Policy STR/CA 1: The Strategy for Capel Parish (part 2)

This response report contains comments received on Section 5: Place Shaping Policies – Capel section.

Contents

Policy STR/CA 1: The Strategy for Capel Parish

Comment No.

Name/Organisation

Response

DLP_5374

Angela Pattenden

I am strongly opposed to the draft local which includes the destruction of valuable green belt productive agricultural land for an unnecessary 2,800 home development being planned under a false statement that it is a Government policy requirement as confirmed by the CPRE of which I am a member. I have lived in the Tudeley for over 33 years and do not want this lovely hamlet and the broader parish of Capel destroyed for our future generations.

I wish to strongly object to “The Strategy for Capel Parish” (Policy STR/CA

I am a senior citizen and have lived within the area for over 30 years. I have been privileged to enjoy this beautiful countryside with my family, walking our dogs along the many footpaths which cross the open landscape. I am strongly against this beautiful green belt agricultural farmland being considered in a plan to be destroyed in order to build a new town, roads and associated civic amenities.

I believe a so called “garden settlement” at Tudeley of 2,800 dwellings is inappropriate and does not follow the principles of garden settlements as defined by the Government. Additionally the settlement will be divided into two by the main line railway. There would be a significant increase in traffic into Tonbridge along the B2017, exacerbating the current extreme traffic congestion that exists on this road every morning and evening. The additional traffic will cause increased levels of air and noise pollution as the residents of this new settlement will want to use their private vehicles for the convenience of getting into their nearest town of Tonbridge, even with the proposed public transport bus link.

The major portion of the new housing will be taken up by people being drawn into the area as there would appear to be an excess of housing already available for local residents. Many of these people will be commuters who will want to travel to London on trains which are already at capacity. I therefore consider this proposal to build this new town on the Tudeley site to be unsustainable.

Destroying valuable good quality grade 2 and 3 agricultural farmland located in the middle of the Green Belt is irresponsible and must never be allowed under any circumstances. In fact I understand that the Government require there to be “exceptional circumstances” before green belt can be considered to be used for development. Doing so will deprive our future generations of this valuable and irreplaceable asset forever. Additionally, we must protect productive agricultural land to provide our food, also we need precious green spaces for our well-being both physically and mentally. Why destroy this important local precious asset just because it is an easy planning option for the council planners based purely on one land owner who is willing to sacrifice his heritage for financial gain.

At this stage there are no ideas what so ever being put forward for comment on infrastructure for roads, sewerage, water supply, gas, etc. All very “finger in the air” strategy which we are constantly being told is normal at this stage of the planning process and will be sorted out with a Masterplan. Yet other parts of the Borough have more details available for comment and already have some of the infrastructure in place. The Tudeley site is obviously a late addition to the process, being the easy option for 65% of the apparent local housing need, there are Brownfield sites within the Borough but these are not so profitable for developers or land owners.

The Police, Fire and Ambulance services are already at capacity and often overstretched and the proposed creation of a large new town will only make this situation even worse. Furthermore, health and dental services within the area, to accommodate the possible additional 9,000 to 10,000 extra people, will be passed on to the adjoining Tonbridge and Malling Borough council.

Climate change is occurring and the introduction of 2,800 new houses and the accompanying additional civic amenities will add to this global catastrophe, adding more carbon and reducing the carbon uptake of the land and associated flora and fauna. Also Tudeley is located on a floodplain with risk assessments based on old and out of date data; locating houses on a floodplain is irresponsible.

Due to the openness and topography of the area, the proposed dumping of 2,800 houses into this landscape will destroy this beautiful and historic part of your Borough, including AONB, heritage sites, listed buildings and traditional Kentish farmsteads. All Saints Church in Tudeley is the only church in the World to be the proud owners of Marc Chagall windows. These were commissioned by the Goldsmid family in tribute to their daughter who died in a tragic accident, and is buried in the family cemetery. People visit from all over the world to view these amazing windows and enjoy the wonderful views across the Kent countryside. No-one would want to view a housing development bordering the church graveyard.

This would appear not to bother the Council planners since we are far away and out of sight in the far outer reaches of the Borough. To move from one part of Tudeley to drive into Tonbridge or Tunbridge Wells for that matter, will involve crossing the railway line. I cannot imagine how this will be possible and I have extreme concerns that the private cemetery belonging to the Goldsmid/Teacher family will be adversely affected as the bridge on Hartlake Road borders the cemetery and the road is only single track. Will the family no longer be allowed to “rest in peace” ? The railway bridge over Sherenden Road is also on a single track road. How can this be changed without destroying peoples homes , not to mention Bank Farm with its state of the art equestrian centre, carefully planned paddocks for the many horses and the livelihood of the people who run the entire centre, and not least the children and adults who enjoy the outdoor life with their horses and ponies. If there are plans to remove this centre it would be complete vandalism and heartbreaking for many people.

Being a rural area, Tudeley is blessed with a diverse and important list of birds and wildlife, many on the European list of protected species and some endangered such as Bats, Great Crested Newts, Turtle Doves and field nesting birds such as Skylarks, Linnets and Yellowhammers. This legacy cannot be just brushed aside by statements that they will be re-located to somewhere else, this is wishful thinking and a complete fantasy. The birds and wildlife will just decline in numbers and finally disappear into extinction. Ancient and old woodlands along with beautiful hedgerows will also disappear and leave a baron and lifeless landscape devoid of wildlife, is this something the Council will be proud to leave as a legacy for the future?

In summary, this proposed new town plan has been ill thought through, in indecent haste without any regard to the needs of the community of Capel and future generations who desire to live in this rural parish. There are other alternatives that should have been discussed and considered, but the so called responsible officers of the Council hastily “nodded through” this unacceptable scheme without question and in a dismissive way. Furthermore, the consultation response process has been made impossibly difficult, especially to an elderly person such as myself and many others like me. How can this be a democratic, fair and open process?

DLP_5376

Alan Powell

I live on the Somerhill Green development, off the A26 (Woodgate Way) and I am writing to strongly object to "The Strategy for Tudeley and Capel Parish" (Policy STR/CA1).

Creating a garden settlement of 2800 residential dwellings at Tudeley will cause immense harm not only to the existing residents of the Parish of Capel but also to the residents of Tonbridge and in particular residents of Somerhill Green. There will be a significant increase in traffic into Tonbridge from the B2017 (Tudeley Road). This road is already heavily congested, particular in the mornings and late afternoons. This makes it very difficult to leave the Somerhill Green site onto the A26 via the roundabout. This is the only vehicle access into and out of Somerhill Green residential development and The Bishops Chavasse primary school. The A26/B2017 roundabout on Woodgate Way is difficult for traffic to enter due to its layout. There is a blind spot when leaving the residential/primary school developments and you cannot see traffic coming from the Vauxhall roundabout until the last minute. The construction of yet another school in this area is a recipe for disaster. It would appear to be a terrible location for a school, surrounded by heavy traffic and requiring children to walk along and cross busy roads on all sides.

Many of the people living in the new houses will use Tonbridge Railway Station for commuting, where will they park ?. The additional traffic will be more than the roads can cope with. The towns roads are already full at peak times, the trains are already packed. With 2800 houses at Tudeley and a further 1500 at East Capel it could mean up to 8600 additional cars on the narrow lanes. I don't believe this proposal is sustainable. There will also be a big impact on health services and other amenities in the Tonbridge area.

Concreting over farmed fields will have a large impact on flood risk. Much of the Medway floodplain will be lost. I believe that flood risks will increase. The developments will make the Medway more likely to flood more often and cause increased flood risks in the whole area of Tonbridge to Yalding.

Creating such a large development and destroying so much Green Belt land will kill wildlife and ruin the habitat for many others, with increased noise and light pollution. We should be protecting our woodland, hedgerows and the environment. Future generations will not thank you for vandalising the countryside.

I would ask you to please think very carefully before adopting this environmental unfriendly plan. Destroying 600 acres of pristine Green Belt, teeming with wildlife and rich biodiversity is not in keeping with todays thoughts for reducing climate change and helping to protect our planet for the children of the future. There must be a better way forward, what about all the empty property in the borough and brown field land left vacant ?.

DLP_5377

Jo Briers

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

People living in Tudeley will use Tonbridge Station for commuting and Tonbridge town services that will need more parking. The increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times and can’t be made wider in most places. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable. Parking in and around Tonbridge Station will be even more difficult. Network Rail have confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. Most people living in the new garden settlements will drive privately owned cars, despite initiatives to encourage bus and bicycle use. The costs of infrastructure on the Tonbridge & Malling side of the boundary will have to be carried by Tonbridge & Malling residents whilst Tunbridge Wells will receive council tax from the residents in the new dwellings. The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area. There will be an increase in pressure on Tonbridge health services, amenities and car parking as residents from the new garden settlement at Tudeley will use Tonbridge as their local town, not Tunbridge Wells, because Tonbridge is much closer.

As a resident of Tonbridge this increase in pressure on local services will be both unsafe and unsustainable.

Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but I believe that flood risks will increase. Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding. There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape. Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saint’s Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. That will cause great harm to its value as a heritage asset of world renown (due to the complete set of Marc Chagall windows)

The garden settlement at Tudeley can never be one settlement as it is divided by a railway line that has very narrow, weak crossings. Putting in larger crossings at frequent points across the railway may be possible but it won’t tie the two halves of the settlement together enough to make it one settlement, so it will never satisfy garden settlement principles.

I believe that housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan. TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant.

The plan preparation process didn’t include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan didn’t go through most of the plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment, no Biodiversity Assessment. I think that this version of the draft Local Plan isn’t complete enough to be ready for public consultation when the land for such a big proportion of the housing hasn’t had the same level of assessment as the rest of the plan. The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they didn’t know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. I think that the plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough.

Earlier in the plan (in 4.40) you refer to Tudeley Village securing a long term option for the borough to deliver the needs of future generations. It is clear from this statement that you intend to add more and more housing to this “garden settlement” in each five year review of future Local Plans. I think that TWBC want to fill Tudeley and East Capel with housing until they coalesce with Tonbridge to the West and Paddock Wood to the East, ultimately creating a massive conurbation that will dwarf Tunbridge Wells town centre. TWBC is using Capel to dump their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the borough on brownfield sites or placing the garden settlement in the middle of the borough, to make it accessible north and south. The developments in Tudeley and East Capel are unsustainable and place huge pressure on Tonbridge.

DLP_5380

Tim Winter

I am a resident of Golden Green, a hamlet that enjoys great surrounding countryside, riverside walks and big skies. My family and I chose to live here eight years ago to benefit from the country life.

I am appalled by the proposed developments for the building of over 4,000 new homes at Capel. This is green belt land, which I understand to be protected from such ruin. This is a proposed development that would serve only to line the pockets of the few, at the great personal expense of the many.

I am not opposed to new housing in the area: there is space to accommodate some small developments, and I know that research carried out by “Save Capel” has highlighted many, many brown field sites for development. These are more costly to develop than one large monstrosity, meaning lower profits for developers. The plans for Capel make no provision for suitable infrastructure improvements: the main road through Tudeley/Capel is already at capacity at rush hour, with single lane access past the the primary school, and bottlenecks at the junction with Tudeley Lane (near The Poacher and Partridge Pub) as well as the main roundabout by The Schools at Somerhill. To suggest a secondary school could be sited at this roundabout to accommodate the additional burden is utterly pathetic. The site is miles from Tonbridge Station, has very few bus routes passing through it, and is hard to access due to the already heavy traffic flow.

There are no “green” credentials to the proposal. New build house developers must have a responsibility to provide suitable energy conservation measures to new buyers. This area is no stranger to flooding, and the laying down of vast paved areas will only serve to exacerbate this issue.

Tunbridge Wells Borough Council have pushed this development to an area that is “out-of-site and out-of-mind”, right on the extremity of their border with Tonbridge Council land. The impact on Tonbridge town centre will be far, far greater than that on Tunbridge Wells. It will be “our” problem, not “theirs”. The land owner providing the land for this development should be greatly ashamed. Yes, his pockets will be well lined, but his gain should not be at the expense of all other local residents.

Please drop these plans: they are not fit for purpose.

DLP_5381

Ginny Stennulat

Please reconsider your plans. I live in Tudeley Lane so will be affected by the developments. My husband travels to London on an already packed train. The car and people congestion in the area is already appalling. Every morning I get stuck in traffic trying to get out of Tonbridge, then when returning home at 4 its just the same. Also the wild life will be destroyed.

DLP_5383

Mark French

I live in Tunbridge Wells north near High Brooms station and my children attend local schools in the borough. My son is at The Skinners' School and my daughter is due to transfer to secondary school in September.

My address is xxx TN4 [TWBC: full address redacted].

My comments refer to Tudeley and Capel draft local plans. STR/CA1 and STR/PW1.

My concern is regarding the road infrastructure locally. I used to work in Hadlow and drove the A21 and Hartlake Road each day on my commute. The roads suffer congestion by Somerhill School and i feel that a new secondary school by Woodgate Way is needed but a new relief road would be required and dual carriageway ideally. I also feel that the railway bridge on Hartlake Road needs widening and a roundabout on Tudeley Road/Hartlake junction. The A26 into the Tonbridge industrial estate would also need to be widened to include a bus/cycle lane. Tudeley Road should be expanded with a cycle way and a proper pavement/bridleway etc. the road is poorly lit and can be dangerous in bad weather.

Train services also need improving in the borough and Tudeley should get a new train station with this many new homes proposed in Capel and Tudeley. I use the trains most weeks to commute to London for business and i now tend to travel after 9.20 to get a seat at High Brooms. High Brooms is very busy but still has poor parking and poor access to the south bound platform. The station needs a car park second tier and lifts for disabled commuters. Toilets would also be good!

My final comment is that new houses and businesses should be built on the A21 bypass at Castle Hill. You have the old Balfour Beatty construction sites on each carriage way plus a new junction and are ideal locations for new homes and ideally some more businesses/offices. The old A21 Shell petrol station was never replaced and we need another service station on the A21. You have Kent College locally but we should also build another school near Knights Wood and Pembury hospital. SKA is full and that end of Tunbridge Wells does not have enough Secondary school options. All the schools are near St John's Road and causes congestion on the A26 every day. New houses should mean more jobs as well for local people and we do really need a better hospital at Pembury with more parking and more specialist services offered.

I appreciate we need new homes and more local businesses but roads and schools need to built first plus the hospital expanded in Pembury. Tunbridge Wells West station should be reopened and BML2 built to give another route into London each day.

DLP_5384

Pete Cowell

I am writing to object to the plans for what I consider to be very important reasons.

I consider that the plans will further create a contiguous development corridor from Tonbridge to Paddock Wood including Tudeley, Capel and Five Oak Green, eroding the rural nature of the area further still. This corridor will span both Tonbridge and Malling and Tunbridge Wells Borough Councils and therefore a bigger picture, wider consideration should be given.

Furthermore, the traffic impact of this proposed development will mostly be borne by Tonbridge Borough Council and in effect, Tunbridge Wells Borough Council are building as close to their border as they can to as best as possible mitigate the impact of such development on their own infrastructure. Again, I would consider that both council's ought to have a say in such a plan which may impact more on the council not proposing the development than the proposing council.

DLP_5387

Helen Rose

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

I live in Capel parish within 2 miles of the proposed site at Tudeley. I have chosen to live here for the past 12 years, to enjoy the peace, tranquility and open spaces that this area provides. I run a business from home that is dependant upon this quiet and rural environment.

I am firstly concerned by the destruction of Green Belt farmland and woodland In Capel parish. This area is rich in biodiversity with rare species and extensive wildlife in woodland and meadows. This should be protected at all costs.

The increase in traffic that the housing development and school will create, will exacerbate an already over burdened road network. The noise, pollution and congestion will be intolerable and make peak times unacceptably difficult to travel between the development and Tonbridge, forcing ‘rat runs’ through small country lanes like Half Moon Lane. We have just started to enjoy free flowing traffic and fewer accidents since the new A21 dualling section, only for congestion to return to the area with an influx of cars from 2,800 new homes. The impact on Half Moon Lane that the increased traffic from this proposed development would cause, is a major concern for me and the business I run.

The journey through Tudeley to Tonbridge station will be gridlocked at peak times, not to mention the inadequate parking at the station with so many more commuters. How is this going to be addressed? Parking generally in Tonbridge is not easy now, without additional residents and the impact of the new school..

There will also be an increase in pressure on Tonbridge health services, and amenities as residents from the new garden settlement at Tudeley will use Tonbridge, not Tunbridge Wells, because of its proximity.

I believe that housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant.

Large parts of the developments will be built on the Medway floodplain with flood risk increasing with climate change. I don’t believe this is suitable land for development

DLP_5389

Debbie Holsman

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel. The comment above about coalescence and the creation of a conurbation from Paddock Wood right across to Tonbridge is very relevant here, as is the land’s use as a flood plain. Building here, even with flood risk mitigation and “betterment” could have disastrous consequences for all, as the measures being looked at are based on old data that does not fully consider the impact of climate change.

DLP_5390

Diana Gibb

I am writing to you as a very long term resident of Tonbridge to express my extreme concern about the impact that your plans for vast areas of new housing very near to Tonbridge will have on my Town.

I really cannot imagine how you are of the opinion that this town can cope with more traffic on our already congested roads and how on earth will all these people reach the Station and park their cars. The extra traffic generated by the siting of your proposed Secondary School will also add to the Traffic problems causing longer jams on the already overcrowded roads leading into and our of the town

I am also concerned as to the impact on the local services, already we are threatened year after year with warnings of drought when there is low rainfall and in times of high rainfall many areas flood very readily and this will surely be affected by yet more concreting over of the countryside causing “run off” to low lying areas.

The local Hospital at Pembury is already overused and trying to park is very difficult, there are not enough doctors surgeries and even if more are built it is proving difficult to find enough doctors to work in them.

Waste from all these new households will be a problem too, the Local tip is extremely busy already and the introduction of the new recycling service has so far failed by a long margin to live up to the promises made to householders both in Tonbridge and Tunbridge Wells.

In all, I feel that this whole plan is badly thought out and possibly the only reason it is being considered by yourselves is because you only will have one Landowner to deal with making the whole exercise easy for you but with dire consequences for the general public.

DLP_5391

Andrew Thomson

Any large scale development within the catchment area of Tonbridge will damage the town due to traffic congestion accessing local facilities and the very high concentration of schools. Whatever facilities are built within these developments there will be a need to access the broader range of services a town like Tonbridge offers. I am therefore opposed.

I think there is some scope for developments that give access to a railway station in 15/20 mins walk. But the drastic reduction in bus services mean that an adequate service that would get people off their cars can be relied on.

DLP_5395

Tegan Bryant

Flooding - TWBC want to build on category 2 and 3a flood risk areas. Huge amounts of developers' money will inevitably be spent on flood mitigation, diverting funds from other essential infrastructure.

Biodiversity - wildlife and plants. Countless creatures will lose their habitat.

Roads - noise, cost, location and upkeep.

Green Belt land - an exceptional reason is needed to build upon it. Sevenoaks has already had its local plan rejected by the government due to this.

Wellbeing - The accessible natural green space standard (ANGSt) recommends that everyone should have accessible natural green space of at least 2ha in size, no more than 5 minutes' walk from home... The candidate local nature reserves, to the SW and E of PW will not meet this standard for those living in the NW of PW

TWBC already recognise that air and noise pollution is a downside to these developments. Light pollution will be a factor too (not just from street lamps, which will be low-pollution LED ones)

Heritage - building near historic buildings/features, e.g. some listed buildings will be surrounded by development areas

Transport - increased number of commuters, non-existent parking spaces, more dangerous parking in residential roads, not enough seats on trains (issue with length of platform so not able to just add more carriages)

Sewerage - Southern Water already over capacity; antiquated and mixed type infrastructure causing back-ups and flooding when it rains; all waste water coming through from Capel parish to PW's water treatment works in North-East Paddock Wood.

Education - Schools and transport to them (especially Tonbridge - e.g. Trains, Tudeley Lane) Also TWBC state that further education is covered in Royal Tunbridge Wells - it really isn't!

Agriculture - With TWBC's plan, a large amount of grade 2/3 land will be lost, including some of Ribena's blackcurrants - did you know that?!

Housing need and type - the latest calculations show that much less housing is actually needed (some sources have said it's almost half!) 'Affordable' housing is rated at 80% of market value - how many local people will actually be able to afford these homes? We believe these homes are being marketed to those in Greater London.

Health provision - Another GP surgery has been allowed for, but they do not take into account the lack of GPs in the NHS.

Police - Increase in population = increase in crime. TWBC want to double the population of PW so we should at least have a part time police presence. With the proposed demolition of the police station, we will have nothing.

Sports provision - A sports hub is planned for the NW side of PW, which floods. If TWBC/PWTC's plan for the Community Centre goes ahead, the PW Memorial Playing Fields will lose its cricket pitch. The tennis courts have already been closed 'for the Winter' as they are in bad repair and dangerous. Will they ever come back in to use?

Along with these issues that the local plan will cause, my home at the moment is in a rural area but with the proposed local plan, in the future my home will be surrounded by houses. This will not only make me feel unsafe but will also significantly decrease the house value, this is unacceptable.

DLP_5396

Adam Oliver

I want to object to development at capel as I feel it's to big a development for the area.

It's bad for the local infrastructure as that many houses will introduce at least double the number of vehicles to roads that struggle to cope as it is now.

The effect for Tonbridge is going to be more over stretched NHS services .

Environmentally it's not great as once that land is gone it will never be anything other than housing stock ever again.

DLP_5397

Jill Carr

We live on the outskirts of Pembury by Kent College and have been here for the last 14 years.

We are writing to object to ‘The Strategy for Capel Parish (Policy STR/CA1)

We feel that Tudeley is the wrong place for a garden settlement of 2,800 houses for a number of reasons:-

*The surrounding roads are already congested, the road to Tonbridge at school times, Colt’s Hill (although we do appreciate the plans for a new road are in place) the A228 into Tunbridge Wells is always busy. Half Moon Lane will offer a cut through from Five Oak Green/Tonbridge Road to the A21, this is a narrow lane with blind bends and passing places. It’s also next to the RSPB reserve and Tudeley woods/Pembury Walks, so often has hikers and dog walkers. It’s already used by parents at Kent College and is vey busy at peak times. It would become more dangerous with extra traffic.

*We agree with the Save Capel objections regarding the Green Belt, loss of agricultural land, biodiversity, wildlife, flood plains etc.

*The rail network would struggle with the extra commuters, as would Tonbridge with Parking.

*It’s nearer Tonbridge than Tunbridge Wells and therefore will impact on Tonbridge and Malling Council and residents

*It concerns us that the fact that the parcel of land is owned by one landowner has provided an easy option for Tunbridge Wells and the decision has been made for ease of acquisition, as opposed to finding more suitable areas in the borough.

DLP_5398

Pat Pelmore

I am writing to object to the proposed building of a vast number of new housing in the villages of Tudeley, Capel and Paddock Wood and fully endorse the objections raised in great detail by the SaveCapel group.

As a resident of Hartlake Road, Golden Green for the last 26 years these are my personal reasons:

This is a beautiful valley, green belt land bordering on an area of outstanding natural beauty. The green belt was specifically introduced to stop urban sprawl and the quantity of houses proposed on this green belt land is astronomical and there do not seem to be any grounds to request permission to build on this land other than that it is easy.
This valley is a flood plain and at least twice since we have lived here there has been major flooding across the whole valley – it is not called Hart Lake for nothing! Also in view of climate change and potentially rising sea levels, this whole area could become at risk.
Looking to the future, there is also the potential for water shortages if more and more houses are built in the driest part of the country and if climate change increases the likelihood of prolonged droughts. There are already times when water is in short supply.
Our local infrastructure cannot cope. Even now the country lanes are struggling with the rush hour traffic and there is already huge pressure on the roads around Tonbridge. A new secondary school opposite Somerhill and thousands of additional homes – each with at least 2 cars –will bring the whole area to a standstill.
It will just become more London urban sprawl with huge numbers of commuters using Tonbridge Station. It’s a great service, but already full to capacity at peak hours. The railway will simply not be able to cope and nor will Tonbridge.
None of this housing will have any impact on Tunbridge Wells. It will all fall on the Tonbridge doorstep and TMBC will receive no revenues.
Not to mention the additional traffic on our country lanes, additional pollution – light, noise, fumes and dust.
Every brownfield site should be explored before one single dwelling encroaches on green belt land

I am sure I could go on.

Of course we need to build more housing for the future, I am sure everyone recognises that, but wilful destruction of acres and acres of green belt land is not the answer. There must be better ways.

DLP_5401

Ari Philips

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

My family and I moved to Tonbridge two and half years ago from Dartford because we wanted to get away from the rat race of the daily traffic. We would often find ourselves sitting in traffic for an hour or more just trying to get onto the A2 or M25, or through Bexley Village to try and get ourselves to either our daughter’s school in Hartley or work in Chislehurst. The impact of all the development on Dartford was massive and actually detrimental as the whole town is a bottleneck.

It was fortunate that our daughter was awarded a place at Hillview School for Girls and that we now live within walking distance of the school on the new Redrow Development. However, since we moved two and a half years ago, the traffic from our development to the A21 and indeed into Tonbridge town centre has increased for various reasons, one of them being the primary school, Bishop Chavasse, which was built at the entrance of our development. The traffic leading out of our development to Woodgate Way and Vale Road is a nightmare both in the mornings and evenings around rush hour and if the proposed Capel Parish Development goes ahead then the traffic will increase tenfold which will mean that we will be stuck in the same situation we were in Dartford.

We had always understood that Green Belt land was protected and with climate change being such a sensitive issue at the present time, I am disappointed to see that this plan will encroach on the Green Belt. Tonbridge and the surrounding areas seem very crowded and if we add to this then the little open space that exists will be diminished further.

My wife has recently opened new Pilates and rehab studios in the centre of Tonbridge and is fortunate to walk to work on most days. However, there are times when she has to drive and it is extremely stressful as the traffic getting into town is always at a standstill and parking is limited that to have any more housing will be detrimental, especially when most households have more than one car.

We really do not think that the true impact this new proposed development will have on Tonbridge and the surrounding villages has been properly looked at and I would be grateful if you could please add my contact details to your consultation database so that I can be kept informed of all future consultations on Planning Policy documents. I understand that my comments will be published by the Borough Council, including on its website.

We believe that housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan. TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant.

I sincerely trust that full consideration will be given to all objections received and that this development will be rejected so that we can continue to enjoy the lovely countryside that currently exists around us.

DLP_5403

Delwyn Kay

I am emailing to register my opposition to the proposed development within Capel/Tudeley and particularly at the junction of Hartlake Road towards the Poacher pub, I understand today is the final day for comments to be registered. My concerns are as below:

Traffic:

I live in East Peckham and am aware that the roads from there to the A21 and Tonbridge are already congested in peak hour. These roads are unable to accommodate the additional thousands of extra commuters that would live in these new developments if the proposed plan goes ahead on its current site and scale. Traffic on Colts Hill would also increase excessively and this is a narrow road that would not be able to accommodate the extra traffic. Ditto travel volume to Maidstone. Additionally as more people would travel to both Paddock Wood and Tonbridge this will increase demands on trains, its already impossible for us to get a seat on commuter trains and certainly that would be the case for Tonbridge Station if the building works go ahead as proposed.

Changed nature of the area:

It would change the nature of the area and the villages that are in the vicinity, turning Capel/Five Oak Green in particular into a town that could become bigger than neighbouring Paddock Wood, rather than the hamlet/village that it is. Extra housing in each village is a better idea than thousands of houses in 3 areas. Additionally this is a green belt area and to build so much on this would significantly change the purpose of that land and the beauty that makes the green belt the treasure it is. Farmland, pasture, crops and nature areas and the very things that have made people like ourselves move to a village to raise our families. As I understand it previous applications for small developments in this area have been declined by TWBC on these grounds, thus it makes sense that such a huge building programme as would be declined also.

Excessive demand on local resources and services:

I am concerned that Tunbridge Wells are proposing to generate the greatest volume of their house building programme on their borders and this would cause new residents to disproportionately use Tonbridge and Malling facilities, including schools, roads, GP and other health care facilities, rather than TWCB services and facilities. This will create demand and delays, most particularly for GP surgeries where there are already delays in getting appointments and also oversubscription, this will only be worsened by the difficulties in filling NHS vacancies that currently exists.

Flood risk:

The area in Tudeley in particular is near the Medway river and towards East Peckham, an area known for flooding. This risk will only increase due to global warning and the increased rainfall we have been experiencing in recent years. I'm not aware that there are forecasts for the impact of the housing proposal in relation to flood risk, how that risk will be mitigated and who will be responsible for those costs. It seems obvious that massive housing increases up river from East Peckham will exacerbate flooding risk in our village and it most certainly shouldn't be East Peckham Parish Council or TMBC having to accommodate and pay for this.

DLP_5404

Alec Pelmore

I am writing to lodge my objection to the plans to develop a large number of houses around Capel and Tudeley My objections can be summarised as

- The majority of the land is in the Green Belt and there is no justification in the plan for the removal of this land from green belt status which is there to limit urban sprawl

- Pressure on local roads - the local roads at rush hour times are extremely busy with both a heavy volume of school and commuter traffic which will only be worsened by the addition of new homes and residents -

- pressure on rail. Residents will almost certainly be commuters who will put further pressure on Tonbridge Station and Network Rail studies have clearly indicated that the line from Tonbridge through to Orpington is already running at full capacity ... and it will be extremely difficult to increase that capacity

- pressure on local Tonbridge services - there has been considerable brown land development in the town (which is appropriate) but this has left services already overstretched - further development at Capel and Tudeley will put pressure on these (not Tunbridge Wells). There is very limited provision for the impact of this.

- while not itself in the AONB, the Tudeley valley is one of the loveliest in the county - a large urban sprawl along one side of it will have an severe impact on the 'curtillage' of the AONB

The detail of these objections has been extensively covered in submissions by SaveCapel and the Golden Green Association which I full endorse

DLP_5405

Jacqueline Evans

I live at XXX Goldsmid Road, Tonbridge, Kent XXX and I am contacting you to object to "The Strategy for Capel Parish" Policy STR/CA1 [TWBC: House number and post code redacted].

A new settlement of 2,800 dwellings at Tudely will have a detrimental impact on the town of Tonbridge, as well as the existing parish of Capel. People living in Capel will use Tonbridge station for commuting and Tonbridge town centre for shopping and other services which will place an increased burden on the already congested roads and overstretched faculties of Tonbridge.

In particular there will be a significant increase of traffic into Tonbridge from the B2017 adding to the already unacceptable levels of traffic along Woodgate Way, Vale Road and Pembury Road at peak times. This in turn adds to the congestion on neighbouring roads like Goldsmid road, where I live, as traffic moves spills over into the neighbouring roads and thereby endangers the hundreds of children walking along crowded pavements into the nearby secondary schools.

The plan include no proposals to ease the pressure on Tonbridge and its already overburdened roads and services.

In a way this proposal seems like a cynical decision by TWBC to fulfil it housing responsibilities and benefit from the added community charge income while leaving the impact to fall on Tonbridge.

DLP_5408

Ismini Philips

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

My family and I moved to Tonbridge two and half years ago from Dartford because we wanted to get away from the rat race of the daily traffic. We would often find ourselves sitting in traffic for an or more just trying to get onto the A2 or M25, or through Bexley Village to try and get ourselves to either our daughter’s school in Hartley or work in Chislehurst. The impact of all the development on Dartford was massive and actually detrimental as the whole town is a bottleneck.

I had always understood that Green Belt land was protected and with climate change being such a sensitive issue at the present time, I am disappointed to see that this plan will encroach on the Green Belt. Tonbridge and the surrounding areas seem very crowded and if we add to this then the little open space that exists will be diminished further.

I have recently opened new Pilates and rehab studios in the centre of Tonbridge and am fortunate to walk to work on most days. However, there are times when I have to drive and it is extremely stressful as the traffic getting into town is always at a standstill and parking is limited that to have any more housing will be detrimental, especially when most households have more than one car.

I really do not think that the true impact this new proposed development will have on Tonbridge and the surrounding villages has been properly looked at and I would be grateful if you could please add my contact details to your consultation database so that I can be kept informed of all future consultations on Planning Policy documents. I understand that my comments will be published by the Borough Council, including on its website.

DLP_5411

Debra Gunning

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1)

I attended a Parish Council Meeting in the village of Five Oak Green Tunbridge wells recently & was most distressed to learn that Tunbridge wells council planning department have put plans forward for consideration that covers the Hamlet of Tudeley that is Green Belt land & AONB.

This is a huge undertaking & has been kept under wraps & the Parish councillors & borough councillor’s until the meeting. There is substantial brown field sites in the borough but obviously Green belt land is easier & more profitable for the council to undertake planning permission requests. It appals me that Green belt land is of little consequence to the council & the wellbeing of the local residents & visitors who come to enjoy the countryside in this area.

At the meeting there were professionals who disputed Tunbridge wells planning departments “specialists” environmental views that this is flood land & has been so for the past 50 years. This is land that locals have also worked on for the past 60 recorded years & have seen this land saturated & flooded in those years. Together with hedgerows & wildlife this will affect.

It was also confirmed that Network Rail would provide no additional trains upgrades to the train station or additional stations. Already these trains are full with commuters from Tonbridge & Paddock Wood & Sevenoaks & the infrastructure cannot cope with this added burden. Together with lack of affordable housing for young locals who are priced out of the area.

The Hadlow Estate which owns a considerable amount of GREEN BELT LAND & AONB will just be eradicated for financial gain with a massive detrimental effect on locals, farming land of good quality stock & the area which will be destroyed for future generations.

Once they receive planning permission on the first phase this will spread like a cancer throughout the borough. It will NOT be the so called proposal title Garden Village – It will be a town & the Hectares depleted with only consist of gardens at each of the many thousands of houses planned.

It is already causing considerable distress to residents when we are supposed to be promoting mental health week – which green areas with public footpaths have been identified as helping substantially with wellbeing, climate change – which producing more cars/traffic within these areas will increase substantially when the roads already are jammed with traffic.

The proposed building of a Secondary school right next to a railway line is totally irresponsible, A well being health specialist advisor mentioned at a recent meeting in her professional capacity counselling vulnerable young adults, it is a tragedy waiting to happen should this plan be moved onto the next stage.

The Tunbridge Alliance got voted into Tunbridge Wells Borough council recently & this was highly due to Tunbridge wells performance with the millions of pounds to be allocated to the building of a replacement to the Assembly Halls Theatre, together with a lack of care or empathy for Calverley park that is again enjoyed by the residents & 1000s of visitors each year.

If the conservatives continue on this destruction of the countryside of building anywhere & everywhere concentrating on Greenbelt sites & AONB their patronage could soon be eradicated by the people they so call serve, which would be a sad event for local government but I feel this has already started to be highlighted to the local community.

Everyone is aware that central government have suggested a need for building – but surely the brown field sites should be used up first with an incentive rather than change the landscape for future generations to come.

DLP_5412

Emily Exall

I am writing this email in order to discuss my concerns in regards to the new housing development plans in the Capel area.

I have lived in Tudeley for 23 years surrounded by beautiful fields & green belt land. This area is a beautiful countryside with lots of wildlife, which would be affected by the new proposed developments.

There is not a reason that can justify getting rid of wildlife habitats and ruining our countryside. The Capel people are completely against this new development due to the increase in traffic and ruining our beautiful scenery we are surrounded by.

I am writing this email so that my voice amongst many other voices can be heard or listened to. I was looking forward to buying my own house within the local area but the housing prices will go up and I wanted to buy a house in the countryside not a concrete town.

Please consider other brown belt land that would be less destructive of our countryside with less of an impact of the local people that live in Capel!

Our voices must be heard and must count!

DLP_5413

Gordon Quinnell

I am writing to add my strong objections to your plan to build a so-called ‘garden settlement’ of some 2,800 houses at Tudeley.

I am a resident of North Tonbridge since 1977 and have always enjoyed the area and its amenities and have continued to do so, notwithstanding the increase in population of recent years and the resultant strain

on services and infrastructure, but feel very strongly that your planned development is going to add a greater burden on Tonbridge than it would on Tunbridge Wells.

In fact, I am of the opinion that you have arrived at your plan as a convenient expedient whereby you can claim to have met your house-building requirement, without having explored ALL options, including available space in and around Tunbridge Wells

Instead you appear to have opted for this ‘One-Stop Solution’ without any true regard for the inevitable consequences and repercussions on services and infrastructure.

I would go so far as to describe your plan is an environmentally irresponsible quick fix, without due diligence having been made as to the wider social and economic consequences for the area as a whole.

In summary, my objections relate to:-

an unsustainable impact on services and transport in Tonbridge
impact on Greenbelt
impact on prime agricultural land
impact of flooding
increase on traffic flow and ‘rat runs’ through surrounding hamlets and villages
no evidence that all alternatives within and on the edges of Tunbridge Wells have been thoroughly examined

I believe that for the benefit of the area as a whole a plan needs to be designed that involves not one single-site, but a number of smaller developments that could be integrated and assimilated in Tunbridge Wells over a phased period involving

all existing brownfield sites as well as redeveloping existing properties, including run-down shopping areas.

As it stands, your proposal will very likely create many more problems for the future than it would solve: you must already know that and are attempting to avoid these issues.

I believe (as do many others, I am sure) this plan is deeply flawed and irresponsible and must be rejected.

Please come up with a with a more holistic solution!

DLP_5414

Iain Mills

I live in Woodfield Road in Tonbridge and regularly commute into London. I also regularly visit Tudeley, meeting up with friends and enjoying the Church and other amenities that the current village provides.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

Creating a garden settlement at Tudeley of 2,800 dwellings will cause immense harm to residents of the Parish of Capel and to residents of Tonbridge.

Traffic within Tonbridge in both morning and afternoon peak hours is already at a standstill, and a development of this size will mean that there will be a significant increase in traffic in to Tonbridge from the B2017, exacerbating the extreme traffic congestion that already exists.

The already unacceptable levels of traffic between 7.45am to 9am on Woodgate Way, Vale Road and Pembury Road coincide with the site of a proposed new 6 form entry senior school. This proposed school will be on the border with Tonbridge, split by a main line railway and alongside a heavily used road. This appears to be a terrible site for a school, surrounded by heavy traffic and requiring children to cross a busy train line to access both sides of the site.

Parking in and around Tonbridge Station will be even more difficult, with people parking on residential streets causing further disruption to the pressure on "on street" parking bays that are meant to be for residents only.

Network Rail have confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. Most people living in the new garden settlements will drive privately owned cars, despite initiatives to encourage bus and bicycle use. The costs of infrastructure on the Tonbridge & Mallingside of the boundary will have to be carried by Tonbridge & Malling residentswhilst Tunbridge Wells will receive council tax from the residents in the new dwellings.

The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area. There will be an increase in pressure on Tonbridge health services, amenities and car parking as residents from the new garden settlement at Tudeley will use Tonbridge as their local town, not Tunbridge Wells, because Tonbridge is much closer.

Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saint’s Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. That will cause great harm to its value as a heritage asset of world renown (due to the complete set of Marc Chagall windows)

DLP_5416

Lionel Austin

I am writing to object to the planned Strategy for Capel Parish(STR/CA1). I am a resident of Golden Green, and the proposed construction of a vast number of houses and a school will impact on my local area and Tonbridge itself.

Our local infrastructure is already under considerable pressure and your proposals will have a huge adverse impact on the surrounding roads, many of which are narrow and can ill support the enormous increase in traffic, and also on rail links. It is already very difficult to find a seat on the trains at rush hour, and there is every likelihood that those coming to live in this new development will require rail transport in connection with their work. The medical provision in the area is already inadequate and is not in a position to cater for the demands this new ‘village’ would create. Nor does the area have sufficient parking to cope with what would be a vast influx of cars.

The rural character of the area would be destroyed by your proposals: swathes of rural land would be destroyed, with the attendant impact on wildlife, woodland, hedgerows and meadows.

It is invidious that council tax monies accruing from the new estate would be used for Tunbridge Wells’ purposes, while it is Tonbridge and the surrounding areas, of which we are one, which would bear the brunt of such an unwelcome proposal.

The construction of this vast new estate would be a disaster for Tonbridge and the outlying areas from an infrastructure and ecological point of view and I would ask you to reconsider your proposals.

DLP_5417

Valerie Coleshill

Dear local plan team, My husband and I have lived at XXX Crockhurst street cottages Tudeley for 46 years [TWBC: House number redacted]! I have lived in Tudeley all my life! Our residence is directly on the B2017, we overlook an area of outstanding natural beauty! My children and my grandchildren have benefited from this very rural setting! We are now very concerned as to what the future holds for Tudeley and certainly do not approve of this local plan for its future!

We write objecting to " the strategy for Capel Parish(Policy STR/CA1) We understand that new housing is required, but why build on green belt sites when there are plenty of brownfield sites available! The proposed plan for 2,800 houses in this small hamlet are not acceptable!

Roads and transport. The B2017 is a very busy road throughout the day and night. It is very often congested from the Somerhill roundabout to the centre of Tudeley during very busy periods! We have trouble getting in and out of our driveway most times! We are very concerned about the volume of traffic that is going to be generated if the development proceeds!Also the surrounding roads that lead to Golden Green and Capel are very narrow and are not designed to accommodate the volume of traffic that is going to be generated by this development! The whole area will be gridlocked! The B2017 as it is now is so congested with haulage vehicles and farm machinery now, so any further vehicles ie, construction traffic will only add to the problems that are here now! Tonbridge is going to have the full impact of any commuters that are generated from this plan, there isn't enough parking spaces now so the impact is going to be devastating for the town!

Flooding, During very wet weather our gardens get flooded with run off from the fields that surround us now, so any further building will only generate more problems when more concrete is added to the area! The drainage cannot cope now , so certainly won't if this plan goes ahead!

Heritage. "Our Garden of England " will disappear under concrete, the Oast Houses will disappear from view and All Saints Church will have its heart ripped out of it!! People come from all over the world to visit this historical building! This will disappear amongst the " garden village", and will lose its quaintness and charm.

Biodiversity, we have so much wonderful wildlife in Tudeley, this will all be put at risk if this development is allowed to happen! We will also lose our wonderful night sky views!

Health services. We use "Woodlands" at Paddock Wood for our health needs, this surgery is under so much pressure now with the shortage of doctors, where are you going to miraculously going to get doctors from to form a new doctors surgery? My daughter is a Staff nurse at Pembury hospital, they are already working at breaking point, how are they going to cope with all the extra population that is going to be generated in the " garden village"? I am led to believe that the surgeries in Tonbridge are overstretched as well!

Utilities. The sewerage in Tudeley is very poor, most properties have their own cesspits, the water supply is very poor quality, the pipe works are so old and narrow . The drainage in the area is ridiculous, the drains are always at breaking point!

The creation of this housing is such a poor idea, it's going to destroy so much beautiful green belt land, which in the current climate should be kept as farmland! The wildlife which is very good in this area and holds some rare species will be destroyed! The whole quaintness and heritage of Tudeley, let alone the hamlet of " Crockhurst Street" will disappear.

We believe the plan is unsound. The plan preparation didn't includeTudeley ( sites CA1 /CA2) until after the issues and Options Process in 2017 . The largest housing area in the plan didn't go through most of the housing plan preparation process! There is no detailed Greenbelt Study for these sites, no landscape assessments, no biodiversity assessments.I believe that the draft local plan isn't complete enough to be ready for public consultation when it hasn't had the same level of assessment as the rest of the plan! The issues and Options process led to most people(60%) wanting a growth corridor led approach.Less than half wanted a garden settlement and that was when they didn't know it involved the destruction of Greenbelt land! Protecting Greenbelt was a key priority for people who participated in the Issues and Potions consultation. I think the plan should be re written to implement a growth corridor led approach and to protect the Greenbelt land in the borough!

Earlier in the plan( in4.40) you refer to Tudeley village securing a long term option to the borough to deliver the needs of future generations. It is clear from this statement that you intend to add more and more housing to this " garden settlement" in each 5 year review of local plans.TWBC appear to be using Capel to fulfil their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the borough, to make it accessible north and south. The development in Tudeley and East Capel are unsustainable and place huge pressure on Tonbridge.

DLP_5419

Mr Peter Borrett

We bought our house in Five Oak Green because it is in a very nice Green Belt area, we strongly object to your plan for 2,800 houses which will ruin the peaceful and beautiful place we live in. please add my contact details to your consultation database so that I can be kept informed. I understand that my comments will be published by the Borough Council, including on its website.

I AM WRITING TO OBJECT TO “THE STRATEGY FOR CAPEL PARISH” (POLICY STR/CA1)

People living in Tudeley will use Tonbridge station for commuting which will need more parking and the increase in traffic will be more than Tonbridge can cope with. Network Rail have confirmed that a station at Tudeley is not viable. Most people living in a new garden settlement will drive privately owned cars, a fact that no amount of Government/Council bluster can change. The cost to Tonbridge based businesses due to traffic issues will drive businesses from the area.

Large parts of the development will occur on the Medway Floodplain with flood risk assessments BASED ON OLD DATA that does not fully consider the impact of climate change, I believe the flood risk will increase, covering farmed fields with concrete and houses will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding. There will be an increase in air, light and noise pollution and create a visual scar across the landscape.

Creating so much housing in Capel Parish will require the destruction of woodland, hedgerows, meadows and farmland that is Green Belt land unless “exceptional circumstances” exist. TWBC should use this argument to remove this garden settlement at Tudeley from this plan. TWBC has taken the housing need figure of 13,560 given to them by Government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Taking the 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the Government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on the Green Belt would be a much better approach. Recent ONS figures show that population growth in the borough is slowing!

There is no detailed Green Belt study for these sites, no Biodiversity Assessment, I think that this version of the Draft Local Plan isn’t complete and is not ready for public consultation. TWBC is using Capel to dump their housing needs on Green Belt meadows, polluting a rural area rather than spreading development across the borough on brownfield sites.

DLP_5421

Hadlow Estate Resident

As residents living on Hadlow Road Tonbridge, users of trains from Tonbridge up to London and users medical services and schools in Tonbridge, we are writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

We object to the creation of this housing estate which will increase pollution, noise pollution and put an even greater strain on Tonbridge's public services, namely schooling and doctor's surgeries which are already stretched. As an example, when we moved to Tonbridge three years ago, we were unable to register with our local doctor's surgery Warders but luckily could register with one on the ship ourne road. residents of this new housing site will wish to use Tonbridge &Malling's infrastructure which is already overstreached. In addition, it is quite wrong to put additional strain on these resources without using the council tax these residents pay to help subsidize these services.

DLP_5425

Robert Botten

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

This proposal will take away valuable farmland, destroying woodland, hedgerows and wildlife habitat. Greenbelt land should be protected providing a buffer between towns and villages and allowing local people some breathing space between built up areas. There are no exceptional circumstances that warrant building here, let alone in such large numbers as other options are available. Just because TWBC would only have to deal with one landowner for this development instead of multiple sites and land owners, it is not a good enough reason to dump such a large development in a rural location on the edge of neighbouring boroughs. TWBC should be looking to use brownfield sites or sites spread across the borough so that the new residents would use Tunbridge Wells for its main town. Once development happens in invariably continues to expand over time and there is a real danger that Tonbridge, Tudeley, Five Oak Green and Paddock Wood will turn into one conurbation. A development at Tudeley would infill the space between Tonbridge and Five Oak Green with only a small buffer of farmland in between.

A garden settlement at Tudeley will result in a large increase in traffic as residents will find they have little option other than to have cars regardless of incentives to use public transport. In addition it is likely that they will be using Tonbridge railway station for commuting where there is limited parking, putting extra strain on Tonbridge. This location is so close to Tonbridge that Tonbridge will bear the brunt of the extra traffic and extra demands on local services while TWBC will collect the council tax.

The vaguely proposed new road seem pointless. If you are going to Tonbridge you will use Tudeley Road, if Tunbridge Wells then Alders Road or through Five Oak Green. All a road will achieve is to cut the area between Barnes Street and Five Oak Green in half, destroying more farmland and spoiling an area that is enjoyed and used by local people for walking

I believe this development will increase the risk of flooding. While it may be possible to introduce some flood mitigation this is an area prone to flooding and overall it can only make matters worse. The Hartlake road regularly floods as part of the Medway floodplain and Five Oak Green Road often runs like a river during and after heavy rain, particularly between Sherenden Road and the junction with Alders Road.

The proposed site for a new school is completely unsuitable. It borders right against Tonbridge and is on the junction of extremely busy roads. This junction suffers tailbacks into Tonbridge and to the A21 during the busy rush hours and a school here will only result in gridlock. Tonbridge already has a number of schools at the south end of the town resulting in heavy traffic during school drop off/pick up times which will be made much worse if a new school is built in this terrible location.

DLP_5433

Charlie Exall

I’m writing this email to show my concerns of the new housing plans and school plans to be built in our lovely green belt land.

I’ve have lived in Tudeley since I was born and been raised to appreciate the beautiful country side that the UK has to offer. Over the 25 years I have lived in Tudeley I have fallen in love with the country side. I look forward to having kids and bringing them back to where I was raised as a child. But at this rate I will be bringing my kids back to a land of tarmac. How can we justify destroying such beautiful land that’s everyone disagrees against ! Why as people that live in the beautiful area don’t have a voice ? Thousands of people are against this plan but nothing is being done about it.

There are also implications that will affect paddock wood, Tonbridge, five oak green and even Hadlow. Traffic will cause chaos with the thousands of houses being built and the new schools. We struggle with traffic as it is how can you think putting more houses and schools down can fix that ?

Not only that, I’m looking to purchase a house and this won’t help me as the house prices locally will go up.

Please listen to the people’s voice and do something about it ! If this is followed through you are destroying animals habitats and beautiful green land. We have plenty of brown belt land that can be used!

Listen to the voices of CAPEL and do what’s right.

DLP_5447

Lawrence Matthews

My name is Gareth Matthews. xxxx [TWBC: postal address redacted]. I live with my Wife and two children as stated in Golden Green,

Although not directly in TWBC area, the proposed development will have a huge impact on us. See STR/CR1, and STR/PWI plans.

It would seem that the Tunbridge Wells plan seems to be targeting East Capel and Tudeley for a huge Housing dump, advised 69% near Tonbridge and Malling.

We are strongly against these plans for many reasons.

Why consider taking prime Green Belt land for this development?

Green Belt has formed from 1935, for the purposes to check the unrestricted sprawl of large built up areas. To prevent neighbouring Towns from merging into one another, and to assist safeguarding the Countryside from encroachment. The benefits of our Green Belt land cannot be overstated. It provides access to open Countryside for the urban populations of Tunbridge Wells and Tonbridge. We dont want the area of East Capel and Tudeley destroyed. This is primarily prime agricultural land which is Grade 2/3, to be lost for ever. With nature taking a hit from all sides we need to keep areas like this for our biodiversity. In a Nutshell we all need open green spaces for our well being , its as simple as that. I want to leave this precious place in Kent for our own Children to enjoy, not just an ever increasing Urban sprawl.

Other areas from a planning prospective need to be addressed.

Flood plan . Has this been thoroughly investigated.

Roads. Are they adequate to cater for hundreds of additional cars and other Road traffic.

With this additional pollution. Road noise , air quality.

Transport. Is it adequate re additional Bus , Train service?

Utilities . Can the water and Gas supplies cope?

Heritage. How will the lovely Church at Tudeley be affected?

Sustainabilty. Are these plans workable in the long term.

I could go on , but there are two many negatives.

Please stop these plans and save both Capel and Tudeley for now, and for future generations.

DLP_5452

Katherine Weinberg

I have recently moved to Five Oak Green from London with my young family. A key driver for our move was to escape a more urban environment, given that my son is asthmatic.

Learning of the Strategy for Capel Parish (Policy STR/CA1) has caused my family great alarm, as it fundamentally undermines the rationale for our move and will likely cause us to again need to relocate.

The key reason for this is the congestion and environmental harm which we will suffer due to the settlement planned at Tudeley. There will be a significant increase in traffic in to Tonbridge from the B2017, a route I take daily to drop my little boy at nursery. This will exacerbate the extreme traffic congestion that exists on this road every morning. Further, as residents on Five Oak Green Road we will be directly affected by the pollution increase caused by the increased traffic on the route from Paddock Wood to Tonbridge. This is precisely what we moved from London to avoid.

I am also very concerned that large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but I believe that flood risks will increase. Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding. There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape. Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saint’s Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. That will cause great harm to its value as a heritage asset of world renown (due to the complete set of Marc Chagall windows)

For these reasons, my view is that TWBC is using Capel to dump their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the borough on brownfield sites or placing the garden settlement in the middle of the borough, to make it accessible north and south. The developments in Tudeley and East Capel are unsustainable and place huge pressure on Tonbridge.

As a new resident of Capel Parish who has moved to the area for the health of her family I urge you to take these comments on board and revise your plans in the ways suggested above.

DLP_5454

H W Topham

I am alarmed that Tonbridge, being the nearest large town to the proposed development in Tudeley and in another District Council Area, Tonbridge & West Malling, will suffer dramatically with more traffic congestion and parking problems for the mainline station and general shopping, we are struggling as it is as a town. During commuting times the town and ring road are already grid-locked. Parking is a nightmare, we can't afford yet more cars being driven into and parked in the town. The infrastructure cannot take a development like this, Tunbridge Wells will not be hit like Tonbridge will because of the proximity of the mainline station, shops and out of the High Street shopping on the Industrial Estate. Please re-think this strategy through. Tonbridge & West Malling Council already have their own problems with infrastructure already over stretched in the town. Other than a new school, what other infrastructure improvements e.g. Roads, parking, access to doctors etc have been considered?

DLP_5456

Steven Crisp

I am wholly against housing development on Green Belt land which should be cherished and not covered in concrete. The proposal at Capel is typical of a seemingly world wide mass movement by governments to destroy the very environment we need to survive on this planet for short term commercial gain. There is not sufficient infrastructure to cope with the proposed amount of houses and CPRE have highlighted enough brownfield sites countrywide to build over one million houses - so why are these valuable green fields even being considered? We need land to grow our food and ares to reforest to cope with climate change which IS a reality! What future have our children got if mad schemes like the Capel house build planning application and many, many others are accepted? It must be thrown out!

DLP_5459

Kate Welford

I live in South Tonbridge and work in London. I enjoy spending my leisure time walking. My favourite local walks are in the Tudeley which I can get to on foot. Driving is harmful to the environment so being able to go for walks directly from home is very important to me and my family

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

People living in Tudeley will use Tonbridge Station for commuting and Tonbridge town services that will need more parking. The increase in traffic will be more than Tonbridge can cope with. I often find commuters parking in Goldsmid Road which means when my elderly parents visit they are unable to park near the house this results in my mother being dropped off and my father having to find somewhere else to park. It is inevitable that the parking will get worse in Goldsmid road and I seriously wonder if my parents will be able to continue to visit us. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable. I commute to London daily and are aware the trains are already at full capacity at peak times.

There will be an increase in pressure on Tonbridge health services, I have recently tried to make an appointment with my GP. Last Tuesday (6/11/19) when I rang there were 30 callers in the queue ahead of me, on the Friday (9/11/19) there were 26 ahead of me and this week (12/11/19) there were 9 ahead of me. I am still to make an appointment with the GP, let’s hope I never need to see one if the houses are built.

Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but I believe that flood risks will increase. Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding. There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape. Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saint’s Church in Tudeley. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. That will cause great harm to its value as a heritage asset of world renown (due to the complete set of Marc Chagall windows)It will no longer be possible to walk there from home.

I have friends that live in the Tudeley area on your plans the house is coloured pink indicating it is owned by Hadlow estates. It’s not, they own it. How many more lies and inaccuracies are tied up in the plans ? Some honesty would be welcomed

DLP_5463

Gabrielle Lear

My name is Gabrielle Lear and I live at XXX, Three Elm Lane, Golden Green XXX [TWBC: House number and post code redacted]. I have lived in Golden Green for almost 17 years and until a few years ago I was a regular commuter to London.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

I am deeply concerned at TWBC’s plan to create a new garden settlement, amusingly called Tudeley Village but more akin to a Town, in an area completely unsuited to such a development.

TWBC’s recent enthusiasm for developing 400 acres of Green Belt land, recent in that it conveniently bypassed much of the plan preparation process, is worrying and gives force to the idea that the convenience of dealing with one landowner has a far greater importance than following normal planning guidelines. For TWBC, there is of course the added advantage of dumping over 60% of their new housing on the border with TMBC ensuring that all the disadvantages of the plan will fall in someone else’s lap. It is to the great credit of the Councillors of TMBC that they soundly criticised the plan at their recent extraordinary meeting of the Planning and Transport Advisory Board.

It is abundantly clear that Tonbridge does not have the infrastructure to deal with the additional pressure that this development will create. During peak hours Tonbridge and its access roads are already unable to cope with existing traffic flows. The main access route from Tudeley to Tonbridge along the B2017 becomes a slow-moving queue of traffic backing up past the junction with Hartlake Road. Even if this road were widened with added roundabouts, no benefit would ensue because Tonbridge itself could not handle the additional traffic.

Many of the Tudeley residents would commute to London. Trains from Tonbridge are already at bursting point with no spare capacity. Tonbridge station during peak hours is rammed full with commuters and school children and could not conceivably take more. Other housing developments further down the line are expected to create capacity issues; 2,800 new homes in Tudeley will likely break the system. The existing parking at Tonbridge station is already insufficient for current needs.

When you add to this a new school to be built on land alongside Tudeley Road, my mind starts to boggle at the havoc that will be created. In fact, the idea that professional planners and conscientious Councillors could have seriously proposed building a school in a location so obviously unsustainable gives me the impression that TWBC’s approach is to take the easy option to the exclusion of all other previously considered choices. This is local responsibility at its laziest.

There isn’t even the obvious need for the number of houses that TWBC is planning to build. You can hide behind central government diktats but there still needs to be “exceptional circumstances” to release Green Belt land for development. TWBC should be far more robust in challenging the existing numbers based on out of date statistics. I would anyway question whether a new development will provide the right type of housing. It is not just a question of numbers; housing needs to cater for those struggling to find accommodation. I seriously doubt whether a green field development, consisting no doubt mainly of substantial houses, will meet existing housing needs however lucrative for the developers. I notice that TWBC is only now updating its brownfield register. Given that such land should take priority for development surely this should have been completed prior to any decision on building over Green Belt land.

Much of the development will be on the Medway floodplain. In the 16 odd years that I have lived in Golden Green I have witnessed significant flooding in East Peckham, Tonbridge and along the Hartlake Road, this despite the Leigh barrier. The papers today are full of reports of disastrous flooding in parts of Yorkshire and Derbyshire, again despite significant investment in flood defences. Climate change is upon us and it seems foolish in the extreme to consider concreting over 400 acres of productive, absorbent agricultural land which can only exacerbate the existing threat of flooding.

There are many other issues to be debated, such as the threat to biodiversity, the pollution created by additional traffic jams, the risks to the heritage site at Tudeley Church and the provision of health and other services. These have been identified by others in their responses so I will not go further into detail, save to point out that the memorably phrased “blobs and arrows” appearing on the maps in the Local Plan brochure and labelled “Proposed Link Routes” completely ignore traffic flows to the North. Hartlake Road will become the next rat-run for those seeking to avoid routes via Tonbridge or Five Oak Green. Hardly helpful on a road barely wide enough in places for two-way traffic.

I end by drawing your attention to a Planning Decision Notice, ref: 18/01767/FULL, dated 31 July 2018 and signed by one Stephen Baughen, the Head of Planning (Interim) at TWBC and who now, I believe, holds the position of Head of Planning Services. The Decision Notice refuses planning permission for a modest extension to The Poacher, a restaurant located at the very edge of the proposed new development.

The reasons given for the refusal are, in summary:

The proposal would constitute inappropriate development within the Metropolitan Green Belt and would be harmful to its openness. There is insufficient evidence of the necessary “very special circumstances” to overcome this harm.
The proposal would have more than a minimal impact on the landscape character of the locality. The overall impact is harmful to the rural character of the area.
There is no evidence that occupiers would not be at risk from flooding or that there would not be increased risk of flooding elsewhere. Therefore, the development is likely to result in a risk to human life from flooding.

A more glorious example of hypocrisy would be hard to find.

In summary, this proposal is unsustainable on several grounds and should be withdrawn without further delay. All those responsible for its production and approval should look deeply into their consciences and reconsider this appalling proposal.

DLP_5466

David Lear

My name is David Lear and I live at XXX, Three Elm Lane, Golden Green XXX. I have lived in Golden Green for over 22 years and until recently I was a regular commuter to London [TWBC: House number and post code redacted].

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

I am deeply concerned at TWBC’s plan to create a new garden settlement, amusingly called Tudeley Village but more akin to a Town, in an area completely unsuited to such a development.

Much of the development will be on the Medway floodplain. In the 20 odd years that I have lived in Golden Green I have witnessed significant flooding in East Peckham, Tonbridge and along the Hartlake Road, this despite the Leigh barrier. The papers today are full of reports of disastrous flooding in parts of Yorkshire and Derbyshire, again despite significant investment in flood defences. Climate change is upon us and it seems foolish in the extreme to consider concreting over 400 acres of productive, absorbent agricultural land which can only exacerbate the existing threat of flooding.

The reasons given for the refusal are, in summary:

1. The proposal would constitute inappropriate development within the Metropolitan Green Belt and would be harmful to its openness. There is insufficient evidence of the necessary “very special circumstances” to overcome this harm.

2. The proposal would have more than a minimal impact on the landscape character of the locality. The overall impact is harmful to the rural character of the area.

3. There is no evidence that occupiers would not be at risk from flooding or that there would not be increased risk of flooding elsewhere. Therefore, the development is likely to result in a risk to human life from flooding.

A more glorious example of hypocrisy would be hard to find.

DLP_5470

Oka Emi

I used to live in London and have a good memory about it. That was more than 10 years ago. I heard about this development through my friends who live in this area.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

DLP_5472

Don Gillett

I am writing to add my comments and objections to the local housing plan. I am a resident of Tunbridge Wells.

I am writing to object to the "The Strategy for Capel Parish" Policy STR/CA1

It is clear that the plan has little to do with actual housing need and it's main aim is to fulfil a quota imposed by central government.The plan talks about creating employment opportunities but gives no detail. It therefore means that the development will not be "affordable" for local need but will provide a dormitory conurbation of commuter homes for London. These will not provide the kind of community envisaged in a Garden Village development. Each dwelling will need motorised transport. Occupants will be commuting daily by rail from Tonbridge and Paddock wood. This will add to pressure on already busy roads and parking at rail stations.

The 2,800 dwellings at Tudeley will furthermore not constitute a Garden Village as it will be cut through by a main railway line without a station. The development is adjacent to a flood plain and will increase the speed of water runoff into the lower areas which has not been adequately addressed given the increased risk of flooding as a result of climate change. This is not sustainable.

The church at Tudeley with it's Chagall windows is a nationally significant treasure. The close proximity of the development will hugely impact on this site with implications not only for it's amenity but also security with the increased traffic in the area.

This area of the weald of Kent is a haven for cyclists. Mention is made in the plan that it does not impinge on a national cycle route. However, route 18 is nearby and is one of the loveliest and most popular routes in the south east. Local cyclists join it from all points and the lanes around Paddock Wood, Tudeley and Tonbridge are as a result very popular with cyclists. The increase in motor traffic resulting from the proposed conurbation will ruin this as a local amenity.

The same argument holds for it's close proximity to the AONB and green belt. The green belt land should only be used in exceptional circumstances and these have not been demonstrated.

DLP_5473

Lynne Assirati

I live in Alders Road, Capel which as I am sure you are aware has flooded on a number of occasions. Together with my husband and neighbours we run the Capel Path Rangers group which was set up to ensure that all the footpaths within the parish are well maintained and I greatly appreciate being able to walk in such lovely countryside with outstanding views. We also run the Friends of Capel Church which is dedicated to maintaining the fabric of this ancient church and welcoming the many thousands of visitors who come to view our medieval wall paintings. Finally, I organise the village litter picks. I am therefore writing to object to “The Strategy for Capel Parish” (Policy STR/CA1) for a number of reasons but primarily because it will increase flood risk, will ruin a huge swathe of our beautiful countryside, and the proposed new road will increase noise pollution and destroy the peace and tranquillity of our lovely church yard which is much used by many locals for a place to come for a few quiet moments away from the bustle and business of our frantic lives. Increased pollution will damage the fabric of the building and thousands more people living in this area will increase litter to a disastrous level. We already get very little support from TWBC to keep our lanes clean and I don’t anticipate there will a change in policy any time soon.

It is naive to believe that the people who will buy these houses will already be living locally. Many, many will come from London seizing the opportunity to get a larger house for the same money and have access to grammar schools. People living in Tudeley New Town will therefore use Tonbridge Station for commuting and Tonbridge town services and that will require more parking. The increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times and can’t be made wider in most places. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable. Parking in and around Tonbridge Station will be even more difficult. Network Rail have confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. Most people living in the new garden settlements will drive privately owned cars, despite initiatives to encourage bus and bicycle use. The costs of infrastructure on the Tonbridge & Malling side of the boundary will have to be carried by Tonbridge & Malling residents whilst Tunbridge Wells will receive council tax from the residents in the new dwellings. The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area. There will be an increase in pressure on Tonbridge health services, amenities and car parking as residents from the new garden settlement at Tudeley will use Tonbridge as their local town, not Tunbridge Wells, because Tonbridge is much closer. There will of course be impact on Tunbridge Wells where there will be even longer queues at A&E, increased pressure on the police service, more accidents on the inadequate roads.

Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but I believe that flood risks will increase. Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding. There will be an increase in air, light and noise pollution that will spread across the boundary into Tonbridge & Malling and create a visual scar across the landscape. Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saint’s Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. That will cause great harm to its value as a heritage asset of world renown (due to the complete set of Marc Chagall windows) Here again, the peace and tranquillity of this very special place will be destroyed and increased pollution will cause irreparable harm. This is a Grade 1 listed building and I would remind you that as such Historic England regards the setting as extremely important.

DLP_5474

Jack Marr

I live in Hadlow, and frequently drive along the roads along which the development in question will be sited. I grew up in the area and am deeply dismayed by the proposal as it will irrevocably alter the character of the area, overload the roads and existing infrastructure, present a flood risk and have a terrible impact on the ecology of the area. We have a collective responsibility to preserve Green Belt land and to use brownfield sites instead wherever possible. I expand on my objections below.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

Creating so much housing in Capel 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, including rare species. An otter was recently spotted by a local person in the Bourne, and such returns of endangered native wildlife will be entirely undone. This area should remain rural with agricultural land that can be used to provide food.

DLP_5485

Charles and Catherine Parmley

AS a long time resident of Tonbridge I am astounded that you propose such a vast increase in Tonbridge -not TWBC headcount and congestion. Having driven to the Industrial Estate in Tonbridge the traffic queue at 4.30pm trying to leave towards Hadlow was back beyond the Mercedes garage. The town is permanently a snarl up during school times. The only relief -and not much at that comes in school holidays. Another large school a joke.

Parking in the town is already stretched and this would be horrendous. Pollution has obviously not been considered.

We already have expensive bicycle lanes un used and unusable! That is no answer in cold damp days -OK for lycra teams perhaps in at the weekend but they don’t use them.

Should this go ahead we will be off to somewhere for a decent standard of living

DLP_5486

Stephanie Sagar

I currently live on Hazelwood Close in Tonbridge which forms part of the Somerhill Green development (“Somerhill”). Somerhill is located just off Five Oak Green Road which leads to Woodgate Way. I live with my husband and 2 year old son and I commute into London every day for work.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

Creating a garden settlement at Tudeley of 2,800 dwellings will cause immense harm to residents of the Parish of Capel and to residents of Tonbridge. There will be a significant increase in traffic in to Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road every morning. The already unacceptable levels of traffic between 7.45am to 9am on Woodgate Way, Vale Road and Pembury Road coincide with the site of a proposed new 6 form entry senior school. This proposed school will be on the border with Tonbridge, split by a main line railway and alongside a heavily used road. This appears to be a terrible site for a school, surrounded by heavy traffic and requiring children to cross a busy train line to access both sides of the site. You should also take into account that a primary school (Bishop Chavasse) has recently opened on Baker Lane. The primary school is not yet at full pupil capacity but already traffice and parking are issues on both Baker Lane and Five Oak Green Road. The parking facilities on the school site already appear to be inadequate and the parking situation will only worsen when the school reaches it capacity of approximately 400 pupils. If parents are unable to park on school grounds, they will inevitably stop on Baker Lane and Five Oak Green Road. Five Oak Green Road is very narrow and already struggles with flow of traffic when cars are parked on the road. This congestion on Five Oak Green Road is extremely likely to have an impact on the traffic flow on Woodgate Way and will not only make it difficult for parents dropping of their children, residents leaving/entering Somerhill but also those individuals commuting to nearby towns and to Tonbridge. Quite simply, the infrastructure is not in place to accommodate another large school in the vicinity of Woodgate Way.

People living in Tudeley will use Tonbridge Station or Paddock Wood for commuting. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable. For a development of the proposed size, you would expect it to have its own transport links but Network Rail have confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. As mentioned, I travel into London everyday and the trains are almost full when they leave Tonbridge. Commuters living in the proposed development would likely travel to Paddock Wood or Tonbridge to catch a train – if individuals board at Paddock Wood, the trains will be full by the time they get to Tonbridge (there would be no standing room after Tonbridge) and even if those additional individuals get on at Tonbridge the train would be so full that the commuters from Sevenoaks would be very unlikely to be able to board the trains at all. How is this going to be dealt with? It is unlikley that Southeastern will provide more services and if they do provide more services this will almost certainly result in an increase in already expensive fares. My train season ticket is currently £4364 per annum – if it increases much above this then it will not be economically viable to commute into London.

Parking in and around Tonbridge Station will be even more difficult. Network Rail have confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. Most people living in the new garden settlements will drive privately owned cars, despite initiatives to encourage bus and bicycle use. The costs of infrastructure on the Tonbridge & Malling side of the boundary will have to be carried by Tonbridge & Malling residents whilst Tunbridge Wells will receive council tax from the residents in the new dwellings. The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area. There will be an increase in pressure on Tonbridge health services, amenities and car parking as residents from the new garden settlement at Tudeley will use Tonbridge as their local town, not Tunbridge Wells, because Tonbridge is much closer.

Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but I believe that flood risks will increase. Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding. There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape. Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saint’s Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. That will cause great harm to its value as a heritage asset of world renown (due to the complete set of Marc Chagall windows).
The garden settlement at Tudeley can never be one settlement as it is divided by a railway line that has very narrow, weak crossings. Putting in larger crossings at frequent points across the railway may be possible but it won’t tie the two halves of the settlement together enough to make it one settlement, so it will never satisfy garden settlement principles.

Creating so much housing in Capel 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, including rare species. This area should remain rural with agricultural land that can be used to provide food.

Please appeciate the environment we live in – it is beautiful. If we continue to destroy green spaces, there will be no end to the urban sprawl and generations after us will not be able to enjoy the countryside as we have done. Once it is gone, it is gone. It also sets a very dangerous precedent for future developments on green belt land.

DLP_5500

Emma Hicks

As a resident of Tonbridge I feel that we will be greatly impacted by this new development without seeing any advantages. I understand that new housing has to be completed to meet demands but we already have a high level of development in Tonbridge and surrounding towns and this new proposal will put pressure on our infrastructure and facitilites and create a port area of living for all of those in Tonbridge, Tudeley, Capel and this new garden town.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

As you’ll see from all the points above it is not one or two issues but several, it seems that there is no serious thought of how this garden development will impact on surrounding areas and there has been no serious consideration of local amenities and infrastructure and how this will affect day to day life in Capel, Tonbridge and Tunbridge Wells.

DLP_5502

Keith and Margaret Stafford

I am writing to add to and voice my concerns over the proposed plan to increase housing in the "Tudeley" and "East Capel" areas and the impact to the areas affected should the Council get planning consent .

Our family have lived in the village of Five Oak Green since 1988, raising our two children in what was at the time a small rural community and a reasonably quiet and safe environment in which to bring them up in.

Since moving to the village over recent years its been noticeable that along with the increase in both the villages and surrounding areas populations that this has obviously meant a steady increase in traffic through the village which has resulted in my regularly finding my journey time increasing due to the added volume of traffic using the B2017 through F.O.G and onto Tonbridge at certain parts of the day, it has also been noticeable that the route via Colts Hill (A228) into Tunbridge Wells is another case where journey time has and is increasing regularly. I am sure I am not the only one with this problem.

With the new proposed plan to build 2800 houses in Tudeley and 1500 in East Capel if the plans are given the "green" light then the village being almost equidistant between the proposed developments will be even more impacted environmentally especially as previously mentioned by the the levels of increased traffic using the B2017 through the village. It appears the Council planners either did not take this into consideration, dismissed it as not being an issue, or entirely ignored during the drawing up of the initial plans.?. It is also of great concern to hear recently that the Tonbridge & Malling Borough Council appear not to have been consulted in the initial stages of the Tudeley development and are now voicing their own concerns over your plans ?.

I would go on to mention other obvious factors for the proposals not going through very importantly being support for keeping "green" belt areas from being destroyed, environmental issues including increasing air pollution, impact on wildlife and flora etc but the Council has already been made aware of these issues by a strong and vociferous "Save Capel" group acting for and continuing to give their valuable time and considerable expertise acting on behalf of our community in opposing the proposed plans.

Finally I hope that with the groundswell of considerable opposition growing for the current plans by local residents that T.W.B.C will reconsider the current proposed plans for the Capel / Tudeley areas and come up with an alternative and viable option to what is in the planning process at the moment .

DLP_5504

Bruce Preston

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

I cannot agree more with the comments below provided by the Save Capel team.

I would like to add from a personal point and say that we have lived in Tonbridge now for 22yrs and have come to love the town and surrounding areas. We live on the Hadlow road which as I’m sure you are aware is nightmare for traffic during the morning rush hour/ school run and this is only going to get worse with this ludicrous plan you are proposing. And what about the impact of extra commuters on our already packed trains in to London? How many of those responsible won’t have to endure that nightmare?

Also I’m a keen cyclist and frequently cycle around Capel, Tudeley and surrounding areas so any further increase/strain on the roads is going to make what is presently a glorious hobby into a stressful and very dangerous one. Let alone the destruction of the already poorly maintained roads in our area of kent. SORT THEM OUT FIRST!

I would relish the opportunity to look all the planners, Government officials, local councillors who are involved with this proposal in the eye and ask them would they want to be responsible for the destruction of this beautiful area we live in and how would they like it if it was their local area being affected and decimated?

And have those responsible considered the impact of air,light and noise pollution? The increased flood risk? The increased burden to local heath services?

So please, please stop this madness and withdraw what to me (and many, many others it would seem) this abomination of a plan.

I agree with the comments below:

DLP_5510

Catherine Sherwin-White

I live with my young family off the Hadlow Road outside Tonbridge. My husband and I both commute to London daily and we chose this area amongst other things due to the green belt setting and the rural upbringing it will offer our children.

I am writing to object to 'The Strategy for Capel Parish' (Policy STR/CA1) and the inclusion of the land of East Capel in 'The Strategy for Paddock Wood' Policy STR/ PW1).

The proposed development will cripple an already crowded and dysfunctional infrastructure. The impact of these sites will be significant on residents, businesses and is totally unsuitable for the area - both in the development phase and when complete. There are already major traffic issues round the Cannon Lane area which need to be resolved as it is. The narrow lanes and a railway going through the middle are the most absurd settings for such a development and a school, presenting immense safety implications.

We know from recent years that Tonbridge is vulnerable to flooding, and meddling with the flood plain further is irresponsible, foolhardy and shows a distinct disregard for the current and future population (including the proposed new residents).

With 5 secondary schools in the area already, it is a very impractical move to add another in such close proximity. Surely there are other areas in TWBC who are far more deserving of a secondary school nearer to them that would benefit the existing and newly planned population.

These plans are alarmingly un-thought-through and will have significant repercussions on the infrastructure the community and the environment. They are shortsighted and will have short term benefits on paper and significant long-term implications - as your councilors have publicly stated in meetings, well after they are gone from this earth.

I trust you will take my comments in to consideration.

DLP_5514

Melissa Funnell

I live in the Somerhill Green development just off of Woodgate Way in Tonbridge, I’ve lived in Tonbridge all my life and work in the town as well. I’ve noticed in the last six months the increase of traffic in and around the town. To even consider this plan in my opinion is absolutely ludicrous, do any of the planning committee ever visit Tonbridge and see how overcrowded it is now?

DLP_5522

Alan and Claire Cattermole

We are writing to you as concerned citizens and residents of Golden Green. WE are wondering why, when there is so much space in Tunbridge Wells you have found it necessary to try and impose the erection of 4,000 homes on the borders of Tonbridge. You state that you are interested in helping to maintain green belt land and ancient woodland but have chosen a site in Tonbridge borders where both of these are going to be destroyed.

How can you justify putting large expensive, unaffordable houses on land bordering Tonbridge and then using the revenue to support Tunbridge Wells facilities? Not really fair is it.

Not only is Tonbridge green belt but also in a flood plain as well as an ANOB. Are you suggesting that you erect all 4,000 home in Tonbridge borders without providing a decent system to deal with the flooding? What happens when the Medway overflows as often happens in the winter, especially around the swimming pool area and Sainsburys. Don’t you think the concrete involved in erecting these houses will exacerbate the flooding situation?

I wonder how you think you are going to solve the traffic problem with the addition of a further 4,000 homes. Tonbridge is already suffering from tailbacks in both directions onto the high street much of the day. Rush hours are practically impossible to move around in. I suppose the plan is to use even more green belt land to increase the road area.

Where are those commuters in the expensive houses going to park their cars when they travel to London? Are they even going to be able to board the trains? These are often packed by the time they arrive at Tonbridge. There aren’t going to be parking places at other stations are there. There has been mention of new businesses in Tonbridge but where are they? And where are they going to go if more are mooted? There was mention of a new station being built at Capel. I wonder what the situation is regarding this? Capel and Tudeley are small and charming little villages where there is the renowned church – a major tourist attraction with the Chagall Windows.

WE have heard too that there is talk of a Capel bypass. How much greenbelt land will disappear under tarmac and how many animals and natural habitats will be destroyed to achieve this aim?

Rumour has it that Tonbridge Cottage Hospital could be commandeered by the local council who will then use the land to build houses. That is a very important facility for the people of Tonbridge with many facilities, the disappearance of which would lead to more disruption.

There is talk about a new school being built opposite Somerhill Schools. How is this even possible? How is it proposed that the children get to school? This will only add to the already hugely overcrowded roads in Tonbridge. ON top of that how many children will be bussed in from other areas. Imagine the destruction to the roads!

How will the small town of Tonbridge sustain such a huge influx of people? Are there plans to knock down the High Street and rebuild?

What a shame that Tonbridge is being used to achieve the aims of Tunbridge Wells fulfilling their housing quota just because the boundary seeps over the edge – BUILDING A NEW TOWN.

DLP_5523

Terence Gibb

I live with my wife at XXX Hayes Farm Cottages, Three Elm Lane, Golden Green, Tonbridge, Kent, XXX [TWBC: House number and post code redacted]. We are both retired and have lived here for 39 years.

I am not opposed to new housing developments, but I am opposed to development on greenbelt land generally, and particularly when other sites are available. Once the greenbelt hand has gone, it has gone forever. A large area of green fields, productive farmland, and woodland will be lost as the result of this Plan.

Although I will not be directly affected by the building of these 2,800 houses in Capel/Tudeley, my main objection relates to the effects this will have on the local area services regarding traffic, schools, doctors, hospitals and associated parking, both on local roads and in the Tonbridge area generally.

As the result of developments in the Tonbridge area, the traffic on the Hartlake Road and Three Elm Lane has increased considerably, being used as a 'short cut' from the B2017 at Tudeley to reach the A26 via Three Elm Lane, avoiding the considerable congestion in the Woodgate Way and Vale Road areas.

Proposed road improvements for the new development will do nothing but exacerbate the congestion already occurring at the roads into Tonbridge, causing virtual gridlock, particularly at rush hours when everyone is wanting to get to their destinations on time. Even when they arrive at their destination, (e.g. particularly for times like Hospital appointments, it can take 1/2 hour to find somewhere to park, if lucky).

The addition of another 2,800 housed with the corresponding increase in population in the area will have a disastrous effect on the local services. Medical facilities, (Doctors surgeries, local hospitals and A&E facilities) and public transport (buses and trains).

Local bus services are very sparse in the area making the car a more necessary requirement. Tonbridge station provides commuter services from a wide area, has limited and expensive parking, and the possibility of getting a seat to London is a matter of luck. Residents of the proposed development in Capel and Tudeley are most likely to choose Tonbridge station as their departure point to London areas causing increased congestion on the roads and on the trains.

It is already difficult to get a Doctor's or Hospital appointment in a reasonable time and one can expect a 4 hour wait when A&E department at Pembury hospital, Both Pembury and Maidstone hospitals are stretched and are often short of beds for urgent cases.

The inclusion in the strategy for a new school to be built on land adjacent to the existing Somerhill School will further add to the congestion at the roundabout at the junction from the B2017 from Tudeley lining Woodgate Way (for access to A21 and Pembury Road into Tonbridge) and Vale Road for access to Tonbridge Town centre car parks and Tonbridge Industrial estate, and to the A26 to Maidstone and the B245 to Sevenoaks via Bordyke. This roundabout is frequently gridlocked even with the current vehicle flow.

DLP_5533

Susan Fletcher

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

Creating a garden settlement at Tudeley of 2,800 dwellings will cause immense harm to residents of the Parish of Capel and to residents of South Tonbridge particularly. There will be a significant increase in traffic in to Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road every morning.

I live at the top of the Pembury Road which is already gridlocked twice daily due to the four existing schools situated there. The proposal to add a fifth is ludicrous. This does not take into account the schools and college at the bottom of the hill and less than a mile away.

