites, feeding the traffic serving up to 120 new houses, onto Maidstone Road in close proximity to each other. That does not take into account traffic serving up to thirty new houses being fed onto the narrow residential Chestnut Lane, already a rat run to Tonbridge. There are potentially eight access points onto Maidstone Road, including the Village Hall entrance in little more than quarter of a mile. One of these is the Standings Cross junction by The Poet, which is a very busy junction that does not have good visibility when crossing or joining Madstone Road from Chestnut Lane. The lives of residents on Maidstone Road will be intolerable.

17) It is obvious that there must be some development across the board throughout the Borough, but a fully dispersed strategy is not appropriate. Development in the villages should be targeted at those local people who need it. To that end, given that Matfield already has 23 new houses consented or being built out, any further development should be small scale and of a density that is appropriate to the character of the village, with the emphasis on two and three bedroom houses, reflecting local needs. "Best land use" should take account of best practice in all areas, including what is best in terms of character, rather than simply squeezing as much profit and capacity as possible out of a site. This principle applies across the Borough.

18) If it is absolutely necessary to build up to 150 new houses in this area, it would seem much more sustainable for the majority to be built in Paddock Wood, two and a half miles away, where the infrastructure is supposedly being created to support them and where it is expected that residents of Matfield will head for most of their basic needs. The additional number that would be built in Paddock Wood would scarcely impact on the numbers already proposed for the town. This would be a more appropriate proposal than building them at Matfield with the consequent harm to this historic village and to the AONB. The site allocations in the village should be reconsidered to ensure that any future development is of an appropriate size and density to the character of the village and its surroundings. It should be borne in mind that the proposals are completely at odds with the Borough's own Evidence Studies and with the NPPF requirement for sustainable development and with Kent Highways recommendations.

DLP_6079

John Barsley

I am writing to comment upon the TWBC Draft Local Plan.

Due to the size and complexity of the document I have not had the time to respond via your on line service.

However I am in agreement with the comments of Brenchley & Matfield Parish Council and would therefore ask that you consider my views as an independent resident to be the same as B&MPC.

[TWBC: see Brenchley and Matfield Parish Council's comments - Comment Numbers DLP_1683 - SEE SECTION 1, 1690, 1694-1696, 1698-1699, 1701-1710. The complete Brenchley and Matfield Parish Council representation is copied below for convenience]:

1. Introduction 

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

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

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

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

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

2. The Local Plan Development Strategy

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

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

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

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

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

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

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

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

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

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

3. Mitigating the Impact of Development 

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

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

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

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

4. Meeting Housing Needs

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

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

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

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

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

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

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

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

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

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

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

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

5. Development Proposals for Brenchley and Matfield

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

6. Development Management Policies

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

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

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

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

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

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

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

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

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

c. Regarding STR/BM1:

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

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

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

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

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

7. Conclusion

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

DLP_6302

Mrs Elizabeth Simpson

Section 5

The over-riding strategy for Brenchley & Matfield, is to identify 4 specific sites, all within Matfield, rather than Brenchley, for the siting of between 91-150 dwellings. Very surprisingly given that when looking at measures of sustainability of each village, carried out by TWBC themselves as part of the Issues and Options Research outcome in 2017, Brenchley was assessed as having better services and facilities more appropriate to accepting additional development. Brenchley was classified in Group B, whereas Matfield, had significantly fewer services and facilities and was classified in Group D. And since that time Matfield has lost further services and facilities: one public house, one hairdressers and one village shop are no longer operating in the village. Further on the “semi-dispersed growth” plan, Brenchley was proposed for development but not Matfield. Only on the “dispersed growth” plan did Matfield get an allocation, and even then, Brenchley also had some development allocated. Now we see a draft plan where it is all allocated to Matfield? What is the rationale for this?

From an infrastructure and transportation viewpoint, KCC Highways have already publicly stated, in commenting on a current planning application for the BM1 site, that “sites in Matfield would not be a favoured in a plan-led approach due to the lack of key facilities within the village and the resultant high dependence of residents on car borne trips”. It doesn’t appear that this unequivocal concern expressed by KCC Highways has been properly taken into account. This view should be listened to in preparing the local plan.

I object to policy STR/BM1, which requires contributions from developments at Brenchley and Matfield to mitigate the impact of the developments in Paddock Wood. A sustainable approach would be to balance improvements to facilities (such as children’s playgrounds) that are within walking distance in the smaller settlements with the provision of larger-scale facilities (such as swimming pools) within Paddock Wood. It is not clear to us why contributions from developments in Brenchley and Matfield would be diverted to the Hop Pickers’ Line, which is not even in the parish

DLP_6812

Matfield Village Hall Management Committee

Policy STR/BM 1

This policy appears not to address the long standing issue of school children being unable to walk safely from Matfield to the Primary School in Brenchley.

Section “f” = contribution for ‘The provision of information and public art along the Hop Pickers line’ will do nothing to mitigate the impact of any development in Matfield. The Hop Pickers line is not even in the Parish!

DLP_7011

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.

Representation repeated under Table 3 Box below.

DLP_7021

Sheena Colville

I am in total agreement with the Parish Council's response to T.W.B.C Draft Local Plan. The Council has been thorough and fully addressed the concerns of the Brenchley & Matfield residents. I would like to re-iterate some of the concerns:-

Paragraph 2 - The Local Plan Development Strategy.

Attention is drawn to paragraphs 102 + 103 of the N.P.P.F (Feb 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 + public transport. Also paragraphs 171 and 172 which seek to conserve + enhance Areas of Outstanding Natural Beauty by limiting the scale + extent of development within such designated areas.

N.B. 77% of the parish is within the High Weald A.O.N.B. I agree with the Parish Council that the D.L.P. directs growth to the rural settlements with limited facilities + jobs, and with poor access to public transport. The proposed sites all come out onto or 'verge' into the already busy Maidstone Road. These villages also cannot sustain this development and do not have the social, economic + environmental infrastructure needed to support it. This policy of dispersed growth would cause irreversible loss of the character, identity + communal well being of our villages.

Paragraph 5J (in the Parish Response) also lists valid points put forward by Matfield residents widespread concern about the development proposals for Matfield. These are based on inappropriateness of the proposed sites in terms of location and scale. Also the unsuitability in the absence of services + facilities. Residents (including myself) are aware of the adverse impact on wildlife + habitats + the harm to the landscapes, views etc., also in A.O.N.B designation + Conservation Area Status. There are references to the impact of noise + light pollution and above all the devastating impact of increased traffic. Residents are concerned that development will take place without updating the physical infrastructure - congestion at Kippings Cross, traffic calming measures on B2160, realignment of the A228 etc. We are trying to highlight the pressures on public transport, water supply, sewage capacity, broadband coverage, + post office services. Affordable Housing is important for locals and I would like to see more buildings for the elderly (in our 'top heavy society'!) eg. warden assisted flats etc on the developers' plans.

DLP_7149

Patricia Stevens

Policy Number: STR/BM1 (AL/BM1, AL/BM2, AL/BM3, AL/BM4)

The development proposed for Matfield is out of all proportion to the present size and character of the village, and should not take place. Moreover, the Plan does not include the Rydon Homes development already underway.

Matfield is in the High Weald Area of Outstanding Natural Beauty, and the sites are all on undeveloped land. The Council has a statutory duty to conserve and enhance the natural beauty of the High Weald AONB and the National Planning Policy Framework states that great weight should be given to conserving AONBs. The LDP does not do this.

Furthermore, it is quite wrong for the Limits to Built Development to have been changed to accommodate these sites, as the Limits should protect the village from intrusive development and prevent the sprawl of the village into surrounding countryside.

There is an increasing need to preserve the countryside and open spaces to mitigate climate change, rural areas being a vital resource for carbon sequestration, and to promote people’s health and well-being. Instead, housing development on brownfield or infill sites, and re-using empty buildings should be reconsidered.

The proposed development is economically, socially and environmentally unsustainable. Matfield has limited infrastructure, services and amenities. It has no school or playground and no GP or Dentists surgery. Employment opportunities are limited. Public transport is limited and there are no safe walking routes from Matfield to either Brenchley Primary School or to Mascalls Academy in Paddock Wood. Together, these factors mean that the proposed housing development could only increase car use, with the resultant adverse effects of noise and air pollution as well as danger to the public and wildlife.

I live on Gedges Hill (on the B2160), and experience its traffic problems daily, I am particularly concerned about the impact this development would have on the road network, traffic volume and highway safety. The B2160 already has a high volume of traffic, especially at key times in the mornings and evenings. On Gedges Hill there is no pavement and often no space for pedestrians at either side of the road. There is a too high 50 mph speed limit, despite houses on both sides of the road and dangerous bends. Thus, it is too dangerous for pedestrians, especially for children from Matfield to walk to and from school in Paddock Wood.

The enormous housing development planned for Paddock Wood can only mean a further increase in traffic – from Matfield and Brenchley down to Paddock Wood’s secondary school, mainline station, shops and services, and up from Paddock Wood through Matfield to the A21 and the South Coast. Consequently, these housing developments already approved and underway will increasingly have an adverse impact on traffic volume, highway safety, and air and noise pollution.

The proposed development is economically, socially and environmentally unsustainable. Matfield has limited infrastructure, services and amenities. It has no school or playground and no GP or Dentists surgery. Employment opportunities are limited. Public transport is limited and there are no safe walking routes from Matfield to either Brenchley Primary School or to Mascalls Academy in Paddock Wood. Together, these factors mean that the proposed housing development could only increase car use, with the resultant adverse effects of noise and air pollution as well as danger to the public and wildlife.

I live on Gedges Hill (on the B2160), and experience its traffic problems daily, I am particularly concerned about the impact this development would have on the road network, traffic volume and highway safety. The B2160 already has a high volume of traffic, especially at key times in the mornings and evenings. On Gedges Hill there is no pavement and often no space for pedestrians at either side of the road. There is a too high 50 mph speed limit, despite houses on both sides of the road and dangerous bends. Thus, it is too dangerous for pedestrians, especially for children from Matfield to walk to and from school in Paddock Wood.

The enormous housing development planned for Paddock Wood can only mean a further increase in traffic – from Matfield and Brenchley down to Paddock Wood’s secondary school, mainline station, shops and services, and up from Paddock Wood through Matfield to the A21 and the South Coast. Consequently, these housing developments already approved and underway will increasingly have an adverse impact on traffic volume, highway safety, and air and noise pollution.

DLP_7489

Angela and Ian McEwen

Object

1. As we live in Matfield, we will restrict our comments to those aspects of the draft document which affect this village which is earmarked for all of the development proposed for the Parish of Brenchley and Matfield. In summary, we object to the strategy for Brenchley and Matfield on the following grounds which are elaborated in the paragraphs below:
   • the Local Plan proposals for the village seem to have been made without any evidential backing for the overall size of the developments (in comparison with that for the Borough as a whole);
   • they appear to take no account of the Borough’s own assessment of sustainability in the Settlement Role and Function Study;
   • they ignore inevitable road congestion issues along the B2160;
   • they do not comply with Policy EN2 with regard to public transport facilities;
   • they do not accord with Policy EN21(or related aspects of  the NPPF and High Weald AONB Management Plan) and will not conserve and enhance the AONB;
   • they do not comply with Policy EN11 on the requirement for long-term gains in biodiversity; and
   • there is no objective assessment of the need for up to 150 new houses in Matfield which is disproportionate to the percentage increase envisaged across the Borough as a whole.

   Sustainability 

   The Draft Local Plan seems to take no account of relative sustainability as set out in the Settlement Role and Function Study.

2. In the 2017 Settlement Role and Function Study, the Council set out a hierarchy of settlements from a sustainability perspective. This was also reflected in the Issues and Options document later that year.  Matfield was placed in the second lowest category (D) and two categories below Brenchley because it has no school, doctor, dentist or children’s play area. In both villages, the bus service is infrequent.  At the time of the Study, Matfield was said to have three public houses and several shops. Now, the village has one pub (plus a former pub which is now a restaurant) and one shop (a butcher’s).  It is not feasible to walk from Matfield to Brenchley to access education and health facilities.
3. There is no indication in the Draft Local Plan that the Council has taken any account of this settlement grouping in the proposed allocation of development sites. Despite its ranking in the second highest category, Brenchley has no allocated sites while Matfield, although in Category D, has more sites than any other village in categories B to E, apart from Horsmonden.

   Transport Infrastructure 

   The Draft Local Plan appears to take no account of significantly increased congestion on the B2160 which runs through Matfield to Kippings Cross and minimises the implications of inadequate public transport through the village which do not accord with proposed policy EN2. 

4. The Draft Local Plan emphasises the importance of improvements in road infrastructure and public transport services. However TWBC is not in a position to deliver such improvements.  The final version of the Plan should make it clear that, if essential transport improvements cannot be made, development will not be allowed to go ahead.
5. With regard to the B2160 through Matfield, the draft does not even suggest that any improvements in the road network are necessary. The Council acknowledges that road improvements will be required to the west of Paddock Wood and on the A228 to take account of the large amount of housing proposed in Paddock Wood, Capel and Tudeley. However, it is disingenuous to envisage that none of the extra traffic generated by several thousand new houses in Paddock Wood, plus the increase of one third in the number of households in Matfield will not seek to travel to the A21 via the B2160.  That road is already busy.  A KCC traffic survey in Matfield in 2015 showed that there were about 22,000 vehicles travelling in each direction per week. Since the A21 was dualled between Tonbridge and Kippings Cross, queues along the B2160 to get onto the roundabout at Kippings Cross can stretch back to Matfield Church at busy times (a distance of nearly 1 mile). An increase of one third in the number of Matfield households and the huge developments in Paddock Wood are likely to cause gridlock in that area without some mitigating action.  However, according to the Local Plan no such action is planned and any further work to alleviate the bottleneck by dualling the A21 beyond Kippings Cross is no more than “a long term Highways England proposal” (paragraph 6.539).
6. With regard to public transport, the Draft Local Plan states in Policy EN2 that it should prioritise development “in locations with frequent and easily accessible public transport services that provide useful links to key facilities such as GP surgeries, train stations, shopping areas, and schools” and “in locations that encourage active travel, such as walking and/or cycling, to key facilities”.  Neither of these criteria exists in Matfield.  Bus services to Brenchley (GPs and dentists) and Paddock Wood (train and shopping) are every 1 to 1½ hours; and, although school buses are available for travel to Paddock Wood, school transport is not available for the educational facilties in Brenchley.  Walking to Brenchley or Paddock Wood is not feasible and cycling is not safe on busy, relatively narrow and winding roads without any cycle lanes.
7. The strategy for the proposed development sites in Matfield (Policy STR/BM1) contains neither a commitment nor even any reference to the improvement of public transport links. Policies for the individual site allocations contain a rather general reference to developer contributions “if necessary” towards improvements in bus services. This falls far short of any attempt to meet the requirements of Policy EN2.