People living in Tudeley will use Tonbridge Station for commuting and Tonbridge town services that will need more parking. The side streets are already used as overflow carparks by commuters, teachers and students and the existing noise and polluting traffic will be exacerbated by the proposed housing development.

We enjoy walking upon and breathing the fresh air around Capel. The beautiful landscape will be lost to us all forever. Whilst I accept the need for additional housing stock, I beg that brown field sites are considered instead. Traffic pollution and congestion have already had a detrimental impact on south Tonbridge. Please do not make it worse.

Tonbridge services and residents will bear the brunt of the development and I consider that this is why the planners have proposed the strategy.

DLP_5538

S Thompsett

I moved from childhood home in Three Elm Lane, Tonbridge to Tudeley with my husband in 1996 and reside in Crockhurst Street, Tudeley, Tonbridge. Our house falls within the proposed development land for the Tudeley garden settlement and stands immediately on the B2017, separated only by a pavement. I have worked locally in Tonbridge/Hildenborough for the last 35 years and my husband is retired. I have had the enjoyment of living on Hadlow Estate all my life and benefiting from the rural lifestyle it brings. The Plan, in its current form, causes for much speculation and concern as to whether our home and our future in Tudeley will even exist with this development.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1) and Tudeley Village (Policy AL/CA1).

Whilst I am not opposed to new housing developments. I am opposed to development on Green Belt land where it is not necessary (with alternative brownfield sites available and offered in the call for sites) and I strongly believe any development should be in proportion and supportive to its surrounding environment and neighbourhood. The proposed 2800 houses increase to the tiny hamlet (currently representing c2% of the TW borough) within Green Belt, is neither proportionate nor supportive.

Roads and Transport. The draft plan does not clearly show how the infrastructure will cope.

The B2017 is already extremely congested at peak times. During morning and evening rush hours Tonbridge is gridlocked with traffic backing up into Tudeley/Crockhurst Street. It is already a challenge to get safely and timely out of driveways along the B2017 at peak times and a 15 minute journey into Hildenborough easily takes nearer an hour via Tonbridge at such times. The extortionate increase in traffic arising from 2800 Tudeley dwellings will cause the surrounding road network to buckle. Adding to that the proposed secondary school site (AL/CA2), next to an already congested roundabout, only compounds to the gridlocking and potential for accidents.

In addition to the B2017, there are many surrounding rural B roads not designed for volumes of traffic (eg Hartlake, Three Elm Lane, Alders Lane) which will inevitably be affected, becoming ‘rat runs’ and unable to accommodate such a development on the proposed scale. No amount of road “improvements” will resolve this.

Furthermore, despite the success of the A21 Tonbridge/Pembury dualling in relieving the B2017 of A21 overflow traffic, the B2017 still becomes the primary A21 relief route when incidents occur on either carriageway, anywhere between Kipping's Cross and North/South Tonbridge roundabouts. Unfortunately this still happens on regular occasions, be it from accidents or roadworks taking place on the A21, causing continuous 2-way streams of heavy detouring A21 traffic to affect the B2017 enormously. The mass disruption and chaos this causes around Capel and Tonbridge now, with the current population, will not be alleviated by the proposed development.

Network Rail confirms a station at Tudeley is not viable. Tudeley residents will use Tonbridge Station to commute, householders likely favouring cars over bicycles/buses. Tonbridge will always be the local town for Tudeley residents, not Tunbridge Wells, due to proximity. Parking is already at a premium and commuter trains are already packed. Tonbridge will not cope with the strain put on it by this Tudeley development.

The Plan indicates ‘consideration’ to transport links either side of the Tudeley dwelling, but neither link has been determined at this stage and it is unlikely both, if any, will come into fruition, even then this will take place after the development of dwellings. Proposed ‘improvements’ to the B2017 are also unlikely to commence until after the development of dwellings, which means the current infrastructure will need to accommodate all construction haulage and machinery and all goods and services transport a new Town brings. Neither the B2017, nor the current residents along the B2017, will be able to cope with such long-term disruption. I feel the current infrastructure plans are therefore unsustainable.

In order for the Plan to be sound, clear explanation for the choice of location for the link road should be in place. An improved B2017 will only speed the traffic to the surrounding bottlenecks. In addition, due to the proximity of houses to the road either side of the B2017, to enable improvements, including cycle lanes etc, it can only result in required demolition of current dwellings in order to extend the current B2017. In turn, irreversibly destroying and breaking an existing historic and extremely settled rural community in order to provide a new town for external outside commuters and to satisfy majority of TWBC housing requirements in one development.

Flooding. Large parts of the developments will occur on the floodplain. Whilst the Plan has been drafted to take into consideration the risk from flooding, I remain concerned about the issues as experience says there is already a high risk in local flooding. Both the B2017 road itself, and Crockhurst Street properties/gardens, already suffer from surface water flooding during the slightest of downpours with run off from fields and water cascading down and off the B2017, due to insufficient drainage. Large developments on the farmed fields (which incidentally results in the loss of Grade 2 and 3 agriculture land) will increase flooding, not only in Tudeley, but surrounding neighbourhoods to the River Medway.

Heritage. The setting of historic assets like All Saint’s Church in Tudeley and current view of the Hadlow Tower and landscape of Kentish Oasts and listed buildings will be greatly impaired. The historic value and charm of the famous All Saint’s Church (and its Marc Chagall windows) which draws visitors worldwide, will be lost, by the surrounding houses, bus lanes and busy road in sight of a large roundabout.

Wellbeing/biodiversity. Quality and enjoyment of rural Tudeley life will be destroyed by the annihilation of green open space, countryside and its wildlife, together with the increased air, noise and light pollution. Local crime, currently almost non-existent within the Tudeley area, will inevitably increase in multiples.

Health Services. The garden settlement will cause an enormous impact on the already pressured local health services. Tunbridge Wells and Maidstone hospitals already have 3-4 hour A&E waiting times and suffer bed shortages. Paddock Wood and Tonbridge medical Practices are already over stretched and unable to facilitate timely appointments.

Utilities. The area has antiquated water system with low water pressure, timeworn water pipes, sewage and drainage systems.

I consider the current Plan to be unsound. The Plan preparation process didn’t include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan didn’t go through most of the plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment, no Biodiversity Assessment. I think that this version of the draft Local Plan isn’t complete enough to be ready for public consultation when the land for such a big proportion of the housing hasn’t had the same level of assessment as the rest of the plan. The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they didn’t know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. I think that the plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough.

DLP_5551

Jackie Packham

I am very concerned about development of rural land with proposed housing development

I fell considerably strongly that local facilities such as schools, Medical centres, roads and hospitals will be totally inundated with this amount of residents to the area

Please consider the effect on the area and residents before profits of builders.

DLP_5552

Lauren Stanley

I live in Tonbridge but have also spent the majority of my childhood and adult life residing in Paddock Wood. Most of my family live in Paddock Wood and Five Oak Green so I spend a lot of time in all three places.

I am objecting to The Strategy for Capel Parish (Policy STR/CA1).

Capel is a rural parish and that is why most people live there. It is inappropriate to place such a large part of the borough’s houses in such a rural area. It will cause even more traffic problems on the road (B2017) through Five Oak Green and onto Tonbridge or Paddock Wood and these are already terrible at all peak times. I cannot imagine how Tonbridge and Paddock Wood town centres and rail stations are going to cope with the traffic, parking and commuters (especially considering the extra houses being built from Ashford to Marden). I’m aware there is no further train capacity and both towns already feel at breaking point. There are huge problems with traffic, parking and the rail system and that’s without thousands more people to accommodate.

There are better alternatives to these proposals. The A21 corridor, land at Mabledon and Knights Park offer better alternatives with easy access to the A21. Capel may have to accept a small amount of additional housing in line with other rural parishes but that should be commensurate to its rural aspect and population (as with other Parishes within the borough).

DLP_5559

Julie Smithers

I know that this has been said multiple times, but now with the terrible floods in the Midlands, surely it's time to stop buildings on low lying ground.

Any new developments should be on high well drained ground.

Obviously, no one wants these new developments close to them, but, in the long term you have to consider the effects of global warming to rainfall and river levels.

On a more selfish note, we live in rural areas because we like the peaceful countryside. Some people prefer to live in towns.

Surely it is better for all reasons of transportation, work etc to enlarge the existing towns, rather than ruin the countryside.

Will TWBC buy our homes at the going rate that will hugely be de-valued because we are no longer living in beautiful surroundings.

Just think of 4000 homes. 6000 extra cars on our lanes. Roads will need upgrading. Not to mention the school runs, driving to work etc.

These new developments need to be in main towns and on brown field sites.

DLP_5567

Sarah Johnson

I live in South Tonbridge with my husband and two children. My husband and I work in central London and commute by train from Tonbridge. My family and I regularly drive around Tonbridge, and regularly walk around Tudeley and Capel and the surrounding areas with my family and our dog.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

Creating a garden settlement at Tudeley of 2,800 dwellings will cause immense harm to residents of the Parish of Capel and to residents of Tonbridge. There will be a significant increase in traffic in to Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road every morning. The already unacceptable levels of traffic between 7.45am to 9am on Woodgate Way, Vale Road and Pembury Road coincide with the site of a proposed new 6 form entry senior school. This proposed school will be on the border with Tonbridge, split by a main line railway and alongside a heavily used road. This appears to be a terrible site for a school, surrounded by heavy traffic and requiring children to cross a busy train line to access both sides of the site.

People living in Tudeley will use Tonbridge Station for commuting and Tonbridge town services that will need more parking. The increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times and can’t be made wider in most places. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable. Parking in and around Tonbridge Station will be even more difficult. Network Rail have confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. Most people living in the new garden settlements will drive privately owned cars, despite initiatives to encourage bus and bicycle use. The costs of infrastructure on the Tonbridge & Malling side of the boundary will have to be carried by Tonbridge & Malling residents whilst Tunbridge Wells will receive council tax from the residents in the new dwellings. The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area. There will be an increase in pressure on Tonbridge health services, amenities and car parking as residents from the new garden settlement at Tudeley will use Tonbridge as their local town, not Tunbridge Wells, because Tonbridge is much closer.

If TWBC is seeking additional council tax revenue from new homes, it should site these homes in locations which would rely on infrastructure provided by TWBC, and which would not adversely impact residents of TMBC.

Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but I believe that flood risks will increase. Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding. There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape. Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saint’s Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. That will cause great harm to its value as a heritage asset of world renown (due to the complete set of Marc Chagall windows).

The garden settlement at Tudeley can never be one settlement as it is divided by a railway line that has very narrow, weak crossings. Putting in larger crossings at frequent points across the railway may be possible but it won’t tie the two halves of the settlement together enough to make it one settlement, so it will never satisfy garden settlement principles.

Creating so much housing in Capel 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, including rare species. This area should remain rural with agricultural land that can be used to provide food.

I believe that housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan. TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant.

The plan preparation process didn’t include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan didn’t go through most of the plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment, no Biodiversity Assessment. I think that this version of the draft Local Plan isn’t complete enough to be ready for public consultation when the land for such a big proportion of the housing hasn’t had the same level of assessment as the rest of the plan.

DLP_5570

Jan Trott

I have been reading about the above mentioned proposed development, and uncharacteristically feel compelled to comment.

The development, if approved, would selfishly allow TWBC to take credit for building a number of homes which if built, would have zero impact on their essential services (except for bin collections)! The proximity of the proposed development to Tonbridge must be appealing to TWBC as it satisfies the demands made by central government to build homes while avoiding the disapproval of most of its own residents as they wouldn’t experience any negative impact. I cannot believe there are no alternative appropriate sites within the Tunbridge Wells boundaries, although planners may wish to avoid the ‘more local’ controversy.

As a Tonbridge resident for over 20years I have seen Tonbridge town itself invest in a considerable number of developments in recent years, all of which have increased the volume of traffic, numbers of commuters and pressure on local services including Doctors surgeries and schools. Tonbridge facilities would inevitably have to absorb the additional pressure of this development by another Borough which would only be detrimental and have no benefit locally.

Whilst appreciating that more homes are needed and each area has to provide its share, the need to make proposals palatable to local communities must be increasingly challenging. Surely, where local proposals such as this would make such an unwelcome impression on the adjacent areas, TWBC must consider other options where they would have to accept the inevitable consequences themselves.

DLP_5571

Angela Ballard

I strongly object to the building of houses in Capel. This is going to have huge impact on Tonbridge. The car parks for commuters in Tonbridge are already full and brimming over and not to mention the impact on the roads and surrounding area. The car parks at the weekend are always full to capacity . The area is prone to flooding, it floods quite often. This will spoil the village area and it also green belt- not to be built on! There must be some brown-fill areas in the nearby vicinity. This is definitely a NO NO situation.

PLEASE LISTEN TO THE PUBLIC!!!!!!

DLP_5578

Kate Butcher

My name is Katie Butcher and I live with my partner in Hazelwood Close, Tonbridge (the new build development on Somerhill Green). I wish to express a real objection to the secondary school being developed on Woodgate Way - this will cause a real increase in traffic to the roundabout on Woodgate Way - once which already struggles to cope with the current infrastructure, let alone the increased number of houses you wish to development in the Capel area.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

DLP_5587

A R Exall

GENERAL COMMENTS with specific reference to Capel Site (CA1)

My name is Amber Exall. I was brought up in Tudeley. My parents have a holiday letting business in Tudeley and my siblings all work in the surrounding areas of Kent.

Tudeley is my home, I enjoy the rural beauty of the land and it’s abundance of life. I often travel to Tonbridge and Paddock Wood for local amenities and commutes to London.

GREEN BELT

Recently there has been a massive push to make people aware of climate change, doing our best to recycle and be mindful of our impact on the planet. News reports constantly imply we must do the right thing for future generations and for our planet.

Hence why this plan is so frustrating. The plan for more than 2,800 houses in Tudeley in the rural open landscape in Green Belt is contradictory to our wellbeing and that of the planet. This plan is putting aside the protection of Green Belt land for profit. Future generations will not have the benefit of the countryside, once this land is gone it is gone forever.

As the plan for Tudeley ‘town’ is so vast it will need a new road systems to deal with the amount of traffic generated, as well as new sewer systems, etc. This will mean further protected land being destroyed to accommodate this. The Borough has 25 percent of unprotected land that has only attracted small scale developments. The attraction to this part of the Borough is that the 400 + acres of Green Belt land proposed in CA1 belongs to one land owner so it is the ‘easy option’. This Green Belt land is lucrative for the developers as it will attract a higher premium for the homes. These homes will not be affordable homes. It would also open the door for further development in the area, it will be ‘the thin end of the wedge’.

The plan will create an impact on the land, the damage would be irreversible. I understand there is a need for affordable homes but it would be better for TWBC to seek other possibilities which will not harm rural and Green Belt land such as brownfield sites with established roads and transport links.

BIODIVERSITY

Tudeley has a diverse amount of wildlife from newts, bats, birds, foxes, deer, etc. I am lucky enough to have seen long eared owls, barn owls, tawny owls and little owls in my garden amongst other more common British birds. High numbers of yellowhammers and linnets have been recorded in the development footprint. These birds are in decline nationally but are thriving in Capel.

If these plans go ahead many species will decline in the midst of construction either from loss of habitat or contact with human activity. Many birds die on the roads due to being pulled by winds created by passing cars. Wildlife needs to be protected not destroyed.

ENVIRONMENT

1 Pollution

Air quality, noise and light pollution will further disrupt ecosystems, have adverse health effects and waste energy.

2 Climate Emergency

Climate change is on everyone’s minds in many shapes and forms. A big focus is lowering our carbon footprint, emissions, recycling, reducing waste, etc. The plan is vast and though it says it will build new roads to meet the demand, it still has transport issues.

With 2,800 more properties being proposed in Tudeley town a build such as this needs a train station or a regular, reliable bus network to cater for demand. Network Rail have confirmed that a station at Tudeley is not viable and will not be built in this planning period. Since living in Tudeley I have never caught a bus back home from Tonbridge or any surrounding area. There is not a regular bus service to Tudeley. There is only a very limited almost nonexistent timetable.

With limited public transport and the nearest railway station being a drive away, the plan will cause further traffic problems in Tonbridge and Paddock Wood. These homes would inevitably be bought by wealthy commuters wishing for easy driving routes to Tonbridge and Paddock Wood Stations, creating more stress for Tonbridge and Paddock Wood. Already packed, cramped trains will have to try to accommodate more commuters as well as the need to create and extend existing parking spaces for the stations. The existing car parks, though big, would need to be extended to meet these needs, but where will they find the land and the space? This may lead to more issues of off road parking which could make it harder for locals to drive or work in the high streets.

Other options to limit carbon emission is to cycle to the station. However, though it is an easy drive from Tudeley to Tonbridge or Tudeley to Paddock Wood, these journeys are not so easy by bicycle. Commuters will not start their day with a 15 minute bike ride, possibly in the dark when it is raining, down into Tonbridge and definitely would not want the uphill cycle after a full day in the office to get home.

3 Community

It has been devastating to hear, without adequate warning, that TWBC is wanting to push through such a big development without adequately consulting the local community. It seems that this plan was hatched a long, long time before any consultation with the local Community. We have been totally left out in the cold.

The Community is infuriated by the announcement, especially as it so ill thought out. We fear that the area will be torn apart and our beautiful open countryside totally destroyed. Many who live in homes owned by the Hadlow Estate are anxious to know if they will be pushed out to accommodate the build. There is a worry that the close Community will be lost, swamped by these 2,800 new homes. It is horrific to think we may soon live in a town, a busy suburb, instead of the beautiful rural area we have grown up in.

My own feelings are of frustration. TWBC claim that Tudeley town will accommodate affordable homes. I am one of the large percentage that cannot afford my own home. I live with my parents saving what I can in the hope that I will one day be able to own my own property. However, Tudeley new town will only serve to increase house prices in the area and I will never be able to afford to live in the area I grew up in. In theory I should be interested in this development, but I’m not. These aren’t just a few houses that are being built, the plan is to create a commuter town destroying endless amounts of rural and Green Belt land. With it being built on such prized land these houses will come with a premium price tag. The reality is young people like myself and families in the local community will not be able to afford these houses. The wealthy who commute to London will buy these ‘affordable’ houses. These houses will not help to home the actual Capel Community itself.

A further issue I have with the plan is that Capel has been landed with over 60% of TWBC’s new housing needs. Wouldn’t it be fairer for all the parishes in TWBC to have their share of the new housing needs? Tonbridge & Malling BC will be landed with all the servicing costs but TWBC will collect the revenue from the new houses. How is that fair? TWBC’s plan to site these new homes in Capel seems unfair and unjust not only for our Community but for Tonbridge & Malling BC as well. Tonbridge & Malling will struggle with the demands these homes will bring to the area.

4 Agriculture

The CA1 land is rural agricultural Green Belt land. These agricultural fields are essential. It is a business not only for the farmers but also for tourism and other rural industries.

These fields also are a haven of diverse wildlife, most of the wildlife use these fields for shelter and food. The fields even have natural woodland corridors so the wildlife is not disrupted while the crops are harvested.

The loss of the agricultural land will not just be a blow to the wildlife that relies on it but also to the Community. When you visit Capel the main attraction is the splendid, vast amount of open countryside with its sweeping views of the agricultural lands and woodlands, it is beautiful. Losing this land would be devastating and it could never be replaced. It will affect the working farmers in the area and their livelihood.

5 Flooding

Having lived in Tudeley for so long I have seen the destruction when the River Medway floods and how it impacts on Tonbridge and Paddock Wood. Covering farmed fields with houses and roads will cause significant run-off and will make the Medway flood even more. It will not only cause flooding risks to Capel and Paddock Wood but also surrounding area.

6 Landscape

I have stated this many times in this document, the heart of the area is the landscape, it is untouched and enjoyed by the Community and many others from other boroughs, counties and countries. If these plans go ahead we will lose a vast amount of Green Belt and rural landscapes which cannot be recreated once destroyed.

This plan is creating a town from what should be protected land. There has been an overwhelming demand by the public to keep our Green Belt land safe, keep it for the future generations. These plans have no regard for this. TWBC have gone for the ‘easy option’, one land owner. Why wasn’t more energy given to looking for a more sustainable choice, such as brownfield options?

7 Heritage

Tudeley All Saints Church is renowned. It is one of the last churches to feature stained glass windows by the famous Russian Artist Marc Chagall. The windows were installed a few days before his death.

This is a one of a kind church and an important landmark in Tudeley. The isolation of the church means there is no obstruction of light creating the ethereal effect. The plans show many dwellings around the church which could obstruct the light, thus destroying the beauty of the church as well as placing the church itself in danger. Drilling and digging close to the church may harm the church and windows.

The real danger though is vandalism to the Church. Small parishes and churches are in constant fear of vandalism and theft. Recent reports from the Small Church Conservation Charity state that vandalism is more prominent in busy/built up areas. These windows are irreplaceable and sort after pieces of contemporary art work. They could easily be destroyed by a rough hand or stolen. The Parish successfully looks after the Church with input from the Community but with more homes there will be pressure on the Parish to install security which is expensive for such a small Parish.

Our Green Belt and open landscape needs protecting. People visit us from all over the world taking in the breath taking landscape and wildlife, to get away from the hectic week and have a quiet moment in the countryside. If these plans go ahead we will lose these wonderful peaceful havens, we will become a suburban commuter town and we will lose valuable countryside.

8 Water & Sewage

From past ‘Save Capel’ meetings it has come to light that many parts of Capel and Paddock Wood have a very limited sewage line that hasn’t been updated since it was installed years ago.

Recent construction near Paddock Wood, Mascalls, has had to stop on the discovery that the sewage system was not adequate enough for the build. The developers had to factor in additional work to the sewers/cesspits for these houses.

With this in mind, not only will the plan destroy the land for these homes to be built, but more disruption and destruction will occur during the installation of a new sewage system on a scale as big as Tonbridge.

9 Location

The B2017 Five Oak Green Road is the fastest route from Hartlake Road to Tonbridge. This road gets very busy, especially in rush hour and school drop offs/pick up times. Somerhill School is situated on this stretch of road and during the school rush hour it is very congested making the journey longer if you don’t plan ahead. Further homes means more commuters and school pupils travelling along this stretch of road in the rush hour. On top of this the proposed plans wish to place a senior school opposite Somerhill School.

I cannot stress enough that the proposed CA1, Tudeley ‘town’, is so problematic for so many reasons. An ‘easy option’ is not the best option!

The inappropriate site at CA1, to which I strongly object, should be dropped in its entirety from the Local Plan.

DLP_5591

Max Green

I am also writing to object to the wider “Strategy for Capel Parish” (Policy STR/CA1).

Building so many new houses in Capel Parish will require the destruction of woodland, hedgerows, meadows, and farmland that is Green Belt land and should be protected.

While I recognise the need to provide housing, I do not believe building so many new dwellings on Green Belt land fits in with wider government policy on the environment, biodiversity and climate change. Nor to do I believe it is truly necessary given the availability of brownfield sites and the large number of houses standing empty across Kent.

I also believe there are serious gaps in the planning process for Tudeley – information is seriously lacking when it comes to Green Belt, Landscape and Biodiversity assessments.

TWBC is effectively using Capel to offload their housing needs on green belt land, polluting a rural area rather than spreading development across the borough on brownfield sites or placing the garden settlement in the middle of the borough, to make it accessible north and south. The developments in Tudeley and East Capel are unsustainable and will unfairly place huge and unnecessary pressure on Tonbridge.

DLP_5601

Sean Chapman

I have lived in Tonbridge my whole life, was educated in Tonbridge and have spent most of my working life in the Tonbridge/Tunbridge Wells area. I feel that makes me particularly knowledgeable of the changes Tonbridge has gone through in that time and its issues and needs for both the present and the future.

For the last six years i have lived in South Tonbridge and in that time alone the increase in numbers of residents and cars has been unimaginable. The increased number of houses and flats, together with the mainline railway station and unusually high number of schools result in the key roads in and around Tonbridge and South Tonbridge in particular being in a permanent state of grid-lock a large proportion of the time.

The idea of adding another 4,000+ homes and a senior school onto the outskirts of Tonbridge will make the town centre, mini-bypass / industrial estate and surrounding areas inhospitable and uninhabitable.

I OBJECT to the Tudeley (STR/CA1), Senior School (STR/CA2) and East Capel (STR/PW1) planning strategies in the STRONGEST possible terms and for the following reasons:

Tonbridge is UNABLE to support its current ever increasing population. That is WITHOUT the creation of a new garden town on its doorstep that is totally reliant on its services.
TMBC has indicated a strategy to discourage unnecssary car use and ease congestion in Tonbridge, via the provision of increased footways and cycle paths. Yet these plans by TWBC render this ethical and environmental strategy of TMBC totally useless, with the provision of the 4,000 totally car dependent homes and senior school on its perimeter. This is UNETHICAL and WRONG.
Only this week i had to queue for ten minutes just to buy a train ticket after 9am and subsequently missed my train. It dawned on me that this is likely to become the norm with the addition of these homes and that is simply not acceptable.
The proposed area of development is an area of natural beauty, intrinsically linked to the history of the region with its orchards and hop growing past. The opportunities to explore this area via its network of public footpaths are vast and spectacular. In today's world, with the surging mental and physical health issues it creates, there is not an expert in the world that would understate the absolute importance of encouraging people to experience and enjoy the natural environment around them. Yet TWBC proposes to remove and urbanise this very environment, that provides exercise and enjoyment to so many. This is UNETHICAL, SHORT-SIGHTED, IRRESPONSIBLE and WRONG.
Perhaps TWBC should concentrate on utilising the many derelict / empty buildings and sites in the existing town first, before it decides to destroy a natural environment.
I would add that in the current Brexit related times, with a possible need to become self-sufficient and a growing conscience in respect of food air miles, the Garden of England should perhaps be that once again, NOT an urban jungle.
Building on Greennbelt is IMMORAL and WRONG.
The proposed area of development is a FLOODPLAIN. This area has already suffered from severe flooding through the years, with the Leigh flood barrier also being at full capacity several times in recent years. Building to this scale on floodplains SHOULD NOT BE ALLOWED. It is quite simple, these developments will increase the flood risk for this area and downstream (Maidstone) exponentially and that should not be allowed to happen.
Building on floodplains is IRRESPONSIBLE and WRONG.
The proposal of a senior school, on greenbelt land, with a railway line running through the site, on the edge of town with road travel the only option, in an already congested area in terms of road traffic is DANGEROUS and NOT SUITABLE.
Finally, the fact that TWBC can propose a development and strategy that will have more of an impact on its neighbouring borough council is both IMMORAL and WRONG. The already hugely over-subscribed services of Tonbridge will not be able to cope, Tonbridge will become clogged and struggle to breath, yet TWBC will tick 4,000 homes off its target and collect its council tax, whilst suffering minimal fall-out. How can that be right? How can that be acceptable?

These strategies are wrong and must not be allowed to happen. The damage will be irreversible. TMBC will suffer unbearably under the weight and cost of the increased burden from these homes and the residents of TONBRIDGE will bare the scars of TWBC's irresponsibility every single day.

DLP_5611

Tom & Helen Adam

We are local residents within Tunbridge Wells Borough and we are writing to object to the Strategy for Capel Parish (Policy STR/CA1), in particular to the proposed New Town at Tudeley.

We summarise our objections as follows.

1. Destruction of Green Belt

a. This is Green Belt land lying within Broad Areas 3 and 4 as defined in a TWBC survey carried out by Land Use Consultants in 2016 and 2017. That survey found that removing land in BA3 and BA4 from the Green Belt would cause the highest category of harm (“very high”) to the main purposes of the Green Belt designation. It is obvious that this is correct.

b. In particular, irreparable harm would be caused to the following purposes of the Green Belt, as listed in para 134 of the NPPF February 2019: Purpose (a) (“to check the unrestricted sprawl of large built-up areas”); Purpose (b) (“to prevent neighbouring towns merging into one another”); and Purpose (c) (“to assist in safeguarding the countryside from encroachment”). Building a New Town which would be bigger than the existing settlement at Paddock Wood represents a massive intrusion into the Green Belt and will inexorably lead to the gradual coalescence of Tonbridge/New Town/Five Oak Green/Paddock Wood. This is precisely what the Green Belt is there to stop.

c. No exceptional circumstances exist to justify such a drastic destruction of Green Belt land. In particular, it is not justified by housing need.

d. First, para 11.b of the NPPF states as follows:

strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:

i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or

ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

e. This expressly allows TWBC to argue that it is not going to meet its objectively assessed need in full because it cannot do so without destroying hundreds of acres of Green Belt land. That argument could and should be advanced.

f. Second, the housing allocation in the draft Local Plan is overstated. TWBC has scaled up its objectively assessed need (13,560 homes) to 14,776 despite having strong grounds to lower it because of the large amount of Green Belt and AONB land in the Borough. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then deciding not to build the remaining 1,584 (on the basis of the exception allowed by NPPF 11.b) would be a much better approach. The case for taking this approach is also supported by the most recent ONS figures, which show that population growth in the borough is slowing. There is no need for this New Town at all, still less “exceptional circumstances”.

2. Environmental issues

a. This plan involves the urbanisation of 400 acres of Grade 2 agricultural land (as shown by TWBC’s Development Constraints Study October 2016, Figure 5). Grade 2 land is defined by the NPPF as being part of the “best and most versatile agricultural land” and the Borough has very little of it (see TWBC’s Agricultural Land Classification Study 2014). The NPPF states that “Where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality” (footnote 53).

b. Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but flood risks will increase. Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding.

c. There will be an increase in air, light and noise pollution that will create a visual scar across the landscape. Views to the Low and High Weald will be impaired.

3. Infrastructure issues - general

Building a large New Town on a site which is connected to the world only by an already overcrowded B-road (the B2017) and a few country lanes (like Hartlake Road) is an incredibly stupid idea. An extra 2,800 homes means an extra 3000+ cars. What are they supposed to drive on? There will be absolute gridlock without major, carefully planned infrastructure upgrades to the entire surrounding road network. But the draft Plan contains no details of proposed upgrades to solve this issue at all. This is unsound planning. The only specific proposal is for a bypass of Colt’s Hill, which has been a long-term objective of TWBC, is unconnected with the New Town and would not help the traffic issues resulting from the New Town one iota. This is a fundamental flaw.

4. Infrastructure issues - Tonbridge

People living in the New Town at Tudeley will inevitably use Tonbridge as their local town, not Tunbridge Wells, because Tonbridge is much closer. We know that this is true because that is what we do – despite living in Tunbridge Wells Borough, we use Tonbridge all the time because it is far closer. This has significant infrastructure issues which the draft Plan does not even begin to grapple with.

a. Most people living in the New Town will drive privately owned cars, despite initiatives to encourage bus and bicycle use, and the increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times. In particular there will be a significant increase in traffic on the B2017, Woodgate Way, Vale Road and Pembury Road, exacerbating the extreme traffic congestion that exists on these roads every morning. This will be made still worse by the proposed new school at Site CA2, which would inevitably generate large amounts of car traffic. See the separate detailed objections to the new school lodged by the Postern Lane Residents’ Association for more details.

b. Trains from Tonbridge Station are already packed and the station car park is near maximum capacity, despite recent development. The inevitable rise in passengers trying to use Tonbridge Station (Network Rail have confirmed that a station at Tudeley is not viable at present) for both commuting and leisure will be unsustainable.

c. Tonbridge town services (supermarkets, pharmacies, GPs, dentists and so on) will be swamped

d. There is already a shortage of parking in Tonbridge.

5. Infrastructure issues – the New Town site itself

This is a short point. The Tudeley site is divided in two by a main railway line that currently has only two narrow crossings. Putting in larger crossings at more frequent points across the railway may be possible (at enormous cost) but it will not tie the two halves of the settlement together sufficiently to make it one settlement, so it will never satisfy “garden settlement” principles.

6. Heritage issues

The major issue here is the impact of the New Town on Tudeley Church, which is Grade 1 listed and a world-famous heritage asset because of its Chagall windows. It is right on the edge of the New Town and the visual and traffic impact on it would be substantial and wholly wrong. It is currently a rural church; under this proposal it would be surrounded by modern housing and bus lanes and sit next to a busy road in sight of a big roundabout. That will cause great harm.

7. Consultation and growth corridor options

a. The plan preparation process did not include the New Town at Tudeley (ie sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan did not go through most of the plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment, and no Biodiversity Assessment. It is in appropriate to put this version of the draft Local out for public consultation when the land for such a big proportion of the housing has not had the same level of assessment as the rest of the plan.

b. The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they didn’t know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. The plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough. It is hard to avoid the suspicion that TWBC is using Capel as an “easy” solution to its housing needs, urbanising a rural area which it can buy from a single landowner rather than doing the hard work of spreading development across the borough on multiple brownfield sites or in growth corridors. This is not sound planning.

Creating a New Town at Tudeley of 2,800 dwellings will cause immense harm to the Green Belt, to the environment, to residents of the Parish of Capel and to residents of Tonbridge. Please reconsider and replan.

DLP_5612

Tom and Helen Adam

We are local residents within Tunbridge Wells Borough and we are writing to object to the Strategy for Capel Parish (Policy STR/CA1), in particular to the proposed New Town at Tudeley.

We summarise our objections as follows.

Destruction of Green Belt

This is Green Belt land lying within Broad Areas 3 and 4 as defined in a TWBC survey carried out by Land Use Consultants in 2016 and 2017. That survey found that removing land in BA3 and BA4 from the Green Belt would cause the highest category of harm (“very high”) to the main purposes of the Green Belt designation. It is obvious that this is correct.
In particular, irreparable harm would be caused to the following purposes of the Green Belt, as listed in para 134 of the NPPF February 2019: Purpose (a) (“to check the unrestricted sprawl of large built-up areas”); Purpose (b) (“to prevent neighbouring towns merging into one another”); and Purpose (c) (“to assist in safeguarding the countryside from encroachment”). Building a New Town which would be bigger than the existing settlement at Paddock Wood represents a massive intrusion into the Green Belt and will inexorably lead to the gradual coalescence of Tonbridge/New Town/Five Oak Green/Paddock Wood. This is precisely what the Green Belt is there to stop.
No exceptional circumstances exist to justify such a drastic destruction of Green Belt land. In particular, it is not justified by housing need.
First, para 11.b of the NPPF states as follows:

strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:

ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

This expressly allows TWBC to argue that it is not going to meet its objectively assessed need in full because it cannot do so without destroying hundreds of acres of Green Belt land. That argument could and should be advanced.
Second, the housing allocation in the draft Local Plan is overstated. TWBC has scaled up its objectively assessed need (13,560 homes) to 14,776 despite having strong grounds to lower it because of the large amount of Green Belt and AONB land in the Borough. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then deciding not to build the remaining 1,584 (on the basis of the exception allowed by NPPF 11.b) would be a much better approach. The case for taking this approach is also supported by the most recent ONS figures, which show that population growth in the borough is slowing. There is no need for this New Town at all, still less “exceptional circumstances”.

2. Environmental issues

This plan involves the urbanisation of 400 acres of Grade 2 agricultural land (as shown by TWBC’s Development Constraints Study October 2016, Figure 5). Grade 2 land is defined by the NPPF as being part of the “best and most versatile agricultural land” and the Borough has very little of it (see TWBC’s Agricultural Land Classification Study 2014). The NPPF states that “Where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality” (footnote 53).
Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but flood risks will increase. Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding.
There will be an increase in air, light and noise pollution that will create a visual scar across the landscape. Views to the Low and High Weald will be impaired.

3. Infrastructure issues - general

4. Infrastructure issues - Tonbridge

Most people living in the New Town will drive privately owned cars, despite initiatives to encourage bus and bicycle use, and the increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times. In particular there will be a significant increase in traffic on the B2017, Woodgate Way, Vale Road and Pembury Road, exacerbating the extreme traffic congestion that exists on these roads every morning. This will be made still worse by the proposed new school at Site CA2, which would inevitably generate large amounts of car traffic. See the separate detailed objections to the new school lodged by the Postern Lane Residents’ Association for more details.
Trains from Tonbridge Station are already packed and the station car park is near maximum capacity, despite recent development. The inevitable rise in passengers trying to use Tonbridge Station (Network Rail have confirmed that a station at Tudeley is not viable at present) for both commuting and leisure will be unsustainable.
Tonbridge town services (supermarkets, pharmacies, GPs, dentists and so on) will be swamped
There is already a shortage of parking in Tonbridge.

5. Infrastructure issues – the New Town site itself

6. Heritage issues

7. Consultation and growth corridor options

The plan preparation process did not include the New Town at Tudeley (ie sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan did not go through most of the plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment, and no Biodiversity Assessment. It is in appropriate to put this version of the draft Local out for public consultation when the land for such a big proportion of the housing has not had the same level of assessment as the rest of the plan.
The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they didn’t know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. The plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough. It is hard to avoid the suspicion that TWBC is using Capel as an “easy” solution to its housing needs, urbanising a rural area which it can buy from a single landowner rather than doing the hard work of spreading development across the borough on multiple brownfield sites or in growth corridors. This is not sound planning.

DLP_5619

Julie Schippers

We hope the TW planning will challenge the number of houses being proposed for our area with central government on the basis that much of the borough contains Areas of outstanding nature beauty and green belt, plus out of date data is being used to calculate housing requirements and should be reassessed.

We have particular and serious concerns regarding the proposed development project for Tudeley/Capel, which will cover precious beautiful countryside and gridlock the Tonbridge area. Also we have big concerns about the development of Paddock Wood, where we understand the current housing development (Church Farm) has not been as successful as planned - so why build more? Is there a genuine need for more housing where the current and near future stock is not selling well?

We also understand the LImits to build are being moved in Matfield and other areas to accommodate more development. LTB are in place to protect communities and sprawling development and can’t just be changed because it suddenly doesn’t suit.

In addition, much of the plan seems to rely on developers providing the infrastructure to go along with the developments. As evidenced by developments such as Ryewood in Sevenoaks, where much was promised (GP surgery, shops and so on) and nothing delivered, it would be a disaster if this was allowed on a larger scale in the proposed ‘garden’ villages.

Please reconsider the plan, ask for more time to consider the need for more housing and look to make the plan more holistic and proportional across the borough.

DLP_5620

Jennie and Michael Baulf

We are Jennie and Michael Baulf, of XXX, Hartlake Road, Golden Green [TWBC: House name redacted].

We have lived here for over 40 years and can claim a good knowledge of the area, its topography and infra structure.

It became a matter of concern to us to learn that Tunbridge Wells Borough Council have included plans to build over 2000 homes on land in Tudeley on the boundary between Tunbridge Wells and our Borough, Tonbridge.

We appreciate that you are under pressure to meet targets for new housing set by central government.

This can be all or part achieved by initially searching out Brown Field sites, infilling and parcels of Green Belt land that are considered of a scale that is least injurious to landscape and infrastructure. This would be a lengthy exercise fully justified by the long term nature of the finished result. It was no wonder then that when a local landowner in tandem with a major public company came forward with a ready made package embracing their property holdings stretching from Capel to Paddock Wood the larger part of your requirement was met and incorporated into your Local Plan.The consequences of development on this scale on a new site is to create heavy demands on the existing infra structure and while there are proposals for improvements they do not address the consequences of the development that will spill over the border into Tonbridge who were not included in any early stage discussions. Indeed it seems that even in your own borough it seemed a good idea to push the development to the extreme borders with no impact on the centre.

Our concerns are that the proposal will increase the traffic, noise and pollution, create congestion, overstretch transport links, especially rail and have serious knock-on effects on roads in adjoining boroughs. Our greatest concern is the destruction of acres of Green Belt land. The proposal sits in the centre of the open lung that lies either side of the River Medway and is an area to be kept in reserve and hopefully for posterity and a haven for wildlife as testified by the numerous visitors. We hope that consideration will be given to removing this proposal from the Local Plan and limiting the housing provision to areas that have adequate supporting facilities and cause the least disturbance to residents, the Green Belt , the Medway corridor and the life beyond Tunbridge Wells.

DLP_5621

Ruby Joan Holdom

I live at XXX Haydens Mews in Tonbridge, XXX and I wish to add my name to all the other people who do not want to see large housing developments coming to Capel and Tudely [TWBC: House number and post code redacted].

My problem is that although I live a mile from the centre of Tonbridge in a retirement complex we are having big problems with car parking. We have commuters parking here in our complex all day when we need the parking spaces for carers, doctors, nurses etc.

The council has put down some yellow lines leaving just a few vacant parking places but these are taken up every day by commuters who do not wish to pay the parking charges in the town. It is so very unfair and unreasonable.

Commuters are already spoiling our lovely town and those of us who live here and we just cannot cope with such a large influx of people and do not have the infrastructure to cope with them.

Tonbridge will soon become a giant car park.

DLP_5622

Philip Clarkson Webb

The Government has assessed the need for extra housing in Tunbridge Wells Borough at 13,560 units, which TWBC has upscaled to 14,776. Why?

Of these 14,776 new dwellings, the draft Local Plan requires 2,800 to be built in Tudeley parish and a further 1,500 to be built in Capel parish, leaving the remaining 9,476 to be built in the whole of the rest of the borough. This places an inequitable burden on just these two parishes.

TWBC's own Sustainability Appraisal shows that Paddock Wood can be expanded to meet most of the housing needs without using Green Belt land at East Capel.

Furthermore, recent floods in Yorkshire and the Midlands have shown the folly of building new housing on flood plains such as those at Capel.

New housing in Capel and Tudeley would inevitably draw extra commuter and other traffic to Tonbridge station and Tonbridge businesses which are already heavily congested. The costs of any new infrastructure needed to cope with the extra traffic would inevitably fall on Tonbridge residents while any benefits in the form of extra council tax would accrue to TWBC.

Finally, as a Tunbridge Wells resident, I would ask TWBC to do a thorough survey of brownfield sites suitable for development, or, if this has been done, to update the figures and to publish them, since this would a major impact on the alleged need to build housing in the Green Belt.

DLP_5624

Jon Webber

I am a resident of Golden Green and travel through the beautiful countryside of Capel on a daily basis.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

I would like to express my concern at the proposal to build 4,000+ houses at Capel and Tudeley for numerous reasons as highlighted below.

Traffic

Tunbridge Wells has long suffered from chronic traffic issues. These housing plans will now export such traffic issues to the edge of your borough, to Tudeley and Capel. From the plans for another 4,000 houses and let's be generous 6-8,000 cars, highways appear to be treated as a separate entity, which is a mistake as past experience must surely indicate. Kings Hill is not a good comparison here. Kings Hill was always a brown field site, an old airfield. Further the roads in the area are considerably better providing access to major arterial routes. I do feel that Tonbridge and Malling Council made more complete decisions when considering a new garden town on that site.

Trains

The trains are already packed from Tonbridge. There is insufficient parking past 7.45am and further demand will result in clogged residential streets. This will have a significant impact on the ability of the local train service to cope, with more packed carriages and the congestion at London Bridge will mean that more trains cannot be accommodated.

Flood Risk

The flooding risk will now be significantly increased. By concreting over the countryside, the impact will be water running down to the flood plains in Hartlake Road, which will already be needed for Hildenborough and Tonbridge - not least because so many more houses have been added to the riverside in that area. There are also plans to quarry the gravel from the floodplains, where will all the water go? Now that the weather appears to be more extreme, the rain is more torrential and sudden. We've seen flooding in Hildenborough and Tonbridge within the last decade alone, not to mention the issues in Yalding.

Senior Schools

There is to be a plan for a new senior school, but in a place where walking will be hazardous and result in more traffic. Regardless the key demand is for more grammar places, which does not appear to be considered as part of this application.

GP access

Currently it is difficult to get a doctors appointment within a fortnight, the additional demand on doctors and other heath professionals are not being managed and fall to the edge of your borough and therefore will fall to others to manage.

Access to Tonbridge

Tonbridge is busy as well, it's difficult to park at weekends to shop etc. There doesn't appear to be any joined up thinking on how people will shop, park etc., in these plans.

Countryside

You are proposing to build over beautiful countryside with concrete, brick etc, some of the most beautiful countryside in the local area.

In summary it appears that all the day to day activities from schools, road access, parking and trains, will be pushed onto Tonbridge. For which presumably they will receive no council tax in return?

If these plans are to go ahead I would like a full explanation as to how each of the issues highlighted will be mitigated with guarantees that required works are planned and completed. I am convinced that there are better sites throughout the Tunbridge Wells Borough for these houses to be built.

DLP_5625

Daniel Maclaren

I would like to object to the strategy for Capel Parish (policy STR CA1). This is Greenbelt land and provides a buffer as intended to prevent urban sprawl to stop districts merging. Although in Capel is in the Tunbridge Wells district it is right on the border with Tonbridge and if lost to housing would represent the merger of the two areas into the surrounding countryside which for 80 years has been protected. Why end that protection now of a green lung at a time of growing environmental awareness and concerns over climate change? Surely this is a time when we should be enhancing the protection of our countryside. The Government and councils across the country have declared a climate emergency, building thousands of homes in this green field site would be counter to that.
The surrounding roads are already heavily congested, the A21 junctions gridlocked in the morning especially at Pembury, building this number of homes will only add to that. The trains at Tonbridge are also overcrowded and would struggle to cope with more passengers and the local health service overwhelmed with the hospital at Pembury at full capacity. This proposal would be to the detriment of the local community.

Although I live in the Sevenoaks area I work in Tunbridge Wells and commute here everyday and so have a keen interest in the area.

10 years ago before moving to Kent I came for a weeks holiday and stayed in a cottage near Tudeley and enjoyed the peaceful surroundings of the area, what a horrendous shame if this was lost for future generations.

DLP_5626

S A Exall

GENERAL COMMENTS with specific reference to Capel Site (CA1)

I have lived in Tudeley for the past 30 years and have run a holiday letting business in Tudeley for the same length of time. Our holiday guests come from all over the world drawn here by our beautiful, open countryside with its rich biodiversity. Guests come back year after year. The impact of this new proposed Tudeley town development will obviously have a seriously negative impact on our business.

I have a dog and walk daily in the surrounding countryside.

I have brought up my children in Tudeley and have done school runs during term time down into Tonbridge and more recently have also worked in Forest Row having to commute by car from Hartlake Road, through Tonbridge, across to Speldhurst and on to Forest Row.

GREEN BELT

We live in a green belt area of outstanding beauty. This was one of the main reasons for choosing to live in Tudeley. We wanted to bring our children up in an area of unspoilt natural beauty with easy access to the countryside and country living. We all love living in Tudeley but are extremely anxious about what the future holds for Tudeley and Capel with the proposed plans hanging over us all. It seems rather late in the day for TWBC to be reviewing their Brownfield register this December. Should this not have been done prior to these plans being hatched to build on our green belt?

Another real concern is the siting of the road network which is to service this new town development. TWBC have not made public the planned road system. This will undoubtedly mean the loss of more green belt over and above the planned site, more damage to the environment, further biodiversity damage, increase in traffic, omissions and flood risk.

BIODIVERSITY

Biodiversity is the most precious gift of nature mankind is blessed with. All ecosystem are interlinked and interdependent, the value of biodiversity in the life of all the organisms including humans is enormous.

The development of such a settlement in this area will have a negative impact on a number of habitats and species which, due to the value of the area in terms of biodiversity, could not be sufficiently offset through enhancement and mitigation within the local area. Attempts of offset any negative impacts outside of the Tudeley area should not be seen as sufficient due to the high value of the habitat mosaic in its current location, in part due to the open nature of this landscape.

Not only is this green belt land but this area is of especially high value to biodiversity in the context of the local area, with European Protected Species, reptiles and declining bird species present across the proposed development footprint. I do not consider it to be possible to offer a true net gain for biodiversity within the local community due to the types of habitat present within the development footprint, such as open farmland and ancient broadleaved woodland. These habitats would either be impacted through direct loss or impacted indirectly due to the development reducing habitat functionality e.g. through reducing connectivity and increasing disturbance. Proposals to enhance existing woodland habitats away from the proposed development will not be sufficient to counter loss of ancient broadleaved woodland or impact on open farmland habitats for which the development area is of such high value, particularly to declining farmland bird species. It is this habitat which would be impacted on not only by this development but by other development across the wider area, including planned quarrying activities. Having gravel extractions pits, solar farm placements, the loss of 400+ acres of green belt land and an extensive network of new roads is a biodiversity disaster and I do not believe that the cumulative effects have been considered at all by TWBC.

ENVIRONMENT

Pollution

Air quality, noise and light pollution will further disrupt ecosystems, have adverse health effects and waste energy.

Climate Emergency

We are all faced with a massive climate emergency and are all working hard to reduce our carbon footprint, recycling, reducing waste, reducing unnecessary journeys, etc, etc. How can this proposed development with 2,800 more properties in the middle of Tudeley with limited public transport, the nearest railway station being a drive away, be anything but contrary to all Government objectives with regards to climate change and reducing omissions? Network Rail have confirmed that a station in Tudeley is not viable.

Periodically we have guests in our holiday apartments in Tudeley who are either in between houses or having work done on their own properties and need temporary accommodation for a few weeks. Many work in London but they do not get on their bikes and cycle to the railway station, they do not catch a bus, they do not walk. They jump into their cars for the 5 minute car journey into Tonbridge, fact.

The proposed dwellings would inevitably be bought by wealthy commuters who will drive to and from the train stations in Tonbridge and Paddock Wood putting more cars onto our already congested roads and increasing omissions. This would lead to an increase in house prices with young residents no longer being able to live in the area they grew up in.

Community

Let alone my own feelings, I am extremely upset and sad to hear my fellow Capel community members express their shock, horror and devastation at the announcement of these so ill thought out plans. Local families who generation upon generation have lived in Capel having to live with the possibility of it being torn apart and sold off. How can a community comprising of only 950 dwellings suddenly deal with the possibility of 2,800 extra properties? The community will be lost, swamped. It will destroy the local community and ruin local residents’ lives. It seems so unfair and unjust that Capel is landed with over 60% of Tunbridge Wells Borough Council’s housing needs. I understand that there is a need for more housing but this should be met in a fair way and spread across the Borough.

Another national issue at the moment is mental health and well being. We are being encouraged to get out into the countryside, into open spaces and walk, take time out of our hectic schedules. How can concreting over such a large area help, it will do exactly the opposite.

The NHS is under huge strain. With thousands more homes in Capel and Paddock Wood how are the doctors, dentists, hospitals and other health services going to cope? My Surgery in Paddock Wood is currently struggling to recruit new doctors so how will new posts be filled in any new medical practice? There might be a lovely new surgery but how will you get the doctors to fill it?

Agriculture

We are encouraged to buy local, eat local and keep our carbon footprint low. Destroying 400+ acres of Grade 2 (very good) and Grade 3 (good to moderate) agricultural land can only mean a loss of food production and supply. New research from Cambridge University advises that ‘Britain is running out of land for food’. We cannot afford to build on agricultural land. We need more land put aside for the food needs of a growing population. Once the land is gone it is gone for ever.

Flooding

Having lived in Tudeley for over 30 years I have seen first-hand the flooding from the River Medway

Large parts of the current proposed development are on the Medway floodplain. With flood risk assessments based on old data I am extremely concerned that insufficient consideration has been given to the impact of climate change and the increasing risk. Covering farmed fields with houses and roads will cause significant run-off and will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding.

Landscape

CA1 is next to an area of outstanding natural beauty. The building of this new town will have a massive visual impact and ruin the landscape. Your view will be drawn to the new town and the beautiful landscape will be scarred and lost.

Heritage

The twelve stained glass windows in All Saints Church Tudeley decorated by the Russian Artist Marc Chagall are stunningly beautiful but the quality of the light is very important. I believe that the proposed development would result in the Church being surrounded by buildings and roads, reducing the quality of the light and thereby causing great harm to its value as a heritage asset.

Water & Sewage

We suffer with a lack of water pressure to our property and our supply is below water board standard but because we are on a private Hadlow Estate supply we have to supplement our water supply pressure with pumps. The current water company obviously cannot cope with delivering an adequate supply to us so how will it deal with an additional 2,800 properties in Tudeley?

Location

During the time I have lived in Tudeley I have had to take my children to School in Tonbridge. During ‘school rush hour’ the traffic at the end of Hartlake Road to turn right on to the B2017 and head towards Tonbridge is extremely heavy. Traffic backs up over the bridge on Hartlake Road, tailing back not too far from the Poacher. Once on to the B2017 the traffic is slow moving right up to and past Somerhill School. At the roundabout turning left towards the A21, to the next roundabout and turning right on to the B2014 to go passed the Weald of Kent, TOGS and down into Tonbridge traffic is often bumper to bumper. It doesn’t take a lot to gridlock the area. More traffic will make for one big traffic jam.

More recently I have worked in Forest Row so have had to travel into Tonbridge and then out onto Brook Street towards Speldhurst. Again this journey has to pass not only Somerhill School but the Weald of Kent Grammar School, TOGS, Judd, West Kent College and Hayesbrook, not forgetting all the Primary Schools. The traffic is solid. I cannot imagine what the same journey will be like with an extra 2,800 homes (with 2 cars per household 5,600 + cars). In addition to the proposed new senior school development opposite Somerhill School.

In the summer months Hartlake Road itself becomes extremely congested with cars parked on the verges with people going to the Poacher. At times cars can be parked on both sides of Hartlake Road making driving difficult but manageable. Extra cars on Hartlake Road could make this a very dangerous road.

The inappropriate site at CA1, to which I strongly object, should be dropped in its entirety from the Local Plan.

DLP_5627

Nicola McGilloway

We live in North Tonbridge. Our three children attend primary school locally and my husband commutes to London each day. We greatly enjoy living in this part of Kent and appreciate and explore the countryside close to us. We wish to protect the area in which we live and are therefore writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

Building 2,800 homes at Tudeley will have a detrimental impact on residents of Capel and Tonbridge. Congested roads are already a problem and would no doubt intensify to a horrendous level if the proposed garden settlement were to go ahead.

Local services including GP surgeries, Tunbridge Wells hospital (especially the maternity unit and A&E department) would be under immense pressure and ultimately unmanageable.

Creating a garden settlement at Tudeley would also attract countless commuters to Tonbridge station for its services to London. As a regular commuter, my husband is all too aware of how overloaded this service already is. There can be no doubt that there would be insufficient seating on trains and insufficient parking at the station.

“The Strategy for Capel Parish” seeks to develop green belt land which would cause the loss of extensive wildlife habitats and ecosystems. We need to protect our environment for future generations and deeply consider our impact on the planet.

In an area of Kent which is plagued by flooding, developing flood plains and countryside which provides considerable drainage opportunities will put the county at an even higher risk of devastating floods. We must take global warming seriously and safeguard against the increased risks of flooding as best we can by withdrawing plans to develop this settlement.

Thank you for taking our thoughts into account.

DLP_5639

Heather Wills

I wish to object very strongly about the prospect of Tunbridge Wells dumping 2000 houses on the doorstep of Tonbridge on green belt land.The area is a rural farming community,always has been and should stay that way,not a quick buck for the landowner and developers

DLP_5640

Pam and Kim Tattam

It has recently been brought to our attention the full extent and implications of the development in neighbouring Paddock Wood and Tudeley.

Although outside the development area it will have an impact on residents of villages such as ours at East Peckham.

As a pair of 83 year old pensioners our prime concern will be the provision of adequate and promptly available Medical Services.

For many years we were provided with an excellent service within the village. This was removed with the flimsiest of excuses to Paddock Wood.

Although all the staff are doing their best they are already feeling the strain of increasing numbers.

The parking facilities are already inadequate and the proposal will add several thousand families to the register.

Public transport is patchy and the walk from stops to health-centre is beyond the capability of many elderly patients.

May we ask if TWBC and TMBC are considering the feasability of replacing services in villages such as ours to alleviate future problems.

DLP_5644

Charles and Catherine Parmley

The current state of the traffic in Tonbridge is at breaking point with near gridlock now becoming more frequent. Living at the Northern end of the town we experience this to travel home. The influx of traffic has increased markedly from the Maidstone direction over recent years. The traffic into Tonbridge in the mornings backs up to Three Elm Lane and drivers use ( I have complained) use Old Hadlow Road as a rat run.The prime instigators for the increased traffic are obviously the schools and the station which stretch the inadequate roads and parking.

The thought of the 2800 homes at Tudeley and the some 1500 at East Capel with no associated change and upgrading of many facilities will create a Tonbridge to be avoided by all current residents as the overburdened facilities try to cope. These facilities are the primary schools, doctors, dentists and, as I have recent experience, the much over used and pressured Pembury Hospital.

If the planning is as poor as the single entrance to the housing estate off the roundabout at Five Oak Green Road with no public transport chaos is inevitable. The Tudeley Road/ Crockhurst Street are not up the increased traffic handling and although designated a ‘B’ road are little more than a country lane. Hartlake Road is now much used as a by-pass to Tonbridge but again narrow. Would the estate have an entrance here also?

I can appreciate that local businesses such as the increased number of supermarkets and pubs/ restaurants will be glad of the increased trade ( if only anyone can get to them or park). The increase of Amazon deliveries and grocery vans visiting these properties will again add to the traffic flow.

Perhaps TWBC should look at expansion at say Pembury Walks where at least there are better Roads!

These are my current views and I will keep a watch on the progress of this proposition.

DLP_5645

Michael Vos

Housing Policy STR 1

The volume of proposed new housing is excessive. It should not exceed the minimum required. In any event the numbers specified by Central Government should be challenged in the interests of Tunbridge Wells Borough so as to retain it’s unique character including in particular the rural nature of it’s environs.

DLP_5648

Charles and Fiona Rosenmeyer

We have read the draft plan, particularly as to its possible effect on Tonbridge, where we live. We have also read the submission to your council by Tom Tugendhat MP. We wish to support his comments and those of Tonbridge and Malling District Council about the proposals in the plan in so far as they affect Tonbridge. We also wish to make the following additional comments about the proposals for Tudeley/Capel, Paddock Wood, Woodgate Way and Mabledon, all of which are on Tonbridge’s doorstep.

Generally

There is a considerable lack of information in the draft or in reports appended to it showing the likely effect on Tonbridge of the proposals, why Tonbridge should be expected to accept that effect and who, other than the council tax payers of Tonbridge, will pay for the costs of ameliorating it.

Green belt

Whilst the draft mentions the green belt, in relation to Mabledon and Tudeley/Capel it must be remembered that what is proposed is not building in the green belt protecting Tunbridge Wells but in the green belt protecting Tonbridge. So the case needs to be made for invading that green space which will have little effect on Tunbridge Wells (other to help it hit its targets) but will have a major effect on Tonbridge, which is not even asking for the development.

Roads and road transport

Tonbridge has only one major rail crossing and one major river crossing in the town. That leads to regular congestion, particularly at the start and end of the working day and in the afternoons when the schools break up. Any new development in the neighbourhood of Tonbridge will have an effect on bus services, parking and the emission of CO2 and other harmful substances. It is not sufficient to state, as does the draft, that these issues should be considered as part of a detailed planning application; Tonbridge, which has not asked for these proposals but will be affected far more by them than Tunbridge Wells, should have access to data and reports now while the plan is still a draft and not later when it will be claimed as a fait accompli.
In the same way, Tonbridge should be told now what alterations to local roads are proposed. The roads around Tudeley are local, narrow, winding, prone to flooding, dangerous in places and already overused. The principal road from Paddock Wood to Tunbridge Wells already needs considerable improvement, not least a by-pass to Colts Hill; no such improvements are proposed by the relevant highway authority. If Paddock Wood is doubled in size as is proposed, major improvements will also be required to the principal route between the town and Tonbridge.
New housing will generate additional private car journeys and delivery journeys. It would be facile to suggest that most food shoppers from any development at Tudeley/Capel would carry out their major food shop anywhere other than Tonbridge. It is also facile to suggest as the draft implies that commuters from Tudeley/Capel would drive to Paddock Wood to board a train for London. To do so would increase their overall travel times and increase the cost of their train tickets.
A new school at Woodgate Way would also increase car traffic not least as there is no obvious way other than the private car by which teachers and pupils can reach the site. There is no principal bus route, no cycle lane and it is too far to walk (and dangerous to do so) either from Tudeley or Tonbridge.
As people shop increasingly on-line, there should be a study on the additional road miles in the vicinity of Tonbridge, which will be generated by these proposals. For instance, it is likely that many food deliveries ordered on-line will be delivered from Tonbridge. Also Royal Mail post for the area, initially delivered to Strood, is driven by articulated lorries into Tonbridge via the A26 for local sorting in the Royal Mail facility in Tonbridge. Deliveries from there to Paddock Wood and Tudeley and collections in reverse are bound to add materially to the use of the surrounding roads.

Train travel

The plan does not say whether the rail transport authorities would support or fund a new station at Tudeley. The line between Tonbridge and Paddock Wood is already congested at peak times. Those commuting from Tonbridge should be informed now what effect the draft proposals would be likely to have on frequency of services, availability of seats, choice of destinations and what rail improvements are required, who will fund them and when they will be carried out.

Flood defences

A material part of the proposed Tudeley/Capel development area lies on the Medway flood plain at a height above sea level of only 50 feet or less. Even though the remainder of the site rises gently above that level, much of it has flooded in the past and the proposals for further defences at Leigh have yet to be carried out. Even if they are, an assessment should be made now of the likelihood/risk of future flooding on the site given climate change, the slow sinking of the landmass and the rising of sea levels.

Schools and healthcare

The draft makes a proposal for a new secondary school but says little about the need for additional infant and junior schools and additional doctor’s surgeries and supporting medical services the need for which will be generated by the additional housing proposed. As the likely effect will be disproportionally laid at Tonbridge’s door, there should be studies now in support of the draft realistically to measure that effect rather than later when a new local plan has been adopted.

Services

It is not good enough to say, as does the draft, that these are issues to be considered in the future when the plan has been adopted. As the supply of services may affect Tonbridge, Tonbridge residents should be told now what that effect will be. For instance;

Gas; will the supply come from Tonbridge, what route will it take, and what impact will it have on local supplies?

Sewage; where will the sewage be treated, by what route will the sewer pipes take it there, will it be pumped, will it have to cross the railway and the Medway and what effect will it have on the already stretched treatment plant in Tonbridge?

Electricity; what additional generating capacity will be required, where will it be sourced, what renewable capacity will be generated on site and what if any additional high tension supplies will need to be brought in?

Internet and mobile ‘phones; what if any disruption to internet availability in Tonbridge will be needed to supply services to the proposed new development? Mobile coverage is already patchy in the area. What binding proposals will there be to ensure adequate coverage?

The draft should deal with all these issues before it goes for consideration by the planning inspector or the minister so that the residents and taxpayers of Tonbridge may have a full understanding of the proposals, which are likely to affect them far more than the inhabitants of Tunbridge Wells.

As Tonbridge residents we feel that the draft reveals that the Tunbridge Wells Council, concerned about development in its own back yard, has cynically decided to place that development in Tonbridge’s back yard, with Tonbridge being expected to pick up many of the ancillary costs, financial, social and environmental.

DLP_5650

Emma Scott

As a resident of East Peckham I am vehemently opposed to the proposed development of Tudeley, Capel and Paddock Wood.

The sheer number of properties contained within the plans will result in a devastating impact on the existing community and infrastructure.

Although the build is to take place within the Tunbridge Wells Borough Council area, the effects on surrounding areas, infrastructure and local services will be far-reaching and detrimental in every way imaginable.

Just from my own personal perspective, I can foresee tremendous difficulty for myself and my family should the build go ahead.

Our family has chosen to live in East Peckham due to the rural location, local facilities, lack of overcrowding, surrounding countryside and our enjoyment of village life.

In recent years we have already seen a reduction in our quality of life due to increased numbers of people moving into the area. We recently lost our GP surgery in the village and now have to travel to Paddock Wood to see a doctor. I am recovering from cancer and have a few ongoing health issues. It is incredibly difficult to get an appointment due to sheer numbers of service users and it is not always convenient to travel to another village whilst ill. It is utterly unacceptable to me that the elderly, disabled, mothers of young children etc should have no access to a doctor in the place where they live.

Bringing yet more people into the area will compound this problem immensely.

Traffic on the roads in this area is already heavy. I work at Tunbridge Wells hospital and have recently had to change my working hours to ensure that I can avoid the worst of it and arrive at work on time. I currently leave my home at 6.30am, by which time the traffic is already considerable.

The vast rise in local population would also have a ‘ripple’ effect in many other ways; school places, travel to school, amount of people using shops and leisure facilities and parking.

As well as the housing to be built, new roads and associated infrastructure will destroy the countryside that we currently enjoy. It cannot be known what the effect on wildlife may be, not to mention levels of pollution and other environmental concerns such as flooding.

The strain placed upon the hospital and other local services by thousands of additional households will undoubtedly be the worst effect of all. Hospital staff are struggling to cope as it is. I personally have had an operation cancelled 4 times due to a lack of capacity. This will clearly only get worse in future, even if no development were to take place.

It seems so unfair that Tunbridge Wells Borough Council can plan what amounts to a mass invasion of the local area. Life as we residents know it will be gone for ever. I personally will seriously have to consider moving away if this goes ahead as the life and home I have created for myself and my family will be ruined.

DLP_5654

Richard Ingham

I am a resident of Tunbridge Wells and live just outside the area affected by the above proposals detailed in the draft local plan. I list below my objections to these proposals.

I have commuted to central London from Tonbridge rail station for the last 35 years. At present the journey time along the B2017 Five Oak Green road during school term time takes approximately 30 minutes with traffic being stationary from the Hartlake Road junction to the roundabout leading on to Woodgate Way. The distance is approximately 2.5 miles which without traffic should take approximately 10 minutes driving time, With an additional 2800 homes being built at Tudeley together with the 2500 homes to be built around Paddock Wood and a senior school, travel to my place of work and for many other commuters will be completely impractical. There will be chaos on these already congested roads with trains packed to capacity for which there have been no planned upgrades.

Climate change is upon us and building on green belt land and flood plains flies in the face of common sense. There will be an enormous increase in air, light and noise pollution and a significant loss of wildlife and fauna of which we presently enjoy a rich diversity. ,

We have one of the most beautiful small churches in Kent which will be in the middle of this proposed development with the world famous Marc Chagall stained glass windows. Its setting could not be more perfect. This will all be lost forever if these proposals are allowed to proceed.

The fact that this proposal can be facilitated by dealing with just one land owner should not override sensible planning considerations. i believe that Tunbridge Wells may have been unduly influenced by this and this has clouded their judgement.

I would be grateful if the above could be taken in to account in reaching a conclusion on this very troubling matter.

DLP_5655

Gerald Thompson

As a resident of Tudeley I wish to support the objections and comments made in previous submissions.

However I wish to add the following :-

a) the demolition of existing homes
b) removal of farms and loss of livelihood.
c) difficulty obtaining insurance for properties in the area TN11

DLP_5656

Christine and Francis Pullen

We strongly oppose this development as it is eating away at our greenbelt, rural countryside and our wild life habitat. Our woodland is disappearing at an alarming rate. Our greenfield sites need more trees and bluebell woods to enhance the possibility of saving our planet and the quality of lives of future generations.

How can we preach to the Brazilians about them destroying their rain forests when we are concreting over the lungs of our own land.

Regarding the need for new homes there are plenty of brown-field sites (i.e. the corner of Canon Lane and Vale Rise, near the Royal Mail site. Also empty flats above shops and shops themselves. Councils need to ease the planning permission needed for change of use from commercial to residential. 'Toys are Us', one for example, would make a convenient site for a Care Homes.

More than 7,000 homes have been empty for at least six months across Kent, amid a national shortage.

Therefore 2000 new homes are not needed here!

DLP_5657

Angie Liddell

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

I live my with husband and two boys on Hadlow Road, in North Tonbridge. We have been here for almost 10 years and love Tonbridge community and the beautiful surrounding villages.

However, the 10 years that we have been here, we have seen traffic increase dramatically. With the development of the Cannon Lane Industrial and Retail parks (M&S, Home Bargain, Aldi, B&M etc) there has been a huge increase in the traffic, congestion and pollution and noise in Tonbridge.

It already feels like we are at breaking point when often, mid day, mid week I am having to queue on the A26 from the roundabout by the Porsche garage to get to Hadlow Road! As I live on Hadlow Road, I have noticed the traffic now queues along the road (it did not do this 10 years ago) and also continues way into the night (thanks to the 24hour McDonalds).

Creating a garden settlement at Tudeley of 2,800 dwellings will cause immense harm to residents of the Parish of Capel and to residents of Tonbridge. There will be another significant increase in traffic in to Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road and the A26 every morning. There are already unacceptable levels of traffic at many times of the day.

People living in Tudeley will use Tonbridge Station for commuting and Tonbridge town services that will need more parking. The increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times (and off peak sometimes)and can’t be made wider in most places. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable. Parking in and around Tonbridge Station will be even more difficult. Network Rail have confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. Most people living in the new garden settlements will drive privately owned cars, despite initiatives to encourage bus and bicycle use. The costs of infrastructure on the Tonbridge & Malling side of the boundary will have to be carried by Tonbridge & Malling residents whilst Tunbridge Wells will receive council tax from the residents in the new dwellings. The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area. There will be an increase in pressure on Tonbridge health services, amenities and car parking as residents from the new garden settlement at Tudeley will use Tonbridge as their local town, not Tunbridge Wells, because Tonbridge is much closer.

There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling - surely we should be looking at ways to save the environment in the current climate, not keep abusing it with additional housing, traffic, people and pollution!

DLP_5659

Roslyn Olson

I am most concerned about the proposed development of over 2,000 homes in Tudeley.

I believe the social infra structure in the Tonbridge area is already under strain from all the new developments in Tonbridge and adding an extra load to the already over burdened surgeries, schools and traffic would be untenable.

DLP_5660

Dennis King

Councillor, Higham Ward, TMBC

Christine,

I am 100% with you with regard to the need to protect our green belt from inappropriate harm and do not believe that the TW Plan is supportable. However, it is my understanding that the Planning Inspectors will be most persuaded by objections which focus on the planning principles and planning reasons why the development is in breach. I.e. that it breaches the National Planning Policy Framework (NPPF) in significant degrees. The NPPF states that the green belt exists to prevent urban sprawl and maintain openness. It also states that exceptional and very special circumstances should exist before it is undermined in any way. There are also the issues of the high grade agricultural classification of the land and the probability of flooding. Another key issue for us is the unsustainable volumes of people and traffic that will be imposed on the roads, the transport links and the amenities in Tonbridge. There is more information on the save Capel web site.

With reference to the 2 brown field sites you mentioned, 1 is in Tonbridge and earmarked for industrial development and the Toys R Us site is similar and would not provide the numbers of houses required.

Regards,
Dennis King
Councillor, Higham Ward.

[TWBC: Comment number DLP_5656 from Christine and Francis Pullen copied below as reference]:

How can we preach to the Brazilians about them destroying their rain forests when we are concreting over the lungs of our own land.

More than 7,000 homes have been empty for at least six months across Kent, amid a national shortage.

Therefore 2000 new homes are not needed here!

DLP_5664

Steve Henderson

I am writing to voice my concerns over the proposal to build 2000 homes around tudeley.

The impact to the environment and local services will be untold and in addition will put extra pressure on already overcrowded train services into London I’m sure local residents will not welcome the proposals and at a time when we are all concerned with the impact on environment neither am I Please register my discontent

DLP_5666

William Forsythe

I work in London and live in Golden green, nearby to this proposed development.

Whilst the government has set targets for homebuilding I feel that this development represents the worst type of unintended consequence. A mad rush to hit building targets regardless of the impact to the local area. There seems to be many factors here which in days gone by would have made this a total non-starter for planners. I truly hope you can scale back these efforts before it is too late and find a way to provide quality housing for current residents rather than entice a London based commuting population into the area and causing great damage to the people your represent and are supposed to protect.

Instead of building the vast majority of your new builds on your furthest border in one huge development, It would be better to consider a more tactical and spread out approach where you would cause minimal harm. Whilst that may entail more work, I feel it is your responsibility as planning departments to exhaust every other option before causing significant damage to the local landscape and Tonbridge local area. Or better still apply to have targets reduced - have you tried this? This plan is not well thought out and must be stopped.

The damage I can see is not limited to the following

1) Tonbridge station will clearly be the main route for commuters to and from London, as an aside I would drive through this development as I live further from the station, so I can say this with certainty – link trains etc would never be used, that is fallacy. It introduces significant extra stain on the car park and the trains. Tonbridge trains take the whole platform during peak hours and are generally full with many standing – this must be addressed BEFORE residents move in. Is this possible?

2) The river Medway runs very nearby to this development, and the area is greenbelt with easy access for walkers, kayakers etc from Tonbridge. It’s clear to be the local aesthetic will be destroyed in this development process. Building will inevitably 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, including rare species. This area should remain rural with agricultural land that can be used to provide food(with some of the most productive farm land in England here). Have you also taken into account the fact there is a pending quarry development with dust, noise and waste also in this local area. Why have the planners decided to put so much on the shoulders of Capel, and its residents, you are ruining lives in this process, and destroying greenspace and enjoyment for Tonbridge citizens in what seems a lazy mass development with the only excuse of “Government building targets” without creating a long set of alternative sites.

3) It must be mentioned you are placing this development in an area of relative low incomes in the area (Sevenoaks and Tunbridge being wealthy), yet the development will end up only servicing wealthy commuters to London, which clearly will be the target buyers for the developer. This will NOT help those affected or local residents, only cause harm. Will you take the impact on your residents into consideration?

I also read the below from an online source :

“Earlier in the plan (in 4.40) you refer to Tudeley Village securing a long term option for the borough to deliver the needs of future generations. It is clear from this statement that you intend to add more and more housing to this “garden settlement” in each five year review of future Local Plans. I think that TWBC want to fill Tudeley and East Capel with housing until they coalesce with Tonbridge to the West and Paddock Wood to the East, ultimately creating a massive conurbation that will dwarf Tunbridge Wells town centre. TWBC is using Capel to dump their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the borough on brownfield sites or placing the garden settlement in the middle of the borough, to make it accessible north and south. The developments in Tudeley and East Capel are unsustainable and place huge pressure on Tonbridge”

Please comment

4) This area is extremely prone to flooding, with a powerful and dangerous river in the area. Who will take responsibility for the quality of flood works, for the flood protection and ongoing costs, and for the impact of flood water driven away from the proposed residence ( Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green). Will there be accountability for their failure which comes back to an individual? I would demand this be the case. If there is a flood event similar to that in north England, with loss of life, someone with personal liability (not a company or Govt department) must be held responsible? This would prevent conflict of interest that I worry is at play – away from a focus on delivering targets regardless the cost – this is vital as mistakes may cost lives and destroy livelihood’s. Please let me know whom this person or persons is.

5) With above in mind I believe that housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan

DLP_5672

Andrea Ray

The additional planning strategy STR/CA1 I would also raise objection too. This Capel development will abut the Paddock Wood parish bourough line merging Paddock Wood with Capel, Tudeley, Five Oak Green and out to Tonbridge. Much of the 4k+ proposed homes for this development will be built on Green belt land. Its only upon exceptional reasons that Green Belt land can be built on. Sevenoaks has already had its local plan rejected by government due to this. Yet TWBC are proposing 75% of the Capel development plan new homes be built on Green Belt, this is wrong. I ask what is happening to the Blantyre House 54 acre sight owned by TWBC in Goudhurst why can a large number of the boroughs new homes be absorbed there?

The areas hospitals and GP surgeries are full to capacity with wait times rapidly increasing. Committing to the volume of new homes in the area will only add to existing frustrations.

DLP_5673

Jose Hyatt-Twynam

Latters Farm Cottages Tudeley has been my home for 34 years.

My husband and I chose to live here because of its rural location, wide-open vistas and for easy access to our work, in Tunbridge Wells, Tonbridge and Matfield. Having both been brought up on housing estates within the TWB we were keen to live in the countryside. We have brought up a family, and worked hard on our house and created a wildlife friendly garden that we are proud of. We try to maintain a healthy lifestyle with daily dog walks on public footpaths most of which are in the proposed ‘Tudeley Garden Village’ development area. Sherenden Road was a great asset to us when our son was growing up as a quiet lane to push a pram, for a child learning to ride a bike, family walks etc.

With a qualification in agriculture and having worked on several farms locally I have a good understanding and love of the land. A general interest in local history means I have an appreciation of the heritage of Tudeley with its connection to Somerhill. We particularly enjoy taking friends to the All Saints church to admire the Chagall windows and its beautiful setting. I have admired Hadlow Estate’s farming policies and their efforts to encourage wildlife, but naively because Hadlow Estate (until now) has been reluctant to sell land, I have always assumed that this area of Green Belt would be safe from development. As a consequence it was a huge shock and a feeling of utter disbelief when we heard that Hadlow Estate had offered 400 acres of prime agricultural land for a ‘Garden Village’ and school.

I am writing to object to ‘The Strategy for Capel Parish’ (Policy STR/CA1)

Primarily I strongly object to sacrificing green belt land for a ‘Garden Village’. The Green Belt in this area is of the utmost importance to limit the urban sprawl of Tonbridge. It prevents Tonbridge, Tunbridge Wells and Paddock Wood merging into one another, as well as helping to preserve the identity and special character of the historic towns of Tonbridge and Tunbridge Wells. The Green Belt encourages recycling of brown field sites. The benefit of providing access for the population to open countryside via the network of public footpaths must not be undervalued.

It is difficult to understand why the TWBC Planning Department hasn’t followed the advice of the NPPF (March 2012) when considering the draft Local Plan. Guidelines state that ‘there should be no inappropriate development on Green Belt unless very special circumstances can be demonstrated to show that the benefits of the development will out weigh the harm caused to the Green Belt’. What are these ‘special circumstances’ that you base the plan on? As TWBC has such a large proportion of AONB, Green Belt, Ancient Woodland and floodplain why don’t you apply the government’s exception to the requirement policy to provide the Full Objectively Assessed Need (OAN) for housing?

In July 2018 The Poacher & Partridge Pub applied for Planning Permission to build 6 B& B units. This was refused for several reasons; the first being ‘the proposal would constitute inappropriate development within the Metropolitan Green Belt, which by definition is harmful to its openness. There is insufficient evidence of the necessary ‘very special circumstances’ to overcome this harm. The proposal is thus contrary to Policy MGB1 of the Tunbridge Wells Borough Local Plan 2006, Core Policy 2 of the TWB Core Strategy 2010 and the NPPF 2018.

The application was considered to be fundamentally contrary to the provisions of the Development Plan and the NPPF and there were not considered to be any solutions to resolve this conflict and signed by Stephen Baughen, Head of Planning.

Less than a year later Stephen Baughen revealed the proposed plan to build a town of approximately 2,800 homes, the perimeter of which will be about 150 metres from the Poacher & Partridge Pub. The landscape is the same. How can this extensive development be justified when the reasons for refusal for The Poacher & Partridge Pub application would also apply to the ‘Garden Village’?

According to the NPPF another purpose of the Green Belt is to ‘retain attractive landscapes’. The view, when driving south along the Hartlake Road from the Medway, across the valley towards the AONB is stunning. A town will be an irreversible scar on this unique and special landscape. It will also have a detrimental affect on the setting and character of the neighbouring AONB. The openness in this area of Kent is unusual and well worth preserving. Looking north from Crockhurst Street towards the Greensand Ridge the view is also very special with the landmark Hadlow Tower and St Michael’s church, East Peckham, in the distance. It seems criminal to destroy something that can lift the spirits of everyone. The ‘brownfield first’ policy of 1998 should be re-introduced to protect our countryside, to stop councils & developers taking the easy, cheap option of building on greenfield sites.

Removing 400 acres of very productive agricultural land from the food chain is very short sighted. The land is predominantly Grade 3 with Grade 2 north of the railway line. It is considered as some of the best and most versatile agricultural land (BMV) and has the potential to give consistently high yields of crops. At the present time it produces wheat, barley, oil seed rape, field beans, bramley apples, pears and some of the highest yields of blackcurrants in the country. There are also 37 acres of pasture used by a livery yard. Average yields will give some 6,175 tonnes of produce over a 5-year period and of course the land has the ability to do so ad infinitum if it isn’t covered in concrete!

Local Planning Authorities are required to consult Natural England for guidelines on assessing development proposals on agricultural land in order to protect the BMV agricultural land & soils in England from significant, inappropriate and unsustainable development proposals. It is difficult to find any reference to this in the Draft Local Plan. In a bid to push the plans forward TWBC seem to be determined to play down the quality of the land. Both the Environment Officer and Head of planning have referred to it as ‘poor quality’ whereas in reality the land is some of the highest-grade land in the country.

I also strongly object to the proposal because of the loss of flora & fauna habitat. It is ambitious & admirable to aim for a net 10% gain of biodiversity on the Tudeley site, but perhaps unrealistic, however if your starting point is the Kent & Medway Biological Records (KMBR) maybe it won’t be so difficult to achieve. Although you claim in the ‘Biodiversity Evidence Base of the draft Local Plan’ that the KMBR to be ‘reliable, comprehensive, up-to-date information, I would question this. They appear to be scant, out of date and not a true reflection of the species present. During my daily walks across Sherenden Farm I see numerous farmland birds including Skylarks, Swallows, Linnets, Lapwings, Barn Owls, Common Buzzards (not mentioned in the records), the last sighting of a Green Woodpecker in the record was 1999. I see them regularly. Not so up-to-date! Through the destruction of their habitat you will be speeding up the demise of some of these species many of which are ‘red-list’ Birds of Conservation Concern.

The same will apply to other wildlife species - Great crested newts, dormice, bats, badgers, fox, hare, snakes, slow worms, all of which have been seen in this area.

Little regard is given to the ‘cumulative effect’ of development. The CA1, CA2, PW1, proposed Stonecastle Quarrying Site, link roads and Colts Hill Bypass sites combined are likely to exceed the capacity of biodiversity to recover. The ‘fragments’ of habitat left will be more vulnerable to noise & light disturbance, water & air pollution, and pet predation. The ‘cumulative effect’ is not truly captured by an Environmental Impact Assessment.

The habitats are varied in this area of countryside – orchards, arable, woodland (some ancient), hedgerows, ponds, streams, and ditches. If the ‘offsetting scheme’ is undertaken, the biodiversity units will be difficult to calculate. How can you put a monetary value on habitat, particularly with farmland? It is very convenient to create funds through offsetting to support existing council run woodland schemes, but it doesn’t replace ‘like’ for ‘like’ habitat.

Living on the edge of the Medway flood plain and bordering the Tudeley Garden Village I am justifiably concerned about the increase flood risk, not only to our home and those nearby, but also the wider area, the villages of East Peckham and Yalding, plus the Hartlake Road and Sherenden Road. Climate change and unpredictability of today’s weather patterns make it difficult to know the extent of the flood mitigation required. It only needs a winter like 2013 when the Leigh Flood Barrier was at capacity and excess water flooded Tonbridge, the Hartlake Road and further down stream, plus additional run off from the vast area of impermeable tarmac/concrete from the Garden Village to cause extensive damage.

To quote Stephen Baughen , Head of Planning in his refusal of the 6 B& B units at The Poacher Pub July 2018 “it has not been demonstrated that the occupiers of the development would not be at risk from flooding or that the development would not increase flood risk elsewhere. Therefore the development is likely to result in a risk to human life from flooding and is contrary to policies EN18 of the Tunbridge Wells Borough Local Plan 2006 and Core Policy 5 of the TWB Core Strategy 2010, guidance in the National Planning Policy Framework 2018 and the Planning Practice Guidance.”

The application was considered to be fundamentally contrary to the provisions of the Development Plan and the NPPF and there were not considered to be any solutions to resolve this conflict.

I object to the proposed development at STR/CA1 for these same reasons.

In the Sustainability Appraisal table 25 the ‘water objective’ for STR/CA1 has a mixed/positive score to reflect the ‘betterment in flooding’ (questionable), but doesn’t truly reflect the insurmountable problem of lack of capacity to provide water and sewerage services in the region. Development has ceased in areas of Paddock Wood because of such problems. The Rt Hon Greg Clarke MP has pledged action on Southern Water to rectify the problems. It should be a fundamental necessity that this infrastructure is in place before any development is considered for the Local Plan.

An additional 2,800 homes could create a potential extra 5,000 vehicles. The present infrastructure is inadequate, new link roads which will sadly involve sacrificing more green belt or AONB, will be slow to materialise causing more chaos in the interim period. A cycle route connecting Paddock Wood with Tonbridge is a good idea, but is only ‘desirable’ in the Draft Plan. This should be upgraded to ‘essential’ to ensure it is built before funds run out. It is unrealistic to expect the majority to use public transport or work from home. Many of the new homes will be sold to commuters travelling to Tonbridge station; children are driven to local schools, trips to the supermarkets, delivery vans etc All adding to the traffic on our already extremely congested roads. The B2017 at rush hour is a nightmare. The Hartlake Road, once a quiet lane cutting across water meadows is narrow, bendy and dangerous for the present number of vehicles let alone a few thousand more.

We have already noticed a large increase in traffic along the Hartlake Road since the

M & S/Aldi/MacDonalds development in Tonbridge was completed as well as an accompanying litter problem.

The trains are at capacity. Parking around Tonbridge station will be even more difficult. The negative impact on Tonbridge & Malling Council and Tonbridge residents is going to be immense. Tonbridge will pick up the cost and TWBC will receive the council tax.

The CA1 site and the proposed school site are both divided by the railway line –hugely impractical and contravening garden settlement principles. A new school will also add to the traffic and pollution problems around Tonbridge.

The Sustainability Appraisal 8.2.4 states ‘TWBC placed great emphasis in the preparation of this Plan on working with local communities particularly in the villages. Such engagement in combination with a consideration of national policy requirements contributed to the selection of sites for short listing as well as the proposed site allocations.” Residents of Capel had NO involvement in the selection process as the Tudeley Site was submitted after the SA was carried out in 2015-2016. This contradicts the ‘Masterplanning’ approach, which requires ‘close liaison and involvement’ with local residents.

Table 15 SA of Draft Local Plan spatial distribution strategy scores for the objectives gives a +ve for ‘health’, with no negative outcomes, because benefits favour urban settlements. I would challenge this score as the health of the existing residents of Capel has not been taken into account in anyway. The proposed draft plan has caused huge stress and anxiety to residents within the parish and this will continue as we live with the consequences of living in close proximity to a building site for many years to come.

DLP_5676

Richard Burt

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

This proposal if it goes ahead will cause will cause immense harm to residents of the Parish of Capel and to residents of Tonbridge. I have lived in south Tonbridge for over 40 years and the proposed development will almost certainly have adverse effects on my quality of life with no benefits. The main reasons for my objections to the proposal are as follows:

A significant loss of green belt will occur if the proposal goes ahead.
People living in the proposed development in Tudeley and East Capel will almost certainly use the facilities in Tonbridge for shopping, schools,etc. This will add more pressure on existing services which are already stretched

3 Traffic into Tonbridge from the B2017, will exacerbate the extreme traffic congestion that exists on this and other roads particularly every morning.and evening.

People living in Tudeley will use Tonbridge Station for commuting and will need more parking in and around Tonbridge Station which is already very difficult.
The costs of any new infrastructure on the Tonbridge & Malling side of the boundary will have to be carried by Tonbridge & Malling residents while Tunbridge Wells will receive council tax from the residents in the new dwellings.

DLP_5677

Paul Mansi

We have lovely woods in Capel where birds and other wildlife thrive please do not destroy them when is so many brown sites are scattered around the whole of the area that could be used instead. Remember once the countryside has been destroyed it never comes back. Future generations must be allowed to see our lovely countryside not more concrete

DLP_5678

Simone Harrington

I am writing to express my concerns about the proposed development across the above mentioned areas.

Whilst I agree that more affordable homes should be built I don't believe this is the way forward.

My concerns are as follows.

Flood risk increased due to large areas not having sufficient drainage, fast run off of rain water due to hard materials.

Traffic congestion & associated pollution.

Insufficient infrastructure to support the new population.

I also remain unconvinced that the homes being built will have a high percentage of affordable homes.

I urge you to reconsider these plans.

DLP_5680

Sarah Taylor

I wish to register my concern at the proposed plan to build so many new homes in Tudeley.

As a resident of Tonbridge I am aware first hand how stretched our infrastructure and facilities already are - the roads are frequently gridlocked, parking in the town centre impossible at weekends, the trains to London full and standing and the waiting lists long for services like Drs and dentist appointments.

Any new development of the size proposed here must include Drs, dentists, shops ,schools and a train station as well as housing otherwise the impact is just to great.

I would also note the importance of the church in Tudeley, especially the stained glass windows, and any development nearby must be sympathetic to maintaining this unique part of our heritage.

DLP_5681

Dermot Cowper

I Live at XXX, Badsell Road, Five Oak Green, XXX [TWBC: House name and post code redacted].

I work as a Landscape Architect here and in Ryarsh and in the surrounding areas local to where I live.

I spend much of my time walking recreationally in the areas proposed for development, across the fruit fields and along the river.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

I feel that this plan is neither well thought out nor will it contribute positively to our local area.

There are insufficient facilities to sustain such a development here. I do not feel the planners have considered the suitability of the sites and I believe that the sites have been chosen only because the land is available to buy.

The unique character of this agricultural land on a flood plane will be devastated and cause an environmental catastrophe to the local wildlife and natural surroundings. There is no evidence that this site can support a new population, currently there is no public service infrastructure to tap into, the roads and transport network are insufficient, the area will be permanently changed and cannot sustain a larger population without vast investment of in local services.

The Hadlow Estate (Land owner) seems to only be concerned with the appearance of the future development rather than it’s sustainability or benefit to the local community. It’s motivation to sell the land for development is purely for financial gain rather than any environmental stewardship.

It seems a daft proposal to place 2800 new homes on a greenfield site without any existing infrastructure to take advantage of. The are numerous sites around the town of Tunbridge Wells that should be considered before as they will offer a better connectivity for a development.

Identifying a place with connectivity to micro and macro infrastructure is a fundamental for new communities to develop sustainable living. Placing a new communities onto fresh site without and away from any facilities will likely lead to the creation of a ‘Ghetto’, for example the Thamesmead development new Abbey wood.

For many years the insufficient funding lack of and connectivity at Thamsmead meant that the housing was left empty until local authorities grouped together to rehouse their own populations there. This inevitably lead to a ‘Sink Estate’ being created.

The Tudely site is completely in appropriate for these reasons. It makes no sense to attempt to make a new community there. To make a sustainable community the funding and resources necessary to realistically connect it to a larger population so that it is not isolated would surely be so vast that it is not worth the damage to the natural capital of this area.

Apart from damaging the natural environment, there will be a dramatic effect on the existing communities. The road network will need updating and expanding along with the local public transport in order for any new community to integrate successfully . Expanding roads is a particularly ungreen policy and does not express a sustainable attitude for the future. There is no mention of any cycle paths or walking routes to and from the development which could connect people with the main line station at Tonbridge. Once again the proposals are old fashioned and designing around the reliance of a family using a car.

Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change.

Creating so much housing in Capel Parish will require the destruction of woodland, hedgerows, meadows, and farmland that is Green Belt land and should be protected.

All in all this is a poorly thought through plan and the sites to be developed have been selected because the land owner wishes to sell, which is lazy. Development here at Tudley poses environmental risks as it is on a flood plane, is detrimental to wild life and the natural environment. It is likely to create a ghetto in the countryside much like Thamesmead because it is so poorly connected and will do more harm than good. It will rely upon a future with cars which is not the right way to design for the future. There are better sites that need to be considered first that could connect future residents into an existing network rather than build a completely new one.

This plan is the least sustainable development that Royal Tunbridge Wells could propose. The council should be associating itself with good development that leads to sustainable communities not this this plan.

DLP_5685

Ruth Davies

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1) and to the inclusion of land in East Capel in “The Strategy for Paddock Wood” ,Policy STR/PW1.

I am a resident of Tonbridge and I object for the following reasons:

The whole development is close to the Tonbridge boundary and is likely to have a negative impact on traffic, station use and Tonbridge amenities. There is already limited parking and traffic levels are high, particularly during school times and the working day. TMBC will incur costs for roads and services infrastructure whilst gaining no revenue from the residents.
There is insufficient community infrastructure, for example community spaces and halls, local shops, medical centres etc. within the plan. The school will result in even more station traffic with pupils who then face a walk along busy and congested roads, with potentially poor air quality.
No development should be undertaken on green belt or agricultural land. There is plenty of brown site land available within TWBC to meet the new housing demand. Equally, the impact on the flood plain is likely to be negative through loss of absorbent land.

DLP_5688

Michael Fulford

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

For the record I am a Tonbridge resident living in a flood prone area next to Hildenborough and have been retired for several years.

Re the proposed development at Tudeley of 2,800 dwellings I am concerned that this will cause some considerable upheaval to both residents of the Parish of Capel and of Tonbridge. It seems most likely that here will be a significant increase in traffic in to Tonbridge from the B2017, adding to the extreme traffic congestion that exists on this road every morning.

No doubt people living in Tudeley will use Tonbridge Station for both commuting and Tonbridge town services using cars that will need more parking. Tonbridge traffic is already notoriously slow and the increase in traffic volumes is bound to cause a more or less permanent rush hour gridlock.

The increased numbers of passengers on already heavily used commuter trains from Tonbridge Station will be a nightmare for existing and new extra commuters.

The costs of infrastructure on the Tonbridge & Malling side of the boundary will have to be no doubt borne by Tonbridge & Malling residents whilst Tunbridge Wells will receive council tax from the residents in the new dwellings. The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area.

I am concerned that here will be an increase in pressure on Tonbridge health services. I have been with my present Tonbridge practice since 1979 in which time it has grown to some 18,000 patients with waiting times for appointments noticeably increasing over the recent years.

As previously mentioned I live on the edge of the Medway floodplain and am apprehensive that any downstream development will increase the overall flooding risk. There are long awaited improvements to the flood defences planned by the Environment Agency and I am concerned that there might be further delay whilst the flood risks of any developments in the Tudeley area are properly assessed and understood.

Whilst I am sure that everyone agreeds that new and improved housing is of great importance I also understand that such housing needs as calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I understand that “exceptional circumstances” do not actually exist in this instance and I do not see whyTWBC should not use this argument to remove the garden settlement at Tudeley from this plan.

Therefore I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1). This land is Green Belt land and should only be built upon if an “exceptional circumstance” exists. TWBC’s own assessments in their Sustainability Appraisal show that Paddock Wood can expand and meet most of the plan’s aims without using the Green Belt land at East Capel.

DLP_5689

Margaret Beston

I have been a Tonbridge resident for just over 40 years. In that time, I have seen the town expand extensively. Additional housing has already put a strain on resources such as medical services, schools and transport. Traffic has increased inordinately causing regular congestion at both ends of the town.

I am writing to object to 'The Strategy for Capel Parish' (Policy STR/CA1).

Although Capel and Tudeley fall within the Tunbridge Wells BC, the creation of a garden settlement of 2,800 dwellings would not only cause harm to residents of the Parish of Capel but have an adverse effect on Tonbridge. It will also destroy some 600 acres of Green Belt and cause damage to an AONB.
There is no train station at Capel. The nearest station is Tonbridge, already one of the busiest in the South East. Additional commuter traffic would place unsustainable pressure on current facilities, not to mention the lack of space for any additional parking.
Tonbridge, not Tunbridge Wells, would be the nearest town where 'garden settlement' residents could access medical and educational facilities. These are already under tremendous strain. Costs for additional facilities would fall on TMBC ratepayers, not TWBC.
Tudeley Chapel is unique. It is the only building with a complete set of windows by the famous French artist, Marc Chagall. Visitors come from all over the world to see them. It is of national and international importance.
The seriousness of flood risk should not be underestimated. Tonbridge is on a flood plain. Replacing huge areas of fields and woodlands with tarmac and concrete will significantly add to the increased risk of flooding - not only to Tonbridge itself, but other villages along the river.
I understand government policy is still that development on Green Belt land should take place only in exceptional circumstances. No such circumstances have been demonstrated in this case.
The current Local Plan appears to envisage further housing development in the area. This would lead to further loss of Green Belt land, and to an unbroken conurbation from Tonbridge to Paddock Wood.

DLP_5691

Andy Macdonald

TUNBRIDGE WELLS PLANNING DEPARTMENT SHOULD BE CONGRATULATED!

They are hoping to achieve their quota for new houses, whether affordable or not, by planning a new housing development at the furthest point from Royal Tunbridge Wells, positioning it in the beautiful green belt area surrounding Capel and Tudely.

By selecting this area TWBC have, very cleverly, chosen a site that creates minimum disruption to themselves, whilst gaining maximum income from both council and business taxes. Conversely, it will create maximum disruption to Tonbridge, its businesses, infrastructure, schools, doctors’ surgeries and so many other amenities, whilst providing not a penny towards the cost.

It is quite amazing how an area designated as Greenbelt can, at a stroke of a pen, suddenly become fair game for building with very little, if any, consideration given to those whose lives are affected.

This proposal is one of the largest yet worst to affect Tonbridge with no affect to Tunbridge Wells in any form. It is Tonbridge town that will bear the cost, daily disruption and pollution.

Food production is becoming critical. We have an ever increasing population needing to be fed so, how on earth will we be able to provide this food if councils take it upon themselves to build on the very land we desperately need to produce our food?

The planning department of Tunbridge Wells Borough Council and the management of Hadlow Place Farm appear to be the only two in favour of such an atrocious scheme.

THIS APPLICATION SHOULD NOT PROCEED!

DLP_5692

Mark Preston

Hi my name's mark and I seriously think this is disgusting what you are doing there is no infrastructure to take all this...you barely get a drs appt in paddock wood as it is also the drainage in paddock wood us already outdated and can't cope ...traffic will be worse more cars more pollution...not enough school places ...seriously you lot need to think about what you are doing ....it's wrong very wrong

DLP_5694

Eric Beston

I have lived in Tonbridge for 42 years and commuted by rail to London from Tonbridge station until my retirement. Through these years, I have walked most of the surrounding countryside, including Capel Parish, and know it well. I have also seen the road congestion in and around Tonbridge increase dramatically; and the pressure upon Tonbridge railway station approach the limits of sustainability.

I write to object to 'The Strategy for Capel Parish' (Policy STR/CA1). My objections are:

The proposed 'garden settlement' of nearly 3000 dwellings and associated roads and other infrastructure would destroy a huge area, some 600 acres, of beautiful Green Belt land and damage part of an AONB.
It would do great harm to Tudely Church (All Saints) which is not only of major national importance but of world significance. With its complete set of Chagall windows the church is a unique heritage asset which merits its peaceful rural setting. It is so much more than a " popular visitor attraction" as the TW Local Plan (page 155) describes it!
The proposed development would cause major harm to Tonbridge residents (in addition to those of Capel) by greatly increasing traffic on the B2017 and,in particular, roads within the town which are already heavily congested at peak times. Tonbridge has few options for easing traffic congestion.
Tonbridge would be the closest station to the proposed development. Tonbridge station is already the busiest in the South East outside London. Not only would traffic to and from the station increase but a great increase in users of the station at peak times would place dangerous and perhaps unsustainable pressure on current facilities.
Tonbridge is closer to the proposed development than Tunbridge Wells so is likely to be used by residents of the Capel 'garden settlement'. Costs and problems will thus fall on TMBC and its council tax payers while TWBC will receive the tax from residents of the proposed development. Problems for Tonbridge would include car parking (already barely adequate), roads within town, health and other local services.
It would be folly to build thousands of new dwellings on the Medway flood plain. Replacing a huge area of fields and woodland with tarmac and concrete will increase the flood risk. The Tonbridge flood barrier and an increase in the height of riverside walls in parts of Tonbridge has saved much, but not all, of the town from flooding. But parts of the town and a number of riverside villages have suffered, especially when it has been necessary to release water from the barrier's lagoons. Green field development will add significantly to the problem.
Despite some changes, I believe government policy is still that development on Green Belt land should occur only in exceptional circumstances. No such circumstances have been demonstrated in this case.There is no detailed Green Belt Study; no Landscape Assessment; no Biodeiversity Assessment. The current version of the draft Local Plan is not complete.
The current Local Plan appears to envisage, in the longer term, further expansion of housing development in the area. This would lead to yet more loss of Green Belt land and, eventually, to an unbroken conurbation from Tonbridge to Paddock Wood.

DLP_5695

Richard & Anne Barber

Your proposed development will ruin what can only be described as a lovely country area and cause chaos to Tonbridge which is ill equipped to deal with such numbers. There is no way the infrastructure could cope with the size of the project envisaged.

It is clear from its position on the boundary of your catchment area that it will not impact TW directly so it is only fair that the local opinion which is strongly against the proposal should prevail.

DLP_5697

Bridget Davis

I am writing to object to the “Strategy for Capel Parish“ (Policy STR/CA1)

I am a resident of North Tonbridge, having lived here for more than 25 years. I am a frequent visitor to the part of Capel on which you propose to build houses and I am horrified at the proposition.

It is currently a beautiful part of our area and Is full of wildlife and I understand that it is good farmland. To build houses there would spoil the area completely and in particular would damage the surroundings of Tudeley Church which is an important local landmark and tourist attraction.

Presumably such development cannot go ahead without huge amounts of public money being spent on infrastructure such as major roads. The country lanes in the area will turn into significant highways.

As a resident of Tonbridge I believe that the impact on this town will be considerable. Even if traffic successfully flows from the new development of 2800 houses into Tonbridge, where will it go from there? Tonbridge is already overloaded. The railway station and surrounding car parks simply will not cope. Nor are the amenities in Tonbridge (where new housing units are already being built) sufficient for this number of extra residents on our doorstep.

Finally, I find the proposed location of the new school, alongside Woodgate Way and straddling the railway to be preposterous. What are you thinking? How will hundreds of children make their way to a school in that location? Presumably they will come from Tonbridge which begs the question as to where this school is serving.

DLP_5698

Sally and David Campbell

We are writing to express our concerns with regard to the above draft plan.

Well being

We relocated from Redhill to Five Oak Green over 35 years ago to live in a quiet village setting. We wanted to bring up our children in a quiet area and less polluted environment. Our children attended Capel Primary School a small village school allowing them to appreciate the beautiful surroundings.

Our concerns centre on the following areas:

Public Services

The road from Five Oak Green to Tonbridge B2017 is already seriously congested during the school run period. This plan will result in even more congestion as people try to get to the new schools or Tonbridge Station. There does not appear to be a solution in the plan.

We are both retired and make use of the local buses. The plan mentions the intention to increase the bus services but these will be impacted by increase in traffic as mentioned above.

Trains from Tonbridge station are already over crowded during rush hour, we cannot see any proposals for additional services or capacity.

Our local health centre at Woodlands Paddock Wood is already stretched to capacity making it difficult to book appointments. Even with the proposal for a medical centre in the plan we are still concerned about the increased demand.

Infrastructure

We do not think the drainage system will be able to handle the additional demand as in the past we have been informed that the drains in the village are at full capacity. Even with the improvement to the drains put in place a few years ago.

Will the existing electrical substations be able to cope with the increased demand? Will additional pylons be required or will the main power supplies be sunk in the ground resulting in either additional eyesore or environmental impact?

Mobile signal in our area is already patchy so will this require additional signal masts to meet additional demand?

Flooding

The village has been subject to flooding in the past.

We are concerned that the increase in hard surfaces and reduction of trees will exacerbate the risk of flooding.

Greenbelt

As mentioned before we moved to this area specifically for the beautiful countryside and wildlife. Building on this greenbelt area will destroy it forever. The already threatened wildlife will be homeless. The plan will increase air noise and light pollution. There will be a significant increase in traffic pollution which is of a great concern to us as both our daughters suffer from asthma which maybe triggered.

Housing

We cannot see from this plan how the lack of affordable houses in Tonbridge and Paddock Wood will be alleviated by this plan as it only mentions a small number. If more flats or single person accommodation were built then less land would be required and the impact on the Greenbelt significantly reduced.

Finally

We understand there is a need for more housing especially affordable houses, however we do not think this is the right place as it is on beautiful greenbelt land and there are other brownfield sites available.

DLP_5700

Mrs Jacqueline Cobell

They call our beautiful countryside Royal Tunbridge Wells.

Because Queen Victoria loved visiting our Town, and the beauty that is The Garden of England.

She would be turning in her grave, if she knew the bulldozers were running riot on our green beautiful fields, ripping up ancient woodlands, our little creatures running for their lives, their habitat gone forever. And once the concrete is laid, the fertile land is gone forever.

We love where we live, we marvel at our Area of Outstanding Natural Beauty.

We are blessed that we live here.

But it all changed in May 2019. Imagine our shock and utter dismay when we learnt of a New Town envisaged to swamp our little hamlets. Tudeley a quaint picture book of Oast houses and historical timbered houses, a world renowned ancient church bearing every window painted by the Russian artist Marc Chagall. Folk come from all over the world to love and appreciate these great works of art, commissioned by Lady Goldsmith in memory of her beloved daughter who died tragically.

The peace, serenity and magical light surrounding our little church will be lost within a mass of ticky tacky homes thrown together in great haste to earn the greedy developers more money. Talking of greed TWBC will be earning millions in Poll tax.

Perhaps other sweeteners as well . ......

So the call went out for landowners, better and cheaper for the planners and council to make deals on Greenbelt. There are 109 Brownfield sites in Tunbridge Wells, so we were told by Steve Baughen Indeed a big brown site is dead opposite TW town hall ! 18 years a brown field site . Homes could be built there !!!!!!

Looking at the draft plan, it is a dire project glued together by planners that haven't got a clue. They say that's it's a government initiative / necessity that we need 4,500 houses. That's just poppycock. Yes homes are needed, but planners want to put them in our village because they have one big landowner offering it all on a plate for an exorbitant amount in one foul move. This is lazy planning, and bad planning !!!

The above is why I sincerely and deeply object to the proposals for sites CA1 and PW1.

Comments on the introduction Plan preparation process para. 1.4 p.13

The issues and options process 2017 mentioned a garden village but with no location.

All of a sudden in mid 2019 its much more than a village set in Tudeley smack bang in the middle of the green belt which is contrary to the issues surrounding the protection of the green belt.

ACTUALLY I OBJECT TO YOU THREATENING TO IGNORE MY COMMENTS IF I DON’T RELATE EACH COMMENT TO A SPECIFIC SECTION AND PARAGRAPH. BEARING IN MIND THAT YOU SHOULD KNOW YOUR DRAFT LOCAL PLAN LIKE THE BACK OF YOUR HAND YOU SHOULD BE ABLE TO RELATE ALL MY COMMENTS TO YOUR SECTIONS AND PARAGRAPHS.

THIS OBJECTION LETTER THAT WE ARE SUPPOSED TO WRITE ON YOUR TERMS IS INTIMIDATING, CONDESCENDING, AGEIST AND DONE ON PURPOSE TO CONFUSE THE ORDINARY FOLK. HUMANITY IS THE GREATEST QUALITY THAT MAN CAN HAVE, ARROGANCE IS UNDOUBTEDLY THE WORST !!

I’M SURE MY FRIEND AT THE BBC WILL BE VERY INTERESTED TO KNOW HOW THE NUMBER OF OBJECTORS HAS BEEN KEPT LOW DUE TO THE HOOPS AND HURDLES THAT THEY HAVE HAD TO MEET TO AVOID BEING IGNORED

1. A Garden Village is defined as a place where local people can live and work.

This New Town will become a hub for commuters working in London, not for our local folk.

2. There is not a need for all these houses for local people. The birth rate in the Tunbridge Wells area is declining.

3 . Why vandalise our Greenbelt and Areas of Outstanding Natural Beauty, bulldozing fertile productive land, when brownfield sites are available ( according to Steve Baughen at the first meeting in May )

4 . The proposed building site of 600 acres is on a flood plane .

Recent houses built in our Village had to have tanks built under their foundations to take up flood water. This means all new houses will have to have the same measures built in. But as developers are self regulating, they won't go to this expense!

5 . Our village has flooded badly at least three times. Councils oppose concrete drives that are non-porous. So what is 600 acres of concrete going to flood. Capel !!!

6 . 4.500 homes will each own 1 or 2 cars. Our country roads are not fit for purpose now, let alone another 6000 or more vehicles in and around the Tonbridge area. This will create massive traffic Jams. It takes half an hour now in the rush hour to reach the roundabout at Woodgate way . Mainly because of Sommerhill School .

7 . The new secondary school opposite Sommerhill will create even more traffic chaos. The school will be divided by the Railway line. This will not be safe !!!!

8 . The New Town will be divided by the Railway Line !!!

9 . Tonbridge Station , the carparks will not handle the extra volume .

The Trains are overcrowded to bursting point already .

10 . The proposed new roads will destroy great swaths of Greenbelt , perhaps even homes compulsory purchased . The Medieval Church of Thomas - a - Becket

And the surrounding countryside will be ruined forever .

Do we not have any pride left in our heritage historic buildings left ???

11 . Global Warming . Chopping down hundreds of trees has a negative impact on purifying Carbon Emissions .

12 . The River Medway will be even more polluted . Mussels that once were along all the River banks have all but died because of pollution .

The River Medway runs into the oceans . More pollution and plastics in the Sea . I was given the opportunity to swim for a short while with Lewis Pugh, the United Nations Patron of the Oceans, as he swum the length of the English Channel last year to highlight the pollution in our rivers and oceans

13 . There will be even greater burdens on Pembury Hospital . doctors surgery , dentists etc etc . Tonbridge has not the Infrastructure to cope with all the extra folk the commute on its roads and services !!!

14 . Why build on Greenbelt and Areas of Outstanding Nature Beauty , when a Site in Horsmonden or in fact the A21 corridor has none of these ???

Perhaps councillors or planners live near there ?

15 . . Where is the democracy??? How dare you run roughshod over 2,000 folk whom have made their lives here . We love where we live . We choose to live in a village to bring our kids up in away from Towns and the inner city's !!!

16 . While the Landowner may make a billion pounds ..... we are losing millions , our homes blighted by this awful Town as big as Kings Hill swamping our 900 homes

Remember Kings Hill was built on a Brownfield Site . And it appeared to be getting bigger and bigger ! In fact , any green spaces have been built on . Just like at Holborough lakes , whereby the divers and swimmers car park has been built on .

Many people enjoyed diving and swimming . They have been denied a healthy pastime , because of greedy developers .

I sincerely hope that you and the planners see sense and decide to stop this folly of a new town in one of Kents most beautiful low wealds that has hundreds of years of history and has truly majestic buildings.

We Love Where We Live. We Love Our Friendly Community.

This plan will devastate so many passionate villagers.

DLP_5704

Roger Tate

I am a resident of Tonbridge and have been for 50 years.

I am writing to object to ' The Strategy for Capel Parish' - Policy STR/CA1

The proposed building of 2,800 dwellings in Tudely is surely not even common sense. The increased traffic into Tonbridge is unacceptable as already parking is difficult and the roads often congested. The increased number of commuters will use Tonbridge station and where will they park? The numbers of commuters travelling to London from Tonbridge will be unsustainable.

To build a senior school on the proposed site alongside a very busy road with no lighting and no pavements some distance from Tonbridge station is surely a recipe for disaster.

The 600 acres of Green Belt should be protected, wild life and agriculture preserved and not destroyed to provide an excessive number of dwellings. Also building on part of the floodplain and covering it with an impermeable surface could be a serious error bearing in mind the impact of climate change we are experiencing at the moment.

If this plan is approved I am sure that sometime in the future further planning will be sought which will eventually encourage more housing resulting in an enormous conurbation which will require more schools, hospitals, doctors and dentists etc. I recently had occasion to make an appointment to see my GP and I was 26th in the queue for the receptionist !

These proposals have not been adequately thought through and the future of Tonbridge and surrounding areas would be irrevocably damaged.

DLP_5705

Shirley Simmons

Tudeley was my home for many years. The Simmons family has lived there for so long it’s been hard to locate when they first came to Capel and surrounding areas but more than 150 years.

Farming has been in my family for years and to put 2500 homes in that location is absolutely stupid. The land floods every so often my mother’s ashes were spread there, along with many others and the stress on the local services would be catastrophic.

Yes homes need to be built but not there there must be other places that are not do sensitive that could be used.

Tudeley is a quiet area with lots of history please don’t ruin that with such a stupid plan - I live overseas now but my home and heart is there and I visit every other year

DLP_5706

Sarah Brett

I'm writing to oppose the proposed planning of 2- 4000 new homes in the Tudeley/Capel area.

As this lies just outside Tonbridge, the huge impact this will have on our town is more than considerable - it would actually be insurmountable! Tonbridge will be tje town they all use with it being just a few miles away. Tonbridge infrastructure can hardly cope with the amount of residents it homes already. Conjestion down the high street is terrible -it takes me over half an hour in the peak times to get from north to south tonbridge. The high street is frequently at a stand still and at best crawling, even during non peak times.

There is currently hardly any space in the local car parks. The supermarket queues just get busier. Getting a seat on the trains is near on impossible during peak times. Ive never been able to see an nhs dentist in Tonbridge despite living here over 8 years and the appointment time for seeing a doctor is already over 3 weeks. In a nut shell, Tonbridge is fit to bursting and cannot possibly soak up any further people needing to use their facilities. It's already so strained that we are tempted to move due to the reasons above and this is such a shame as my husband's patents and my husband have been living here for almost 40 years.

I would be grateful if you would take these points into consideration during your consultation period.

DLP_5708

Tony Ansell

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

A new garden settlement at Tudeley of some 2,800 dwellings will cause immense harm to residents of the Parish of Capel and to residents of Tonbridge. This will generate significantly increased traffic into Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road every morning. The already unacceptable levels of traffic between 7.45am to 9am on Woodgate Way, Vale Road and Pembury Road coincide with the site of a proposed new 6 form entry senior school. This proposed school will be on the border with Tonbridge, split by a main line railway and alongside a heavily used road. This appears to be a terrible site for a school, surrounded by heavy traffic and requiring children to cross a busy train line to access both sides of the site.

Parking in Tonbridge is already fully used by commuters, and people living in Tudeley will also use Tonbridge Station for commuting and Tonbridge town services that will need a significant increase in parking provision. The increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times and can’t be made wider in most places. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable. Parking in and around Tonbridge Station will be even more difficult, if not impossible. Network Rail have confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. Most people living in the new garden settlements will drive privately owned cars, despite initiatives to encourage bus and bicycle use. The costs of extra infrastructure on the Tonbridge & Malling side of the boundary will have to be carried by Tonbridge & Malling residents, of which I am one, whilst Tunbridge Wells will receive council tax from the residents in the new dwellings. This is patently unfair to Tonbridge and Malling residents who will be severely affected. The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area. There will be an increase in pressure on Tonbridge health services, amenities and car parking as residents from the new garden settlement at Tudeley will use Tonbridge as their local town, not Tunbridge Wells, because Tonbridge is that much closer. Shopper parking in Tonbridge is already at bursting point.

Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. The recent flooding in the Midlands where new housing has been built on flood plains should set alarm bells ringing in TWBC. Flood mitigation measures may help, but I consider that flood risks will increase significantly. Covering farmed fields with houses and roads will increase rain run-off thus making the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding. Every 1 inch of rain on an acre is another 22,350 gallons of water to be disposed of via infrastructure, rather than just soaking into the open ground. For the areas that will be covered by impermeable material, the scale of the run-off will be overwhelming. There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape. Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saint’s Church in Tudeley, and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. Presently, it is an ocean of calm and tranquility, and the development will cause great harm to its value as a heritage asset of world renown which attracts many visitors and tourists (due to the complete set of Marc Chagall windows).

Creating so much housing in Capel Parish will require the destruction of woodland, hedgerows, meadows, and farmland that is Green Belt land and should be protected. It will blight the landscape and kill wildlife that is very special to the area, including rare species. This area should remain rural with agricultural land that can be used to provide food.

The plan preparation process didn’t include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan didn’t go through most of the plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment, and no Biodiversity Assessment. I think that this version of the draft Local Plan isn’t complete enough to be ready for public consultation when the land for such a big proportion of the housing hasn’t had the same level of assessment as the rest of the plan. The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they didn’t know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. I think that the plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough.

DLP_5710

Charlie Crampin

I have to say I truly despise of your idea to build over 2000 new houses in Capel. The green and wildlife is extremely important and it should not be removed. We do not want to make our countryside into a city. It is why I first moved here. My children go to Somerhill and if you build another senior school, the traffic will be terrible in the mornings. It will also mean it will get rid of a lot of the wildlife. I’m absolutely disgusted by your idea and this should not happen. I hope you think extremely carefully about this and reconsider this idea.

DLP_5711

Jacky Burrell

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

I live in East Peckham and drive to Sevenoaks each day. I am most concerned about the expected increase in traffic on the road through Golden Green and Tudeley and the impact on the existing traffic queues from the end of Hartlake Road, along the Tudeley Road and all the way along the A26 to the Vauxhall Inn roundabout especially during the morning rush hour.

My daughter keeps a horse stabled at .Bank Farm Stables Farm which is located off Tudeley Rd. This land is owned by Hadlow Estate. It is my understanding that the garden settlement will be constructed on land owned by Hadlow Estate and the stables will be demolished.. This would mean a loss of business for Hadlow Estate and nowhere in the close vicinity with the space and facilities to accommodate over 40 horses.

I believe the flood risks will increase. Covering farmed fields with houses and roads will cause increased flood risks across Tudeley, Golden Green, East Peckham, Tonbridge and Yalding. There will also be an increase in air, light and noise pollution and create a visual scar across our beautiful landscape.

DLP_5714

Brenda Benson

I am writing with my objections as to why I believe the proposed Tudeley Garden Village should be re-considered.

I have lived here for 39 years and am horrified at the proposals for building a Garden Village in Tudeley.

The proposals will cause chaos on the already congested roads in and around Tonbridge and the 600 acres of beautiful countryside will be destroyed, not to mention the wildlife. In London they are giving 30,000 trees to local residents to plant to help protect the environment and yet here we are destroying them to make way for more houses, more roads, more schools, more cars, more people, more everything. Its ludicrous.

I am a resident in Tudeley Village and the thought of replacing a beautiful, unspoilt and protected site with housing for city commuters and their families, heavily reliant on their private cars for transport outrages me and many others. It will destroy local communities and ruin local residents’ lives.

I am disgusted with Tunbridge Wells Borough Council planning for even considering such plans for Capel and Surrounding areas

DLP_5716

Sarah Gough

I understand that you are planning to build houses close to the graveyard of Tudely Church. This is an iconic Church and a most beautiful site - people need homes, but please not here. Surely there must be some brownfield sites that would not encroach on this lovely area. I do hope that you will reconsider.

DLP_5717

Joe Hale

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1)

Additionally, I am writing to object to the Mabledon & Nightingale Proposals.

I strongly object to the plans for additional housing in the Capel, Tudeley and Hangman's Hill.

There is no local appetite to build on the Green Belt land in the Borough of Tunbridge Wells. The Mabledon and Nightingale Proposals are advocating the construction of 120 dwellings in the 'Protected' High Weald Area of Outstanding Natural Beauty. This land should be protected, as it acts as a buffer zone between the Tunbridge Wells and Tonbridge Connurbations and is a Beautiful, Uninterupted site, following the local valley like landscape.

If the plans go ahead, these connurbations will be joined, effectively creating one single huge Borough. The plans of the Tunbridge Wells Borough contradict the message and theory behind Green Belt Laws

The Proposals to create effectively a Tudeley New Town is absolutely Ludicrus, they do not respect the Local wishes, neither do they respect the AONB's, Green Belt Land and Flood Plains as advertised in the Borough's Local Plan. The area for the Proposed new Garden Village regularly floods, and lanes nearby would be totally stretched to capacity, when a flood would occur with the 2800 new homes, as the developments would be cut off completely in the event of the Medway bursting it's banks near Tudeley. The Fields nearby where the development is planned are mainly agricultural, and can become unusable when flooding occurs. Tonbridge town Centre is already overstretched, with the surrounding roads operating at Capacity regularly, A brand new secondary school would be proposed near Somerhill Estate, however this wouldnt succumb to the demand for school/GP Places nearby, pushing nearby already overstretched facilities to the maximum.

I wouldnt be objected to additional development's on the Matfield and Brenchley side of Paddock Wood, as additional infrastructure including an A228 Bypass and an A21 Improvement near Kipping's Cross.

Nearby to the Tunbridge Wells Town Centre, more dwellings should be alternatively built near the Existing Developments of Showfields, Ramslye and Hawkenbury, as there is sufficient space to regenerate the Southern Side of the Town Centre. These Communities would most benefit the additional homes, as there is an existing community there. Dwellings here wouldn't effect the local landscape of the town, Green Belt and the AONB. I would be very, very supportive of New Homes in this area of the town and Borough, compared to the Tudeley and Hangman's Hill proposals.

Nearby existing towns such as Maidstone and Hastings have engulfed previously quiet tranquil villages on the outskirts of town, making the Town Centre's a less appealing space to visit. I would not be pleased if more visitors decided to avoid the Tunbridge Wells area, due to an apparent short sited development programme that focussed on Housebuilding, making the developer's richer and the Town Centre and Beautiful Scenic spots nearby a less appealing space to live, work and visit!

DLP_5719

Gordon Gunning

I have lived in Capel for the last twelve years and the surrounding areas for thirty - five years.

Over this long period of time, I have enjoyed the beautiful and tranquil surrounding countryside.

Whilst I fully accept the need for more housing and in particular, affordable housing. What I cannot accept is the shear scale of the proposed development in this area which will have a devastating effect on wildlife habitat.

Over the years on many of my walks through the local countryside, I have seen an increase in the numbers and diversity of wild birds. I have enjoyed watching deer grazing in the fields alongside rabbits and foxes.

The pressure on wildlife has never been so acute, so why on earth construct new homes, roads and infrastructure so densely on such a scale in an area of outstanding natural beauty.

As we are all aware, the roads in this area are not suitable to cope with the huge increase in traffic which is inevitable should the proposed development go ahead.

The risk to local residents, in particular children from traffic related accidents and pollution will be significant.

I trust that common sense will eventually prevail in the interests of all stakeholders !

DLP_5720

Debbie Morritt

I am writing to object to the housing estate on Capel. The reason for objecting is because with the addition of this many houses so many things in Tonbridge will be negatively impacted:

The roads in Tonbridge are already busy, this will make moving around impossible.

The addition of a senior school in that location is crazy.

Parking will be impossible in Tonbridge.

The train line is already overcrowded so an increase in travellers will push the line to breaking point.

The primary schools in Tonbridge are struggling already they cannot increase.

Doctors, dentists are all over capacity.

I appreciate this is a TW initiative but the real impact will be on Tonbridge and it’s residents. The council tax will go to TW borough council but the residents of TW will not be impacted but those in Tonbridge will.

Please object to this level of development.

DLP_5724

Julie Sanders

I am a resident of Five Oak Green and a mother with 3 children, the youngest attending Capel Primary School. My two elder children attend school in Tunbridge Wells and I work at Maidstone Hospital. As a family, we enjoy the green open spaces around Five Oak Green and Tudeley. The village and surrounding area are an ideal safe community in which to raise children due to the current level of traffic and low pollution. However, already, with current housing, the traffic on the main B2017 is congested particularly in the mornings

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

Creating a garden settlement at Tudeley of 2,800 dwellings will cause immense harm to residents of the Parish of Capel and to residents of Tonbridge as there will be a significant increase in traffic in to Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road every morning. The already unacceptable levels of traffic between 7.45am to 9am on Woodgate Way, Vale Road and Pembury Road coincide with the site of a proposed new 6 form entry senior school. This proposed school will be on the border with Tonbridge, split by a main line railway and alongside a heavily used road. This appears to be a terrible site for a school, surrounded by heavy traffic and requiring children to cross a busy train line to access both sides of the site.

The increased number of residents will use Tonbridge Station for commuting and the increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times. In addition, Tthe increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable and parking around Tonbridge Station will be even more difficult. at present Most people living in the new garden settlements will drive privately owned cars, massive,despite initiatives to encourage bus and bicycle use. The costs of infrastructure on the Tonbridge & Malling side of the boundary will have to be carried by Tonbridge & Malling residents whilst Tunbridge Wells will receive council tax from the residents in the new dwellings. The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area.

The building of so much housing in Capel 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, including rare species. This area should remain rural with agricultural land that can be used to provide food. With the current Climate emergency it seems ludicrous to add to the problem by the creation of more traffic and destruction of green belt land.

DLP_5728

Roger Worraker

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

I object to the inclusion of land in East Capel in “The Strategy for Paddock Wood” (Policy STR/PW1).

I live in Five Oak Green and for the last 50 years have travelled through Tudeley on my way to Hadlow and surrounding fruit farms in the area.

I am therefore fully conversant to the area surrounding Tudeley and the proposed areas of development. I object to the plans for many reasons:

1) It will destroy a large area of farming ground.

2) It will destroy an area of outstanding natural beauty.

3) It has always been a pleasure to travel to Tonbridge from Paddock Wood and Five Oak Green as well as Golden Green and Hadlow. This will no longer be the case.

4) I have experienced the occurrence of flooding in Five Oak Green and am concerned that the proposed development will increase the risk of future damage to property.

5) The dramatic increase in property will mean the traffic flow through Five Oak Green and Tudeley and the consequent road traffic risk.

DLP_5729

J.A. Blackmore

Regrettably I don't have enough time to read through a 500+ pages document, and unfortunately I have no confidence in the common sense and motives (I am afraid money plays too big a role) of those who will eventually take the decisions about the TWBC future plans for the Paddock Wood/Capel area.

These are my worries:

1. At the moment, at times of heavy rain, a lot of water is soaked up

by the fields around us. Even so, many gardens, fields, paths and roads are prone to temporary flooding. Where large areas of fields will be build on, this reduces the ability of the ground to soak up the excess, and especially with the future weather expected to be more extreme, it seems to me inappropriate to consider sites close to a river or even a brook like the Medway and the Tudeley Brook (a current example of "unforeseen difficulties" are the floods in the Midlands).

2. Wherever houses will eventually be build, it must surely be of utmost importance that they will be as environmentally friendly as possible; i.e. build out of environmentally friendly materials which will last, with low carbon output, energy saving and of a high safety standard (unlike Grenfell Tower and the recent wooden houses in the Maidstone area that caught fire too easily). Who will trust private companies to do this voluntarily? And who will be in charge of quality control and be ultimately responsible if anything goes wrong in the future (names and addresses please!)?

3. Around Paddock Wood the bulk of planned houses are on the North side

of the railway line. There is only one road crossing the railway, so everybody who wants to go to the centre of Paddock Wood will have to use this road, drive to the petrol station, turn left, through the whole length of Commercial Road to get to parking and shops. When the plans mention a total "make-over" of the town centre, I am convinced that a new plan will look lovely, but that it will be dumped because there are too many practical difficulties that cost far too much money (and who will commit to spending that?). Already a plan for a new primary school appears to have been taken out of an original agreement "because there is no current need for it".

Forget looking at the future!

4. There is already a shortage of facilities such as medical and dentist services, parking, useful/affordable bus transport and a community centre, and what there is, is not always well looked after ( e.g. roads - Warrington Road has been atrocious for a very long time - footpaths around Paddock Wood and existing ditches).

5. How much new housing will be actually affordable for people without pots of money or parental help? We seem to have a large number of expensive housing available for commuters, but this does not necessarily make for a thriving community. All new house owners should in future be protected against the uncontrolled, open-ended charges associated with, for example, "gated communities".

6. How much attention is given to the development of a "community" rather than a number of houses to be build (possibly in straight lines for convenience and keeping down of the costs), no matter what the effect will be on an already existing community?

7. When it turns out that miscalculations have been made and difficulties not been addressed; who will ultimately be responsible and, more to the point, who will have to pay for mistakes that have been made through lack of proper planning or neglect? Surely not the taxpayers?

8. And finally, why is the Council not pushing for a nationwide policy to use houses more economically with a chance for people to move more easily without financial penalties, especially when they want to downgrade.

I am rather depressed when I think of the chances of ordinary people being listened to when Government departments are prone to being influenced by smooth-talking entrepreneurs with great looking plans where difficulties are not mentioned or can be "worked out".

May be this time will be different?

DLP_5732

J Newman

I am totally against developing the local area of Capel and Tudeley on the grounds that the Green Belt should not be developed.

I live in the parish of Hadlow and Golden Green which directly borders Capel parish. We have lived here for many years and chose to live in this part of the world as it green countryside and everyday we walk across the public paths in this area.

I am writing to object to the “The Strategy for Capel Parish (Policy STR/CA1).

As I live so close to Tudeley, creating a garden settlement of 2,800 houses will cause an enormous upheaval to the local area. At the present time for me to get into Tonbridge in the mornings during school/rush hour it can take me over 30 minutes to do a journey that out of the rush hour takes 5 minutes along the A26. Hence, for me (and for most commuters from our area) it is easier and quicker to use the B2017 from Capel to Tonbridge. However, this road is now becoming so congested that again it can take 30 minutes to get to Tonbridge and the station. More especially during the term time when the Somerhill Schools have their hundreds of cars dropping off at the end of the B2017/roundabout. To then add another school on the opposite side of the road would be really dangerous and totally unacceptable.

So if you build 2,800 houses that is approximately a minimum of 2,000 people commuting to work and using Tonbridge Station. Where will they park? Tonbridge Station is already congested and full and this would also mean an increase in traffic in Tonbridge, which already cannot cope and is unsustainable. It is all very well saying that people will use the bus and cycle but a) the buses are so expensive in Kent, even for schoolchildren, that it is cheaper for 2 or 3 children to get driven to school than take the bus and b) in winter trying to cycle in Kent along the dark, country roads is madness. Although many people do cycle in the lighter summer months this falls right off in the autumn and winter when it is wet and snowy.

So where will these people go to shop and to use the health facilities? They will use Tonbridge – not Tunbridge Wells. This will increase he pressure on the paying borough residents of Tonbridge – not Tunbridge Wells. Will all their rates they pay come to TMBC?

From where I live in Blackmans Lane, just off Three Elm Lane to get to the B2017 we have to cross 2 bridges. The first one is a good bridge but the road is narrow and currently many people park either side of the bridge to fish, canoe and dog walk. This makes it very dangerous when cars come over the bridge and if there is a lorry travelling over it there is no room on the road either side. The second bridge – the railway bridge is so narrow that currently only one car at a time can cross the bridge. It is also not strong enough to take any lorries. With a new settlement of 2,800 houses and the lorries, delivery lorries and added cars this really would cause a problem for the bridges. Both would have to be rebuilt and strengthened.

My main problem though is building on Green Belt Land, which I totally oppose. Does Tunbridge Wells not have any brown sites, undeveloped sites by property developers (that they are sitting on) or land outside the Green Belt that could be used? I strongly believe that they do. The Second Reading in Parliament of the Green Belt Protection Law took place on 15/3/2019 and is slowly making its way through Parliament. So, hopefully, in the not too distant future building on Green Belt land will become illegal. Has there been a Green Belt Study for the Tudeley site? Have the local people been asked whether they would agree to their local countryside being developed? I do not think so.

I am also very worried for the local area as already the River Medway is being disrupted by the new and bigger Quarry along the Tudeley and Capel boundaries. I believe that this will cause more flooding on the Medway Floodplain and hence make the area of Tudeley totally unsustainable for building more houses on.

Please reconsider this Plan and if the Government still needs Tunbridge Wells to build more houses then please look at areas within your Borough that are not in the Green Belt and are more sustainable without upsetting the local wildlife. I would like our children to grow up walking through the fields/woods and seeing the wild birds and animals (like the otters along this patch of the Medway).

DLP_5735

Pandora Wilson

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

People living in Tudeley will use Tonbridge Station for commuting and Tonbridge town services that will need more parking. The increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times and can’t be made wider in most places. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable. Parking in and around Tonbridge Station will be even more difficult. Network Rail has confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. Most people living in the new garden settlements will drive privately owned cars, despite initiatives to encourage bus and bicycle use. The costs of infrastructure on the Tonbridge & Malling side of the boundary will have to be carried by Tonbridge & Malling residents whilst Tunbridge Wells will receive council tax from the residents in the new dwellings. The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area. There will be an increase in pressure on Tonbridge health services, amenities and car parking as residents from the new garden settlement at Tudeley will use Tonbridge as their local town, not Tunbridge Wells, because Tonbridge is much closer.

Upon review of the proposal it appears to be woefully lacking in its consideration of the substantial impact it will have on an already highly stressed area. As a resident of Tonbridge I can confirm the town already suffers from three significant pressures impacting the health, well-being and functionality of this town. This proposal will do nothing but exponentially worsen the obvious cracks in the infrastructure provisions currently in place and is seemingly lacking a holistic approach to the need for extra accommodation.

To draw from recent personal experience the problems to which I refer are as follows:

- GP services

o Upon moving to Tonbridge circ. 18 months ago I was unable to register at a GP in the local vicinity. I ended up having to go via the NHS allocation service which forces GP surgeries to take on new patients. I was confidently assured the GP books in Tonbridge are never open as there is never capacity.

o The GP was the nearest GP (some 20 minutes’ walk) and had an online patient rating of 3 stars. Despite being sceptical of online ratings this one is certainly deserved. Having spent collectively in excess of 40 minutes waiting on hold to book a doctor’s appointment (over 2 attempt) and facing a number of availability issues I was cheerfully advised that I should in future plan to see the doctor a month in advance. Let’s hope that none of the things people are waiting a month to discuss turn out to be time sensitive.

o Not to belabour the point but in 18 months I have been astonished that the provision of medical services in Tonbridge is no better than those on offer in Tower Hamlets (where I previously lived), where the sheer volume of people made it nigh on impossible to properly service the populous. It feels that Tonbridge is edging ever closer to the medical edge. A fantastic new hospital in Pembury is not a giant Elastoplast for the county.

- Roads

o If you have ever been to Tonbridge at “peak” during term time you will perfectly understand the how abhorrent the idea of directing more people, more students, more buses, more pedestrians in Tonbridge is.

o The proposed “high school” is ludicrous. It will merely add more traffic to what is a straining system. During term time London Road, Tonbridge High Street, Pembury Road and indeed the entirety of the A26 is at a crawl, based on the difference in term time / holiday it is clear a vast amount of the peak traffic is school children being ferried about. While there is effort to encourage dedicated bus routes frankly it falls much too short to solve the current problem, let alone if it is added to.

o Saturday and Sunday mornings / early afternoons are equally poor in terms of traffic through Tonbridge and into Tunbridge Wells. With the restriction on access to amenities caused by this, and the extremely limited free parking facilities in Tonbridge can have only an increasingly detrimental impact on the local economics. People will not “pop into a shop” if they are faced with no obvious locations and constant traffic queues. Tonbridge as an existing town must be prioritised over trying to “move the problem” which in effect only creates a wider sphere of influence and higher intensity of those problems.

o I have no idea what (if any) options have been explored but to improve this environmental and health lodestone on Tonbridge currently, but to take no action while approving a vast development and new school would be grossly negligent to the future of the town and the area.

- Trains

o In the past week of commuting there has been 3 morning trains (at different peak times) that have been standing room only by the time they arrived in Tonbridge. Southeastern has already admitted a capacity problem with the only current solution being to add more stock to the formations, something that is often evidently not being done. Tonbridge is already a substantial rail commuter draw for the town and surrounding villages. There is limited parking, terrible traffic and frequently maximum capacity trains. In adding another 6,800 homes in Tudeley and Paddock Wood this will push the morning commute into the realms of the TFL tube. Standing on a tube for 15 minutes with a constant ebb and flow of passengers is something quite different to a 32 – 50 minute over-ground journey where 32 minutes is timetabled but never achieved and being stuck behind freight, broken down trains, slow trains or delays into London Bridge can often make it a significantly delays journey.

o It would be interesting to know what discussions have taken place with Southeastern regarding train capacity and the need for more frequent “de-classifications” of seating when the train is over-populated.

The above list is in no way intended to be exhaustive but it flags some of the key infrastructure problems that are invariably not sufficiently addressed in the face of an expansion project. The urge is to always improve the infrastructure in parallel or afterwards or suggest it won’t be significantly impacted because… ... ...

Tonbridge already has social, health and transport problems, it would be self-destructive to ignore those in order to add housing capacity. The current proposal, without significant further revision and pre-approval milestones achieved, will only serve to hogtie Tonbridge to a quality of life downward trajectory. You cannot overlook the physical limitations of the town in terms of topography and infrastructure in the hope that a round peg will jam in a square hole for long enough to get the development over the line.

Please can you advise me of your feelings to this proposal and why? Finally, I request that you do not support this proposal that is ill thought and unsustainable and is detrimental to both local residents and businesses and those from further afield.

DLP_5748

Andy Kingsley

Save chapel my family and I have lived in caple All our lives and we strongly disagree with your proposal to build thousands of houses in our area we are asking you to reconsider your decision but we will not sit by and let you ruine our village way of...

(TWBC - comment was entered into subject line of email and this is all that could be retrieved.)

DLP_5761

Bruce Burdett

I strongly object to this proposal.

My key concerns are;

1. The A264 road between Paddock Wood and Tunbridge Wells is already is already at saturation point. HGVs between Paddock Wood and Pembury make this narrow road dangerous. The plan will only encourage even more traffic onto the the A264/

2. The land is Green Belt and open countryside and must be preserved as such. The new Prime Minister recently spoke of his plans for '' a massive house building programme on BROWN FIELD sites'', The plan
clearly contradicts government policy.

DLP_5782

R W Pegden

As a resident of Tonbridge I would like to make the following comments on the above plan.

1) The proposed development on the land at Tudeley will have a far greater impact on the resources of Tonbridge than on TWBC.

2) Roads into Tonbridge which are busy at the best of times but in particular at the beginning and end of the day will be overwhelmed by the additional vehicles coming from the Tudeley development.

3) Whilst a new school is planned the impact on the established schools in Tonbridge will be unimaginable.Demand is high for places at the local grammar schools at present and it will get even worse.

4) Whilst London commuters will have the option of going to Paddock Wood I suspect many will choose to go to Tonbridge with a greater choice of trains. This will create further pressure on already crowded trains and in addition problems with regard to parking.

5) All the benefits of the scheme will give a tick in the box to TWBC whilst they are far away from the negative impact. This must fall on Tonbridge.

6) Further erosion of our precious Green Belt.

7) The potential impact on Tonbridge can be seen by the way in which the West Malling development has impacted on it.

8) Little consultation seems to have taken place with surrounding Councils and the impact on them. The dangers of not doing this can be seen with regard to the comments of the Inspector who viewed the Sevenoaks proposals.

DLP_5783

Mark Colyer

I have lived since 1993 in Tudeley where we have raised children through the local schools of Tonbridge and Tunbridge Wells (TW), and who are now both at university. My family has been privileged to live for this time within the Somerhill Park – an area of AONB and on the Register of Parks and Gardens of Special Historic Interest.

As such, I am a resident of Tunbridge Wells but feel more a part of Tonbridge. For the last 10 years I have run a consultancy business now based on Riverside Road, Tonbridge to which I commute each day in my (electric) car along the B2017. Several times a week, I also take a train to London from Tonbridge station. We shop in Tonbridge. I run in Tonbridge Park, swim in the pool and so on. My son played rugby for TJs for many year. My wife and daughter kept horses within Somerhill Park and rode them along the toll paths from Tudeley towards Hadlow. I have been a member of The Angel Centre gym for around 15 of the years I have lived here. We have a Tonbridge postal address.

I am outlining the above simply to make the point that I am absolutely in the heart of some of the major proposals of TWBC Draft Local Plan, living and working on and across the border between the two boroughs. I feel as qualified as anyone else therefore to provide heartfelt thoughts on the horrific real world implications of this plan on the residents of this part of TW, but also the impact on those who live and work in and around Tonbridge.

This letter follows an earlier letter dated August 2^nd 2019 to the councillors of TWBC as well as local MPs Messrs Clark and Tugendhat. I might add I have not any response from TWBC to this date.

I am writing to formally object in the strongest possible terms to “The Strategy for Capel Parish” (Policy STR/CA1).

In short, this appears to be an ill judged proposal which will detract from the lives of every resident of Capel Parish and surrounding areas. Mention of “betterment” seems crass and insulting in the context of destroying 300ha of attractive high quality agricultural Green Belt In addition the huge impact on the residents of Capel, it will negatively impact on many areas of the south east and central Tonbridge, including all major routes in and out of Tonbridge in all directions, and the residents and commuters of these areas.

I have many points to make and will do this over the following pages but I would like to preface all of it by one other There is, what appears to me, to be an underlying bias in approach to how this high risk and lop-sided “eggs in one basket” garden settlement strategy has been thrust at last minute upon the residents of both Capel and Tonbridge with almost no detail or assessment of viability in many major areas. Whether is due to under-resourcing in the TWBC Planning department or not I do not know but at times it feels like underhand methods have been employed. And it is hard to see how it benefits ANYONE in the area paying Council Tax today to TWBC (or neighbouring TMBC).

Green Belt

Destroying 300ha of Green Belt cannot be undone and must not be allowed when other options clearly exist and an absence of real “exceptional circumstances.”

NPPF paragraph 134 states “Green Belt serves 5 purposes”, two of which are “(a) to check the unrestricted sprawl of large built-up areas; (b) to prevent neighbouring towns merging into one another”. The most elementary assessment of the local geography show that this Strategy will do precisely what Green Belt policy seeks to avoid.

As one drives from Woodgate Way onto the B2017 towards Five Oak Green, one leaves an urban area and immediately enters countryside with views to ancient woodland in Green Belt to the left and AONB/Parks and Gardens of Special Historic Interest to the right. Then one enters the village of Tudeley, drives past the world renowned historic Tudeley Church and leaves the village with open views across the proposed site of the Tudeley village development towards Hadlow Tower and the North Downs, before entering the village of Five Oak Green. Building the proposed school on GB/Ancient Woodland and then placing 2,800 dwellings in Tudeley will make Tudeley nothing more than a suburb of Tonbridge and then in turn the East Capel development coming back towards Five Oak Green will simply destroy the separation of the distinct areas with, over time, a merging into one continuous sprawl from Tonbridge to Paddock Wood.

The Local Plan states “The site is in the Green Belt: the TWB Green Belt study (2017) identified that the harm caused by the release of land in this broad parcel is “high””, but then ignores its own assessment and proposes it as suitable, unlike other less harmful alternatives.

Scarring of the Landscape

Building on the previous point, the proposed Tudeley village development will be highly visible damaging views from many, many points both near and far.

There is no assessment of the visual impact of developments.

Most locally, it will be viewed from within Somerhill house itself, from many viewpoints within the Somerhill Park, from all the (worldwide) visitors of Tudeley Church with its famous Chagall windows which will directly face the housing estate – literally 10 or 20m away. Local walks such as Tunbridge Wells Circular Walk and Medway Valley Walk will either border the development and/or have direct viewing of it for significant distances. Anyone driving between Tonbridge and Capel or Five Oak Green will lose the beautiful uninterrupted views to the North Downs.

Then, nearby villages such as Golden Green will look directly across to it as will, from further afield, viewing from the North Downs looking south. There are almost certainly many other views that I am not familiar with which will be affected due to its prominent position on ground rising from the Medway flood plain.

Roads and Traffic

The B2017 is notorious for being blocked, most notably during the morning commute creating gridlock back down Hartlake Road and Crockhurst Street. Two of the main causes of the gridlock are a) Schools at Somerhill traffic and b) lack of capacity exiting the roundabout in both directions on Woodgate Way.

STR/CA1 proposes adding a new school right on this bottleneck, plus adding 2800 houses approximately 1km down the road and with no developed strategy for what road infrastructure will be put in place to support either of the two additions.

The Infrastructure Delivery Plan offers the following: Additional capacity between A26 and Capel on B2017;

New roundabout at B2017 Tudeley Road/Hartlake Road to increase junction capacity; Upgraded roundabout at A26 Woodgate Way/B2017 Tudeley Road to increase capacity at junction;

TMBC has made it clear that they cannot resolve the existing road infrastructure issues due to the railway line and Medway running through the centre of the town. The three Somerhill schools will almost certainly remain a major cause of road traffic indefinitely. So irrespective of how much improvement is made to the B2017 capacity or adding/improving the roundabouts, this does not address the root cause: the roads absorbing flow from B2017 either way along the A26 into Tonbridge and the A21 are the bottleneck and will remain so. Adding another school and village development will simply expand the existing gridlock.

In addition the IDP offers:

New link to Colts Hill bypass (above) from B2017 (to bypass Five Oak Green) or to north towards Paddock Wood;

STR/CA1 “strategy” isn’t developed enough to know if new roads will run to the north or south of the railway line. It states “The exact location of such a link has not been determined”. This implies the Local Plan does not even know where the traffic demand will be, nor how to address it. Any additional roads, wherever they fall, will almost certainly be primarily on AONB or Green Belt as that is all that exists in the area. It is apparent that no real plan for roads, transport and traffic exists and as such, the “strategy” is nothing more than a TWBC Planning/landowner wish. Apart from being uncosted in financial terms, in reality the several miles of imaginary road will destroy an undisclosed and significant further amount of Green Belt or AONB. How can the Draft Local Plan proceed with this gaping omission?

Rail network

There are numerous major issues related to the rail network, literally cutting across the whole of Capel.

The main SE coastal rail line runs through the middle of both the proposed school AL/CA2 and the Tudeley village development AL/CA1. There are 3 road crossings between Woodgate Way and Five Oak Green. One is a single track private road (Postern Lane) with single track road bridge. One is a single track road bridge at the top of Hartlake Road. One is a single track (and regularly flooded) underpass on Sherenden Road.

There is no solution proposed on how AL/CA1, a “garden village” will be interconnected across the railway line which runs approximately on its centre line splitting it about 60:40 by area. Yet STR/CA1 talks of “exceptional permeability”. And justifies release of Green Belt on this basis yet there is no mention of HOW the village will function or traffic can cross from north to south other than the existing singe track bridge which is already a gridlock in rush hour before a further 2800 houses are placed around it, or via the (regularly flooded) single track underpass.

There is no solution proposed on how the new school on AL/CA2 will be interconnected across the railway line which runs approximately on its centre line splitting it about 60:40 by area. STR/CA2 notes “Suitable provision shall be made for access into the site, and between the different parts of the site (i.e. on either side of the railway line)”. But that is it – no details on HOW one school can operate straddled either side of a high speed rail line. Nor does it show how the area of CA2 to the north of the rail line is even accessed given it only has a tiny single track private road and a rail line bordering it. Nor does it raise any mention of possible risks to children being schooled around a high speed rail line.

It is well documented how busy Tonbridge Station is and it is my understanding the rail line is already at capacity. More advanced plans than TWBC Local Plan are already likely to be adding significant pressure to the rail line including large scale commuter developments in Marden, Staplehurst and beyond. Jumping ahead to another point, the nature of the development clearly lends itself not to the needs of the local community, but to the needs of London emigres many of whom will almost certainly need to commute back into London. And it is almost beyond doubt that the vast majority will do this from Tonbridge Station. The likely impact on Tonbridge and Capel traffic has already been addressed above. But the rail infrastructure itself will not be able to cope and having “standing room only” for existing and new additional Tonbridge commuters all the way to London is not acceptable. There is no plan identified to provide commuting capacity for the residents of CA1.

Local Education and Schools

A number of points referring to the AL/CA2 school proposal have already been made. In addition, from a general education provision perspective, Tonbridge is one of the most “secondary school dense” towns in the region with children travelling from the south coast and south London to attend it’s schools. Similarly Tunbridge Wells has a huge density of schools particularly along the A26. Adding yet another secondary

school on the A26 to the long list of state and private schools covering age 11-18 within 1-2 miles seems an unneeded proposal. To propose doing it in such an unsuitable location (urban sprawl, Green Belt, Ancient Woodland, railway line and gas line through site, gridlocked road infrastructure etc) seem extraordinary.

Air Quality

The Draft Local Plan states “Tunbridge Wells borough faces significant transport challenges, particularly in terms of managing existing congestion and future growth, as well as needing to respond to the impacts of air quality and climate change”.

And “The new Local Plan should be supportive of opportunities for improving air quality within these areas, as well as borough-wide; for example, by promoting non-motorised forms of travel, including walking and cycling.”

And “Developments are expected to be at least air quality neutral, with air quality positive proposals strongly encouraged”.

The SHEEILA says in its Sustainability Assessment for AL/CA1 “Air quality is given a mixed score. There is a high risk to deterioration of local air quality.” It is biased to give this anything other than a strongly negative score. How is destroying 600 acres of woodland and farmland and replacing it with a new commuter town right on the fringe of urban Tonbridge and close to Tunbridge Wells going to do anything but harm to the already challenged air quality of the borough? How can this development be “air quality neutral or better”? What actual assessment has been done to assess the impact that AL/CA1 and AL/CA2 will have on both TW and Tonbridge? Bringing 2800 commuters into the area CANNOT do anything but degrade air quality for your existing population be it TW or Tonbridge: the borough boundary is irrelevant here – Tonbridge people’s health and wellbeing WILL be affected negatively by TW actions as well as those of us lucky enough to live in a rural area of Capel with as of now, decent air quality.

Flooding

Others more expert than me will I’m sure comment on the flood risks both for existing residents of both TWBC and TMBC areas relating to the Medway flood plain.

But I would also like to add the issue of surface water. Despite living on a hill and some 30m above the Medway we have been very close to flooding in the past due to groundwater running across the farmland behind Somerhill Schools. This then floods down the road to Park Farm and across the B2017 causing regular flooding. See Figure 1 attached from 24/09/19 showing a typical local flood blocking the road following normal rain. The surface water flood risk from https://flood-warning-information.service.gov.uk/long-term-flood-risk/map for the area is also shown in Figure 2 attached with many sources of floodwater affecting both the B2017 and the whole AL/CA1 site on which 2800 houses will be built.

The effects of this coupled with that of Stonegate gravel pit proposals by the Medway must be mitigated in any plans. STR/CA1 notes “Falls outside of the areas of flood risk as ascertained through the Council's strategic flood risk assessment work. However, it is considered appropriate to ensure that any development on the site does not adversely contribute to flooding elsewhere in the vicinity, and that as part of the wider delivery the development reduces the flood risk to particular existing residential areas in Five Oak Green”. No flood risk assessment has been conducted to actually define what risks are and what mitigation actions will be required and costed into STR/CA1 given accelerating climate change.

Contaminated Land

The Draft Local Plan states “Any land contaminated with hazardous or toxic materials is potentially a serious cause of pollution, as well as a threat to human health; it can also migrate into watercourses, impacting not only on water quality, but also biodiversity. Contamination can derive from previous uses, such as industrial processes involving chemicals, intensive agriculture, or closed waste disposal sites where landfill gas and leachate are still present.”

I understand there is a historic landfill site in Whetsted which lies on Level 3 flood plain. Surely any additional flood risk from any of the proposed developments to CA1 or Stonegate Gravel provides additional risk of leachate contamination from the land fill to local residents and to the aquifers in that area and beyond? There does not appear to be a single mention of this in the Local Plan – why not?

Historic Buildings, AONB, Historic Parks and Gardens

For a tiny village/hamlet, Tudeley contains an unusual density of protected elements (AONB, Somerhill House and Somerhill Park, All Saints Church Tudeley etc). Surely large scale development directly adjacent to a designated building or area of land will have a significant impact on it? The proposed developments AL/CA1 and AL/CA2 fundamentally ignores this whilst stating proximity to Listed Buildings or AONB as a reason to reject other sites – this is very biased and inconsistent.

I would like to draw attention to the world renowned All Saints Church in particular. With reference to Wikipedia “The sandstone footings of the nave and tower may date from before the Norman conquest, and the church is listed in the Domesday Book under the village's alternative name of Tivedale. In 1293 the church was given to Tonbridge Priory.[4] The majority of the existing structure was created in the later medieval period, during the 13th and 14th centuries”.

Please see https://www.tudeley.org/chagallwindowpreservationtrust.htm where you will find the following.

THE CHAGALL WINDOWS PRESERVATION TRUST

A message from the Chairman, Chloe Teacher: "Dear Friend

I think the stained glass at All Saints' Tudeley is one of the artistic wonders of the world and it fills me with immense pride that my parents were responsible for bringing Marc Chagall to this holy place.

It doesn't matter whether the sun is shining or not- although, of course, the quality of the light is important

- to witness Chagall's work is to experience profound spirituality irrespective of any particular religious beliefs.”

I find it sad and wish to object in the strongest terms to the building of 2800 houses literally 40m (see Figure 3) from the windows of this church listed in the Domesday Book. AL/CA1 will of course affect the quality of light to which Lady Teacher refers! The fact that the Chairman’s son is selling all the 600 acres of Green Belt land to enable the development is beyond irony.

Deliverability and Viability

As a tax payer to TWBC I would like my money spent wisely and see the benefit of having a Local Plan. Amongst many other things, ability to deliver a Local Plan is key. I can obviously see the benefit of a single land owner for AL/CA1 and AL/CA2 for TWBC.

However it appears this single fact has clouded the whole decision process such that viability risks of STR/CA1 outweigh any theoretical deliverability benefit of one landowner.

In simple terms, the cornerstone of the Local Plan is STR/CA1 and there is no fallback, yet MAJOR areas of the plan are simply missing or have no substance or detail. So our money is being spent progressing a single plan with no idea if it is feasible, deliverable or the economics add up. The site for AL/CA1 in particular is bereft of almost any infrastructure and it has to be questionable if it has sustainable scale for the undefined infrastructure investment required. Major omissions include:

Lack of (literally miles of) new road infrastructure plan to either Colts Hill or Paddock Wood through Green Belt and/or AONB
Lack of road infrastructure plan to cross/bridge the railway in AL/CA1 and make permeable
Lack of foot infrastructure plan to cross/bridge the railway in AL/CA1 and make the new village permeable
Lack of road infrastructure plan to access north side or cross/bridge the railway in AL/CA2
Lack of foot infrastructure plan to cross/bridge the railway in AL/CA2
Lack of flood mitigation plans – flood plain and surface water
Lack of plan for gas, water, sewage utilities to AL/CA1
Lack of a plan for “Undergrounding” of overhead power cables
Lack of a plan from neighbouring TMBC on how to create infrastructure (roads, parking, services) for the commuters who will use Tonbridge as the natural local town and commuting station and release the bottleneck from improvement proposed to the

Other aspects of economic viability include:

The need for significant quantities (TBD at Reg 19) of affordable housing yet the strategy is anything but with significant cost drivers including:
- “High quality, distinctive homes….Layout and design is to be of the highest quality, with exceptional permeability”
- HQM Level 4
- A very low proposed density of housing (15-30 units/ha).

It is hard to imagine how this all adds up with the massive infrastructure investment (undefined as my previous point) for transport access and utilities. A natural outcome may well be that the development as proposed is NOT viable and with no other alternative at that point, the “solution” needs to be larger requiring MORE Green Belt or AONB release. In other words, stealth planning for larger developments.

Bias in SHELAA

It appears to me that the reason there are not alternatives proposed is that the same planning parameters have been applied inconsistently to different options. This suggests bias or incompetence. Tudeley has had a special and inconsistent set of criteria applied: why? Is it due to pressure of the dominant Hadlow land owner?

To take one case in point below – there are many examples like this. I have highlighted some key comparisons.

Capel Parish has a total population of approx 2,467 but Tudeley itself is only a few hundred people in a distinct separate settlement. Tudeley site AL/CA1 is 100% on Green Belt or AONB and has listed buildings within the site and has higher grade (ALC 2) farmland. AL/CA1 is put forward as a suitable development – a disproportionate development of 2800 houses dwarfing the existing village of a few hundred.

Capel: Site reference: 448 (Local Plan Allocation AL/CA1) Gross area (ha): 157.47 Developable area (ha):148.62

Potential site use: Site has been submitted as a potential new settlement. It would be a mixed use scheme including residential use. Potential yield if residential: 2,500-2,800 (4,4459 @ 30 dpha, 2,229 @ 15dpha)

Issues to consider:

Green Belt considerations; AONB (2 component parts);

Ecological interest; notable feature/designation; SFRA Flood Zones 2 and 3;

Heritage matters (listed buildings on and adjacent to the site);

Land contamination (sewage treatment works, cemetery (Modern), railway land (tracks));

Highway matters; Infrastructure;

ALC: Grade 2, Grade 3 Cross boundary issues

Capel Conclusion: The site has been submitted as a potential new ettlement

Horsmonden has a total population of approx 2,435 and is not in the Green Belt nor does it have listed building on the site 144 below and is ALC farmland. However, Horsmonden 144 is considered unsuitable as a potential site allocation with 600-1200 houses because “this would be a very large scale strategic allocation that would be disproportionate to the size of the settlement, with concern about landscape and heritage”.

Horsmonden: Site ref: 144

Gross area (ha): 51.78 Developable area (ha): 41.44

Site has been assessed for development potential, notably for mixed use including residential

Potential yield if residential: 622 - 1,243 Issues to consider:

Adjacent to AONB (2 component parts); Ecological interest; notable feature/designation; Landscape Sensitivity Study (HO1 and MB4); Highway matters;

Heritage matters (adjacent to listed buildings / Hop Pickers Railway Line); EA Flood Zones 2 and 3;

Land contamination (landfill site, repairs and sales of motor vehicles, Unknown Filled Ground (medium), Railway Land);

ALC: Grade 3

Horsmonden Conclusion: This site is considered unsuitable as a potential site allocation. Reason: This would be a very large scale strategic allocation that would be disproportionate to the size of the settlement, with concern about landscape and heritage.

Farming and Food Production

A large percentage of AL/CA1 Green Belt is in fact farmland graded from ALC 2 “Very Good Quality” to ALC 3 “Good”. Local food production is a critical part of managing the global sustainability crisis and destroying it for housing needs rather than using lower grade or non-farming land elsewhere is the wrong decision.

Doctors Surgeries

The quality of GP health provision has, based on personal experience, declined significantly in the past 25 years with overstressed and under-resourced GP surgeries. STR/CA1 states “Provision shall be made for appropriate health facilities, or contributions towards such facilities” but until a commitment to this from a suitable organisation is in place it is only words.

Lopsided and Disproportionate Development

Many references have been made in the press particularly in Tonbridge to TWBC “dumping” their housing needs challenges on the doorstep of Tonbridge and it is hard to come to any other conclusion. The Key Diagram in the Local Plan makes this abundantly clear.

The result is, apart from the impact on Tonbridge, a totally disproportionate development in Capel and particularly in Tudeley AL/CA1.

Housing Needs

I am aware that others have challenged if the TWBC housing needs assessment is valid or appropriate and I will not repeat this point.

However, from a practical perspective, it is abundantly clear that the housing requirement does not meet the needs of the local community in any shape or form. Low cost housing IS needed and as mentioned previously, there is nothing in STR/CA1 that explains how this would ever be achieved – in fact quite the opposite. The data may be out of date but for many years Kings Hill was cited as having the highest average household income in the country. The Tudeley development at AL/CA1 will almost certainly mimic this simply because it will be a magnet for London commuters.

Tunbridge Wells borough has plenty of expensive housing for sale. What it needs is low cost housing and STR/CA1 simply does not deliver this by building low density housing in an “exemplar” development on land with no infrastructure and little accessibility.

Technology

The plan makes many references to new technologies and appears to be assuming that widescale social and technological change will occur conveniently to get round many of the known issues with the proposal as it stands.

To base a 20 year plan on the premise that every trend you need to make this work happens at the right time and in the way you imagine/forecast is clearly ludicrous. To make provision for changing habits/scenarios is of course wise, but to base the Local Plan on specific changes is in my opinion naïve and foolhardy in the extreme. And to use it to justify Exceptional Circumstances for large scale release of Green Belt is immoral.

Local Plan Process

I have appreciated the recent efforts by Mr Steven Baughen to personally get out to meet Capel residents and discuss the Local Plan. However, this does not disguise the fact that the plan preparation process didn’t include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan didn’t go through most of the plan preparation process and therefore, to provide either the residents of Capel or the residents of Tonbridge adequate time to become aware of the huge implications of the Local Plan for them. It feels as if this has been kept “under the radar” as long as possible due to the controversial nature of the core of the Local Plan. If for no other reason, the Local Plan should not progress with STR/CA1 as its centrepiece – it has NOT had fair review nor has it been developed enough for anyone to make any real assessment of its viability. The inherent risks in this approach must make the Local Plan unsound.

DLP_5786

Susan Brock

My name is Susan Brock and I grew up in Tudeley many years ago. In recent years my parents were buried at All Saints, Tudeley, alongside my 2 week-old brother who died in the 1960s.

Any development would interfere with the sacred ground, and would compromise the important heritage site that it is.

In my view it would be a disastrous move to interfere with the sanctity of a Cemetery. The peaceful resting place of my parents would be disturbed.

Specifically, I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1 &CA2).

Creating a garden settlement at Tudeley of 2,800 dwellings will cause immense harm to residents of the Parish of Capel and to residents of Tonbridge. There will be a significant increase in traffic in to Tonbridge from the B2017. People living in and visiting Tudeley will use Tonbridge Station for commuting and Tonbridge will need more parking. The increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times and can’t be made wider in most places. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable. Parking in and around Tonbridge Station will be even more difficult. Network Rail have confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. Most people living in the new garden settlements will drive privately owned cars, despite initiatives to encourage bus and bicycle use.

Disastrous for the environment.

Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding. There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape. Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saint’s Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. That will cause great harm to its value as a heritage asset of world renown due to the complete set of Marc Chagall windows.

DLP_5798

Mrs J Macdonald

I am a long time resident of the TMBC area and am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

I have lived initially in Hadlow and now, for many years in East Peckham and am absolutely opposed to this Local Plan. I find it unbelievable that such a development, as is proposed, could even have been seriously contemplated.

I would summarise my objections as follows:

Such a development does not address the national problem ie. the need for affordable homes not on greenfield sites, such as these at Capel and Tudeley. The increase in traffic over the past decade is caused by just this sort of development that necessitates every household requiring at least one vehicle simply to function. Building should be confined to town centres.
Creating so much housing in Capel Parish will require the destruction of woodland, hedgerows, meadows, and farmland that will never be replaced. It amounts to an irresponsible and wanton destruction of the countryside in favour of tarmac and concrete. Small animals, birds and insect life, all essential for our planet and well-being, none of whom have a voice to object, are being sacrificed to this reckless urbanisation. Once their habitat is destroyed they have nowhere else to go.
How clever of TWBC to welcome a housing development in Tonbridge & Malling. It will not have escaped their notice that, whilst all the council taxes and business taxes would be collected by TWBC, all the inconvenience, pollution and traffic, will be suffered by Tonbridge, and all the services - transport, schools, doctors and general health and social care will need to be provided here in Tonbridge.
And where will all these extra commuters park their cars?
Flooding in the area is bound to become a problem, once concrete and tarmac have replaced low lying, open countryside

TWBC is using Capel to dump their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the borough on brownfield sites or placing the development in the middle of the borough where it should be. The proposed developments in Tudeley and East Capel are unsustainable and place enormous and unfair pressure on Tonbridge.

I would summarise my solution to the affordable housing need as follows:

Confine house-building to brownfield sites which are plentiful within TWBC.
Require / Encourage freeholders of shops and business properties to convert their properties for homes. Cars would not be essential, services would be within walking distance and the dying town centre that is Tunbridge Wells would be revived. Incentives could be offered.
Owners of brownfield sites should also be either compelled or incentivised to get on and allow house-building of small, affordable homes.

DLP_5842

Sandra de Wet

I am a resident of Postern Lane and live in the Borough of Tunbridge Wells.