   Village Character, AONB Aspects and Biodiversity 

   The proposed developments in Matfield will adversely affect the character of a small rural village within the AONB, in contravention of proposed policy EN21, the National Planning Policy Framework, the High Weald AONB Management Plan and the associated High Weald AONB Design Guidance. It will also contravene policy EN11 on the requirement for gains in biodiversity. 

8. Policy EN21 in the Draft Local Plan states that “All development within, or affecting the setting of, the High Weald AONB shall seek to conserve and enhance its landscape and scenic beauty, having particular regard to the impacts on its character components, as set out in the High Weald AONB Management Plan”. The National Planning Policy Framework states 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”
9. The construction of up to 150 houses on the edges of this small, traditional Kentish village will not conserve and enhance the AONB and will fundamentally change its character.
10. Objective S3 of the High Weald Management Plan attaches importance to compliance with the High Weald AONB Design Guidance.  The final consultation version of this guidance advises that, in order for development to reflect and enhance the character of the High Weald, it must be designed to integrate into its setting. It states (Section DG1) that “this means more than reflecting merely the visual appearance of the current setting, but includes understanding how landscapes and settlements work and have evolved and why the area is the way it is today”.  Like many other AONB villages, Matfield developed in a loose, largely linear pattern, centred around the village green and radiating along the roads which feed into the settlement.  The AONB Design Guidance states that settlements in the High Weald are typically highly permeable in layout, as is the case in Matfield.  It advises that “to maintain this characteristic, it is important for new development to sit successfully as an integrated piece of village that people can walk and travel through, rather than a separate ‘estate’  that they travel into.  Dead-ends are uncommon and not in keeping with the historic character. Dead-ends / cul-de-sac arrangements are therefore to be avoided in the design of new developments.”

11. All of the proposed developments in Matfield are housing estates with only one vehicular way in and out. They are to be built at a significantly higher density than is the case in the traditional village.  BM1 and BM4 are placed at the main north and south ends of the village and will have an adverse visual impact on the entrances to Matfield.  (There is an already approved development of 20 homes across the road from the BM4 site so up to 45 homes there will make matters even worse). Although the Draft Local Plan states that BM4 housing should be largely screened by existing trees and hedging, the site sits on an inward facing bend so, apart from the gap required by an entrance road, a significant amount of the existing screening will have to be removed to allow a sufficient visibility splay for safe exit from the site.  Development in these sites does not accord with paragraph 6.197 of the draft Plan which emphasises the importance of preserving landscape approaches at the entrance to towns and villages.
12. Both BM1 and BM4 are immediately adjacent to the Matfield Conservation area and their visual effect is likely to impact adversely on that conservation area. In addition, the site at BM3, though less visible from the main road, will encroach upon the AONB countryside and fruit orchards, will be very visible from the public footpath running through that countryside and will abut rather closely on some ancient woodland.
13. The National Planning Policy Framework also states that the conservation and enhancement of wildlife are important considerations in the AONB. Policy EN11 in the Draft Local Plan states that development will only be allowed where “it can demonstrate … that completion of the development will result in a measurable long term net gain for biodiversity.”
14. All four of the proposed development sites in Matfield are currently agricultural land on the edges of the village and support a variety of wildlife, some of which is protected. An ecological survey of site BM4 has found dormice, for example. Site BM4, in particular, has not been farmed actively for many years and is likely to support a number of wildlife species. Intensive housing development in Matfield, as proposed in the Draft Local Plan, will lead to a loss of wildlife habitats and cannot lead to any gains in biodiversity as required by policy EN11.

    Housing Needs and Growth

    Despite its rural nature and lack of facilities and services (see ‘Sustainability’ above), the development proposed in Matfield is disproportionately large compared with the Borough as a whole, yet no evidence is presented for why this should be. 

15. The various housing needs/demands papers supporting the Draft Local Plan make no mention of projections, requirements or housing need specifically affecting Matfield. There are some references to Brenchley Parish which is said to contain 1,150 dwellings (Housing Needs Study, Table 4.1).  However, the Parish includes Brenchley, Petteridge and Castle Hill as well as a number of rural houses. Matfield itself only has about 450 dwellings.  Since there is no proposed Local Plan development in the Parish outside the village of Matfield, it is the figure of 450 houses rather than the wider Parish figure of 1,150 which provides a meaningful baseline for any consideration of future growth.
16. The Housing Needs Study states that the total number of households in the Borough will increase by 15.5% by 2033 (paragraph 7.11) and that the over-65 population of the Borough will rise by 40.7% over the Plan period (paragraph 7.10). The proposed maximum development of 150 houses in Matfield over the same period would mean that the village would increase in size by approximately 33% - over twice that in the Borough as a whole - while being relatively unsuitable for older people because of the infrequency of local transport and the absence of shops and services.
17. The Draft Local Plan offers no evidence in favour of such a disproportionate increase in the number of houses in Matfield in comparison with the Borough as a whole, particularly given the village’s unsuitability for significant development given the other points put forward in these comments.

DLP_7615

Jonathan Hayes

Apologies but I am not a policy expert and feel qualified to comment in depth regarding specific policies and related subsections, as such I fully support that findings and comments of Matfield and Brenchly Parish Council and Matfield’s Future regarding specific policies. I would however like to (re-raise) some specific concerns regarding the intended development/destruction of Matfield (although labelled Matfield and Brenchley within the TWBC documentation)

The TWBC Settlement Role and Function Study of 2017 stated that Matfield is one of the least sustainable settlements in the borough, this was also supported by Kent County Council.

I reject the idea that Matfield could support  91 to 150 new houses, as this idea seems completely unjustified and contrary to previous sustainability reports. The proposed population growth of 37.5% would be contrary to the sustainability criteria set out in the NPPF (Paragraphs 7&8) given that it lacs basic infrastructure, which it should be noted is on a negative trajectory given the recent application to convert the Wheelwright’s Arm into 3 residential properties, which would result in the potential loss of 3 local businesses (given the use of the parking area for a Pizza and Fish and Chip Van).

I note that the allocation of for Matfield and Brenchley appears to be satisfied through sites entirely within Matfield – whilst I understand that this is partially due to the sites volunteered through the recent and ongoing call for sites, I would hope and therefore suggest that any assessment of sustainability and local resources to support the new allocation of houses should primarily consider the infastuture of Matfield (as a sole entity).

I am also disappointed to note that the draft plan does not include within Matfield and Brenchley’s allocation the Rydon Homes development – It was previously advised that this allocation of circa 27 homes would contribute towards the M&B quota.

It appears that the allocated sites have been choosen based soley on the numbers they would contribute towards the overall allocation – whilst obviously significant I would urge the council to consider how these proposed areas would fundanmentally alter the fabric of a much loved village, moving from a linear, ribbon based development to a cluster structure, with a large number of developments a significant distance from the required infrastructure.

I note that within the local plan it states that TWBC are unable to further develop TW given the constraints of the AONB and Green belt (as assertation that I do not necessarily contest), however the DLP appears to want to tred roughshod over the constraints within Matfield, I can only speculate that TWBC are more concerned with the feelings of the voters within the Towns than the unprotected minority of the villages – out of sight and very much out of mind. The proposcal advocates a significant increase of Matfield’s LBD based on a need to accommodate an additional 4 sites – which is ironic given the purpose of the LBD. It is so disappointing that something designed to protect village expansion, within an AONB can be so easily removed.

I object to the proposal to increase the extension of the LBD to accommodate sites BM1, BM2 and BM3. The Parish council advise that the LBD would increase from 17.44 hectares to 27.03 hectares in Matfield, an increase that would be at odds with the policy objective to protect and enhance the AONB.

Site BM1, which is already the subject of a planning application to build 45 homes, is a key site at the gateway of Matfield village and forms part of the High Weald AONB; major development here would not conserve or enhance the AONB. The Parish council advise that the site also forms part of the “Matfield and Brenchley Fruit Belt”, with high-quality Grade 2 agricultural land, as identified in the Landscape Character Assessment SPD 2017, and incorporated within the Environment and Design policies EN20, EN21 and EN22. Collectively these policies state that such sites should be protected from development, to “conserve and enhance the essentially rural, working agricultural character of this area”. The introduction of a development would fundamentally alter the character of the village and destroy a vista that is so fundamental to tourism and visitors to the village (former Village of the Year).

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

DLP_7793

Mr and Mrs T Hollings

Could you please ensure that the following is included with the above submission.

Unfortunately I was unable to get sight of the document prior to its submission, meeting change dates by the Parish Council.

Having now read the document in full I have become aware of a mistake in one area that has slipped through, particularly the latter part of the second sentence section 5 As shown below.

‘Section 5 Development proposals for Brenchley and Matfield paragraph e. Second sentence ‘The Council also rejects the extension of the LDB at Market Heath and around the former Corsica Nursery in Matfield, for which there does not appear to be any justification’

The TWBC document ‘ LDB Topic paperwork draft local plan regulation 18 consultation August 2019’

This document outlines the methodology and criteria for the establishment of LDB

Minor extension of of the LDB at Corsica Nursery is specifically justified Items 1 to 7 then item 25 and 25.1

Of note para 7 Boundary review

7.1 a. To ensure that LDB boundaries are logical and reflect what is on the ground

The said buildings and sheds have been in existence for over fifty years!

I should also like to point out that no one from the Parish Council has visited Corsica Nursery or at any time contacted myself in this regard.

DLP_8184

Highways England

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

DLP_8255

Brenchley War Memorial Hall and Recreation Ground Charity

Policy STR/BM 1 states that developer contributions should be used for the provision of allotments, amenity/green spaces, parks and recreation grounds, children’s play space and youth play space.  The policy highlights the need for play spaces and a new children’s playground in Matfield.  To create sustainable housing developments, the provision of on-site play facilities and a contribution towards a children’s playground in the Matfield should be a priority.  In most of the parish bus services are non-existent, cycling on busy roads populated by large numbers of HGVs is hazardous and there are no pavements to enable pedestrian access to Paddock Wood.  A new sports hub in Paddock Wood will not be easily accessible to residents in Brenchley and Matfield and TWBC should ensure that developer contributions prioritise much-needed facilities within the parish.

[TWBC: see full representation].

DLP_8299

NHS West Clinical Commissioning Group

General Observation

Howell Surgery provides the main general medical service provision to this area; the practice has premises located in Brenchley (main surgery) and Horsmonden (branch surgery). The existing premises do not have capacity to accommodate the estimated growth of c 1100 registered patients within the area (Brenchley, Matfield and Horsmonden). The CCG is strategically assessing, with general practice, how capacity may be provided in the future. Please also see response to Policy STR/HO 1.

DLP_417

Rona Hogan

Object

Comments on Map 75 Policy

Please see my comments already sent in specific to this development in AONB land as planning permission as already been submitted. It is too large and out of character with the rest of the village and will lead to cars being parked around the Island site on Maidstone Road. It is suburbanisation of Matfield and will have a detrimental effect on the rural character, AONB should be protected and will have a detrimental impact on services such as doctors in Brenchley which have no additional capacity - Matfield has no services to support large development as shown in the Local Plan. I object to this development strongly.

Final comment

TW Council is using rural villages including Matfield to dump their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the borough on brownfield sites (which the plan does not detail what has been reviewed) or placing small developments directly off of the A21 avoiding congestion in the small villages which will be unable to cope. The expected contributions will not mitigate the impact of the 4 developments proposed on Matfield, as the doctors in Brenchley have stated they cannot cope with any more patients and the landscape and rural feel of Matfield will be lost for future generations.

DLP_645

Janet Mitchell

Object

The housing proposed - 150 - is mainly located near Chestnut Lane and its surrounds and fails to include the 22 houses already under construction next to the Poet pub; thus bringing the total number of houses to 172. This is a significant omission from the Map on page 7 of the Plan which shows no construction opposite the Coppers Lane/Brenchley site. There will be, in fact 67 houses alongside the busy Maidstone Road from the top of Gedges Hill on the approach to the village, thus destroying the 'dark skies' and various environmental features in that part of the village which Tunbridge Wells has a duty to protect.

At the exhibition of the Draft Plan at Horsmonden Village Hall on 1st October there was mentioned the possibility of a parallel road being built along the busy Colts Road. This road has already generated a 'rat run' into Chestnut Lane and the surrounding roads as motorists try to avoid the daily disruption at Kippings Cross. The plan to build extra houses on the Matfield House orchards site with 'vehicular access' onto Chesnut Lane would only lead to greater congestion in this area and increase the possibility of accidents.

It is well understood that a number of new houses have to be provided, but there are other considerations to be taken into account, not least, the water supply, sewer capacity etc. A series of smaller developments spread between the two parishes should surely be considered?

DLP_948

Mrs Karen Stevenson

Object

Policy AL/BM 1 –Land between Brenchley Road, Coppers Lane and Maidstone Road (Island site). Allocated for a mixed-use scheme including approximately 30-45 (C3) residential dwellings, allotments and play space. Single point of vehicle access could be via Maidstone Road or Brenchley Road. Proposals are to include a crossing point opposite site AL/BM 2, provision of a children’s playground on the northern part of the site and provision of allotments in south west corner, adjacent to existing allotments, including off-street parking for this use.

This site falls wholly within the AONB, and wholly outside the existing LBD. It is a significant piece of land very prominent when viewed from B2160 Maidstone Road, a significant visual amenity when approaching to the village from Paddock Wood to the North. The proposed access is off the main through the village, which is already at significant risk of becoming much busier if the Paddock Wood proposals come to fruition.

Development of this very high profile site would be totally contrary to the High Weald AONB management strategy.

DLP_1698

Brenchley and Matfield Parish Council

Object

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

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

[TWBC: part of whole comment number DLP_1683 - SEE SECTION 1].

DLP_1767

Mr Paul Spedding

Object

AL/BM1 - Land between Coppers Lane, Maidstone Road and Brenchley Road

This part of the parish is in the AONB. It also retains the typical housing layout in the AONB - ribbon developments along roads and lanes, one of the few parts of Matfield, apart from the Green, that does so. The proposed development is a typical cul-de-sac and so is totally against the current character of the immediate areas. The site can hardly be considered sustainable given its scale. Public transport in the area is infrequent and there are no safe cycle routes to either Paddock Wood (school/shopping) or Brenchley (doctors/village hall/school). The bulk of new journeys will therefore be by private car. I see nothing in this policy that meets the "exceptional" criteria that developments with AONBs should meet apart from TWBC needing to meet arbitrary government targets.

The site also has wide-ranging views from the Maidstone Road as far as the ridge above Petteridge. These will be damaged and there appears to be no attempt by the developers to mitigate this damage.

DLP_2101

Terry Everest

Object

Object

A reduction of the scale and number of develppments is called for here to better fit with the current village setting.

DLP_2637

DHA Planning for Fernham Homes

1 Introduction

1.1 Purpose of this report

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

1.1.2 Fernham control land located between Maidstone Road, Brenchley Road and Coppers Lane, Matfield and has a live planning application pending for the site. Furthermore, the site is identified for potential development within the emerging Local Plan.

1.1.3 Based on the current national and local planning context, we consider the site to be suitable for formal allocation and we consider there to be the ‘exceptional circumstances’ to allow development within the High Weald Area of Outstanding Natural Beauty (‘AONB’). Give this context, this representation responds to the content of the draft plan (and relevant supporting documents), reinforces why the site remains suitable and outlines how development could be delivered.

1.2 About Fernham Homes

1.2.1 Fernham Homes are a Kent based developer, with headquarters in nearby Tonbridge and a workforce predominantly from the local area.

1.2.2 Each Fernham Home is built to the highest standards with meticulous craftsmanship and combines the latest in product design and technology with a 10 year NHBC warranty.

1.2.3 The company directors are committed to respecting the environment, seamlessly blending each home with the surrounding area. The design ethos is to provide landscape led schemes that retain and enhance existing landscaping and boundary treatments, whilst providing small to large size family homes of a range of tenures for which there is the greatest need.

2 The Tunbridge Wells Draft Local Plan

2.1 Overview

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

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

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

• Vision and Strategic Objectives;
• Development Strategy and Strategic Policies; and
• Place Shaping Policies for the Parish of Matfield.

2.2 Vision and Strategic Objectives

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

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

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

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

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

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

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

2.3 Development Strategy and Strategic Policies (Policy STR1)

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

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

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

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

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

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

2.3.7 We support the general principle of proportionately spreading the benefits of growth. 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 the basis that there would be a number of house builders involved the construction of different parts/phases. However, by their own admission, TWBC do not currently know how many housebuilders will be involved.

2.3.12 Taking the above into account, our view is that the Council have applied 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 sustainable settlements such as Matfield and to reduce the reliance upon Tudeley within this current plan period.

2.4 Place Shaping Policies

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

Brenchley and Matfield

2.4.2 Policy STR/BM1 sets the proposed strategy for Brenchley and Matfield and states that Approximately 91-150 new dwellings will be delivered on four sites, including Fernham’s land AL/BM 1.

2.4.3 Policy AL/BM 1 states that the land is allocated for a mixed use scheme, including approximately 30-45 dwellings, allotments and play space.

2.4.4 Development on the site shall accord with the following requirements:

1. A single point of vehicular access onto Maidstone Road or Brenchley Road (not Coppers Lane) to be informed by a landscape and visual impact assessment and highway assessment; the highway assessment to include consideration of crossing points and impact of development on surrounding junctions, including the junction of Coppers Lane with Brenchley Road (see criterion 3 of Policy EN 1: Design and other development management criteria, Policy EN 20: Rural Landscape, and Policy TP 1: Transport Assessments, Travel Plans and Mitigation);
2. Pedestrian access onto Maidstone Road required to link with existing footway along south eastern side of Maidstone Road, to include crossing point opposite site AL/BM 3 (Land fronting Maidstone Road and Chestnut Lane; land north east of Maidstone Road), and renewal of existing footway;
3. Provision of pedestrian link through site from Coppers Lane to provide a desire line through site;
4. A landscape and visual impact assessment and heritage assessment to inform site access and site layout, and to maintain the setting of the settlement, including views from and through the site to countryside beyond, including from Maidstone Road (see criteria 1 and 3 of Policy EN 1: Design and other development management criteria, Policy EN 20: Rural Landscape, and Policy EN 7: Heritage Assets);
5. Contributions towards an assessment of traffic along the surrounding roads to inform a scheme of potential traffic calming measures and contributions towards these measures;
6. Opportunities to be explored for providing approximately 12 parking spaces to serve existing dwellings on Brenchley Road;
7. Relocation of the 30mph speed limit northwards to Invicta Oast on Maidstone Road, installation of speed sign with number plate recognition facility, and associated gateway features;
8. Regard shall be given to existing hedgerows and mature trees on site, with the layout and design of the development protecting those of most amenity value, as informed by an arboricultural survey and landscape and visual impact assessment (see Policy EN 14: Trees, Woodlands, Hedges, and Development and criterion 3 of Policy EN 1: Design and other development management criteria);
9. Provision of on-site amenity/natural green space, improvements to parks and recreation grounds, and youth play space in accordance with the requirements of Policy OSSR 2: Provision of publicly accessible open space and recreation;
10. Provision of children's play space in northern part of site to include fully equipped and funded children's playground;
11. Provision of allotments in south west corner adjacent to existing allotments, including provision of off-street parking for this use.
12. It is expected that contributions will be required towards the following if necessary, to mitigate the impact of the development:
13. a. Highway related works including traffic calming in the settlements;
14. b. Improvements to bus service provision;
15. c. BT fibre upgrade and mobile reception upgrade (see criterion 10 of Policy EN 1: Design and other development management criteria) and Policy ED 3: Digital Communications and fibre to the premises).

2.4.5 Having regard to these draft requirements, our client supports the general thrust of what is required, which largely reflects the current planning application reference 19/01099/OUT.

2.4.6 For the avoidance of doubt, access design is included in detail. It is proposed that a new access will be created along the north western boundary of the site, approximately 140m to the south west of the junction between Coppers Lane and Maidstone Road. The internal access road will initially measure 5.5m in width, with the access junction provided with 6m radii, with over-runnable strip in the left-hand lane, facilitating larger vehicle movements.

2.4.7 During pre – application scoping, it was also suggested by KCC H&T that a number of off – site mitigation strategies be considered.

2.4.8 Subject to the agreement of the highway authority, it is proposed that the existing verge extending in either direction away from the development is used to increase the width of the existing footway to 1.8m. To the north – east of the site access, this footway will extend for approximately 45m along the southern side of the B2160 Maidstone Road. A dropped kerb crossing is then proposed at this point, to link in to the existing footway to the north of the B2160 Maidstone Road.

2.4.9 The 1.8m wide footway also extends to the south west of the site access towards Matfield village centre as far as the B2160 Maidstone Road / Brenchley Road / Chestnut Lane junction.

2.4.10 The current 30mph speed limit zone begins approximately 30m to the south west of the site access (heading southbound), with a 50mph speed limit in place in the vicinity of the site access and along much of the proposal site’s frontage heading north towards Paddock Wood. It is proposed to extend to the 30mph speed limit by approximately 100m in the northbound direction, up to approximately 70m to the north east of the proposed site access. It is noted that the site access has been designed irrespective of this, with the required visibility splays calculated using current measured speeds.

2.4.11 The pending application is accompanied by a detailed heritage assessment. In summary, there are a small number of listed buildings that are located in the vicinity of the site. These include:

(A) Thorn Cottages

(B) Standings Cross

(C) Thorn House

(D) Acer Cottage

(E) Whitethorn Cottage

(F) Whitethorn Cottages

(G) Homebush Cottage

(H) Homebush

[TWBC: to view map/plan please see page 10 of  full response].

2.4.12 From a wider perspective, the site is located outside of the Conservation Area and historic core of the village.

2.4.13 The heritage assessment has identified that the proposed development has the potential to result in a highly limited level of harm to the significance of Thorn Cottages, Whitethorn Cottage and Whitethorn Cottages. The highly limited level of harm stems from the slight reduction in the rural surroundings of the buildings. In NPPF terms this low level of harm is considered to fall within the lowest realms of less than substantial harm with Whitethorn Cottage and Whitethorn Cottages slightly less affected than Thorn Cottages.

2.4.14 Overall, the significance of the conservation area would be preserved as a result of the proposed development.

2.4.15 From an ecology and tree perspective, a Preliminary Ecological Appraisal was undertaken in November 2018 by Corylus Ecology. The initial PEA findings are summarised below.

(a) Three hedgerows along the boundaries have been assessed as species-rich and meet criteria for the important hedgerow assessment. The proposals have considered the presence of the important hedgerows and so the hedgerows are retained with a wide buffer between the features and development;

(b) The hedgerows around the boundaries of the Site support suitable dormice habitat. Presence / likely absence surveys have been recommended and are being undertaken the early findings of which were provided;

(c) Suitable reptile habitat has been identified along the boundaries of the Site and presence / likely absence surveys have been recommended;

(d) One tree has been assigned ‘Low’ potential to support a bat roost under the BCT guidelines (Collins 2016). Further surveys to ascertain the presence / likely absence of a bat roost were only recommended if this tree is to be directly or indirectly affected by the proposal, which it is not.

(e) The Site has been assessed to support Low quality habitat for foraging and commuting bats however as the areas of highest quality are the boundary features which will be retained, no surveys in relation to bat activity have been recommended.

(f) The Site supports suitable terrestrial habitat for great crested newt and therefore Habitat Suitability Index Assessments of two offsite ponds at 77m and 124m to the north-east are undertaken and further surveys are being carried out to determine presence / likely absence.

(g) A pre-commencement check of the Site for badger field signs is recommended immediately prior to works commencing.

(h) The Site supports suitable breeding bird habitat. It has been recommended that any clearance of vegetation is undertaken outside of the core bird breeding season 1st March to 1st August or checked prior to clearance.

(i) Recommendations under the National Planning Policy Framework for enhancing the ecological value of the proposed Site have been provided and these include installation of bird boxes, generous native planting and measures to enhance the Site for hedgerows.

2.4.16 As set out above, the following protected species surveys were recommended in the ‘Preliminary Ecological Appraisal:

(a) Reptile presence/likely absence surveys

(b) Great crested newt (GCN) Habitat Suitability Index (HSI) assessments and, for suitable ponds,

(c) GCN presence/absence surveys

(d) Dormouse presence/likely absence surveys

2.4.17 These reports were subsequently commissioned in full and are either complete or in progress and have been reported in detail.

2.4.18 The protected species report also confirms that the proposals result in an increase in the number of biodiversity units in line with the Defra Metric.

2.4.19 In respect or arboricultural matters, the focus of the application has been to preserve existing tree coverage and provide additional tree planting as part of the wider landscape and ecology strategy. This includes retention of the hedgerows and an adequate landscape buffer.

2.4.20 Landscape Collective have been instructed by Fernham Homes to carry out a tree survey in accordance with BS: 5837:2012. In total 19 items were surveyed. 1 surveyed item was considered to be good quality, 5 survey items were considered to be moderate quality and 13 surveyed items were considered to be low quality.

2.4.21 The prominent trees within and around the site are primarily oak. These are of variable quality.

2.4.22 Most of the trees within the site are of important landscape value as they are visible from many of the residential properties around the site and the adjacent roads.

2.4.23 Future management must include careful monitoring of the health of the retained trees within the site, so as to maximise the aesthetic and wildlife value of the tree resource.

2.4.24 Although some of the hedgerows are well-managed other parts of the hedgerow resource are very undermanaged and need strengthening/infilling in places.

2.4.25 The above findings have subsequently informed core decisions that focus on maintaining the existing tree coverage. All trees will be protected by the proposed landscape buffer.

2.4.26 Having regard to the above, we support the proposed allocation and consider a significant degree of evidence has been provided as part of the ongoing planning application to demonstrate that it is deliverable. However, we do have concerns in respect of the criterion seeking new allotment provision, when the existing adjacent provision is not fully utilised or occupied and as such would wish to see the evidence base that underpins this request.

2.4.27 Furthermore, whilst Fernham would have no objection in principle to the provision of an equipped play area, the plan as drafted is silent as to whether and in what capacity the borough Council or Parish Council would adopt the long term management of the facility. In this regard, it would be unsound to expect the future residents to bare the ongoing costs of a village wide play facility or for the developer to do so in perpetuity.

Summary

2.4.28 Taking all of the above into account, we support the principle of the proposed allocation. However, consider that it would be advantageous for the Council to look at more simplified allocation policies that seek to secure the quantum of development and essential infrastructure requirements. For more aspirational elements, such as allotment provision or play space, these elements should be written into wider design guidance so that the policies are not overly prescriptive and remain deliverable.

2.5 Exceptional Circumstances

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

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

(1) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;

(2) the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and

(3) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.

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

2.5.4 We set out below why we consider exceptional circumstances exist for the allocation of this site within the AONB.

2.6 The need for the development

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

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

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

2.7 The cost of, and scope for, developing elsewhere

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

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

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

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

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

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

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

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

In summary, we support the Council’s conclusions that exceptional circumstances exist to justify the allocation of sustainable AONB land.

3 Section 6: Development Management Policies

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

3.1.19 Finally, we note that paragraph 6.160 states:

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

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

“For ancient woodlands, you should have a buffer zone of at least 15 metres to avoid root damage. Where assessment shows other impacts are likely to extend beyond this distance, you’re likely to need a larger buffer zone.” [1]

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

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

4 Conclusion

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

4.1.2 In this respect, we support the aspiration to meet housing need in full and consider that a dispersed growth strategy represents the optimum means to achieve this. Furthermore, we support the inclusion of our client’s site in Matfield.

4.1.3 It is important that such sites are retained within the Regulation 19 draft as we consider that the Local Plan strategy relies too heavily on the delivery of strategic sites that would require the provision of supporting infrastructure. Moreover, the Council have applied overly optimistic projections to the delivery of housing for the extension of Paddock Wood and the Tudeley Garden Village, largely disregarding the NLP 2016 report and the time it would take to masterplan the strategic sites and deliver the required infrastructure.

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

DLP_3332

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy. The following changes are requested:

Paragraph 2 - Improved pedestrian access to include works at junction of Maidstone Rd/Brenchley Rd and Chestnut Lane and along Maidstone Rd and also to include crossing points

Points 5, 6 and 7 should be removed. The Transport Assessment will highlight specific mitigation measures: should not be pre-empted at this stage.

The standard paragraph regarding contributions should feature in this policy - It is expected that mitigation measures will be implemented by the developer. A contribution may be taken if appropriate

Heritage Conservation

Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval.

DLP_3460

High Weald AONB Unit

Object

The proposal is major development in the AONB which has not been adequately justified under paragraph 172 of the NPPF. It will result in significant harm to the High Weald AONB in the following ways:

* the loss of connection between the dispersed development in the area and its surrounding countryside contrary to objective S1 of the High Weald AONB Management Plan;

* the loss of the historic settlement pattern and character of this area as a separate entity to the main village of Matfield contrary to objective S2 of the Management Plan; and

* the development is of an excessive scale out of proportion to the size and character of Matfield contrary to objective S3 of the Management Plan.

DLP_3850

Natural England

Object

Development of this site is considered to be major development within the AONB. Natural England advises that AONBs should not be considered as suitable locations for major development. All allocations for major development within the AONB need to be robustly assessed against the criteria set out in paragraph 172 of the NPPF. We advise further information is submitted to demonstrate that the criteria of para 172 can be met, and this should include a Landscape and Visual Impact Assessment (LVIA) in line with the Guidelines for Landscape and Visual Impact Assessment (GLVIA 3rd edition). Subject to the provision of further information to support this site allocation, 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 this allocation.

DLP_4135

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

CPRE remains to be convinced that these major developments in a small village with very limited facilities in the AONB is justified under NPPF paragraph 172.

DLP_5060

Mrs Rosie Bishop

This site forms part of the AONB and is at the gateway to Matfield village; major development here would have a huge impact not only in terms of traffic but also visually – the rural quality of the AONB would be lost.  It is outside the LBD but the intention is to re-draw the LBD to include this site.  There would be a very large increase in traffic, which will be exacerbated because the B2160 will also have a huge flow increase following the enormous developments in Paddock Wood.