I am writing to object to the inclusion of Sites 454 and 447 as development land in TWBC draft Local Plan to 2036 Policy STR/CA1 and Policy AL/CA2

Green Belt

The proposed secondary school planned for sites 454 and 447 is on the border of Tonbridge and Tunbridge Wells. The law specifically requires Green Belt between boroughs to prevent urban sprawl and merging of boroughs. The A26 functions acts as a barrier, preventing Tonbridge from encroaching into Green Belt. Building on sites 454 and 447 would be in contravention of national planning policy. Both of these sites adjoin Postern Lane and are both designated Green Belt sites and as such should be protected from harm. The soil on the two sites tested as Grade 2 category which is prime agricultural land and is rare in the Borough. As such this land should be left as productive agricultural land.

Somerville Park and Gardens view over the Low Weald would be destroyed and be replaced by urban sprawl making Postern Lane the eastern boundary of Tonbridge

Environmental Concerns

Alders Wood, the ancient wood on Site 447, is home to a variety of large and small wildlife. By fencing the wood, although it would stop the children from destroying the woodland it would also stop the movement of animals and reduce biodiversity. Light, noise and litter pollution would be detrimental to the local fauna and flora and I’m sure that teenagers would not be happy to be part of a school that is contributing to the destruction of a valuable asset of ancient woodland and its ecosystem.

We are only just starting to understand the function of mushrooms and their complex system of hyphae which are mutually beneficial to plants, trees and habitats. A building would destroy the root-like threads that make up mats of mycelium and without this it will result in the ancient woodland slowly dying over time. The root system stretches far beyond the visible evidence of mushrooms above ground.

Most of site 454 and some of site 447 is within the Flood Zone 3 as defined by the environmental agency. Buildings, hard standing and artificial playing fields on these sites will affect the water table which would not only increase the risk of flooding on nearby farmland, properties and Tonbridge but could potentially decimate the nearby orchards.

The planners state that buildings would not be constructed on high flood risk land which would result in the removal of a large portion of the proposed sites 447 and 454 from potential development. The sites both are on a gradient and would need landscaping to accommodate building and playing fields which would affect flood lines and the surrounding area.

There is a natural spring near the oak tree on site 454 which would have consequences for the sport fields proposed for this site.

Artificial playing surfaces proposed by the planners for the playing fields will not solve the problem of flooding. The artificial fields in addition to causing earthworm mortality will be under water. The rubber chips on the artificial sports fields will be washed into the river and end up as micro plastics in our water supply, rivers and seas.

Traffic

South Tonbridge already has one of the highest concentrations of secondary schools for a town of its size in the whole of the UK. This increases pressure on local road, bus and rail networks and as a result Tonbridge and the surrounding areas are often subject to congestion and gridlock.

The site is isolated from the proposed new housing development creating additional vehicle traffic. The increased traffic will add to current levels of pollution and bring Tonbridge to a standstill due to the traffic gridlock caused by the increase of cars on the road.

The proposed site 447 is a corner site with an A road (A26) and a B road (B2017) which join onto a roundabout that is already unable to take the strain of the current traffic flow in peak times. The increased pollution levels from the additional cars and buses will be harmful to children’s developing lungs and the noise level will not be conducive to an optimal learning environment. If the development were to go ahead, part of the land would have to be used to improve the road infrastructure thereby reducing the size of the school site and making it even less feasible. In addition to the school buildings, much of the land would have to be tarred to provide parking for teachers, parents and students. Any entrance or exit onto the B2017 would be very dangerous as it is a twisting road with blind rises and sharp bends where there is a speed limit of 50 miles per hour despite the large primary school at Somerhill. If the speed limit is not reduced for primary school children then surely it won’t be reduced for secondary school pupils either.

Pollution Concerns

Footpaths crossing the railway line near Sites 454 and 447 make it necessary by law for the train to signal loudly as a warning to pedestrians. This results in regular loud intermittent noise disturbance, which is not conducive to a good learning environment.

There will be an increase of noise pollution due to the children’s chatter and classroom bells which will be detrimental to the surrounding green belt which is rich in animal and bird life and would make the peace and tranquility of the long established footpath a thing of the past.

There will undoubtedly be an increase in litter. Currently residents who live along the lane are responsible to maintain the lane. If the development goes ahead who will accept responsibility to clear the litter from the lane?

Health and Safety Concerns

The school site is not within walking distance of any train station and even if there were to be a footpath and cycle path along the B2017, there are many unanswered questions about the route it should take through Tonbridge. Crossing the A26 or the B2017 by foot or bicycle would be incredibly dangerous and put school children’s lives at risk.

The school would be bisected by a railway line and would pose serious safety risks to young teenagers who could either by accident or with intent suffer serious injury or possibly death. The cost of making the site safe including the increased insurance risks and providing acceptable bridge crossings would be significant and not in the interest of TWBC residents and definitely not in the interest of the children attending the school. The current Postern Lane Bridge is showing signs of wear and tear and as a single lane has weight and width restrictions. There is a public right of way over the bridge for use as a footpath (not for vehicles) and the bridge has two blind corners and is unsuitable for regular heavy traffic.

The police and Network Rail have been called out to incidents where teenagers have thrown objects onto the tracks and also at the trains from the Postern Bridge and this is an unreasonable risk to train drivers and passengers. Siting a school on the lane, forcing children to cross the bridge on a daily basis would be an unreasonable risk for all concerned.

Most of Postern Lane has the North Sea gas pipeline running along it and as a consequence has a helicopter checking the line several times a week to ensure the integrity and safety of the line. This would be yet another noise disturbance for children attending school which is not conducive to a good learning environment.

Network Rail

The proposed site is bisected by the Tonbridge to Ashford trainline. On the western side of the two sites (nearest the A26 bridge) the railway track is at ground level. Further along towards the eastern side of the two sites the tracks are in a deep ravine. The noise generated by the train on the tracks would not be conducive to a good learning environment and would definitely disturb sports games. There is a single track railway bridge crossing the railway line on Postern Lane which is owned by Network Rail. They require 24/7 access to the lane and the bridge. Network Rail have a junction box located within site 454 about a third of the way into the site. This land “wedge” will need fencing off for safety reasons and thereby reducing the size and suitability of site 454.

Postern Lane

At the entrance to Postern Lane on the B2017 there is a lay-by for vehicles. This lay-by will undoubtedly become a casual parking area during peak times restricting use of the lay-by for the purpose that it is intended.

Postern Lane is a private single track lane bounded by indigenous hedges and ancient hedgerow with few passing places. Much of Postern Lane is also a public footpath. The surrounding farms use the lane to transport apples and there is only one small speed hump between the Little Postern residence and the B2017 so that fruit will not be unnecessarily bruised in transit. Additional traffic calming measures cannot be introduced onto the lane for this reason.

The school backs onto a private single farm lane that is also a public footpath. This is an important resource for residents and visitors who wish to enjoy the Kent countryside. A school on part of the path would detract from the calmness and tranquility which currently supports good mental health and physical fitness for residents and visitors. A secondary school on the site with increased noise levels would deter the public from utilising this footpath.

The farm fields backing site 454 are regularly sprayed with fertiliser and pesticides and would affect young developing teenagers. This would be an unacceptable risk to children’s health.

Sites 454 and 447 are surrounded by hedges that are a haven for insects, birds and wildlife. To make the school safe fences would need to be erected and this would decimate miles of hedges and consequently the wildlife and their ecosystem. The trees and hedges on the proposed properties currently help offset carbon emissions and help to reduce noise levels currently produced by the adjacent B and A roads.

There are phone lines crossing site 454 making it unsuitable for playing fields.

Postern Lane abounds with listed building and the impact on 9 heritage sites would be adverse and irreversible.

The fruit Tennant has thousands of apple trees near the school and I wonder if the school would be insured to compensate them for the lost fruit scrumped by hundreds of passing school children every day?

For TWBC and KCC to knowingly build a school with all of the above risks would be incredibly foolhardy and totally inadvisable.

DLP_5879

Annabel de Vrij

I am writing to register my utter dismay at the proposed development of a garden village at Tudeley of up to 2800 homes. Tudeley has been my home and my place of work for nearly 50 years.

Why on earth is it good planning to plonk 2800 new families and residents in a small community? In my view it is a totally inappropriate location for such a large expansion for a significant number of reasons which I outline below.

Tudeley is a tiny hamlet, of around 50 houses. You propose to increase it by 2800 houses, yet in your paper “The distribution of development topic paper” you justify not siting this garden village in Horsemonden by saying “This would be a very large scale strategic allocation that would be disproportionate to the size of the settlement, with concern about landscape and heritage”. Surely this argument is doubly true for Tudeley, a smaller village, recorded since doomsday, with the culturally significant St Marks church and its windows.

You propose to place 27% on your borough’s new housing in just 2% of the borough’s area. These figures illustrate that majority of people coming here will have no community or families ties, and the current community will be swamped, if not drowned, their ability to welcome new members exceeded. This is not a way to plan for a happy and harmonious future, but leads to potential ghettoization, which is regrettable to all.

This enlargement of Tudeley would bring harm to the amenities of neighbouring occupiers, including substantial loss of privacy, as well as a great deal of inconvenience through out the long duration of construction, particularly as already the roads are significantly congested. Furthermore the facilities and amenities for new residence are utterly insufficient, and it appears this plan relies on palming off responsibility on the nearest local town, which is Tonbridge, and not your borough. GP Surgeries in Tonbridge are already full. The costs and planning for new medical facilities are inordinate and it seems extremely unlikely that one could be up and running in manner timely to this development plan. Similar issues arise with public transport such as rail and bus, as well as roads full to capacity. Your placement of a school, in an area already congested, with a provision of multiple schools near by seems poorly thought out.

Ultimately finances will dictate as to whether people will want to live there. If it takes you 30 mins to drive through congestion from Tudeley to Tonbridge, to park at an exorbitant car park, to buy a ticket to stand all the way to London, you might as well live further down the line. If you can afford the home but there are no buses, shops, community facilities available to you, why choose to live there?

This area is one I know extremely well, having walked and ridden my horse round most of it. As I child I played in the streams, and stomped through the fields. Water here is a real issue. The water table is only just below the surface in many places, there are numerous unrecorded springs. The affects of building on this wet land will have ramifications on the flooding pattern of the Medway. It is my fear that these proposed new houses may flood, and there will be increase flooding to existing houses in Tudeley and nearby villages. These houses will become uninsurable and thus unmortgageable, so your building plan is well on the way to creating ghost towns.

Finally this loss of green belt is inexcusable when there are brown field sites available. They may not have the convenience of one single landowner with whom to negotiate, but please tell me where are the “exceptional circumstances” that allow the release of this green belt when brown field sites are available? Yes your documentation states it is “only 5%” of the total green belt in the borough, but it concentrated in a very small area. This loss of farm land, hedgerow, copse and wild life is irreplaceable and not an acceptable cost of your development plan.

DLP_5890

Tracy Chapman

I live in Taylor Close, Deakin Leas, Tonbridge

I have lived in Tonbridge for 6+ years having lived in Tunbridge Wells prior to that.

I strongly object to the proposals STR/CA1, STR/CA2 & STR/PW1. Please see my reasons for objecting these proposals below.

In those 6 years I have noticed the remarkable increase in the number of people and cars, noise and traffic pollution, demand on infrastructure and amenities.

This has been attributed to the fact that several residential projects have been completed since 2013, including the flats adjacent to Waitrose and the large site at Somerhill Green. The completion of the A21 bypass including longfield Road roundabout, has also meant a noticeable difference to the amount of traffic using that stretch of the A21, and the traffic entering Tonbridge along Pembury Road from the Vauxhall roundabout down into Tonbridge.

It is more sensible, astute and acceptable to build small developments in areas where there is already a derelict building or derelict land, but this proposal STR/CA1 is on a totally outrageous level and will mean that green belt land will be destroyed unneccessarily forever with very detrimental effects on the environment and the residents of Tonbridge. How can this possibly be a good idea or an acceptable solution?

It quite simply will be disastrous for the everyday lives of people living in Tonbridge. Whilst it is healthy to keep the High Street and the community alive, it will have an adverse affect on Tonbridge if CA1 goes ahead. To build this number of houses is basically creating another small town which will depend on Tonbridge for everything. Tudeley village life will be swallowed up along with its history and its beauty.

The traffic will be ridiculous at this end of Tonbridge. It already is during school times and rush hour. The whole structure will grind to a halt. This in turn will impact on air pollution, noise pollution, quality of life, and will have a very negative affect on the access to the High Street and shops. The parking will be difficult and impossible at times. The train service from Tonbridge is already at "breaking point" and this plan does not include any future plans for a new station, despite the train line running through the centre of both CA2 and CA1

The proposed senior school site AL/CA2 is just as ridiculous, but dangerous too, for obvious reasons. It will be on an already very busy roundabout which will directly impact on traffic and the safety of both road users and school children. The train line running through the school will surely lend itself to some undesirable and unsafe situations. The impact of the school will also add to the issues of already overloaded public transport and road use.

I could list many other reasons that these proposals are not sustainable and are very shortsighted. They are not a long term answer to needing more houses!

These include demand on water supply, sewage waste, the affect on nature and the environment in destroying green belt land, demand on schools, medical and dental practitioners, Pembury hospital, on the well being of the present residents who live in Tonbridge. This is not a complete list.

The proposals are unsustainable and very shortsighted. The Tonbridge infrastructure is already fragile and these proposals will break it irreversibly.

The irony is that these are TWBC proposals but it will be Tonbridge and the surrounding villages that will be affected. Tunbridge Wells should look to build some houses near to it's centre on several sites so that it encourages the High Street to become a vibrant and healthy centre. The old cinema site is one that comes to mind.... this is a shameful eye sore in the centre of the town and it is an absolute disgrace that this site has been derelict for so many years!

DLP_5909

Mr Andrew Stanley

I am writing to object in the strongest terms to parts of the Tunbridge Wells Borough plan and with particular reference to “The Strategy for Capel Parish” I believe this to be covered by Policy STR/CA1 and Policy STR/PW1.

I live on the boundary of Paddock Wood and Capel and was brought up in Five Oak Green. Members of my family continue to live in Five Oak Green. I enjoy the countryside and regularly walk the footpaths and fields of Capel (both east and west).

I have seen many references by the Council regarding public consultation. The people of Capel became aware of this undemocratic and unfair plan on 20 May 2019; the rest of the borough subsequent to that date. At every meeting I have attended since, the Council or its officers have said that it is not “a done deal”. When I attended the TWBC’s Planning and Transport Cabinet Advisory Board’s meeting on 5th August 2019 the TWBC Leader (and Chair of the Planning Policy Working Group) opened by saying how much time and money had been spent on the project. Now, where have I heard that before!

By whatever means this plan was arrived at, it is as damaging and inappropriate as it could possibly be. I understood that greenbelt land was so designated to stop exactly what is being proposed in this plan and only “exceptional circumstances” might allow that restriction to be circumvented or breached. There is little or no evidence in this plan that such is the case.

In priority to considering greenbelt land there is approximately 25% of the borough that is either brownfield or non-green belt. The Council has not identified or allocated all brownfield sites (contrary to Government guidance). It has found reasons not to prioritise non greenbelt land.

Capel is a rural parish and that is why most people live there. If they wanted to live in an urban environment, they would live in one. To plan for an area with 2% of the Borough’s population to take 40% of the new housing (that rises to around 65% if you consider adjacent Paddock Wood) isn’t planning at all. Just imagine if that had been proposed for Bidborough, Goudhurst, Sandhurst et al!

The plan will mean virtually unrestricted development from well to the east of Paddock Wood through to the new proposed school at Somerhill (Policy AL/CA 2) on the fringes of Tonbridge. It will also require a huge upgrading in transport infrastructure (roads) including re-routing the A228 through an AONB and then a spur further bisecting Capel to join to Tudeley New Town. Capel will be destroyed by this plan. The cost of the roads and their future maintenance will be enormous.

With roads being the greatest expense in infrastructure terms it is clear that the A21 corridor and Knights Park/Longfield Road or Mabledon offer far better alternatives with immediate and easy access to the A21. It would also lead to householders using a range of rail stations. I am sure Capel understands that it should provide a small amount of additional housing in line with other rural parishes but that could be accommodated by infill within Five Oak Green without too much devastation.

The plan has all the hallmarks of 3 major landowners offering up their land and the Council taking the easy option (as alluded to re Hadlow Estates at the meeting in Five Oak Green Village Hall on 20 May 2019 by the Planning Officer). It should be the responsibility of TWBC to do the right thing rather than the easiest. Offers by landowners along and adjacent to the A21 and elsewhere were not taken forward!?

At the western boundary of Capel, the proposed new town (Policy AL/CA1) is on greenbelt land which separates Tonbridge and Capel. The amount of traffic movement resulting from this proposal will be unsustainable; people will not start cycling and walking despite initiatives/fanciful claims. The B2017 is already congested at peak times and that will only get worse. I don’t know whether residents of Golden Green, Hadlow and Tonbridge appreciate how this plan will impact on them but many other minor roads will become blocked with cars trying to find alternative routes. Tonbridge rail station will be inundated as the effects of developments from Ashford to Tonbridge take effect with no new stations possible or, more importantly, very little additional capacity available with London stations already at or near capacity.

Hartlake Road which is on the western boundary of the proposed development is subject to regular flooding as is land to the east of that road. Much of the land here and in East Capel (Policy AL/CA3) is in a flood plain and no amount of mitigation measures and “betterment” will resolve that. I consider that little or no account has been taken of the severe weather implications of global warming/climate change. Where severe weather events were one in a hundred years they are occurring once in ten years; that position will deteriorate further and is not planned for in this proposal. The large parts of Capel in known flooding areas is a major reason why no development has taken place before. It is difficult to understand how covering the land in concrete is going to help this floodplain.

As this plan is progressed, we know that house numbers are based on the standard method of calculation and on 2014 projections. Subsequent calculations show that this is a significant over-estimate of the number of homes required in the borough; just adding to the injustice and lack of need. I would consider that this is something TWBC would have made representations to Government long before we got to Regulation 19 and particularly with the high level of AONB and greenbelt in the borough.

Throughout this entire plan I note repeated references to masterplanning/constructive masterplanning/strategic masterplanning. In my view there is nothing that such planning (whatever that means in practice) can do with a plan that is ill conceived. I am surprised that with such masterplanning at the forefront, the Planning Officer has advised that there is no back-up plan! So, does that mean entirely starting again? That does not suggest the Council is prepared to listen to any significant extent. All organisations have back-up plans on major projects and often more than one.

The Council has declined to make representations to government regarding a lower housing number and advises of the dire outcomes of not planning for the proposed number or offering any plan at all. There is little evidence of government sanctioning local authorities where representations are made. I can’t imagine that a government-imposed plan could be more destructive for Capel than what is proposed here.

I strongly object to the land in East Capel being included in “The Strategy for Paddock Wood” (Policy STR/PW1 and Policy AL/CA3)

Many of the comments above relating to Policy STR/CA1 apply here. I note the Council’s attempt to blend Capel into Paddock Wood despite boundaries and the separate identity of Capel.

The land designated for development is on a flood plain. It floods regularly to my knowledge as I frequently walk the area. Any attempt to deal with this issue by mitigation and “betterment” do not take account of global warming/climate change or its use as a flood plain to stop flooding elsewhere.

All of the land is designated greenbelt and is grade 2 or 3 agricultural land which will be lost at a time when the country only provides 50% of its own food requirements. A range of crops have been produced on the land over the past 50 years.

It is also important to note that the large area of planned development will result in Paddock Wood being entirely joined to Five Oak Green (Capel) as a built-up area. The Council’s own review rejects fields to the west of the A228 (ID CA16 part of CA02; local plan site ref 308) due to concerns given as “There is concern that allocation of this site would result in coalescence concerns between Capel and Paddock Wood. It is also part of a larger Green Belt parcel the release of which would cause very high harm”.

The Council can conclude that the above field of 14 acres would cause problems with “coalescence” between Paddock Wood and Five Oak Green (Capel) at the same time as planning to build on adjacent fields east of the A228 (ie over the road) (ID CA17 part of CA01; local site plan 309) and (ID CA7 part of CA01; local site plan 142; AL/PW1). These latter 2 sites are 22 and 112 acres respectively in size; are greenbelt; have some AONB land; are flood zone 2; have noise issues; pose a high risk to deterioration of local air quality; contains agricultural land and have cross boundary and highways issues but are deemed suitable and form a substantial part of the Local Plan for East Capel. It is an amazing piece of logic where the desired outcome has ignored the Council’s own evidence!

It is also worthy of mention that the massive housebuilding on the above 2 sites will create considerable traffic and parking problems in Paddock Wood (just yards from the development) and will cause unresolvable problems at Paddock Wood rail station where peak time trains are already at capacity. This plan doesn’t even include over 700 of the houses with planning permission already given in Paddock Wood.

Finally, I wonder how the medical services will cope with this localised onslaught? I am Chairman of the local Patients Participation Group. There are significant issues with finding GPs in Paddock Wood and Capel; appointments are harder to get and the local hospital is already over-stretched. The Planning Officer advised that this isn’t within the planning remit – it needs to be within someone’s! Another matter that could perhaps be referred upward with regard to a reasonable planning level.

Conclusion

Although there is a great deal more of concern, I feel the above at least provides a starting point to raise concerns about this plan.

The Planning Officer advised at one meeting that Councillors will be able to consider options but also says there is no other plan!

TWBC's Issues & Options Consultation report in 2017 recommended spreading new housing across the borough with alternative garden village sites outside of the green belt identified augmented by areas along the A21. More suitable alternatives appear to have been discarded.

3 acquiescent large landowners appear to be a better option.

Former Prime Minister David Cameron and Chancellor of the Exchequer George Osborne wrote: “We will always protect the green belt and make sure planning decisions are made by local people.” (David Cameron and George Osborne, The Times, here’s how to build a homeowning Britain, 4 July 2015). So, promises don’t even last 4 years!

DLP_5926

Sarah Chilvers

I have lived along with my family in the area for my entire life and have seen at first hand the dramatic changes and the effects this has had on our local community.

This very unique network of small rural hamlets and villages have evolved and developed around the farming community. From my childhood of growing up being surrounded by hop fields and orchards over the last decade have seen the removal of the hop fields an orchards to be replaced with Quarries, Solar Farms and now potentially 4,000 new homes. The creeping ‘Urban Sprawl’ is becoming more and more evident by the day, destroying the unique character and community spirit many of the surrounding villages have always enjoyed.

To surrender 1000’s of acres of productive agricultural land in the centre of Kent’s Green Belt, bordering High Weald AONB does not make any sense at all, especially as we depend on crops produced both locally and nationally. We have a number of extremely successful fruit farmers within the area, with Moat Farm being one of the largest fruit farms in Kent.

To replace these vital parcels of Green Belt with further quarries and houses would severely compromise this very important industry which supports our local economy as well as contributing to the conservation of the vibrant biodiversity within the area.

Upon reading the evidence or lack of it ...within the Draft Local Plan and reading the NPPF polices and guidance on Green Belt I can not see any justification that supports the “ Special Circumstances” that the Council justifies .

Creating a garden settlement at Tudeley of 2,800 dwellings will cause immense harm to residents of the Parish of Capel and to residents of Golden Green and Tonbridge. There will be a significant increase in traffic in to Tonbridge from the B2017,Hartlake Road, Three Elm Lane and the A26 exacerbating the extreme traffic congestion that exists on this road every morning. The already unacceptable levels of traffic between 7.45am to 9am on Woodgate Way, Vale Road and Pembury Road coincide with the site of a proposed new 6 form entry senior school. This proposed school will be on the border with Tonbridge, split by a main line railway and alongside a heavily used road. This appears to be a terrible site for a school, surrounded by heavy traffic and requiring children to cross a busy train line to access both sides of the site.

The decision by TWBC to build over 60% of its total housing allocation between Paddock Wood and Tonbridge will effectively be the commencement of the disappearance of the villages of Tudeley, Capel, Five Oak Green and the surrounding hamlets as once one development happens more will follow e.g Kings Hill West Malling.

30% of total housing allocation is on the borders of TMBC, which will provide TWBC with all the associated revenues and TMBC with all the costs and liabilities. People living in Tudeley will use Tonbridge Station for commuting and Tonbridge town services will need more parking and public services facilities and budgets will have to be increased substantially, who will maintain and pay for the substantial infrastructure requirement now and the ongoing liabilities, as well as the recruitment of all the additional public services that will be required TWBC ratepayers or TMBC ratepayers?

Large parts of the developments will occur on the Medway floodplain, which is a key natural flood defence for many of the surrounding villages, any removal or partial removal could create further flooding issues in the future , it appears although parts of the proposed CA1 development are situated with EA Flood Zone 3 the Council have not undertaken any flood risk assessment as outlined within the NPPF.

CA1 overlies a significant Aquifer of which is SPZ3, for public water abstraction, this is an important local water supply further development of this area may impact water supply options.

As per the recent correspondence between the Environment Agency and KCC regarding the proposed quarrying extensions the EA have concerns that any further development within this area could have a negative impact upon the Aquifers and have requested a Hydrogeological Risk Assessment to be undertaken, this assessment should extend to CA1 as well, to ensure that the Aquifers are not compromised by further development on CA1.

The Aquifer and natural springs within the site will seriously hinder excavations for building, sewage, drainage as suitable mitigation schemes will have to be implemented to avoid puncturing the natural clay membrane that protects the Aquifer

CA1 is situated within an area where its water resources are already under serious stress, and currently there are a number of issues outstanding with the Environment Agency, KCC and local residents.

The Draft Local Plan has not considered the potential environmental issues around the Hartlake Aquifers and, with rising nitrate and pesticide levels that have already been identified, any penetration to the Aquifers would lead to further significant human health risks.

The draft plan does not identify the neighbouring 2 former landfill sites of which have had millions of tonnes of household, industrial rubbish deposited there in the 1980’s and 1990’s, given the historical issues regarding previous mineral workings, and the major concerns of further pollution to the surrounding aquifers it is very concerning that the Council have not appeared to have considered the potential environmental and health risks prior to submission of CA1 to the Draft Local Plan.

In view of the size and scale of the proposed developments (one of the largest within the plan) and the potential net loss of land, far more information should have been provided within the plan.

No biodiversity assessment has been produced to date, it is very evident that the Council have not collaborated with other local authorities who have development plans within the area as many biodiversity issues have arisen which will have a direct effect to these sites.

The LP should ensure that biodiversity cannot be offset elsewhere, and must demonstrate through a clear application metrics that net biodiversity gain is achieved now, and not some point in time, in the future.

The Government 25 year Environmental Strategy requires net gains for biodiversity this is reflected within the NPPF.

There are many other issues I have but due to time constraints of todays 5 pm deadline i will list them without providing further detail.

No Green Belt Assessment
No Flood Risk Assessment
No Landscape Sensitivity Assessment
No Biodiversity Assessment
No Environmental Assessment
No Transport Assessment
No Heritage Assessment
Questionable Sustainabllity Scores versus other Identified sites.

The initial Draft Plan preparation process did not initially include CA1 and CA2 until the Issues and options Process Stage, therefore many of the processes and procedures that were undertaken with other sites have not been completed.

DLP_5955

Claire Derbyshire

For the past 12 years my husband and I have been fortunate to live in Tudeley. We chose to purchase a Grade II listed building and have invested time and money in it's ongoing maintenance and protection. We were drawn by the setting – within the AONB surrounded by beautiful countryside and assumed since designated Green Belt, the local area would be protected from development. I enjoy walking the local footpaths and for the past 8 years have undertaken voluntary work and species surveys at RSPB Tudeley Woods Reserve. I am also a keen wildlife gardener and constantly amazed by the species we attract to the garden from neighbouring habitats.

I consent to my contact details being added to your consultation database. Please keep me informed of all future Local Plan consultations. I understand that my comments may be published by TWBC.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1) and make the following comments:

1) Loss of MGB

https://www.gov.uk/guidance/national-planning-policy-framework/13-protecting-green-belt-land

National Planning Policy Framework

Protecting Green Belt land

Notably Paragraphs 134 & 143-145

- The Capel Master Plan is contrary to the purpose of the Green Belt:

(a) to check the unrestricted sprawl of large built-up areas;

(b) to prevent neighbouring towns merging into one another;

(d) to preserve the setting and special character of historic towns; and

(e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

- This maps illustrates the potential reduction in separation between Tonbridge, Tudeley, Five Oak Green and Paddock Wood which is wholly unacceptable and impractical on so many levels.

[TWBC: see map1].

2). The Natural Environment

- As Capel currently stands we are blessed with a network of public footpaths which enable access to attractive countryside, wonderful views and the ability to easily walk between settlements. The possibilities to get outside and the health and well-being benefits that bestows, are endless with local highlights being:

Foal Hurst Wood
RSPB Tudeley Woods
Sherenden and Moat Farms
The River Medway
Whetsted Gravel Pits

- The amenity of all of these sites and many of the connecting footpaths have the potential to be harmed by the proposed developments, be it by destruction of views, noise pollution or increased footfall and its associated issues (littering, dog fouling, anti social dog walkers).

Biodiversity

- Capel is rich in biodiversity.

- A historic lack of biodiversity recording as evidenced by inventories supplied by KMBRC of the area (see attachments) does not mean species do not exist! .

- Whilst some species are highly territorial and location loyal, that is not to say they won't be adversely affected by significant changes to neighbouring locations particularly in terms of air, noise and light pollution. From my own experience, the land around Sherenden Farm, which borders the CA1 site, is used for feeding and or breeding by a number of Birds of Conservation Concern - I suspect there are many more besides:

Red List:

Fieldfare
House Sparrow
Lapwing
Linnet
Redwing
Skylark
Song Thrush
Starling
Yellowhammer

Amber List:

Kestrel
Swift

- At present our amphibians, aquatic animals, birds, invertebrates, mammals, reptiles and fauna enjoy a fairly undisturbed existence save for seasonal agricultural operations in some areas and they are free to roam and spread without too many man made barriers. With the exception of the A228 Paddock Wood bypass, they currently do not encounter major roads. If this were to change, it may artificially and detrimentally alter natural behaviour whilst potentially increasing road kill.

Cumulative Effect

The cumulative effect on biodiversity of this level of simultaneous development must not be underestimated - Tudeley Village and Senior School (CA1), East Capel (PW1), Mineral extraction at Whetsted Gravel Pits and the Colts Hill bypass proposal will destroy or disturb vast tracts of habitat. The associated ground disturbance and noise and air pollution on site and construction plant noise/pollution on surrounding roads will surely encourage species displacement. I cite Foal Hurst Wood LNR as a specific example likely to be adversely impacted by East Capel (PW1) and the Colts Hill Bypass.

- When considering development of this scale in a relatively confined area of the borough we can't afford to consider each site in isolation but should employ a holistic view to protection.

- It unjust and short sighted that only species with designated protections are considered during the planning process.

Biodiversity Offsetting

- Just because an agency arrives at a notion for national adoption, doesn't make it a credible idea.

- If you proposed replacing a substantial area of tarmac i.e. a disused airfield, or cleaned up a substantial contaminated brownfield site, then I would agree this would represent a net gain in biodiversity.

- If however you tell me you are going to destroy a large area of Green Belt but mitigate its loss by better managing a TWBC woodland I would call this an insult. The woodland is already a biodiversity resource and if you are currently not managing a precious resource in an optimal way you are failing.

- Biodiversity Offsetting is just smoke and mirrors.

[TWBC: see CA1, Capel East, Whetsted Gravel Pits and Foal Hurst Wood Biodiversity Records].

3) Transportation

Existing Road Management and Anti-social Behaviour

- Is it wise to create/expand roads within Capel and surrounding areas when TWBC and local agencies are obviously stretched to the limit. Whilst proactive in road surface maintenance, this is not true of the roadside verges. Littering is already an issue the length of the B2017 and Hartlake Road etc with residents resorting to litter picking in the absence of council operations. I requested a litter pick along the B2017 from Tudeley to the Somerhill roundabout on 25 September 2019 (FS-Case-145831376), the litter that drew my attention remains.

- Similarly, whether down to lack of will or resources, the Police seem unable to control the late night anti-social driving issues along the B2017, neighbouring lanes and Woodgate Way which is both a source of noise pollution and potential jeopardy for legitimate road users and residents.

- Drivers routinely exceeding the 40 mph speed limit, together with inappropriate HGV use are issues that will be exacerbated by any road expansion and increased population.

- If TWBC and the authorities are unable to address such issues as the population currently stands what chance have they with a significant population increase?

Road Network

- I fail to see how existing roads outside of the development sites will cope with the increased population. Woodgate Way, Vale Road, and Cannon Lane Tonbridge and Pembury Road Tunbridge Wells are already subject to chronic congestion.

- I frequently travel between Tudeley and the B245 (London Road), when Cannon Lane is congested I use the High Street via Medway Wharf Road as the Vale Road/High Street roundabout is increasingly unusable. A significant increase in road users will exacerbate congestion in Tonbridge as the nearest town to 'Tudeley Village'.

- In the 12 years we have lived in Tudeley the increase in local traffic congestion has grown.

Associated road network as yet undefined.

- Expansion of existing roads and/or creation of new roads may further contribute to sprawl.

- I fail to see how the B2017 through Tudeley could be expanded given that dwellings abut the road on either side, the southern portion being AONB.

- We can only surmise new road locations which seems an unsound basis for consultation.

4) Inappropriate Development

Senior School west of Tudeley

- TWBC state 'Tudeley Village' is “a standalone garden settlement” so why will senior school provision be made outside it's boundaries? Similarly, primary school provision may be met by expansion of Capel Primary School, Five Oak Green.

- Both these proposals will have detrimental effects on traffic congestion on the B2017 and A26 Woodgate Way west of Tudeley and on the western extreme of Five Oak Green where school run parking is already chronic and a source of traffic congestion.

6. The school shall be designed to minimise trips to and from it by private vehicle and to facilitate active transport modes, such as walking and cycling from Tudeley Village.

- Regrettably, I think it is a naïve and idealistic expectation in this age of multiple vehicle ownership and heavy use thereof.

5) Inconsistent Approach to Planning

How is it that the following planning application was refused and yet the grounds for refusal equally apply to 'Tudeley Village' CA1 – scandalous!

[TWBC: see Decision Notice 18/01767/FULL].

6) Additional Concerns

- Water supply to development sites – how is an increase in population sustainable when Kent is vulnerable to drought?

- Further negative environmental impact of bringing utilities and drainage to and from development sites.

- Increased potential for flooding with increase in impervious surfaces.

- Reduction in vital food production through loss of valuable agricultural land.

- The negative impact of nearby development on heritage assets and their setting notably the many listed buildings and in particular the unique and renowned Tudeley All Saints Church with its Marc Chagall stained glass windows.

- I understand Pembury Hospital is already struggling to meet demand, how will an increase in population be cared for particularly as 'Tudeley Village' occupancy is aimed at all stages of life so would assume maternity, paediatric and elderly care etc?

- I understand there is controversy as to how the future population / housing requirement figures were arrived at. There is evidence of local properties stagnating on the housing market (ironically I suspect a symptom of the outrageous Local Plan). Rumours abound that such housing schemes attract London overspill rather than address local need. As the uncertain political climate and Brexit unfolds I would expect a review of the proposed figures and against more up to date ONS data than is currently being used.

I implore you to do the right thing for the residents of Capel Parish and beyond.

[TWBC: see also Comment No. DLP_5959 - Policy STR/PW 1].

DLP_5987

Alexander Fisher

I am writing to object to The Strategy for Capel Parish (Policy STR/CA1).

I think that the installation of a garden settlement at Tudeley resulting in 2,800 dwellings will cause immense harm to the residents of the Parish of Capel and to the residents of Tonbridge.

There will be a significant increase in traffic in to Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road every morning. The already unacceptable levels of traffic between 7.45am to 9am on Woodgate Way, Vale Road and Pembury Road coincide with the site of a proposed new 6th form entry senior school to sited next to the Woodgate Way roundabout.

This proposed school will be on the border with Tonbridge, split by a main line railway and alongside a heavily used road. This appears to be a terrible site for a school, surrounded by heavy traffic and requiring children to cross a busy train line to access both sides of the

site. It is extraordinary to consider siting a school on a split site that is so close to already overused roads and opposite the entrance to The Schools at Somerhill. I would have serious concerns at the siting of the school in such a location because of the safety issues and the fact that Tonbridge hosts many schools already, all of them of an high standard.

No amount of infrastructure improvements will assist in reducing the already overflowing roads at peak school times in the morning and afternoon if a further 1000+ pupils are heading to and from the school and Tonbridge town and the B2017 to the east. If a second senior school is to be developed as part of the Local Plan a better and more secure location has to be found. People living in Tudeley will use Tonbridge Station for commuting and Tonbridge services that will need more parking. The increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times and can’t be made wider in most places. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable, especially in view of the plans to build more houses further down the line at Marden, Staplehurst & Headcorn.

Parking in and around Tonbridge Station will be even more difficult.The car parks there close to/at full capacity every weekday. Network Rail has confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period.

Most people living in the new garden settlements will drive privately owned cars, despite initiatives to encourage bus and bicycle use. The costs of infrastructure on the Tonbridge & Malling side of the boundary will have to be carried by Tonbridge & Malling residents whilst Tunbridge Wells will receive council tax from the residents in the new dwellings.

The cost to Tonbridge-based businesses due to traffic issues may drive businesses from the area. There will be an increase in pressure on Tonbridge health services, amenities and car parking as residents from the new garden settlement at Tudeley will use Tonbridge as their local town, not Tunbridge Wells, because Tonbridge is much closer.

It is apparent that the B2017 will not be viable in its current form as it will require expansion if a garden settlement were created. It is already busy at peak times, exacerbated by traffic from Hartlake Road which is becoming a rat-run. People will drive east-west, for commuting and shopping in Tonbridge, not north-south as TWBC appear to think will be the case.

In a transport infrastructure study there is shown a new roundabout at the junction of Hartlake Road and Tudeley Road/Crockhurst Street but there is a lack of any proper detail at present on the transport planning for the Tudeley town development. The plan remains incomplete in this critical aspect and that is unacceptable. This appears to be an apparent breach of garden settlement guidance in terms of infrastructure provision and consultation relating to proposed garden settlements.

Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but I believe that flood risks will increase. Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, Hadlow, East Peckham, Tonbridge, and Yalding.

There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape.

Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saints Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout.

It would be an egregious folly to permit the possibility of an enormous housing estate to be built around All Saints Church with consequential bus lanes, roundabouts and an increased road capacity. That will cause great harm to its value as a heritage asset of world renown, due to the crowning jewel of its Marc Chagall windows which are quite unique. It is one of the most popular Churches in Kent by reference to visitor numbers.

It has been my pleasure to guide visitors around the church – the only church open to the public in the world to have had all its windows completed by Marc Chagall – and I have had enquiries about it from as far afield as Rome and the United States of America. A key part of the church – and the village’s – aesthetic appeal is its rural surroundings, fundamentally unchanged from when it would have been visited by King Charles II when he regularly stayed at Summerhill.

As a serving army officer, I might add that the thought of profoundly altering the setting of any Commonwealth War Grave (as changing its setting from being surrounded by open fields to a modern housing development) is odious in principle and undermines the spirit of the military covenant.

The garden settlement at Tudeley can never be one settlement as it is divided by a railway line that has two very narrow, weak crossings (one on a bridge,one under a bridge). Putting in larger crossings at frequent points across the railway may be possible but it won’t tie the two halves of the settlement together enough to make it one settlement, so it will never satisfy garden settlement principles.

Creating so much housing in Capel 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, including rare species. This area should remain rural with agricultural land that can be used to provide food. The landscape is ancient and Tudeley was listed in the Domesday Book. One thousand years of non-intensively farmed country set in woodland would therefore be lost forever. There appears to be very little thought given to the conservation of the landscape in the area as per the High Weald AONB management principles.

I believe that housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan.

TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant. The Green Belt Strategic Study commissioned by TWBC states that building houses at Tudeley and East Capel would cause the maxium level of harm possible to the Green Belt.

The plan preparation process did not include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan did not go through most of the plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment, no Biodiversity Assessment. I consider that this version of the draft Local Plan isn’t complete enough to be ready for public consultation when the land for such a big proportion of the housing hasn’t had the same level of assessment as the rest of the plan.

The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they didn’t know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. The plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough.

At point 4.40 in the Plan you refer to Tudeley Village securing a long term option for the borough to deliver the needs of future generations. It is clear from this statement that you intend to add more and more housing to this “garden settlement” in each five year review of future Local Plans.

I fear that TWBC want to fill Tudeley and East Capel with housing until they coalesce with Tonbridge to the West and Paddock Wood to the East, ultimately creating a massive conurbation that will dwarf Tunbridge Wells town centre. TWBC is using Capel to dump their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the borough on brownfield sites or placing the garden settlement in the middle of the borough, to make it accessible north and south. The developments in Tudeley and East Capel are unsustainable and place huge pressure on Tonbridge. I believe that the publication of the lazy and unsound draft proposals for a garden settlement at Tudeley have led already to a blight on existing properties in the area.

DLP_6045

Mr C Mackonochie

The site is split by a mainline railway line with two narrow crossings and, if built, will result in two separate communities with their own distinct characteristics. This goes against the ethos of a garden settlement; infrastructure costs will rise as duplication will be required. Thus this site is not suitable for a garden settlement

The site is within the Green Belt and only in exceptional circumstance under the NPPF can land be released from the Green Belt – this has not been demonstrated

The site is between the High Weald AONB and the Low Weald and provides a transfer between the two areas and therefore provides an invaluable link both in biodiversity terms, landscape characteristics and scene setting. The border of the AONB follows the route of the B2017; the landscape is the same on both sides of the road and it is reasonable to speculate that if the road had been further north, say along the railway line, then the more than 50% of the site would be in the AONB

The strategy recognise that sites outside the AONB but within the High Weald National Character Area, or close to the boundary of the designated AONB landscape, will have similar characteristics and are likely to contribute to the setting of the designated landscape. It has not been demonstrated how this will be taken into account

The boundaries of AONB should have been reviewed before the Plan was formulated. I believe this review should be carried out before Regulation 19

No comment has been made about how the loss of Grade 2 agricultural land will be offset.

It is unclear how the area will retain and protect its historic, industrial (iron workings), flora and fauna and landscape heritage from an urban sprawl of 1,900 houses. This contrary to the NPPF

The infrastructure costs will be very high thus not achieving the expected developer contributions – there is no evidence of this having been taken into consideration

There is no mention of the impact of the KCC Minerals and Waste Draft Plan, so I assume this and potential new quarry workings have not been taken into account nor is there mention of neighbouring two former landfill sites, used in 1980’s and 1990’s, and the safeguarding of local pollution and pollution to the local aquifers

DLP_6078

Peter Brooks-Johnson

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

Before starting my detailed comments I feel compelled to point out that the process of community engagement is fundamentally flawed. I understand that the local plan is a broad complex undertaking. But to attempt to consult with the general public on a sprawling document filled with planning pseudo legal jargon is, at best, sub optimal, at worst deliberately distracting. The draft local plan document alone is over 500 pages long, I can only imagine how long the entire document set is (I haven’t accessed, let alone read it all).

To expect normal, working residents of the borough to read, understand and make cogent comment is lunacy and not founded in a spirit of engagement.

Equally I find the process of presenting the plan to be equally flawed. Why does it a take an entirely community run group to organise presentations in Tudeley, the centre of your proposed new settlement. The tone of the presentations I have seen thus far are not truly engaging they are “marketing” the plan, either wilfully misquoting facts (the quality of the agricultural land, mis-representing KCCs approval of the school site for example), or reserving detail for “later in the process”.

The process of forming the plan is unsound.

It is vital we provide more housing and affordable housing for residents of the Borough. It would therefore seem unwise to build in locations which are likely to have a higher cost of delivery and also appeal to people from outside of the Borough. The process for selecting the key sites in the plan CA1 and CA3 is unsound. The 2017 Issues and Options document selects a combination of option 4 and option 5 based purely on the theoretical properties of a site for a new settlement which might be found, not on a specific site. Clearly if such a perfect site could be found it would be the preferred option. It is not obvious to me that this assessment has been rerun based on the actual site for CA1.

The Distribution of Development Topic Paper apparently places much weight on the responses received during the Issues and Options Consultation, citing various percentages of respondents on each of the proposals.

This analysis pays no heed to the same respondents also stipulated that any New Settlement should be outside of the AONB and Green Belt (CA1 is wholly in the Green Belt and CA3 partially so), that infrastructure improvements would need to be delivered prior to commencing any work and that all other development potential should be maximised before this was considered. The draft local plan ignores this inconvenient data. A plan based on selective analysis is unsound.

The criteria in the Sustainability Appraisal Issues and Options Report May 2019 (p.21-26), may or may not be appropriate, but it is impossible that they can all be of equal weight. To conclude that one option is better than another purely because the total number of criteria satisfied is poor analysis. A plan based on poor analysis must be unsound.

The report concludes that a combination of options 4 and 5 is the best option, option 5 is the option with the highest number of mitigation strategies required:

Help turn the health and deprivation objectives positive by ensuring the settlement is positioned in a location that can achieve Accessible Natural Greenspace Standard and where a pocket of deprivation can benefit.
Turn the air objective positive by positioning the settlement in a location that draws traffic away from the AQMA.
Improve the noise objective through careful design and consideration of the settlement location.
Improve the landscape objective by choosing a location well outside of the AONB.
Improve the water objective by choosing a location inside Flood Zone 1 that eliminates impacts from flooding.
Introduce policy for resource conservation and waste management to help turn the resources and waste objective positive.
Turn the employment objective positive by choosing a settlement location that would provide employment opportunities for key wards.

Again this is poor analysis which does not stand up to any form of impartial appraisal. I have failed to find anything in the draft plan which conclusively demonstrates what these mitigation strategies might be in relation to site CA1, the detail is apparently later in the planning process.

What if the mitigations are not possible or not possible economically? I may not be a planner, but given my other experiences it is plain that a plan based on unknown mitigations is unsound.

To take each mitigation in turn:

Five Oak Green/Tudeley is not a “pocket of deprivation”. In any regard, the plan acknowledges the need to access high quality rail links confirming that the location may be suitable for commuters. With an annual rail season ticket being close to £5,000 there will be no impact on the non existent deprivation. Choosing a location where car ownership is more or less essential is unlikely to help the non existent deprivation either
The proposed settlement draws the location away from one AQMA in the Tunbridge Wells Borough and will likely create another in Tonbridge by positioning a settlement where car ownership is more or less essential with the exiting issues on and around Woodgate Way in Tonbridge
The location carefully considers the residents of Tunbridge Wells Borough, whilst making the lives of those in neighbouring Tonbridge and Malling immeasurably worse by dumping traffic into an already congested town
The proposed settlement abuts an area of AONB
At whose cost will the mitigation be? The plan is not clear
This is a purely fatuous mitigation, it could apply to any option. It takes no account of the significant extra resources required to create appropriate infrastructure in a rural area
I find this perhaps the most egregious mitigation. Building houses and zoning for employment does not create long term employment. Local employment at any scale would be within Tonbridge or the North Farm industrial estate, both requiring car transport. There is no evidence that the proposal will create any employment in itself.

The mitigations are not deliverable for the CA1 and CA3 sites, the plan based on them is unsound.

The detail of STR/CA1 is unsound

I am sure many others will have noted the loss of biodiversity, ancient woodland, flooding impacts and the impact on the scheduled buildings in the area.

It is incredible that over 60% of the Borough’s housing need will be delivered in Capel Parish and that 75% of the need will be delivered with 2 miles of the Borough border. The development will put an unbearable strain on Tonbridge town in terms of traffic and facilities, yet the plan has no mitigations for Tonbridge. Incidentally, given the relative proximities many residents of Capel would consider themselves residents of Tonbridge over Tonbridge Wells, as indeed does the post office. A plan which does not consider its full impact by using the Borough’s borders as an imaginary wall cannot be seen to have fulfilled a duty to cooperate is therefore unsound.

STR/CA1 destroys 600 acres of untouched Green Belt land irrevocably. In the NPPF the Green Belt is only to be released for development in exception circumstances. Tunbridge Wells Borough contains much non AONB or Green Belt land. The exceptional circumstances for releasing the Green Belt land in CA1, CA2 and CA3 appears to be that there are poor employment prospects in those areas outside the Green Belt.

The transport assessment reveals that the majority of residents in the newly created settlements will commute away from the Borough for work, with many making use of the train service to London. This creates two contradictions:

The plans proposed in STR/CA1 are not located in areas of employment
Yet more Green Belt must be sacrificed for the appropriate infrastructure development.

The plan does not cite the exceptional circumstances for releasing Green Belt land. In any reasonable definition, lack of effort to pursue suitable sites other than a call for sites does not constitute exceptional.

STR/CA1 contravenes the NPPF and is therefore unsound.

Beyond the damage to the Green Belt, the development in Capel will in time lead to the coalescence of Tonbridge and Paddock Wood, breaching the very purpose of the Green Belt (as noted in the council’s on study on the value of this particular area of Green Belt. Even ignoring the allusions in the plan to further releases of Green Belt the proposed development would create a ribbon of development from Tudeley in the west to Paddock Wood in the east. Travelling along the B2017 via Mascalls Court road to Mile Oak is a five mile journey. This plan proposes that for all but 0.3 miles that journey will be developed on at least one side of the road. The plan removes the distinct nature of the settlements in the area and is therefore unsound.

There is no detail offered on the route of the necessary connection between the proposed Colt’s Hill bypass to the new settlement at Tudeley, no assessment of practicality or therefore reasonable costing. Equally there is no detail for the enhancements to the B2017 towards Tonbridge which incidentally forms the boundary of the AONB, can one side of a road be an area of outstanding natural beauty and the other have no impact upon the beauty?

However, the plan is clear the cost will be borne by the developers. Since developers are commercial businesses what mechanisms will be in place that they commit to this unknown expenditure without costing and without guarantee of revenue? There is no real guarantee that the required infrastructure will be built before development begins. At the very least the plan should make any development within CA1 or 3 contingent on an agreed and deliverable plan for all the infrastructure. Given the elapsed time to agree the route for the, as yet undelivered Colt’s Hill bypass, residents are rightly sceptical that housing development will being and the promised infrastructure will be “forgotten” or stuck in a bureaucratic deadlock. Residents have experience of multiple mineral extraction and solar farm schemes in the area failing to deliver planning imposed remediation programmes. Tunbridge Wells Borough have shown neither the will nor ability to ensure their planning promises are met by commercial entities.

AL/CA1 says “This should include promotion of public transport, walking, and cycling”. Given the distances to the nearest settlements, walking and cycling are not likely to be practical for most, particularly in the winter. There is very little current provision of bus transport in the rural areas of the Borough.

Both the road and other transport arrangements are poorly developed making the plan unsound.

STR/CA1 makes frequent use of the word “quality” in the description of the development. It makes little to no use of the word “economic” in the description of the development. It would appear that much emphasis has been given to the design of the settlements in Capel, but none to the ability to deliver. Given the lack of foresight from the planners (an oxymoron surely) the chances of a quality development being delivered would appear slim. I could find no mention of contingency or other measures to ensure the plan for Capel is delivered as envisaged. Given experience in other developments in Paddock Wood which have falter under lack of market need and lack of sewerage capacity a plan without deliverability must be unsound.

AL/CA2 describes a six form entry school built straddling a main line railway. The school would be over a mile to the settlement it serves. That route will be along an, as yet undefined cycleway. One presumes that that cycleway will be sufficiently lit to provide a modicum of safety to the children commuting along it in the winter. There is little in the plan assessing the safety risks of a school straddling a railway or a mile long cycle path though countryside. An unsafe plan is unsound.

Despite copious pages, much of the plan has the hallmarks of a flight of fancy. Tunbridge Wells Borough councillors have made much of the parallels to Poundbury (to which, I understand a number enjoyed a paid for visit). Of course the parallels are slim, Poundbury being an urban extension beside a major trunk road and within walking distance to two rail stations. 600 acres of Green Belt and thousands or residents and future residents of Tonbridge and Capel should not be sacrificed for gain and convenience whilst bringing no affordable housing solutions for residents of the area. As if to add insult to the considerable injury STR/CA1 causes to the parish, the map accompanying AL/CA1 does not correctly identify all the privately held land within the parcel. If Tunbridge Wells Borough allow such a fundamental, simple and easily verifiable omission how can such a complex plan be sound?

DLP_6098

Julia Speight

I have been encouraged to email and voice my concerns about your proposed development surrounding Tudeley, Paddock Wood and the school on Woodgate Way.

Shame on you.

I agree with SaveCapel that this will be a blight on our landscape. The air, light and noise pollution will be disruptive to the residents. I don’t want to lose 600 acres of pristine Green Belt, the wildlife and biodiversity destroyed, when Brown Belt sites sit empty and should be utilised, it is pandering to the developers that they may build cheaply and make more money, rather than doing the right thing.

I am very concerned about these developments as I think they are proposed to that area with an unscrupulous intent. They may be positioned in your council and your council will receive any and all revenue connected with the developments, yet the burden on the roads, services and general disruption will be placed firmly on the shoulders of Tonbridge and Malling council. It will significantly increase traffic in and out of Tonbridge, these people will not be using Tunbridge Wells for their daily needs, they will be travelling to Tonbridge. The GP surgeries and dental surgeries that are already stretched to limits will struggle with the influx of population. The public transport is already packed.

I recognise a new school is probably needed, I just think it is rather underhanded to build on the very border of your council knowing that the brunt of the disruption during building and then once open will be felt by Tonbridge residents. It is already busy in and around Tonbridge. It is not close to the train station and the buses are already packed. Piling on more students will not help that situation. So many come into Tonbridge from as far away as Kings Hill and Sevenoaks, the buses are already standing room only by the time they are coming into Tonbridge. And it also has the train line bisecting the site. Really? How is this a good idea?

The massive development at Tudeley seems ill conceived. With the rail line also bisecting the development, that also seems an expensive way to build, it must make it more difficult catering to a very busy and necessary line. Just seems ridiculous. It is almost like someone proposed it as a joke and it caught traction. Were they patted on the back for coming up with a way to make money without too much duress on your Royal Tunbridge Wells? There is a flood risk around that area and this can only make it worse. I remember the Christmas flood, and paving over floodplains seems the absolute worse thing to do. Losing that agricultural land seems short sighted, as well.

I recognise that homes are needed. This plan is not the answer, get back to the drawing board and look at Brown Belt sites. Then you MAY have more public support.

Shame on you.

DLP_6146

Turley for Taylor Wimpey UK Ltd

On the basis of the evidence base presented thus far on this and Policy STR/PW1 options, we have concerns over the scale, location and delivery expectations for these proposals. Over 67% of the Draft Local Plans new allocations are dependent on these policy options being delivered. A high degree of certainty is therefore needed to justify a strategy so heavily reliant on these. As outlined in our comments to Policy STR1 (Development Distribution and Delivery), there remains significant gaps in the evidence base underpinning the delivery assumptions for these options. We have suggested further evidence be commissioned to refine and robustly support delivery rates from this policy. The delivery uncertainties posed by such options place an added onus on delivering the smaller allocations proposed elsewhere in the district, so as to maintain a rolling five year housing land supply. We have recommended additional or alternative allocations be made in this context at Cranbrook. Specifically the allocation of our clients lands (SHELAA Site 25) for a modest development of around 70 homes in addition to, or instead of, draft Policy site CRS6 or CRS7 or CRS4. A site we believe may have been overlooked by TWBC in error through the SA and SHELAA process (see introduction to this letter and Cranbrook policies below).

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

DLP_6163

Susan Bevan

As a resident of Tonbridge, I strongly object to the proposals to fulfil the bulk of Tunbridge Wells’ projected housing requirements on the borough’s border with our borough, Tonbridge and Malling. In particular, I am aghast by the proposal to swamp the small village of Capel, on Tonbridge’s doorstep, with a development of 4,000 houses.

As the main urban centre of Tonbridge and Malling, Tonbridge has seen rapid expansion in recent years and further expansion is proposed in our borough’s own local plan. Our infrastructure is already creaking under the strain. The proposals for Capel would make intolerable demands with the new residents inevitably using our facilities and not those of Tunbridge Wells which would nevertheless be in receipt of their Council Tax payments.

In particular, our road system, which is inadequate already, due in part to insoluble problems presented by the town’s location straddling the River Medway, could not sustain the additional pressure generated by the proposed development. Capel has no existing public transport. The new residents would be dependent on their cars whose initial destination is likely to be Tonbridge. Commuters would inevitably add to the congestion at Tonbridge railway station already the busiest in the south-east.

The proposal to build a new secondary school straddling the railway line on the outskirts of Tonbridge is absurd. Tonbridge already has an exceptionally high concentration of secondary schools attracting pupils from far and wide whose transport contributes significantly to our traffic problems. The proposed school would not be in walking distance of the station or on a bus route.

Apart from its ramifications for Tonbridge, this very large development on the green belt adjacent to the High Weald Area of Outstanding Natural Beauty, is completely unacceptable and contrary to national planning policy. A particular scandal would be the impact on Tudely church, which attracts visitors from around the world to view its beautiful Chagall windows. This little building in the countryside would, under these proposals, be surrounded by a housing estate.

It is quite clear that Tunbridge Wells Borough has seen an easy route to fulfilling its housing needs by entering into agreement with a single substantial landowner quite regardless of any other priorities or considerations.

DLP_6229

Amy Togher

I object to “The Strategy for Capel Parish”.

The location of this site is on the borough border with Tonbridge; with the Tonbridge train station, high street and supermarkets all in closer proximity than any TWBC alternative. The current population of Tonbridge is approx. 40,000. The Tudeley Village/Capel development of approximately 4,000 new dwellings has the potential to increase the population using the already strained Tonbridge infrastructure by 25-50%.

It will be crippling to all roads and carparks in Tonbridge town centre; something which cannot be addressed simply through new transport links in and out of the Village or the inclusion of cycling paths. There will be a significant increase in traffic into Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road every morning. The already unacceptable levels of traffic between 7.45am to 9am on Woodgate Way, Vale Road and Pembury Road coincide with the site of a proposed new 6 form entry senior school.

There is no mention of new access to the A21, which means Tudeley village residents will be funnelled westward along Tudeley Road to the A26, putting immense pressure on an already busy roundabout.

Infrastructure for a development of this size cannot simply ignore the need for a new railway station. Network Rail have confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. The longer journey times and less frequent trains from Paddock Wood make it far more likely that residents of Tudeley village would use Tonbridge station, which is already dangerously overcrowded during peak hours, and there is not sufficient car parking to support such an increase in demand.

It is, frankly, irresponsible to progress with this development, when Tonbridge & Malling Borough Council have raised “serious concerns”. Specifically, that "the proximity of some of the major development proposals to the borough boundary and specifically, the south east of our main settlement of Tonbridge, is a matter of serious concern due to the potential impacts on the local highway network, rail services and other community infrastructure including health care and education, particularly when combined with planned developments in Tonbridge as part of our own Local Plan."

Furthermore, none of the council tax revenue from these new homes would support infrastructure in Tonbridge.

These are fundamental flaws in the planning process. TWBC cannot be allowed to make decisions of this magnitude in a vacuum.

Vague and Inaccurate Targets

TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Recent ONS figures also show that population growth in the borough is slowing.

In addition, the portion of these new homes designated as “affordable” is also unacceptably vague. This country does not need more over-priced housing.

Flooding

Pollution

There will be an increase in air, light and noise pollution that will spread across the boundary into Tonbridge & Malling and create a visual scar across the landscape.

Heritage Assets

Green Belt

No exceptional circumstances have been demonstrated. Housing need is not an exceptional circumstance.

The plan preparation process didn’t include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan didn’t go through most of the plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment, no Biodiversity Assessment. This version of the draft Local Plan isn’t complete enough to be ready for public consultation when the land for such a big proportion of the housing hasn’t had the same level of assessment as the rest of the plan. The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they didn’t know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. I think that the plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough.

In conclusion, whilst I appreciate the great challenge of meeting future housing needs, the convenience of partnering with a single landowner does not override the council’s obligations to national policy and the residents of Capel & Tonbridge.

DLP_6269

David Witt

I am writing as a resident of Tonbridge.

Having looked at the plans for the developments in Tudely and Capel and the school at Woodgate Way, I can only say that I am absolutely appalled by the potential impact on the infrastructure and services of Tonbridge. These developments would seriously overload and threaten the viability of the town’s train and medical services and almost inevitably lead to severe congestion.

The fact that these plans were conceived and promoted by a neighbouring council (TWBC) which will not itself have to suffer the burdens caused by the developments represents one of the most cynical acts of local planning that I have ever encountered. It is difficult to believe that our planning system could be so inadequate as to allow one town to meet its own objectives by crippling the infrastructure of a neighbouring town without even bothering to make a serious assessment of the resultant damage or secure agreement on a resolution with the other town.

I would therefore urge all those who are in a position to influence the outcome of this proposal to do everything in their power to ensure its rejection.

DLP_6320

Emma Stroud

Object

Policy Number: STR/CA1

I object to “The Strategy for Capel Parish”.

There is no mention of new access to the A21, which means Tudeley village residents will be funnelled westward along Tudeley Road to the A26, putting immense pressure on an already busy roundabout.

Infrastructure for a development of this size cannot simply ignore the need for a new railway station. Network Rail have confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. The longer journey times and less frequent trains from Paddock Wood make it far more likely that residents of Tudeley village would use Tonbridge station, which is already dangerously overcrowded during peak hours, and there is not sufficient car parking to support such an increase in demand.

Furthermore, none of the council tax revenue from these new homes would support infrastructure in Tonbridge.

These are fundamental flaws in the planning process. TWBC cannot be allowed to make decisions of this magnitude in a vacuum.

Vague and Inaccurate Targets

TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Recent ONS figures also show that population growth in the borough is slowing.

In addition, the portion of these new homes designated as “affordable” is also unacceptably vague. This country does not need more over-priced housing.

Flooding

Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but I believe that flood risks will increase. The news from Sheffield this week is a clear example of unprecedented rainfall. Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding.

Pollution

There will be an increase in air, light and noise pollution that will spread across the boundary into Tonbridge & Malling and create a visual scar across the landscape.

Heritage Assets

Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saint’s Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. That will cause great harm to its value as a heritage asset of world renown (due to the complete set of Marc Chagall windows).

Green Belt

Creating so much housing in Capel 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, including rare species. This area should remain rural with agricultural land that can be used to provide food.

No exceptional circumstances have been demonstrated. Housing need is not an exceptional circumstance.

The plan preparation process didn’t include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan didn’t go through most of the plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment, no Biodiversity Assessment. This version of the draft Local Plan isn’t complete enough to be ready for public consultation when the land for such a big proportion of the housing hasn’t had the same level of assessment as the rest of the plan. The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they didn’t know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. I think that the plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough.

DLP_6438

Andrew Palmer

I know the Parish of Capel and the surrounding area well, having grown up in the local village of Hadlow and lived in Southborough and Tonbridge. In 2016, I and my family moved from Sevenoaks to a property near All Saints Church in Tudeley. We had visited the Church on many occasions to view the Chagall windows and had used the public footpaths that are threaded through the surrounding countryside. Since moving to Capel Parish, we have worked to restore our property so that it adds to the landscape; and have encouraged wildlife. Having worked for many years in Central London, I appreciate fully what the Parish of Capel represents.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

I do not believe the proposed housing development at Capel can be dressed in any way that would make it an improvement to the area, or be comparable to the ‘garden village’ developments in Cornwall or Scotland.

Roads, Traffic and Transport.

Traffic along the B2017 travelling from Capel towards Tonbridge is already becoming increasingly overloaded without the significant increase in vehicles that would arise from the Capel development. Long tailbacks can build from the Woodgate roundabout with the A26 and roundabout with the A21 and extend past All Saints Church. Although there is currently very little information on how the dramatic increase in traffic would be mitigated, any road widening scheme would inevitably add to the existing traffic problems in Tonbridge. The proposal to build a new school adjacent to the Woodgate roundabout would also significantly add to traffic.

In all probability, the new housing would attract families moving out of London rather than local people and would generate a high number of additional commuters. As the creation of a new train station to serve the development has been ruled out, people would use Tonbridge as their local station. It would be unrealistic to suggest that they would travel back along the railway line to Paddock Wood or Tunbridge Wells. In addition to the problems that would arise from the increased traffic movements and need for parking, Tonbridge Station is one of the busiest in the South East and is already operating at capacity.

Environment and Heritage

Policy CA1 is not environmentally sustainable, as the construction, traffic movements and footfall associated with what in effect would be a new town would destroy Green Belt land in an area already stretched to its limits. It would also irrevocably damage the Area of Outstanding Natural Beauty with its associated wildlife and endangered species. In our own garden which is near the open fields by All Saints Church, we have regularly seen Green and Greater Spotted Woodpeckers; and a Kingfisher has begun to visit the pond which was originally dug to serve the adjoining oast house. The ponds situated across the fields that form the Capel development are also often visited by Cranes. Long established wildlife would be lost if their habitat was damaged or destroyed; or if large numbers of vehicles, people and their pets were to be introduced into the area.

Air quality could also be compromised through a combination of losing the established woodland and replacing it with housing and busy roads and. Having been a commuter, I appreciate the difference in quality between the clean air of Capel and the air in London, where pollution has continued to increase to a level where it is now damaging to health. Planting new trees would be an inadequate response at a time of increasing environmental pressure.

The light pollution that would be caused from the proposed development would also directly conflict with the Local Plan’s stated aim to promote “dark skies” in rural areas.

Heritage

The visitors’ book at All Saints Church shows that people come to Capel from countries across the world to see the unique stained glass windows created by the artist Marc Chagall. Visitors also look at the oast houses, woodland and farmland which compliments the Church, and comment that the people of Capel are lucky to live in such a unique and beautiful setting. I believe that it is the local authority’s responsibility to protect Capel Parish from the harm and dilution that would be brought by the proposed development.

Brownfield Sites

There are many brown field sites in the borough that could be used for sustainable housing development. I do not believe that the local authority has demonstrated enough evidence that alternative brownfield sites were properly sought, or adequately considered during the preparation process. Instead, it seems clear that the Council chose the easier option of dealing with one landowner and allocating the majority of its new housing in a Parish conveniently situated at the edge of the borough, with little regard to the consequences.

Conclusion

I wish to record my objection to Policy CA1 in the strongest terms possible.

The proposal would have a disproportionate impact on the environment, travel network and the neighbouring borough. I consider it to be a strange response to the increasing recognition of the value and importance of the Green Belt and agricultural land, which need to be protected as measures to halt climate change.

I fully recognise the need for housing but would suggest that current government policy for housebuilding is misplaced, as other parts of the UK with more open space would welcome the investment and benefit that could arise from such a major development.

It is unfortunate that the Council appears to be willing to oversee the destruction of a unique and valued part of the borough, as I believe that the responsible authorities have a duty and moral obligation to protect the environment and Green Belt for this and future generations.

DLP_6482

Woolf Bond Planning for Millwood Designer Homes Ltd

Site 2: Chittenden Fields, adjacent to High Street and Slip Mill Road, Hawkhurst

Policy STR/CA 1: The Strategy for Capel Parish and Policy STR/PW 1: The Strategy for Paddock Wood

Representation

The strategy for Capel Parish and Paddock Wood seeks to provide for significant growth as follows:

- The provision of a standalone garden settlement (referred to as Tudeley Village) of 2,500-2,800 dwellings, of which 1,900 are expected to be delivered in the plan period, together with appropriate employment, including retail provision, within the settlement. This is required to be developed using a comprehensive masterplanned approach;

- Together with land outside of Capel parish on the northern, eastern, and southern sides of Paddock Wood, and within the town centre, a proportion of approximately 4,000 new dwellings and associated education, leisure, and health facilities to be delivered (on the wider allocations). Again, they are required to be advanced using a comprehensive masterplanned approach.

The approach to masterplanning and delivery states as follows:

“The comprehensive masterplanning approach will require close liaison and involvement with local communities and organisations, infrastructure providers, statutory consultees, relevant landowners and developers, and county and neighbouring authorities, and will follow garden settlement principles. Proposals for the piecemeal development of individual sites will not be supported….”

The strategic site allocations include a number of separate land ownerships and there are significant infrastructure issues to address and deliver.

In setting out our concerns in response to Policy STR 1 above, we have considered the content of the Housing Supply and Trajectory Topic Paper (Sept 2019) and the analysis set out therein in relation to build rates etc.

Including for the reasons set out in that Paper, and the accompanying source documents (paragraph 4.2.2 refers), we consider the assumed build rate of 299 dwellings per annum at the strategic allocations of 2,000+ dwellings (Table 8 refers) is overly optimistic.

Reliance on overly optimistic build rates artificially inflates the assumed rate of completions set out in Table 9 of the Topic Paper.

The available evidence does not support nor justify relying upon 150 completions from Tudeley village (AL/CA1) in 2025/26 and nor does it justify 333 completions from Paddock Wood (AL/PW1) in 2024/25.

A more robust assessment, with a more realistic start date and annual rate of completions would require additional site allocations in order to demonstrate a deliverable and developable supply of housing land sufficient to meet the minimum housing target during the plan period.

Suggested Change

Revise the delivery assumptions for the sites to provide for a more realistic date for first completions as well as a more realistic annualised build rate.

[TWBC see full representation, site plan and Landscape and Visual Statement ].

[TWBC: see also Comment Numbers DLP_6479-6484]

DLP_6489

Woolf Bond Planning for Millwood Designer Homes Ltd

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

Policy STR/CA 1: The Strategy for Capel Parish and Policy STR/PW 1: The Strategy for Paddock Wood

Representation

The strategy for Capel Parish and Paddock Wood seeks to provide for significant growth as follows:

The approach to masterplanning and delivery states as follows:

The strategic site allocations include a number of separate land ownerships and there are significant infrastructure issues to address and deliver.

Reliance on overly optimistic build rates artificially inflates the assumed rate of completions set out in Table 9 of the Topic Paper.

Revise the delivery assumptions for the sites to provide for a more realistic date for first completions as well as a more realistic annualised build rate.

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

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

DLP_6530

Robin & Gillian Dunn

We have lived and worked in Tonbridge since 1990; we’ve used the local infrastructure, schools and amenities; we’ve brought up our family here. Please add my contact details to your consultation database so that I can be kept informed of all future consultations on Planning Policy documents. I understand that my comments will be published by the Borough Council, including on its website.

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

DLP_6556

Woolf Bond Planning for Millwood Designer Homes Ltd

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

Policy STR/CA 1: The Strategy for Capel Parish and Policy STR/PW 1: The Strategy for Paddock Wood

Representation

The strategy for Capel Parish and Paddock Wood seeks to provide for significant growth as follows:

The approach to masterplanning and delivery states as follows:

The strategic site allocations include a number of separate land ownerships and there are significant infrastructure issues to address and deliver.

Reliance on overly optimistic build rates artificially inflates the assumed rate of completions set out in Table 9 of the Topic Paper.

Revise the delivery assumptions for the sites to provide for a more realistic date for first completions as well as a more realistic annualised build rate.

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

[TWBC: see also Comment Numbers DLP_6548-6450, 6452-6453, 6456-6457, 6459]

DLP_6596

Jane Spicer

I live on the outskirts of Paddock Wood off Badsell Road. My family has lived in The Greenways since 1983. Sadly we have recently lost our lovely orchard to 309 Berkeley Homes and now they plan another 117 on the same site. My husband commutes daily to London and can hardly get a seat on the 06.30 to Cannon Street now, so heaven knows how he will manage when all the current planned houses are built and occcupied - let alone another 4,000 in the local plan.

I worked at The Schools at Somerhill for 23 years and the traffic along Tudeley Lane/Five Oak Green Road at school time is manic. With 4,000 odd new homes in Paddock Wood, Capel and Tudeley, it will be extremely difficult to travel along the lane between Paddock Wood and Tonbridge during peak/school times.

It seems ludicrous to me that all this proposed building of houses (local plan) in both Paddock Wood, Capel and Tudeley even come under TWBC as they directly impinge on the people and infrastructure of Tonbridge and do not affect Tunbridge Wells in any shape or form. The people of Tonbridge will bear the brunt of the services, trains, Health services, schooling etc.

Flooding:

Building on the flood plain from Tonbridge towards Paddock Wood makes absolutely no sense. I have seen over 43 years of living in Paddock Wood and driving to Tonbridge many many occasions when Five Oak Green Post Office/store has been flooded, the houses nearby and all along The Medway, Hartlake Road being submerged either side of the bridge and impassable. The Leigh barrier isn’t always enough to halt the river! In any event, insurance companies are unlikely to insure houses along the flood plain, but I guess whether the houses sell isn’t a worry to the local plan!

Infrastructure:

As Greg Clarke pointed out in his speech in Parliament last week, the infrastructure does not get done ahead of building works. The sewerage system in Paddock Wood is already suffering, without even the latest houses being added to the system. This, along with commuters suffering a long journey without a seat on the train to and from London, GP waiting lists currently around 3 weeks and schooling at Paddock Wood, Capel Primary and the local villages at capacity, another 4,000 odd houses between Paddock Wood and Tonbridge is, in my view, beyond belief.

There is already gridlock with the two girls grammar schools in Tonbridge. Another secondary school opposite Somerhill will cause an unfathomable amount of traffic chaos.

Also there is obviously the danger of the school being bisected between the mainline to London. Surely there is a safer sight for a new school?

Green Belt:

There are plenty of brownfield sites available. There are no ‘exceptional circumstances’ in my view, to build on green belt. Land which will be lost forever to animals, birds, recreation. I have seen many deer, badgers and smaller mammals over the years and seen owls, many herons - they will all go once the houses are built. All that will remain, are the public footpaths and Medway towpath (hopefully).

Roads:

The B2017 from Paddock Wood to Tonbridge, especially towards both roundabouts at each end, will be totally gridlocked with thousands more cars on a daily basis. Cars will undoubtedly use Alders Road as a ‘rat run’, which will be dangerous, as it’s very narrow in parts.

Heritage and Woodland:

All Saints, Tudeley with its unique Marc Chagall windows is inundated with coachloads of tourists visiting this wonderful church. To be surrounded by housing? Really? What a shame. Thank heavens Grade 1 Listed Somerhill has its own substantial acreage and more precious woodland won’t be lost to development. All the woodland that will be lost between Paddock Wood and Tudeley will be dreadful, increasing pollution (trees absorb carbon dioxide and produce oxygen). It’s not exactly a ‘green’ local plan is it!

I hope you consider my comments.

DLP_6598

Victoria Marshall

As a resident of East Peckham, I am very concerned with regard to Tunbridge Wells Council’s proposed development to build 4,000 houses in Paddock Wood and an additional 2,000 houses in Tudeley. Building on this scale is totally unacceptable and will impact the Tonbridge & Malling area ie:

* Of utmost concern, the proposed developments are just off the floodplain. East Peckham and the surrounding villages are on the floodplain and construction of this magnitude will have a monumental environmental impact on the current waterways, increasing flood risk to low lying properties dramatically, due to water run-off from the developed land.

* South Eastern Rail currently struggle to run an efficient and effective service from Paddock Wood and the surrounding stations, I commute to London daily. The impact of an additional c.24,000 (conservative estimate) people in the area, a percentage of whom I am sure will commute into London daily, will severely impact the rail network.

* Currently, I have to wait two weeks for an appointment with my local GP. Additional head count from the proposed development will put ever increasing pressure on the current services, there being no plans to provide extra facilities. Hospitals too will be impacted greatly.

* The road network in the local area is already under strain as over the years traffic volume has increased dramatically. Additional traffic from 6,000 new builds will render local roads not fit for purpose.

* Parking in the local areas will be even more problematic than currently.

* Local schools/nurseries will be oversubscribed, which again will add to the current system being put under extreme pressure.

In summary, the development of 6,000 homes in Paddock Wood and Tudeley is totally unsustainable. Many developments have been built locally over the years and the current infrastructure is not fit for additional development I am totally against this proposed development.

DLP_6621

Nicholas Fisher

I am writing to object to The Strategy for Capel Parish (Policy STR/CA1).

The creation of a garden settlement at Tudeley resulting in the first instance in 2,800 dwellings will cause immense harm to the residents of the Parish of Capel and to the residents of Tonbridge. It is completely out of scale with the current pattern of habitation in Capel Parish.

There will be a significant increase in traffic in to Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road every morning. The already unacceptable levels of traffic between 7.45am to 9am on Woodgate Way, Vale Road and Pembury Road coincide with the site of a proposed new 6 form entry senior school to sited next to the Woodgate Way roundabout.

This proposed school will be on the border with Tonbridge, split by a main line railway and alongside a heavily used road. This appears to be a terrible site for a school, surrounded by heavy traffic and requiring children to cross a busy train line to access both sides of the site. It is extraordinary to consider siting a school on a split site that is so close to already overused roads and opposite the entrance to The Schools at Somerhill. I would have serious concerns at the siting of the school in such a location because of the safety issues and the fact that Tonbridge hosts many schools already, all of them of an high standard.

No amount of infrastructure improvements will assist in reducing the already overflowing roads at peak school times in the morning and afternoon if a further 1000+ pupils are heading to and from the school and Tonbridge town and the B2017 to the east. If a second senior school is to be developed as part of the Local Plan a better and more secure location has to be found.

Most people living in the new garden settlements will drive privately owned cars, despite initiatives to encourage bus and bicycle use. The costs of infrastructure on the Tonbridge & Malling side of the boundary will have to be carried by Tonbridge & Malling residents whilst Tunbridge Wells will receive council tax from the residents in the new dwellings. The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area. There will be an increase in pressure on Tonbridge health services, amenities and car parking as residents from the new garden settlement at Tudeley will use Tonbridge as their local town, not Tunbridge Wells, because Tonbridge is much closer.

It is apparent that the B2017 will not be viable in its current form as it will require expansion if a garden settlement were created. It is already busy at peak times, exacerbated by traffic from Hartlake Road which is becoming a rat-run. People will drive east-west, for commuting and shopping in Tonbridge, not north-south as TWBC appear to think will be the case. In a transport infrastructure study there is shown a new roundabout at the junction of Hartlake Road and Tudeley Road/Crockhurst Street but there is a lack of any proper detail at present on the transport planning for the Tudeley town development. The plan remains incomplete in this critical aspect and that is unacceptable. This appears to be an apparent breach of garden settlement guidance in terms of infrastructure provision and consultation relating to proposed garden settlements.

There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape.

Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saints Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. It would be an egregious folly to permit the possibility of an enormous housing estate to be built around All Saints Church with consequential bus lanes, roundabouts and an increased road capacity. That will cause great harm to its value as a heritage asset of world renown, due to the crowning jewel of its Marc Chagall

windows that are unique to place and setting and represent the only installation of its type in the world. It is one of the most popular Churches in Kent by reference to visitor numbers.

Creating so much housing in Capel 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, including rare species. This area should remain rural with agricultural land that can be used to provide food. The landscape is ancient and Tudeley was listed in the Domesday Book. There appears to be very little thought given to the conservation of the landscape in the area as per the High Weald AONB management principles.

I believe that housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan.

TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant. The Green Belt Strategic Study commissioned by TWBC states that building houses at Tudeley and East Capel would cause the maxium level of harm possible to the Green Belt.

DLP_6628

Louise Castro

I am writing to express my concerns about the proposed building of 2,000 homes and building of a secondary school in Tudeley.

Whilst I am aware that housing is needed I feel that the impact on Tonbridge and the areas surrounding the proposed site will be extremely detrimental. It is so close to Tonbridge that the residents of the new homes will inevitably want to access the services within the town.

The town does not have the infrastructure to cope with the increased demand. The town GP practices already have had to implement managed lists as they are at capacity and all the primary schools have classes of 30 pupils so where we all these new residents meant to go?

The impact of additional traffic will also have a massive impact on the roads around the area. At present the rural road through Tudeley passing the Somerhill Schools is already congested every morning and after school so more cars would only make the problem worse.

It seems unfair that the council tax paid by the residents will go to Tunbridge Wells Council whilst they make use of Tonbridge facilities . Perhaps that was all part of the plan.

I therefore urge you to reconsider these plans.

DLP_6635

Eugene & Nicky Androsov

I am writing on behalf of the Androsov family in Tonbridge to object to “The Strategy for Capel Parish” (Policy STR/CA1).

Creating a development at Tudeley of 2,800 dwellings will cause real and significant harm to residents of the Parish of Capel and to residents of Tonbridge. The development will result in a substantial increase in traffic in to Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road every morning - as I well know having had two children at Somerhill and having lived for a while in Postern Lane. The already unacceptable levels of traffic between 7.45am to 9am on Woodgate Way, Vale Road and Pembury Road coincide with the site of a proposed new 6 form entry senior school and school bus services in the area being heavily reduced in general. This proposed school will be on the border with Tonbridge, split by a main line railway and alongside a heavily used road. This appears to be a terrible site for a school, surrounded by heavy traffic and requiring children to cross a busy train line to access both sides of the site. This is unacceptable.

Furthermore, the new residents in Tudeley are likely to use Tonbridge Station for commuting; they will inevitably use Tonbridge town services meaning that the town will need more parking. The increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times and can’t be made wider in most places. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable. Parking in and around Tonbridge Station will be even more difficult. Network Rail have confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. Most people living in the new garden settlements will drive privately owned cars, despite initiatives to encourage bus and bicycle use (as said bus services are being reduced, certainly school ones). The costs of infrastructure on the Tonbridge & Malling side of the boundary will have to be carried by Tonbridge & Malling residents whilst Tunbridge Wells will receive council tax from the residents in the new dwellings. The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area. There will be an increase in pressure on Tonbridge health services, amenities and car parking as residents from the new garden settlement at Tudeley will use Tonbridge as their local town, not Tunbridge Wells, because Tonbridge is much closer.

Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but we believe that flood risks will increase. Covering farmed fields with houses and roads i.e. hard surfaces will undoubtedly make the Medway flood more often and therefore causes increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding. There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape next to one of the region's most historic assets, All Saint’s Church in Tudeley. In fact, from the plans it seems that the church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. That will cause great harm to its value as a heritage asset of world renown (due to the complete set of Marc Chagall windows, which really are incredible).