In common with the other Matfield sites, it is not clear that the development would be sustainable in terms of available services, facilities and transport

DLP_6305

Mrs Elizabeth Simpson

Object

Policy Number: AL/BM1

Site BM1, which is already the subject of a planning application to build 45 homes*, is a key site at the gateway of Matfield village and wholly outside the existing LBD. It forms part of the High Weald AONB; major development here would not conserve or enhance the AONB. The site also forms part of the “Matfield and Brenchley Fruit Belt”, with high-quality Grade 2 agricultural land, as identified in the Landscape Character Assessment SPD 2017, and incorporated within the Environment and Design policies EN20, EN21 and EN22. Collectively these policies state that such sites should be protected from development, to “conserve and enhance the essentially rural, working agricultural character of this area”. The introduction of a large housing estate would surely be contrary to these policies; and the proposed access is off the main through the village, which is already at significant risk of becoming much busier if the Paddock Wood proposals come to fruition.

Development of this very high profile site, the rural approach to the village, would be totally contrary to the High Weald AONB management strategy.

Please note that following the publication of the Draft Local Plan the presence dormice, a protected species, have been confirmed on this site.

(*19/01099/OUT refers: please see the extensive objections on planning grounds)

DLP_7151

Patricia Stevens

Object

Policy Number: STR/BM1 (AL/BM1, AL/BM2, AL/BM3, AL/BM4)

The development proposed for Matfield is out of all proportion to the present size and character of the village, and should not take place. Moreover, the Plan does not include the Rydon Homes development already underway.

Matfield is in the High Weald Area of Outstanding Natural Beauty, and the sites are all on undeveloped land. The Council has a statutory duty to conserve and enhance the natural beauty of the High Weald AONB and the National Planning Policy Framework states that great weight should be given to conserving AONBs. The LDP does not do this.

Furthermore, it is quite wrong for the Limits to Built Development to have been changed to accommodate these sites, as the Limits should protect the village from intrusive development and prevent the sprawl of the village into surrounding countryside.

There is an increasing need to preserve the countryside and open spaces to mitigate climate change, rural areas being a vital resource for carbon sequestration, and to promote people’s health and well-being. Instead, housing development on brownfield or infill sites, and re-using empty buildings should be reconsidered.

The proposed development is economically, socially and environmentally unsustainable. Matfield has limited infrastructure, services and amenities. It has no school or playground and no GP or Dentists surgery. Employment opportunities are limited. Public transport is limited and there are no safe walking routes from Matfield to either Brenchley Primary School or to Mascalls Academy in Paddock Wood. Together, these factors mean that the proposed housing development could only increase car use, with the resultant adverse effects of noise and air pollution as well as danger to the public and wildlife.

I live on Gedges Hill (on the B2160), and experience its traffic problems daily, I am particularly concerned about the impact this development would have on the road network, traffic volume and highway safety. The B2160 already has a high volume of traffic, especially at key times in the mornings and evenings. On Gedges Hill there is no pavement and often no space for pedestrians at either side of the road. There is a too high 50 mph speed limit, despite houses on both sides of the road and dangerous bends. Thus, it is too dangerous for pedestrians, especially for children from Matfield to walk to and from school in Paddock Wood.

The enormous housing development planned for Paddock Wood can only mean a further increase in traffic – from Matfield and Brenchley down to Paddock Wood’s secondary school, mainline station, shops and services, and up from Paddock Wood through Matfield to the A21 and the South Coast. Consequently, these housing developments already approved and underway will increasingly have an adverse impact on traffic volume, highway safety, and air and noise pollution.

The proposed development is economically, socially and environmentally unsustainable. Matfield has limited infrastructure, services and amenities. It has no school or playground and no GP or Dentists surgery. Employment opportunities are limited. Public transport is limited and there are no safe walking routes from Matfield to either Brenchley Primary School or to Mascalls Academy in Paddock Wood. Together, these factors mean that the proposed housing development could only increase car use, with the resultant adverse effects of noise and air pollution as well as danger to the public and wildlife.

I live on Gedges Hill (on the B2160), and experience its traffic problems daily, I am particularly concerned about the impact this development would have on the road network, traffic volume and highway safety. The B2160 already has a high volume of traffic, especially at key times in the mornings and evenings. On Gedges Hill there is no pavement and often no space for pedestrians at either side of the road. There is a too high 50 mph speed limit, despite houses on both sides of the road and dangerous bends. Thus, it is too dangerous for pedestrians, especially for children from Matfield to walk to and from school in Paddock Wood.

The enormous housing development planned for Paddock Wood can only mean a further increase in traffic – from Matfield and Brenchley down to Paddock Wood’s secondary school, mainline station, shops and services, and up from Paddock Wood through Matfield to the A21 and the South Coast. Consequently, these housing developments already approved and underway will increasingly have an adverse impact on traffic volume, highway safety, and air and noise pollution.

DLP_7740

Angela Underhill

Object

I am unable to download the forms for commenting on the Tunbridge Wells Local Plan as my computer does not have the necessary software so I am emailing my comments here & ask that they be taken into account along with the other comments that are received.

I live in Matfield & I wish to associate myself with all the comments made in the response from Brenchley and Matfield Parish Council to the Local Plan (Regulation 18). I need not repeat them all here, but I would particularly like to emphasise my objection to the proposal to extend the LBD for Matfield to the site AL/BM1 ( land between Brenchley Road, Coppers Lane and Maidstone Road. If this site is included in the LBD it would have a severe adverse impact on the landscape character of Matfield & it would result in ribbon development /coalescence in that a green field gap would be lost to a housing development.

DLP_418

Rona Hogan

Object

Comments on Map 76 Policy

The number of houses planned is too large, leading to suburbanisation of the centre of the village by historic houses will have a detrimental impact on the rural character of the village and the land is AONB which should be protected. I object tot his development strongly.

Final comment

TW Council is using rural villages including Matfield to dump their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the borough on brownfield sites (which the plan does not detail what has been reviewed) or placing small developments directly off of the A21 avoiding congestion in the small villages which will be unable to cope. The expected contributions will not mitigate the impact of the 4 developments proposed on Matfield, as the doctors in Brenchley have stated they cannot cope with any more patients and the landscape and rural feel of Matfield will be lost for future generations.

DLP_439

Miss Claire Atkins

Object

Matfield House Orchards / Chestnut Lane:

1) The plan states - This site is stated as undeveloped land located adjacent to the existing Limits to Built Development of Matfield

to the western side of the settlement centre, within the AONB; - 

The fact that this is located within the AONB is firstly a huge concern. We pay a premium for our properties in Chestnut Lane based on the fact that we are in an AONB and at no point when we purchased the property in November 2018 where we made aware of any plans to sell the land for development. I would be expecting some form of compensation if this plan got given the go ahead.

2) The plan states - The land includes an orchard parcel, now disused, and is associated with Matfield House,a listed building. The other parcel is possibly still used as orchard; The site comprise two parcels, one, orchard land located south of Chestnut Lane and theother to the east of this located to the rear of properties fronting Chestnut Lane.  

This plot of land on the plans is litterally backing onto residents homes and any priviacy will be lost.

Why has it been decided that this particular part of the orchard is OK to be built on when the the other side of the orchard that doesn't back onto residents property has been deemed and not suitable to built on? It surely makes more sense to select the parcel of land that doesn't have a direct effect on residents?

3) The historic orchards that back onto our property in Chestnut Lane are inundated with wildlife. We regularly see bats of an evening along with hedgehogs and many birds of prey circulating such as Buzzards.

4) The fact that Chestnut Lane is already used as a 'rat run' between Tonbridge and the A21 means that the thought of 4,000 homes being proposed in Capel will make this a far busier intersection.

Currently, as soon as there is an accident at Colts Hill or Pembury, our lane becomes inundated with vehicles. Have another housing development in Chestnut Lane will only add to this chaos.

5)The cross road in Matfield village centre is already a potential crash hazzard and the plan to build further houses in the village will only add to this.

The proposed garden village in Capel will also have an impact as more people decide to cut thorugh Chestnut Lane to join the A21. Many of these drivers will not be aware of the narrowing in the road at Pimms Cottage and I can forsee more accidents here as well as at the corssroads.

6) I have attached photographic evidence of the current traffic issues at the Blueboys Roundabout. These photos were taken at 11:15 on Saturday 21st September, not a peak time.

Having more houses built so close to this traffic black spot makes no sense as the current infrasturcture is already struggling.

7) Matfield is not equiped with services to accomodate a further 150 families. We currently have no Dr's surgery, not village shop, local schools already have waiting lists, public transport is minimal. We never see local policing in place.

8) There is already a new development being built which is not being included in the draft plan, surely there new homes should be part of the plan as our small village is already due to increase and no one seems to be taking this into account.

[TWBC: see Image 1 and Image 2]

DLP_823

C R W Mitchell

Object

My general comments on all the applications for development in the Borough's Draft Local Plan correspond with those I made on the Island site in Matfield (AL/BM 1) viz the primary school in Brenchley is full to capacity; the medical and dental surgeries are fully stretched which inevitably means that a larger number of cars will be coming onto the village roads where traffic accidents and speeding are a matter for alarm and concern.

Matfield House Orchards site Policy AL/BM 2

As a resident of Chestnut Lane I am particularly concerned that the application for development in the Matfield House Orchard and land site, only recently published, now brings to three the number of sites which may be scheduled for development there are three little more than 100 yards from Chestnut Lane (1) the Rydon Homes site adjacent to the Poet (already being developed) (2) the Island site and (3) the Matfield House Orchard site. I am trying to emphasise there is an unevenness in the areas of the village chosen for development - the preponderance being around Chestnut Lane.

In addition the road to this site is to emerge into Chestnut Lane  which is already beginning to rival the Maidstone Road B2160 for speeding cars and this will only become worse if more houses, with their accompanying cars, are built on the Matfield House Orchard site.

The Borough Council's statutory duty to conserve and enhance the A.O.N.B. of the High Weald will not be achieved it it insists on planting estates of houses whose design and architecture do not accord with the style of traditional village houses.

It should not be assumed that I am against all house building. There is clearly a need for some, and the focus should be on genuinely "affordable" houses and not for those able to afford houses of £600,00 or more. I suspect that the need for affordable homes has been gravely underestimated, but they should be built in countryside style in small clusters and not in large estates. Developers and builders may not like this, but to populate villages almost entirely with the retired and well-to-do is a form of social engineering.

If young people/first time buyers are unable to buy houses in the village where they were brought up and move into towns this will result in the reduction or loss of young people with countryside skills and aptitudes to work in, for example, farming, forestry, water management, equestrian activities, quarrying and running or working in village shops.

I leave you think of what the result would be.

[TWBC: see also comment number DLP_348].

DLP_871

Nick Tester

Object

Tunbridge Wells Borough Council Local Plan and its disastrous implications for Matfield and surrounding area.

1. BM3 is situated in the orchard of Ashes Plantation with a proposed 30-60 new dwellings, the only access proposed is through Oakfield Road, which seems a crazy idea. Oakfield Road has an historical acute parking problem that means this road is in effect a one lane road and not a two lane. Therefor emergency vehicles and/or large vehicles would more than struggle to gain access to properties down Oakfield Road and into BM3. Local residents will be fuming with their Local Councillor’s, because residents will have to park somewhere. It’s very difficult to exit a vehicle onto Maidstone road from Oakfield Road at present due to the already high volume of traffic passing between Kipping’s Cross and Paddock Wood. With a further potential of 50-60 vehicles from BM3 plus vehicles from all the other future proposed housing sites it would be nigh on impossible. I can see nothing but trouble in Oakfield Road with all the extra vehicles generated by BM3. Especially from BM4’s access that is almost opposite Oakfield Road’s exit onto Maidstone Road and on a dangerous bend? Plus, all the other TWBC Local plan developments all using Matfield as the link to the A21 and Paddock Wood.
2. The main bottle necks will be “Kipping’s Cross” and the cross-roads at “The Poet” plus all the future accesses to and from all the new Matfield developments. The cross-roads junction at Maidstone Road, Brenchley Road and Chestnut Lane will be under enormous pressure from the Island Site (BM1), the Rydon site, with 22 new homes already under construction and from BM2 off Chestnut Lane plus Paddock Wood and Capel 4000 homes and Tudeley 2500 homes, a complete nightmare!
3. Also, the access that is shown on Map77 policy AL/BM3 shows the red line passing through half of one block of flats in Oakfield Road to allow for access widening of the garage access road. One can only assume, that half a block cannot be removed therefore the entire block would have be demolished losing four dwellings, rendering the occupants homeless. Not good news.
4. The Green space /recreation/amenity area on map 77 looks ok on paper but there is a “badger’s clan set” in the gully on the side banking of the green area. This set produced four healthy cubs this year and these badgers can be seen most evenings feeding up through the orchard of BM3. The green space proposal will greatly curtail their feeding range, if not frighten them away all together! Plus, the noise level will increase due to children and youths playing in the green space, extra dogs barking, the playing of loud music, extra cars causing extra pollution and more light pollution i.e. no dark skies. Please note, It is an offence to intentionally damage, destroy or obstruct the access to a badger’s set. Most in danger are the woodland owls, bats, small rare birds, frogs, butterflies, hedgehogs and birds of prey that we enjoy, all in the south end of “Church Wood” at the bottom of BM3. These animals are obviously finding small mammals to feed on, but with extra cats arriving in BM3, in future small mammals will be in short supply? All these new problems will have such a huge negative impact on the existing wildlife and destroy a unique habitat.
5. There is no mains gas supply in “Matfield” and all new homes will have to be heated, either by oil, electricity, gas cylinders, log burners or solid fuel? All these fuels will create a lot more CO2 pollution that will add to climate change and act against the environment!
6. Services for Matfield are almost non-existent, i.e. no School, no Doctors, no Dentist, no shop, we have a mobile Post Office three days a week but it’s not always working, we do have a very good Butchers. All the services are in Brenchley. There were 24 sites proposed for Brenchley and Matfield with plans for 91-150 homes. But it’s Brenchley who has all the services i.e. Doctors surgery, primary School, Dentist and full time Post Office and shop but have had none of the proposed new housing developments. This also means Matfield residents young and elderly will definitely require transport to visit these services?
7. Visiting Tunbridge Wells or Tonbridge for shopping will be a thing of the past, due to the traffic bottle necks and jams! Trying to visit Tunbridge Wells shops at present is difficult enough. The High Street shops will suffer even more than before with these new developments. Good job we have the online shopping option to fall back on, although the deliveries may take extra time to get through. Assuming you and your vehicle made it to the town, parking would be much more difficult, Car parking charges are not very welcoming either.
8. Any new development should aim to enhance the villages, minimise the impact and not destroy their uniqueness for future generations. In-essence, these proposed new developments are far too large for such small villages.
9. The infrastructure, especially the extra water, electricity and sewage used will all have to be increased. The fact that a high acreage of land will be built on, means rainwater will not be able to be soaked up so naturally, in these areas, therefore there is a higher risk of flooding i.e. the water will have run off to somewhere. The orchards of BM2 and BM3 will lose hundreds of their apple trees. Trees that soak water and take CO2 from the atmosphere and give back oxygen in return, are good for the environment and Global warming.
10. The smaller Villages seem to be acquiring all the new housing estates while Paddock Wood is getting all the extra goodies in the form of new facilities.
11. On Map 76, the access to and from BM2 is opposite Wish Courts access road and is possibly not the best outcome to gain access to BM2 as it makes a new crossroads. It’s also a very narrow access. The fact that the new proposal would mean just about every house along Maidstone Road and Chestnut Lane (about 20 houses) will have their light and view blocked. Plus, there’ll be a lot more noise emanating from the new housing estate and yet more light pollution. If these houses were re-situated in the Green area of BM2 close to and along Chestnut lane, then only two houses could possibly see the new development and then only at some distance.
12. The road systems around the Tunbridge Wells and Tonbridge area are mostly narrow and full of dangerous bends, therefore an increase in accidents will occur around our villages. Unless the roads infrastructure is greatly improved. Due to the double roundabout at Kipping’s Cross there are traffic holdups every day at present at busy times and it will get a 100% worse, if these developments go ahead.

DLP_949

Mrs Karen Stevenson

Support with conditions

Policy AL/BM 2 –Matfield House orchards and land, The Green (between Chestnut Lane and The Star). Allocated for residential development (C3) of approximately 20-30 dwellings. Land forming the western part of the site to be maintained as orchard. Built development on eastern part of the site only outside of the Conservation Area.

Whilst I have already expressed my concerns about the proposed LBD changes, and this also requires a change, the part of this site proposed to be allocated for development is within the heart of the village, surrounded by existing housing and would be barely visible from any road. Therefore provided this is conditional on the more prominent and more visible western part of this site being offered green space protection, then this proposal has more merit.

Although the issue remains, as already stated earlier, that Matfield does not have the services or facilities to support such a large development, further, the transport infrastructure cannot accommodate this scale of development access off Chestnut Lane, whose access to the B2016 at Standings Cross is a dangerous junction already, and in the other direction, the road becomes single track in part.

DLP_1744

Clare Kember

Object

BM2 Matfield House orchards and land, The Green (SHELAA Reference: Site 18) - (20-30 homes)

* BM2 is situated within Matfield House Orchard. This historical orchard has an existing driveway up to an Oast House on the land. BM2 covers one section of the orchard, the other section is to be safeguarded and managed for its contribution to landscape and ecology. Since both sections form one orchard, it should all be safeguarded.

* BM2 is an intrusive development that will cause destruction to the historic buildings and surrounding countryside, causing a detrimental impact on the High Weald Area of Outstanding Natural Beauty (AONB) which should be protected.

* BM2 will be detrimental to our dark skies, wildlife and its habitats, rural character and beautiful landscape. Wildlife that can be seen regularly in the orchard include hedgehogs, frogs, bees, bats, butterflies and a wide range of birds including owls and other birds of prey that rely on the small rodents that also live in the orchard. These should all be safeguarded.

* The number of houses proposed on BM2, is proportionately far greater than on any of the other larger sites proposed in the village, putting further strain on infrastructure and services around Chestnut Lane. The number of homes on BM2, relative to its size, would suggest that the houses would not be built well-spaced, have respect for the character of the land or have adequate parking.

* BM2 is disruptive and intrusive to local residents, with 3 sides of the plot boundaries directly adjoining existing properties in Chestnut Lane, Maidstone Road and The Avenue in Maycotts Lane.

* Any development should aim to minimise the impact to village infrastructure and its residents. It should be sympathetic with the surrounding area and maintain rural village life for future generations. BM2 does not achieve these aims.

* The roads, parking, services and infrastructure around the Chestnut Lane area and the Standings Cross junction will already be under increased, unsupportable and unsustainable strain from the Rydon Homes building development (22 homes) underway on Maidstone Road and the proposed Island Site (BM1) proposed between Brenchley Road, Coppers Lane and Maidstone Road (30-45 homes). The very large proposed developments in nearby Paddock Wood and Capel (4000 homes) and Tudeley (2500 homes) would add significantly to the issues faced in Matfield and be a further strain on the B2160 passing through Matfield and the inadequate roads around Chestnut Lane that are already heavily used to access the B2160, A21 and A228.

DLP_2102

Terry Everest

Object

Strongly Object

These are Orchards filled with trees and should be protected !

You must preserve elements of the garden of England rather than build at every chance.

DLP_3333

Kent County Council (Growth, Environment and Transport)

Object

Highways and Transportation

The Local Highway Authority objects to this policy.

This is a landlocked site. The site does not abut Chestnut Lane and the narrow farm access is outside the red line boundary.

Heritage Conservation

Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval.

DLP_3463

High Weald AONB Unit

Object

The proposal is major development in the AONB which has not been adequately justified under paragraph 172 of the NPPF.

DLP_4136

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

CPRE remains to be convinced that these major developments in a small village with very limited facilities in the AONB is justified under NPPF paragraph 172.

DLP_4559

Historic England

Policy AL/BM 2: Matfield House orchards and land, The Green - new development of 20-30 houses to the rear of grade I listed Matfield House on land historically associated with the house and still within the same ownership as the mansion, though reasonably well separated from the main house, may cause some harm. A requirement for appropriate seperation and screening should be added to the wording of the policy.

DLP_7010

Kember Loudon Williams for Mr and Mrs John & Sarah Garthwaite

General Observation

Paragraph 5.112

The second bullet point, last sentence says “the other parcel is possibly still used as an orchard.”. This is not the case, it was last used for producing commercial fruits in 1988 – 31 years ago. The fruits are left to rot and not used. It is suggested that this be amended in the final document.

DLP_7019

Kember Loudon Williams for Mr and Mrs John & Sarah Garthwaite

Object

Policy AL/BM2 – First sentence

For the same reasons as articulated in the objection to strategic policy STR/BM1 the dwelling range of 20-30 should be reworded to express the number of units as a minimum of 30. This would accord with the NPPF at paragraph 60

Policy AL/BM2 – Map 76 and development site area

The first sentence of the policy sets out the quantum of development and the site area is defined on the accompanying Map 76. The owner of Matfield House has also taken advice on the potential development of the site, its extent and the effect on the land values of the retained buildings comprising Matfield House and its converted outbuildings. Accompanying the submissions is an indicative site layout. This demonstrates that a slightly larger site area is required to deliver the 30 dwellings. The reason for requesting this change to the policy is outlined below and in other objections to this policy.

As you know Matfield House is Grade I Listed. It is a Georgian house built by Thomas and Mary Marchant in 1728. More importantly, it was designed by Thomas Archer who is widely recognised as a leading Georgian architect of the period.  The house, together with the other buildings that have been sensitively converted,  retain high land values. The historic setting extends as far as Matfield Oast, which retains its own curtilage and views to the west of Matfield Oast across remnant orchard and the garden of Matfield Oast towards Chestnut Lane. It is considered correct that no development occupies this broad sweep of land which has important views to the cupula on top of an outbuilding. However, the area east of the new access road and west of the Matfield Oast access track, could reasonably be developed. If the allocation was extended in a modest way it would serve a number of purposes:

1. It would enable the maximum number of 30 units identified for this location to come forward in a design that respects surrounding character. The allocation as currently drafted, if developed for 30 units, would result in an extremely high density scheme squeezed into a small site area. This would be out of character with the surrounding areas, and would not be commensurate with the setting of Matfield Oast, the conservation area or Matfield House. The design of the scheme presented here would enable a low density scheme to be developed on the inside of the new access road with the density increasing in a modest but appropriate way the further east. This would have important design benefits for the village in that it would enable a good quality design that feathers the development site into the wider rural character and countryside in a more pleasing way than the abrupt development of the terraced houses and the cul de sac development of Wish Court and Birch Close to the north. Initial design thoughts are to include a Suds pond and swales in this area to facilitate a low density character and attractive entrance feature to the village. Such features could be used by residents for amenity purposes.
2. An access road to the west of the Wish Court junction would be essential to ensure the safe turning of vehicles into the development site and to preserve the vista along the Matfield Oast access and toward that listed building. If there are no houses of substance fronting the new access road and contributing towards its cost then it would be difficult to offset the cost of the road with the remaining development, where 40% must be affordable housing at a much higher density and therefore lower in value.
3. Importantly, Matfield House is Grade 1 Listed. It, together with other buildings, retain very high land values and the development of part of its land holding would have a negative effect on this. Preliminary work on this indicates that to offset this, a small extension to the development area is necessary in the manner shown on a plan to be submitted in due course. The extended site area would enable higher value properties which off set the negative effects of the development upon land values of the house and its outbuildings.

Policy AL/BM2 – Map 76 

The owner has had careful regard to the site area identified on the Policy Map. The owner supports the location of the allocation outside of the Conservation Area boundary.

Currently development is shown to the east of the access to Matfield Oast, a Grade II Listed Building. Land to the west of the access is shown as open space.

Criterion 1 says that there should be a single point of access from Chestnut Lane. No vehicular access is identified on Map 76.  The existing track which serves Matfield Oast is a private way and lined with small trees and a hedgerow. Its character and proportions help provide a vista towards the Grade II Listed Matfield Oast and retain a rural approach to this Listed Building. It is inappropriate to alter this track to be the main access. The owner wants to retain its rustic character for the setting of Matfield Oast and to provide an informal pedestrian route to Chestnut Lane. It is also the case that this track junctions with Chestnut Lane opposite the Wish Court junction. It would be inappropriate to locate a new junction so close to Wish Court as this would cause traffic conflict when vehicles turn. A new road for the development must be sited to the west of the Wish Court access. This will form a point at which the road speed can be reduced to 30mph. Map 76 should be updated to reflect this. The landowner has prepared a site layout plan to illustrate how the site could be designed with an access west of Wish Court and which can deliver the 30 dwellings proposed.

Policy AL/BM2 - Criterion 3 

The land owner supports the inclusion of a pedestrian access onto Maidstone Road. Town and Country are the affordable housing provider which operates Marchants through which a pedestrian route could be built. The criterion should not rule out alternative arrangements and the landowner does own the cottage adjacent to the sub station opposite the village pond. This could form an alternative should that be deemed appropriate.

Policy AL/BM2 - Criterion 5

The landowner is supportive of looking at the opportunities to reduce the on street parking linked to Marchants. However, this is an additional cost unrelated to the development in question and the landowner would have to look carefully at whether a more appropriate option would be to provide driveways off Maidstone Road as part of any enhanced pedestrian access opportunity. We say this because for practical reasons, residents mostly require parking close to their houses and directly off the road onto which they front. It is highly unlikely that residents would drive past their house, along Maidstone Road, along Chestnut Lane and through the site to a parking bay. The added benefit of driveways would then be to remove on street parking and enable the retention of the existing tree screen which is beneficial.

A secondary issue is that some of the existing houses adjoining the site have very small rear gardens and the indicative layout indicates that a small amount of land could be offered to these properties to enhance their rear gardens by between 5-7m. This relates to a terrace of 3 houses and The Marchants, both located off Maidstone Road through the village. Whilst this could never be a policy criterion in a Local Plan, the applicant would have no objection to the supporting text identifying that local amenity improvements should be explored as part of the scheme and this could cover such proposals.

Policy AL/BM2 - Criterion 7

The applicant has no objection to the future landscape and ecological management of this western area of the site (subject to the small increase in the allocated housing development area). The applicant has the intention of retaining this land within his ownership in the longer term as it is important to keep to in the same ownership as the Grade I Listed Building.

Policy AL/BM2 - Criterion 11

The landowner is willing to provide amenity and play space for the residents of the development and include this within the proposed housing allocation of BM2. However, no other land to the west would be gifted as the landowner wishes to retain ownership in order to ensure the setting of the Listed Building can be secured. Notwithstanding, the landowner would be willing to provide commitments towards appropriate landscaping and ecological enhancements through a long term management plan of this area.

The wording of criterion 11, by referencing allotments and recreation grounds, appears to conflict with criterion 7 which seeks landscaping and ecology enhancements. This is objected to because it would alter the character of the retained open space in a way which is negative in the context of the setting of this important listed building.

The legal tests for obligations under s106 agreements are set out in regulation 122 and 123 of the Community Infrastructure Levy Regulations 2010 as amended.

The tests are:

1. necessary to make the development acceptable in planning terms
2. directly related to the development; and
3. fairly and reasonably related in scale and kind to the development.

The use of the western portion of the site defined as allotments or open and recreational space would not meet these tests as it would not be in scale or kind nor is it necessary to make the development acceptable. Reference to “improvements to existing allotments” suggests that some of the land would be devoted to allotment use. This would alter the views to and from the Listed Matfield House and be an inappropriate change to the character of the area, particularly when approaching the village from the junction of Chestnut Lane and Maycotts Lane. The landowner could not support the use of the land for this purpose and so the policy wording ought to change to reflect a wholly landscape/ecology led management scheme.

DLP_7152

Patricia Stevens

Object

Policy Number: STR/BM1 (AL/BM1, AL/BM2, AL/BM3, AL/BM4)

The development proposed for Matfield is out of all proportion to the present size and character of the village, and should not take place. Moreover, the Plan does not include the Rydon Homes development already underway.

Matfield is in the High Weald Area of Outstanding Natural Beauty, and the sites are all on undeveloped land. The Council has a statutory duty to conserve and enhance the natural beauty of the High Weald AONB and the National Planning Policy Framework states that great weight should be given to conserving AONBs. The LDP does not do this.

Furthermore, it is quite wrong for the Limits to Built Development to have been changed to accommodate these sites, as the Limits should protect the village from intrusive development and prevent the sprawl of the village into surrounding countryside.

There is an increasing need to preserve the countryside and open spaces to mitigate climate change, rural areas being a vital resource for carbon sequestration, and to promote people’s health and well-being. Instead, housing development on brownfield or infill sites, and re-using empty buildings should be reconsidered.

The proposed development is economically, socially and environmentally unsustainable. Matfield has limited infrastructure, services and amenities. It has no school or playground and no GP or Dentists surgery. Employment opportunities are limited. Public transport is limited and there are no safe walking routes from Matfield to either Brenchley Primary School or to Mascalls Academy in Paddock Wood. Together, these factors mean that the proposed housing development could only increase car use, with the resultant adverse effects of noise and air pollution as well as danger to the public and wildlife.

I live on Gedges Hill (on the B2160), and experience its traffic problems daily, I am particularly concerned about the impact this development would have on the road network, traffic volume and highway safety. The B2160 already has a high volume of traffic, especially at key times in the mornings and evenings. On Gedges Hill there is no pavement and often no space for pedestrians at either side of the road. There is a too high 50 mph speed limit, despite houses on both sides of the road and dangerous bends. Thus, it is too dangerous for pedestrians, especially for children from Matfield to walk to and from school in Paddock Wood.

The enormous housing development planned for Paddock Wood can only mean a further increase in traffic – from Matfield and Brenchley down to Paddock Wood’s secondary school, mainline station, shops and services, and up from Paddock Wood through Matfield to the A21 and the South Coast. Consequently, these housing developments already approved and underway will increasingly have an adverse impact on traffic volume, highway safety, and air and noise pollution.