In addition, we understand that as the garden settlement at Tudeley is divided by a railway line that has very narrow, weak crossings, even though putting in larger crossings at frequent points across the railway may be possible, it won’t tie the two halves of the settlement together enough to make it one settlement, so it will never satisfy garden settlement principles.

What greatly concerns us is that creating so much housing in Capel 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, including rare species. This area should remain rural with agricultural land that can be used to provide food. The increased noise and other pollution as a result of the increased traffic and reduced greenery should also not be ignored. We need to protect our planet for our descendants - and this is doing the opposite.

I believe that TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough.

We are informed that the plan preparation process didn’t include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. If this is correct this means that the largest housing area in the plan didn’t go through most of the plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment, no Biodiversity Assessment. I think that this version of the draft Local Plan isn’t complete enough to be ready for public consultation when the land for such a big proportion of the housing hasn’t had the same level of assessment as the rest of the plan. The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they didn’t know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. I think that the plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough.

Earlier in the plan (in 4.40) you refer to Tudeley Village securing a long term option for the borough to deliver the needs of future generations. It seems clear from this statement that you intend to add more and more housing to this “garden settlement” in each five year review of future Local Plans. I think that TWBC want to fill Tudeley and East Capel with housing until they coalesce with Tonbridge to the West and Paddock Wood to the East, ultimately creating a massive conurbation that will dwarf Tunbridge Wells town centre. TWBC is using Capel to dump their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the borough on brownfield sites or placing the garden settlement in the middle of the borough, to make it accessible north and south. The developments in Tudeley and East Capel are unsustainable and place huge pressure on Tonbridge. This makes for very depressing reading.

DLP_6749

Joanna Ginsberg

OBJECTION TO THE STRATEGY FOR CAPEL PARISH (POLICY STR/ CA1)

I’m writing to express my strong opposition to the proposal to build Tudeley New Town (garden village), a proposal to build 2800 houses in the fields around the village of Tudeley which currently consists of approximately 60 homes. The plans would mean the beautiful countryside, which is Greenbelt, being destroyed forever, where there is no infrastructure to support this type of development, it is on the edge of a floodplain, on a site split by a railway line and a predominantly rural area with irreplaceable historical assets.

We live at xx Bank Farm Cottages, Sherenden Road, Tudeley TN11 xx [TWBC: part of postal address redacted]. I have lived in the area for over sixteen years and have chosen this beautiful rural environment to bring up our family. I feel fortunate to have this opportunity of a lovely place to live where we can all enjoy the vast benefits that this environment brings, the positive health benefits and tranquil and free open green spaces. We live and work in the local area, regularly enjoying the incredible asset that we live amongst and that we appreciate every day. We chose to live here because of the rural location and all that that offers. There is also another personal family connection to Tudeley as my Father is recently buried in the graveyard at All Saints Church at Tudeley, a peaceful and secluded graveyard that has wonderful uninterrupted vista of the area allowing time and space for contemplation and remembrance away from the busyness of day to day life.

GREENBELT

The purpose of the Greenbelt is to prevent urban sprawl and protect the countryside and the threat posed to wildlife and landscape. The building of a new town on this scale would destroy the rural environment where the biodiversity is rich and diverse, ancient trees and woodland remain, meadows, hedgerows and good quality agricultural land exists alongside a small rural community built sympathetically within this rural setting. If the new town was built on the Tudeley site, the rural environment and landscape would be destroyed and lost forever, over 600 acres of very good/good agricultural land would go. It could never be replaced.

As the NPPF states, developing on Greenbelt should only be in ‘exceptional circumstances’ and must be justified and evidenced and not to just alleviate demands for further housing. It is not clear what the exceptional circumstances are at these sites of Tudeley and East Capel?

These areas of Greenbelt have a purpose and must be protected. In an area that is already a built up and congested part of the South East corner of the UK, the priority must surely be to save these precious green, rural landscapes for future generations. There are many alternatives, more suitable and sustainable sites throughout the Parish for building new homes which are available, for example the high number of Brownfield sites throughout the borough of Tunbridge Wells.

Although the proposed development is being promoted as a garden village, it will inevitably end up as a traditional housing type of development which is entirely unacceptable in this rural Greenbelt location.

INFRASTRUCTURE

Due to the fact that Tudeley is a rural area and sustainable in that format there is no infrastructure in place to support a huge development of this scale, 2800 houses. The site is not sustainable in that it is poorly served by public transport and residents will have no option but to drive to work. The current road infrastructure for the intended site is served only by narrow country lanes and there is inadequate capacity to accommodate the proposed housing development. The roads are already at capacity from Tudeley into the neighbouring town of Tonbridge especially during peak rush hour times.

The lack of infrastructure would have a hugely detrimental impact on the neighbouring town of Tonbridge and its residents recognise this fact, are extremely concerned and many are strongly objecting to the proposals. Residents of Tudeley use Tonbridge as their nearest town and an increase in population in the area would impact on the volume of traffic on the roads, the increase in the numbers of commuters – trying to get to Tonbridge station to park and find a seat on the train, plus pressure on amenities such as health services, emergency services and schools.

The concern is that the development both in Tudeley and East Capel would result in the urbanisation of the entire area from Paddock Wood to Tonbridge destroying the Greenbelt and rural landscape permanently.

FLOODING

The location of the proposed quarries in the floodplain would exacerbate any attempts to reduce flooding and may lead to make the problem worse in both sites.

HERITAGE / HISTORICAL ASSETS

The proposed developments would not only alter the landscape forever but the detrimental effects of pollution would increase, in particular noise, light and air. This would impact on the immediate population and also on the heritage assets that are in the Parish and that form part of Tudeley’s uniqueness. One historical asset that was chosen specifically for its location and quality of light is All Saints Church Tudeley and the world famous Marc Chagall windows. To this day this church attracts visitors from all over the world to enjoy and view the wonderful windows. On reading the visitors’ book recently the overriding common theme of response to the church and the setting was the word ‘peaceful’, this was used time and time again. This would disappear if the church was surrounded by 2800 houses and busy and congested roads. The whole of the area is steeped in history and is mentioned in the Domesday book.

Heritage assets are irreplaceable and should be conserved for future generations; there are more than 140 listed buildings in the Parish of Capel including Somerhill which is a Grade 1 Listed building located in an impressive and imposing position on the very edge of the parish boundary. Any excessive development would by the very nature of development impinge and encroach on this.

DLP_6766

Mark Ginsberg

OBJECTION TO THE STRATEGY FOR CAPEL PARISH (POLICY STR/ CA1)

I’m writing to in response to the consultation period of the Tunbridge Wells Local Plan to express my very strong opposition to the proposal to build Tudeley New Town (garden village), a proposal to build 2800 houses in the fields around the historic hamlet of Tudeley which currently consists of approximately 65 homes. The proposed plans would result in the destruction of good agricultural land situated within the beautiful Greenbelt at a location where there is no infrastructure to support such a development. Furthermore the proposed site is on a slope leading directly to and abutting floodplain and on a site which is split by a main railway line with only two minor crossing points, one being single track. This rural area has irreplaceable historical and heritage assets.

I live at XXX Bank Farm Cottages, Sherenden Road, Tudeley XXX and have lived at this location for over 23 years bringing up both my children here [TWBC: House number and post code redacted]. I chose this location with my late wife due to the rural aspect having moved from an urban area. I feel fortunate to have this opportunity of a lovely place to live where we can all enjoy the vast benefits that this rural environment brings, the positive health benefits and tranquil and free open green spaces. We live and work in the local area, regularly enjoying the incredible asset that we live amongst and that we appreciate every day. We chose to live here because of the rural location and all that that offers.

GREENBELT

The proposed site sits within the Metropolitan Greenbelt. The purpose of the Greenbelt is to prevent urban sprawl and protect the countryside and the threat posed to wildlife and landscape. According to the NPPF, there are five stated purposes of including land within the green belt, these are to check the unrestricted sprawl of large built-up areas; to prevent neighbouring towns from merging into one another; to assist in safeguarding the countryside from encroachment; to preserve the setting and special character of historic towns and finally to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. The NPFF states, developing on Greenbelt should only be in ‘exceptional circumstances’ and must be justified and evidenced and not to just alleviate demands for further housing.

It is not clear what the exceptional circumstances are at these sites of Tudeley and East Capel? A single landowner does not constitute exceptional circumstances and should not be considered in an intelligent and well thought out planning policy. These areas of Greenbelt have the above purposes and must be protected. In an area that is already considerably built up and congested part of the South East corner of the UK, the priority must be to save these precious green, rural landscapes for future generations. There are many alternatives, more suitable and sustainable sites throughout the Borough for building new homes which are available, for example the high number of Brownfield sites throughout Tunbridge Wells Borough. The site at Blantyre House and the government land around it. The extent of land in the north east of the Borough which is non designated land.

Save Capel campaign group are currently undertaking a survey of potential brownfield sites and have identified a number of locations that are not registered as such with the Borough and are prime sites for development.

Although the proposed development is being promoted as a garden village, the volume of 2800 homes does not make it a village other than on a planner’s desktop. It will inevitably end up as a traditional housing type of development which is entirely unacceptable in this rural Greenbelt location, breaching every aspect of the need for Greenbelt.

The proximity of the site to the town of Tonbridge and the neighbouring Borough of the same name constitute considerable urban sprawl, especially when taken with the proposed new school site and the other planned sites in the Parish. Tonbridge will extend as urban to Paddock Wood. The choices made now must be prudent for our future. The areas of non-designated land must be prioritised ahead of any green belt development.

The area of this site is rich in its biodiversity. Tudeley is mentioned in the Domesday Book and there are records that show the land, which was even then noted for its richness for agriculture, was given as a gift from William the Conqueror to his half brother. 1000 years later the land is still agricultural and is a combination of grade 2 and grade 3 agricultural land. Grade 2 and 3 are very good and good respectively. The Planning office for TWBC are on record as referring to the agricultural land as poor during meetings held with Borough Councillors when voting on taking this option forward towards the plan. This was clear misinformation and untrue, to hear a planning office make such obvious untruths about the land raises serious concerns as to whether an abuse of process has taken place.

The building of a new town on this scale would destroy this rural environment where the biodiversity is rich and diverse, ancient trees and woodland remain, meadows, hedgerows and good quality agricultural land exists alongside each other with a small rural community built sympathetically within this rural setting. If the new town was built on the Tudeley site, the rural environment and landscape would be destroyed and lost forever, over 600 acres of very good/good agricultural land would go. It could never be replaced.

INFRASTRUCTURE

Due to the fact that Tudeley is a rural area and sustainable in that format there is no infrastructure in place to support a huge development of the proposed scale. The proposed site is NOT sustainable in that it is poorly served by public transport and residents will have no option but to drive to work. The current road infrastructure for the intended site is served only by narrow country lanes and there is inadequate capacity to accommodate the proposed housing development. The roads are already at capacity from Tudeley into the neighbouring town of Tonbridge especially during peak rush hour times. The proposal to build new roads has yet to be produced in any planned format and these new roads would take up more Greenbelt. Any new Road would lead traffic to Tonbridge. Tonbridge itself is at road capacity. A new Road May bring the traffic in but would cause a bottleneck at Tonbridge, increase the problems within that town and impact on local, air quality, business costs and quality of life. For Tunbridge Wells to be prepared to inflict this type of devastation on a town of a neighbouring Borough displays a scant regard for cross Borough working as required in NPPF and for the communities that will suffer. Tunbridge Wells will pocket the council tax and Tonbridge and Malling will suffer the burden and demand.

The hugely detrimental impact on the neighbouring town of Tonbridge and its residents has already been recognised by its Borough Council who are extremely concerned over its soundness as a plan. Many of the residents within that town are also strongly objecting to the proposals. Residents of Tudeley being so close, use Tonbridge as their nearest town for most services including health, transport, retail and leisure services. an increase in population in the area would not only impact on the volume of traffic on the roads but would increase the number of commuters attempting to use Tonbridge railway station. Parking around the station is at capacity as are the commuter trains to London. With the other planned developments at sites already with suitable infrastructure such as Paddock Wood, Marden, Staplehurst and Ashford further along the line, trains may be at capacity prior to arrival at Tonbridge which is a rail hub. In addition to pressure on amenities such as health services, emergency services and schools.

There is no railway station within close proximity of the proposed site. Network Rail have confirmed that there will not be a new railway station at Tudeley as it is too close to Tonbridge and paddock Wood Stations for the 12 coach trains to alter their speed and to build a new station comes with huge cost implications. As mentioned previously, the proposed garden village development is split into two by the railway line and this goes against the principles for a garden village of one settlement and a fluid community. There are only two current crossings of this railway line, Hartlake Road bridge (Red Cow Bridge) which passes over the railway line. Hartlake Road is a wide single track road that allows vehicles travelling in opposite directions to pass; however, the bridge crossing is narrower and only allows two narrow vehicles to pass with extreme caution. The only other crossing is the road passing under the railway line at Sherenden Road. This road is a single track lane with the restricted height bridge being of the same width. The railway line is a main line used for both passenger and freight from the rest of Kent and Kent Ports and to impede this with any new crossing, which would be required would have significant cost implications which would need to be recovered by developers and so would impact on final costs.

FLOODING

Much of the proposed development is on or near the floodplain. There have been limited flood risk assessments on the site and from living in the area, it is a known problem that the agricultural land floods. This problem will be exacerbated if 2800 homes are built on the Tudeley site and will impact not only on the immediate area but towns downstream of the River Medway, East Peckham and Yalding specifically. All these villages have their own flood issues that they are currently battling. The soil is Kent Clay and despite having a large number of irrigation culverts around most fields standing water remains moderate rainfall. Along the existing railway embankment within the planned development area there are storm type drains, where these drains exist the soil is wet for most of the year and during the winter months has several inches of standing water. Where the embankment lies by the main buildings of the current solar farm there is a permanent swamp due to the failure of the land to adequately drain. This combined with the changing climate and rising sea levels add significantly to the risk.

The proposed plan lies alongside an existing proposal to create an extensive quarry site increasing the current Stonecastle Quarries. The creation of the quarries on existing floodplain and adjacent to the River Medway May have a significant impact on the risk to flooding, the water table lying just below the surface. This fact may cause a significant risk to any adjacent housing development and will create a considerable challenge to develop a suitable sewerage facility which will be required to treat the waste for any development. In any case, the placing of a necessary sewage facility will be difficult and costly and represents a risk to the Medway River.

HOUSING

The current average house price in Tudeley is in excess of £700,000 and therefore represents an expensive location for home ownership. The idea that affordable housing can be included within any development at the location, which will be a high cost site for developers is hard to envisage. The likelihood is that what is termed affordable is in reality at the upper reach of the average household. Developers would seek to minimise the number of affordable to maximise profits and the result would mean a significant number of executive type houses. Within Five Oak Green, less than a mile from the proposed site sit two 5 bedroomed new executive homes. Both of these homes have been empty for a year since completion, this questions the need for such homes.

Similar developments in Kent have brought a number of purchasers moving from London with the idealogy that they are moving to the country and the fact that they can get more house for their money against London prices. The availability of the good rail connections from Tonbridge will encourage this, irrespective of the saturation of the railway by existing commuters. This will also raise the number of vehicles that will be travelling towards rail stations.

The 2016 Government Garden Settlement paper raised questions on the need for a garden settlement. These included, the siting of a garden settlement should not be where there is an existing community, Tudeley has an existing community. Garden Settlements should seek to help support local businesses and local workers, there are no immediate existing local businesses and as stated above, many potential residents would be commuters for London. Garden settlements should have the support of the local community, in the case of Tudeley this is a firm no and is not built of nimbyism but is supported not just by the local community but by CPRE, London Green Belt Council, Tonbridge and Malling Borough Council and many residents from Tonbridge and other towns and villages that would be significantly detrimentally affected by these proposed plans.

The site of the plan includes old iron works and more importantly Bank Farm which until recently had been a working agricultural farm. An issue with building on working farmland is the fact that farmers tend to bury their waste rather than dispose of it through commercial and costly means. The result of the iron works and farm sites within the planned site is that extensive and thorough surveys MUST take place before any works. Such surveys must look at any contaminants or hazardous waste or soil. To build housing without such a survey could lead to harm to residents and potential expensive law suits against the local authority or developers. Such a survey would be costly and take time but it is vital that such a survey be carried out before this plan is considered any further.

HERITAGE / HISTORICAL ASSETS

The proposed developments would not only alter the landscape forever but the detrimental effects of pollution would increase, in particular noise, light and air. This would impact on the immediate population and also on the heritage assets that are in the Parish and that form part of Tudeley’s uniqueness. One historical asset that was chosen specifically for its location and quality of light is All Saints Church Tudeley and the world famous Marc Chagall windows. To this day this church attracts visitors from all over the world to enjoy and view the wonderful windows. On reading the visitors book recently the overriding common theme of response to the church and the setting was the word ‘peaceful’ used time and time again. This would disappear if the church was surrounded by 2800 houses and busy and congested roads. The whole of the area is steeped in history and is mentioned in the Domesday book. Heritage assets are irreplaceable and should be conserved for future generations, there are more than 140 listed buildings in the Parish of Capel.

LIAISON WITH TWBC

From the commencement of this process there has been a considerable lack of information, misinformation and a lack of detail from Tunbridge Wells Borough Council. Mistakes have been made and specifically to us, our home was not included and shown as a freehold property on the map of the site of Tudeley New Town. Bank Farm Cottages as a group of four cottages were covered in ‘pink’ and incorporated within the new town buildings. This has caused a great deal of upset and has been hugely unsettling to ourselves and our immediate neighbours as our home is one of the few properties in the centre of the proposed development and we would be surrounded by a new town. There seems to be a total disregard for the individuals in our community and our homes and security.

This mistake was made verbally to the planning officer on 5th August 2019, a month before the Local Plan was published yet it still remained incorrectly shown on the maps. Making enquires of the main planning consultants state that our home and that of our neighbours were not included within the maps sent to the local authority and this suggests that it is indeed the local authority that have made the error. In any case it has rendered our property unsellable until the situation is corrected. If it was indeed the council’s error then it is another display of poor planning and lack of attention to detail.

I would add that the Local Plan of over 500 pages makes it extremely difficult to ‘translate’, navigate and then to try and understand the process to respond. It should have been made so much more straightforward to encourage all to respond and have their say. This along with a very complicated portal which has continued to crash has meant that many hours have been lost by those trying to enter their response.

SUMMARY

The large scale, disproportionate proposed developments in Tudeley and East Capel are unsustainable and unsound. They contradict the key arguments to greenbelt land and the local authority have not fully considered all other options. The Parish of Capel currently consists of approximately 940 homes, to add 4000 new homes in these two sites alone would devastate this small strong rural community sitting between towns in greenbelt. The sites seem to have been chosen entirely on landownership and deliverability. The senior planner stated that having a single landowner makes it a good choice. Development should be spread across the whole borough and not concentrated in one corner , the Parish of Capel have been allocated 60% of the Borough’s development in the proposals regardless of the land being Greenbelt and its very close proximity to the neighbouring town and Borough, Tonbridge.

The building of houses needs to be sustainable with environmentally friendly solutions and that reduce the impact on wildlife and nature, whilst meeting the needs of local people. The special circumstances of greenbelt MUST be adhered to and greenbelt should be a last resort, not a convenient option.

DLP_6808

Lorna Veale

I am writing to OBJECT to “The Strategy for Capel Parish” (Policy STR/CA1).

Introduction

I am a resident of Tunbridge Wells Borough, living in Postern Lane, and therefore also benefit from being close to Tonbridge. I enjoy the significant benefits of the TWBC countryside and green belt within which my house is situated. The National Planning Policy requires that such countryside and green belt should be both protected and enhanced. The situation of the property was the main reason for choosing to live here.

The Draft Local Plan documents are numerous and quite complex. In addition, cross referencing between the documents is in places non-existent, which leads to confusion and frustration. As an individual with a full-time job and a family I do not have the time to examine each and every part and policy in detail. There appears to be no overarching, well constructed and balanced summary of the documents, apart from the 8 page summary which is at such a high level and therefore of no substance.

The Local Plan website is not particularly user friendly; for example there are drop down menus and colour differentiators, but you are not lead back to where you came from, which means wasted time searching through more menus. Given the investment in the draft plan to date, and the proposed scale of development, some more time spent on user interface and user experience would have been worthwhile. For such a significant plan, these are basic elements which need addressing.

Proper consultation needs to be accessible and user friendly for the people to whom it matters – this local plan is neither of these things and should be significantly revised before going any further.

I find it very frustrating that it has taken over two years and many thousands of pounds in fees and reports in order to get planning permission for a 65m2 single storey extension; and yet, in just over one further year, it seems a plan has been assembled to build 2,800 houses and related services and infrastructure on green belt land, within a mile of our house.

I wish to make specific comments as follows:

Distribution of Development Paper

Section 3.3 stands out for me in setting out the 5 purposes of green belt land. These are clarity personified. Section 3.4 states that such areas “should only be altered in exceptional circumstances”. Given the lack of clarity around selection of Option 5 in the Issues and Options consultation, the ‘exceptional circumstances’ are not satisfactorily explained.
Paragraph 6.56 confirms that there was no landscape assessment of Green Belt sites. It seems unacceptable to identify land for development, particularly Green Belt land, without understanding its existing value and contribution to the local ecosystem, especially if there are ‘exceptional circumstances’.
Section 4 discusses housing needs. These appear to be based on 2014 figures. The majority of lay people are able to google more recent ONS population figures and see the downward impact on housing requirements for all boroughs. Again, this does not speak to ‘exceptional circumstances’.
In section 5, a key issue identified in the Issues and Options consultation was:
“Vision should be balanced to both developing existing built town areas and preservation of surrounding countryside and unique historic villages”
Given the allocation of 2,800 houses to a garden settlement at Tudeley, it appears such preservation of countryside has been disregarded, without satisfactory explanation.
Issues and options section 5 – The most preferred option for provision of housing was clearly option 4, the ‘corridor’ option. A Garden town was less preferable. There is no real explanation for the U-turn in strategy or decision to move away from the preferred option. This is unacceptable.
Section 6.140 – it appears all scenarios set out are about meeting housing needs in full. TWBC has not considered it appropriate to partially meet or consider flexibility depending on numerous possible circumstances, and therefore has not planned in any way for this. This would seem blinkered at best.

Infrastructure

Trains – these are already at high capacity for commuters. Expansion is obviously limited by:
1. franchise appointment – over which TWBC has no control
2. existing lines/tunnel limitations – this also has very little scope for development. It is already clear there will not be an additional station between Tonbridge and High Brooms to cater for a new Garden Town. Thus, many of the inhabitants would have to go to Tonbridge or Tunbridge Wells in order to get the train. This will put additional strain on already overburdened stations and lines.
3. Parking – This is already an issue in both Tonbridge and Tunbridge Wells and there is no real focus within the infrastructure document as to how to deal with it.
4. Funding sources – These are not fully within TWBC control, making it hard to see how strategy or development can be strongly influenced or coordinated.
5. Overall, there is no real plan or strategy as to how trains and usage will be catered for.
6. Section 3.59 - Cycling provision is in its infancy – even an afterthought. The separate cycling policy document is largely platitudes and waffle about health benefits. There are a few possible route suggestions but far too little of substance which suggests TWBC has no real strategy as to shifting people away from their reliance on cars. Very few people are going to cycle any further than 10-15 minutes.
7. Cycling isn’t the answer in terms of modal shift from cars. As a nation we are too comfortable, too used to cars, too lazy and too obese. To get people cycling, it isn’t just about upgrading or providing new routes, it’s about education, offering bike discounts etc
8. Section 3.63 Car parking:
  1. In the Infrastructure document, apparently parking will be provided for. This is completely unacceptable as a ‘plan’.

In the parking plan document (dates from 2016) almost exclusively focused on Tunbridge Wells. Absolutely no consideration of new garden town, and also no consideration of parking required at Tonbridge station for additional commuters. This is TMBC’s responsibility and clearly very little by way of cross border communications have taken place.

Parking is one of the biggest pressures on transport and adding 2500 houses to Capel is only going to make it worse.
Section 3.133 Water – Southern water hasn’t yet carried out capacity assessments? This would appear to be a big hole in the plan, making it unsound.
Section 3.151 + Carbon emissions etc:

In order to reduce carbon emissions to zero by 2050 (government objective), we are going to have to move away from conventional coal and gas fired power. We need to move towards low carbon fuels. This Infrastructure plan appears to ignore this fact completely. It talks about the current gas provision and SGN’s future strategic planning (with an estimated 10% reduction up to 2025).

On the other hand the Currie and Brown (Energy Policy Viability) report suggests no new homes built after 2025 should connect to gas. TWBC needs to think about low carbon fuels, renewable energy, future proofing design and build of property etc. This is simply not addressed in the infrastructure plan. Also note Labour general election campaign pledge that all homes after 2022 should not be heated by fossil fuels.

THIS IS A GOOD EXAMPLE OF NO INTERALATION BETWEEN REPORTS.

Local Plan – STR/CA1

Creating a garden settlement at Tudeley of 2,800 dwellings will cause immense harm to residents of the Parish of Capel and to residents of Tonbridge. There will be a significant increase in traffic into Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road every morning.
There is a proposed secondary school to be situated east of Tonbridge (AL/CA2 – site 447 & 454). This utterly preposterous for a number of reasons:
1. It is situated either side of a railway track, the only bridge being a private single lane road.
2. It is situated adjacent to Tonbridge borough, which already has numerous (6) secondary schools within a few mile radius.
3. It is situated some distance from the proposed Tudeley Garden Town, with no obvious access routes by foot or bicycle.
4. It is situated some distance from both Tonbridge and Tunbridge Wells railway stations, making it even more inaccessible for secondary school pupils.
5. It is situated adjacent to a roundabout and roads which are already very heavily congested during rush hour periods. I often sit in traffic queues at both ends of the day.
6. It is situated in Green Belt land.
7. It is adjacent to AONB.

Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but I believe that flood risks will increase. Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding. There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape. Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saint’s Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. That will cause great harm to its value as a heritage asset of world renown (due to the complete set of Marc Chagall windows)
Creating so much housing in Capel 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, including rare species. This area should remain rural with agricultural land that can be used to provide food.
The plan preparation process didn’t include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan didn’t go through most of the plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment, no Biodiversity Assessment. I think that this version of the draft Local Plan isn’t complete enough to be ready for public consultation when the land for such a big proportion of the housing hasn’t had the same level of assessment as the rest of the plan. The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they didn’t know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. I think that the plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough.
Earlier in the plan (in 4.40) you refer to Tudeley Village securing a long term option for the borough to deliver the needs of future generations. It is clear from this statement that you intend to add more and more housing to this “garden settlement” in each five year review of future Local Plans. I think that TWBC want to fill Tudeley and East Capel with housing until they coalesce with Tonbridge to the West and Paddock Wood to the East, ultimately creating a massive conurbation that will dwarf Tunbridge Wells town centre. TWBC is using Capel to dump their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the borough on brownfield sites or placing the garden settlement in the middle of the borough, to make it accessible north and south. The developments in Tudeley and East Capel are unsustainable and place huge pressure on Tonbridge.

Masterplanning

There is discussion about a ‘Masterplanning’ approach. It is not totally clear what this means. In addition, a significant part of the Tudeley Garden Town is to be developed by the single landowner who is linking up with TWBC. This landowner has no masterplanning experience. That is worth repeating. The proposed developer has no masterplanning experience.

If TWBC are to be involved, one would also question its pedigree in this field. The new hospital at Pembury, completed in 2011, is already at full parking capacity. I have been there on 3 separate occasions recently and had to wait between 40 minutes to an hour to park. Clearly, whatever forecasts were made about visits, footfall, etc, were either not heeded, or totally wrong.

Transport Strategy Review – Context and way forward

There really is very little about the way forward in this crucial element of the plan.

Climate Change

Given the climate emergency facing the planet and the UK, there is not enough consideration to mitigation to the environment if such extensive building takes place. Far more attention needs to be paid to this element in every facet of the plan.

One example is that climate change will mean prime agricultural land will become more and more important. The land is rated as grade 2 and 3 agricultural land. Brexit, if it ever happens, will mean home grown, seasonal produce may become more and more important. How will this be replaced/mitigated for?

Summary

In summary, this plan appears unsound. Certainly, in its current form it is not accessible to the very people from whom it requires a response. It is comprised of hundreds of pages of material, not easily navigable and some of which even appears contradictory.

There appear to be many more questions than answers, and given the very justifiable objections, it is my view TWBC should reconsider this plan as soon as possible.

I CONFIRM MY STRONG OBJECTION TO THE STRATEGY FOR CAPEL PARISH (STR/CA1).

DLP_6820

Mrs Carol Richards

Policy STR/CA 1 (The Strategy for Capel Parish) p.156

I have never wanted to object to something as strongly as this strategy.

Para 1. To Build 1900 and eventually 2800 homes in Green Belt land on this ridge will not be a stand alone settlement. This statement is wrong. Retail provision of any kind will still mean trips to the larger M&S, Waitrose and Sainsbury in Tonbridge NOT Paddock Wood or Tunbridge Wells. The provision of employment and retail provision within the settlement will be minimal and no compensation for the agricultural land and farming/equestrian employment lost if the development goes ahead.

Para 2. The provision of a Secondary school at the Tonbridge Woodgate roundabout is utter madness. Every state school bar two (the Hadlow rural community school and Hugh Christie) in Tonbridge are situated, as the crow flies, along a distance of less than 2 ½ kms from Brook Street to the Weald of Kent roundabout. The number of pupils in these schools totals, 5,206. There is also a large private school also within 100yds of the Woodgate roundabout, which has 750 pupils. In total within a 3kms range, together with the 750 at the proposed new secondary school- there will be nearly 7000 school children. TWBC proposed site is on the other side of the road opposite The Schools at Somerhill- that is 2 schools at the Woodgate roundabout. The logistics of those extra numbers on the traffic in Tonbridge is totally unacceptable. No infrastructure improvements will negate the problems that will arise from this plan. The knock-on effect of roads in Tonbridge will mean traffic will tail back around the industrial estate and compound congestion in rush hour traffic along the Hadlow Road where I live. The centre of Tonbridge will be tail to tail with traffic on every artery in the town.

This school site also has an ancient woodland in the grounds and is bisected by a main rail line. It also has yet to have the backing of the Education Authority. The danger of a school being on two sites- bisected by a rail line-is very great. Policy TP5 states, development that is located adjacent to Network Rail assets, and or operational railway infrastructure will not be permitted if the development will have a negative impact on the safe and continuous operation of the associated railway service. I am not sure if Network Rail would be happy with a school either side of its rail line. No infrastructure improvements will negate the problems that will arise from this plan.

Para 3. I can see the sense of having one 3FE and expanding 1FE at Capel Primary but only if these homes were occupied by families. The birth rate is dropping and new homeowners will probably be commuters with no children.

Para 4. Looking at Table 1 Housing Need 2016-2036 (as of 01 April 2019)- TWBC calculate that the minimum allocations to meet housing need after consideration of points 2-5 in the table will be 7593. TWBC is proposing by the year 2036 AD – 2,800 homes in Tudeley Village and at Capel and Paddock Wood 4000 homes. These 2 plans (AL/CA 1 and AL/CA 3) total 6800 homes all along a band to the north of the borough. I calculate from these figures 89.56% of TWBC housing needs are planned to be built along this corridor. This number of houses is overkill. Spread them across the borough. It is totally unacceptable to build this number in one area of the borough and to burden Tonbridge with the consequences of your ‘Masterplan.’

Para 5. The flood risk that this development will precipitate (no pun intended) is huge. The hamlet of Tudeley overlooks the Medway Floodplain. The land on the ridge is in no danger of flooding being up to 50 or so metres above sea level. However, the valley Tudeley overlooks -along which the Hartlake Road runs- does flood-2013/4 being an example. You only have to look at an Ordnance survey Map- to see the small streams, lakes and the river itself - how much water there is along this flood plain. The runoff from the hardstanding from houses and driveways at the proposed Tudeley Village will be catastrophic for houses in the valley, East Peckham and Laddingford. As the ground here is so saturated with water there is nowhere for the water to go. It will form lakes of water as there are now- and over a very wet Winter will cause flash floods. This development will add yet more water to the Flood zone level 3 in the valley below. There is nothing you can do to mitigate this threat- the water has to run somewhere- and the only way is downhill to the River Medway. This issue does not even seem to register anywhere on Appendix1: Infrastructure delivery Schedule and there would appear to be no input form the Environment Agency on this threat either. This is unsound and totally irresponsible.

Para 6. TWBC say that road locations have regard to KCC minerals allocations but those allocations have not yet been approved. Strategic transport links cannot be provided without destroying large areas of AONB. The offline A228 link will cause horrendous traffic issues at Pembury. Any transport links provided will have to continue on through Tonbridge doubling, tripling or quadrupling the road improvement costs and causing chaos in an already highly congested traffic area. The Road infrastructure routes p498 still seem to be TBC? There is no assessment of the impact of links on the ANOB or the local environment. The plan is deficient and not sound to wait until Reg19 as stated in 6.536 p498.

Para 7. Strong Green infrastructure must be provided? Flood storage areas and other mitigation strategies cannot be delivered without developer contributions from new housing and introducing hard surfaces and dwellings on to the meadows and fields will increase the flood risk beyond any mitigation measures-you can’t mitigate against a flood plain the land is flat and saturated with water.

Para 8. Despite surrounding Five Oak Green with 4,000+ new houses, you state clearly that you want to keep on providing additional housing within Five Oak Green. Unacceptable. Unsound

Para 9. The release of Green Belt land is not permitted within the NPPF as there are no “exceptional circumstances,” just a greedy landowner and a lazy planning approach favouring negotiating with a single landowner over dealing with multiple landowners at Horsmonden (which is outside of Green Belt and AONB and won’t cost millions of pounds to try to alleviate the threat of floods).

Para 10. The AL/RTW 12 policy I very find odd. This lies within the Green belt in Capel Parish, is almost adjacent to the A21, so it already has a major road running nearby and yet- TWBC are prepared to save this now tainted Green Belt land(A21) and build on Green Belt land at Tudeley ruining an idyllic rural hamlet and surrounding an internationally renowned church with 2800 homes? Logic would suggest maybe build more homes here along with the planned 80000sqm of business use and workers could walk/cycle to work? Now that would reduce carbon emissions.

Para 13. The Biodiversity on this site is extraordinary. As you rightly note, it is also adjacent to a Biodiversity Opportunity Area and directly adjacent to AONB and is assessed as such in STR1/CA 1. TWBC has failed to assess the local ecosystem/biodiversity.

It should be noted this development is on prime agricultural land. The LPA should seek to protect this land, not build on it Policy EN22 p415. This is not noted in the site description.

Masterplanning and Delivery

The landowner and co-masterplanner is inexperienced and ill-equipped to deliver such a complex project.

Tonbridge and Malling Borough Councillors are very unhappy with these proposals, as are Tonbridge Residents ( who are aware of it). I am personally livid.

This policy is ill-thought out, lacks vision and clarity and as to the detail and how it will be achieved- well it is TBC! You cannot mitigate the harm that will result from developing this land in way the LP proposes. It is totally unsound and so wrong in so many ways.

Flood Risk – applies to policies STR/CA 1, STR/PW 1, AL/CA 1, and AL/CA 3

The LP is planning 52% of its additional housing allocation in AL/CA 3 and STR/PW 1 and 36% in STR/CA 1 and AL/CA 1- (Draft Plan Table 1 p 35) but both have elements in Flood Zones 2 and 3.

TWBC should consider:-

1. The River Medway is the largest river catchment within the Environment Agency’s Southern Region.

2. The floodplain (defined by the Environment Agency’s Flood Zone 3) of the River Medway lies to the north of Tudeley, Five Oak Green, Paddock Wood. With the tributaries Alder Stream, Tudeley Brook and River Teise.

3. The Leigh Flood Storage Barrier is located approximately 3 km west of the Tudeley. It was designed to protect Tonbridge from flooding and is the largest on-line flood storage reservoir in Europe, retaining a volume of 5,580,000 m3.( This is just an indicator to the level of water that this area has to cope with.) There are plans to increase this capacity by 2023, following the floods of 2013/4

4. The area around Five Oak Green and Paddock Wood is situated on the Low Weald, which is relatively flat underlain by impermeable WEALD CLAY. This means that water cannot soak into the ground AND the FLAT LAND MEANS it cannot flow away-it just lies on top.

5. Tudeley lies on a ridge above the Medway Flood Plain and this means the precipitation on hard -standing areas, of 2,800 homes- will cause faster run-off during a large event- into the flood plain below.

www.Gov.uk shows the Flood Map for Planning of this area:- Exhibit 4 (TWBC Comment - seeattachment)

This is a very powerful visual reminder of the area where TWBC have chosen to put the large number of homes 2016 -2036- up to 6,800 in total. Flooding will continue to increase with Climate Change-forecasting wetter winters. Why chose here?

TWBC have obviously not taken water related issues into account from an early stage in the process of identifying land for development and redevelopment, to encourage the use of sites where past problems can be solved and seek to avoid sites where water supply and/or drainage provision is likely to be unsustainable;

Some extracts from the NPPF:

The NPPF 149 states:

“Plans should take a proactive approach to mitigating and adopting to climate change, taking into account the long-term implications for flood risk... Policies should support appropriate measures to ensure the future resilience of communities and infrastructure to climate change impacts, such as providing space for physical protection measures, or making provision for the possible future relocation of vulnerable development and infrastructure” [My emphasis]

So why plan to put homes in a vulnerable area in a flood plain zone in the first place?

The NPPF 150 states:

“New development should be planned in a way that avoid increased vulnerability to the range of impacts arising from climate change and should avoid ‘inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk(whether existing or future) ………….and without increasing flood risk elsewhere”

i.e. in this case Golden Green, East Peckham and Laddingford.

The NPPF 155 states:

“inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk (whether existing or future). Where development is necessary in such areas, the development should be made safe for its lifetime without increasing flood risk elsewhere.” [my emphasis]

And finally NPPF 163 states:

“When determining any planning applications, local planning authorities should ensure that flood risk is not increased elsewhere.. . Development should only be allowed in areas at risk of flooding where . . . it can be demonstrated that:

b) the development is appropriately flood resistant and resilient”

TWBC cannot assert, with all honesty, that these developments are appropriately flood resistant and resilient.

The TWBC and the environment agency can apply all the sequential risk-based approach to location development they wan, but essentially TWBC is building on a functional flood plain for the River Medway and will put not only these new homes at risk but other homes at risk in other boroughs.

Prospective buyers will look at these homes and will not buy them. They will be difficult to insure, and they will only have to flood once and people who do buy will not be able to sell them. There are other sites that do not have the River Medway hinterland so close to villages and towns.

Exhibit 5 (TWBC Comment - seeattachment) shows that Capel and Paddock Wood already have the greatest number of homes at risk in the whole of the borough as circled and TWBC propose more homes in these same boroughs. On these figures I wouldn’t look at Lamberhurst either. There is no logic to these Plans. Totally unsound and immoral.

The OS Map at Exhibit 6 (TWBC Comment - seeattachment) shows the cross sections taken from The B2017 Five Oak Green Road on the ridge- to show the topographc affects of surface water flow down the slopes - running into the valley below and into the Medway. Hardstanding on this ridge will cause increased rate of flow causing flash flooding in times of wet weather.

Exhibit 7 (TWBC Comment - seeattachment) shows the profile of the ridge (sections A and C) from Five Oak Green Road (B2017) to the Flood Plain of the River Medway.

Climate change is predicted to increase rainfall intensity in the future by up to 40% (for the Upper End estimate to the 2080s epoch (2070 to 2115) under the new range of allowances published by the Environment Agency. This will increase the likelihood and frequency of surface water flooding, particularly in impermeable urban areas, and areas that are already susceptible. Changes to predicted rainfall should be incorporated into flood risk assessments and drainage and surface water attenuation schemes associated with developments. Is there a specific assessment for Tudeley to assess surface runoff?

Historical flooding

The events of 1960, 1963, 1968, 1985, 2000 and 2009 caused widespread flooding within the north of the borough e.g. at Paddock Wood and Five Oak Green, and areas along the River Teise, due to heavy rainfall over a prolonged period of time. Since this time, significant flooding occurred within the borough during the Winter 2013/14, which included notable flooding from the River Medway, as well as August 2015. Climate change predicts more rainfall and more frequency of flooding. We can all still remember 2013/14in this area.

Assessing Flood Risk and Developments

157 d) of the NPPF states, ‘where climate change is expected to increase flood risk so that some existing development may not be sustainable in the long term, seeking opportunities to relocate development, including housing, to more sustainable locations’

A site-specific FRA is required for all developments which are located in the Environment Agency’s Flood Zones 2 and 3, or developments. As TWBC are putting the bulk of homes in area of potential flood risk has this been achieved? I have not been able to find a specific assessment for Tudeley/ Five Oak Green / Paddock Wood. It could be I have not been able to find the correct document (as there are so many) The appendices A - didn’t have detailed information for these 3 locations

Table 13-1 in the Level 1 Strategic Flood Risk Assessment (SFRA) is quite illuminating. It lists all the call for sites assessed against flood risk. To note:

* In the column ’Site intersected by Risk of Flooding from Reservoirs extent’, nearly 80% of the sites covered Tudeley, Five Oak Green or Paddock Wood (30 out of 38).

* In the column ‘Proportion of site within Flood 3a as of now’, 72% covered Tudeley, Five Oak Green or Paddock Wood (43 out of 60).

* In the column ‘Proportion of site within future flood zones 3a’ 57% covered Tudeley, Five Oak Green or Paddock Wood (45 out of 79).

* None of this analysis has used 2019 information, which bearing in mind TWBC are looking to PLAN to 2036 is not up to date enough.

Table 13-1 shows the sites most at risk and TWBC have chosen nearly every one of them for their ‘Masterplanning’ approach. The cost of attempting to use these sites will require SuDS and other methods to attempt to reduce the impact of future flooding at these sites to the tune of £12M (Appendix 1: Infrastructure Delivery Plan Table 16 p98 and 99). Why would anyone in their right minds chose the worst sites to build on i.e. the ones most likely to flood now and in the future?

The provision to mitigate flood risk and surface water management should be used to protect the current homes at risk- not planning more homes to be at risk and then, to try to protect them!

One important fact to remember

If you fail to Plan- you Plan to fail. TWBC should be looking at the report by JBA having paid for the advice . LOOK at what the report is telling TWBC.

TWBC have not shown they have site specific evidence for these sites and provided evidence they have adequately considered other reasonably available sites that won’t flood!.

TWBC believe they can build on these sites and provide ‘betterment ’at these sites-like the homes will only flood to 100mm not 500mm? TWBC are willing to spend £12M of public and developer funding to do so.

The TWBC Development Constraints Study states on p 9- 2.19 “Flood zone 3 should be a significant constraint” and all the sites at Tudley /Five Oak Green/ Paddock Wood have a % of Zone 3 areas. (Table 3-1 of Site summary assessment) p91-108.

There is a policy emphasis in the NPPF to steer development away from areas with high flood risk. Planning Practice Guidance states that:-

“The National Planning Policy Framework set strict tests to protect people and property from flooding which all local authorities are expected to follow. Where these tests are not met, National policy is clear that new development should not be allowed.’

2.2.2. p7 of the TWells Level l /2 combined SFRA states

“A further review of preliminary flood risk assessments was completed by KCC in 2017 and no Flood risk areas were identified for the borough and indeed the county as a whole”.

Can you please explain why this statement can be made when we have the Leigh Barrier- the biggest in Europe- AND it is being developed to hold more volume of water by 2023? I think there is something wrong with the analysis.

2.4.2 page 10 of the SFRA (Paddock Wood Stage 1 SWMP (2011) and Stage 2 SWMP (2015)) states

“Paddock Wood is an area that has experienced a number of incidents of surface water flooding associated with small watercourses, sewerage and private drainage systems. It was recommended within the Tunbridge Wells Borough Council Level 2 SFRA (2009) that Paddock Wood be designated as an ‘area of critical drainage’. However, formal adoption of Paddock Wood as a Critical Drainage Area did not occur. To better assess the local flooding issue, the Paddock Wood Stage 1 SWMP8 (2011) was conducted to provide a more detailed understanding of local flood risk in the study area. This was extended to a Stage 2 SWMP assessment (2015).

As part of the Stage 1 SWMP, an options assessment was undertaken to identify, shortlist and assess a series of structural and non-structural measures for mitigating surface water flooding across Paddock Wood. Based on the outcomes of the assessment, a range of recommended actions were identified, and an Action Plan was established. It is noted that actions are not specific to individual development sites, but the prioritisation of actions would be affected by any future potential housing allocations.”

So, I gather from the above TWBC that Mitigating measures will be used for this area of Critical drainage.

In section 3 p17 (The sequential risk based approach) the SFRA states:

“It is often the case that it is not possible for all new development to be allocated on land that is not at risk from flooding”

That sentence just makes no sensible-why would anyone chose to build on a site that is at risk of flooding. You are asking for trouble?

Out of 513 call for sites, there are 74 which are at risk of flooding- TWBC chose nearly every site at risk from flooding some the most likely -high- for development and TWBC think mitigating measures will solve the problem? This is development planning at its worst and to think they PLAN this for the next 27 years!!!!!!!!!!!

The following diagrams show one mitigation method won’t work

Exhibit 8 (TWBC Comment - seeattachment) - water, water everywhere…..and the sewage.

In the SHELAA report AL/CA3 and AL/PW1at the very bottom it states,’

‘A mixed water scores is applied as the proposals would represent a substantial demand for water and wastewater treatment, and all would provide significant benefits to Paddock Wood in the form of reductions in existing flood risk’ . TWBC know there is a huge problem here and yet they are prepared to ignore all the issues raised in ‘Issues to consider’ ANOB ( I Part), land contamination, railway, Flood zones etc because it suits them. They use these ‘issues’ in other sites to discount them and many are 100% in Flood Zone1 (No risk) so why change their standards here- especially when the flood risk is High !

Exhibit 9 (TWBC Comment - seeattachment) - water, water everywhere……….. along with the sewage.

I am intrigued as to why TWBC are so determined to build at Paddock Wood. I just wonder if this is one way, they can get developers to pay for flood improvements to this area-but let’s remember this is to alleviate the problems that are recognized now. More homes will mean more problems. It is also worth noting that TWBC are relying very heavily on Development contributions -which are incorporated into the house price. This is not going to provide affordable housing, where large amounts of money will be needed to be spend by the developer trying to mitigate the huge flood issues at Paddock wood and Five Oak Green. If they do get build and sold- one bad flood, which is inevitable, and homeowners will be left with homes they cannot sell or insure.

2.4.2 of SFRA states:

“The two highest contributing factors to flooding are reported to be the overland flows that affect residential properties in the north west and north east and the ability of the surface water network to discharge into the watercourses”

and this is because the land is so flat and impermeable. This is not going to change. I have also read in reports that the ground water system is acknowledged not to be fully understood especially when linked to climate change scenarios and I know Five Oak Green has this issue-as milder wetter winters may increase the frequency of groundwater flooding incidents in areas that are already susceptible. “Current understanding of the risks posed by groundwater flooding is limited and mapping of flood risk from groundwater sources is in its infancy” SFRA 6.6 p37

Still it is believed that these are Areas Susceptible to Ground Water Flooding for example, more than 75% of the area within the 1km grid squares surrounding the Whetsted and Tudeley Hale as well as the area north of Five Oak Green are susceptible to groundwater flooding’

Paragraph 162 of the NPPF, sets out a method to demonstrate and help ensure that flood risk to people and property will be managed satisfactorily, while allowing necessary development to go ahead in situations where suitable sites at lower risk of flooding are not available. Again, why chose so many sites fraught with major difficulties that will only exacerbate over the decades and cause misery to families and TWBC are planning this? There are other sites.

The Sequential and Exception Tests will be used to show it is safe to build at Paddock Wood and Capel Parish, but the Sequential test is supposed to be used to steer new development to areas with the lowest probability of flooding i.e. Flood Zone 1 and the Exception test is to be used as set out in paragraph 162 of the NPPF, to demonstrate and help ensure that flood risk to people and property will be managed satisfactorily, while allowing necessary development to go ahead in situations where suitable sites at lower risk of flooding are not available. Well there are 513-74 = 439 other sites and NONE of these are considered a more suitable location?. There are other safer sites than Paddock Wood. Five Oak Green and Tudeley.

The real TEST- will be- will there be people to BUY these houses…. I have heard buyers are very wary about buying homes in Paddock Wood and Capel Parish, as they know there is a flood risk. There are already sewage problems at Paddock Wood and buyers are not stupid.

I would never buy a house in Paddock Wood or Five Oak Green-there is a huge flooding issue and no amount of :Strategic Storage, flood defences, Increased channel conveyance , new channels, raising level of occupied floors of buildings above ground level- would induce me to buy a home in either of these places. I think it is wrong to expect others to do so. Hopefully builders will realize this too and market forces will prevail-they will have the sense not to build homes they cannot sell- even if there is no common sense at TWBC.

The SFRA at 14.6.2 Future Developments states:

“Development must seek opportunities to reduce overall levels of flood risk at the site, for example by:

* Reducing volume and rate of surface water runoff based on Local Plan policy and LLFA Guidance

* Locating development to areas with lower flood risk

* Creating space for flooding.

* Integrating green infrastructure into mitigation measures for surface water runoff from potential development and consider using Flood Zones 2 and 3 as public open space”

Maybe TWBC should listen to the advice they paid for?

Finally, I note the suggestion in the Summary of Level 2 SFRA (p161), section 5.1.3:

* Floodplain restoration or augmentation represents the most sustainable form of strategic flood risk solution by allowing watercourses to return to a more naturalised state. This may involve measures such as . . . return existing and future brownfield sites that are adjacent to watercourses back to floodplain, rather than allowing new development

Hear hear!

DLP_6883

Barton Willmore for Crest Nicholson

i) Policy STR/PW1 [with ref to Policy STR/CA1]

6.12 This policy offers the overarching strategy for the development of Paddock Wood sites in addition to the preceding over-arching strategic Policy STR1.

6.13 Paddock Wood is identified within the Draft Plan as suitable for a series of urban extensions in line with garden village principles. The NPPF (Para 72) encourages the use of larger scale development for the delivery of significant numbers of homes, and Crest welcomes the opportunity to come forward as part of the broader masterplan for Paddock Wood. However, we have some reservations with regards to the arrangement of policies associated with this allocation.

The Strategy for Paddock Wood

6.14 We note that Criterion 1 sets the overarching housing, infrastructure and facilities to be delivered through the allocation policies (AL/CA3, AL/PW1, AL/PW3). The quantum of development is reiterated in Criterion 4 of STR/CA1. Whilst Polices STR/PW1 [and STR/CA1] are strategic in nature, they do actually go into a significant degree of detail.

6.15 It is this criterion which introduces the concept of a comprehensive masterplan approach for the 4,000+ new dwellings. Whilst we recognise the importance of a comprehensive approach for the settlement as a whole, it will likely prove challenging if seeking to prepare a settlement-wide masterplan and may result in unnecessary costs and delays to delivery of housing, employment and infrastructure.

6.16 As an alternative, albeit a similar approach in principle, we would suggest the preparation of the following:

Town-wide Framework Plan

[] [] [] []

Separate “east”; “west”; and “town centre” masterplans

[] [] [] []

Individual Planning Applications thereafter

6.17 We explore the rationale for this further below (see “masterplanning and delivery” subsection).

6.18 Criterion 2 requires that the development provides for the regeneration and revitalisation of Paddock Wood Town Centre. Whilst the delivery of sites on the edge of Paddock Wood will clearly have an indirect positive contribution to the overall viability and vitality of the Town Centre, the policies explicitly state that the wider allocations should provide for the regeneration and re-vitalisation of the Town Centre.

6.19 It is assumed the intention here being that is the “town centre sites” providing for the direct regeneration and re-vitalisation of the Town Centre, albeit it is understood that the Draft Local Plan does not presently provide for any such “allocations” per se.

6.20 This reinforces our suggested approach above, ie separate actual “masterplans” for the 3No areas. As presently drafted the policy is not “justified” or “effective”, and we consider the aims of TWBC would be better served by separate sub-sections for the 3No areas across Paddock Wood.

6.21 Criterion 3 requires the provision of a “community hub” and “sporting hub”, and Crest welcomes the principle of such provision – to be identified as part of our suggested “town- wide Framework Plan”.

6.22 Criterion 4 [and STR/CA1 #5] requires the provision of flood storage/attenuation and mitigation to reduce flood risk from existing residential areas. We support this requirement, and Crest’s Site (and proposed drainage strategy) will, along with other parts of the allocations at Paddock Wood, help achieve this objective.

6.23 Criterion 5 [and CTR/CA1 #6] relates to the provision of strategic transport links within the Borough and makes reference to the need to provide an off-line A228 Colts Hill bypass. The policy commits development around Paddock Wood to the delivery of this strategic link in this early stage of the plan which is not “justified”. Whereas in reality, it is the County Council (as Highway Authority) that will actually deliver the off-line improvements – with financial contributions from the various development sites in and around Paddock Wood.

6.24 Crest supports the principle of an off-site financial contribution to such works, albeit on a fair and equitable basis with all other strategic and development sites, and of course, subject to the over-arching viability of Crest’s future development.

6.25 Criterion 6 refers to the future redevelopment of potential sites within the existing delineated settlement boundary. It is considered all such sites could/should be identified as part of our suggested over-arching “town-wide Framework Plan”, in order to ensure the comprehensive provision of services and facilities.

6.26 We support the reference in Criterion 7 [and #9 of STR/CA1] as to the need to release Green Belt land to deliver development at the settlement of Paddock Wood [and Capel].

6.27 Criterion 8 states that proposals should provide natural and semi natural green space. We support these objectives, albeit that such provision should be proportionate to the respective development area alongside which it is being delivered. We also note that this reiterates the requirements of Policy OSSR2.

Town Centre+

6.28 We support the stated principles and objectives of Town Centre regeneration. However, it is only “town centre sites” that can assist with the “reconfiguration of the town centre”. It would not be “justified” to seek the peripheral sites to the east and west of Paddock Wood to play any direct part in these regeneration objectives.

Masterplanning and Delivery

6.29 The principle of a comprehensive approach to the future development proposals at Paddock Wood is supported. However, and as previously indicated, this should be based upon:

* A settlement-by-settlement basis; and

* A “town-wide Framework Plan” (as opposed to a “masterplan”).

6.30 As rehearsed previously, Crest’s land interests fall within both Paddock Wood Parish and Capel Parish. It is inevitable that future residents will relate directly with Paddock Wood (as a settlement), as opposed to Capel as a Parish. We can therefore already foresee potential problems and misunderstandings for Crest’s future residents in respect of the administrative practices/operations, ie the maintenance of areas of open space, or the use of any precepts added to Council Tax, etc…, by way of a couple of examples.

6.31 Criterion 1 [also STR/CA1 #1] sets out a two-tier approach to masterplanning of development in Paddock Wood [and Capel]. At the higher level would be a strategic infrastructure plan to set out the provision of infrastructure, which we have suggested should be called a “town- wide Framework Plan”.

6.32 We would then advocate the use of 3No separate “master plans” for each of the following areas – to be prepared reflecting the higher level “framework plan”:

* Paddock Wood East;

* Paddock Wood West; and

* Paddock Wood Town Centre.

6.33 We would support the “town-wide Framework Plan” being a SPD, but we do not consider it necessary (or effective) for each of the 3No masterplans to be SPDs too.

6.34 As presently drafted, there is some repetition between Criteria 1&2, and Criterion 3 is simply a statement. [Also Criteria #1-3 of STR/CA1 (masterplanning)].

6.35 Criterion 3 states that “It is highly likely that the delivery of development will require land equalisation agreements.” We would suggest that it is highly unlikely that it would be possible to create any land equalisation agreement for the entire settlement. It is possible that “understandings” or “agreements” could be reached between the component parts of the relevant “east” and “west” development areas, which reinforces again our suggested approach of the 3No area masterplans. We suggest that this sentence be removed and TWBC can use the proposed town centre framework plan to set out its expectation of any strategic infrastructure whose delivery would be a shared responsibility as regards cost of delivery including infrastructure costs and land and which allocated areas should have shared responsibility.

6.36 Criterion 4 duplicates the content of Policy STR3, and we would ask that clarification is required on how TWBC intends to use its Compulsory Purchase Powers. We interpret this as being that TWBC will use its CPO powers where a small element of an allocated site might hold up delivery of a wider allocation scheme. TWBC should clarify that it will not be intending any wholesale acquisition of land to deliver allocations in their entirety.

6.37 This section also includes reference to Site Allocation AL/PW4, which it requires to be incorporated into the masterplan, along with a land outside the Borough but adjacent to allocations. [This is repeated in STR/CA1]. We do not necessarily consider this would be “effective” or “justified”, and greater clarity is sought in this regard.

Flooding

6.38 This section requires the provision of flood storage/attenuation/mitigation areas and flood defence works to reduce the flood risk to particular existing residential areas of Paddock Wood, Capel and Five Oak Green.

6.39 This is broadly in line with the NPPF (paras 163 and 165) and sustainable drainage systems can be satisfactorily incorporated into any development on site. However, as the sites do not lie within the same hydrological catchment as Five Oak Green, the requirement to provide mitigation measures to this settlement is not reasonable or in fact technically possible. On this basis the policy is not “sound” for the purposes of the NPPF (para 35) as it is not “justified”, “effective” or “consistent with National policy”. To be considered ‘sound’ the policy should delete reference to Five Oak Green.

Transport

6.40 An over-arching “infrastructure plan” would be useful in providing an understanding for determining how the costs of providing the other strategic off-site transport measures and schemes would be apportioned. However, the responsibility for funding and implementation have not been defined. We consider this is the area of the Draft Local Plan that would benefit the most from greater clarification and understanding.

6.41 Crest supports the principles of what is being sought to be achieved, however we presently have reservations as to the “justification” and “effectiveness” of the actual delivery thereafter.

6.42 Sustainable transport improvements will allow the expansion of Paddock Wood to improve accessibility as well as promote active and healthier lifestyles. A focus of the masterplan layout is to place pedestrians (and other non-motorised users) at the heart of the design of streets and spaces. Improvements to existing public rights of ways, and the creation of new functional and leisure cycle routes will also extend the range of destinations which can be reached sustainably.

Landscape

6.43 The Strategy for Paddock Wood states that developments must provide natural and semi natural green space and a range of formal and informal open space; and provide strong multi- functional green and blue infrastructure to tie in with the surrounding landscape and to integrate with flood defence measures. This policy is supported by the “Green Infrastructure Framework” (TWBC, 2019) and complies with requirements of the NPPF (para 127). Therefore it is considered to be sound and in accordance with the NPPF (section 12).

Infrastructure

6.44 Crest recognises and supports the provision of supporting infrastructure related to its proposed development. This criterion provides a list of suggested infrastructure improvements that must be provided for to mitigate any impacts.

6.45 We largely support the listed items of infrastructure that may need to be provided across the settlement of Paddock Wood, and have suggested the preparation of a “town-wide Framework Plan” would be the most appropriate manner of apportioning these across the development sites coming forward.

6.46 We would reiterate our concerns that greater clarity is required in respect of the “transport measures” being sought, and would also seek specific clarification in respect of “secondary education” places:

* Policy STR/PW1 seeks the expansion of Mascalls Secondary School (via financial contributions), which Crest fully supports; whereas

* Policy STR/CA1 seeks either a new Secondary School (to the east of Tonbridge) or the expansion of Mascalls Secondary School, to which Crest only supports the latter (in respect of its land interests at Paddock Wood settlement). This is because we have concerns that it would result in undue travel demands that would result from a school that would be remote from the development.

Summary of Policy STR1/PW1 [Policy STR/CA1]

6.47 We support the overarching aims of Policies STRPW/1 [and STR/CA1], however there remain a number of concerns relating to the overall structure of the policies, especially when considered in context with Policies AL/PW1 [and AL/CA3]. These policies, although strategic, go into a significant degree of detail that extends beyond the purposes of a strategy policy. Furthermore, we have reservations regarding the overall structure of the policies and the parish-by-parish based approach as set out above, which has led to a significant degree of unnecessary crossover and repetition of policies across the Plan, contrary to the NPPF (para

16).

6.48 With regards to the detail of Policies STR/PW1 [and STR/CA3], significant clarification needs to be provided in the next iteration of the Plan in order for it to be “effective”, and we look forward to the opportunity of working alongside TWBC in helping to develop these policies for Paddock Wood.

6.49 Specifically the “masterplanning” and “delivery” approach could be far more “effective”, and the requirements for each of the component parts of the development need to be better “justified".

6.50 Notwithstanding the above concerns and requests for greater clarification, Crest supports the overall thrust of Policy STR/PW1 [and Policy STR/CA1].

[TWBC: see full representation and supporting documents Appendix 1, Appendix 2 Part 1 , Appendix 2 Part 2 and Appendix 3]. See also Comment Numbers DLP_6836, 6844, 6847, 6843, 6855, 6859, 6860, 6863, 6865, 6866, 6869-6870, 6872, 6877, 6883, 6890, 6897, 6909-6911, 6926, 6928, 6931, 6933-6937].

DLP_6950

Gilly Legg

As a resident of Tudeley for 47 years I object, in the strongest possible terms, to the above policy, the proposal to build 2,600 houses (the number seems to fluctuate) in this tiny little hamlet of Tudeley. The proposal for Tudeley, let alone for East Capel, is unsustainable and, in it’s present form, not possible to achieve realistically.

Most of the houses in Tudeley (approximately 90 residents) have no main drainage, no mains gas and fragile internet service. The water supplies to Tudeley have always been problematical, particulary as they have not been properly maintained down the years. TWBC have issued no plans, or even ideas as to how they would provide the infrastructure to service 2,600 houses in Tudeley. Each house would have at least 1 or 2 cars , would you be able to build in sufficient roadways to accommodate this number of vehicles and provide sufficient parking spaces within the developments? Residents in Kings Hill, West Malling are having to use Waitrose car park and other public facility parks because there is insufficient parking.

Drainage and sewage would be a big problem particularly as the water table is only a few feet below the surface and the whole area is laced with ancient springs and dew ponds which are apt to overflow after heavy rain. And who will supply the water? I think that Southern Water would be a bit pushed considering their current finances

TWBC put out a request for land release and they hit the jackpot. TWBC had fallen way behind in providing the allocated number of houses to be built per year. They were being pressurised by Central Government when, lo! And behold! Along comes Hadlow Estates offering thousands of acres, all of it greenbelt. What could be easier for TWBC than to do a deal with Hadlow Estates, an eager seller – dump 60% of their housing requirements on the furthest boundary of their borough and they have only one, very compliant, landowner to negotiate with – problem sorted. HOWEVER no thought was given as to the affect on local residents or the nearby town, Tonbridge. How can this tiny little place absorb such a massive increase in population?

Where will the children go to school? Capel Primary and Tonbridge Secondaries are full to capacity.

How will they get there? Bus services are about 3 per day at present.

Where can they sign in to a doctor’s practice? Nowhere – all practices are already over subscribed.

Commuters to London – where on earth are they going to park and would they even get on the train, unless trains are made much longer – platforms would have to be extended.

The effect on local road networks will be catastrophic. Tonbridge is already at a standstill for parts of the day and the periphery roads towards Five Oak Green through Tudeley carry an excessive amount of traffic. The roads are not wide enough but widening them requires taking land from existing properties many of which are listed.

This development would not be Tudeley Garden Village, it would be Tonbridge Urbanization without the requisite facilities. There would be no room for gardens as that space would be used for parking cars; all local habitats such as the woodlands, hedgerows, ponds, paths and bridleways would all disappear from this ancient area. In 910 AD Tonbridge (Tunnebridge) was a thriving market town, long before Tunbridge Wells was even a speck on the horizon, and Tudeley was part of that history being so close to the River Medway which was the main form of transport by horse drawn barges.

Everyone is aware of the desperate need for housing and I think that it would be reasonable to expect some housing to be built on this land, maybe 50 houses, but 2,600, that is just unrealistic. The plan that has been submitted has been badly thought out and needs some drastic rationalising and a great deal of common sense, because it is simply not achievable without making Tudeley a complete slum and a very uncomfortable place for the existing residents.

Affordable Housing – this is just a joke – what developer is going to put up housing that is on the market for £150,000, a liveable house/flat, not a pigsty. That is supposed to be the name of the game, is it not? There will be no affordable housing until the bank interest rates increase and mortgages become more difficult to purchase – then the price of property will drop. No Social Housing Company will touch this project for 2 reasons - the project is not deliverable and secondly, too much local opposition.

TONBRIDGE have submitted on their own account against this submission. Tonbridge have been fulfilling their need of housing requirement by infilling over the last 5 years and they are now up to capacity. Tonbridge facilities will be heavily jeopardised by a sudden increase of population, albeit over a number of years, of 5,200 people, that is on the basis of 4 per family.

This application STR1/CA1 should be withdrawn and I think you should consider all the responses you have received with care and sensitivity. After all, Borough Councillors are elected by the people of the Borough and the people are now saying, not asking, that their voices should be heard. If their opinions are not heard and acknowledged then it must be assumed that democracy has died on the Borough Council. PLEASE WILL YOU THINK THIS ONE OUT AGAIN and this time be realistic.

May God, and common sense, guide you in your deliberations.

DLP_6953

Cllrs Tyler, Redman, Bate and Hine
Shipbourne Parish Council

On behalf of the above Councillors at Shipbourne Parish Council, I have been asked to forward our concerns on the draft Tunbridge Wells Local Plan. We have particular concerns about the STRATEGIC SITES: LAND AT CAPEL AND PADDOCK WOOD, AND TUDELEY which border Tonbridge. Tonbridge is our nearest service town and is already extremely congested. We object to the level of proposed development as it will cause an increase in traffic and put pressure on our local services, amenities and infrastructure such as schools, transport and GP's surgeries. We also object to the loss of 600 acres of greenbelt.

DLP_6995

Rydon Homes Ltd

6. The basic concept of creating a new "garden settlement" at Tudeley is not considered to be sound and therefore will not survive examination in terms of Paragraph 35 of the NPPF. In particular the proposed policy is not:-

justified because there are reasonable alternatives that would avoid the serious adverse environmental impacts that would arise from this development.

effective because the infrastructure that is necessary to support the scheme will not be in place in time to deliver the development, even in significant part, within the plan period.
consistent with national policy - which seeks to balance competing objectives of the need for more housing against the protection of the environment. In this case the balance should fall in favour of avoiding the extensive harm to the environment that will result from this development.

7. The main reason why this development proposal should not be taken forward into the Reg 19 submission draft plan is that it puts at risk the soundness of the Plan as a whole and this will potentially prejudice the adoption of the Plan and at least delay its' progress whilst Main Modifications to remove the proposal from the Plan are considered and processed. The policy makes the whole Plan highly controversial and this will have consequences for the timing, complexity and cost of the plan process. These are not justified when alternative strategies are available.

8. The proposal will involve the loss of an extensive tract of open countryside which, although not within the AONB designation, is attractive and unspoilt including many areas of special ecological and environmental importance, notably Ancient Woodland, Listed Buildings (including the Grade 1 Listed Church of All Saintes), areas of Archaeological Potential, Habitat of European Protected Species and adjacent to the AONB and a Biodiversity Opportunity Area. The side does not lie adjacent to any substantive settlement and will manifestly change the character of the site and a wide surrounding area from undeveloped rurality to an urban area of Tonbridge and then another short gap to the east to Five Oak Green which itself is close to an expanded Paddock Wood, the Plan will introduce what is effectively an urban corridor between Tonbridge and Paddock Wood.

9. The selection of a site that is split by the main railway line and bordered by a higly trafficked main road is counter-intuitive in terms of objectives of connectivity and cohesion of the various parts of the proposed settlement. This simply presents problems for the creation of a unified settlement, increases infrastructure costs and sterilises development opportunities due to noise along both transport corridors.

10. The list of new infrastructure that will have to be provided, and mainly front-loaded, is daunting. The concept is unprecedented in Tunbridge Wells Borough and Members will have to be assured that the Council has the skill set and resources to manage this type of proposal properly at the same time as managing the expansion of Paddock Wood. One such project is a challenge, two is an impossibility.

11. The transport infrastructure that is required cannot be guaranteed in terms of practicality, cost/viability or timing. The route, costings, land assembly and planning consent for the connection to the proposed Colts Hill by-pass (in order to by-pass Five Oak Green) are all, as yet, undetermined. The timing is therefore uncertain but must await the completion of the Colts Hill by-pass which itself has been decades in plan but without any reality. Also, the project requires the introduction of a bus service simply to serve the Garden Settlement. Existing bus services run primarily from Paddock Wood to Maidstone and Tunbridge Wells, picking up Five Oak Green on the way. There is a variable timed but roughly hourly Autocar bus service from Paddock Wood to Tonbridge through Tudeley but this is focussed on a school-day service. It is more convenient to take a train between Paddock Wood and Tonbridge. The viability of a new bus service and the ability of this development to subsidise it are questionable.

12. There is an obligation to assist in the mitigation of flood risk in Five Oak Green but there appears to be no firm flood mitigation scheme proposed or details of costs, funding, practicality or timing. The requirement for the garden settlement to alleviate existing flood risk at Five Oak Green is unlawful in the light of the tests set out in the CIL regulations 2010.

13. The evidence base to the Plan does not include any meaningful viability assessment of this major development proposal. There being no existing infrastructure to assist provision in the early years of development, the new education, health, retail, drainage, utilities, transport, highways, social and leisure infrastructure will have to be fully front loaded. Without a detailed analysis and careful viability assessment this proposal can only, at best, be considered to be aspirational and there is insufficient evidence to give the necessary assurance that provision of infrastructure will be in place to deliver the suggested 1900 dwellings within the Plan period.

14. The SHELAA for the site assumes a 5% gross to net ratio, which is wholly unrealistic. It would be more realistic, given the level of necessary infrastructure to be delivered at this site, to apply a 60-40% gross to net. Based on 30 dph the land could deliver 2,834 units, 15 dph 1,417 units. The policy assumes 2,500-2800 new dwellings and it is questionable whether the site could deliver this, unless densities are increased which would likely have a detrimental impact on the landscape, heritage and flood risk etc.

15. The resilience of the Local Plan upon the success of this proposal is too great. It places the Plan as a whole at risk of being unsound because it is not justified, effective or sufficiently consistent with natioanl policy to protect open countryside and other important environmental considerations. This highly controversial policy should be withdrawn from the Plan - event if that is only to allow a longer period for the essential details and practicalities to be fully costed and investigated allowing a properly considered proposal to come forward in a future plan. 78% of the entire housing target is either allocated to Paddock Wood or Tudeley and this unbalanced strategy is too risky.

[TWBC: See full representation]

DLP_7057

Stewart Gledhill

[TWBC: see full report, including diagrams, figures and pictures].

As a member of the SaveCapel Steering Team and the campaign, I am submitting the attached Representation in response to the consultation under Regulation 18 -- The Town and Country Planning (Local Planning) (England) Regulations 2012.

I understand the national policy constraints applied to the development of the Local Plan and will watch its progression post-consultation and the evolution of national planning policy with great interest.

OBJECTION – POLICIES STR/PW1 & AL/PW1 CAPEL EAST

OBJECTION – POLICIES STR/CA1 & AL/CA1 TUDELEY

FOREWORD

This report has been prepared by the Flooding (including strategic flood risk and sewerage) Group on behalf of the SaveCapel Campaign Team. This group is made up of seven local residents who have lived in the area for a considerable length of time and are all familiar with the degree, frequency, and location of the flooding problems in the area which quite simply does flood on a regular basis. Members have detailed knowledge of flood prevention measures already taken and those being investigated to prevent flooding in Capel. In addition, members include professionals in their field of water management science, surveying, engineering, construction and accountancy.

Whilst this report raises specific issues relating to each of the above policies in the Draft Local Plan, there are also many common matters and relevant background information sections. Rather than duplicate many sections of this representation, it is intended that the contents are read as our response to the consultation on each of the above policies.

Whilst we all have many concerns about the development in general these are being addressed by other working groups. Our primary concern is to demonstrate the danger and costs that flooding issues will produce with a view to getting the existing plan moved to a more sensible and suitable location that will reduce costs and bring it into line with government policy of not building on areas liable to flooding.

1 : GEOLOGY

1.1 The soil is described in the National soil resources Institute as “Loamy and Clayey floodplain soils with naturally high groundwater”.

1.2 Geology of the site mainly comprises of impermeable clay which does not drain easily and is susceptible to volume change, with changes in moisture content. The undeveloped land at both sites PW1 and CA1 is likely to contain high levels of sulphates from the agricultural use of the land which attacks the integrity of concrete. Historic Ironworks and mining deposits are scattered over the southern side of CA1 with shafts up to 15 metres deep.

1.3 Special material and Foundation design are likely to be required and building out of the ground would be costly with possible retaining structures and terracing design required to accommodate sloping ground in places.

1.4 The map below of the Capel area (Figure 1) has been built using the boundary maps from the Tunbridge Wells Borough Council Master Plan and the British Geological Society UK bedrock (625k Version 5) map and the British Geological Society UK superficial geology map. This shows sites CA1 Tudeley and PW1 Capel East in red outline.

[TWBC: for Figure 1, see full report, including diagrams, figures and pictures].

1.5 Variations in the superficial geology are shown, with the lighter colours indicating mainly clay and the purple areas largely sand. * CLSS – Clay Sand and Silt. * SAGR – Sand and Gravel.

1.6 The geology of a catchment can be an important influencing factor in the way that water runs off the ground surface. This is primarily due to variations in the permeability of the surface material and bedrock stratigraphy.

1.7 Potential development parcels located in the west of Paddock Wood are underlain by the Tunbridge Wells Sand Formation consisting of interbedded sandstone and siltstone whilst sites in the east are underlain by the Weald Clay Formation consisting of mudstone.

1.8 The area is therefore likely to have a varied response to rainfall events, with eastern areas of Paddock Wood underlain by typically less permeable mudstones being characterised by a quicker catchment response. Flood volumes will be more critical for areas underlain by the less permeable Weald Clay Formation with areas underlain by the Tunbridge Wells Sand Formation having a slower response to rainfall.

1.9 There is a variety of superficial (at the surface) deposits including River Terrace Deposits, head Deposits and Alluvium.

1.10 However, both of the proposed allocations have very similar immediate substrates; namely alluvial deposits under a clay cap. This is shown by the beige and purple areas. These immediate substrates will require significant ground works to make any buildings stable, as they are inherently unstable and liable to subsidence.

1.11 The southern area of CA1 shows the extent of the sandstone bedrock (the purple area that is darkly shaded). This is sufficiently porous that it allows the aquifer it contains to self-balance by expelling water through springs. This higher area is capped with impervious clay, which means that surface water run-off from this area must be considered a serious risk (see Tudeley levels map Figure 5).

1.12 In addition, this aquifer will seriously hinder excavations for building, sewage transport, and drainage; puncturing the clay cap will release the aquifer and mean that such excavations and any permanent holes will require constant pumping. The effects of compression on the aquifer of any buildings and roads/driveways, as well as the compaction of the surface clay, will affect the ability of the surface and underlying geology to take up surface water.

1.13 All three types of substrate have porous aquifer substrates under a clay cap. If that cap is punctured by excavations, pipes and flood defences, then the risk of aquifer leakage will be very high. In addition, the aquifer is often above capacity, as shown by the large number of local springs. This means that its capacity for taking additional water load will be low or indeed will have a negative contribution to water absorption. Interfering with this aquifer will have a seriously detrimental effect on flooding prevention.

2 : TOPOGRAPHY

2.1 Topographical history: From The History & Topographical Survey of The County Of Kent. Published in 1798. “Capel is a very obscure and unfrequented place, the surface of it is very low and flat, except in the middle of it where there is a small rise, on which the church stands; … in the rest of the parish it is deep miry clay.”

2.2 Bagshaw’s Directory of Kent in 1841 refers to the soil as being “mostly a miry clay”

2.3 This clay is hydratable and extremely unstable; it is subject to swelling when wet and to contraction when dried out.

2.4 The only major change between 1798, 1841, and 2019 is that while we still have thick wet clay, and still have a slope, since the 1840’s there has been a railway embankment in place to prevent the water from getting away.

2.5 Levels and Topography: The map below (Figure 2) has been built using the boundary maps from the Tunbridge Wells Borough Council Master Plan and the European Union 10 metre resolution Digital Elevation Model. This Digital Elevation Model is produced from data collected as part of the SRTM (Shuttle Radar Topography Mission) and ASTER GDEM (Advanced Spaceborne Thermal Emission and Reflection Radiometer Global Digital Elevation Model) projects.

[TWBC: for Figure 2, see full report, including diagrams, figures and pictures].

2.6 What this map shows is how little variation in levels across the PW1 and the northern side of the CA1 area: for the majority of both areas there is around 1m variation in levels. Such small variations in Height above Mean Sea-Level [HSL] indicate a greater risk of flooding.

2.7 The clay cap, aligned with slower drainage times and an over-abundance of supply, would mean that these areas are more likely to flood, even under moderate rainfall or moderate storm events.

2.8 CA1 Flood Risk: The Draft Local Plan has not included a comprehensive assessment of flood risk at the proposed site in Tudeley. However, Flood Risk Assessments were prepared in 2018 by Waterco to inform KCC’s Mineral Plan, sites M10 Moat Farm and M13 Stonecastle/Hartlake, which are in close proximity and relevant to this allocation (see Figure 7, page 16). The issues relating to Stonecastle Quarry are discussed in more detail in section 7 below.

2.9 The border of the M13 site is within 500 metres of CA1 and this FRA¹, in particular, is relevant to our understanding of the ground levels in the allocation. Waterco predict flood water levels of up to 1.12m, calculations have been used for the “Defended 1% AEP + 35% Climate Change event” modelling, and shows that much of the solar farm at risk of being seriously flooded (see Figure 4 below).

2.10 The land levels from the Hammer Dyke moving south towards the railway line remain low before dropping lower in the fields prior to the start of the solar farm. The Waterco report data indicates a potential flood risk level at this point of up to 1.7 metres, allowing for climate change of 35%.

2.11 Furthermore, the Waterco mapping clearly shows much of the land in M13 to be at risk of flooding between 0.6 metres to 1.2 metres, with some areas at risk of flooding between 1.2 - 2.4 metres. The EA stress concern in a letter dated 5.7.2018 contained within the document that flooding could be increased elsewhere as a result of the proposed mineral extraction. This has implications for CA1 and this FRA provides the best evidence available.

2.12 Ground survey: The Flood Group decided that further investigation into the ground levels of the north-east section, in particular, of the proposed CA1 development site (north of the railway line) was needed.

2.13 A levels survey was undertaken from footpaths at both the Tudeley and Capel East sites on the 13.7.2019. This used laser technology and followed a traditional rise and fall method. The results of the survey confirm this minimal variation of ground levels.

2.14 A map showing the path of the survey undertaken at CA1 Tudeley is shown below (Figure 3):

[TWBC: for Figure 3, see full report, including diagrams, figures and pictures].

2.15 This map shows the position of each survey point and the blue dotted line shows a cross-section of the mean values. This should be read in conjunction with the graph below (Figure 4) which highlights the recorded levels and anticipated flood levels from point A to B.

2.16 From the Environment Agency’s Flood Model, the highest flood level above sea-level in the proximity to the site is 18.4m which is the likely path level rather than field level at the border position of CA1 (circled).

2.17 The graph below (Figure 4) shows the variation in levels along the survey undertaken compared with anticipated flood levels and should be viewed in conjunction with the survey map above (Figure 3):

[TWBC: for Figure 4, see full report, including diagrams, figures and pictures].

2.18 The Datum is taken from the Waterco data and deduced land levels at 16.030m 16.660m 15.780m 16.710m and 22.925m ending at Lilley Farm are shown below the horizontal line. The figures of 1.67m 1.09m 1.92m and 1.0m above the horizontal line are approximate levels to which flood water could reach based on the Waterco data¹ [¹ Flood Risk Assessment for Site M13: Stonecastle Quarry Waterco consultants 13-July-2018 Online: consult.kent.gov.uk/file/5165135].

2.19 These levels do not include the assessment of climate change over the ‘lifetime’ of the proposed residential development (>100 years) and therefore understate the potential flood risk (see section 10).

2.20 Assessment of the data and levels indicates flooding to a depth of approximately 1.12 metres in fields around the Hammer Dyke.

2.21 The Flood Group’s levelling survey revealed fields to be reasonably level from the Hammer Dyke to Sherenden Farm, but then dropping significantly by up to O.8 metres giving a potential flood depth of considerably more than 1.12 metres up to the Solar Park from where the land starts to rise at the southern end.

2.22 Land to the east of CA1 Tudeley running to Capel East, from available data, generally appears lower.

2.23 These maps and figures demonstrate that there are three areas to note:

Firstly, that there is so little variation in levels that flood water is likely to spread across a significant proportion of the entire area. Over much of the northern area of CA1 and the majority of PW1, there is less than 1m variation in levels above Mean Sea Level.
Secondly, that the Environment Agency’s flood risk model has obvious shortcomings in this area. For example, it show areas that are lower, in terms of level above Mean Sea Level, than immediately adjacent higher areas not flooding, while those higher areas do flood.
Thirdly, given the small variations in level over the entire PW1 area and the norther section of the CA1 area, there will be a much higher risk of flooding as the effects of climate change continue to develop. This is further explained in section 10.

2.24 Essential flood protection systems, such as bunds, flood storage and so on, are less likely to be remain feasible options; there is a limit to the size these can be built to, without impacting on the development’s viability.