The proposed development is economically, socially and environmentally unsustainable. Matfield has limited infrastructure, services and amenities. It has no school or playground and no GP or Dentists surgery. Employment opportunities are limited. Public transport is limited and there are no safe walking routes from Matfield to either Brenchley Primary School or to Mascalls Academy in Paddock Wood. Together, these factors mean that the proposed housing development could only increase car use, with the resultant adverse effects of noise and air pollution as well as danger to the public and wildlife.

I live on Gedges Hill (on the B2160), and experience its traffic problems daily, I am particularly concerned about the impact this development would have on the road network, traffic volume and highway safety. The B2160 already has a high volume of traffic, especially at key times in the mornings and evenings. On Gedges Hill there is no pavement and often no space for pedestrians at either side of the road. There is a too high 50 mph speed limit, despite houses on both sides of the road and dangerous bends. Thus, it is too dangerous for pedestrians, especially for children from Matfield to walk to and from school in Paddock Wood.

The enormous housing development planned for Paddock Wood can only mean a further increase in traffic – from Matfield and Brenchley down to Paddock Wood’s secondary school, mainline station, shops and services, and up from Paddock Wood through Matfield to the A21 and the South Coast. Consequently, these housing developments already approved and underway will increasingly have an adverse impact on traffic volume, highway safety, and air and noise pollution.

DLP_419

Rona Hogan

Object

Comments on Map 76 Policy

The number of houses planned is too large, suburbanisation of the centre of the village on AONB land, leading to a huge increase in traffic and pressure on service such as doctor which are in Brenchley and will have a detrimental impact on the rural character of the village. There is a loss of substantial amounts of trees and vegetation and wildlife habitat. Matfield has no infrastructure to cope with this increase in number of houses. I object to this development strongly.

Final comment

TW Council is using rural villages including Matfield to dump their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the borough on brownfield sites (which the plan does not detail what has been reviewed) or placing small developments directly off of the A21 avoiding congestion in the small villages which will be unable to cope. The expected contributions will not mitigate the impact of the 4 developments proposed on Matfield, as the doctors in Brenchley have stated they cannot cope with any more patients and the landscape and rural feel of Matfield will be lost for future generations.

DLP_631

Rosamund Barwell

Object

The 'full pop-up image' link on this site doesn't work. The entire site is slow, dreadfully designed and exceedingly difficult to navigate.

Policy AL/BM3

Oakfield Road was not designed to be a through road.

Under this proposal, the volume of traffic in Oakfield Road would likely treble.

Under this proposal, the noise effect from traffic in Oakfield Road would likely treble.

Under this proposal, the pollution from traffic in Oakfield Road would likely treble.

The current speed of cars in Oakfield Road is between 5-10mph. As a through road, this would likely increase to 30mph, again trebling the current value.

There is not enough space in what is currently the garage area at the end of Oakfield Road to enable parking for all cars currently using Oakfield Road for said purpose. An area twice this size would be required.

Oakfield Road would not be the easiest way for residents on the Ashes plantation to reach Maidstone Road. It is not the nearest access to Maidstone Road. The nearest road option would be the current track on what appears to be called Orchard Way (the name of this is difficult to decipher from the plan, because as stated above, the link doesn't work).

Clearly this proposal in its current format is not viable. Of the 4 'BM' proposals it is by far the worst. It is the only site of the 4 that doesn't have direct access to a main road, and the only one of the 4 that would change the daily lives of an entire road of people.

However, it is quite possible that of the four 'BM' sites, the BM 3 site would effect the most Matfield residents who are on social housing. Perhaps this is something that the local authority prefers?

DLP_873

Nick Tester

Object

Tunbridge Wells Borough Council Local Plan and its disastrous implications for Matfield and surrounding area.

1. BM3 is situated in the orchard of Ashes Plantation with a proposed 30-60 new dwellings, the only access proposed is through Oakfield Road, which seems a crazy idea. Oakfield Road has an historical acute parking problem that means this road is in effect a one lane road and not a two lane. Therefor emergency vehicles and/or large vehicles would more than struggle to gain access to properties down Oakfield Road and into BM3. Local residents will be fuming with their Local Councillor’s, because residents will have to park somewhere. It’s very difficult to exit a vehicle onto Maidstone road from Oakfield Road at present due to the already high volume of traffic passing between Kipping’s Cross and Paddock Wood. With a further potential of 50-60 vehicles from BM3 plus vehicles from all the other future proposed housing sites it would be nigh on impossible. I can see nothing but trouble in Oakfield Road with all the extra vehicles generated by BM3. Especially from BM4’s access that is almost opposite Oakfield Road’s exit onto Maidstone Road and on a dangerous bend? Plus, all the other TWBC Local plan developments all using Matfield as the link to the A21 and Paddock Wood.
2. The main bottle necks will be “Kipping’s Cross” and the cross-roads at “The Poet” plus all the future accesses to and from all the new Matfield developments. The cross-roads junction at Maidstone Road, Brenchley Road and Chestnut Lane will be under enormous pressure from the Island Site (BM1), the Rydon site, with 22 new homes already under construction and from BM2 off Chestnut Lane plus Paddock Wood and Capel 4000 homes and Tudeley 2500 homes, a complete nightmare!
3. Also, the access that is shown on Map77 policy AL/BM3 shows the red line passing through half of one block of flats in Oakfield Road to allow for access widening of the garage access road. One can only assume, that half a block cannot be removed therefore the entire block would have be demolished losing four dwellings, rendering the occupants homeless. Not good news.
4. The Green space /recreation/amenity area on map 77 looks ok on paper but there is a “badger’s clan set” in the gully on the side banking of the green area. This set produced four healthy cubs this year and these badgers can be seen most evenings feeding up through the orchard of BM3. The green space proposal will greatly curtail their feeding range, if not frighten them away all together! Plus, the noise level will increase due to children and youths playing in the green space, extra dogs barking, the playing of loud music, extra cars causing extra pollution and more light pollution i.e. no dark skies. Please note, It is an offence to intentionally damage, destroy or obstruct the access to a badger’s set. Most in danger are the woodland owls, bats, small rare birds, frogs, butterflies, hedgehogs and birds of prey that we enjoy, all in the south end of “Church Wood” at the bottom of BM3. These animals are obviously finding small mammals to feed on, but with extra cats arriving in BM3, in future small mammals will be in short supply? All these new problems will have such a huge negative impact on the existing wildlife and destroy a unique habitat.
5. There is no mains gas supply in “Matfield” and all new homes will have to be heated, either by oil, electricity, gas cylinders, log burners or solid fuel? All these fuels will create a lot more CO2 pollution that will add to climate change and act against the environment!
6. Services for Matfield are almost non-existent, i.e. no School, no Doctors, no Dentist, no shop, we have a mobile Post Office three days a week but it’s not always working, we do have a very good Butchers. All the services are in Brenchley. There were 24 sites proposed for Brenchley and Matfield with plans for 91-150 homes. But it’s Brenchley who has all the services i.e. Doctors surgery, primary School, Dentist and full time Post Office and shop but have had none of the proposed new housing developments. This also means Matfield residents young and elderly will definitely require transport to visit these services?
7. Visiting Tunbridge Wells or Tonbridge for shopping will be a thing of the past, due to the traffic bottle necks and jams! Trying to visit Tunbridge Wells shops at present is difficult enough. The High Street shops will suffer even more than before with these new developments. Good job we have the online shopping option to fall back on, although the deliveries may take extra time to get through. Assuming you and your vehicle made it to the town, parking would be much more difficult, Car parking charges are not very welcoming either.
8. Any new development should aim to enhance the villages, minimise the impact and not destroy their uniqueness for future generations. In-essence, these proposed new developments are far too large for such small villages.
9. The infrastructure, especially the extra water, electricity and sewage used will all have to be increased. The fact that a high acreage of land will be built on, means rainwater will not be able to be soaked up so naturally, in these areas, therefore there is a higher risk of flooding i.e. the water will have run off to somewhere. The orchards of BM2 and BM3 will lose hundreds of their apple trees. Trees that soak water and take CO2 from the atmosphere and give back oxygen in return, are good for the environment and Global warming.
10. The smaller Villages seem to be acquiring all the new housing estates while Paddock Wood is getting all the extra goodies in the form of new facilities.
11. On Map 76, the access to and from BM2 is opposite Wish Courts access road and is possibly not the best outcome to gain access to BM2 as it makes a new crossroads. It’s also a very narrow access. The fact that the new proposal would mean just about every house along Maidstone Road and Chestnut Lane (about 20 houses) will have their light and view blocked. Plus, there’ll be a lot more noise emanating from the new housing estate and yet more light pollution. If these houses were re-situated in the Green area of BM2 close to and along Chestnut lane, then only two houses could possibly see the new development and then only at some distance.
12. The road systems around the Tunbridge Wells and Tonbridge area are mostly narrow and full of dangerous bends, therefore an increase in accidents will occur around our villages. Unless the roads infrastructure is greatly improved. Due to the double roundabout at Kipping’s Cross there are traffic holdups every day at present at busy times and it will get a 100% worse, if these developments go ahead.

DLP_882

Paul and Janet Dyer

Object

Specific comments re TWBC draft local plan AL/BM3

Access via Oakfield Road

Many residents in Oakfield Road do not have their own car parking space and have to park their vehicles in the road. Many households have more than one car. The result of this is that there are often up to 30 vehicles parked on the road. This means that there is regularly a nearly continuous line of parked vehicles along one side of the road and access and egress is along the same half of the road. There can be difficulty turning in the road and the garage entry is used for this purpose.

Cars are parked right up to the junction with Maidstone road so access into Oakfield Road is on the wrong side of the road and there is restricted visibility when leaving Oakfield Road.

Currently, there are frequent problems for large vehicles to access properties in Oakfield Road. this would also apply to vehicles delivering building materials for The Ashes site.

Oakfield Road would be unable to cope with the increase in volume of traffic created by the new residents in The Ashes site.

[TWBC: see also comment number DLP_879].

DLP_893

Mr Peter Coombes

Object

These two specific sites in the proposed Draft Plan will directly affect us and other residents on Maidstone Road. These proposed sites are situated to the front and rear aspects of our properties.

AL/BM3

This site borders the rear of our garden and other Maidstone Road residents. The proposed site is much too large for Matfield and represents a major development for the village within our rural environment. Access will be via Oakfield Road which is a narrow road with resident’s cars parked on both sides and is totally unsuitable for the proposed site.  Despite extra parking spaces being planned, residents will still want to park cars outside their houses as usual making access from the proposed site very difficult. This site is destroying relatively new orchards which surely, we should try and retain in a fruit growing area. We will be losing the whole character of the village with this site and spoiling the environment for those who like to walk the village footpaths and surrounding fields. There is a wealth of wildlife either on or coming through the site from the surrounding fields and orchards including badger, grass snake, newts etc which visit our gardens through the proposed site. It is very disappointing that TWBC have moved the Limit to Build Line encroaching into the heart of the green space surrounding our village. The number of vehicle movements from this site will make an already traffic situation in the village much worse.

DLP_950

Mrs Karen Stevenson

Object

Policy AL/BM 3 –Ashes Plantation, Maidstone Road (to right of Oakfield Road). Allocated for residential development (C3) of approx. 30-60 dwellings and a fully equipped children’s play space. Retention of agricultural access between the farm buildings and agricultural land to the south. Eastern triangle of land on the site to be retained as green open space. Contributions (50%) towards the installation of speed sign with number plate recognition facility on agreed location on Maidstone Road. Avoidance of demolition wherever possible.

This proposed site is substantial, outside the existing LBD, encroaches into the AONB and iis adjacent to protected ancient woodland. This is a substantial proposal, whilst less prominent again the B2016 main road through the village, it has very poor access only from Oakfield Road, which is a narrow cul-de-sac with limited parking. This road itself is unsuitable for offering the sole means of access to such a large development.

DLP_1363

Anthony Palmer

Object

i am writing to voice concern and object to the inclusion of the above site in the draft local plan. It involves a proposal to build an excessive number of homes (up to 60) on a small site that is agricultural land. It will have an adverse impact on an Area of Outstanding Beauty lying on its direct southern border which is owned by me.

The proposal will give rise to:-

1. Loss of privacy over a tranquil parkland garden which has been developed to encourage nature and wildlife through careful planting and organic gardening;
2. Disturbance of the visual appearance of the parkland garden described above.
3. The impact on the 400 year old Friars estate buildings which provide an important part of the character of this Wealden village;
4. An impact on the wildlife. My garden is the home to a large badger set (which is within 50 metres of Ashes Plantation) and much wildlife, which has been encouraged by the development through the planting of hundreds of trees and bushes;

National Policy Framework at paragraph 172 states:-

"Great weight should be given to conserving and enhancing landscape and scenic beauty....Areas Of Outstanding Natural Beauty, which have the highest status of protection.... The scale and extent of development within these designated areas should be limited. Planning permission should be limited. Planning permission should be refused for major development other than in exceptional circumstances... "

The setting of the estate at the Friars should be conserved and enhanced. If there is to be development the guidance in paragraph 9 should be implemented which states that:-

"Reinforcement of the southern landscape boundary. It is expected that any built development is set away, northwards from this boundary."

In the light of the large badger community in the garden the boundary should be thoroughly dog proofed and constructed to prevent people accessing this private garden. Hedging/fencing should be high enough to prevent invasion of privacy and light intrusion in an otherwise dark area.

Development should be given if steps are taken to prevent the natural springs in Ashes Plantation from causing flooding and damage on the land lying to the southern boundary,  which they do at present.

If your officers would like to visit my property to see the amenity and the badger set then do let me know.

DLP_1699

Brenchley and Matfield Parish Council

Object

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

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

[TWBC: part of whole comment number DLP_1683 - SEE SECTION 1].

DLP_1746

Clare Kember

Object

BM3 Ashes Plantation, Maidstone Road (SHELAA Reference: Site 353) - (30-60 homes)

* The access proposed to BM3 is from Oakfield Road, which already has a parking problem and is effectively a one lane road. It is also very difficult to see to safely enter and exit Oakfield Road from Maidstone Road (B2160). The development at BM3 will not allow sufficient access for existing and additional cars that would use Oakfield Road, including emergency and amenity vehicles.

* Map77 shows access to BM3 passing through the middle of an existing block of flats in Oakfield Road. If the block has to be demolished, 4 homes might be lost to existing residents.

DLP_1768

Mr Paul Spedding

Object

Ashes Plantation AL/BM3

Although this site is partly hidden from the Maidstone Road, there are several reasons it is inappropriate. First, in terms of travel, it is not sustainable. Public transport is infrequent and there is no safe cycle route to Paddock Wood (shops/schools/rail station) or to Brenchley (schools, only parish playground, doctors surgery, parish sports facilities). As such new journeys from this development will almost certainly be largely car based. The route to Tunbridge Wells is already congested following the dualling of the A21 and additional car journeys will increase the degree of gridlock during rush hours/school runs. The site has ancient woodland on its boundaries which should have a material buffer zone in order to protect it. The access to the site is down Oakfield Road which, because of residents parking, is effectively a singe-track road during much of the day. (Up to 20 cars can be parked on the street - this excludes the dedicated parking bays). To use this road to access any new development will lead to increased traffic incidents. Given the development is likely to be car-based, the amount of parking set out in TWBC's LP policy will be inadequate - leading to even more overspill parking. It is also likely that there will be more pavement parking in the area to the detriment of pedestrians, especially those with young children or those using wheelchairs. This can hardly be regarded as "sustainable".

DLP_2103

Terry Everest

Object

Object strongly

all objections are strong to be fair.

The site is highly treed and should be protected.

DLP_3334

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy.

The following changes are requested:

Paragraph 1 – “Vehicular access into the site to be informed by a Transport Assessment, to include assessment of junction of Maidstone Road/Oakfield Road”

Paragraph 3 – “Provision of pedestrian access to Maidstone Road including assessment and provision of pedestrian crossing points”

Paragraph 5 – “ Contributions (50%) towards the provision of a pedestrian access to the existing children's play space at Maidstone Road”

Points 6 and 7 should be removed. The Transport Assessment will highlight specific mitigation measures: should not be pre-empted at this stage.

The standard paragraph regarding contributions should feature in this policy - It is expected that mitigation measures will be implemented by the developer. A contribution may be taken if appropriate

In Point a – reference to traffic calming should be removed.

Heritage Conservation

Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval.

Potential for remains associated with post medieval activity

DLP_3464

High Weald AONB Unit

Object

The proposal is major development in the AONB which has not been adequately justified under paragraph 172 of the NPPF.

DLP_3621

Southern Water Services Plc

Support with conditions

Southern Water is the statutory wastewater undertaker for Horsmonden. As such, we have undertaken a preliminary assessment of the capacity of our existing infrastructure and its ability to meet the forecast demand for this proposal. Our assessment has revealed that Southern Water's underground infrastructure crosses this site. This needs to be taken into account when designing the site layout. Easements would be required, which may affect the site layout or require diversion. Easements should be clear of all proposed buildings and substantial tree planting.

In consideration of the above, we recommend the following criterion is added to Policy AL/BM 3

Layout is planned to ensure future access to existing wastewater infrastructure for maintenance and upsizing purposes

DLP_4137

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

CPRE remains to be convinced that these major developments in a small village with very limited facilities in the AONB is justified under NPPF paragraph 172.

DLP_5061

Mrs Rosie Bishop

Object

The proposed access to this site is unworkable. Oakfield Road is a narrow cul-de-sac with mostly on-street parking and would not be able to provide access for another 60 homes on the new site, let alone access for construction.

The site is adjacent to an area of Ancient Woodland and development would have a very negative impact on these and the wildlife therein.

In common with the other Matfield sites, it is not clear that the development would be sustainable in terms of available services, facilities and transport

DLP_6814

Matfield Village Hall Management Committee

Comment upon Policy AL/BM 3 the nearby Ashes Plantation, Cfs reference Site 353.

Para 5 ; Contributions (50%) towards the provision of pedestrian access to the existing children’s play space at Maidstone Road:

We do not believe there is such an existing Children’s Play space at Maidstone Road, nor anywhere in Matfield.

DLP_7026

Sheena Colville

At this site the proposed access is through the narrow cul de sac (Oakfield Road) of approximately 40 houses, with significant on street parking. With 60 new homes I am concerned about the safety as there could be another 100 cars using this road - with all the cars wanting/trying to exit onto the Maidstone Road. There is a single car width access to the proposed site which even if this is widened (losing some Town + Country Housing Association propoerty (affordable flats!) would not add width to the cul de sac. Parking is a premium in this road (I live in the road and thus have experienced the problem).

Also this proposed site is within the AONB, adjacent to Ancient Woodland, and would have considerable adverse impact on the abundant existing wildlife. Development of this site would be contrary to paragraph 171 and 172 of the N.P.P.F. It is also in conflict with Environment and Design Policies EN14, EN15 + EN21

DLP_7154

Patricia Stevens

Policy Number: STR/BM1 (AL/BM1, AL/BM2, AL/BM3, AL/BM4)

The development proposed for Matfield is out of all proportion to the present size and character of the village, and should not take place. Moreover, the Plan does not include the Rydon Homes development already underway.

Matfield is in the High Weald Area of Outstanding Natural Beauty, and the sites are all on undeveloped land. The Council has a statutory duty to conserve and enhance the natural beauty of the High Weald AONB and the National Planning Policy Framework states that great weight should be given to conserving AONBs. The LDP does not do this.

Furthermore, it is quite wrong for the Limits to Built Development to have been changed to accommodate these sites, as the Limits should protect the village from intrusive development and prevent the sprawl of the village into surrounding countryside.

There is an increasing need to preserve the countryside and open spaces to mitigate climate change, rural areas being a vital resource for carbon sequestration, and to promote people’s health and well-being. Instead, housing development on brownfield or infill sites, and re-using empty buildings should be reconsidered.

The proposed development is economically, socially and environmentally unsustainable. Matfield has limited infrastructure, services and amenities. It has no school or playground and no GP or Dentists surgery. Employment opportunities are limited. Public transport is limited and there are no safe walking routes from Matfield to either Brenchley Primary School or to Mascalls Academy in Paddock Wood. Together, these factors mean that the proposed housing development could only increase car use, with the resultant adverse effects of noise and air pollution as well as danger to the public and wildlife.

I live on Gedges Hill (on the B2160), and experience its traffic problems daily, I am particularly concerned about the impact this development would have on the road network, traffic volume and highway safety. The B2160 already has a high volume of traffic, especially at key times in the mornings and evenings. On Gedges Hill there is no pavement and often no space for pedestrians at either side of the road. There is a too high 50 mph speed limit, despite houses on both sides of the road and dangerous bends. Thus, it is too dangerous for pedestrians, especially for children from Matfield to walk to and from school in Paddock Wood.

The enormous housing development planned for Paddock Wood can only mean a further increase in traffic – from Matfield and Brenchley down to Paddock Wood’s secondary school, mainline station, shops and services, and up from Paddock Wood through Matfield to the A21 and the South Coast. Consequently, these housing developments already approved and underway will increasingly have an adverse impact on traffic volume, highway safety, and air and noise pollution.

The proposed development is economically, socially and environmentally unsustainable. Matfield has limited infrastructure, services and amenities. It has no school or playground and no GP or Dentists surgery. Employment opportunities are limited. Public transport is limited and there are no safe walking routes from Matfield to either Brenchley Primary School or to Mascalls Academy in Paddock Wood. Together, these factors mean that the proposed housing development could only increase car use, with the resultant adverse effects of noise and air pollution as well as danger to the public and wildlife.

I live on Gedges Hill (on the B2160), and experience its traffic problems daily, I am particularly concerned about the impact this development would have on the road network, traffic volume and highway safety. The B2160 already has a high volume of traffic, especially at key times in the mornings and evenings. On Gedges Hill there is no pavement and often no space for pedestrians at either side of the road. There is a too high 50 mph speed limit, despite houses on both sides of the road and dangerous bends. Thus, it is too dangerous for pedestrians, especially for children from Matfield to walk to and from school in Paddock Wood.

The enormous housing development planned for Paddock Wood can only mean a further increase in traffic – from Matfield and Brenchley down to Paddock Wood’s secondary school, mainline station, shops and services, and up from Paddock Wood through Matfield to the A21 and the South Coast. Consequently, these housing developments already approved and underway will increasingly have an adverse impact on traffic volume, highway safety, and air and noise pollution.

DLP_420

Rona Hogan

Object

Comments on Map 76 Policy

Whilst this is the smaller of the four developments, the area is AONB and should be protected the comments referred to above on the other 3 developments are relevant to this development.

Final comment

TW Council is using rural villages including Matfield to dump their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the borough on brownfield sites (which the plan does not detail what has been reviewed) or placing small developments directly off of the A21 avoiding congestion in the small villages which will be unable to cope. The expected contributions will not mitigate the impact of the 4 developments proposed on Matfield, as the doctors in Brenchley have stated they cannot cope with any more patients and the landscape and rural feel of Matfield will be lost for future generations.

DLP_1217

Claire Sandford

Object

With respect to site 401: AL/BM4. I would like to bring to your attention a deed of covenent dated 20 July 1998 that exists over a significant part of the proposed development site which prevents development of the covered part of the site for anything other than equestrian or domestic shelters. Therefore, residential development would not be able to be undertaken for most of the northern part of the site.  The deed of covenant is registered at HM Land Registry under title number K805433.

DLP_874

Nick Tester

Object

Tunbridge Wells Borough Council Local Plan and its disastrous implications for Matfield and surrounding area.

1. BM3 is situated in the orchard of Ashes Plantation with a proposed 30-60 new dwellings, the only access proposed is through Oakfield Road, which seems a crazy idea. Oakfield Road has an historical acute parking problem that means this road is in effect a one lane road and not a two lane. Therefor emergency vehicles and/or large vehicles would more than struggle to gain access to properties down Oakfield Road and into BM3. Local residents will be fuming with their Local Councillor’s, because residents will have to park somewhere. It’s very difficult to exit a vehicle onto Maidstone road from Oakfield Road at present due to the already high volume of traffic passing between Kipping’s Cross and Paddock Wood. With a further potential of 50-60 vehicles from BM3 plus vehicles from all the other future proposed housing sites it would be nigh on impossible. I can see nothing but trouble in Oakfield Road with all the extra vehicles generated by BM3. Especially from BM4’s access that is almost opposite Oakfield Road’s exit onto Maidstone Road and on a dangerous bend? Plus, all the other TWBC Local plan developments all using Matfield as the link to the A21 and Paddock Wood.
2. The main bottle necks will be “Kipping’s Cross” and the cross-roads at “The Poet” plus all the future accesses to and from all the new Matfield developments. The cross-roads junction at Maidstone Road, Brenchley Road and Chestnut Lane will be under enormous pressure from the Island Site (BM1), the Rydon site, with 22 new homes already under construction and from BM2 off Chestnut Lane plus Paddock Wood and Capel 4000 homes and Tudeley 2500 homes, a complete nightmare!
3. Also, the access that is shown on Map77 policy AL/BM3 shows the red line passing through half of one block of flats in Oakfield Road to allow for access widening of the garage access road. One can only assume, that half a block cannot be removed therefore the entire block would have be demolished losing four dwellings, rendering the occupants homeless. Not good news.
4. The Green space /recreation/amenity area on map 77 looks ok on paper but there is a “badger’s clan set” in the gully on the side banking of the green area. This set produced four healthy cubs this year and these badgers can be seen most evenings feeding up through the orchard of BM3. The green space proposal will greatly curtail their feeding range, if not frighten them away all together! Plus, the noise level will increase due to children and youths playing in the green space, extra dogs barking, the playing of loud music, extra cars causing extra pollution and more light pollution i.e. no dark skies. Please note, It is an offence to intentionally damage, destroy or obstruct the access to a badger’s set. Most in danger are the woodland owls, bats, small rare birds, frogs, butterflies, hedgehogs and birds of prey that we enjoy, all in the south end of “Church Wood” at the bottom of BM3. These animals are obviously finding small mammals to feed on, but with extra cats arriving in BM3, in future small mammals will be in short supply? All these new problems will have such a huge negative impact on the existing wildlife and destroy a unique habitat.
5. There is no mains gas supply in “Matfield” and all new homes will have to be heated, either by oil, electricity, gas cylinders, log burners or solid fuel? All these fuels will create a lot more CO2 pollution that will add to climate change and act against the environment!
6. Services for Matfield are almost non-existent, i.e. no School, no Doctors, no Dentist, no shop, we have a mobile Post Office three days a week but it’s not always working, we do have a very good Butchers. All the services are in Brenchley. There were 24 sites proposed for Brenchley and Matfield with plans for 91-150 homes. But it’s Brenchley who has all the services i.e. Doctors surgery, primary School, Dentist and full time Post Office and shop but have had none of the proposed new housing developments. This also means Matfield residents young and elderly will definitely require transport to visit these services?
7. Visiting Tunbridge Wells or Tonbridge for shopping will be a thing of the past, due to the traffic bottle necks and jams! Trying to visit Tunbridge Wells shops at present is difficult enough. The High Street shops will suffer even more than before with these new developments. Good job we have the online shopping option to fall back on, although the deliveries may take extra time to get through. Assuming you and your vehicle made it to the town, parking would be much more difficult, Car parking charges are not very welcoming either.
8. Any new development should aim to enhance the villages, minimise the impact and not destroy their uniqueness for future generations. In-essence, these proposed new developments are far too large for such small villages.
9. The infrastructure, especially the extra water, electricity and sewage used will all have to be increased. The fact that a high acreage of land will be built on, means rainwater will not be able to be soaked up so naturally, in these areas, therefore there is a higher risk of flooding i.e. the water will have run off to somewhere. The orchards of BM2 and BM3 will lose hundreds of their apple trees. Trees that soak water and take CO2 from the atmosphere and give back oxygen in return, are good for the environment and Global warming.
10. The smaller Villages seem to be acquiring all the new housing estates while Paddock Wood is getting all the extra goodies in the form of new facilities.
11. On Map 76, the access to and from BM2 is opposite Wish Courts access road and is possibly not the best outcome to gain access to BM2 as it makes a new crossroads. It’s also a very narrow access. The fact that the new proposal would mean just about every house along Maidstone Road and Chestnut Lane (about 20 houses) will have their light and view blocked. Plus, there’ll be a lot more noise emanating from the new housing estate and yet more light pollution. If these houses were re-situated in the Green area of BM2 close to and along Chestnut lane, then only two houses could possibly see the new development and then only at some distance.
12. The road systems around the Tunbridge Wells and Tonbridge area are mostly narrow and full of dangerous bends, therefore an increase in accidents will occur around our villages. Unless the roads infrastructure is greatly improved. Due to the double roundabout at Kipping’s Cross there are traffic holdups every day at present at busy times and it will get a 100% worse, if these developments go ahead.

DLP_894

Mr Peter Coombes

Object

These two specific sites in the proposed Draft Plan will directly affect us and other residents on Maidstone Road. These proposed sites are situated to the front and rear aspects of our properties.

AL/BM4

This site is directly across the road from our property and it borders Maidstone Road. It is outside the line designated for the Proposed Limits to Built Development STR 10. It would appear however that BM4 is exempt from this limit as it is a proposed low-density scheme. I cannot see the point of establishing a building limit and then allowing small developments to grow outside that limit. This site is totally unsuitable for development and I object strongly to it being included in the Draft Plan. The site will affect all residents on Maidstone Road, spoil current views and remove an area of green space surrounding Matfield. It is positioned on a bend in the road coming into the village past the site to the Village Hall. It is just within the 30mph limit and traffic coming from Pembury on the straight stretch of road into the village are still travelling at speed past this site. It is already difficult to exit the Village hall and turn right as you cannot see the fast-moving traffic. It is even more treacherous to cross the road on foot from the village hall due to traffic approaching from the right. The side of BM4 fronting the road has old well-established high hedges which are home for much wildlife including many nesting birds. Any interference with these hedges would totally spoil the view coming into the village. A large section of this hedge would need to be removed to give adequate sight lines due to the curve in the road. There are walks and footpaths in the fields around this site and development would further encroach into the green areas surrounding the village.