3 : FLOOD HISTORY

3.1 Tunbridge Wells Borough has a well-documented history of flood events; the main sources of which are from fluvial (river/watercourse) and pluvial (surface water) sources. The events of 1960, 1963, 1968, 1985, 2000 and 2009 caused widespread flooding within the north of the borough e.g. at Paddock Wood and Five Oak Green, and areas along the River Teise, due to heavy rainfall over a prolonged period of time:

November 1960: The heavy and prolonged rainfall caused widespread flooding across much of Kent as the Rivers Medway, Teise and Beult exceeded their channel capacities. The areas surrounding Five Oak Green, Lamberhurst, Buckhurst, Ashurst and Ashour Wood are recorded to have flooded during this event.
November 1963: The Rivers Medway, Teise and Beult exceeded their channel capacities. However, the flood event was not as extensive as that during November 1960 as records only show the area north of Tudeley Hale and Whetsted to have flooded within Tunbridge Wells Borough.
September 1968: Prolonged heavy rainfall associated with a slow-moving depression and thunderstorms caused severe flooding across the south east of England. Between the 14th and 15th of September, 150mm-200mm of rainfall was recorded across Kent and consequently the river flow on the Medway was recorded at 225 cubic metres per second. As a result, the River Medway exceeded its channel capacity and caused extensive flooding in many areas of the borough including Tudeley Hale, Five Oak Green and Paddock Wood.
Christmas 1999: Floods in Five Oak Green, the playing field and the road leading down to it. The centre of the village was flooded with water entering a number of homes and the village shop. Residents erected barriers at each end of the village to prevent vehicles passing through the village causing problems with their bow waves. The Alder Stream overtopped its banks and the path beside it became impassable due to the rate of flow and depth of water. One end of Nortons Way and all of Willow Crescent flooded. The small lane leading down to the hop processing plant flooded along with all the land at the end of it down to the railway. Fire Engines were brought in to pump out the Village, Nortons Way and Willow Crescent. Fifty properties in Five Oak Green flooded including the village shop. The Alder stream overtopped its banks, surface and ground water inundated the foul water system, and gullies and culverts failed. Half of the village lost power.
May 2000: The Alder Stream overtopped. Areas of Five Oak Green were flooded.
October 2000: The wet weather in the autumn of 2000 resulted in many river catchments being subjected to multiple flood events. Large areas of Kent and Sussex were left under water as several rivers burst their banks. The river flow on the Medway exceeded that of 1968 at 260 cubic metres per second. Consequently the reservoir behind the Leigh barrier rose by 3cm per minute on an area of 278 hectares. The barrier had to be released gradually which helped protect Tonbridge but the flooding in Five Oak Green, Yalding and other villages downstream made national news.

The police were forced to close the Five Oak Green Road after residents erected barriers at each end of the village to prevent vehicles causing further problems with their bow waves. Parts of the road had water up to 2 feet deep. At least one house on that road was flooded to the depth of 3 feet, others in the village reported depths inside properties of 18 inches. Properties affected included parts of Nortons Way Willow Crescent, around the village green - The Forge, Whetsted Road and Falmouth Place. Householders in the village renewed their call for better drainage systems after they had been evacuated from their flooded homes for the third time in 10 months.

Paddock Wood also recorded flooding at Mascalls Court Farm and at the Hop Farm livestock drowned. In total, around fifty properties were flooded from the Gravelly Way Stream and Tudeley Brook.
January 2002: Firefighters spent four hours pumping out flood water from the King’s Head Pub and neighbouring cottages, Badsell Road, and Five Oak Green Village.
2008/2009: Southern Water recorded sewer flooding for Five Oak Green. The EA also describes issues of hydraulic overload from foul sewers and surface water in Five Oak Green.
2011: Five Oak Green Rd / Tudeley Lane flooded.
2012: Roads flooded - Colts Hill, Willow Crescent, Church Lane, Alders Road, and Badsell Road.
March 2013: Flooding in Alders Road, Capel, to a depth of 30cm - the worst in living memory.
December 2013: During the winter of 2013-14, a series of Atlantic depressions brought heavy rainfall and stormy conditions to much of England and Wales when Kent received 242% of the long-term average rainfall causing widespread flooding.

Of particular note is the storms of 19th-24th December when 110mm of rain fell on already saturated catchments which caused river, surface water and foul water flooding across the area affecting hundreds of homes and businesses, including in Five Oak Green and Paddock Wood.

[TWBC: for image of Five Oak Green village 2013, see full report, including diagrams, figures and pictures].

The Army were put on standby for evacuation assistance when the whole of the Medway valley was flooded upstream and downstream. The Leigh Barrier had to be released to relieve the water volume upstream and failed to stop Tonbridge from flooding. This was close to a national emergency.

Five Oak Green suffered a power cut and the pumping station failed. As a consequence roads and properties were flooded to such an extent that some families had to vacate their homes for several months.

Since this time, significant flooding occurred within the borough during August 2015, July 2017, and July 2018. 3.2 Flooding incidents have been reported historically in Paddock Wood, with the corner of Church Road, The Cedars and The Ridings being subjected to floods every year. The area to the north of the railway is reported to have been affected by flooding from the rivers Teise and Medway (flood events occurred in 1960, 1968, 2000/2001, and 2013/14). Flooding south of the railway is noted to generally be associated with heavy rainfall, resulting in flooding from surface water and watercourses that flow south to north through and adjacent to Paddock Wood. 3.3 Hartlake Road also has a history of regular flooding. Last winter it was closed for a complete 4 week period! 3.4 At Crockhurst Street, the south west part of the CA1 Tudeley proposed development, which is one of the highest points of the area, flash flooding often occurs (left and centre below):

[TWBC: for images referred to above, see full report, including diagrams, figures and pictures].

3.5 Surface water flooding at the site of the Solar Farm in June 2014 is shown in the above picture (right). This is immediately adjacent to the eastern boundary of CA1 north of the railway.

3.6 Sherenden Road has a history of flooding - with flooding of the Roads and adjacent fields up to 3 feet deep in places. The road was closed three times in two weeks in 2014:

[TWBC: for image of record of road closure referred to above, see full report, including diagrams, figures and pictures].

3.7 CA1 Tudeley north side of railway floods up to Lilley farm and at the lower section of the south of the site adjacent to the railway embankment. In May 2018, not a notable flood event for the borough, surface water flooding was severe along Sherenden Road at Lilley Farm:

[TWBC: for images of Lilley Farm referred to above, see full report, including diagrams, figures and pictures].

3.8 Rail tracks that dissect the CA1 plan have flooded in the past.

3.9 Historical points of interest:

3.10 The accounts records at Tatlingbury, in the 1700‘s, record the costs of drainage and the failed attempts at improvement. The new method was to dig ditches in the direction of the river and then backfill them with brushwood. This failed because the flood plain covered the same area as it does today. The water table is 450mm, in the wet season, in between the industrial estate and Badsell Roundabout. There will be no improvement until the water table and the depth of the river are sustainably lowered. This could then interfere with bore holes and aquifers affecting water quality.

3.11 The John Bowra surveying map of Stone Castle c 1760 shows: Great Mead, Footway Mead, Bridge Mead, The Marsh Orchard, Little Huntley Mead, and Great Huntley Mead. Other names: Whetsted, Hart Lake, Poors Mead, Ottershaw, Moat Farm. Lilly Hoo. Tudeley Brook farm. Gold Hill Mill, Little Mill. Oak Wear.

3.12 KCC Heritage maps 1871 – 1890 show that: Whetsted was also known as Washlingstone. The Hop Farm was Wateringbury.

3.13 In 1545 King Henry III was assembling an army and navy in Portsmouth to meet the threat of a French invasion. Tonbridge was described as being a small town on the Medway much subject to flooding and poor ground hampering the efforts to get men and materials from London and the North down to Portsmouth.

4 : REGULATORY POLICY & GUIDANCE

4.1 PLAN NEEDS TO MEET NPPF:

Section 149: Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk.
Section 155: Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk (whether existing or future). Where development is necessary in such areas, the development should be made safe for its lifetime without increasing flood risk elsewhere.
Section 157: All plans should apply a sequential, risk-based approach to the location of development – taking into account the current and future impacts of climate change - so as to avoid, where possible, flood risk to people and property….. seeking opportunities to relocate development, including housing, to more sustainable locations.
Section 158: Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower risk of flooding (such sites are available).

4.2 FLOOD RISK AND CLIMATE CHANGE - GUIDANCE FOR PLANNERS:

Inogen Environmental Alliance Inc. (June 2019): The NPPF sets out how the planning system should help minimize vulnerability and provide resilience to the impacts of climate change, and alongside planning policy guidance demonstrates how flood risk should be managed now and over the lifetime of the development, taking into account climate change. Consequently, the Environment Agency (EA) has recently updated their climate change guidance in 2016, providing climate change allowances to support the NPPF which is now split by river basin district rather than a blanket percentage increase in river flow. See photo of River Medway, Tonbridge 2013 below.

If the Site is within a floodplain then the proposed development is typically raised above the flood level. The exact level of land raising is dependent on the predicted flood levels and the EA allowance for climate change. However, the displaced floodwaters will need to be compensated for through flood compensatory water storage. This impacts development as the location of the storage will undoubtedly impact the masterplan as it needs to be located within or on the edge of the floodplain and demonstrated on a level for level basis. This could also potentially affect the developable area, building design and access. If climate change is not considered, the modelled water levels are likely to be deemed too low and the planning application objected by the EA on flood risk grounds.

The EA’s Flood Zones do not take into account climate change so if not formally provided by the EA, hydraulic modelling may be needed to be conducted which can be time and cost prohibitive.

[TWBC: for image within text, see full report, including diagrams, figures and pictures].

Aside from river flooding, surface water is a key risk as demonstrated in the Pitt Review- the Government’s response to the 2007 summer floods. The EA climate change guidance applies climate change allowances to peak rainfall to determine runoff rates. This may mean you need larger attenuation storage to protect the proposed development for its lifetime. As per the risk from rivers, the location of surface water attenuation storage or other forms of Sustainable Drainage Systems (SuDS) will impact the masterplan in terms of developable area, building design and access. In addition to the statutory planning requirements, building occupiers are increasingly aware of the potential for flooding to impact their operations. As a result, some major occupiers are imposing their own flood risk standards which are more stringent than the planning requirements. Where an investor is considering an asset that satisfies the statutory requirements, this may not be sufficient to truly consider the potential for re-letting, with some occupiers being unwilling to compromise their own demanding flood standards.

4.3 RECOMMENDATIONS FROM OTHER AGENCIES:

4.4 Environment Agency document – Lessons learned from autumn 2000 Floods - Ground water from hidden springs brought misery to many. Despite flows being held back on the river Medway by the Leigh barrier the swollen rivers of the Medway, Teise, and Beult converged on Yalding leading to extensive flooding. Five Oak Green and East Peckham flooded up to 5 times in 2000. The policy statement 6 from this EA document states “when developing in the floodplain prevention is better than cure”.

4.5 In 2000, the United Nations Economic Commission for Europe listed points to note: “2. Human interferences with natural processes has increased the threat of flooding and should where possible be reversed and in future prevented”.

4.6 From KCC select committee report 2007 - “flooding can happen at any time in any season and with enough severity to overwhelm defences” - as we know, we have no formal defences.

4.7 I D Oliver, of the Romney Marsh area Internal Drainage Board, wrote - “Few if any surface water systems would have coped with the intensity or duration of rainfall experienced in other parts of the country, we in Kent were very fortunate to have escaped”

4.8 Mr Older, Flood Risk manager of EA quoted “Flash flooding and water run-off was a key contributor to flooding in 2007”.

4.9 Historically, a point of reference for heights above sea level has been provided by reference to benchmarks, which were located, in times gone by, at intervals all around the country. Given the flooding disasters in recent times, and bearing in mind the Somerset Levels as a particular case in point, perhaps we should remind ourselves of a statement made at the time. “If you build on an area that floods, you will flood.”

4.10 Let us also remind ourselves of the statements made by the Government and others after recent flooding events, such as the Somerset Levels, that “lessons would be learned about building in areas at risk of flooding”.

5 : PLANNING PRECEDENT

5.1 MAIDSTONE LOCAL PLAN – REGULATION 19 REJECTION DUE TO FLOOD RISK: Neighbouring Parish site located at Yalding, downstream from Capel, has been rejected by the Inspector:

Former Syngenta Works, Hampstead Lane, Yalding. Extract from Inspector’s report: “The former Syngenta site at Yalding is a large flat brownfield site that was previously used for agro-chemical production. The site has been mainly cleared of buildings and remediated for land contamination. It was identified in the submitted Local Plan for 8,600 sq m of business space and 200 dwellings. However the site is wholly within Flood Zone 3a and is at high risk of flooding. The national policy aims for Flood Zone 3a in the NPPF are to relocate development to areas with a lower probability of flooding. The Environment Agency therefore objects to residential development on the site. The deletion of a housing allocation is necessary for reasons of flood risk. However as the housing was needed to assist development viability of the mixed use scheme the site is also unlikely to be developed for the proposed business use”.

5.2 GARDEN SUBURB REJECTED FOR FLOOD RISK: A large urban extension to the town of Maldon in Essex has been refused against officer advice over flood concerns:

The ‘garden suburb’ proposal submitted by developer Countryside Properties would have seen the creation of 1,138 new homes to the north of Heybridge covering 76 hectares. However, members of the Maldon District Council North West Area planning committee voted to refuse the application, going against the Planning Officer’s recommendation of approval.
Within the Officer’s Report for the application, it said “Delivery of the site will assist the Council in achieving its five year housing land supply requirements”. The site is one of three strategic locations contained within the Council’s local plan for the creation of a garden suburb in the area, guided by a strategic masterplan framework.
Despite the apparent policy compliance, Councillors voted to refuse the application due to concerns with flooding issues. Citing the Council’s formal reason for refusal, it said “Insufficient evidence has been submitted with the application to demonstrate that the proposed development would be able to incorporate adequate surface water drainage infrastructure and that the infrastructure that would be proposed would be maintained in a manner that would ensure that the development would not cause increased flooding risk within the vicinity of the site and the catchment areas of the watercourses that are within the site”.
Maldon Council released a statement which said that the potential impact on flood risk from the development was unacceptable and contrary to both local and national planning policies.

5.3 TUDELEY PUBLIC HOUSE EXTENSION REJECTED: Proposals for the extension of the Poacher & Partridge PH, Hartlake Road have been rejected by TWBC for the following reasons:

(2) The proposal, by virtue of creating new buildings with associated domestic paraphernalia, works to alter the land levels and potential additional impacts from further parking and works in close proximity to the trees at the rear would have more than a minimal impact on the landscape character of the locality. It would not conserve and enhance the rural landscape, nor would it protect the countryside for its own sake, nor preserve the interrelationship between the natural and built features of the landscape. The overall impact is harmful to the rural character of the area.

(3) It has not been demonstrated that the occupiers of the development would not be at risk from flooding or that the development would not increase flood risk elsewhere. Therefore the development is likely to result in a risk to human life from flooding.

The application was considered to be fundamentally contrary to the provisions of the Development Plan and the NPPF, and there were not considered to be any solutions to resolve this conflict. This decision directly contradicts the promotion of the adjacent development of 2,800 homes (CA1) by the same TWBC Planning department.

5.4 OTHER PROPOSED DEVELOPMENTS REJECTED FOR FLOOD RISK:

South Stanley: Plans to build 290 homes in South Stanley were unanimously rejected by council bosses. The application for land south of Hustle Down road and Middies Road was thrown out due to concerns about traffic congestion, road safety and flooding as well as harm to the character of the local landscape. It was felt the application represented a significant encroachment into the countryside.
Cannon Bridge: Plans for 27 houses in Cannon Bridge rejected by the Highland Council planning officers after flood risk fears raised by the Scottish Environment Protection Agency (SEPA) and the councils flood risk management team.
Yatton: Plans for a new estate in Yatton near Bristol were rejected. A risk of flooding was one of the chief concerns expressed about the proposed development by members of the North Somerset Council planning committee.
Dublin: Plans for 900 new homes in South Dublin have been refused due to concerns about flooding and traffic impact. The board said it was not satisfied that the developer had provided adequate information around how it would manage storm waters on an area at risk of flooding. It had serious concerns in relation to the effectiveness of the proposed solution including plans for a water storage area, and overall calculations of the surface water runoff rates. Furthermore the board was not satisfied that the storm water outflow could be limited or that the site when developed would no result in flooding in the Ballyogon Stream and related catchment downstream of the development site. It said that the proposed development would therefore lead to a risk of flooding lands outside the subject site and be contrary to the proper planning and sustainable development of the area.
Kings Lynn: Housing development in Clenchwarton near Kings Lynn rejected for fears regarding flooding.
Stockton-on-Tees: The appeal site lay partly within flood zone 2. The developers had produced a flood risk assessment that demonstrated a reduced risk of flooding and the Environment Agency withdrew its objection. However, the appeal Inspector found no evidence that alternative sites had been considered. Notwithstanding the absence of an objection from the Environment Agency or the local planning authority on this issue, the Inspector considered that the proposal did not meet the requirements of national guidance and refused planning permission.

6 : CURRENT HYDROLOGY & FLOOD RISK

6.1 Flooding from reservoirs

6.2 Reservoir flooding is very different from other forms of flooding. It will happen with little or no warning and evacuation will need to happen immediately. The likelihood of such flooding is difficult to estimate, but it is less likely than flooding from rivers or surface water. It may not be possible to seek refuge upstairs from floodwater and buildings could be unsafe or unstable due to the force of the water from the reservoir breach or failure.

6.3 Reservoirs with an impounded volume greater than 25,000 cubic metres in England are governed by the Reservoir Act 1975, as amended by the Flood and Water Management Act, 2010 and are listed on a register held by the Environment Agency. Recent changes to legislation under the Flood and Water Management Act require the Environment Agency to designate the risk of flooding from these reservoirs.

6.4 The only such reservoir in our area is at Leigh (see section 8). Flooding as a result of a breach/failure (or deliberate release) of this reservoir structure would impact allocation parcels in the north of the Paddock Wood (SFRA prepared for the DLP). This may be up to 2 metres high in some cases, and perhaps 1 to 1.5 metres in the CA1 Tudeley area and Five Oak Green, when levels are fully assessed.

6.5 Fluvial flood risk

6.6 The principle watercourses flowing through Tunbridge Wells Borough are the River Medway and its tributaries, which include the Alder Stream, Paddock Wood Stream, River Beult, and the River Teise, the longest watercourse within the borough. The main source of fluvial flood risk is associated with the Rivers Medway, Teise and Beult, caused by run-off and catchment inflows across the borough.

6.7 In addition to these watercourses, flooding within the borough has also been associated with Alder Stream, which flows through Five Oak Green, and Paddock Wood Stream, which flows through Paddock Wood. The Alder Stream catchment is described as particularly flashy, resulting in regular flooding from the Stream. Railway embankments act as a dam, which consequently worsens the flooding in this area of the borough with roads and property having been affected in the past. In some instances, high water levels in the Alder Stream have affected highway drains, gullies, and local sewer networks.

6.8 A number of ordinary watercourses flow through the Paddock Wood area including the Alder Stream, Paddock Wood Stream and Tudeley Brook. In the east, a number of unnamed smaller ordinary watercourses flow off the hills to the south of Paddock Wood and through a number of allocated sites before flowing into Paddock Wood Stream. Paddock Wood Stream flows through the central area in a northerly direction towards the River Medway. Tudeley Brook flows in a northerly direction through the west of the area before joining Alder Stream which flows in a north easterly direction.

[TWBC: for Figure 5, see full report, including diagrams, figures and pictures].

6.9 Numerous water courses are marked on the above map at CA1 and the Tudeley Brook at Capel East. By the very nature of such watercourses a myriad of underground branches are likely to exist beneath the slopes at CA1 and possibly at the site Capel East. Water also runs under and over the southern sloping areas. Much of southern CA1 slopes in more than one direction.

6.10 The southern section of CA1 floods and ponds with flooding at the railway line down from the church, the ground from the church level being uneven, and sloping in different directions in wave patterns. Tudeley levels floods, bringing water to Tudeley Road, this being water from springs and watercourses on higher ground. The lions head spring passes down through Somerhill and can often be seen flooding across the road into the fields at Postern.

6.11 There are noticeable run-offs from spring points, e.g. southern section of CA1. Springs are present to the rear of All Saint's Church, Tudeley and behind Crockhurst Street, another spring can be seen opposite Park Farm on the higher ground to the south west.

6.12 Groundwater Flooding

6.13 The groundwater (water table) is stated as being naturally high in the Capel area by the National Soil Resources Institute. 6.14 Current understanding of the risks posed by groundwater flooding is limited and mapping of flood risk from groundwater sources is in its infancy. Groundwater level monitoring records are available for areas on major Aquifers. However, for low lying valley areas, which can be susceptible to groundwater flooding caused by a highwater table in mudstones, clays and superficial alluvial deposits, very few records are available.

6.15 Mapping suggests that susceptibility to groundwater flooding is greatest in the north-east of the borough, specifically in the areas of Whetsted, Tudeley Hale and Five Oak Green. This groundwater flood potential is consistent with the location of more permeable strata and superficial deposits to the north of the borough.

6.16 Additionally, there is increased risk of groundwater flooding where long reaches of watercourses are culverted as a result of elevated groundwater levels not being able to naturally pass into watercourses and be conveyed to less susceptible areas. Mapping for the Local Plan has shown that more than 75% of the area within the 1km grid squares surrounding the Whetsted and Tudeley Hale, as well as the area north of Five Oak Green, are susceptible to groundwater flooding.

6.17 The playing field in Five Oak Green regularly floods to a greater or lesser extent a few times every winter. Significantly when this happens the water remains in place for days or even weeks due to the underlying nature of the soil and/or the high water table.

6.18 Pluvial flooding

6.19 Flooding from surface water runoff (or ‘pluvial’ flooding) is usually caused by intense rainfall that may only last a few hours and usually occurs in lower lying areas, often where the natural (or artificial) drainage system is unable to cope with the volume of water. Abnormally heavy rainfall can also occur for an extended period of time.

6.20 Surface water flooding problems are inextricably linked to issues of poor drainage, or drainage blockage by debris, and sewer flooding.

6.21 The risk of flooding from surface water predominantly follows the topographical flow paths of existing watercourses or dry valleys with some isolated ponding located in low lying areas.

6.22 For the most part, surface water flooding could be attributed to heavy rainfall overloading carriageways, drains and gullies. However, there are other instances where the source of flooding is perceived to be from blocked drains and gullies, or due to high water levels within receiving watercourses impeding free discharge from surface water drains and gullies. It is noted that roads within the borough are regularly flooded due to run-off from adjacent agricultural land discharging into watercourses that do not have sufficient capacity to convey the flows.

6.23 Paddock Wood has experienced several incidents of surface water flooding associated with small watercourses, sewerage and private drainage systems, often occurring relatively rapidly from the onset of heavy rainfall.

6.24 Thanks to the Parish Council Flood Committee and the Five Oak Green Flood Action Group, with the aid of various agencies, especially the environment agency, the regularity of incidence and severity of flooding in Five Oak Green has been greatly reduced. Despite this the centre of the village does still flood on a regular basis. Much of the improvement has been due to extra measures taken to get the water through the village and away. Maintenance of the stream leading to the culvert, keeping the screen at the start of the culvert clear, unblocking and lining the culvert, clearing the exit of obstructions, and the regular maintenance of the ditches all the way down to the Medway have brought about dramatic improvements. Anything such as the proposed development which impeded this would inevitably increase the frequency and severity of flooding in Five Oak Green/Capel.

6.25 The surface water drainage system has not been increased and upgraded in terms of layout, positioning, and capacity to keep pace with the continued and continuing construction of new houses, extensions to existing houses, conservatories, and other buildings in and around the village.

6.26 Development of two new dwellings at Pendore, Five Oak Green. The previous building and hardstanding areas had a gross area of approximately 276 m². The two new dwellings have a footprint of 267 m² with a total impermeable area of 697 m². EA prescribed a total of 28 m³ of attenuation (swales etc.) with restricted discharge via a hyrdobrake of 2 l/s to the adopted sewer in Five Oak Green Road. This demonstrates the large size of storage that is required by the EA under each dwelling and curtilage to attenuate the flood risk.

6.27 Three houses have recently been built on Five Oak Green Road near the centre of the village, three more houses are being constructed opposite the allotments, and two more recent builds are now on Sychem Lane, one of them newly completed. A Planning Application has recently been approved for five new houses on Sychem Lane. To the north of the railway, more new houses are being completed on Whetsted Road. All in this small village. And the former Kings Head site awaits development!

6.28 It is also noted that much of the drainage infrastructure has been in place for well over a century and was not designed and built for the current and future demands. Further, the current water company has made clear that not all of the layout of the system is known to them or mapped by them.

6.29 Over the two sites, just 50mm of rain falling would amount to 26.4million gallons of water, equivalent to 40 Olympic size swimming pools. All in addition to that resulting from developments in Paddock Wood and Tonbridge.

6.30 Flood defences

6.31 There is presently only one (modest) flood defence in the local vicinity. A small raised embankment (<40 metres long) is located along the banks of the Alder Stream near Brook Farm, approximately 0.2km south of Five Oak Green Road. This is accompanied by concrete bank protection works and is owned and maintained by the Local Authority.

6.32 The condition grade of the defence is ‘Fair’, meaning that defects may be present that could affect the overall performance of the defence lining the Alder Stream. The defence has been designed to provide a standard of protection of 20% AEP and thus only protect the surrounding properties from a 1 in 5-year flood event.

6.33 A Five Oak Green flood alleviation scheme has been proposed to reduce fluvial flood risk from the Alder Stream which has been discussed over many years. Options are being assessed by the EA which include additional flood defences around the Alders Road area behind Colts Hill. This may include a reservoir but no decision has been taken.

6.34 The Policy AL/PW1 includes reference to Five Oak Green (FOG) but only states specifically Paddock Wood (see strategic storage in section 11). It is now understood that the Alder stream project would not be progressed and the ‘betterment’ for FOG would be through CA1 Tudeley, as confirmed by TWBC Head of Planning (12-Nov-2019).

6.35 EA Flood Map

6.36 The mapping of current flood risk from fluvial flooding in Capel is shown below (Figure 6) which confirms that the majority of PW1 Capel East is in Flood Zone 3. In addition, there is a significant area of the northern part of CA1 Tudeley that is within the flood mapping.

6.37 It is important to note that this mapping does not include an allowance for climate change nor the additional effects of surface water flooding. There is also no consideration of the run-off from the proposed development and the replacement of agricultural land with hard surfaces.

6.38 The Environment Agency’s current flood model is based on assumptions that are 25 years old, which is reflected on its inability to cope with such small variations in HSL. It is also clear that, in some key areas, the underlying data may be out of date – newer land use mapping would have shown that the surface roughness in these areas had decreased as agricultural use has moved away from hedge-bound orchard systems to open-field cereal and rootvegetable crops.

[TWBC: for Figure 6, see full report, including diagrams, figures and pictures].

6.39 This area regularly floods throughout the year to a greater or lesser degree. In addition those areas that don’t flood become very muddy. With global warming and building on the site matters can only get worse. Whilst it is possible to protect properties by building up its a bit pointless if the roads flood - damaging vehicles – and making access to the houses difficult and potentially dangerous.

7 : STONECASTLE QUARRY

7.1 The map below (Figure 7) shows clearly how the area of the proposed allocations in Capel, the historic landfill parcels, and adjacent land proposed for mineral extraction are closely linked.

7.2 The Draft Local plan has stated in its policies that the strategy must “have regard to Kent County Council minerals allocations in the vicinity” and therefore the cumulative effect of any quarry expansion and new housing plans needs full assessment.

[TWBC: for Figure 7, see full report, including diagrams, figures and pictures].

7.3 Historic Landfill

7.4 The Mineral Planning Authority (MPA) permitted the importation of various waste materials to Stonecastle Quarry under condition (xii) of the planning permission TW/79/753 and subsequent other conditional consents. We understand that this continued through the 1980s and 1990s.

7.5 The landfill areas comprise of two large parcels of land which were backfilled with these waste materials following the completion of mineral extraction. These areas are located to the north & south-west of the previous processing area and we understand that the southern parcel was backfilled first (see map above).

7.6 Condition (iii) (h) of the planning permission TW/79/753 states “measures to minimise the accumulation of groundwater and generation of leachate within each cell being backfilled, and for removing such groundwater and leachate as does arise from the site for appropriate treatment and disposal”.

7.7 Our research and the limited monitoring information obtained from the Environment Agency has raised the following initial concerns:

The southern site is bordered by the Hammer Dyke and is dissected by the Alder Stream (Main River).
The levels of highly toxic leachate in the segregated cells that make up the northern parcel have consistently been around 4.5 metres higher than the level prescribed in the Waste Disposal Licence.
Excess leachate has seemingly not been removed from these sites, with the licence stating that this should have been done within four weeks of a monitoring level exceeding the permitted level.
The northern parcel appears to have contaminated the adjacent Primary Silt Lagoon (immediately west and north) as there appears to be an absence of wildlife in contrast to the other lagoons.
The leachate may have escaped into the surrounding water courses/aquifers especially during the severe flood events in 2000 and 2013. Volatile readings and elevated substances have been found in the groundwater.
Volatile and apparently high levels of methane gas and carbon dioxide have been recorded.
Numerous readings have not been made due to bore holes/wells being flooded, damaged or inaccessible.
The waste materials in the cells are bunded/contained by clay overburden and silt remnants from aggregate washing and any ground movement could severely compromise the security of the leachate.

7.8 There is extreme concern in our community, especially as the area has historically flooded, and numerous people are asking for a comprehensive independent report that provides full analysis of the contamination risks of these landfills and whether our health has been affected by evidently uncontrolled methane gas emissions.

7.9 This matter is relevant to the Draft Local Plan because of the contamination risks on the water courses and aquifers (see section 14), and also due to the connectivity of numerous water courses in the immediate area, especially Alder Stream and Tudeley Brook (within PW1).

7.10 KCC Minerals Plan

7.11 The Kent Minerals and Waste Local Plan 2013-30 is currently being assessed by the inspectorate under Regulation 19 and members of the Flood Group participated at the hearings in October 2019. The Inspector’s report will only be available after the end of this Regulation 18 consultation on the Draft Local Plan.

7.12 TWBC was not represented at the hearings for sites M10 Moat Farm and M13 Stonecastle and no Statement of Common Ground between KCC and TWBC was provided to the Inspector. This raises serious concerns about the fulfilment of “Duty to Co-operate” requirements and whether either of these plans meet the test of soundness.

7.13 M10 Moat Farm: The map above highlights that the eastern boundary of the proposed site M10 Moat Farm envelopes the historic southern landfill and the north-east section is adjacent to the northern landfill area. Any disturbance of the contaminants, the elevation of these landfill areas and substantial contamination risks of leachate, Methane gas, and other toxic substances on the water courses is of significant concern.

7.14 In addition, the proposed mineral site borders the Hammer Dyke and is dissected by the Alder Stream which raises significant further concerns as to the effect of this proposed extraction on the flood risk and water courses/aquifers.

7.15 The Draft Local Plan is proposing a new road link from the new town CA1 at Tudeley to the A228 (orange arrows in Figure 7) that would follow a route across M10 Moat Farm and the southern parcel of the historic landfill. Whilst this new road link is not included in the Transport Assessment Review prepared in support of the Draft Local Plan, the Strategic Sites Map released for the consultation still includes it.

M10 Moat Farm is expected to produce the extraction of 1.5 million tonnes of sand and aggregate (combined) over a period of 15 years. The restriction on Stonecastle Quarry activity because of the road access at the A228/Whetsted Road junction means that the various mineral sites must be worked consecutively (not concurrently).

Tarmac have stated that M10 Moat Farm would be scheduled for extraction after the completion of the Stonecastle extensions. By implication, this proposed mineral extraction could run from the late 2020s to the mid-2040s.

The Draft Local Plan covers the period 2016 to 2036 and it is therefore inconceivable how both the Mineral Plan and the new road link can be achievable during this period.

7.16 M13 Stonecastle extension: This proposed site is expected to produce the extraction of one million tonnes of sand and aggregate (combined) over a period of 7 years. As with the above site M10, the restriction on Stonecastle Quarry activity means that the various mineral sites must be worked consecutively.

7.17 This site is the centre of the catchment area of the EA designated Groundwater Protection Zone (GSPZ) related to the aquifers at Hartlake (see section 14). These aquifers have historically been an environmental concern. In 2002 KCC refused planning permission for the proposed extension of Stonecastle Farm Quarry phases 3 & 6 (now M13) on the grounds of potential pollution and contamination. Further quarry working was deemed to be a public health risk as the Hartlake aquifers are a source of public and commercial water supply.

7.18 The Flood Risk Assessment (FRA) prepared by Waterco in support of the Mineral Plan states that the site M13 is an important setting for local water supply and extensions to this quarry may impact water supply. Questions remain as to whether the full extent of these extensions are acceptable on this functional floodplain.

7.19 There is also uncertainty about the sustainability of the restoration plan and how the integrity of the watercourses will be maintained. Groundwater maps show the northern parcel has a 25-50% susceptibility to ground water flooding and the southern parcel 75%. Any effect on further waterbodies adjacent to the river Medway may result in the risk of further flooding.

7.20 Given the proximity and land levels of CA1 Tudeley, the resulting rainfall run-off and drainage, together with potential contamination and increased flood risks, needs to be fully assessed in relation to the proposed mineral extraction in this area.

7.21 Mineral Processing

7.22 Tarmac have applied to the MPA for new processing facilities (KCC/TW/0093/2019) and this is currently under consideration by KCC.

7.23 The proposal is that silt laden waters resulting from the mineral washing process will be discharged to the Primary Silt Lagoon which is adjacent to the northern landfill parcel. Given the close proximity of the proposed operation to the landfill and the interaction with the lagoons, the contamination risks need to be fully assessed.

7.24 It is important to note that KCC and the Environment Agency have been asked to provide a comprehensive review of the contamination risks from the historic landfill before determining this planning application. Although originally scheduled for consideration at the November 2019 Planning Committee, this has been deferred.

7.25 In addition, KCC Highways are reviewing the level of traffic entering/leaving the quarry site at the junction with Whetsted Road/A228. Given the potential vast increase, which could continue for up to 30 years, the cumulative effect of the proposed development of PW1 Capel East and resulting traffic needs to be fully assessed.

7.26 KCC Policy DM7 - Safeguarding Mineral Assets

Planning permission will only be granted for non-mineral development that is incompatible with minerals safeguarding where it is demonstrated that either:

the mineral is not of economic value or does not exist; or
that extraction of the mineral would not be viable or practicable; or
the mineral can be extracted satisfactorily, having regard to Policy DM9, prior to the non-minerals development taking place without adversely affecting the viability or deliverability of the non-minerals development; or
the incompatible development is of a temporary nature that can be completed and the site returned to a condition that does not prevent mineral extraction within the timescale that the mineral is likely to be needed; or
material considerations indicate that the need for the development overrides the presumption for mineral safeguarding such that sterilisation of the mineral can be permitted following the exploration of opportunities for prior extraction; or
it constitutes development that is exempt from mineral safeguarding policy, namely householder applications, infill development of a minor nature in existing built up areas, advertisement applications, reserved matters applications, minor extensions and changes of use of buildings, minor works, non-material amendments to current planning permissions; or
it constitutes development on a site allocated in the adopted development plan where consideration of the above factors (1-6) concluded that mineral resources will not be needlessly sterilised.

7.27 The TWBC Draft Local Plan states “The Kent Minerals and Waste Local Plan is part of the Development Plan. Issues including minerals safeguarding are important considerations during decision taking on planning applications. Given the strong relationship between minerals and the delivery of new building, it is important that decisions do not put at risk the delivery of both Plans”.

7.28 KCC have specified that the criterion ‘adopted development plan’ should be interpreted literally, such that provided there is an adopted development plan with allocations, regardless of whether the development is incompatible with the mineral safeguarding principles, development in those areas is, in all cases, exempt from the need to consider safeguarding.

7.29 Clearly, although we understand that TWBC will have consulted with KCC, the Draft Local Plan by definition is not “adopted” and no further details have been provided to explain how the policy DM7 has been applied. This raises further serious concerns about the fulfilment of “Duty to Co-operate” requirements and whether either of these plans meet the test of soundness.

7.30 It is also relevant to explain that the substrates of the area are mainly alluvial deposits under a clay cap which extend over the CA1 Tudeley site. Indeed, this site was included in the early KCC Draft Minerals Plan and there now appears to be a contradiction between the safeguarding of these minerals and the proposed development of CA1 Tudeley.

8 : LEIGH RESERVOIR

8.1 The Leigh flood storage area (FSA) was built in 1982 following the devastating 1968 floods and is formed by a 1.3 kilometre-long, five-metre-high earth embankment across the Medway valley.

8.2 The River Medway passes through a reinforced concrete control structure built into the embankment. The 3 steel radial gates can be moved to either let the river flow normally, or to restrict the flow and hold water in the FSA, to control the amount of water flowing downstream.

[TWBC: for image showing concrete structure referred to above, see full report, including diagrams, figures and pictures].

8.3 The Environment Agency operates it at the peak of a flood event, when river levels passing through the structure are at their highest. However, at times of exceptional rainfall there will still be some flooding downstream.

8.4 It currently has a capacity to store 5.5 million cubic metres of water and plans to increase this have been approved. This will allow the Environment Agency to increase the flood reservoir water level from 28.05 metres to 29 metres at Leigh, upgrade an existing embankment near Hawden Farm in Hildenborough, and install a new control structure and pumping station to prevent water from the Medway backing up into the village.

8.5 The total cost of the project is estimated at £15.5million, with contributions expected to come from the South East Local Enterprise Partnership (£2.3m); the Environment Agency Flood Defence Grant (£10.1m); Kent County Council (£2.5m); and Tonbridge and Malling Borough Council (£0.5m).

8.6 The expected construction of the additional storage capacity is scheduled to commence in 2020, with anticipated completion in 2023, providing up to 30% additional river storage upstream.

8.7 The barrier was released in October 2000 and December 2013.

8.8 If we were to face another December 2013, namely that the barrier would be compromised or breached again, with the additional flood storage capacity, the velocity of the release would be greater than the 2013 release. This is likely to cause extreme damage to properties and a serious risk to human life.

8.9 There should be a requirement that that suitable assurances and mitigation are implemented to protect the communities that were flooded in 2013 by the barrier breach.

8.10 Photos of the December 2013 major flooding event when the Leigh barrier was released, Tonbridge Park:

[TWBC: for images, see full report, including diagrams, figures and pictures].

8.11 There are proposals for two further Reservoirs to be constructed to the south of Paddock Wood. These would have a maximum storage capacity of 220,000m³ (see section 11) and there is concern on the implications, e.g. flooding levels from the 2013 Leigh event exceeded 2.14m at Hartlake Bridge. This proposal would present a further significant risk to human life.

9 : TMBC LOCAL PLAN

9.1 Tonbridge & Malling Borough Council has prepared a new borough wide Local Plan focussed on the period up to 2031, which has been consulted upon and has reached the examination stage. The Inspector has raised several issues that are now subject to a further public consultation process that ends on 16-Dec-2019.

9.2 The T&M Borough covers a total area of 240 km² (70% Metropolitan Green Belt) which compares with a total area of 326 km² in the Tunbridge Wells Borough.

9.3 The plan is proposing a housing requirement within the Local Plan of an additional 6,834 dwellings to meet the projected population growth:

* 121,900 (2012) * 133,000 (2021) * 145,000 (2031)

9.4 Flood risk: The River Medway runs through the Borough, flowing from the upper reaches through the town of Tonbridge to the downstream section through and beyond Aylesford. The Medway is fluvial between the outer north-western limits of Hildenborough down to Allington Lock (in Maidstone). Downstream from the Lock, including Aylesford, the Medway is tidal, eventually feeding into the Thames Estuary.

9.5 Flood mapping shows that a significant section of the central area of the principal town in the Borough, Tonbridge, is at high risk from flooding. In addition, the Rural Service Centre of East Peckham is at high risk whilst parts of Aylesford, in the north-eastern parts, are at medium and high risk from flooding.

9.6 Significant rainfall fell during the days leading up to Christmas 2013 making it the wettest December in 79 years. During the Christmas period the flow in the Upper Medway was the highest ever recorded at 300+m³/sec. To put this into context, a figure of 220 m³/sec. was recorded in the year 2000 and 250 m³/sec. in 1968, the last two severe rain events.

9.7 High flows in the River Medway are controlled by sluice gates and a flood storage area at Leigh. Within the town itself there are flood walls which are built along the banks of the Medway. Even with the presence of flood defences, the town of Tonbridge is not completely protected from flooding.

9.8 Flood Policy: The Council has responded to the issue of flood risk during the preparation of the Local Plan by pursuing a development strategy that avoids areas at high risk of flooding, particularly for residential development. This assessment took account of an allowance for climate change over the plan period and the likely effect this will have on the flows of watercourses.

9.9 The increased likelihood of flooding is widely recognised as one of the key consequences of climate change in the UK. Severe flooding has, from time to time, been a key concern in Tonbridge & Malling causing distress to many local communities and damage to properties and infrastructure. The Council with its partners have striven to bring forward capital proposals to address issues and is working in partnership with other agencies to mitigate flood risk through other means.

9.10 In determining planning applications the Council will apply the requirements of the Government’s policy in the NPPF and the PPG on flood risk. If a development proposal is in conflict with the relevant national policy then it will be in conflict with this Policy.

9.11 Implications on TWBC Plan: The proposed development of housing, commercial, and associated infrastructure in T&M Borough will already lead to considerable additional water flows to the Medway and the floodplain. The cumulative effect on flooding implications, when added to by the TWBC plan, has not been fully assessed.

9.12 TMBC appears to have followed NPPF flood risk policy guidelines closely which highlights its efforts to discourage development within vulnerable flooding areas, where as TWBC have taken the opposite approach. TWBC are challenging current Green Belt Policy, requesting the removal of 100’s of hectares of MGB, and keen to promote many sites that are situated within Flood Zones 2 and 3.

9.13 TMBC have elected to promote a combination of small and larger developments widely across the borough, with the largest development a garden village at Borough Green. This will have a maximum of 1,700 dwellings, compared to TWBC’s largest two developments that propose around 8,000 dwellings within a 3 mile radius of each other and parts of these developments will be situated within Flood Zone 3 areas.

9.14 At a recent Extraordinary General Meeting of the TMBC Cabinet Advisory Board that discussed the TWBC Draft Local Plan, several members of TMBC raised serious concerns about the increased flood risk that could arise from the proposed developments in Capel. There is also concern that the TWBC plan does not demonstrate how the flood risk to several residential areas in Tonbridge Borough will be mitigated.

10 : CLIMATE CHANGE

10.1 The NPPF sets out how the planning system should help minimise vulnerability and provide resilience to the impacts of climate change. The Environment Agency published updated climate change guidance on 19 February 2016, which supports the NPPF and must now be considered in all new development plans and how allowances for climate change should be included.

10.2 The guidance presented in the Strategic Flood Risk Assessment (SFRA) prepared by JBA for the Paddock Wood area is based on UKCP09, but it should be noted that following the publication of UKCP18, updated Environment Agency guidance on climate change is expected to be issued in 2019, after the publication of this SFRA.

10.3 The 2016 climate change guidance includes climate change predictions of anticipated change for peak river flow and peak rainfall intensity. The guidance also covers sea level rise and water height. These allowances are based on climate change projections and different scenarios of carbon dioxide emissions to the atmosphere. Due to the complexity of projecting climate change effects, there are uncertainties attributed to climate change allowances related to the confidence in the prediction. As a result, the guidance presents a range of possibilities to reflect the potential variation in climate change impacts over the three periods that reflect the differing levels of confidence in the predictions.

10.4 Peak river flows: Climate change is expected to increase the frequency, extent and impact of flooding, resulting from an increase in the magnitude of peak river flows. Wetter winters and more intense rainfall may increase fluvial flooding and surface water run-off and there may be increased storm intensity in summer. Rising river levels may also increase flood risk. The peak river flow allowances provided in the guidance show the anticipated changes to peak flow for the river basin district within which the subject watercourse is located.

Once the river basin district has been identified, guidance on uplift in peak flows are provided for three allowance categories, Central, Higher Central and Upper End which are based on the 50th (Central), 70th (Higher Central) and 90th (Upper End) percentiles respectively. The ‘percentile’ is a measure of the confidence in the prediction of the magnitude of the allowance, i.e. lower uplift values (50th percentile – ‘Central) are statistically more likely and thus attributed with greater confidence compared with higher uplift values (e.g. 90th percentile – ‘Upper End’) which allow for future conditions that accept a greater level of uncertainty.

The allowance category to be used is based on the vulnerability classification of the proposed development and the flood zones within which it is to be located. These allowances are provided, in the form of figures for the total potential change anticipated, for three climate change periods:

* The ‘2020s’ (2015 to 2039) * The ‘2050s’ (2040 to 2069) * The ‘2080s’ (2070 to 2115)

The time period used in the assessment depends upon the expected lifetime of the proposed development.

10.5 Time frame: Residential development should be considered for a minimum of 100 years.

10.6 Fluvial flooding: Climate change does not just affect the extent of flooding. Even where flood extents do not significantly change; flooding is likely to become more frequent under a climate change scenario. The impact of an event with a given probability is also likely to become more severe. For example, as water depths, velocities, and flood hazard increase, so will the risk to people and property. Although qualitative statements can be made as to whether extreme events are likely to increase or decrease over the UK in the future, there is still considerable uncertainty regarding the magnitude of localised impact of these changes.

10.7 The map below (Figure 8) shows the fluvial flood projections that have been included in the SFRA using the following methodology:

Some climate change modelling was available from the Environment Agency for Alder Stream and part of the River Teise (downstream of Goudhurst Road) for the Flood Zone 3a event in the 2080s epoch for the Higher central and Upper end estimates. This information has been used to inform the predicted climate change extents presented in the mapping.
Additionally, modelling prepared as part of the SFRA for Paddock Wood also simulated these events, and this information has also been used to inform the mapping.
Where no climate change modelling and mapping is available, a precautionary approach has been adopted for the SFRA, in which the present day Flood Zone 2 extent has been used as a conservative indicator of the potential changes to Flood Zone 3a in the future. This does not directly relate to published guidance on potential changes to fluvial flood flows but used as an indication for the SFRA. Note that future modelling that does use the published values may produce outlines that differ from the mapping presented in the SFRA.
The modelling and mapping completed focused on predicted flood risk at the 2080s epoch (2070-2115) under increased flow rates of +30% and +70% for the undefended case 1% AEP event (Flood Zone 3a). The fluvial flow allowances represent the Higher Central and Upper End allowances under the latest guidance for the Thames River Basin District in which the River Medway catchment is located.

[TWBC: for Figure 8, see full report, including diagrams, figures and pictures].

10.8 This map is un-defendable as it appears to show no detailed modelling. All that it appears to have happened is that the lower risk areas have been “upgraded” to higher risk areas in certain areas. That is not modelling.

10.9 It also does not take into account the cumulative effects of surface run-off and groundwater flooding (see below).

10.10 All current climate change models strongly indicate that, while summer droughts will be more prevalent, storm events will be more common and stronger, as well as winters being milder and wetter. Both of these factors will mean that flooding events are likely to be more frequent and have a greater magnitude. At the moment, it is not entirely clear what new flood water levels will be: modelling a specific drainage basin's response to an increase in supply is difficult, as there are often too many variables. However, it is clear that even the conservative estimates of between 35% (by 2030) and 70% (by 2080) show increases in precipitation that are likely to be under estimations. This will have an impact on the long term sustainability of both of the Capel development sites.

10.11 Surface Water flooding: Climate change is predicted to increase rainfall intensity in the future by up to 40% (for the Upper End estimate to the 2080s epoch (2070 to 2115)) under the new range of allowances published by the Environment Agency. This will increase the likelihood and frequency of surface water flooding, particularly in impermeable urban areas, and areas that are already susceptible. Changes to predicted rainfall should be incorporated into flood risk assessments and drainage and surface water attenuation schemes associated with developments.

10.12 Groundwater flooding: The effect on groundwater flooding problems, and those watercourses where groundwater has a large influence on winter flood flows, is more uncertain. The updated climate change guidance released in February 2016 does not provide information on expected changes to groundwater flooding under future climate change. However, milder wetter winters may increase the frequency of groundwater flooding incidents in areas that are already susceptible. Where groundwater flooding is expected to influence a development site, it will be expected that consideration of groundwater flooding under a changing climate is assessed and measures taken to mitigate any change in risk.

10.13 Guidance: The NPPG contains information and guidance for how to identify suitable mitigation and adaptation measures in the planning process to address the impacts of climate change. In addition, assessments are required to demonstrate future implications of climate change have been considered, and risks managed where possible, for the lifetime of the proposed development:

Considering future climate risks when allocating development sites to ensure risks are understood over the development’s lifetime
Considering the impact of and promoting design responses to flood risk and coastal change for the lifetime of the development
Considering availability of water and water infrastructure for the lifetime of the development and design responses to promote water efficiency and protect water quality
Promoting adaptation approaches in design policies for developments and the public realm, for example, by building in flexibility to allow future adaptation if needed, such as setting new development back from watercourses
Identifying no or low cost responses to climate risks that also deliver other benefits, such as green infrastructure that improves adaptation, biodiversity and amenity, for example by leaving areas shown to be at risk of flooding as public open space.
Consideration of the vulnerability of the proposed development types or land use allocations to flooding and directing the more vulnerable away from areas at higher risk due to climate change.
Use of ‘built in’ resilience measures. For example, raised floor levels.
Capacity or space in the development to include additional resilience measures in the future, using a ‘managed adaptive’ approach.

The last consideration acknowledges that there may be instances where some flood risk management measures are not necessarily needed now but may be in the future. This ‘managed adaptive’ approach may include, for example, setting a development away from a river so it is easier to improve flood defences in the future.

10.14 Sea levels: BBC News (25-Sep-19) highlighted a scientist’s prediction of sea level increases of up to 1.1 metres by the mid 2000’s. [TWBC: for image within text, see full report, including diagrams, figures and pictures].

It is also very clear (from someone who has worked on climate change models), that the SFRA models and the longterm models in this report are very seriously underplaying the impact of climate change - especially as the ice-cap data from the North-Atlantic Ice reservoir indicates that we are almost certainly looking at something a lot more severe.

In a recent study on Greenland ice-caps (sadly, at the moment, unpublished), a figure of an 8 metre rise in sealevel was considered to be conservative.

10.15 Planning: Climate change is a serious worldwide problem, with far reaching consequences, and the Draft Local Plan fails to demonstrate that it has fully addressed the current understanding of the impact of climate change:

The Local Plan polices, e.g. Policy EN 5, lack any detail or clarity and should be far more robust.
NPPF 14 Meeting the challenge of climate change, flooding and coastal change:

The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.
Planning for climate change:

Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long- term implications for flood risk and coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures. Polices should support appropriate measures to ensure the future resilience of communities and infrastructure to climate change impacts, such as providing space for physical protection measures, or making provision for the possible future relocation of vulnerable development and infrastructure.

10.16 So far, the local plan demonstrates the complete reverse of the NPPF Climate Change Policies;

10.17 Greenhouse gas and Carbon emissions will increase substantially over the development period, with the large number of HGV’s, and various construction machinery accessing the sites, as well as the local road network.

10.18 In addition, the proposed quarry extension at Stonecastle Farm, and additional quarries at the adjoining Moat Farm, will all have a detrimental effect on local air quality and increased carbon emissions.

11 : PW1 CAPEL EAST DEVELOPMENT

11.1 Draft Local Plan: The proposed development of Paddock Wood in the Draft Local Plan is listed as Policy AL/PW1 Land at Capel and Paddock Wood. Land to be allocated under this policy falls within both the parishes of Capel and Paddock Wood. Sites which lie outside the allocation(s) at present may be included in the Regulation 19 Presubmission version of the Local Plan. [TWBC: for Figure 9, see full report, including diagrams, figures and pictures].

11.2 This site, as defined on the Policy Map, is allocated for:

The provision of approximately 4,000 new dwellings and a three pitch (one mobile home and one touring caravan per pitch) gypsy/traveller site on this land and in Paddock Wood Town Centre (AL/PW2);
Additional employment provision, including expansion of Key Employment Areas (B1/B2/B8 uses);
The provision of an enlarged Mascalls Secondary School and additional primary schools;
The provision of a new medical centre;
The provision of open space, youth and children's play and sports facilities (including a new outdoor sports hub) and recreational facilities as well as areas of natural and semi-natural green space and allotments/food growing.

11.3 Flood Policy Statement AL/PW1 Land at Capel and Paddock Wood: The development on the site should demonstrate that it will not exacerbate flooding elsewhere in the vicinity and through the provision of flood storage, attenuation/mitigation areas (including those outside the allocations) to substantially reduce the flood risk to particular existing residential areas in Paddock Wood, and potentially at Five Oak Green. This is one of the key justifications for the release of Green Belt land.

11.4 Focus: This report is focussed on the allocations within Capel Parish (sites PW 1-1 and PW 1-2 on the above map) and the effect on existing local communities and surrounding areas. Herein referred to as PW1 Capel East.

11.5 Strategic Flood Risk Assessment (SFRA)

11.6 The SFRA prepared by JBA for the Paddock Wood area has established that a large section of the proposed allocations are within Flood Zone 3. Development in Flood Zone 3a is significantly constrained by flood risk. Highly Vulnerable development is not permitted within this zone and More Vulnerable development and Essential Infrastructure are only permitted if the Exception Test can be passed.

11.7 Exception Test: Local Authorities are guided to adopt a precautionary approach to the issue of flood risk, avoiding such risk and managing it elsewhere. An Exception test is applied when it is not possible to locate development in zones with a lower risk of flooding.

The Draft Local Plan appears to fail the test as it does NOT steer new development to areas with a lower risk of flooding, and has not put forward obvious safer sites.

11.8 It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk and:

a) A site-specific Flood Risk Assessment must demonstrate that the development will be safe for its lifetime, taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall

b) It should be demonstrated that flood defences provide an acceptable standard of protection, including an allowance for climate change for the lifetime of the development.

c) Residual risks should be assessed, and the Environment Agency consulted regarding whether there is a need for a breach analysis to map a rapid inundation zone.

d) The layout of buildings and access routes should adopt a sequential approach, steering buildings towards areas of lowest risk within the site. Where rapid inundation zones have been identified, development should be avoided in these areas.

e) Development should not impede flow routes, reduce floodplain storage or consume flood storage in a ‘flood cell’ within a defended area. If the development does result in a loss of storage, compensatory floodplain storage should be provided on a ‘level for level’ and ‘volume for volume’ basis.

f) If existing defences are to be upgraded as part of the development, an assessment should be undertaken to ensure it does not result in an increase in flood risk elsewhere.

g) Development design should incorporate mitigation measures, to manage any flood risk to the development, including residual risk for the lifetime of the development. FFLs should be above the 1 in 100-year (1% AEP) flood level, plus an allowance for climate change.

h) It is recommended that all types of new development behind flood defences is avoided, where possible, due to the residual risks of breach and overtopping

i) Consideration should be given to the type of building that will be permitted, for example single-storey buildings and basements should be avoided.

11.9 The plan does not demonstrate that the proposed development at Capel East will provide wider sustainable benefits that outweigh flood risk, nor that it will be “safe for its lifetime”. The sustainability of any residential development should be considered over a minimum of 100 years. Therefore, the plan does not justify that this site, in such a location that requires measures to mitigate its flooding risk on a floodplain, will not flood in its lifetime, especially with the climate change uncertainties that must be taken into account (see section 10).

11.10 TWBC have not demonstrated how the proposed mitigation measures will ensure that the development will not cause flooding in the vicinity or further down river. The loss of flood water storage in the agricultural terrain and run-off/drainage from the buildings and hard surfaces will certainly increase the flood risk to all surrounding areas.

11.11 Development Parcels: Parcels within PW1 Capel East (1a-1b; 2a-2d) are separated by the railway line and comprise of a total of 114.5 hectares (280 acres) of undeveloped agricultural land. There are no formal drainage systems or any formal flood defences within or upstream of the parcels. See map below (Figure 10).

11.12 Ground levels slope from south/southwest to north/northeast. The largest watercourse through parcel 1 is Tudeley Brook, which enters the parcel in the south, before bifurcating into two streams that exit the parcel through separate culverts under the railway line. There is a smaller overland flow route in the southwest of the parcel that joins Tudeley Brook at the bifurcation, as well as an easterly overland flow path that joins a channel running along the east of the parcel.

11.13 An unnamed ordinary watercourse flows along the western boundary of parcel 2. This bifurcates and a branch of the watercourse flows through to the centre of the parcel before then flowing in a northerly direction. A further unnamed tributary flows into this watercourse from the south to the west of Whetsted Wood. Tudeley Brook flows along the eastern boundary of the parcel in a northerly direction.

11.14 Flood risk (present day): There are localised areas within Flood Zone 3b (functional floodplain), predominantly adjacent to Tudeley Brook and other minor watercourses, and in the east of Parcel 2.

11.15 Larger areas of land are designated Flood Zone 3a and these occupy much of the north of parcel 1, which appears to be exacerbated by flood water accumulating behind the railway embankment, as well as surrounding the easterly overland flow route and west of Tudeley Brook. Also, large areas of Parcel 2 are Flood Zone 3a, most notably in the north and east with localised areas to the west near the watercourses.

11.16 Fluvial flood risk is associated with the network of drains and ordinary watercourses as well as Tudeley Brook. These watercourses convey water from the hills to the south of the parcel and ultimately onward into the River Medway.

11.17 Surface water flood pathways generally align with the fluvial network, although rain falling directly on the parcel causes localised ponding of flood water.

11.18 Large areas of the north/north-west of parcel 2, and southern parts of Parcel 1, are susceptible to groundwater flooding.

11.19 Flood risk (climate change): The following mapping (Figure 10) displays the change in peak flood depths for the 1% AEP (+70% flows) event when the flood depths for the ‘with development’ model simulation are subtracted from the ‘SFRA baseline’ (no development at the parcel).

11.20 49% of the proposed area PW1 Capel East is at risk of fluvial flooding (67% of Parcel 1 and 33% of Parcel 2). [TWBC: for Figure 10 see full report, including diagrams, figures and pictures].

11.21 Flood risk increases, with changes in flood depth of up to +0.25m are typically predicted through the open space areas, although a portion of Parcel 1 has changes in peak flood depths greater than this predicted.

11.22 Flood depths across the railway line are predicted to increase. Flood depths and extents to the north of the railway line also increase, with some areas increasing by >0.25m.

11.23 The most influential factor predicted to change flood risk is residential area 1a and the impact this has on flood flow pathways.

11.24 This residential area potentially impedes the north-easterly flow of flood water, resulting in the deflection of water westward through the centre of the parcel and northward beyond the railway line.

11.25 The position of proposed development 2c is also influential, deflecting water eastward into Paddock Wood.

11.26 Flood Risk Management

11.27 Measures recommended by the SFRA to mitigate the impact of development and manage flood risk in the Capel and Paddock Wood area include:

11.28 Floodplain: The SFRA states “Compared to flood defences and flood storage, floodplain restoration represents the most sustainable form of strategic flood risk solution, by allowing watercourses to return to a more naturalised state, and by creating space for naturally functioning floodplains working with natural processes”.

11.29 This strategy has been understood in environmental science for years. However, the proposed development of PW1 on the floodplain is in direct contrast with the policy of using the Sequential approach of locating development away from watercourses. The opportunity to restore floodplain in previously developed areas is extremely limited.

11.30 Even re-wilding the flood plain would not protect the areas from surface water, drainage, and groundwater flooding together with the risks of sewage system failures and reservoir breaches.

11.31 Flood defences: There is a proposed defence that would extend from residential area 1a to the railway line, and aims to reduce the risk of flood water from Tudeley Brook along this eastward flow route. This would need to be considered in combination with other measures to help manage changes in flood risk.

11.32 When the defence is assessed, flood risk increases notably within Parcel 2, given the increase in flows across the railway line onto the north of the parcel. Flood risk also increases to the north of the parcel and in the area immediately east of proposed development 2c.

11.33 It is difficult to see how any effective further flood defences could be put in place within PW1 Capel East given that most of the flooding is simply caused by rain falling on the site faster than it is able to be absorbed due to the nature of the soil. Some water may flow onto the site from adjacent areas but to block this would result in unacceptable problems for those areas.

11.34 Increased conveyance: When the conveyance measures are assessed there remains increased flood depths predicted within Parcel 1 and to north of the railway line. Increased channel conveyance/new channels are predicted to provide only marginal flood risk benefits at a more localised scale rather than strategic benefits.

11.35 There also remains increased flood depths predicted across the majority of Parcel 2 and to the north.

11.36 Sustainable drainage systems (SuDS): These systems aim to alleviate surface water flooding by storing or re-using surface water at source. As surface water flows through the system, flow velocity to watercourses is controlled and pollutants are removed.

11.37 The SFRA states “Investigations will be required to evaluate whether infiltration SuDS are a feasible option. Drainage can utilise the existing watercourses within the parcel, and ditches and surface water sewers that may be present around existing development”. This statement of “feasibility” directly contradicts regulatory guidance and extensive SuDS initiatives must be considered in relation to the raised floor level requirements:

Planners should be aware of the conditions set by the LLFA (KCC) for surface water management and ensure development proposals and applications are compliant with the policy.
SuDS should be promoted (and implemented) on all new developments to ensure the quantity and quality of surface water is dealt with sustainably to reduce flood risk. On substantial development sites consideration should be given to the integration of sustainable water management with the provisions for green infrastructure within urban areas.

11.38 The raised levels (see below) facilitate the construction of containment tanks and other SuDS initiatives that should be included in the masterplanning. Comprehensive SuDS are required to mitigate the flood risk of the development on this fully functional floodplain and to ensure pre-treatment of contamination risk prior to infiltration.

11.39 Strategic Storage: The potential strategic storage parcels considered as part of the SFRA are positioned upstream of Parcel 1 on land within Capel Parish (see Figure 11) on Tudeley Brook - in order to reduce peak flow of flood events by reducing flood depths within Paddock Wood.

[TWBC: for Figure 11, see full report, including diagrams, figures and pictures].

11.40 Location 1 provides most opportunity for meeting the storage volume requirements (max storage 680,000m³). However, the area identified and maximum storage level/volumes would mean that development would not be possible at the Parcel 1 site and the PW1 plan would not be deliverable.

11.41 Location 2 (max 130,000m³) provides slightly greater other potential for flood storage and therefore reduction in flows. It is also further downstream so would capture greater volumes of run-off compared with location 3.

11.42 At location 3 (max 90,000m³), it is identified that greater storage volumes may be possible if the maximum storage could be increased.

11.43 It was agreed with the council that locations 2 and 3 should be considered in combination for model testing as part of the SFRA. However, there remains a localised increase in flood risk at the southern end of the parcel 1 due to reflection of flood water.

11.44 These proposed measures would probably be categorised as Reservoirs under the 1975 Act and Flood and Water Management Act, so would need to be designed, constructed and maintained accordingly. The required land parcels for this storage have not yet been safeguarded, as confirmed by TWBC Head of Planning (12-Nov-2019).

11.45 Raising levels: The raising of occupied floors of buildings above ground level so that a relatively unobstructed flow route under buildings may substantially reduce flood depths. The raising of floor levels within a development also avoids damage occurring to the interior, furnishings and electrics in times of flood:

11.46 * Finished Floor Levels (FFLs) should be set to the higher of a minimum of 600mm above the 1 in 100-year (1% AEP) plus climate change peak flood level, or 300mm above the general ground level of the site. This additional height is referred to as the “freeboard”. Additional freeboard may be required to account for risks such as blockages to the channel, culvert or bridge, reservoir breaches, and the uncertainty in the predictions.

11.47 The SFRA states “This measure was not implemented as it was agreed with the council that it would be unlikely to be deliverable given the scale and type of development being proposed”.

11.48 There have been several relevant developments recently in Capel where the EA has insisted on raised floor levels and containment (tanks, swales, etc.) with restricted discharge. In some cases, the EA have specified the inclusion of voids below the raised ground floor level to allow flood water to run and lay below the ground floor accommodation, including bedrooms.

11.49 Given the nature and likely EA requirement of these being compulsory measures within the development, it follows that the PW1 plan is not likely to be deliverable as stated by TWBC. Several points are relevant to the need for raising the levels of the developments:

The SFRA understates the impact of climate change over the >100 year horizon for residential development
The dwellings would need to be protected from a potential breach of the new reservoirs
These parcels are most affected by surface water and groundwater flooding
The wealth of guidance on flood risk and climate change (see sections 4 and 10)
Occupiers (and insurers) are imposing more stringent measures than the basic statutory requirements
The existing agricultural ditches and watercourses have been in place for centuries and are not designed to accommodate the run-off and drainage from this proposed level of development
Flooding risk resulting from the construction of buildings, roads, driveways, and other impermeable areas would not be materially affected by the raising of these levels. The EA are likely to prefer these measures.
The raising of the levels would facilitate the incorporation of storage tanks and other SuDS (see above)
Strategic drainage flows and watercourses can be accommodated within the freeboard

11.50 Therefore, the plan is not sound as it has not properly addressed the measures necessary to mitigate the flood risk from the PW1 Capel East development.

11.51 Increased Flood Risk

11.52 Our principle objections to the Policies STR/PW1 & AL/PW1 CAPEL EAST are that the proposed development will increase the flood risk both within the development and to the existing communities in Paddock Wood, Five Oak Green, and the surrounding areas.

11.53 The SFRA prepared in support of these policies is not fit for purpose because it does not adequately quantify the flooding risk, does not include comprehensive flood mitigation measures, and does not provide detailed specifications of those measures that have been included:

These development proposals are very reliant on additional storage capacity at Leigh and do not provide any contingency plans should there be a repeated breach. The planned further storage capacity upriver at Leigh will increase river flows down river when under stress causing significant risk to human life.
The impact of climate change has not been adequately assessed over the >100 year horizon and appropriate cautionary allowances have not been made.
The parcels are not currently protected by formal flood defences and the SFRA admits that the development will cause increased flood risk. Given that the proposals remove so much floodplain storage by building on it, then the contradiction should be fairly obvious. There is also an admission that other areas 2 - 12 can only be seen as "not influencing flooding" if they are considered in isolation. That is a seriously weak fudge.
Given that, for the majority of the sites, flooding from the Medway is mostly irrelevant, the Leigh Barrier should be discounted as effective mitigation for these sites - as are widening the Medway, etc.
Loss of floodplain connectivity within rural upper reaches of tributaries which flow through/around the development site is likely to increase flooding.

The SFRA does not conclude that the limited mitigation will eliminate future flood risk or provide evidence of ‘betterment’ to the existing residential areas.

11.54 The above policies are inconsistent with Policy EN 1 : Water/Flooding:

Ensure there is adequate drainage provision. This will ensure that the surface water is appropriately controlled within the development site, flood risk is managed on-site and off-site, and any existing flood risk, in the locality is not exacerbated: and
Avoid inappropriate new development within areas at risk from flooding, or mitigate any potential impacts of new development within such areas whereby mitigation measures are integral to the design of the buildings.

Development/removal of this part of one of the UK’s largest floodplains is not appropriate and the presented plan does not provide the necessary justifications for the release of Green Belt land.

11.55 It is extremely concerning that TWBC have not provided sufficient evidence and assurances that the identified sites, situated in a well-documented flood vulnerable area, will be protected and are prepared to ignore NPPF guidelines, and local community concerns, in pursuit of achieving their housing targets.

12 : CA1 TUDELEY DEVELOPMENT

[TWBC: see full report, including diagrams, figures and pictures for Figure 12].

12.1 Draft Local Plan: The proposed development of Tudeley in the Draft Local Plan is listed as Policy STR/CA1 with the following requirements:

The provision of a standalone garden settlement (referred to as Tudeley Village) of 2,500-2,800 dwellings, together with appropriate employment, including retail provision, within the settlement. This shall be developed using a comprehensive masterplanning approach;
The delivery of a new secondary school to the west of Tudeley Village (and to the east of Tonbridge);
The provision of a new primary school within Tudeley Village and the expansion of Capel primary school;
Together with land outside of Capel parish on the northern, eastern, and southern sides of Paddock Wood, and within the town centre, a proportion of approximately 4,000 new dwellings and associated education, leisure, and health facilities to be delivered (on the wider allocations);
The provision of flood storage/attenuation/mitigation areas to reduce the flood risk to particular existing residential areas in Five Oak Green and Paddock Wood;
Strategic transport links shall be provided between Tonbridge, Tudeley Village, the A228, Five Oak Green, Royal Tunbridge Wells/Southborough, and land at Capel and Paddock Wood and Paddock Wood Town Centre. To include the provision of an offline A228 strategic link. Links from Tudeley Village to the east should minimise the impact on the road network in the settlement of Five Oak Green and have regard to Kent County Council minerals allocations in the vicinity. The exact location of such a link has not been determined;
Strong green infrastructure must be provided to tie in new development with the surrounding landscape. Multifunctional green infrastructure (green wedges) to be integrated with drainage and flood defence measures;
Additional housing may be delivered through the redevelopment of appropriate sites and other windfall development inside the defined Limits to Build Development of Five Oak Green;
Tudeley Village and land at Capel and Paddock Wood will both require the release of Green Belt land.;
Furthermore, the northern part of the site allocation for employment at Land adjacent to Longfield Road (Policy AL/RTW12) (which predominantly comprises land indicated as Open Space and Buffer and will not include built development on it and therefore will not be released from the Green Belt), also lies within Capel parish;
Zero and low carbon energy production to be considered during early design stages and incorporated to provide an exemplar scheme;
Where a site is within the AONB, it should be demonstrated that the proposal will make a positive contribution towards achieving the objectives of the most recent AONB Management Plan and show how relevant guidance from the AONB Joint Advisory Committee has been considered to meet the high standards required of the other policies in this Plan for the High Weald AONB landscape;
Sites outside the AONB but within the High Weald National Character Area, or close to the boundary of the designated AONB landscape, will have similar characteristics and are likely to contribute to the setting of the designated landscape. The AONB Management Plan and any supporting guidance will be a material consideration for these sites.

12.2 Flood Policy Statement AL/CA1 Tudeley: The provision of flood storage/attenuation/mitigation areas to reduce the flood risk to particular existing residential areas in Five Oak Green and Paddock Wood;

- Contributions will be required for flood storage/attenuation/mitigation;

- the masterplanning for this site be linked with the strategic delivery of infrastructure, including in relation to surface water, multiple benefit Sustainable Urban Drainage Systems, foul water, etc.;

- the development on the site should demonstrate that it will not exacerbate flooding elsewhere in the vicinity, particularly from the Alder Stream at Five Oak Green, and that as part of the wider delivery the development delivers storage/attenuation/mitigation, to reduce the flood risk to particular existing residential areas in Five Oak Green. This is also one of the justifications for the release of Green Belt land;

- regard should be given to the Groundwater Source Protection Zone which falls within the north of the site and the Environment Agency should be consulted on any planning applications coming forward.

12.3 Strategic Flood Risk

12.4 Whilst we acknowledge the SFRA report on Paddock Wood, there is no such assessment for CA1 Tudeley. This is despite the Policy Overview stating “Flood Zones 2 and 3 in northern part of Tudeley”. It is well known that many parts of this site are regularly subjected to flooding, as demonstrated in this report.

12.5 Given the absence of information regarding the development parcels within the allocation, unlike PW1 Capel East, the consideration of Policies EN26-EN29 covering Water Resources, Drainage and Flood Risk cannot be adequately made. A full SFRA, with parcel analysis, for the proposed site CA1 is required for several reasons, including:

The northern section of the proposed development CA1 includes areas within the floodplain as shown in the EA current flood risk map (Figure 6) even before any adjustment for climate change.
There is no assessment of the effects of this proposed development on the surrounding communities located along this flood plain.
The increased risk of flash flooding from surface water given the vast amount of lost agricultural land.
Run-off from developments, including roofed and paved surfaces.
The specification of adequate SuDS to mitigate the flows and filter contaminated run-offs.
The site is already at risk from extensive surface water flooding (Figure 13 below).
The assessment of the impact of climate change on local and wider areas.

12.6 The EA map below shows the likelihood of surface water flooding, and is a general indicator of an area’s flood risk but does not include flood risk from sources such as blocked drains and burst pipes.

[TWBC: for figure 13 referred to above, see full report, including diagrams, figures and pictures].

12.7 The area proposed for removal from the Green Belt designation is shown in red outline. This surface water map confirms the existence of several flow routes that dissect the site, particularly in the northern parcel, and is supported by extensive flood history (see section 3).

12.8 Railway

12.9 The site is divided by the South Eastern Main Line and both the CA1 Polices and Infrastructure Plan do not include any explanation of how the two main parts of the “garden village” will be connected. The location of these developments would lead to significant noise and other pollution problems. Also, a bridge(s) over the line will need to be built to connect the two halves of the proposed village. The specification would undoubtedly be required to be high enough to allow for possible future conversion of the line to overhead power cables.

12.10 There is currently only one small bridge under the line to allow access for farm vehicles and the small number of 14 dwellings along Sherenden Road in the central portion. However, this is frequently flooded in the winter months and regularly throughout the year. The possibility of solving the problem with a level crossing is almost certainly to be rejected given how busy the rail line is and how much road and pedestrian traffic there would be using it. A new station at Tudeley has been refused by Network Rail.

12.11 There are a number of existing culverts running under the Railway line. These would need to be regularly maintained to prevent flooding. It is likely that additional culverts will be necessary but these will need to consider flood risk and water flows on to the northern section in particular.

12.12 Increased Flood Risk

12.13 The geology, topography, and hydrology of the CA1 Tudeley site has been explained earlier in this report (sections 1, 2 and 6). The area to the north of the railway is much lower and the water flows are broadly south to north. The railway embankment provides some restriction and banking of water, particularly at the eastern section.

12.14 This area of approximately 375 acres of substantially undeveloped agricultural land already sends vast amounts of water northwards to the fully functional floodplain and aquifers. The scale of the proposed development would mean that extensive flood mitigation measures are needed due to the substantial increase in flood risk (see below):

Substantial run-off from the construction of buildings, roads, driveways, and other impermeable areas
Restriction of the existing agricultural ditches and watercourses that have been in place for centuries which are not designed to accommodate the run-off and drainage from this proposed level of development
Loss of floodplain connectivity within rural upper reaches of tributaries which flow through/around the development site
A large proportion of existing vegetation would be destroyed - trees, wooded areas, hedges, surface vegetation and crops. This vegetation absorbs large quantities of water during active growing periods significantly reducing the ground water level ahead of the winter. Water volume and flood height will increase, e.g. a single mature Oak tree can absorb 100,000 gallons of water from the ground each year (Building Research Establishment).
Contamination risk from pollutants in run-off flows to the GSPZ aquifers at Hartlake and other watercourses.

12.15 Flood Risk Management

12.16 The Policies STR/CA1 & AL/CA1 TUDELEY do not provide any detail on how the proposed development will provide mitigation and merely state that this will be determined in masterplanning. This means that this plan cannot demonstrate that it is sound or deliverable. The flood policy statement is also unsound as it only includes Five Oak Green and Paddock Wood and does not consider the more immediate impacts on Tudeley residents nor the effects on East Peckham and further downstream from the barrier.

12.17 Strategic Storage: Many of the development proposals throughout the Draft Local Plan are very reliant on additional storage capacity at Leigh to provide flood mitigation and do not provide any contingency plans should there be a repeated breach. The planned further storage capacity upriver at Leigh will increase river flows down river when under stress causing significant risk to human life.

12.18 The masterplanning will likely include the construction of additional strategic storage facilities/reservoir(s) to restrict the water flows from the development. Whilst the location is unidentified, there are several relevant issues that need to be considered:

The southern parcel (south of the railway) of the CA1 site does not directly benefit from the strategic storage at Leigh, given that the existing flooding here is from run-off from higher ground to the south, surface water, and watercourses that are downstream.
The southern parcel comprises c. 250 acres of agricultural land (with 9 dwellings) and, given the sloping nature of the terrain (see Figure 14), the development would result in vast amounts of run-off that will descend towards the railway and eastwards across the Sherenden Road area. The railway embankment already acts as a buffer, particularly in the north-east, and this is also shown in the above surface water map.
The design of strategic storage in the southern parcel would need to take account of the risk of a possible future breach and, in particular, its effect on the northern parcel. This also has implications for the build design and other mitigation measures (see below). [TWBC: for Figure 14, see full report, including diagrams, figures and pictures].
Large areas of the northern parcel are already subject to risk from fluvial flooding of the Medway and, whilst the increased capacity at Leigh would provide some strategic mitigation, a repeated breach would cause increased flood levels compared to those in 2000 and 2013.
The northern parcel comprises c. 125 acres of substantially agricultural land (with 5 dwellings) and is closely linked with the Medway floodplain. Given the relatively flat landscape, and closer proximity to the water table, any strategic storage for this parcel would need to be considered along with other extensive mitigation measures (see below).

12.19 Residual risk of any new reservoir(s) and potential flood defences (see below) should be understood and managed and maintenance arrangements (including funding mechanisms) will need to be evidenced for the lifetime of the development (>100 years) including appropriate allowances for climate change.

12.20 Flood defences: There are no formal strategic flood defences at these sites and it is important to understand the consequences if the design standard of any new defences is exceeded or if they fail.

12.21 It will need to be demonstrated that the defences will not have a resulting negative impact on flood risk elsewhere and that there is no net loss in floodplain storage that could cause flood water levels on adjacent land to be elevated.

12.22 Increased conveyance: There are a number of well-maintained and regularly dredged streams and ditches that exist on the proposed site. These are important both in allowing water from adjacent areas to pass through and providing water storage capacity. Robust sustainable provision will need to be made to ensure this capacity is sufficient to mitigate the increased flood risk from the proposed developments.

12.23 Raising levels: The raising of occupied floors of buildings above ground level so that a relatively unobstructed flow route under buildings may substantially reduce flood depths. The raising of floor levels within a development also reduces the risk of damage occurring to the interior, furnishings and electrics in times of flood.

12.24 Given the nature and likely requirement of these being compulsory measures within the northern parcel, and northern/eastern parts of the southern parcel (see Figure 14) in particular, the exact level of land raising is dependent on the predicted flood levels and the EA allowance for climate change. The building design must specify how the flood risk from ALL sources is adequately mitigated.

12.25 Finished Floor Levels (FFLs) should be set to the higher of a minimum of 600mm above the 1 in 100-year (1% AEP) plus climate change peak flood level, or 300mm above the general ground level of the site. Additional freeboard may be required to account for risks such as blockages to the channel, culvert or bridge, reservoir breaches, and the uncertainty in the predictions.

12.26 The raising of building levels facilitates the construction of containment tanks, and other SuDS initiatives, and strategic drainage flows and watercourses can be accommodated within the freeboard.

[TWBC: for image see full report, including diagrams, figures and pictures].

12.27 Sustainable drainage systems (SuDS): These systems aim to alleviate surface water flooding by storing or re-using surface water at source. As surface water flows through the system, flow velocity to watercourses is controlled and pollutants are removed. Regulatory guidance must be considered in relation to the raised floor level requirements:

Planners should be aware of the conditions set by the LLFA (KCC) for surface water management and ensure development proposals and applications are compliant with the policy. SuDS should be promoted (and implemented) on all new developments to ensure the quantity and quality of surface water is dealt with sustainably to reduce flood risk. On substantial development sites consideration should be given to the integration of sustainable water management with the provisions for green infrastructure within urban areas.
The location of surface water attenuation storage or other forms of SuDS will impact the masterplan in terms of developable area, building design and access. In addition to the statutory planning requirements, building occupiers are increasingly aware of the potential for flooding to impact their operations. As a result, some major occupiers are imposing their own flood risk standards which are more stringent than the planning requirements.
Where an investor (and insurer) is considering an asset that satisfies the statutory requirements, this may not be sufficient to truly consider the potential for re-letting, with some occupiers being unwilling to compromise their own demanding flood standards.

12.28 Comprehensive SuDS are certainly required to mitigate the flood risk within the development and to ensure pretreatment of contamination risk prior to infiltration to the fully functional floodplain and the aquifers.

12.29 Policies STR/CA1 & AL/CA1 have not identified the measures necessary to mitigate the flood risk within the development and the stated ‘betterment’ of flood risk to the existing residential areas would need to be evidenced with a suitable guarantee that would satisfy insurance underwriters.

12.30 This report has highlighted the many inconsistencies within the Draft Local Plan and, considering the evidence, it seems incomprehensible that the Council has not conducted a SFRA for CA1, unlike other identified flood vulnerable sites. The presented Plan is neither sound nor deliverable and does not provide the necessary justifications for the release of Green Belt land.

13 : SEWERAGE

13.1 Flood risk

13.2 Since 1980, the Sewers for Adoption guidelines have meant that most new surface water sewers have been designed to have capacity for a rainfall event with a 1 in 30 chance of occurring in any given year, although until recently this did not apply to smaller private systems. This means that, even where sewers are built to current specification, they are likely to be overwhelmed by larger events of the magnitude often considered when looking at river or surface water flooding (e.g. a 1 in 100 chance of occurring in a given year).

13.3 Existing sewers can also become overloaded as new development adds to the discharge to their catchment, or due to incremental increases in roofed and paved surfaces (urban creep). Sewer flooding is therefore a problem that could occur in many locations across the Tunbridge Wells Borough and more specifically in Paddock Wood.

13.4 In Five Oak Green, we are aware that some surface water finds its’ way into the foul system at times of elevated stress on the system overall. That is why some houses have had to be fitted with non-return valves under their bathrooms to prevent sewage coming up from the drains.

13.5 In Paddock Wood, the areas susceptible to sewer flooding are generally located from the allocated parcels in the plan which are predominantly in rural locations. One notable exception is the parcel to the west of Maidstone Road which is located adjacent to an area which has experienced at least six instances of sewer flooding.