DLP_951

Mrs Karen Stevenson

Support with conditions

Policy AL/BM 4 –Land at Maidstone Road (behind and to the left of the village hall). Allocated for residential development (C3) of approximately 11-15 dwellings and additional car parking for the village hall. Residential units to be sited on the southern area of the site. Pedestrian access through the site to children’s play space. Contributions (50%) towards the installation of speed sign with number plate recognition facility on agreed location on Maidstone Road. Contributions (50%) towards the provision of pedestrian access to the proposed development at Ashes Plantation (AL/BM 3).

This site is again outside the existing LBD and strangely remains outside the proposed re-drawn LBD in the draft plan. The fact it can be directly accessed from the B2106 main road,  will be hidden behind the existing high hedgerow and is only 11-15 homes, again makes this more acceptable proposals than BM1 or BM3. Again, the lack of services and facilities in Matfield remain an issue as does the previously mentioned inadequate highways infrastructure.

DLP_1378

Claire Sandford and Andrew Peaple

We are writing with respect to the proposed development of the Land at Maidstone Road behind Matfield Village Hall, which has been suggested as a possible site for development under TWBC's plan (site 401 AL/BM4 in the draft plan for Matfield sites).

We are the owners of Matfield Court and would like to draw your attention to a covenant dated 20 July 1998 which is registered at HM Land Registry under title K805433. The terms of the deed of covenant prevent the development of a significant part of the proposed development site.  The affected plot of land is currently included in the proposed development area, it forms approximately 50% of the proposed site for development. Therefore this covenant would prevent any residence being able to be built on the affected land.

We attach the covenant and also the land registry to which the covenant belongs. In the covenant the land hatched purple (identified with the number 8) forms part of the deed and per para 6c) there is a covenant 'not to construct any buildings other than equestrian or domestic shelters on the land hatched purple and the land coloured yellow on the plan.'.

Please take this into account when considering the development plans for the land and ensure there are no plans to develop the land over which the covenant exists.

[TWBC: see Land Registry document and Covenant].

DLP_2104

Terry Everest

Object

Strongly Object

Site is full of trees, we need every tree we can get to fight climate change and preserve our environment. Cannot be supported.

DLP_3335

Kent County Council (Growth, Environment and Transport)

Support with conditions

Highways and Transportation

The Local Highway Authority conditionally supports this policy. The following changes are requested:

Paragraph 1 – “Vehicular access into the site to be informed by Transport Assessment, to include assessment of junction of Maidstone Road/Oakfield Road, including assessment/construction of pedestrian crossing points”

Points 3, 4 and 5 should be removed. The Transport Assessment will highlight specific mitigation measures: should not be pre-empted at this stage.

The standard paragraph regarding contributions should feature in this policy - It is expected that mitigation measures will be implemented by the developer. A contribution may be taken if appropriate

In Point a – reference to traffic calming should be removed

Heritage Conservation

Scale 4 - Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval.

Potential for remains associated with post medieval activity

DLP_3573

Barton Willmore for Clarendon Homes

Support with conditions

Clarendon Homes, as promoters to this site, broadly supports this policy as including the objective of securing approximately 11 – 15 dwellings at the site and additional car parking provision for the adjacent village hall. Clarendon does however make the following representations concerning the site:

1. Quantum of Development

Clarendon considers that the site is able to accommodate a greater level of development than that allocated in the Draft Local Plan. The site extends to 1.6 ha and the allocated amount of development would therefore result in a density of c. 8 – 11 dwellings per hectare.

Notwithstanding the rural nature/village character of Matfield, the proposed density is considered to be low and draft policy H4 (Housing Density) is clear in that development shall be delivered to appropriately high density having regard to its context, including landscape, topography, surrounding built form, and any other relevant factors.

Draft policy H4 goes on to note that planning applications will be refused where development is not found to make efficient use of land. This objective is in accordance with the National Planning Policy Framework 2019 (Section 11 – Making Effective Use of Land) which seeks for development proposals to make optimal use of land.

Clarendon has undertaken numerous background surveys for the site including landscape/visual, heritage, ecology, arboriculture and highways and these surveys have informed emerging development proposals for the site.

In this regard, Clarendon considers that the site is capable of accommodating up to c. 30 dwellings whilst having regard to/respecting the character of the area and the local context. This level of development could also include the additional village hall car parking and would make a more meaningful contribution to the Council’s housing supply and mix.

The Draft Local Plan seeks to make provision for a total supply of 14,776 units up to 2035/36. As against the Government’s current requirement during the same period (13,560 units) this amounts to a 9% uplift on the housing need.

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, Matfield is identified for development of c. 91 – 150 dwellings during the Plan period. Within this quantum, Ashes Plantation (AL/BM 3) is allocated for c. 30 – 60 units and thereby an average of 45 units for this site is used in the housing supply for the Local Plan.

We do not dispute this approach however it may be the case that the Local Plan does not achieve the full anticipated levels of growth. Increasing the quantum of development on this site (and potentially others) would enable the Council to achieve a higher buffer and thus provide for more flexibility in the market for new homes. We would therefore recommend that the policy is amended to “providing approximately 30 dwellings”. Moreover, we consider that the Local Plan should be seeking to achieve a housing supply buffer closer to 20% and increasing the quantum of development at the site would make an important contribution in this regard.

2. Policy Criteria

Criterion 1 (“Permeability to children’s play space”) – This criterion requires pedestrian permeability through the site “to the children’s play space”. We consider that this criterion is written in error as there is no children’s play space adjacent the site. It is therefore recommended that this element of the policy is deleted.

Criterion 6 (Village Hall car parking) – This element of the policy requires the provision of additional public car parking to serve the village hall and for it to be sited in the northern area of the site.

As above, Clarendon does not object to this, however, Clarendon considers that the delivery of the car park should be borne from planning obligations from this and other development sites in Matfield. In this scenario, Clarendon would make the land available for car park use.

Moreover, Clarendon considers that flexibility should be allowed for in case there is a more suitable part of the site (not exclusively the northern part of the site) whereby the additional car parking can be provided.

It is therefore recommended that the criterion is amended as follows:

“Land for the provision of additional public car parking to serve the village hall and proportionate contributions towards the delivery of such car parking”.

Having regard to the above, it is also advised that criterion 10 is deleted to afford flexibility in terms of the location of the car park.

Criterion 3, 4 and 5 (Planning Obligations) – These criteria refer to a number of contributions being sought from development at the site and being directed towards:

3. Contributions towards an assessment of traffic to inform a scheme of potential traffic calming measures;

4. Contributions (50%) towards traffic calming measures; and

5. Contributions (50%) towards pedestrian access to Ashes Plantation.

For criteria 4 and 5 above, it is not known as to what the 50% represents and this needs to be clarified/made effective. Should this relate to 50% as aligned with other developments, this should be reduced as the site results in significantly less than 50% of the total allocated growth for Matfield.

For each of the criteria above (i.e. 3, 4 and 5) we would therefore recommend that the policy is amended to state “Proportionate contributions towards….”

Criterion 7 (and others) – The policy also refers to contributions towards:

- Improvements to existing allotments, amenity/natural green space, parks and recreation grounds, children’s play space and youth play space (Criterion 7);

- Improvements to bus provision; and

- BT fibre upgrade/mobile reception upgrade.

Clarendon does not necessarily object to the principle of these provisions, however the contributions to be made from the site must be (as per NPPF – para 56):

- Necessary to make the development acceptable in planning terms;

- Directly related to the development; and

- Fairly and reasonably related in scale and kind to the development.

DLP_4048

Philip Bilney

Object

The comments below concern the land at Maidstone Road behind Matfield Village Hall which has been suggested in the Local Plan as a possible site for development (Cfs Reference: Site 401).  For your information the below comments have also been sent to Brenchley and Matfield parish counsel on 12 October who have also raised concerns separately.

By way of background we live at Little Court which is directly next to the proposed site.  We, along with our neighbouring properties East Court and Matfield Court (the “Properties”), are concerned by the development proposed on this site.

We object to the proposed development on the site for the following reasons:

1. The Properties enjoy a number of legal rights which are contained in a number of deeds of covenants and other agreements with the “Carters” who I believe are the current family which own the site. We can happily provide copies of the deeds of covenants if required.  In summary these rights provide a number of obligations and restrictions on development which interplay between the Properties and impact on the site.  The rights these properties enjoy particularly affect the area of the site which is nearest to the properties and adjacent to the Village Hall (currently shaded on the site as “Community Uses”).  Development of the site cannot occur until these rights and obligations have been analysed and (where necessary) complied with.
2. Loss of visual amenity and other related issues.  There are a number of mature trees and other plants which need to be kept “as is” to maintain the current wildlife, scenery and heritage.  This is especially important bearing in mind the site is next to the Conservation Area which requires strict control.
3. Increased  traffic and noise pollution.  Access to the site is in the Northern corner. This would mean all traffic to the site would need to go through that one access point which runs parallel to the back of the Properties thereby impacting on their gardens and their quiet enjoyment of them.
4. Impact on current anti-social behaviour issue.  The existing Village Hall car park already has an issue with youths “hanging about” and playing loud music.  We, along with others, have made a number of complaints to both the police and the council.  By extending the parking at the Village Hall, particularly round the back of the Village Hall as we understand is currently being proposed, is likely to lead to an increase in such anti-social behaviour.

DLP_6813

Matfield Village Hall Management Committee

Specific Comment upon Policy AL/BM 4 “Land at Maidstone Road, 

Cfs reference; Site 401”

MVH MC are interested to see that this plot which adjoins the MVH on 3 sides is under consideration and in principle may welcome improvements to the site.

To date TWBC have made no contact with MVH MC to discuss future requirements of this important Community Facility.

The Hall has been left short of information in what is obviously an important possible development for them.

However;

A. Increased and better parking for the use of Village Hall users would be most welcome.  Contributions as to how this might be funded are not clear in the policy.

B) Much more open green space to the West of existing hall would enable the hall to better host such activities as children’s outdoor activities, croquet, bowls, garden for summer receptions etc.

C) The areas to the North of the site could provide a Children’s playground to link in with the Parish Council owned triangle west of TWBC Toilets.

D) The built security of the hall must be considered carefully if any part of the site is to be used to access the residential development. Security of the Hall is paramount as there is no permanent staff on site to guard against vandalism, which from time time sadly does occur.

E) No objection in principle to the 11-15 dwellings to the South provided they are well spaced,  have respect for the sylvanian character  of the land, have more than adequate parking independent of the Hall, and are affordable by local parishioners.

In fact it could re-create the scheme abandoned by TWBC 25 years ago.

It is not clear from the Policy where the vehicular and pedestrian access to Maidstone Road might be located.

The existing access / egress of the Hall onto B 2160 has its vision splay to the South compromised by the large hedge overhanging the KCC verge.

F) Some traffic calming may be welcome however humps would lead to increased noise and air pollution.

G) It is not clear what Policy item 5 requiring pedestrian access to Ashes Plantation is for? 

However if it is for a pedestrian crossing from the MVH over B2160 to the east side of Maidstone Road this could be most welcome for bus users and many other pedestrians trying to cross the busy road.

DLP_7155

Patricia Stevens

Object

Policy Number: STR/BM1 (AL/BM1, AL/BM2, AL/BM3, AL/BM4)

The development proposed for Matfield is out of all proportion to the present size and character of the village, and should not take place. Moreover, the Plan does not include the Rydon Homes development already underway.

Matfield is in the High Weald Area of Outstanding Natural Beauty, and the sites are all on undeveloped land. The Council has a statutory duty to conserve and enhance the natural beauty of the High Weald AONB and the National Planning Policy Framework states that great weight should be given to conserving AONBs. The LDP does not do this.

Furthermore, it is quite wrong for the Limits to Built Development to have been changed to accommodate these sites, as the Limits should protect the village from intrusive development and prevent the sprawl of the village into surrounding countryside.

There is an increasing need to preserve the countryside and open spaces to mitigate climate change, rural areas being a vital resource for carbon sequestration, and to promote people’s health and well-being. Instead, housing development on brownfield or infill sites, and re-using empty buildings should be reconsidered.

The proposed development is economically, socially and environmentally unsustainable. Matfield has limited infrastructure, services and amenities. It has no school or playground and no GP or Dentists surgery. Employment opportunities are limited. Public transport is limited and there are no safe walking routes from Matfield to either Brenchley Primary School or to Mascalls Academy in Paddock Wood. Together, these factors mean that the proposed housing development could only increase car use, with the resultant adverse effects of noise and air pollution as well as danger to the public and wildlife.

I live on Gedges Hill (on the B2160), and experience its traffic problems daily, I am particularly concerned about the impact this development would have on the road network, traffic volume and highway safety. The B2160 already has a high volume of traffic, especially at key times in the mornings and evenings. On Gedges Hill there is no pavement and often no space for pedestrians at either side of the road. There is a too high 50 mph speed limit, despite houses on both sides of the road and dangerous bends. Thus, it is too dangerous for pedestrians, especially for children from Matfield to walk to and from school in Paddock Wood.

The enormous housing development planned for Paddock Wood can only mean a further increase in traffic – from Matfield and Brenchley down to Paddock Wood’s secondary school, mainline station, shops and services, and up from Paddock Wood through Matfield to the A21 and the South Coast. Consequently, these housing developments already approved and underway will increasingly have an adverse impact on traffic volume, highway safety, and air and noise pollution.

The proposed development is economically, socially and environmentally unsustainable. Matfield has limited infrastructure, services and amenities. It has no school or playground and no GP or Dentists surgery. Employment opportunities are limited. Public transport is limited and there are no safe walking routes from Matfield to either Brenchley Primary School or to Mascalls Academy in Paddock Wood. Together, these factors mean that the proposed housing development could only increase car use, with the resultant adverse effects of noise and air pollution as well as danger to the public and wildlife.

I live on Gedges Hill (on the B2160), and experience its traffic problems daily, I am particularly concerned about the impact this development would have on the road network, traffic volume and highway safety. The B2160 already has a high volume of traffic, especially at key times in the mornings and evenings. On Gedges Hill there is no pavement and often no space for pedestrians at either side of the road. There is a too high 50 mph speed limit, despite houses on both sides of the road and dangerous bends. Thus, it is too dangerous for pedestrians, especially for children from Matfield to walk to and from school in Paddock Wood.

The enormous housing development planned for Paddock Wood can only mean a further increase in traffic – from Matfield and Brenchley down to Paddock Wood’s secondary school, mainline station, shops and services, and up from Paddock Wood through Matfield to the A21 and the South Coast. Consequently, these housing developments already approved and underway will increasingly have an adverse impact on traffic volume, highway safety, and air and noise pollution.