13.6 Current Infrastructure

13.7 There is a single treatment plant that serves Capel, Paddock Wood, and surrounding areas which is located at Rhoden, Paddock Wood (see drainage map below). The total catchment area is approximately 3,600ha, with an elevation range of 7mAOD to 149mAOD and the sewerage system is primarily separate.

[TWBC: for Figure 15, see full report, including diagrams, figures and pictures].

13.8 The Paddock Wood foul drainage system is split into two distinct areas by Tudeley Brook. The western area comprises of the village of Five Oak Green and a number of hamlets and farms to the south, connected to the network by a terminal SPS. In Paddock Wood piped flows drain north east to two terminal SPS discharging to the treatment works.

13.9 The surface water drainage network follows the highway layout and discharges at a number of locations to the Rhoden Stream, Gravelley Ways Stream and Paddock Wood Brook. There are also surface water attenuation ponds predominantly located in the south of the town, for which Paddock Wood Town Council are responsible for.

13.10 Paddock Wood Brook passes through the urban area and is culverted for the majority of its length. There are two unculverted sections, one off Rowan Close and a section alongside The Cedars. The Gravelley Ways Stream is a narrow water course which borders the western extent of the town into which some of the urban runoff discharges.

13.11 Sewerage from Five Oak Green is pumped to the treatment plant at Paddock Wood by a pumping station situated between Oak Road and Larkfield. There is a catchment tank which can hold enough to give time to bring tankers if the station fails. Failure occurs on a regular basis due to plant failure, pipe failure both upstream and downstream or power supply failure (there is no backup generator). Failures mainly last for days or in some cases weeks. In the event of such a failure three large tankers are brought in to remove the sewerage, with one full tanker load being removed every hour. The regular failures that occur are due to the existing system being overloaded and the age of the system.

13.12 The current sewer infrastructure is already under excessive strain, there are two very old large pumps, and one has been out of commission. The pumps are so old that parts have to be specially made as the manufacturer no longer exists.

13.13 The current house building programme in Paddock Wood has been halted due to inadequate sewerage infrastructure and we believe that one developer (Berkeley Homes) is working on the provision of huge sewerage/water storage holding tanks with Southern Water.

13.14 Flood history

13.15 Historical incidents of flooding are detailed by Southern Water in their DG5 register. This database records incidents of flooding relating to public foul, combined or surface water sewers and displays which properties suffered flooding. The data provided by Southern Water covers all reported incidence as of its export of 3 October 2016.

13.16 DG5 records provided by Southern Water indicate that there have been more than twenty reported flood instances in the Paddock Wood area as a result of overloading public sewers.

13.17 Town Council committee minutes reveal that many more flood instances occur but residents were unable to get through to Southern Water at the time. There are residents living in bungalows in Paddock Wood that are unable to use their toilets in times of heavy rainfall as they will overflow.

13.18 Southern Water recorded sewer flooding in 2008 and 2009. The EA also describes issues of hydraulic overload from foul sewers in Five Oak Green.

13.19 Proposed Development

13.20 Southern Water have confirmed that any projects of a strategic scale that are required to increase the local sewer network capacity, in particular in the Paddock Wood/Capel area, will need to be included in their next AMP. This will cover the period from 2025-2030 and will be agreed by Ofwat.

13.21 Where capacity constraints for new development have been identified in the sewer network, occupation of development will need to be phased with the delivery of network reinforcement, in liaison with the service provider and Southern Water has requested that this requirement is set out in the Local Plan.

13.22 Current Development: Sewer flooding is already a regular problem within Paddock Wood/Five Oak Green and, due to lack of investment over many years, the current system is already at capacity. Recent developments have been delayed/suspended as Southern Water are working with developers on additional storage capacity solutions as any further connectivity to the current infrastructure will seriously compromise existing users.

13.23 Existing sewers have become overloaded already as new developments add to the discharge to their catchment, due to incremental increases in roofed and paved surfaces at the individual property scale and sewer flooding is already a major problem. New homes are being built and connected to a sewerage system that is already so inadequate that it results in sewage flowing through the streets and the flooding of existing properties. The overload of the current network has unacceptable, unhealthy and frankly disgusting consequences for residents.

13.24 Greg Clark MP met with representatives of Southern Water, members of Paddock Wood Town Council, and officers and members of Tunbridge Wells Borough Council and Kent County Council on 7 September. All those local representatives were dismayed to discover that the previous plans were not even going to be proceeded with, and that the company had in effect gone back to the drawing board to consider what could be done about the capacity in Paddock Wood.

13.25 Mr Clark also raised this matter in a Parliamentary debate in the House of Commons on 28-Oct-2019 and asked three questions of The Under-Secretary of State for Environment, Food and Rural Affairs (Rebecca Pow):

1) Will she intervene to insist that Southern Water present comprehensive infrastructure plans without further delay to the community of Paddock Wood and others in my constituency where development is being considered, and that it implement those plans?

2) Will she strengthen the powers of local councils to require water companies to make an assessment of the infrastructure needs, and not to approve new development until it is certain that the infrastructure will be provided before or at the same time as the development?

3) Will she accept that if we as a nation are to support development, whether it is in the town or the countryside, commercial or residential, the rules should be established and acted upon, and that there is always I before E: infrastructure before expansion?

Ms Pow replied “Without a doubt, evidence highlights that the performance of Southern Water has left a great deal to be desired. If improvements are not forthcoming, I shall be requesting a meeting with Southern Water. I believe my right hon. Friend asked whether I would step in and take some serious action, and I shall be doing that and asking some serious questions” and agreed to meet with Mr Clark saying “Of course I will meet my right hon. Friend. We want water companies that are working effectively and efficiently, and we need to understand the pressures they are under and how to deliver for all new houses. We are committed to building new houses as a Government. We need new houses, but they need to function properly, with the right infrastructure, so of course I will meet him. In conclusion, we want to see a water industry that puts customers at the heart of the business, contributes to communities, and protects and enhances our precious natural environment. I will continue to push the sector and hold water companies, such as Southern Water in this case, to account if necessary”.

13.26 Paddock Wood and Capel: Southern Water note that treatment capacity is currently limited at Paddock Wood, and the levels of development proposed exceed the current catchment forecast. The level of growth outlined at this stage for Paddock Wood will more than double the size of the catchment, triggering the need for investment in network and treatment capacity solutions.

13.27 There will be a need for investment in the Paddock Wood treatment works to deliver increased capacity for the proposed housing growth. Therefore, new development would need to be coordinated with the provision of additional capacity and Southern Water will need clarification on the potential phasing of new development to ensure that this issue is addressed early in the process and to ensure that this investment is delivered alongside the housing growth.

13.28 Whilst land around the existing plant has been safeguarded for necessary expansion, Southern Water do not currently have an allocated budget for any extension, and have not provided any guidance on its expected delivery.

13.29 Capel (CA1 Tudeley): Southern Water will be carrying out further capacity assessments at both the existing Paddock Wood and Tonbridge treatment works to assess capacity to meet the future needs of all the proposed developments in Capel parish, including CA1 Tudeley.

13.30 In terms of the sewage network, this is upgraded in line with the specific requirements of individual development proposals as they come forward. It is likely that some sites will necessitate reinforcement of the sewerage network in order to accommodate additional foul flows. Southern Water aims to provide timely infrastructure in cooperation with developers and the local authority, and therefore early engagement is encouraged.

13.31 Given the above constraints at Paddock Wood and extensive increased demands on the Tonbridge sewerage plant, there is a very real likelihood that a complete new treatment plant will be required at Tudeley. Whilst the provision of sewerage facilities has not been specified, the consequent run-off to the Medway floodplain from new plant would further add to flooding risk and adequate/enhanced mitigation from SuDS and other measures must be incorporated in the build design at CA1 Tudeley (see section 12).

13.32 TWBC has confirmed (12-Nov-2019) that there are no detailed plans for sewerage infrastructure provision at CA1 and this would be ‘determined through infrastructure masterplanning’. They expect to receive further information from Southern Water in their response to this Regulation 18 consultation.

13.33 Funding sources: Developer contributions for local sewerage infrastructure will be secured through the New Infrastructure Charge.

13.34 Additional investment in waste water treatment works is funded by Southern Water through the water industry's price review process as agreed by Ofwat. Over the lifetime of the Local Plan, there will be repeated opportunities to fund any future investment as it is needed.

14 : POTABLE WATER SUPPLY

14.1 Current Infrastructure

14.2 At present the water supplying the Capel/Paddock Wood area (WRZ7) is taken from Trottiscliffe and the surrounding areas (from groundwater) where it is treated. This supply is then transported via strategic mains to a storage reservoir at Bour Beech (Seven Mile Lane), then onto the Paddock Wood Service reservoir (Gedges Hill) and then out to supply the local areas. Occasionally the water is also taken from Bewl Water (a surface reservoir) and transferred to the area via trunk mains and a storage reservoir.

[TWBC: for Figure 16, see full report, including diagrams, figures and pictures].

14.3 The EA has applied a Groundwater Protection Zone (GSPZ) related to the aquifers at Hartlake (Figure 16 above) with the route of the supply from the Hartlake Wells shown on the right:

* Hartlake Wells pump → Lilley Farm → Paddock Wood reservoir → Pembury/Tunbridge Wells customers

14.4 In 2018 work near Brampton Bank was carried out to replace pipe section being 350mm diameter that feeds from Lilley Farm to the Paddock Wood Reservoir, Pembury.

14.5 Out of the five public wells at Porters Lock Hartlake, the old Well route is to the West, and a newer uPVC pipe runs to the East which scales 800m downstream. This indicates that a while ago Hartlake needed to draw more because Tunbridge Wells needed it, so another draw line was drilled and built to tap into the old system being the concrete bases in the middle of the hoppers, now corn field.

14.6 A system of private water mains belonging to Hadlow Place Estates exists around the area of the proposed CA1 development which they would like to pass over to South East Water (SEW). Given that SEW also have a mains in Hartlake road this seems unlikely to happen. In any event, the water pressure in both systems is very low and even combined they would have no where the needed capacity to supply the proposed new town. Indeed where any of these pass under the site they may well be required to be capped off to reduce the risk of future leeks causing subsidence.

14.7 Proposed Development

14.8 SEW have stated that the same sources will be used in the future and forecasts for WRZ7 show there would be a deficit in the amount of water available to supply the growing demand by 2030.

14.9 A number of different options are being investigated to ensure enough water is available including demand management, reducing leakage, metering, recycling water, creating new sources, sharing water with other companies and expanding our current sources and treatment capacity.

14.10 Paddock Wood and Capel: Whilst SEW have stated that there is sufficient capacity in the existing network to supply the planned developments in East and Central Paddock Wood, there will also be large strategic mains installed to take surplus water from a new source of water at Aylesford towards Beech reservoir by 2023.

14.11 This will allow for more water to be transported in and around the WRZ7 area via the large strategic mains and to support the expected growth in consumption at PW1 Capel East. For the new source at Aylesford some of the existing network between Beech and Paddock Wood will need to be reinforced.

14.12 For the properties near Tudeley, SEW plan to lay new mains to connect back to a strategic trunk main that transfers water from Beech reservoir to Paddock Wood reservoir as the existing pipes are typically much smaller at around 5” and unable to sustain higher demands. They plan to link in the Capel East development to the same main with a short section of reinforcement main.

14.13 Funding sources: The Water Act enables South East Water to charge developers for a contribution towards any reinforcement and new mains required as a result of new development to ensure it maintains levels of service for both new and existing customers. The cost of contribution is based upon the cost of both on-site and off-site mains less all the revenue South East Water receives over the first 12 years for the new properties.

14.14 Capel (CA1 Tudeley): Although there is some capacity already in their plans to serve the proposed Tudeley garden settlement, it is considered that it may require an adaption or expansion of the existing mains. This is in addition to the laying of new mains within the residential area.

14.15 SEW have carried out extensive investigations into eight groundwater sources, and within its Water Industry National Environment Programme (WINEP) report it identifies concerns of raw water quality deterioration from significant levels of nitrate and pesticides, metaldehyde and carbendaizm.

14.16 The Hartlake catchment is already at risk from nitrate and pesticides and the investigation found a significant relationship between groundwater levels in the river terrace gravels at the Hartlake site and River Medway levels and flows. Metaldehyde has been applied to the nearby neighbouring agricultural land surrounding the abstraction and high levels of metaldehyde concentrations have also been found in the River Medway.

14.17 The GSPZ catchment area of the significant Aquifer at Hartlake, which is SPZ3, extends under almost all the section of CA1 Tudeley that is north of the railway line. Any further development of this area may impact water supply options that serve SEW customers in Pembury and Tunbridge Wells:

SEW have stated they intend to use the same sources of Hartlake Wells for future supply but have not anticipated additional provisions for 2,800 new homes, which would result in a deficit in the area by 2030.
SEW will be required to increase the current water infrastructure which will require a substantial developer contribution under the water Act, but there are currently no details of these financial obligations required of the developer/landowner. Furthermore, there is very little detail regarding the improvements of supply, treatment facilities, and timing of their provision which the above highlights is critical to the delivery of the development.
Polluted run-off from the proposed development in both construction and general pollutants/chemicals will find its way into groundwater and aquifer/rivers without extensive SuDS filtration, and indeed as a result of any breach or failure of these measures.
The Council states the protection of ground water resources is particularly important in Tunbridge Wells Borough, since the majority of the public water supply is abstracted from water-bearing strata or aquifers. The quality of ground water is easily polluted, directly and indirectly, and can pose a serious risk to public health.
Clearly CA1 is situated within an area where its water resources are already under serious stress, and currently there are a number of issues outstanding with the Environment Agency, KCC and local residents.
In 2002, KCC refused planning permission for quarry extensions at M13 Stonecastle Farm (see section 7) on the grounds of potential pollution and contamination to the Aquifers, as well as concerns of public health risk, as the Hartlake Aquifers are a source of public and commercial water supply. Future mineral extraction would involve wet excavation methods, and recharge trenches, which will certainly affect the capacity of the Hartlake drawdown.
The draft plan does not identify the neighbouring two historic landfill sites which have had millions of tonnes of household and industrial rubbish deposited there in the 1980’s and 1990’s. Given the historical issues regarding previous mineral workings, and the major concerns of further pollution to the surrounding aquifers it is very concerning that the Council have not appeared to have considered the potential environmental and health risks prior to the inclusion of CA1 Tudeley in the Draft Local Plan.

14.18 The Draft Local Plan has not considered the potential environmental issues around the Hartlake Aquifers and, with rising nitrate and pesticide levels that have already been identified, any penetration to the Aquifers would lead to further significant human health risks.

14.19 The Aquifer and natural springs within the CA1 site will seriously hinder excavations for building, sewage, drainage, etc. as suitable mitigation schemes will have to be implemented to avoid puncturing the natural clay membrane that protects the Aquifers.

15 : SUSTAINABILITY APPRAISAL

15.1 There were 13 sites brought forward as proposed Garden Settlement Sites:

1) Blantyre House, (Former Prison) Goudhurst Parish,

2) Capel,

3) Frittenden Area,

4) Horsmonden,

5) Iden Green,

6) Kippings Cross, East of Pembury and adjacent to the northern and southern carriageways of the A21,

7) Land Adjacent to Colliers Green Primary School, Colliers Green

8) Land at Great Bayhall, East of RTW,

9) Land between Cranbrook & Sissinghurst,

10) Land between Sandhurst and Iden Green,

11) Langton Green, adjoining western edge of existing development

12) Paddock Wood, land surrounding the existing settlement

13) Walkhurst Farm, Benenden

15.2 Eleven sites were rejected or did not come forward in the final call for sites process.

15.3 The two allocated sites (PW1 and CA1) are within a 3 mile radius and situated on/adjacent to a dedicated floodplain with a well-known flood history, all the other sites are not situated at such flood vulnerable locations. It very much appears that Flooding has a much lower score rating with TWBC within its Sustainability Assessment commentary than other LPAs.

15.4 Given the flood history of the two identified areas and the substantial size of the developments, the overwhelming evidence seems to indicate that the scoring/rating assessment/analysis has not been considered/evaluated equally across the Borough, and has failed to evaluate the potential risk to human health/life should further flooding occur.

15.5 Chapter 4: Methodology (Table 4 pg.24) states “KCC Draft Minerals and Waste Local Plan - Sites at Moat Farm and Stone Castle, Five Oak Green are adjacent to the boundary with Tunbridge Wells Borough (TWB)”.

Since both Moat Farm and the entrance to/large parts of Stone Castle Quarry are within TWB, and adjacent to the proposed CA1 site, this error reinforces our view that the Mineral Assets have not been adequately considered in the Draft Local Plan (see section 7).

15.6 Chapter 6: Spatial Development Strategy (Table 15 pg.42) states “There is also potential for increased flood risk due to cumulative effects. However, significant betterment of flooding issues at Paddock Wood and Five Oak Green, and policies for other smaller sites, will provide significant positive benefits. Overall score is mixed”.

It is now understood that the Alder stream project would not be progressed and the ‘betterment’ for FOG would be through CA1 Tudeley, as confirmed by TWBC Head of Planning (12-Nov-2019).

Given the total absence of any specification of flood mitigation at CA1, this “mixed” score is certainly not sustainable as it cannot be proven to be deliverable.

15.7 Chapter 6: Spatial Development Strategy (Table 16 pg.45) states “A mixed/positive water scores is applied to [CA1] as it would represent a substantial demand for water and wastewater treatment and would provide significant benefits to Five Oak Green in the form of reductions in existing flood risk. The presence of the total catchment of a Groundwater Source Protection Zone north of the railway line also creates a risk that must be carefully managed”.

Here, again the “mixed/positive” score is not proven to be deliverable. Even with extensive storage of increased run-off from the CA1 development, the risk of breach, and/or sewerage/drainage failures, increases the overall flood risk to the existing residential areas. The effect on the Aquifer cannot be determined due to the lack of detail. 15.8 Chapter 6: Spatial Development Strategy (Table 17 pg.48) states “A mixed water scores is applied equally across the options as all would represent a substantial demand for water and wastewater treatment, and all would provide significant benefits to Paddock Wood in the form of reductions in existing flood risk…An improvement to flooding issues for existing residents is one of the key justifications for the proposed release of this Green Belt land on the west side of the settlement”.

The “mixed” score is not sound as the SFRA has not properly addressed the measures necessary to mitigate the flood risk from the PW1 Capel East development (see section 11).

The SFRA does not conclude that the limited mitigation will eliminate future flood risk or provide evidence of ‘betterment’ to the existing residential areas.

16 : OTHER CONSIDERATIONS

16.1 The character of the parish of Capel, situated in the green belt, would be virtually destroyed by the cumulative effect of these developments, together with quarry extensions, with the removal of more than 1,000 acres of agricultural land. The Capel sites comprise of a total of around 650 acres and each acre of wheat can absorb nearly 600,000 gallons of water per crop (USDA & NIFA²) [² eXtension.org. Supported by USDA United States Department of Agriculture and NIFA National Institute of Food and Agriculture.]. It is estimated that around 60% of annual rainfall could be taken up by the vegetation and crops, when compared with the average annual rainfall of 600mm (MetOffice).

16.2 Poor sales potential: House prices, given the increased flood-related building costs resulting in higher selling prices, may well reduce sales potential. This has already become evident with the current development in Paddock Wood, and also it appears at Marden. Two new houses in Five Oak Green, built with elevated ground floors to accommodate surface water storage underneath, have been on the market for well over a year and despite a significant drop in the price have significantly failed to sell.

The required elevation of FFLs, as in the case of Ellis Close in Five Oak Green village, would add additional height to the houses themselves and added costs to the construction. This would also mean that the houses may be more difficult to sell to families with members who have disabilities and/or young children.

Even more important, with the floods that have occurred in many parts of the country and the publicity they have received, potential customers may well avoid purchasing in low lying areas where such flood risk exists. This could have a devastating effect on sales. It may well be that potential developers may decide that it was not even worth the risk of becoming involved with such a development!

16.3 Setting: The proposed extension of Stonecastle Farm Quarry and additional Quarry at adjoining Moat Farm, within Kent County Councils Minerals and Waste Local Plan 2013-2030, has not been fully considered within the CA1 development plans. Who will want to buy a house looking into a quarry for possibly the next 20-30 years?

Virtually all the residential development at CA1 will be affected by the noise, air and light pollution from the South Eastern Main Line. This would restrict the market’s attraction for the new homes.

Much of the residential development at PW1 will back on the A228, with a vast increase in traffic resulting from the housing increases and quarry trucks.

16.4 Affordable housing: Ground conditions will mean that foundations for buildings will need to be deep and pass through a bed of highly unstable gravel. Foundations for roads etc. will also need to be robust enough to prevent subsidence and Piling may be used but, if deep, will be very expensive. The required extensive installation of SuDS, to mitigate flood risk, would likely wash fines/soil flows under foundations and lead to possible failure. This adds to the costs of strategic storage and other measures; all of the above will make the site expensive to develop.

16.5 The landowners/developers and LPA are blithely promising a high percentage of affordable housing. This is a regular promise made for similar developments which are then almost inevitably ignored. Given the high cost of building at these flood affected sites, it is difficult to see how these targets could be achieved unless such costs are offset by a sizable reduction in the realized values from the development land.

16.6 Site Access: Sites will be difficult and potentially dangerous to access, made even more so by clay based mud deposited on the road by construction traffic leaving the site that by its nature would be difficult to remove, presenting a very real skidding hazard to traffic.

16.7 Much of the area becomes very muddy. Access and site roads would need to be established before work could start. Working conditions would, at best, be very difficult and in the winter the whole site could easily turn into a muddy quagmire that could well lead to work having to be suspended. Trenches dug for foundations would fill up with water even while they were being dug, throughout much of the year.

16.8 Even simple matters such as providing parking for cars and vans would need to be addressed. When the nearby Solar Farm was being built, which needed relatively little site traffic, some areas became simply impossible to walk on due to deep glutinous mud!

16.9 Insurance: For some properties within these developments insurance cover for flooding is likely to be difficult, expensive or even impossible to obtain. No houses built from 2009 onwards can beneﬁt from the Flood Re. Scheme as, if they are in a ﬂood risk area, they are required to have resilience built in to the development. If new developments cause a greater ﬂood risk to older houses these may have insurance problems, obviously.

16.10 Mortgages: There may also be problems obtaining mortgages - we understand that mortgages have been recently been refused on some properties along Maidstone Road in Paddock Wood because of flood risk.

17 : CONCLUSION

17.1 The Capel sites in the Draft Local Plan are neither sound nor deliverable. The policies do not demonstrate that planners have considered the full effects of flood risk, they have not specified adequate flood mitigation measures, and have inadequately assessed the impact of climate change. There is an over-reliance on the Leigh barrier, which provides no benefit to much of the area, and the stated ‘betterment’ is not proven. Therefore, the justification for the removal of Green Belt land is not substantiated at both sites.

17.2 In Paddock Wood (PW1), the exclusion of raised levels in the build design, and the necessary SuDS initiatives, demonstrates that planners have not addressed the flood risk on this floodplain and the effects of any breach of the reservoirs. Development/removal of this part of one of the UK’s largest floodplains is not appropriate.

17.3 In Tudeley (CA1), there is no assessment of the flood risk to existing communities (no SFRA) and the additional costs of railways crossing(s), and necessary extensive flood mitigation, would likely make the development unviable. This, together with the masterplan approach with the landowner, who has no proven development experience, renders the Plan unsound, not sustainable, and an unacceptable risk for the Borough.

17.4 We understand the pressure TWBC is under to deliver its housing targets but it should not be at any cost, especially when it involves so many people/communities and the effects will be irreversible. There are numerous precedents where plans have been rejected for flood risk, e.g. at neighbouring Yalding and the Garden Village in Essex, and TWBC should be adopting a robust defence of the Green Belt and floodplain.

17.5 There is wide condemnation of the 2014 housing needs assessment and the Council should be defending more appropriate (and current) projections. Given we are in an General Election campaign, and with the ongoing Brexit uncertainties, we urge the Council to reconsider and remove these flood affected sites from the plan now before committing to further costs and taxpayers money.

17.6 Existing developments in Paddock Wood have halted due to inadequate sewerage infrastructure and questions were raised in Parliament. After record fines this year, there is no confidence that Southern Water will fulfil the needs of the proposed 4,000 additional houses in Paddock Wood and a possible new sewerage system in Tudeley.

17.7 In this final week of the consultation period we have seen the tragic death of the former High Sheriff of Derbyshire after being caught in floodwater. In Doncaster, 1200 properties were evacuated and 1900 people had to be rescued. This adds to an extensive list of major flood incidents, including the Dam breach and bridge collapse earlier this year, which are now occurring ever more frequently. Planners should take careful regard of these warnings.

17.8 This reports sets out the Capel landscape, flood history, regulatory guidance, external factors, and effects of the proposed developments. The Flood Group have carried out extensive research from the limited information in the DLP and highlight the many dangers, challenges, risks and extraordinary costs any development would have at these inappropriate locations in Capel. These sites Flood and are widely known as flood vulnerable areas on a floodplain.

We submit that Sites PW1 Capel East and CA1 Tudeley must be removed from the Plan – thus preventing the Council from having to re-learn the mistakes of the past………building on/near a floodplain with fatal consequences!

SUBMITTED BY:

Stewart Gledhill, Whetsted

Flood Group Convenor – SaveCapel

ENDORSED BY MEMBERS:

Alan Chilvers, Tudeley
Geoff Croker, Tudeley
Megan Forster, Five Oak Green
Colin Leake, Five Oak Green
Peter Miller, Whetsted
Alaric Smith, Five Oak Green

DLP_7118

Jan Mueller

I wish to object to the TWBC Draft Local Plan - in particular the strategy for Capel Parish (CA1-3).

Attached please find a document detailing alternative solutions to the above developments that have been researched by concerned residents in Capel and surrounding areas.

WE OBJECT TO THE STRATEGY FOR CAPEL PARISH (POLICY STR/CA1)

Report on Alternatives to Tudeley Garden Village (CA1/2) and East Capel (CA3) Developments

In response to the Tunbridge Wells Borough Council Draft Local Plan under Regulation 18

Prepared on behalf of the Save Capel Brownfield Research Team

Contributors: Nigel Tansley & Jan Mueller

A. Introduction

A.1. Report Objective and Content

This report has been compiled in response to Tunbridge Wells Borough Council (TWBC)’s proposals to build an estimated 4,000 houses on Green Belt, productive agricultural land in Capel Parish. We believe these proposals to be misguided and unsustainable.

The objective of this report is to highlight feasible alternatives that would allow TWBC to achieve its housing target without resorting to the destruction of over 600 acres of Green Belt land in Capel Parish.

It provides a summary of suitable sites and alternative solutions to building on Green Belt. We have been pro-active in our search for these sites and solutions. TWBC should be significantly more pro- active in this regard.

A.2. Report Structure

The report commences with two contextual sections to set the scene:

(1) Section B. provides general feedback on the Draft Local Plan and proposed developments in Capel. This includes commentary on Plan methodology and decision-making, climate considerations, the impact on Capel as well as the suitability of the Tudeley site in particular.

(2) Section C. discusses the appropriateness of TWBC’s housing target and suggests alternative requirements.

The core of the report is Section D. which seeks to highlight alternative solutions to achieve TWBC housing target. Here, we investigate the following topics:

(1) How many sites submitted for development were rejected by TWBC but - in light of the decision made to develop land in Capel - should be reconsidered?

(2) How many sites in the borough are available for development (brownfield and other categories) which are not registered on TWBC’s system and what is their housing potential?

(3) What is the additional housing potential if land were to be used more effectively for:

(a) SHELAA sites selected by TWBC;

(b) SHELAA sites rejected by TWBC but that we believe should be reconsidered

(d) Brownfield sites already on TWBC’s register;

(e) incremental Brownfield and other sites identified in this report;

(4) Are there alternative solutions to improve effective use of land by developments?

In closing, Section E. contains a summary of conclusions and recommendations as well as suggested next steps which we hope to undertake in conjunction with TWBC’s planning team.

B. Overall Feedback on the TWBC Draft Local Plan

B.1. Decision-Making and Due Diligence

The TWBC Draft Local Plan (“Plan”) has been years in the making and a lot of careful work and analysis has been undertaken to reach some well-founded and justifiable proposals. The Strategic Housing and Economic Land Availability Assessment (“SHELAA”) documents in particular are generally well thought-out and sound reasons are given for approving or declining sites which had been submitted by landowners.

However, this makes it all the more striking that the proposed development at Tudeley Village and East Capel seem entirely inconsistent with - in fact diametrically opposed to - the standard evaluation criteria, decisions and overall tenets of the Plan. There is a contradiction between the assessment of sites CA1-3 relative to almost all others. The typical reasons for rejecting sites were based on environmental, infrastructure and sustainable development concerns – reasons that we would typically agree with. Unfortunately, when assessing CA1-3 these very same criteria seem to have been completely disregarded. For illustration, please see Figure 1 below – this is just one example, but we could cite many more. As a result, we question the objectivity and consistency of site assessments for CA1-3 as here the Plan seems to employ double-standards.

[TWBC: for Figure 1 see report].

This also inspired an analysis of ‘rejected’ SHELLAA sites which we will return to in Section D.1.

We are also concerned that TWBC has not completed (or has not had the time to complete) the due diligence required to adequately assess the Tudeley Village site in detail and the decision to develop here is ‘built on sand’.

It is astonishing that while careful consideration has been given to Landscape Sensitivity Assessments for locations across most of the borough, this seem to have been completely over- looked for CA1. The nearest location assessed was Five Oak Green village. Similarly, CA1 is missing entirely from the various geo- and biodiversity assessments. Considering the over-reliance on Tudeley / East Capel’s contribution to the overall Plan this is a strange and disconcerting omission.

In researching the apparent absence of a Landscape Sensitivity Assessment for CA1, it became evident that the Reg 18 Draft Local Plan should build upon the findings of the ‘Issues and Options’ document (published May/June 2017). However, much of the evidence base – compiled prior to Hadlow Estate offering hundreds of hectares to TWBC – does not address CA1. For this there are manifold examples:

Issues and Options document

The ‘Issues and Options’ document does not include Tudeley in the Settlement Hierarchy table and “Traditionally it has been the case that the scale and distribution of housing sites directly follows from the settlement hierarchy. As commented in the study, however, there are many other factors to be taken into account when allocating land in the rural areas and settlements of the borough, such as transport, environmental considerations, landscape and flooding issues.”

It seems to be clear that Tudeley Garden Village was not conceived at this stage.

Evidence Studies for Local Plan Issues and Options

(documents below should have addressed Tudeley if CA1 was to be included in the Reg 18 Plan)

Landscape Sensitivity Assessment of Countryside around TW (LUC) - published February 2017 This assessment is intended to inform the Local Plan and therefore assist TWBC to identify potential development areas or sites for allocation. The next step would be a Landscape and Visual Impact Assessment of any site identified for further consideration. The selected study area by TWBC/LUC “is likely to be considered as part of the Local Plan process”. Tudeley (CA1) is not even mentioned in this report and therefore not assessed; it can be assumed that Tudeley was not considered an appropriate site for development prior to Hadlow Estate offering land. The nearest sub-area considered in the assessment is PW10 which is identified as having “high” sensitivity to medium-large scale development.
Settlement Role and Function Study - April 2017. Tudeley is not included.

Evidence Studies for Local Plan after Issues and Options Consultation

(documents below should have addressed Tudeley if CA1 was to be included in the Reg 18 Draft LP)

TW Green Belt Study - Stage 2 (LUC) - July 2017

There is no recommendation that the Metropolitan Green Belt (“MGB”) boundary is altered or green belt parcels are released in Tudeley. CA1 falls within Broad Area BA3 and BA4 - development would cause “very high harm"
Interim SHELAA (2017)

The main aim of the interim SHELAA is to provide an initial assessment of all the sites submitted through the TWBC's Call for Sites 2016… “although the Call for Sites remains open, it will no longer be possible to include any new sites within the site assessment process that is informing the `Local Plan (Reg 18 Consultation), as there is insufficient time to adequately assess such sites.” Site CA1 was not submitted in the Call for Sites 2016 and therefore not assessed.

SHELAA (July 2019)

Due to the delayed publication of the Plan, there was time to include and assess all these new sites.

However, an assessment of the CA1 site was included in these reports:

TWBC Landscape Character Assessment (LUC) - commissioned in August 2016, referenced for Issues and Options document, adopted December 2017

Site CA1 lies within Character Area 13 and character sensitivities, valued features and qualities, detractors and opportunities and Landscape Strategy are addressed. This document details the landscape and settlement characteristics at Capel and Tudeley. It notes the strong association between Character Area 13 and the AONB and "the area enhances the character of the AONB landscape.”
Historic Landscape Characterisation of the Parish of Capel (Revision of HLC 2000) - dated October 2016, published May 2017 (but still stamped Draft in 2019). Discusses the sharp contrast of early modern/C20 land use in the middle and north of the parish with remnants of the older medieval farmed landscape to the south. The changes in the C19 and C20 are shown most clearly along the edge of the Medway valley, but the underlying structure of remaining field boundaries, old routeways (lanes and paths) and the dispersed nature of the historic settlement is still present and can be identified here.

It seems clear that the development at Tudeley was submitted at a very late stage in the process – probably AFTER the second call for sites - and hence it both post-dated and is excluded from much of the evidence base compiled in support of the Plan. Given the prominent contribution of Tudeley / East Capel to the Plan’s housing numbers this ‘knowledge gap’ constitutes a major risk to the Plan.

It has also led to numerous statements during the consultation process that are simply inaccurate. For example, on pages 8 and 82 of the SHELAA document for Capel the agricultural land classification is shown as grade 3. And in consultation meetings members of the TWBC planning team referred to it as “low quality” land. The reality is that there are both grade 2 and grade 3 productive agricultural lands on this area – one of the few areas of grade 2 in the entire borough! This may be a simple error, but it is symptomatic of the lack of detailed assessment of the sites in question and extremely worrying.

There is therefore considerable concern that in relation to CA1-3 TWBC have made a decision based on a lack of knowledge about the area concerned and seemingly utilising double-standards in evaluation criteria versus other sites.

On a side note: It is hard not to be suspicious that the inclusion of CA1-3 was primarily driven by the sudden appearance and convenience of having a willing landowner to provide a large bulk of land as opposed to being selected based on objective and consistent criteria.

B.2. Climate Emergency / Green Belt

While the ‘tectonic plates’ of global climate change move slowly, scientific studies have evidenced the reality of global warming since the 1970s. It is now a generally accepted fact that fighting climate change will be one of humanity’s defining challenges in the 21st century – including in the borough of Tunbridge Wells.

In this context – and while this may fall outside the narrow confines of planning criteria – the Plan’s proposal to sacrifice 600 acres of Green Belt land and >5% of its total Green Belt ‘land bank’ seems severely short-sighted and frankly irresponsible.

Implementing this will cause irreversible damage to the natural environment, decrease biodiversity, contribute to pollution and climate change, and deprive future generations of much needed green space. It inconceivable that such proposals will be deemed appropriate in years to come.

It is also in complete contradiction to TWBC’s recent announcement of a Climate Emergency - a conflict of policies which is not addressed in the Plan.

It is becoming well established that any open area of land, even simple grassed areas, are essential in carbon capture, so to lose such large swathes of Green Belt is counter to the increasing move for reforestation.

The crops currently grown in CA1 will need to be grown elsewhere, ultimately leading to new farmland being created at the expense of woodlands and forests - here or elsewhere in the world.

In addition to needing more – not less – agricultural land in the future, because of the increasing population, it seems likely that alternatives to fossil fuels will be plant-based, putting even more pressure on agriculture.

To build large expanses of houses in Capel, or Paddock Wood, or anywhere else on open countryside – and in fact any undeveloped land in general – is completely opposite to the progress that society is making in recognising the value of the environment.

Whilst we appreciate the need to fulfil housing requirements and that the National Planning Policy Framework (“NPPF”) makes allowance for the release of Green Belt land under “exceptional circumstances”, we propose that

- building on Green Belt land should be an absolute last resort, and not the core contribution and lynchpin of TWBC’s Plan

- there are viable alternatives that have not been sufficiently explored / rejected and that would fully satisfy the borough’s housing requirements

- the Plan fails to substantiate a case of “exceptional circumstances” to release GB land

- the proposed development at Tudeley Village in particular is completely inappropriate: vastly excessive in land use versus the housing numbers proposed and carving a large ‘black hole’ in the Green Belt – with proposals to swallow surrounding AONB/GB land in future planning periods

In summary, the existing Plan – whilst based on much detailed work – feels like a tactical process- driven tick-box exercise. It lacks both the courage and initiative to re-imagine how to make efficient and best use of the land in the context of climate change - instead preferring to take the ‘easy option’ of building on the Green Belt.

We strongly urge TWBC to re-think their planning approach – prioritising the retention of Green Belt / green-field land and encouraging innovative solutions to redevelop and encourage better use of developed land at higher housing density.

B.3. Disproportionate Impact on Capel Parish

When examining the Plan and its supporting documentation it is obvious that Capel Parish – and the small settlement of Tudeley in particular – is expected to take on a significant proportion of Tunbridge Wells Borough’s total perceived housing need. The intended allocation for Capel Parish is vastly disproportionate to its share of the borough’s total territory, population, housing stock and / or need. This imbalance is neither required nor equitable.

Figure 2. – Comparison of Population vs. Approved Housing by Parish

#	Parish	Population (2011) Inhabitants % of TOTAL		Approved Housing (Plan) Dwellings % of TOTAL
1	Benenden	2,400	2.1%	160	1.0%
2	Bidborough	1,163	1.0%	-	0.0%
3	Brenchley and Matfield	2,863	2.5%	121	0.8%
4	Capel	2,467	2.1%	6,695	42.9%
5	Cranbrook and Sissinghurst	6,700	5.8%	1,214	7.8%
6	Frittenden	888	0.8%	28	0.2%
7	Goudhurst	3,327	2.9%	48	0.3%
8	Hawkhurst	4,991	4.3%	706	4.5%
9	Horsmonden	2,435	2.1%	258	1.7%
10	Lamberhurst	1,706	1.5%	56	0.4%
11	Paddock Wood	8,253	7.1%	4,175	26.7%
12	Pembury	6,128	5.3%	299	1.9%
13	Royal Tunbridge Wells	48,324	41.8%	1,615	10.3%
14	Rusthall	4,976	4.3%	15	0.1%
15	Sandhurst	1,478	1.3%	24	0.2%
16	Southborough	12,459	10.8%	190	1.2%
17	Speldhurst	4,978	4.3%	18	0.1%
	TOTAL	115,536	100%	15,622	100%

Note: For simplicity, CA3 housing has been fully allocated to Capel (as no exact split was available). This overstates Capel’s and understates Paddock Wood’s housing allocation. The total for both parishes is correct.

Whilst only accounting for 2% of the borough’s population, Capel Parish is expected to close to 30% of the borough’s housing needs. This reflects the Plan’s lopsided nature that proposes to squeeze ca. 70% of total housing into just 2 out of 17 parishes at the North West boundary of the borough (Capel and Paddock Wood). This in no way complies with the policy to reflect local housing needs. It also imposes a vastly disproportionate burden on these two parishes and will irreversibly change the semi-rural nature of Capel to the detriment of its current community.

We strongly recommend a more equitable distribution of development across the borough. This should include a better-balanced housing allocation across parishes, a focus on extending existing settlements where appropriate, a stronger emphasis and leverage of brownfield sites and the prioritisation of building outside of Green Belt / AONB land.

B.4. Sustainability Assessment of CA1 – Tudeley Village

Site Characteristics

Turning to CA1 – the site earmarked for the development of Tudeley Village – itself, it is hard to imagine a site less suited to larger scale development.

Key considerations that make this site unsuitable for situating a Garden Village include:

Land Status: The land is part of the Green Belt and borders on AONB
Landscape / Use: The site predominantly consists of high-quality arable land (Grade 2 and 3) that is in agricultural production. It also includes hedging and woodland and supports several public foot paths regularly used by the both the local community and people from further afield for recreational purposes.
Infrastructure: There is no existing electricity or sewage infrastructure to support large scale development. This would have to be built from scratch at a very high cost
Services: Development of several thousand houses will lead to substantial new demand for health and educational services for which there are no existing facilities within Capel parish. Demand would likely fall on the adjacent Tonbridge and Malling (T&M) borough. Their facilities already experience very high demand and are unlikely to cope with large increases. Investment in new schools or GP practices are likely to be required.
Transportation (1 – on CA1): Apart from 1-2 narrow winding tracks, there is currently no road infrastructure on the CA1 site. Bus services are very limited / non existing. There are no cycle paths or walking paths connecting to Tonbridge. All would have to be built from scratch. Tudeley Road / B2017 which is the main East-West connection (to Tonbridge or Five Oak Green / Paddock Wood) is already heavily used with long tailbacks at the entrance to Tonbridge (especially at both roundabouts next to the Schools at Somerhill) during rush hour / school pick up times.
Transportation (2 – congestion): Given the type of development envisaged at Tudeley Village, it is highly likely that this will predominantly cater for regular commuters to London who will want to use Tonbridge Station. There are currently no suitable bus services to / from Tonbridge station, and cycle and walking options are unrealistic. It seems clear that there will be a heavy reliance on cars leading to a large-scale increase in road traffic around the site. While expanding the B2017 (or building a new road) could conceivably allow faster traffic flow to / from Tonbridge – this is likely to come to a shuddering halt at the entrance to and cause gridlock in Tonbridge where there are no opportunities for widening the road network.

In addition, the plan to build a new secondary school at CA3 is likely to further add to congestion and air pollution right at the entrance to Tonbridge which already is a traffic pinch point. TWBC’s assertion that this school will only cater for local pupils and be accessed through walking or cycling flies in the face of the reality experienced by the existing schools in Tonbridge – which already has one of the highest densities of secondary schools in the UK.
Transportation (3 – safety): We would similarly expect a heavy increase in traffic down Alders Lane to the A228, Hartlake Road as well as the ‘cut throughs’ to the A21 (e.g. Half Moon Lane). These are narrow winding country lanes with limited visibility and where cars can often not easily pass each other. Increasing traffic flow is guaranteed to lead to a much- heightened risk of accidents.
Heritage: The site includes the All Saints Church – the only Church globally with Marc Chagall designed windows – which attracts regular international visitors and would not benefit from being surrounded by large scale development. It also includes the landowner’s century old family graveyard. Neither of which is mentioned in the SHELAA assessment
Other constraints: The site is dissected by an existing railway line. This raises obvious concerns about how to adequately and safely connect North and South halves of the site. The only current connections are a small underpass in the middle of the site as well as bridge over Hartlake Road on the site boundary. Both are single lane and not suitable for the anticipated traffic increase.

The table below illustrates that from the centre of the site there are currently no direct routes to nearby key destinations. New roads through the site and to the nearest roads of suitable standard would only, as pointed out above, enable the anticipated increased traffic congestion to reach bottlenecks (largely with cross-border concerns) more easily. In addition, it is clear that full research has not been carried out to establish further critical information.

Distance from centre (miles) to:	as crow flies	by existing roads
road infrastructure of suitable capacity	1.6	2.3
railway station – Tunbridge Wells	4.8	7.6
railway station – Tonbridge (cross border)	2.6	3.7
railway station – Paddock Wood	2.6	4.3
nearest supermarket – Tunbridge Wells Asda	2.6	5.8
nearest supermarket – Tonbridge Sainsburys	2.4	3.4
nearest supermarket – Paddock Wood	2.7	4.3

Its own large supermarket similar to Asda at Kings Hill would create cross border issues Mains water of sufficient capacity not known

Mains sewers of sufficient capacity not known

Land use productive agriculture

Land status green belt

Land contamination not known, Landscape Sensitivity Study not made

Ecological interest not known, Landscape Sensitivity Study not made

Critique of the Sustainability Assessment for STR / CA1

We have already noted that we are in broad agreement with sustainability assessments (“SA”) for most sites contained in the SHELAA documentation – unfortunately these seem to be wildly inconsistent with the assessment for CA1-3.

The scoring for CA1 in particular beggars belief. In our mind, scoring should be ‘negative’ or ‘very negative’ for all of the following sustainability objectives: Air, Biodiversity, Climate Change, Health, Heritage, Land use, Landscape, Noise, Travel, Waste and Water.

Air: How can this be given a “mixed score”? The SA correctly notes that “traffic will increase substantially” with a “high risk to deterioration of local air quality”. The intent to discourage private car usage through shared transport is laudable but is not backed up with any actionable initiatives and is both unenforceable and Increased traffic WILL lead to poorer air quality – the only question is by how much? Score should be very negative
Biodiversity: How can you say that “constraints are limited”. And it is unclear why the reference to Ashdown Forest should be relevant for this Building a large-scale new development on 100s of acres of Green Belt land can only be detrimental to biodiversity. References elsewhere to achieving a “biodiversity net gain” feel like a smokescreen that is not backed up by anything tangible. And the experience of the Tesco Site where woodland was removed for a GBP 25,000 contribution in order to score a ‘biodiversity net gain’ is frankly perverse. This is of course not directly related to CA1 but it does not give any confidence that environmental concerns will be dealt with the seriousness they deserve Score should be very negative
Business: We agree with the existing positive Though it should be noted that the low density envisaged for this site may actually make it more difficult to justify local retail outlets and/or local services (e.g. buses)
Climate Change: Similar to Air and Loss of greenfield land and the associated carbon capture will negatively impact climate change. As will the additional pollution through incremental development and traffic Score should be very negative
Deprivation: We agree with the existing positive And we note the comment that “maximum scores cannot be applied as the proposals are unlikely to address existing problems of fuel poverty”
Employment + Equality: We agree with the existing
Health: We question the positive score The provision of sports facilities is a positive. But to include a consideration that “It was also felt likely that the proposals would include provision for elderly care services.” seems very strange. This is not a fact or even a promise but an unfounded assumption that is actually unlikely to happen since the Garden Village will predominantly attract working families and not elderly people. Also, concreting over the local Green Belt will destroy the public foot paths currently used by locals for recreational purposes Score should be mixed
Heritage: Agree with the existing negative score though you could argue that this actually very TWBC do not seem to have considered All Saints Church at all
Housing: The maximum positive score for housing is of course the obvious consequence of concentrating the lion’s share of TWBC housing requirements in Capel It is hard not to believe that this is the prime criteria and that assessing / scoring for all other criteria is just ‘window dressing’
Land Use: Why is this score not very negative? Score should be very negative
Landscape: We do not understand why this is not very negative. Apart from the destruction of the Green Belt, encroaching on neighbouring AONB, the developments will also cause ‘landscape scarring’ visible from the North Downs. The existing proposals to extend development further into GB and AONB land in subsequent planning periods are even more worrying Score should be very negative
Noise: We agree with the existing negative score
Services & Facilities: How can you provide a positive score based on the “likely well thought-out provision in the new settlement as a result of the master planning process”? This is wishful thinking and not based on any evidence. A more consistent approach would be a mixed or no score until there is actually a plan to assess. Score should be mixed
Travel: The positive score feels like a joke. New bus routes would be a good idea but these have not been defined (nor any new road links to Tonbridge to start with). The feasibility of any new routes will be undermined by the excessively low density of development at Tudeley Village. And, as has already been noted, the predominant transportation vehicle will be the car anyway. The “relatively easy access to train station” comment can only have been written by someone with zero knowledge of the locality. There are no alternatives to car travel to Tonbridge station. In mornings / afternoons, Tonbridge is already in gridlock with no options to increase road width and once there Tonbridge Station and the trains are already at full capacity Score should be negative / very negative
Waste reduction: While we appreciate this may be out of TWBC’s immediate control, not applying any score seems wrong. Of course, building a large-scale development here will lead to more waste Score should be negative / very negative
Water: The mixed / positive water score is unclear and feels strange. This again seems to be based on anticipated improvements due to “substantial demand for water and wastewater treatment”. In reality, there will be greater water usage and greater waste water generation that at best will be mitigated so as to have no incremental negative effect. But even this cannot really be credited since there are no proposals to review Score should be negative

In summary, we believe the scoring methodology for CA1 to be flawed and inconsistent with the overall rationale / criteria / logic employed in other SHELAA sustainability assessments. The actual scores for CA1 should be predominantly negative or very negative as the site is entirely unsuitable for the development intended.

[TWBC: the above comment has also been entered against the Sustainability Appraisal consultation - see Comment Number SA_135].

C. Appropriateness of the Housing Target

It seems that TWBC have used predictions based on 2014 data, rather than more recent projections from mid 2016 released in May 2019. These more recent figures produce lower anticipated housing needs than those used by TWBC to forecast the Plan’s housing requirements. It is likely that the difference between these values represent a figure significant enough to make the proposed development at CA1 unnecessary. More detailed information is available from reports submitted by other teams of the Save Capel Campaign.

We strongly recommend re-evaluating TWBC’s housing target based on latest available data in order to avoid excessive development to the detriment of the environment and the communities affected.

D. Alternative Solutions to achieve the Housing Target

D.1. Rejected Sites Suggested for Review

How many sites submitted for development to TWBC SHELAA (Strategic Housing and Economic Land Availability Assessment) were rejected but, in view of the decision made to develop land in Capel, should be reconsidered?

Based on the SHELAA documentation, there was a total of 437 unique sites submitted for inclusion in the SHELAA process. Of these, 323 unique sites were rejected by TWBC.

In the light of TWBC’s proposal to develop Tudeley Village, we reviewed a total of 90 ‘Rejected Sites’ across a representative sample of 3 parishes (Capel, Pembury and Tunbridge Wells). The purpose of the review was to contrast the rationale for rejecting proposed sites versus the approval for CA1 / Tudeley Village in terms of consistency.

While we found ourselves in agreement with TWBC’s assessments in a majority of cases, we also observed a striking inconsistency between the approval of Tudeley Village versus the rejection of a large number of sites.

As a result, we strongly recommend for TWBC to review 43 ‘rejected’ sites and to reconsider these for inclusion in the Plan INSTEAD of Tudeley Village. Note that this includes sites located in the Green Belt / AONB that in an ideal world we would prefer not to develop at all. But given the need for affordable housing, the 43 sites suggested below are much preferable, better integrated into existing settlements and significantly less damaging to the environment than building at Tudeley Village.

In total, these 43 sites provide a developable area of 87 ha with a total incremental housing potential of ca. 2,270 units in three parishes alone. This is based on TWBC’s proposed housing numbers and density estimates (which we believe are too low) for each site.

The parishes analysed account for ca. 50% of the total borough population. If extrapolating to the total borough, we would expect to find over 4,500 potential housing units that should be reviewed and reconsidered – and developed in preference to building Tudeley Village.

Disregarding the development proposal for CA1, the decision of rejecting these sites seemed appropriate. But as a result of then comparing them with building on large areas of Green Belt productive farmland we ask that the sites listed below should be reconsidered. Together they make a significant contribution towards the numbers of homes for TWBC’s plans which should be considered as an alternative to building on open countryside.

We would ask TWBC to review its analysis and re-consider these 43 “rejected” sites for inclusion in the plan.

Figure 3.: Rejected Sites proposed for Reconsideration – Overview by Parish

#	Parish	Save Capel Request to Review
#	Parish	Sites (#)	Developable Area (ha)	Housing (dwellings)
1	Benenden	0	0	-
2	Bidborough	0	0	-
3	Brenchley and Matfield	0	0	-
4	Capel	13	22	521
5	Cranbrook and Sissinghurst	0	0	-
6	Frittenden	0	0	-
7	Goudhurst	0	0	-
8	Hawkhurst	0	0	-
9	Horsmonden	0	0	-
10	Lamberhurst	0	0	-
11	Paddock Wood	0	0	-
12	Pembury	11	26	733
13	Royal Tunbridge Wells	19	38	1,013
14	Rusthall	0	0	-
15	Sandhurst	0	0	-
16	Southborough	0	0	-
17	Speldhurst	0	0	-
18	Outside borough boundary	0	0	-
	TOTAL	43	87	2,267

Figure 4.: Rejected Sites proposed for Reconsideration – By Site

Site ref:	Site Address:	Parish / Location:	Developable Area (Rejected by TWBC)	Housing Yield if Residential (TWBC original figures)
11	Land at and to the rear of 50 Whetsted Road, Five Oak Green, TN12 6RT	Capel	1.62	49
48	Bramley House, Five Oak Green Road, Five Oak Green, Capel, TN12 6TJ	Capel	0.7	21
141	Site south of Badsell Road, Paddock Wood, TN12 6QR	Capel	0.33	Less than 10
143	Land at Tolhurst Road, Five Oak Green	Capel	0.7	21
156	Bracken Dale, Maidstone Road, Colts Hill, Capel, TN2 4AL	Capel	0.25	Less than 10
216	Land at Moat Farm, Whetstead Road, Five Oak Green	Capel	1.06	32
307	Land to the north of Badsell Road, Five Oak Green, Kent	Capel	3.79	114
329	School field, Finches Farm, Five Oak Green, Tonbridge, Kent	Capel	7.31	219
330	Finches Farm, Five Oak Green, Tonbridge, Kent	Capel	0.34	10 or less
331	Forstal Field, Finches Farm, Five Oak Green, Tonbridge, Kent	Capel	2.95	88
418	Capel Grange Farm, Badsell Road, Five Oak Green, Kent	Capel	1.45	44
453	Land off Hartlake Road, Tudeley, Tonbridge, Kent	Capel	0.69	21
Late site 10	Orchard Brook, Five Oak Green Road, Five Oak Green	Capel	0.67	20
28	Land on the eastern side of Woodside Road, Pembury, TN2 4BG	Pembury	0.89	27
64	Land at Woodside House, Woodside Road, Pembury TN2 4BG	Pembury	1.55	47
190	Land south east of Sandhurst Avenue, Pembury	Pembury	3.52	106
191	Land north of Henwoods Mount, Pembury	Pembury	3.19	96
208	Romford House Farm, Kings Toll Road, Pembury, TN2 4BE	Pembury	5.68	170
290	Abbots, Woodside Close, Pembury, Kent	Pembury	0.91	27
332	Priory Farm, Romford Road, Pembury, Kent	Pembury	5.77	173
354	Stone Court Farm, Stone Court Lane, Pembury, Kent	Pembury	1.95	59
367	Land to the southwest of Woodside House, Woodside Road, Pembury, Kent	Pembury	0.92	28
379	Land at Henwood Green Road, Pembury, Kent	Pembury	1.98	59
395 (Local Plan Allocation AL/PE7)	Woodsgate Corner, Pembury, Tunbridge Wells, Kent	Pembury		Not to be allocated for residential
91	RTA Joinery, Rear of 5 Birling Road, Tunbridge Wells, TN2 5LX	Royal Tunbridge Wells	0.23	Less than 10
99	Land at Pembury Road, Tunbridge Wells	Royal Tunbridge Wells	6.57	197
104	3 Lonsdale Gardens, Tunbridge Wells, TN1 1NX	Royal Tunbridge Wells	0.09	Less than 10 units
105	5 Lonsdale Gardens, Tunbridge Wells, TN1 1NX	Royal Tunbridge Wells	0.1	Less than 10 units
114	Land at Sandown Park, west of A21 Royal Tunbridge Wells TN2 4RT	Royal Tunbridge Wells	9.74	292
134 (overlap with site 175)	Land around Sandstone House, Longdrift, Court Lodge and Shallowdene, Broadwater Down, Royal Tunbridge Wells, TN2 5PE	Royal Tunbridge Wells	1.35	41
145; SALP AL/RTW13	WA Turner Factory Site, Broadwater Lane, Tunbridge Wells, TN2 5RD	Royal Tunbridge Wells	1.36	41
165	Pantiles Car Park, Major Yorks Road, Tunbridge Wells, TN2 5TP	Royal Tunbridge Wells	0.77	23
175 (overlaps with site 134)	Court Lodge & Land to the rear of Sandstone House, 44 Broadwater Down, Tunbridge Wells, TN2 5PE	Royal Tunbridge Wells	0.46	Less than 10 units
206	54a Culverden Down, Tunbridge Wells, TN4 9SG	Royal Tunbridge Wells	0.66	Less than 10 units
226	St Mark’s Recreation Ground Frant Road Tunbridge Wells, TN2 5LS	Royal Tunbridge Wells	1.07	32
248 (SALP AL/RTW8)	Land at Rifle Range, Warwick Park, Royal Tunbridge Wells, TN2 5FD	Royal Tunbridge Wells	1	Less than 10 units
258	TN2 and adjacent land, Greggs wood Road, Sherwood, Tunbridge Wells.	Royal Tunbridge Wells	0.06	Less than 10 units
280	Land at The Midway, Nevill Court, Tunbridge Wells, Kent	Royal Tunbridge Wells	4.02	121
328	Land at Eridge Road & Eastlands Close, Royal Tunbridge Wells, Kent	Royal Tunbridge Wells	0.73	22
359 (this site also forms part of site 400)	Land to the east of Halliwell Nursing Home, Kingswood Road, Tunbridge Wells, Kent	Royal Tunbridge Wells	0.4	12
400 and including site 359	Land to the east of Halliwell Nursing Home, Kingswood Road, Tunbridge Wells, Kent	Royal Tunbridge Wells	2.97	89
411	Land at Sandown Park between Pembury Grange and A21, Royal Tunbridge Wells, Kent	Royal Tunbridge Wells	5.51	165

Note: Please find detailed rationale for re-consideration for each site in Appendix A.

D.2. Brownfield Potential

How many sites in the borough are available for development (brownfield and other categories) which are not registered on TWBC’s system and what is their housing potential?

As of November 2019, TWBC’s existing Brownfield Register contains 34 sites with a total of 884 proposed dwellings. Of these, 22 sites have been permissioned and are included in the Plan with a further 2 sites under review. This would yield a total of only 500 housing units from brownfield sites. In other words, currently ‘brownfield’ fails to make a meaningful contribution to the Plan.

While the brownfield potential in the borough is constrained, we believe that the existing Register is far from complete and there is a MUCH larger brownfield potential that needs to be identified and evaluated as a priority BEFORE resorting to building on Green Belt / AONB land. We do not believe this effort has been undertaken to date.

As a result, we have commenced a survey to identify untapped brownfield potential. This is ongoing and will go on into 2020. This report includes interim results of potential sites and the associated housing units for 4 parishes (Tunbridge Wells, Southborough, Speldhurst and Capel). The survey will be extended to other parishes and we intend to provide updated results to the borough’s planning team in due course.

We urge TWBC to collaborate in this initiative to proactively identify brownfield potential / already developed sites with a poor use of space and to proactively engage landowners to contribute to the Plan.

Overleaf please find interim summary results for new, incremental Brownfield sites (for further site details including exact location and commentary, please see Appendix B):

Figure 5.: New Brownfield Site List (Interim)

Ref	Location	Parish	Size (hectares)	Potential Housing Yield at 30 dph
1	West of A21 half mile south of Kippings Cross roundabout	Brenchley & Matfield	13.0	390
2	North east of junction Sychem Lane and Alders Road	Capel	1.9	56
3	West of Whetsed Road, north of last dwelling, 400m from	Capel	0.6	18
4	North of Badsell Road, east of Orchard Business Centre	Capel	0.6	18
5	Capel Village Hall, Falmouth Place, Five Oak Green	Capel	0.2	5
6	Adjacent to Orchard Business Centre, Badsell Road, Five	Capel	0.1	3
7	Industrial building, Five Oak Green Road, opposite	Capel	0.1	2
8	West of A228 Maidstone Road opposite Capel Cottage	Capel	0.0	1
9	Kings Head Pub, Five Oak Green	Five Oak Green	0.1	2
10	Blantyre House	Goudhurst	5.7	172
11	Hawkwell Farmhouse, Maidstone Road	Pembury	0.3	8
12	Car Park of Tunbridge Wells Leisure Centre, Off St Johns	Southborough	0.7	21
13	Land next to 136 - 138 Speldhurst Rd	Southborough	0.4	13
14	Land + Garages between Sir David Park and Keel Gardens	Southborough	0.1	4
15	Langton Geen Village Hall Car Park, Speldhurst Road	Speldhurst	0.4	11
16	Colebrook Park, Land at A21 and Longfield Rd.	Tunbridge Wells	19.7	590
17	Land / Car park at Knights Park Leisure Park (140)	Tunbridge Wells	2.3	69
18	Off Birling Road - in Industrial Area	Tunbridge Wells	2.2	65
19	Sainsburys / Homebase - Car Park	Tunbridge Wells	1.5	45
20	South side of A264, Langton Road opposite All Saints	Tunbridge Wells	1.3	39
21	B&Q off Longfield Rd. - Car Park	Tunbridge Wells	1.1	34
22	Garage area at end of Birling Drive	Tunbridge Wells	0.8	24
23	Car Park at Culverden Square, off St Johns Road	Tunbridge Wells	0.7	20
24	Marks & Spencer / Halfords / Homesense, Off Dowding	Tunbridge Wells	0.6	19
25	AXA PPP office car park, corner of Camden Rd & Forest	Tunbridge Wells	0.6	17
26	Asda, Longfield Road - Car Park	Tunbridge Wells	0.5	15
27	Grass area between Elphicks place and Forest Road	Tunbridge Wells	0.5	14
28	John Lewis off Kingslanding Way - Car Park	Tunbridge Wells	0.4	12
29	Behind ABP, Broadwater Lane - Car Park	Tunbridge Wells	0.4	11
30	South side of Dowding Way and railway, accessed via lane	Tunbridge Wells	0.3	10
31	Tunbridge Wells Shopping Park off Longfield Rd (TK Maxx,	Tunbridge Wells	0.3	9
32	Baldwins Lane, north off North Farm Road, opp High	Tunbridge Wells	0.3	9
33	East of St Johns Rd TW near to sports centre on opposite	Tunbridge Wells	0.3	8
34	Wickes, Off Longfield Road - Car Park	Tunbridge Wells	0.2	7
35	Behind WA Turners in Broadwater Lane - Car Park	Tunbridge Wells	0.2	6
36	North east of junction North Farm Road, Chapman Way,	Tunbridge Wells	0.2	6
37	John St Car Park, just off west of St Johns Rd, opp side to	Tunbridge Wells	0.2	5
38	Car park in Camden Road, between Beulah Road and	Tunbridge Wells	0.2	5
39	Tunbridge Wells Royals Indoor Bowls Club - Car Park,	Tunbridge Wells	0.1	4
40	Tunnel Road	Tunbridge Wells	0.1	4
41	Car park in The Beeches (road) off Sandhurst Road, behind	Tunbridge Wells	0.1	4
42	Calverley Court Car Park, off Calverley Park Gardens	Tunbridge Wells	0.1	3
43	Linden Park Road, Tunbridge Wells - Car Park	Tunbridge Wells	0.1	3
44	Hobbycraft, Longfield Road - Car Park	Tunbridge Wells	0.1	3
45	The Old Coach Park, Linden Park Road - Car Park	Tunbridge Wells	0.1	3
46	Car Park off North Farm Road / Holmewood Rd	Tunbridge Wells	0.1	3
47	Beach St Car Park – off Beech St / Camden Road	Tunbridge Wells	0.1	3
48	Salvation Army Car Park, on junction between Bayall	Tunbridge Wells	0.1	2
49	Garden Street Car Park, off Camden Road	Tunbridge Wells	0.1	2

To date, we have identified 49 potential brownfield sites with an incremental housing potential of ca. 1,800 dwellings.

This brownfield potential is based on only 4 out of 17 parishes, accounting for ca. 60% of the borough’s population. Extrapolating for the total borough, this would lead us to expect a total brownfield potential of ca. 3,000 incremental housing units. We will seek to confirm the total brownfield potential - bottom up and supported by specific sites - in due course.

It should be noted that the housing figures stated above are based on a conservative density assumption of only 30 dwellings per hectare. Some of the sites included have the potential to cater for a much higher density – and thus more housing units - which we will cover in the next Section.

D.3. Increasing Housing Density

What is the additional housing potential that sites might offer if land is used more effectively?

The general standard for housing density that TWBC seem to have utilised in the Plan is 30 dwellings per hectare (dph). While this is in line with national planning guidelines, in the context of the proposed sacrifice of Green Belt land this strikes us as decidedly unambitious and unjustifiably low.

Given the announcement pf a national climate emergency, it is imperative to make best use of finite land resources – this means to exploit (to be) developed land to its full potential and to conserve valuable agricultural and Green Belt land.

Developing at higher densities would sharply increase the housing yield per hectare thereby reducing the need to build on greenfield land.

This especially applies to Tudeley Village where the proposed densities of 15-30 dph are very low, effectively gobbling up a much larger amount of Green Belt land than needed. On a side note: This also indicates that the intention for this site is not to build affordable housing (the real local need) but to provide executive homes for London commuters.

The following sections and figures show how increased housing densities can more easily satisfy the stated housing requirements. While this simulation is by necessity based on top-down estimates - and may not be desirable / feasible in many cases - it clearly illustrates the vast opportunity to increase housing yield through increased density, thereby foregoing the need to sacrifice scarce Green Belt land. See Appendix E for a summary of methodology used.

(1) SHELAA sites approved by TWBC

Increasing density for all approved sites to a minimum of 40 or 50 dwellings per hectare, would yield additional housing of 5,000 to 10,000 units respectively. This alone would negate the need to develop at Tudeley Village / East Capel.

Figure 6: Housing Potential / Density Elasticity for Approved Sites

#	Parish	Dwellings - Density Elasticity
		Approved Dwellings at Original Density	Approved Dwellings if increasing density to c. 40 dph	Approved Dwellings if increasing density to c. 50 dph
1	Benenden	160	213	267
2	Bidborough	-	-	-
3	Brenchley and Matfield	121	161	202
4	Capel	6,695	8,927	11,158
5	Cranbrook and Sissinghurst	1,214	1,534	1,855
6	Frittenden	28	37	47
7	Goudhurst	48	64	80
8	Hawkhurst	706	941	1,177
9	Horsmonden	258	344	430
10	Lamberhurst	56	75	93
11	Paddock Wood	4,175	5,567	6,958
12	Pembury	299	392	498
13	Royal Tunbridge Wells	1,615	1,836	2,073
14	Rusthall	15	15	25
15	Sandhurst	24	32	40
16	Southborough	190	253	317
17	Speldhurst	18	24	30
18	Outside borough boundary	-	-	-
	TOTAL	15,622	20,416	25,249

(2) SHELAA sites rejected by TWBC but we feel should be reconsidered.

Increasing density for the 43 rejected sites that should be reconsidered (see Section D1) to a minimum of 40 or 50 dwellings per hectare, would yield additional housing of 1,000 to 1,900 units respectively.

These include windfall sites rejected by TWBC, but we felt should be reviewed because even though they fall below the 0.25h threshold they still represent a contribution to the overall housing numbers and there are developers who specialise in these smaller sites.

Figure 7: Housing Potential / Density Elasticity for Rejected Sites (Selected Parishes)

#	Parish	Dwellings - Density Elasticity
		Rejected Dwellings at Original Density	Rejected Dwellings if increasing density to c. 40 dph	Rejected Dwellings if increasing density to c. 50 dph
1	Benenden
2	Bidborough
3	Brenchley and Matfield
4	Capel	521	859	1,073
5	Cranbrook and Sissinghurst
6	Frittenden
7	Goudhurst
8	Hawkhurst
9	Horsmonden
10	Lamberhurst
11	Paddock Wood
12	Pembury	733	1,056	1,320
13	Royal Tunbridge Wells	1,013	1,422	1,773
14	Rusthall
15	Sandhurst
16	Southborough
17	Speldhurst
18	Outside borough boundary
	TOTAL	2,267	3,336	4,167

(3) Brownfield sites on TWBC’s register

Potential uplift by flexing density for sites on TWBC’s current Brownfield Register is limited – as noted above the Register only includes a limited number of sites and these are typically already on reasonably high density. Increasing density for already permissioned sites would probably only yield an incremental 25-30 units. Even when including sites that are pending or where the decision is unclear, this would only generate an additional 50 units at higher density.

Figure 8: Overview of BF Register 2019 by Status

BF Register 2019 - status	Sites (no)	Size (hectares)	Proposed Dwellings (no.)	Density (dwellings per hectare)
Not permitted	1	0.03	12	400.0
N/A	9	4.67	350	74.9
Decision Pending	2	2.5	42	16.8
Permissioned	22	8.3	480	57.8
Total	34	15.5	884	57.0

Figure 9: Housing Potential / Density Elasticity for BF Register by Status

BF Register 2019	Dwellings at original density	Dwellings if increasing density to 40 dph or below (ca. x 33%)	Dwellings if increasing density to 50 dph or below (ca. x 66%)
Permissioned sites only	480	503	508
Decision Pending	42	50	50
N/A	350	360	365
Total	872	913	924

(4) Brownfield and other sites that we have located;

When reviewing the newly identified 49 brownfield sites (see Section D2) – these currently yield ca. 1,800 units at 30 dwellings per hectare. Increasing density to 40 or 50 dph which is possible for a number of these sites would generate an additional 600 to 1,200 housing units.

And as stated above this analysis only covers a subset of the total borough so we would expect there to be further upside.

Figure 9: Housing Potential / Density Elasticity for newly identified BF sites

Newly Identified BF Sites

Dwellings at 30 dph

Dwellings if

increasing density to 40 dph

Dwellings if

increasing density to 50 dph

New Sites

1,793

2,391

2,988

There is clear opportunity to achieve higher housing yields, to optimise the use of land and to decrease the need to build on Green Belt by a moderate increase in housing density.

D.4. Alternative Housing Solutions

In this Section we would like to expand on the topic of how to achieve TWBC’s housing target through alternative solutions than building on Green Belt land. In the section we will return to the topic of housing density, cover a better use of car parks and then turn to a number of specific locations which we believe hold a large housing potential.

THE CASE FOR DENSITY

TWBC’s ‘Distribution of Development Topic Paper’ was encouraging in its examples of locations where it had increased density from the original number of dwellings proposed in planning applications, and apparently had taken steps to encourage higher density by various means.

However, we have found numerous instances where density of housing throughout the borough could be increased from the 30 dwellings per hectare (dph) to 40 or even 50 dph without compromising the acceptability to the occupants.

The Garden Village concept was an admirable one, at the time of its introduction at the beginning of the 20^th century. One of its main attributes was that of space: wide, tree-lined boulevards, large gardens front and back, for families to grow their own home-grown vegetables.

A century later, we are running out of space, as confirmed by the wish of TWBC to use valuable agricultural land to resolve the problem of housing required in anticipation of an increase in population / households. The issue of needing that land to feed the increasing population does not seem to have been taken into consideration.

Land is now a luxury and needs to be used much more efficiently and carefully.

It is therefore encouraging to see that there are locations both in nearby boroughs and in our own, where these higher densities are successfully being used.

In Tunbridge Wells a new estate is being built with luxury homes, a feeling of spaciousness, and a density of
Another group of buildings in Tunbridge Wells has recently been built at
In Tonbridge, there is an estate part of which attractively fronts onto the river, which takes up 27ha with 97 dwellings which gives a density of 76dph – excluding the flats at the entrance to the estate.
Again, in Tonbridge, again adjacent to the river, are flats with a density of

In Section 3, we have demonstrated that by merely increasing from 30 to 50dph a significant number of dwellings can be built upon the SHELAA sites submitted to TWBC.

The Plan includes a majority of estates being built at low densities: there is plenty of housing stock available of that size but a constant (local) demand seems to be there for affordable housing. By that it is not meant homes that are part of a scheme, but simply homes that can be bought conventionally, with a mortgage as the first step on the ladder.

There are figures which indicate a significant number of young – and no longer so young – people who cannot afford to move out their parents’ homes.

Similarly, the numbers of people getting divorced is significant and many of those need to downsize.

Equally there are plenty of people who have retired, or their families grown up and left the home and the parents wish to downsize.

As a result, a general increase in density of housing would seem to mitigate many of the demands of housing in the borough.

In fact, this is encouraged by the NPPF: in section 11: Making Effective Use of Land, in item 123(a) on page 37 is specifies ‘plans should contain policies to optimise the use of land in their area and meet as much of the identified need for housing as possible. This . . . should include the use of minimum density standards for city and town centres and other locations that are well served by public transport. These standards should seek a significant uplift in the average density of residential development …’ There is every reason to include rural locations too because they often have pockets of high density, for example traditional terraces of farmworkers cottages. There is even more reason not to waste space in a rural location.

CAR PARKS

In addition, it seems to be traditional that car parks generally must be visible to all. The floor space of retail units is greatly increased by the space required for open air car parks.

It is acknowledged that the car rules all and there is a strong feeling that its presence is too much of a significant part of the visual scene, in addition to taking up valuable space.

For future retail developments it would be far more effective to require car parking to be beneath instead of next to retail units. This would improve the shopping experience for shoppers because they would no longer be exposed to all weather conditions simply to go shopping. In eliminating surface car parks, shops could be closer together, enabling an indoor mall concept which seems to work well in town centres. In doing this, more retail units could be built within the area allocated.

Existing retail car parks could have accommodation built above the space, releasing pressure on the housing need. The car parking would be retained, and residents would be in a prime location, reducing the need to actually have a car. While construction is taking place, it would be possible for a temporary structure adding a second floor to be located in the other part of the car park so that parking spaces are not reduced.

With that in mind, it was interesting to note that car parking was likely to be reduced by a possible retail development in Tunbridge Wells:

The SHELAA site number 140, at Knights Park, in its Sustainability Assessment says: “A slight positive score for Air reflects the probability that intensification of leisure use will involve loss of some parking spaces thus forcing users to consider the alternative modes of transport that already exist and would be further improved by this allocation”.

As a side issue, there are few existing alternative modes of transport that are suitable. For residents of Five Oak Green, there are no direct buses that serve Knights Park.

A minority of Five Oak Green inhabitants might be prepared to wait for a bus, travel slowly to a bus stop, get off, wait for the next bus and catch that: or perhaps to cycle, but those figures would be low indeed. The same would no doubt apply for residents of the proposed CA1 development.

Therefore, parking is and will continue to be needed and requires space. This is a good example where the parking can be retained with a building above the car park.

In response to the desperation that forces TWBC to consider building houses upon open countryside, measures need to be put in place to consider surface car parks as residential potential (building above to retain the car parks).

This would be in line with the NPPF Para 11: Making Effective Use of Land (page 35) item 118(d): ‘promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively (for example converting space above shops, and building on or above service yards, car parks, lock-ups and railway infrastructure)’ plus a footnote ‘As part of this approach, plans and decisions should support efforts to identify and bring back into residential use empty homes and other buildings, supported by the use of compulsory purchase powers where appropriate.’

Combining car parks with residential, or where appropriate commercial or leisure, would solve multiple issues, including the policy mentioned in the TWBC Parking Strategy document to improve parking provision.

POTENTIAL IN SPECIFIC LOCATIONS

There are several sites in the borough with exceptional potential for development – both local to Tunbridge Wells and further removed. Below we explore a number of selected sites that we believe could make a significant and yet untapped contribution to achieving the Plans’ housing ambition.

1. Blantyre House

Looking at the specification for Garden Villages, one of the criteria seems to be that it should ideally be separate from neighbouring large towns.

The former Blantyre Prison fits that particular requirement and is of a reasonable size, especially if considered in conjunction with the neighbouring SHELAA site number 325 which is in the Cranbrook and Sissinghurst parish. At the nearest point they are only 300m apart.

As far as we can tell the property is owned by TWBC or the government and seems to be 77ha. Site 325 is about 40ha developable area, so that totals 117ha. At a density of 30 dph that offers 3,510 dwellings.

CA1’s potential yield is 2,500-2,800 so there is room for CA1 plus some of East Capel, at Blantyre / site 325, at just 30dph.

Staplehurst Station is 11 minutes drive away, with its connection to Ashford International and the high-speed rail link to London and also the continent. Cranbrook is 10 minutes drive away.

However, Blantyre has at this stage not been included in TWBC’s allocations despite, according to their report in the Distribution of Development Topic Paper, page 22:

‘Location has the benefit of being outside of some key constraints and is within reach of the mainline rail at Staplehurst’

Because:

‘However, the scale of site was too small and the site was not submitted in the call for sites and thus this option did not become available for ’ (At this stage, the prospective Tudeley site, now known as CA1, had not been submitted to the SHELAA scheme either.)

There is no mention of the neighbouring SHELAA site 325, despite the potential together with Blantyre outlined above.

So even though the site is owned by the government, borough council, other government associated bodies or combinations thereof, i.e. it is public land, it has not been offered up as a solution to the borough council / government’s housing problems.

As pointed out in NPPF page 35 paragraph 119, ‘Local planning authorities, and other plan-making bodies, should take a proactive role in identifying and helping to bring forward land that may be suitable for meeting development needs, including suitable sites on brownfield registers or held in public ownership, using the full range of powers available to them. This should include identifying opportunities to facilitate land assembly, supported where necessary by compulsory purchase powers, where this can help to bring more land forward for meeting development needs and/or secure better development outcomes.’

It would no doubt be possible for the two sites to become a unit without losing too much of the woodland west of Roundgreen Lane. However, if it was deemed unworkable because of the separation between the two sites, that in fact would equally apply to the CA1 Capel site which is divided very effectively by the railway.

2. East Pembury

Referring to the illustration below, site 375 in green has been approved by TWBC.

However, site 190 was not approved even though it was just the other side of the Hastings Road. It seems logical to include 190 in the TWBC Plan because it is a natural infill and accessible directly from the A21.

Sites 191, 208, 290, 28, 64, 332, 367 are individually remote, accessing only onto unsuitably narrow Woodside Road, and Romford Road for 332.

However, if access is possible between sites 190 and 191 it would be feasible to connect these sites to the others above with a spinal road connecting them all (see the blue line in Figure 10 below).

This also applies to the group comprising 379, 367, 64, 332 (and 458 already approved by TWBC). If they are all available, they could access (see green line) via 458 onto Henwood Green Road.

If the eastern bloc was not workable via sites 190, 191, etc. it might be accessible via 458, depending on whether it was felt that Henwood Green Road would have the capacity to cope with additional number of houses. Or the same could work in reverse if access via site 458 on Henwood Green Road was not possible.

Sites at this location would have immediate access to the A21 meaning that most traffic would exit from the development at this point, even traffic heading northwards beyond Pembury, because it would no doubt be faster to route along the A21 and then the A228 Northern Pembury Bypass than cutting through Pembury itself.

The total allocation for these sites according to SHELAA documents totals 674 dwellings.

[TWBC: for Figure 10: Draft Proposal for Eastern Pembury sites working in conjunction see full report].

3. Pembury Road, Sandown Park

Close to the western side of the A21 / A264 junction, on the northern side of Pembury Road are sites 99, 411 and 144. Once again, if these work in conjunction with a road combining all three, or at least two of them, either from Sandown Park or preferably from the A264 so that traffic to/from the development has direct access to the A21, these three sites combined would offer 654 dwellings according to the SHELAA documents.

These sites combined would offer even better access than the eastern Pembury sites to the A21, the A264 and to Tunbridge Wells (via bus, bike and on foot).

4. A21/A264, Tesco Site

On the eastern side of the A21 / A264 junction is the Tesco supermarket site which was initially proposed for one of the termini for a Park and Ride scheme. A feasibility study was instigated by TWBC but discounted on the basis that it would require too great a subsidy to be worthwhile considering. In researching the documentation, it seems unlikely that an express bus service from Pembury to Tunbridge Wells (i.e. non-stop to / from Tunbridge Wells centre from the proposed park and ride site) was considered, serving not only a park and ride at the Tesco site but the approved SHELAA sites along the A21 totalling 260 properties at TWBC predicted numbers in addition to Pembury village itself .

Offering car parking space for the ‘park and ride’ would also provide the opportunity to build above the car park - one or two storeys – which would have been an ideal location for commuters by car, having direct access to the A21 and A264.

In addition, even having dismissed the ‘park and ride’ scheme, the site would still have been ideal for residential purposes for the above reasons.

The site is of 4.78ha. At a housing density of TWBCs standard figure of 30 dph, there is potential for 143 dwellings. At 40dph, 191 and at 50dph, 239. If four storey flats of 50 sqm were constructed with parking for occupants on the ground floor, these could potentially supply 600 apartments in a key location immediately accessible to an excellent road infrastructure. When compared to the proposed CA1 in the middle of green fields with currently no infrastructure for access, this seems an excellent choice of site for residential purposes.

Instead, the site is in an advanced stage of the planning permission process for a car sales showroom (when there are already more than adequate choices available in this market)

5. Liptraps Lane, near to High Brooms Railway Station

Even more local to Tunbridge Wells, site number 238, the Sports Field off Liptraps Lane has a developable area of 3.92ha, out of a gross 4.22ha. The predicted yield is 60 dwellings. At the usual 30 dph density this indicates that half the playing field will be retained. If that is the case, increasing to 50dph would substantially increase the area of land remaining for leisure use.

Alternatively, making the most of the 2 ha representing half the area, 50dph would increase the yield to 100 dwellings.

However, being right next to High Brooms Station, a 5 minute walk away along Clifton Road and up the footpath to the station, this would be an ideal location for commuters, and this could justify the higher yield that a series of apartment buildings would produce.

In the lower field alone, three blocks of 50 sqm apartments over 3 floors plus parking at ground level would yield 126 apartments in 0.5ha, a density of 252 dph.

In this lowest field, the buildings would not be close to the dwellings at the south or east of the field; the north would be unlikely to be visible from the road and the west elevation would face the railway and industrial estate beyond. For this reason, the height could probably extend beyond four storeys.

If a second series of apartments were placed in the centre field that would double the yield to 252 dwellings, from an original anticipated number of 60.

6. Former Gasworks in Sandhurst Road

SHELAA site reference SALP AL/RTW10, the former gasworks site in Sandhurst Road, has been approved for development and it is encouraging to see that at a size of 1.78h the anticipated yield would be 170 dwellings, a density of about 95dph. That compares with the estate in Tonbridge mentioned earlier and would anticipate a similar arrangement with conventional town houses, hopefully with parking of cars beneath the dwellings to maximise leisure space for residents.

There is more potential on this site however.

Like the playing field above, it is convenient to High Brooms Station, a 2 minute walk in fact from its nearest point. Due to the neighbouring houses, the buildings on the outer edge of the development should not be overbearing, but in the central part similar figures could be produced to the playing field with a series of flats, so that would be 126 dwellings in the apartments at 252 dph in the central part plus the outer edges at 95 dph which would produce 121 dwellings: so 373 apartments compared to the original 170 dwellings.

Traffic from these sites would be anticipated to be lower than for locations in the countryside or outskirts of Tunbridge Wells due to the proximity of transport infrastructure such as High Brooms Railway Station and nearby buses. There are cycle lanes, and it would be a half hour walk to the Victoria shopping centre.

Taking into account the employment situation in this ward, these two developments might be considered large enough to justify small shops to serve this community and the neighbouring area and could also incorporate other services such as a surgery, which would provide employment locally. In addition, some of the space available could be devoted to offices instead of residential, which would similarly provide work for local people.

7. SHELAA site numbers 57, 101 and 43 (southern part south of woodland) comprising the Colebrook Estate, located north of Longfield Road, east of Kingstanding

Planning permission has been sought for this group of sites, for various commercial proposals, none of which appear to have included residential factors.

This is a large site and ideal for residential purposes for the following reasons:

Infrastructure is in place;
Together they offer a site with access both to Longfield Road and to the A21 directly onto the slip road which makes an ideal entry/exit for traffic for the site, without affecting Longfield
In this prime position adjacent to A21 commuter traffic for north, east, southward directions would not need to affect Tunbridge Wells;

In addition:

Bus service into Tunbridge Wells for local commuters to Tunbridge Wells to the train stations;
Trains to London and the coast from High Brooms Station, within bus / cycle / walking distance;
Large food supermarket within bus / cycle / walking distance
Wide range of other shops and leisure facilities within bus / cycle / walking distance
Tunbridge Wells centre within bus / cycling distance: even walking is not unrealistic at 50
Site 57 has a developable area of 91ha, site 101 6.98ha and the southern part of 43 7.16ha: 32.05ha. At 30 dph that’s 960, at 40 pdh 1200, at 50 dph 1500 dwellings.
With the sloping site the lower parts adjacent to the industrial estate on Kingstanding Way would suit apartments of perhaps six
The visual concerns of a series of tall structures would be not significantly greater than the very visible roofs of the neighbouring industrial

The site actually offers an exciting opportunity for a different type of accommodation which although not common, can be built using conventional methods – a Hybrid Building.

Basically, a row of ten terraced houses, single or twin storeys, with a patio area. On top, another row, of the same size but set back, their patio being on the roof of the house below. Several layers upwards give a terraced effect. The inner part of the house accesses onto an internal ‘street’, similar to the walkways in a shopping precinct. A similar arrangement backs onto the first, creating a triangular section. Within the heart of the section is space for shops, cafes, surgeries, gyms because rarely do these need external windows. Even office accommodation could be included: many office staff don’t have a view out the window, and even then, it’s not dramatic. With the technology now available, large display screens could give the impression of windows, with any sort of much better view than another building. The structure would be of a standardised columns and beams construction so that internal walls would not be load bearing, so could be moved and removed as required, thus future-proofing the building for changing and developing needs.

Potential: if the hybrid buildings comprised a row of ten 50 sqm apartments on each of two opposing sides, eight storeys high, each block could provide 160 apartments on a footprint of

50x60m. Two blocks fit in a hectare so 320 dph. 32h available: 10,240 units of fifty sq m apartments.

That’s plenty of room for trees and open space, with the shops and facilities within the building, the car park on the ground floor, so the residents need never get wet while living there.

[TWBC: for Figure 11 and image see full report].

The patios of the apartments would be hung with flower tubs so the overall impression of the building would be of merging with the countryside, hence reducing the visual impact of the building.

This is not a new idea.

Below is the Alt-Erlaa estate in Vienna. Built in the 1970s it is held as an example of a community project that is an outstanding success. People are on waiting lists to live there.

This is the description in one website (1): ‘Every apartment . . . opens out on to a generous balcony which terminates in a half-drum planter, wide and deep enough for small trees. A low-tech integrated watering system recycles rain into the planters, which retreat at each level according to the hyperbolic curve of the building form.’

And below is Liuzhou Garden City in Southern China, one of a series of similar projects currently being built around the world.

From a magazine article (2):

‘Instead of completely getting rid of the trees to build houses, the city’s design accommodates the surrounding greenery. Homes and commercial buildings will be covered with trees, with gardens on the balconies of every floor, and rooftops that are home to miniature forests.’

Stafano Boeri, the architect: ‘I have been working on the idea of urban forestation for years,” says Boeri. “In those areas of the planet where it is still necessary to build new cities, we are planning real forest cities for a maximum of 150,000 inhabitants.’

(courtesy Science Focus Magazine) [TWBC: for image see full report].

The overall design addresses the visual aspects of the development, assisting it to merge with the countryside with green spaces and green terraces where a taller building is used, and in the case of substantial sized buildings adapt a more natural contour so that instead of vertical walls there is a flowing increase in height, in anticipation of climate change and high winds, so that these flow over rather than hitting the front of larger developments and also helping the development visually to merge better with the countryside.

These innovative concepts should allay any concerns regarding the site being within the AONB. In addition, the AONB seems to include the neighbouring Kingstanding Way (also the Tesco site at Pembury which has just had its wooded area removed) and is between an industrial estate, a scrap yard, a dual carriageway and roundabout. The field itself is unproductive and unmaintained though a few areas of ancient woodland add aesthetic value to the site. The addition of wooded areas between the buildings would enhance the environment in that respect. The site would not be visible from neighbouring residences and from a distance – if designed to merge with the countryside its view would be relatively insignificant amongst the wider area and should be less noticeable than the conspicuous roofs of the industrial estate which have already compromised the long-distance view.

For these reasons the AONB status at Colebrook should be relaxed, particularly when this might be an excellent alternative to building on green belt, productive arable fields in the middle of the countryside and where the infrastructure required will require significant additional funding on top of the usual commitments by developers to local needs.

In summary – and as shown below in Figure 12 – the housing potential for these (groups of) sites is over 10,000 units.

Figure 12: Housing Yield for Selected High Potential Sites

Sites	Dwellings (#)				Commentary
Blantyre plus site 325	3,510	At	30	dph
East Pembury group of sites:	674	At TWBC’s figures for each site
Pembury Road, Sandown Park	654	At TWBC’s figures for each site
A21/A264 junction, Tesco site	143	At 30dph: 600 apartments in four storey flats
Liptraps Lane	60	At TWBC’s figures: 126 apartments in four storey flats
Former Gasworks, Sandhurst Road	170	At TWBC’s SHELAA figures for that site. Could be 373 apartments in a mix of flats and housing at TWBCs figures
Colebrook Estate	5,000	Up to 10,000 apartments plus accommodation for businesses, retail, leisure etc. by using the Hibrid Building concept
Total	10,211

The diagram below compares CA1 with these sites relative to nearby transport infrastructure and essential retail outlets.

Figure 13: Proximity to Transport/Retail - Comparison of CA1 and High Potential Sites

[TWBC: for Figure 13 see full report].

Together, and in some cases individually, these high potential sites provide a realistic alternative to building at Capel.

E. Conclusion & Next Steps

In reviewing the Plan and the parts of the borough we have been able to research to date, we have come to the conclusion that there are better alternatives to building at Capel:

If a Garden Village has to be the chosen option, we advocate building this in a location where it would be less intrusive on neighbouring boroughs. Blantyre Park is a possibility, although it would affect nearby Staplehurst regarding through traffic and commuters using the station.

Otherwise:

Explore and fully exploit brownfield sites throughout the borough;
Distribute the housing allocation along the A21 corridor at, for example, the eastern end of Pembury, the Pembury Road / Sandown Park area and Colebrook Park;
Maximise potential near to High Brooms station with sites such as the gas works site and playing field;
Ensure that current under-utilised land is developed, such as car parks, building above these to retain the car park itself, for example on the Longfield Road Industrial Estate and the area around the Sainsburys / Homebase area;
Maximise future land usage by eliminating surface car parks, and ensuring that where car parks are built the airspace above is developed too;
Increase density of new-build housing to maximise land efficiency;
Review the design of larger developments to incorporate new concepts to improve living conditions so that residents do not have to experience weather conditions just to go shopping or to their car (i.e. simply a development of shopping malls extended to residential situations);

We propose to continue searching for suitable sites and considering other solutions, but it is felt that rather than being re-active, TWBC should be even more pro-active in its search for these.

We sincerely hope that TWBC will review their concept of building on green belt, productive arable land in the open countryside with unique historical and cultural considerations and little in the way of infrastructure and re-consider locating developments of varying sizes throughout the borough using existing infrastructure and making best use of under-utilised land.

With this challenge comes the opportunity for TWBC to propose innovate solutions which might become the blueprint for other boroughs to follow, evolving to the next generation the principles of the current century old garden city principles.

[TWBC: for Appendices A-E see full report].

DLP_7120

Mr Jeff Fenton

I am writing to object to “The Strategy for Capel Parish” (Policy STR/CA1).

The key elements of the plan relative to Capel Parish are:

* A new “garden village” at Tudeley in the parish of Capel of 2,800 dwellings plus retail outlets etc

* 1 (or is 2?) new schools at Tudeley to meet the needs of the new garden village

* A link road between Tudeley and the A228 at Colts Hill through and bordering AONB & MGB land

* A228 Colts Hill bypass will be built after 41 years in the planning system

* Widening of the B2017 in Capel from the proposed Tudeley village to A21 via A26 & Vauxhall roundabout

* 4,800 new homes, industrial sites, 2 x gypsy sites - east of Paddock Wood encompassing part of Capel parish

* (There is a further 1,000 new homes already approved for Paddock Wood in 2017 with construction already begun)

* Stop Press – Plans to extend the currently being built estate in Paddock Wood by 121 homes will be submitted to TWBC Planning dept within a matter of weeks.

The main focus of this objection is Highways, Infrastructure & Flooding.

Section 1 - Highways

Highways infrastructure is an area of particular concern that will seriously impact the health and wellbeing of the current Capel residents and will increase the risk of loss of life on our already overcrowded roads within the parish.

* Highways is outside of the direct control of any of the developers, landowners or Tunbridge Wells Borough Council.

* All responsibility (and budget) is held directly by Kent County Council (KCC) who to date have shown little interest in improving road safety within Capel parish despite Capel Parish Council raising serious concerns over the past 26+ years.

TWBC/KCC Joint Transportation Board (JTB) meets quarterly at TWBC Town Hall and a Capel Parish Councillor sits on the JTB representing Capel and other TWBC parishes.

* To date there is no official record regarding the TWBC Draft Local Plan being discussed at any meetings of JTB

* No discussions have been reported to Capel Parish Council by the parish representative on the JTB.

* There were no items on the October 2019 meeting agenda of the JTB relative to the draft local plan.

* Why has the draft local plan not been discussed by JTB when it is the biggest change to traffic movements in the area for 40 years?

The current highways issues in Capel Parish that remain unresolved for more than a decade are:

* High volume of traffic throughout the parish, particularly throughout early morning & late afternoon

* Rat-running along very narrow country lanes & side roads with no pavements or speed restrictions

* No official HGV or weight restrictions anywhere in the parish of Capel.

* No traffic calming, crossing islands, pelican crossings, traffic lights, 20mph limits along B2017 throughout Five Oak Green.

* Many roads in the village have very restricted pavement widths or no pavements at all.

* No speed cameras

* Junction with Crittenden Lane/Alders Road on A228 (accident black-spot)

* Junction with Alders Road/Five Oak Green Road B2017 (accident black-spot)

* Turning right when travelling in a southerly direction on A228 into old Whetsted Road – (accident black-spot)

* Need for 20mph speed restriction past Capel Primary School

* Crossing the main B2017 road anywhere in the village

* The railway bridge on Whetsted Road; very narrow and used by some HGVs accessing Moat Farm and industrial units on the farm. There is separate HGV access road to Moat Farm via A228 but KCC Highways will not implement a weight restriction on the bridge.

* Colts Hill – a bypass was proposed 41+ years ago and has never been built – (major accident black spot)

There is no doubt in the minds of the overwhelming majority of local residents that the main road through Five Oak Green (B2017) has major issues and an “advisory” sign that the road is unsuitable for HGV traffic is generally ignored by regular HGV drivers as it is a shorter journey (by 2.4miles) to use B2017 through Five Oak Green between Tonbridge & Paddock Wood (& vice versa) than to use the new £100m A21 dual carriageway between Pembury & Tonbridge which has traffic lights and queuing traffic at the Pembury junctions. HGV drivers save on time and fuel so why use the A21? A simple weight limit of 7.5 tons along B2017 would immediately solve this issue but KCC Highways have done nothing except refuse.

These lorries are very large, often foreign, HGV vehicles up to 18m long (flatbed) or 16m long (covered) plus road planing or tarmac laying machinery (from a local company based the other side of Paddock Wood) that drives all its vehicles through the village to access A21/M25.

Many extremely large vehicles are accessing Paddock Wood industrial and distribution sites and we have far too many through the parish. In Five Oak Green there has already been a number of incidents of children being hit by passing traffic and an awful incident of a dog on a lead being killed by a lorry that mounted the pavement. The dog was being led by a mother and two children, one in a pushchair.

The only shop in the village, a popular Tesco One Stop, is opposite the main bus stop which serves buses running in both directions as there is a small green (island) in the centre of the village which the buses use as a turning point. This means most of the school children have to cross the road without any pelican or zebra crossing to either reach the school bus or visit the shop.

The B2017 from Tonbridge is also the quickest route at peak times between the industrial areas of Tonbridge and the various villages and residential areas to the east around Maidstone as the A26 in Tonbridge experiences huge queues at the junction of A26 and Cannon Lane. The reverse occurs during the morning commute from Maidstone & Paddock Wood to Tonbridge as again the A26 has large queues. The whole area is grid-locked during early morning and evening commute times and rat running is the norm.

Rat running along Whetsted Road is constant throughout the day and this road has no pavements along most of it, has a very narrow bridge with no weight limit and a blind entrance to the bridge at one side. Any significant increase in traffic will result in fatalities without any doubt.

Rat running and local traffic (including many HGVs) turning from A228 into Old Whetsted Road (leading to Whetsted Road) has to cross A228 on a bend with a 50mph limit. There have been some very serious accidents at the black spot and any increase in traffic along A228 will exacerbate the situation.

Tarmac UK Ltd is just re-opening 2 quarries which will use Old Whetsted Road/A228 junction. 40 ton lorries cannot accelerate very quickly and this accident black-spot is more than likely to see an increase in incidents.

Furthermore, by “dualling” the Tonbridge to Kippings Cross section of the A21, opened in 2018; traffic along the A21 has increased so much that we now have long queues at Kippings Cross roundabout on the A21 where the road narrows to a single lane in each direction. Due to the long delays at Kippings Cross rat running is returning to Alders Road in Capel and every country lane has damaged grass verges and evidence of minor accidents as the infrastructure simply is not good enough for the amount of traffic.

When the Draft Local Plan was launched the residents were dumb struck by the ignorance of the planners in understanding what the likely impact was going to be on our highways infrastructure. Already overloaded roads and country lanes will see more than double the traffic and the proposed new roads (if ever built!) will have little impact as they do not reflect the needs at all.

The very significant increase in traffic along the B2017 will further exacerbate the extreme traffic congestion throughout the area for most of the day. Tonbridge roads will be clogged on Woodgate Way, Vale Road, Cannon Lane and Pembury Road as commuters fight with workers and parents delivering their children to existing schools in the area.

The opening of new quarry sites in the Medway valley, close to the proposed new village at Tudeley will bring a minimum of approx 60-120 HGV movements per day to the area for at least the next 20 years.

New school traffic at Tudeley will further exacerbate the situation. The proposed new secondary school in Tudeley will be on the border with Tonbridge, dimidiated by a main line railway and alongside a heavily used road. A school surrounded by heavy traffic and construction sites, with the site divided by a major railway line, cannot be a healthy choice and the distraction of passing trains and noise will further harm the education of the school children. There is NOTHING within this proposal that supports “a child’s education should be conducted in calm and healthy surroundings with no distractions”. That is of course if they manage to get to school on time!

It is also worth noting that the new school will be directly down wind of the current sewage treatment site at Tonbridge to the north of the school. How nice for the pupils & staff!

Tonbridge town services cannot support the additional amount of parking for both commuter and shoppers alike and the recent opening of a major supermarket (Aldi) has had an immediate impact with long traffic queues throughout the day on roads originally built as a “through route” avoiding Tonbridge town centre. Tonbridge cannot cope with this already and there is no space for alternative routes.

Packed commuter trains from Tonbridge Station will be unsustainable, particularly as platforms have already been lengthened to take the longer trains, which are now full most of the day.

Suggestions that “many people living in the new garden settlements will cycle to work or train stations” is ridiculous. The contempt of the planners to view this situation as an excuse to encourage cycling is utter nonsense. The level of HGV traffic on the roads in the area is such that it is unsafe for cycling at dawn and dusk and in the winter it will be dark, raining, cold and very dangerous. There are no cycle routes, sharp blind bends and no traffic controls, it will be mayhem.

The cost to Tonbridge based businesses due to traffic issues is already driving businesses from the area and there are now several empty sites. This simple fact cannot be ignored as the whole draft plan is based upon employment prospects increasing in the local area where workers can (laughably) cycle to work. New businesses will not move to Tonbridge or Paddock Wood unless there is a massive improvement in transportation links. None of the proposed works properly address the issues and the funding for the works will not commence until after the houses have been occupied.

The suggestion in the draft plan of “fast buses” is ridiculous. Whilst the residents of Capel have been fighting for a number of years to have traffic calming with speed reduction, crossing islands and a 20mph zone in the village of Five Oak Green (and to date have been granted nothing at all by KCC!); TWBC wants to introduce “fast buses”! What an insult to the residents. How fast will they be? Either stuck in a traffic queue or wiping out the local community by speeding!!!

There is a plan to build the A228 Colts Hill Bypass. The facts are clear:

* This was planned 40+ years ago around 1975 when Paddock Wood industrial area was being developed.

* The plan has been dumped by KCC more times than men have walked on the moon.

* The current “live” KCC Transport & Infrastructure budget clearly shows there is no financial commitment at all (not a penny!) until “after 2023”.

* The proposed “link” road between Tudeley and A228 is totally dependent upon the Colts Hill bypass being built as the main junction is on the new bypass.

* The bypass will cause all sorts of challenges from pressure groups and residents alike as most of it is AONB and MGB and disturbs other properties.

* It is unlikely to receive any commitment to build until at least 2026-7 and it is therefore unlikely to be completed before 2029-30 as the route is more challenging and expensive than any current “back of an envelope” budget can foresee. We are not aware of a single roads project on an “A” class road in SE England that has ever run to original budget.

* It will therefore require increases to budgets inevitably creating further delays or even result in yet another cancellation of the project if the revised costing before works start is well beyond budget.

* The bypass is unlikely to be completed before 2030+

* By the time we approach the opening of ANY new roads, there will be an increase in dwellings in the area of approximately 80% at a minimum.

* There is a rumour that South East Development Fund money will be financing 50% of Colts Hill but how can that go ahead when KCC has no budget allocation until “after 2023”?

Given this clear delay of 9-10 years from now, where is all the additional traffic going until then? The residents of Capel know exactly where; through our parish on the B2017 with no improvements to road safety at all.

There are 1,000 new homes already under construction in Paddock Wood that were approved 2 years ago. These new estates have zero funding allocated by TWBC or KCC for any road safety schemes whatsoever in Capel, except a ridiculous roundabout improvement scheme which is simply unworkable and designed by developers to find a “solution” that satisfies the planning dept.

The developers believed the roundabout was part of Paddock Wood. It is actually in Capel Parish and Capel Parish Council was not even consulted at all about the plans to change the accident prone roundabout to a three lane roundabout skirting a 16th century Grade 1 listed building. The plan is abominable.

The health of residents will be detrimentally affected and the costs to businesses in the area will be so great that many will move elsewhere and render the need for new housing as totally unnecessary.

Costs regarding the new link road from Tudeley to A228 and improvements to B2017 from Tudeley to A21 will be financed by the developers from the sale of new homes. If we look at the housing needs figures being used by TWBC, they are bound by government to use the 2014 figures. These 2014 estimates are inaccurate, overstated and simply wrong. The later 2016 government housing needs figures are approx 34% lower than the 2014 data and are accepted by every planning dept in the country as being the best and most accurate figures to use but our government insists on using the out of date 2016 data. Is this to attract more development or overdevelopment?

Given this huge discrepancy in numbers, and taking into account that the new roads will be financed from the sale of these imaginary new homes; how will local government finance the new roads if their income is reduced by 34% due to the reduced number for homes being sold (or in reality not being built!)?

You cannot build 66% of a new road so it is likely that nothing will be built until 30-35 years time at earliest. This whole calculation is pure conjecture at this stage and to suggest there will be substantial sums available for a new and improved major road network is dabbling in the realm of fantasy, just the same as the KCC promise for 41 years that Colts Hill bypass will be built.. There needs to be a more formal dialogue with KCC, TWBC, parish council and planners well before any plans are approved to ensure the right roads are being built in the right places.

The current highways plan is not reflective of travel needs in the west Kent area at all and is just an add on to the awful mess we currently have where much of the A228 traffic would not be there had KCC and Highways England reviewed the situation first.

The industrial bases in Kent are Paddock Wood, East Peckham, Tonbridge, Tunbridge Wells, Ashford, Medway, Aylesford, Canterbury, Rochester, Chatham and Maidstone area.

By examining the actual road network in Kent we find there are a number of simple omissions to the network that have a massive impact on the area surrounding Paddock Wood and Capel and if these basic issues were addressed by KCC and Highways England the roads planning for West Kent and in particular areas such as Capel would likely be changed.

Some basic facts need to be noted:

* A major omission when the M25/M26 was built has had a serious impact upon traffic levels in the M20/A21 corridors and the along A228 & A26.

* The A21/M25/M26 major junction at Sevenoaks has no off ramp to allow traffic on M26 going west (from M20/M2 Maidstone /North East Kent/Dover etc) to turn south on to A21 to Tonbridge, Tunbridge Wells, Hastings, Bexhill & Crowborough.

* Vice versa there is no off ramp on A21 heading north to access the M26 to M20/M2 to East & North Kent, Maidstone, Dover etc.

* Drivers from Tunbridge Wells/Tonbridge/Paddock Wood area etc heading to M20/M2/Dover corridor have a choice:

1. Travel via A228 to West Malling/Leybourne M20 junction approx.19 miles or:

2. Travel an additional 21 miles to travel via A21/M25/M20 to reach the same Leybourne A228 junction on M20.

* The A228 is being used as the shortest route simply because the M25/M26/A21 junction is incomplete.

If we then add the issue of HGVs travelling through Hadlow and Tonbridge on the A26, which has been a major problem for decades, it becomes obvious that serious upgrades to the roads in the area are needed but not as per the TWBC Draft Local Plan. There is apparently no helicopter perspective regarding highways and despite a duty to cooperate the various Boroughs are just looking at housing need & then infilling the road network ad hoc.

1. Build the M26/A21 link at Sevenoaks M25 junction to remove traffic from A228 & A26.

2. Build a new road from A228 Beltring (Hop Farm) roundabout through the Medway valley to A21/A26 junction at Tonbridge for Paddock Wood industrial areas to access A21.

3. Ban all HGVs from B2017 except for access

4. Install traffic calming measures within Capel, particularly in Five Oak Green village to deuce traffic speed.

5. Do NOT build A228 Colts Hill bypass unless 1,2+3 above have been completed first and a further review of requirements completed.

Hopefully the Inspector will compare the Tudeley proposals to the new Sherford Community close to Plymouth where the planning authority insisted that a new access road should be built PRIOR to the start of construction of any housing to protect the lives and livelihoods of nearby residents. However, Sherwood is a sustainable project whereas there is nothing about the TWBC Draft Plan that can be proven to be sustainable as it clearly is not.

Despite all the suggestions on how to improve the local roads network, it is totally unacceptable to add a further 6,000 houses in this area as it is damaging to MGB land; will destroy peoples lives and increase road deaths through Capel.

Flooding

We must not ignore the delicate balance between rainwater, rivers, streams and flooding in the Medway floodplain and in particular the history of flooding in Five Oak Green. We must also note the facts regarding recent flooding during November 2019 in Doncaster and surrounding area which affected the lives of thousands of residents in the river Don valley.

After installing new flood defences to protect Sheffield the floodwaters moved downstream to flood in Doncaster. Flood prevention only works if there is adequate land for floodwater that does not impact housing or industrial areas further downstream. Water does not flow uphill and finds its own level.

In West Kent we do not have the luxury of hundreds of acres of spare land that can be left to flood as there is already a flood plain that on numerous occasions has flooded to depths of up to 10+ feet (3m). The village of Yalding, downstream from Tudeley has seen some of the worst flooding ever in the UK in recent years and anything likely to move water further downstream instead of remaining on the land upstream of Yalding is likely to severely impact the village. Concreting over 300 acres of farm land for a new village at Tudeley will have a severe impact on river levels in the Medway and the villages of Five Oak Green, East Peckham, Yalding and further downstream will be seriously affected.

Parts of Five Oak Green and Capel parish have suffered severe flooding since the 1970s. Various small schemes have been implemented, such as cleaning old pipes and drains regularly, but the flooding still occurs in places. Make no mistakes about this; the balance between water and flood is already at extreme levels and Southern Water have tankers on permanent standby to protect Five Oak Green.

Hundreds of homes in the Medway valley have experienced flooding over the past two decades and the proposed developments are likely to add further to the complex and very delicate balance between water, land drainage and flooding.

The land where the proposed development is planned in Capel East, adjoining Paddock Wood to the north, has flooded to several feet in recent years on more than one occasion and pouring more water into the Medway further upstream will only worsen the situation.

There will be various ”desktop models” that will show this can be made to work but go and ask the people who live in these areas and they will all tell you that the “models” are based on flawed data. An example of this is that the Environment Agency flood data for Five Oak Green is based upon rainfall and water dispersal in Paddock Wood, yet there is no river in Paddock Wood (and it still floods regularly) and Capel has 14% more rain than Paddock Wood due to its adjacency to the hills to the south.

The first new estate currently being developed in Paddock Wood has already stopped building work due to drainage issues and new houses are now having cess-pits installed as the drains simply do not work. This is just one estate out of the 3 already approved and another planning application is to be submitted by one of the current developers, Berkeley Homes, for a further 117 homes bordering their current site. The new application will be submitted in the next few weeks.

The developments in both Tudeley and East Capel (its NOT Paddock Wood yet!) will further create major issues to causing even more flooding.

To date; there is absolutely no evidence at all of the Environment Agency (a statutory consultee) in any area of the country ever having stopped the building of any development on the grounds of potential flooding. The approach by developers is to use a highly paid consultancy to demonstrate that the risk of flooding is minimal and that preventative measures will satisfy the Environment Agency.

Ask the people of the Somerset levels, Doncaster, East Peckham, Five Oak Green and Yalding etc etc what they think of the EA and what confidence they have in their ability to manage flood risk in any area of the country? They are a toothless quango.

Other Objections

There will be an increase in air, light and noise pollution that will spread across the boundary into Tonbridge & Malling and create a visual scar across the landscape.

The garden settlement at Tudeley can never be one settlement as it is divided by a railway line that has a very narrow, bridge. Putting in larger crossings at frequent points across the railway may be possible but it won’t tie the two halves of the settlement together enough to make it one settlement, so it will never satisfy garden settlement principles.

One fails to understand how a brand new community that will instantly become divided by a railway line can support the basic function of a community and that is to be united! In years to come teenage gangs will enjoy battling against their opponents from “the other side of the tracks”.

DLP_7134

Jonathon & Zamira Benthall

(2) Policy STR/CA1 (The Strategy for Capel Parish)

(i) In general, we regard the proposed imposition of a "garden settlement" on Tudeley, with allowance for 2,800 dwellings, as a local disaster. The permanent loss of agricultural land, designated as Green Belt and AONB, would need very persuasive arguments in its favour to be justified. We are not convinced that other alternatives, especially the use of brownfield sites, have been explored, and the suspicion arises that this Tudeley/Capel solution has been chosen because it is relatively easier for the Council to negotiate with a single landowner than with many different proprietors.

(ii) Apart from the loss of beautiful agricultural land, and the problem of flood mitigation (on which we have no expertise), the most serious objection would be the impact on rail, road and parking facilities in the Tonbridge area. It is likely that many of the new dwellings will be bought by Londoners able to sell their London homes for a large profit and move to the Tonbridge area to commute – thereby adding to the pressure on transport facilities. Tonbridge functions quite well at present as a commuter town, though its rail services, roads and parking space are already stretched to capacity, and there is no safe access by bicycle. We anticipate that the proposed Tudeley/Capel development will have a negative impact on the quality of life for everyone who uses Tonbridge as a communications hub – which includes pupils, staff members and parents at the many schools in the Tonbridge area.

(3) All Saints’ Church, Tudeley

We can find no reference in the Local Plan to the fact that this much visited church is listed Grade 1, one of the very few churches in the world with a complete set of windows by Marc Chagall. The setting of the church to the east, with its large churchyard, is a place of restorative tranquillity which should if possible be retained. There are suggestions that the church would in future find itself next to a busy roundabout, which would be a great pity.

DLP_7135

Ann Kelly

I am writing to object to the Strategy for Capel Parish (STR/CA1), to the plans for development of Mabledon and Nightingale Farm (AL/SO3) and expansion of business, industry, storage and leisure at Longfield Road/Knights Park (AL/RTW 12, AL/RTW 13, AL/RTW14).

I am a long time resident of the region and borough, having lived in Tonbridge and Southborough as a child, and in High Brooms for the last twenty years, and am very familiar with all of the areas I am commenting on. I have watched with dismay as the Borough has become increasingly built up and congested, and the beautiful and valuable natural landscapes it contains have been pared away at by ill-considered development. The Draft Plan though, takes this to a hideous extreme, and I must raise my voice against it.

All of these developments will cause huge harm to local communities, to the environment, and to the character and beauty of the area. Additionally, all are extremely unfair to the people of Tonbridge, who will reap a large proportion of the downsides and none of the benefits, and so represent an act of extreme bad faith by Tunbridge Wells planners.

I have numerous points of objection but will restrict them to the following:

1. Climate change and ecosystem preservation: We are in a climate and nature emergency - parliament itself have declared this to be the case. We need to plant trees, we need to maintain the ecosystems that help regulate the planet's temperature, rainfall and other natural cycles.

This is not a time to be destroying countryside and natural habitat, as these plans will do. Much of this is good agricultural land - we should be using it to provide our food in a sustainable manner, not capping it off with concrete. It is also clear that areas of ancient woodland will be destroyed by these developments - this is unjustifiable, more now than ever. Once destroyed, ecosystems are almost impossible to restore on a human timescale. Your grandchildren will curse your names if you go ahead with this ecological vandalism.

2. Large parts of the Tudeley/Capel development are on a flood plain. Flooding is more likely than ever due to climate change, and assessments based on old data, such as those used by the Draft Plan, cannot be relied upon. Capping off the land with houses and roads will reduce the land's ability to soak up water and mitigate flooding, making flooding more likely both here and further downstream, e.g. Yalding. Houses that flood are difficult to sell and difficult to insure. Their value reduces, along with the tax they bring in. Looking after flooded out families is expensive. Is this something Tunbridge Wells Borough is keen to store up for itself?

2. Destruction of beauty: The visual and character effects on the area will be appalling - views across the high and low weald will be destroyed, the landscape will be scarred. The Capel development will turn a green and pleasant valley, which can be seen from numerous vantage points across South Tonbridge, Pembury, Southborough and High Brooms, to a grey built enviroment with no such visual appeal. The Mabledon development will destroy another pleasant valley, historically important as part of the South Frith forest, and affect yet more ancient woodland. The Longfield Road development will make the recent eyesore of the new A21/Longfield Road junction, viewable from Castle Hill, Southborough and various other locations, even worse.

3. Transport: The transport infrastructure will not cope with the massive new amounts of housing - traffic will pour into Tonbridge, already ridiculously congested for much of the day, and already packed communter trains will be put under further strain. Existing communities, especially in Capel, Tudeley and in South Tonbridge, will be seriously disadvantaged, and I do not believe these impacts have been considered fully. The Mabledon development will add to already excessive congestion on the A26. See below for comments on Knights Park, which will also have very negative effects on congestion. This will increase air pollution and emissions of greenhouse gasses, creating yet more negative environmental effects.

4. Bad faith: The developments are as close to the boundary between Tunbridge Wells and Tonbridge boroughs as is possible, and as such will have a disproportionately negative effect on Tonbridge. New residents use transport, medical, educational etc facilities nearby to them in Tonbridge rather than further away, so the town will suffer from increased pressure on these facilities while gaining none of the benefits, such as increased council tax receipts etc. This is unfair, unneighbourly and reflects very badly on the Council. Surely borough councillors are motivated by improving conditions for their whole communities? How can it be right that one council should advantage itself by beggaring its neighbour? I would be surprised if Tonbridge and Malling Borough Council have not made their own representations on this matter.

5. With reference to Knights Park/Longfield Road specifically -

a) Tunbridge Wells has a town centre dying on its feet, with a large underused shopping centre in it. Why, then, encourage further flight to out-of-town leisure facilities, with the accompanying emissions and congestion from car use? Encouragement of development of leisure facilies within the town would be far more sensible, and help revive the town centre. Yet by developing elsewhere, demand will be diverted from this far preferable outcome.

b) All of these developments will seriouly exacerbate the congestion that has already started to build up again on the industrial/retail estate, which was briefly alleviated by the road layout improvements finished in 2017. It will no doubt have knock on effects on the generally impassable Pembury Road as people try to find alternative routes. Development that will inevitably bring more cars, lorries and congestion to this area is ill-conceived. A few bus lanes won't cut it here, it's frequently completely gridlocked up to ASDA.

6. Flaws in the assumptions of the Draft Plan: The levels of housing need as stated in the draft plan are higher than required by government policy, and therefore should be reduced. I will quote from information provided by the Save Capel group on this:

"Housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan. TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant."

Additionally, the draft plan as it relates to Tudeley is not fit for purpose due to failure to assess the impacts on the area adequately. I quote again.

"The plan preparation process didn’t include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan didn’t go through most of the plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment, no Biodiversity Assessment. I think that this version of the draft Local Plan isn’t complete enough to be ready for public consultation when the land for such a big proportion of the housing hasn’t had the same level of assessment as the rest of the plan. The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they didn’t know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. I think that the plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough."

Tunbridge Wells Borough Council is putting a desire for development before its duty to do the right thing for the communities it serves. I urge a reconsideration of this ill-conceived plan.

DLP_7140

Chrissie Wise

I have grown up in and around Capel and the surrounding area. Walking every day in the fields from Paddock Wood to the A228 by pass.

Please add my contact details to your consultation database so that I can be kept informed of all future consultations on planning policy documents. I understand that my comments will be published by the Borough Council, including on its website.

I am writing to object to THE STRATAGY FOR CAPEL PARISH [POLICY STR/CA1] and also the inclusion of land in East Capel in THE STRATEGY FOR PADDOCK WOOD [POLICY STR/PW1]

I understand that we require more houses but feel that Capel is not a viable option. Capel is low and flat with the soil being mostly clay. It is a wet place with many ponds and streams which with the extra housing would be liable to flooding as it is close to the river Medway.

Creating 2800 homes will cause a major impact on Capel and the surrounding area.

Increased traffic, which our roads cannot take as they barely accommodate the traffic we have at present.

Tonbridge station has already been named as the busiest outside of London, keeping up with the increasing numbers of commuters will mean another overhaul of this site, T & MBC will not be receiving council tax from the proposed planning to implement the overhaul of infrastructure required to accommodate the above.

Our hospital and doctors are already overstretched and again I believe T & MBC will be affected more than Tunbridge Wells council.

The planning would destroy green belt land and natural habitats for many creatures/insects. We need to keep as many trees as possible to off set our carbon foot print.

DLP_7144

Siobhan O'Connell

Object

Policy Number: STR/CA1

People living in Tudeley will use Tonbridge Station for commuting and Tonbridge town services. There is already significant traffic congestion in Tonbridge and the increase in traffic will be more than can be accommodated. Its roads are already full at peak times and can’t be made wider in most places. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable. Parking in and around Tonbridge Station will be even more difficult. Network Rail have confirmed that a station at Tudeley is not viable at present and so will not be built in this plan period. Most people living in the new garden settlements will drive privately owned cars, despite initiatives to encourage bus and bicycle use. The costs of infrastructure on the Tonbridge & Malling side of the boundary will have to be carried by Tonbridge & Malling residents whilst Tunbridge Wells will receive council tax from the residents in the new dwellings. The cost to Tonbridge based businesses due to traffic issues may drive businesses from the area. There will be an increase in pressure on Tonbridge health services, amenities and car parking as residents from the new garden settlement at Tudeley will use Tonbridge as their local town, not Tunbridge Wells, because Tonbridge is much closer.

Large parts of the developments will occur on the Medway floodplain with flood risk assessments based on old data that does not fully consider the impact of climate change. Flood mitigation measures may help, but I believe that flood risks will increase. Covering farmed fields with houses and roads will make the Medway flood more often and cause increased flood risk not only in Tudeley but in Golden Green, East Peckham, Tonbridge and Yalding. There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape. Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saint’s Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. That will cause great harm to its value as a heritage asset of world renown (due to the complete set of Marc Chagall windows).

The garden settlement at Tudeley can never be one settlement as it is divided by a railway line that has very narrow, weak crossings. Putting in larger crossings at frequent points across the railway may be possible but it won’t tie the two halves of the settlement together enough to make it one settlement, so it will never satisfy garden settlement principles.

DLP_7146

Kaye Palmer

I am writing with my formal comments on your Local Plan. I live in Tudeley with my family and passionately love where I live. Although we pay our Council Tax to Tunbridge Wells Borough Council, we have a closer affiliation to the town of Tonbridge and use their amenities, being only a short car or bus journey away. For example my child attends school in Tonbridge, I have never started a train journey from either Paddock Wood or Tunbridge Wells stations because Tonbridge station is closer and we are registered with the Hadlow medical practice, also in Tonbridge and Malling Borough, because this is closer than any Tunbridge Wells practice.

For the reasons set out below, please include my objections to policies CA1 and CA2 of the Local Plan.

“The Strategy for Capel Parish” (Policies STR/CA1 and CA2)

Traffic and Transport – To say the least, the Plan is sketchy on its highway proposals for this site – much more information would have allowed constructive comment. However, I do not believe it will be possible to mitigate the effects of the additional houses because any improvements in TWBC will merely deliver traffic to the pinch points in Tonbridge faster, where most traffic will be heading either as a destination or en route elsewhere. The B2017 is already very heavily used, and traffic frequently queues back from All Saints Church to the Woodgate roundabout, then to the A21 roundabout and beyond into Tonbridge along the Pembury Road during the morning rush hour. There are many secondary schools and a FE college in a small area of Tonbridge (and close to CA1) which contribute considerably to the daily congestion, creating a danger to school children as drivers’ patience wears thin. This will be acerbated by the proposed new secondary school which will not be served by a railway but will necessitate most children arriving and leaving by road.

Tonbridge station is one of the busiest in the South East and will not be able to cope with a large increase in passenger numbers or station car parking. It is unrealistic to suggest that residents of Tudeley will travel to Tunbridge Wells or Paddock Wood stations for their daily commute or that large numbers will choose to cycle to their destination. Trains are already at capacity with passengers having to stand as a result of developments which have already taken place further down the line. This will also affect passengers in Sevenoaks and Orpington and is unsustainable.

Pollution and air quality – The increase in traffic, congestion and idling car engines will increase the presence of harmful emissions and damage air quality at a time when TWBC should be responding constructively to the climate emergency not adding to it. Leading scientists are promoting the planting of trees to remove harmful greenhouse gases from the atmosphere and yet TWBC is promoting the removal of trees and ancient woodland.

Dark Skies – The Local Plan is promoting “dark skies” in rural areas stating, “Dark skies are places where you can look at the night sky without light pollution”. The Parish of Capel is currently such a place. It goes on to say “Light pollution can harm the character of an area and cause problems for wildlife especially nocturnal animals”. It is difficult to imagine anything more at odds with this aim than constructing a new town on a site which currently, because of its topography, has vast open night skies and is teaming with nocturnal wildlife including owls and bats. Policy CA1 conflicts with the dark skies objective.

Biodiversity and Wellbing – The site of CA1 is currently occupied by woodland (some of it ancient), hedgerows, meadows, farmland and is home to threatened species. Wildlife visitors to my garden would be under serious threat from the proposal including finches, nuthatch, thrush, tits, woodpeckers, kingfisher, newts and hedgehogs. The proposals would wipe out acres of land currently enjoyed by residents, visitors and wildlife. I see daily the very many walkers who use our footpaths and appreciate the fresh air and wildlife of this Parish. The restorative nature of our beautiful landscape is so vital to the mental and physical wellbeing of people taking a break from the stresses of daily life. At a time when the UK is redefining its place in the world, we should be supporting not destroying our high quality agricultural land which can provide sustenance and support wellbeing. CA1 is not environmentally sustainable.

Tourism and Heritage – Our parish has a rich history and attracts very many tourists. They visit All Saints Church, with its unique Chagall windows; and enjoy our distinctive, beautiful landscape, peppered with oasthouses reflecting a bygone age of hop picking by Londoners who would take up temporary residence in Capel. Tourists also appreciate the open views across the High Weald to Hadlow Tower. As the All Saints visitors’ book will testify, coach parties and individuals from around the world are frequent visitors to the church. Its setting is as important as its windows and should be protected. Having installed the one window Chagall was commissioned to create, he declared that he would replace all the windows, such was the beauty and perfection of the setting for his art. It is a great shame and an embarrassment that TWBC are blind and profligate with the beauty that was so obvious to Chagall and to the many visitors to our parish. The Plan refers to its requirement to conserve heritage sites – CA1 is contrary to this requirement.

Greenbelt – The separation between settlements that the greenbelt provides has been protected for generations. Once it has been built on, it will be gone for ever. Therefore, the Government advises that Greenbelt land should only be developed in exceptional circumstances. No such exception has been evidenced for CA1. This large swathe of prime agricultural land and woodland should continue to enjoy the protection provided by the Greenbelt policy. CA1 together with PW1 will vastly reduce the separation between settlements and eventually result in a coalescence of development creating a conurbation from Tonbridge to Paddock Wood. In addition, large parts of this land are within the Medway Floodplain and will increase the risks of flooding to the nearby villages of Golden Green, East Peckham and the town of Tonbridge, as well as further afield in Yalding which already has a history of major flooding. I understand that the housing need calculated by the Government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan.

Housing – To suggest that Tudeley new town will meet the local need for affordable homes is disingenuous. New housing estates in the area are frequently marketed in London, with offers of season tickets thrown in to attract buyers when properties are difficult to sell. It appears that Capel is being sacrificed to help deal with the wider issue of Londoners being priced out of the Capital. The railway bisecting Tudeley will provide no benefit to residents but will lead to a divided community. This is contrary to the unified new settlement being promoted and required by garden settlement principles. The number of homes the parish of Capel is expected to provide is completely disproportionate to the rest of the Borough.

I understand that TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the Borough. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the Borough is slowing, making this proposed approach honest and relevant. The Plan refers to Tudeley securing a long-term option for the Borough to deliver the needs of future generations. This statement indicates an intention to add more and more housing to this “garden settlement”. TWBC is using Capel to dump their housing needs on green fields and meadows, polluting a rural area rather than spreading development across the Borough. The developments in Tudeley and East Capel are unsustainable and place huge pressure on Tonbridge.

Brownfield Sites – The Plan does not provide adequate evidence of brownfield sites either being sought or considered during the preparation process. Bringing back into use some of the many derelict sites around the Borough would have been a far more sustainable approach to meeting the housing need, in locations where infrastructure already exists. Instead the Council has struck a financially expedient deal with one landowner by dumping the majority of its new housing in one Parish with little regard to the consequences.

Local Plan Consultation Process - The plan preparation process did not include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. Therefore, the largest housing area in the Plan did not go through most of the Plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment or Biodiversity Assessment. Therefore, the draft Local Plan is not fit for public consultation.

The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they did not know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. Therefore, the plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the Borough.

DLP_7184

Nigel Tansley

I wish to object to the TWBC Draft Local Plan - in particular the strategy for Capel Parish (CA1-3).

Attached please find a document detailing alternative solutions to the above developments that have been researched by concerned residents in Capel and surrounding areas.

Contributors: Nigel Tansley & Jan Mueller

A. Introduction

A.1. Report Objective and Content

A.2. Report Structure

The report commences with two contextual sections to set the scene:

(2) Section C. discusses the appropriateness of TWBC’s housing target and suggests alternative requirements.

The core of the report is Section D. which seeks to highlight alternative solutions to achieve TWBC housing target. Here, we investigate the following topics:

(1) How many sites submitted for development were rejected by TWBC but - in light of the decision made to develop land in Capel - should be reconsidered?

(2) How many sites in the borough are available for development (brownfield and other categories) which are not registered on TWBC’s system and what is their housing potential?

(3) What is the additional housing potential if land were to be used more effectively for:

In closing, Section E. contains a summary of conclusions and recommendations as well as suggested next steps which we hope to undertake in conjunction with TWBC’s planning team.

B. Overall Feedback on the TWBC Draft Local Plan

B.1. Decision-Making and Due Diligence

[TWBC: for Figure 1 see full report].

This also inspired an analysis of ‘rejected’ SHELLAA sites which we will return to in Section D.1.

Evidence Studies for Local Plan Issues and Options

(documents below should have addressed Tudeley if CA1 was to be included in the Reg 18 Plan)

Landscape Sensitivity Assessment of Countryside around TW (LUC) - published February 2017 This assessment is intended to inform the Local Plan and therefore assist TWBC to identify potential development areas or sites for allocation. The next step would be a Landscape and Visual Impact Assessment of any site identified for further consideration. The selected study area by TWBC/LUC “is likely to be considered as part of the Local Plan process”. Tudeley (CA1) is not even mentioned in this report and therefore not assessed; it can be assumed that Tudeley was not considered an appropriate site for development prior to Hadlow Estate offering land. The nearest sub-area considered in the assessment is PW10 which is identified as having “high” sensitivity to medium-large scale development.
Settlement Role and Function Study - April 2017. Tudeley is not included.

Evidence Studies for Local Plan after Issues and Options Consultation

(documents below should have addressed Tudeley if CA1 was to be included in the Reg 18 Draft LP)

TW Green Belt Study - Stage 2 (LUC) - July 2017

There is no recommendation that the Metropolitan Green Belt (“MGB”) boundary is altered or green belt parcels are released in Tudeley. CA1 falls within Broad Area BA3 and BA4 - development would cause “very high harm"
Interim SHELAA (2017)

SHELAA (July 2019)

Due to the delayed publication of the Plan, there was time to include and assess all these new sites.

However, an assessment of the CA1 site was included in these reports:

TWBC Landscape Character Assessment (LUC) - commissioned in August 2016, referenced for Issues and Options document, adopted December 2017

Site CA1 lies within Character Area 13 and character sensitivities, valued features and qualities, detractors and opportunities and Landscape Strategy are addressed. This document details the landscape and settlement characteristics at Capel and Tudeley. It notes the strong association between Character Area 13 and the AONB and "the area enhances the character of the AONB landscape.”
Historic Landscape Characterisation of the Parish of Capel (Revision of HLC 2000) - dated October 2016, published May 2017 (but still stamped Draft in 2019). Discusses the sharp contrast of early modern/C20 land use in the middle and north of the parish with remnants of the older medieval farmed landscape to the south. The changes in the C19 and C20 are shown most clearly along the edge of the Medway valley, but the underlying structure of remaining field boundaries, old routeways (lanes and paths) and the dispersed nature of the historic settlement is still present and can be identified here.

B.2. Climate Emergency / Green Belt

It is also in complete contradiction to TWBC’s recent announcement of a Climate Emergency - a conflict of policies which is not addressed in the Plan.

The crops currently grown in CA1 will need to be grown elsewhere, ultimately leading to new farmland being created at the expense of woodlands and forests - here or elsewhere in the world.

B.3. Disproportionate Impact on Capel Parish

Figure 2. – Comparison of Population vs. Approved Housing by Parish

#	Parish	Population (2011) Inhabitants % of TOTAL		Approved Housing (Plan) Dwellings % of TOTAL
1	Benenden	2,400	2.1%	160	1.0%
2	Bidborough	1,163	1.0%	-	0.0%
3	Brenchley and Matfield	2,863	2.5%	121	0.8%
4	Capel	2,467	2.1%	6,695	42.9%
5	Cranbrook and Sissinghurst	6,700	5.8%	1,214	7.8%
6	Frittenden	888	0.8%	28	0.2%
7	Goudhurst	3,327	2.9%	48	0.3%
8	Hawkhurst	4,991	4.3%	706	4.5%
9	Horsmonden	2,435	2.1%	258	1.7%
10	Lamberhurst	1,706	1.5%	56	0.4%
11	Paddock Wood	8,253	7.1%	4,175	26.7%
12	Pembury	6,128	5.3%	299	1.9%
13	Royal Tunbridge Wells	48,324	41.8%	1,615	10.3%
14	Rusthall	4,976	4.3%	15	0.1%
15	Sandhurst	1,478	1.3%	24	0.2%
16	Southborough	12,459	10.8%	190	1.2%
17	Speldhurst	4,978	4.3%	18	0.1%
	TOTAL	115,536	100%	15,622	100%

B.4. Sustainability Assessment of CA1 – Tudeley Village

Site Characteristics

Turning to CA1 – the site earmarked for the development of Tudeley Village – itself, it is hard to imagine a site less suited to larger scale development.

Key considerations that make this site unsuitable for situating a Garden Village include:

Land Status: The land is part of the Green Belt and borders on AONB
Landscape / Use: The site predominantly consists of high-quality arable land (Grade 2 and 3) that is in agricultural production. It also includes hedging and woodland and supports several public foot paths regularly used by the both the local community and people from further afield for recreational purposes.
Infrastructure: There is no existing electricity or sewage infrastructure to support large scale development. This would have to be built from scratch at a very high cost
Services: Development of several thousand houses will lead to substantial new demand for health and educational services for which there are no existing facilities within Capel parish. Demand would likely fall on the adjacent Tonbridge and Malling (T&M) borough. Their facilities already experience very high demand and are unlikely to cope with large increases. Investment in new schools or GP practices are likely to be required.
Transportation (1 – on CA1): Apart from 1-2 narrow winding tracks, there is currently no road infrastructure on the CA1 site. Bus services are very limited / non existing. There are no cycle paths or walking paths connecting to Tonbridge. All would have to be built from scratch. Tudeley Road / B2017 which is the main East-West connection (to Tonbridge or Five Oak Green / Paddock Wood) is already heavily used with long tailbacks at the entrance to Tonbridge (especially at both roundabouts next to the Schools at Somerhill) during rush hour / school pick up times.
Transportation (2 – congestion): Given the type of development envisaged at Tudeley Village, it is highly likely that this will predominantly cater for regular commuters to London who will want to use Tonbridge Station. There are currently no suitable bus services to / from Tonbridge station, and cycle and walking options are unrealistic. It seems clear that there will be a heavy reliance on cars leading to a large-scale increase in road traffic around the site. While expanding the B2017 (or building a new road) could conceivably allow faster traffic flow to / from Tonbridge – this is likely to come to a shuddering halt at the entrance to and cause gridlock in Tonbridge where there are no opportunities for widening the road network.

In addition, the plan to build a new secondary school at CA3 is likely to further add to congestion and air pollution right at the entrance to Tonbridge which already is a traffic pinch point. TWBC’s assertion that this school will only cater for local pupils and be accessed through walking or cycling flies in the face of the reality experienced by the existing schools in Tonbridge – which already has one of the highest densities of secondary schools in the UK.
Transportation (3 – safety): We would similarly expect a heavy increase in traffic down Alders Lane to the A228, Hartlake Road as well as the ‘cut throughs’ to the A21 (e.g. Half Moon Lane). These are narrow winding country lanes with limited visibility and where cars can often not easily pass each other. Increasing traffic flow is guaranteed to lead to a much- heightened risk of accidents.
Heritage: The site includes the All Saints Church – the only Church globally with Marc Chagall designed windows – which attracts regular international visitors and would not benefit from being surrounded by large scale development. It also includes the landowner’s century old family graveyard. Neither of which is mentioned in the SHELAA assessment
Other constraints: The site is dissected by an existing railway line. This raises obvious concerns about how to adequately and safely connect North and South halves of the site. The only current connections are a small underpass in the middle of the site as well as bridge over Hartlake Road on the site boundary. Both are single lane and not suitable for the anticipated traffic increase.

Distance from centre (miles) to:	as crow flies	by existing roads
road infrastructure of suitable capacity	1.6	2.3
railway station – Tunbridge Wells	4.8	7.6
railway station – Tonbridge (cross border)	2.6	3.7
railway station – Paddock Wood	2.6	4.3
nearest supermarket – Tunbridge Wells Asda	2.6	5.8
nearest supermarket – Tonbridge Sainsburys	2.4	3.4
nearest supermarket – Paddock Wood	2.7	4.3

Its own large supermarket similar to Asda at Kings Hill would create cross border issues Mains water of sufficient capacity not known

Mains sewers of sufficient capacity not known

Land use productive agriculture

Land status green belt

Land contamination not known, Landscape Sensitivity Study not made

Ecological interest not known, Landscape Sensitivity Study not made

Critique of the Sustainability Assessment for STR / CA1

Air: How can this be given a “mixed score”? The SA correctly notes that “traffic will increase substantially” with a “high risk to deterioration of local air quality”. The intent to discourage private car usage through shared transport is laudable but is not backed up with any actionable initiatives and is both unenforceable and Increased traffic WILL lead to poorer air quality – the only question is by how much? Score should be very negative
Biodiversity: How can you say that “constraints are limited”. And it is unclear why the reference to Ashdown Forest should be relevant for this Building a large-scale new development on 100s of acres of Green Belt land can only be detrimental to biodiversity. References elsewhere to achieving a “biodiversity net gain” feel like a smokescreen that is not backed up by anything tangible. And the experience of the Tesco Site where woodland was removed for a GBP 25,000 contribution in order to score a ‘biodiversity net gain’ is frankly perverse. This is of course not directly related to CA1 but it does not give any confidence that environmental concerns will be dealt with the seriousness they deserve Score should be very negative
Business: We agree with the existing positive Though it should be noted that the low density envisaged for this site may actually make it more difficult to justify local retail outlets and/or local services (e.g. buses)
Climate Change: Similar to Air and Loss of greenfield land and the associated carbon capture will negatively impact climate change. As will the additional pollution through incremental development and traffic Score should be very negative
Deprivation: We agree with the existing positive And we note the comment that “maximum scores cannot be applied as the proposals are unlikely to address existing problems of fuel poverty”
Employment + Equality: We agree with the existing
Health: We question the positive score The provision of sports facilities is a positive. But to include a consideration that “It was also felt likely that the proposals would include provision for elderly care services.” seems very strange. This is not a fact or even a promise but an unfounded assumption that is actually unlikely to happen since the Garden Village will predominantly attract working families and not elderly people. Also, concreting over the local Green Belt will destroy the public foot paths currently used by locals for recreational purposes Score should be mixed
Heritage: Agree with the existing negative score though you could argue that this actually very TWBC do not seem to have considered All Saints Church at all
Housing: The maximum positive score for housing is of course the obvious consequence of concentrating the lion’s share of TWBC housing requirements in Capel It is hard not to believe that this is the prime criteria and that assessing / scoring for all other criteria is just ‘window dressing’
Land Use: Why is this score not very negative? Score should be very negative
Landscape: We do not understand why this is not very negative. Apart from the destruction of the Green Belt, encroaching on neighbouring AONB, the developments will also cause ‘landscape scarring’ visible from the North Downs. The existing proposals to extend development further into GB and AONB land in subsequent planning periods are even more worrying Score should be very negative
Noise: We agree with the existing negative score
Services & Facilities: How can you provide a positive score based on the “likely well thought-out provision in the new settlement as a result of the master planning process”? This is wishful thinking and not based on any evidence. A more consistent approach would be a mixed or no score until there is actually a plan to assess. Score should be mixed
Travel: The positive score feels like a joke. New bus routes would be a good idea but these have not been defined (nor any new road links to Tonbridge to start with). The feasibility of any new routes will be undermined by the excessively low density of development at Tudeley Village. And, as has already been noted, the predominant transportation vehicle will be the car anyway. The “relatively easy access to train station” comment can only have been written by someone with zero knowledge of the locality. There are no alternatives to car travel to Tonbridge station. In mornings / afternoons, Tonbridge is already in gridlock with no options to increase road width and once there Tonbridge Station and the trains are already at full capacity Score should be negative / very negative
Waste reduction: While we appreciate this may be out of TWBC’s immediate control, not applying any score seems wrong. Of course, building a large-scale development here will lead to more waste Score should be negative / very negative
Water: The mixed / positive water score is unclear and feels strange. This again seems to be based on anticipated improvements due to “substantial demand for water and wastewater treatment”. In reality, there will be greater water usage and greater waste water generation that at best will be mitigated so as to have no incremental negative effect. But even this cannot really be credited since there are no proposals to review Score should be negative

[TWBC: the above comment has also been entered against the Sustainability Appraisal consultation - see Comment Number SA_135].

C. Appropriateness of the Housing Target

D. Alternative Solutions to achieve the Housing Target

D.1. Rejected Sites Suggested for Review

Based on the SHELAA documentation, there was a total of 437 unique sites submitted for inclusion in the SHELAA process. Of these, 323 unique sites were rejected by TWBC.

We would ask TWBC to review its analysis and re-consider these 43 “rejected” sites for inclusion in the plan.

Figure 3.: Rejected Sites proposed for Reconsideration – Overview by Parish

#	Parish	Save Capel Request to Review
#	Parish	Sites (#)	Developable Area (ha)	Housing (dwellings)
1	Benenden	0	0	-
2	Bidborough	0	0	-
3	Brenchley and Matfield	0	0	-
4	Capel	13	22	521
5	Cranbrook and Sissinghurst	0	0	-
6	Frittenden	0	0	-
7	Goudhurst	0	0	-
8	Hawkhurst	0	0	-
9	Horsmonden	0	0	-
10	Lamberhurst	0	0	-
11	Paddock Wood	0	0	-
12	Pembury	11	26	733
13	Royal Tunbridge Wells	19	38	1,013
14	Rusthall	0	0	-
15	Sandhurst	0	0	-
16	Southborough	0	0	-
17	Speldhurst	0	0	-
18	Outside borough boundary	0	0	-
	TOTAL	43	87	2,267

Figure 4.: Rejected Sites proposed for Reconsideration – By Site

Site ref:	Site Address:	Parish / Location:	Developable Area (Rejected by TWBC)	Housing Yield if Residential (TWBC original figures)
11	Land at and to the rear of 50 Whetsted Road, Five Oak Green, TN12 6RT	Capel	1.62	49
48	Bramley House, Five Oak Green Road, Five Oak Green, Capel, TN12 6TJ	Capel	0.7	21
141	Site south of Badsell Road, Paddock Wood, TN12 6QR	Capel	0.33	Less than 10
143	Land at Tolhurst Road, Five Oak Green	Capel	0.7	21
156	Bracken Dale, Maidstone Road, Colts Hill, Capel, TN2 4AL	Capel	0.25	Less than 10
216	Land at Moat Farm, Whetstead Road, Five Oak Green	Capel	1.06	32
307	Land to the north of Badsell Road, Five Oak Green, Kent	Capel	3.79	114
329	School field, Finches Farm, Five Oak Green, Tonbridge, Kent	Capel	7.31	219
330	Finches Farm, Five Oak Green, Tonbridge, Kent	Capel	0.34	10 or less
331	Forstal Field, Finches Farm, Five Oak Green, Tonbridge, Kent	Capel	2.95	88
418	Capel Grange Farm, Badsell Road, Five Oak Green, Kent	Capel	1.45	44
453	Land off Hartlake Road, Tudeley, Tonbridge, Kent	Capel	0.69	21
Late site 10	Orchard Brook, Five Oak Green Road, Five Oak Green	Capel	0.67	20
28	Land on the eastern side of Woodside Road, Pembury, TN2 4BG	Pembury	0.89	27
64	Land at Woodside House, Woodside Road, Pembury TN2 4BG	Pembury	1.55	47
190	Land south east of Sandhurst Avenue, Pembury	Pembury	3.52	106
191	Land north of Henwoods Mount, Pembury	Pembury	3.19	96
208	Romford House Farm, Kings Toll Road, Pembury, TN2 4BE	Pembury	5.68	170
290	Abbots, Woodside Close, Pembury, Kent	Pembury	0.91	27
332	Priory Farm, Romford Road, Pembury, Kent	Pembury	5.77	173
354	Stone Court Farm, Stone Court Lane, Pembury, Kent	Pembury	1.95	59
367	Land to the southwest of Woodside House, Woodside Road, Pembury, Kent	Pembury	0.92	28
379	Land at Henwood Green Road, Pembury, Kent	Pembury	1.98	59
395 (Local Plan Allocation AL/PE7)	Woodsgate Corner, Pembury, Tunbridge Wells, Kent	Pembury		Not to be allocated for residential
91	RTA Joinery, Rear of 5 Birling Road, Tunbridge Wells, TN2 5LX	Royal Tunbridge Wells	0.23	Less than 10
99	Land at Pembury Road, Tunbridge Wells	Royal Tunbridge Wells	6.57	197
104	3 Lonsdale Gardens, Tunbridge Wells, TN1 1NX	Royal Tunbridge Wells	0.09	Less than 10 units
105	5 Lonsdale Gardens, Tunbridge Wells, TN1 1NX	Royal Tunbridge Wells	0.1	Less than 10 units
114	Land at Sandown Park, west of A21 Royal Tunbridge Wells TN2 4RT	Royal Tunbridge Wells	9.74	292
134 (overlap with site 175)	Land around Sandstone House, Longdrift, Court Lodge and Shallowdene, Broadwater Down, Royal Tunbridge Wells, TN2 5PE	Royal Tunbridge Wells	1.35	41
145; SALP AL/RTW13	WA Turner Factory Site, Broadwater Lane, Tunbridge Wells, TN2 5RD	Royal Tunbridge Wells	1.36	41
165	Pantiles Car Park, Major Yorks Road, Tunbridge Wells, TN2 5TP	Royal Tunbridge Wells	0.77	23
175 (overlaps with site 134)	Court Lodge & Land to the rear of Sandstone House, 44 Broadwater Down, Tunbridge Wells, TN2 5PE	Royal Tunbridge Wells	0.46	Less than 10 units
206	54a Culverden Down, Tunbridge Wells, TN4 9SG	Royal Tunbridge Wells	0.66	Less than 10 units
226	St Mark’s Recreation Ground Frant Road Tunbridge Wells, TN2 5LS	Royal Tunbridge Wells	1.07	32
248 (SALP AL/RTW8)	Land at Rifle Range, Warwick Park, Royal Tunbridge Wells, TN2 5FD	Royal Tunbridge Wells	1	Less than 10 units
258	TN2 and adjacent land, Greggs wood Road, Sherwood, Tunbridge Wells.	Royal Tunbridge Wells	0.06	Less than 10 units
280	Land at The Midway, Nevill Court, Tunbridge Wells, Kent	Royal Tunbridge Wells	4.02	121
328	Land at Eridge Road & Eastlands Close, Royal Tunbridge Wells, Kent	Royal Tunbridge Wells	0.73	22
359 (this site also forms part of site 400)	Land to the east of Halliwell Nursing Home, Kingswood Road, Tunbridge Wells, Kent	Royal Tunbridge Wells	0.4	12
400 and including site 359	Land to the east of Halliwell Nursing Home, Kingswood Road, Tunbridge Wells, Kent	Royal Tunbridge Wells	2.97	89
411	Land at Sandown Park between Pembury Grange and A21, Royal Tunbridge Wells, Kent	Royal Tunbridge Wells	5.51	165

Note: Please find detailed rationale for re-consideration for each site in Appendix A - see full report].

D.2. Brownfield Potential

How many sites in the borough are available for development (brownfield and other categories) which are not registered on TWBC’s system and what is their housing potential?

Overleaf please find interim summary results for new, incremental Brownfield sites (for further site details including exact location and commentary, please see Appendix B - see full report]):

Figure 5.: New Brownfield Site List (Interim)

Ref	Location	Parish	Size (hectares)	Potential Housing Yield at 30 dph
1	West of A21 half mile south of Kippings Cross roundabout	Brenchley & Matfield	13.0	390
2	North east of junction Sychem Lane and Alders Road	Capel	1.9	56
3	West of Whetsed Road, north of last dwelling, 400m from	Capel	0.6	18
4	North of Badsell Road, east of Orchard Business Centre	Capel	0.6	18
5	Capel Village Hall, Falmouth Place, Five Oak Green	Capel	0.2	5
6	Adjacent to Orchard Business Centre, Badsell Road, Five	Capel	0.1	3
7	Industrial building, Five Oak Green Road, opposite	Capel	0.1	2
8	West of A228 Maidstone Road opposite Capel Cottage	Capel	0.0	1
9	Kings Head Pub, Five Oak Green	Five Oak Green	0.1	2
10	Blantyre House	Goudhurst	5.7	172
11	Hawkwell Farmhouse, Maidstone Road	Pembury	0.3	8
12	Car Park of Tunbridge Wells Leisure Centre, Off St Johns	Southborough	0.7	21
13	Land next to 136 - 138 Speldhurst Rd	Southborough	0.4	13
14	Land + Garages between Sir David Park and Keel Gardens	Southborough	0.1	4
15	Langton Geen Village Hall Car Park, Speldhurst Road	Speldhurst	0.4	11
16	Colebrook Park, Land at A21 and Longfield Rd.	Tunbridge Wells	19.7	590
17	Land / Car park at Knights Park Leisure Park (140)	Tunbridge Wells	2.3	69
18	Off Birling Road - in Industrial Area	Tunbridge Wells	2.2	65
19	Sainsburys / Homebase - Car Park	Tunbridge Wells	1.5	45
20	South side of A264, Langton Road opposite All Saints	Tunbridge Wells	1.3	39
21	B&Q off Longfield Rd. - Car Park	Tunbridge Wells	1.1	34
22	Garage area at end of Birling Drive	Tunbridge Wells	0.8	24
23	Car Park at Culverden Square, off St Johns Road	Tunbridge Wells	0.7	20
24	Marks & Spencer / Halfords / Homesense, Off Dowding	Tunbridge Wells	0.6	19
25	AXA PPP office car park, corner of Camden Rd & Forest	Tunbridge Wells	0.6	17
26	Asda, Longfield Road - Car Park	Tunbridge Wells	0.5	15
27	Grass area between Elphicks place and Forest Road	Tunbridge Wells	0.5	14
28	John Lewis off Kingslanding Way - Car Park	Tunbridge Wells	0.4	12
29	Behind ABP, Broadwater Lane - Car Park	Tunbridge Wells	0.4	11
30	South side of Dowding Way and railway, accessed via lane	Tunbridge Wells	0.3	10
31	Tunbridge Wells Shopping Park off Longfield Rd (TK Maxx,	Tunbridge Wells	0.3	9
32	Baldwins Lane, north off North Farm Road, opp High	Tunbridge Wells	0.3	9
33	East of St Johns Rd TW near to sports centre on opposite	Tunbridge Wells	0.3	8
34	Wickes, Off Longfield Road - Car Park	Tunbridge Wells	0.2	7
35	Behind WA Turners in Broadwater Lane - Car Park	Tunbridge Wells	0.2	6
36	North east of junction North Farm Road, Chapman Way,	Tunbridge Wells	0.2	6
37	John St Car Park, just off west of St Johns Rd, opp side to	Tunbridge Wells	0.2	5
38	Car park in Camden Road, between Beulah Road and	Tunbridge Wells	0.2	5
39	Tunbridge Wells Royals Indoor Bowls Club - Car Park,	Tunbridge Wells	0.1	4
40	Tunnel Road	Tunbridge Wells	0.1	4
41	Car park in The Beeches (road) off Sandhurst Road, behind	Tunbridge Wells	0.1	4
42	Calverley Court Car Park, off Calverley Park Gardens	Tunbridge Wells	0.1	3
43	Linden Park Road, Tunbridge Wells - Car Park	Tunbridge Wells	0.1	3
44	Hobbycraft, Longfield Road - Car Park	Tunbridge Wells	0.1	3
45	The Old Coach Park, Linden Park Road - Car Park	Tunbridge Wells	0.1	3
46	Car Park off North Farm Road / Holmewood Rd	Tunbridge Wells	0.1	3
47	Beach St Car Park – off Beech St / Camden Road	Tunbridge Wells	0.1	3
48	Salvation Army Car Park, on junction between Bayall	Tunbridge Wells	0.1	2
49	Garden Street Car Park, off Camden Road	Tunbridge Wells	0.1	2

To date, we have identified 49 potential brownfield sites with an incremental housing potential of ca. 1,800 dwellings.

D.3. Increasing Housing Density

What is the additional housing potential that sites might offer if land is used more effectively?

Developing at higher densities would sharply increase the housing yield per hectare thereby reducing the need to build on greenfield land.

(1) SHELAA sites approved by TWBC

Figure 6: Housing Potential / Density Elasticity for Approved Sites

#	Parish	Dwellings - Density Elasticity
		Approved Dwellings at Original Density	Approved Dwellings if increasing density to c. 40 dph	Approved Dwellings if increasing density to c. 50 dph
1	Benenden	160	213	267
2	Bidborough	-	-	-
3	Brenchley and Matfield	121	161	202
4	Capel	6,695	8,927	11,158
5	Cranbrook and Sissinghurst	1,214	1,534	1,855
6	Frittenden	28	37	47
7	Goudhurst	48	64	80
8	Hawkhurst	706	941	1,177
9	Horsmonden	258	344	430
10	Lamberhurst	56	75	93
11	Paddock Wood	4,175	5,567	6,958
12	Pembury	299	392	498
13	Royal Tunbridge Wells	1,615	1,836	2,073
14	Rusthall	15	15	25
15	Sandhurst	24	32	40
16	Southborough	190	253	317
17	Speldhurst	18	24	30
18	Outside borough boundary	-	-	-
	TOTAL	15,622	20,416	25,249

(2) SHELAA sites rejected by TWBC but we feel should be reconsidered.

Figure 7: Housing Potential / Density Elasticity for Rejected Sites (Selected Parishes)

#	Parish	Dwellings - Density Elasticity
		Rejected Dwellings at Original Density	Rejected Dwellings if increasing density to c. 40 dph	Rejected Dwellings if increasing density to c. 50 dph
1	Benenden
2	Bidborough
3	Brenchley and Matfield
4	Capel	521	859	1,073
5	Cranbrook and Sissinghurst
6	Frittenden
7	Goudhurst
8	Hawkhurst
9	Horsmonden
10	Lamberhurst
11	Paddock Wood
12	Pembury	733	1,056	1,320
13	Royal Tunbridge Wells	1,013	1,422	1,773
14	Rusthall
15	Sandhurst
16	Southborough
17	Speldhurst
18	Outside borough boundary
	TOTAL	2,267	3,336	4,167

(3) Brownfield sites on TWBC’s register

Figure 8: Overview of BF Register 2019 by Status

BF Register 2019 - status	Sites (no)	Size (hectares)	Proposed Dwellings (no.)	Density (dwellings per hectare)
Not permitted	1	0.03	12	400.0
N/A	9	4.67	350	74.9
Decision Pending	2	2.5	42	16.8
Permissioned	22	8.3	480	57.8
Total	34	15.5	884	57.0

Figure 9: Housing Potential / Density Elasticity for BF Register by Status

BF Register 2019	Dwellings at original density	Dwellings if increasing density to 40 dph or below (ca. x 33%)	Dwellings if increasing density to 50 dph or below (ca. x 66%)
Permissioned sites only	480	503	508
Decision Pending	42	50	50
N/A	350	360	365
Total	872	913	924

(4) Brownfield and other sites that we have located;

And as stated above this analysis only covers a subset of the total borough so we would expect there to be further upside.

Figure 9: Housing Potential / Density Elasticity for newly identified BF sites

Newly Identified BF Sites

Dwellings at 30 dph

Dwellings if

increasing density to 40 dph

Dwellings if

increasing density to 50 dph

New Sites

1,793

2,391

2,988

There is clear opportunity to achieve higher housing yields, to optimise the use of land and to decrease the need to build on Green Belt by a moderate increase in housing density.

D.4. Alternative Housing Solutions

THE CASE FOR DENSITY

Land is now a luxury and needs to be used much more efficiently and carefully.

It is therefore encouraging to see that there are locations both in nearby boroughs and in our own, where these higher densities are successfully being used.

In Tunbridge Wells a new estate is being built with luxury homes, a feeling of spaciousness, and a density of
Another group of buildings in Tunbridge Wells has recently been built at
In Tonbridge, there is an estate part of which attractively fronts onto the river, which takes up 27ha with 97 dwellings which gives a density of 76dph – excluding the flats at the entrance to the estate.
Again, in Tonbridge, again adjacent to the river, are flats with a density of

In Section 3, we have demonstrated that by merely increasing from 30 to 50dph a significant number of dwellings can be built upon the SHELAA sites submitted to TWBC.

There are figures which indicate a significant number of young – and no longer so young – people who cannot afford to move out their parents’ homes.

Similarly, the numbers of people getting divorced is significant and many of those need to downsize.

Equally there are plenty of people who have retired, or their families grown up and left the home and the parents wish to downsize.

As a result, a general increase in density of housing would seem to mitigate many of the demands of housing in the borough.

CAR PARKS

In addition, it seems to be traditional that car parks generally must be visible to all. The floor space of retail units is greatly increased by the space required for open air car parks.

It is acknowledged that the car rules all and there is a strong feeling that its presence is too much of a significant part of the visual scene, in addition to taking up valuable space.

With that in mind, it was interesting to note that car parking was likely to be reduced by a possible retail development in Tunbridge Wells:

As a side issue, there are few existing alternative modes of transport that are suitable. For residents of Five Oak Green, there are no direct buses that serve Knights Park.

Therefore, parking is and will continue to be needed and requires space. This is a good example where the parking can be retained with a building above the car park.

POTENTIAL IN SPECIFIC LOCATIONS

1. Blantyre House

Looking at the specification for Garden Villages, one of the criteria seems to be that it should ideally be separate from neighbouring large towns.

CA1’s potential yield is 2,500-2,800 so there is room for CA1 plus some of East Capel, at Blantyre / site 325, at just 30dph.

Staplehurst Station is 11 minutes drive away, with its connection to Ashford International and the high-speed rail link to London and also the continent. Cranbrook is 10 minutes drive away.

However, Blantyre has at this stage not been included in TWBC’s allocations despite, according to their report in the Distribution of Development Topic Paper, page 22:

‘Location has the benefit of being outside of some key constraints and is within reach of the mainline rail at Staplehurst’

Because:

‘However, the scale of site was too small and the site was not submitted in the call for sites and thus this option did not become available for ’ (At this stage, the prospective Tudeley site, now known as CA1, had not been submitted to the SHELAA scheme either.)

There is no mention of the neighbouring SHELAA site 325, despite the potential together with Blantyre outlined above.

2. East Pembury

Referring to the illustration below, site 375 in green has been approved by TWBC.

Sites 191, 208, 290, 28, 64, 332, 367 are individually remote, accessing only onto unsuitably narrow Woodside Road, and Romford Road for 332.

However, if access is possible between sites 190 and 191 it would be feasible to connect these sites to the others above with a spinal road connecting them all (see the blue line in Figure 10 below).

This also applies to the group comprising 379, 367, 64, 332 (and 458 already approved by TWBC). If they are all available, they could access (see green line) via 458 onto Henwood Green Road.

The total allocation for these sites according to SHELAA documents totals 674 dwellings.

[TWBC: for Figure 10: Draft Proposal for Eastern Pembury sites working in conjunction see full report]

3. Pembury Road, Sandown Park

These sites combined would offer even better access than the eastern Pembury sites to the A21, the A264 and to Tunbridge Wells (via bus, bike and on foot).

4. A21/A264, Tesco Site

In addition, even having dismissed the ‘park and ride’ scheme, the site would still have been ideal for residential purposes for the above reasons.

Instead, the site is in an advanced stage of the planning permission process for a car sales showroom (when there are already more than adequate choices available in this market)

5. Liptraps Lane, near to High Brooms Railway Station

Alternatively, making the most of the 2 ha representing half the area, 50dph would increase the yield to 100 dwellings.

In the lower field alone, three blocks of 50 sqm apartments over 3 floors plus parking at ground level would yield 126 apartments in 0.5ha, a density of 252 dph.

If a second series of apartments were placed in the centre field that would double the yield to 252 dwellings, from an original anticipated number of 60.

6. Former Gasworks in Sandhurst Road

There is more potential on this site however.

7. SHELAA site numbers 57, 101 and 43 (southern part south of woodland) comprising the Colebrook Estate, located north of Longfield Road, east of Kingstanding

Planning permission has been sought for this group of sites, for various commercial proposals, none of which appear to have included residential factors.

This is a large site and ideal for residential purposes for the following reasons:

Infrastructure is in place;
Together they offer a site with access both to Longfield Road and to the A21 directly onto the slip road which makes an ideal entry/exit for traffic for the site, without affecting Longfield
In this prime position adjacent to A21 commuter traffic for north, east, southward directions would not need to affect Tunbridge Wells;

In addition:

Bus service into Tunbridge Wells for local commuters to Tunbridge Wells to the train stations;
Trains to London and the coast from High Brooms Station, within bus / cycle / walking distance;
Large food supermarket within bus / cycle / walking distance
Wide range of other shops and leisure facilities within bus / cycle / walking distance
Tunbridge Wells centre within bus / cycling distance: even walking is not unrealistic at 50
Site 57 has a developable area of 91ha, site 101 6.98ha and the southern part of 43 7.16ha: 32.05ha. At 30 dph that’s 960, at 40 pdh 1200, at 50 dph 1500 dwellings.
With the sloping site the lower parts adjacent to the industrial estate on Kingstanding Way would suit apartments of perhaps six
The visual concerns of a series of tall structures would be not significantly greater than the very visible roofs of the neighbouring industrial

The site actually offers an exciting opportunity for a different type of accommodation which although not common, can be built using conventional methods – a Hybrid Building.

Potential: if the hybrid buildings comprised a row of ten 50 sqm apartments on each of two opposing sides, eight storeys high, each block could provide 160 apartments on a footprint of

50x60m. Two blocks fit in a hectare so 320 dph. 32h available: 10,240 units of fifty sq m apartments.

That’s plenty of room for trees and open space, with the shops and facilities within the building, the car park on the ground floor, so the residents need never get wet while living there.

[TWBC: for Figure 11 and image see full report].

The patios of the apartments would be hung with flower tubs so the overall impression of the building would be of merging with the countryside, hence reducing the visual impact of the building.

This is not a new idea.

Below is the Alt-Erlaa estate in Vienna. Built in the 1970s it is held as an example of a community project that is an outstanding success. People are on waiting lists to live there.

And below is Liuzhou Garden City in Southern China, one of a series of similar projects currently being built around the world.

From a magazine article (2):

(courtesy Science Focus Magazine) [TWBC: for image see full report].

In summary – and as shown below in Figure 12 – the housing potential for these (groups of) sites is over 10,000 units.

Figure 12: Housing Yield for Selected High Potential Sites

Sites	Dwellings (#)				Commentary
Blantyre plus site 325	3,510	At	30	dph
East Pembury group of sites:	674	At TWBC’s figures for each site
Pembury Road, Sandown Park	654	At TWBC’s figures for each site
A21/A264 junction, Tesco site	143	At 30dph: 600 apartments in four storey flats
Liptraps Lane	60	At TWBC’s figures: 126 apartments in four storey flats
Former Gasworks, Sandhurst Road	170	At TWBC’s SHELAA figures for that site. Could be 373 apartments in a mix of flats and housing at TWBCs figures
Colebrook Estate	5,000	Up to 10,000 apartments plus accommodation for businesses, retail, leisure etc. by using the Hibrid Building concept
Total	10,211

The diagram below compares CA1 with these sites relative to nearby transport infrastructure and essential retail outlets.

Figure 13: Proximity to Transport/Retail - Comparison of CA1 and High Potential Sites

[TWBC: for Figure 13 see full report].

Together, and in some cases individually, these high potential sites provide a realistic alternative to building at Capel.

E. Conclusion & Next Steps

In reviewing the Plan and the parts of the borough we have been able to research to date, we have come to the conclusion that there are better alternatives to building at Capel:

Otherwise:

Explore and fully exploit brownfield sites throughout the borough;
Distribute the housing allocation along the A21 corridor at, for example, the eastern end of Pembury, the Pembury Road / Sandown Park area and Colebrook Park;
Maximise potential near to High Brooms station with sites such as the gas works site and playing field;
Ensure that current under-utilised land is developed, such as car parks, building above these to retain the car park itself, for example on the Longfield Road Industrial Estate and the area around the Sainsburys / Homebase area;
Maximise future land usage by eliminating surface car parks, and ensuring that where car parks are built the airspace above is developed too;
Increase density of new-build housing to maximise land efficiency;
Review the design of larger developments to incorporate new concepts to improve living conditions so that residents do not have to experience weather conditions just to go shopping or to their car (i.e. simply a development of shopping malls extended to residential situations);

We propose to continue searching for suitable sites and considering other solutions, but it is felt that rather than being re-active, TWBC should be even more pro-active in its search for these.

[TWBC: for Appendices A-E see full report].

DLP_7258

Mr John Telling

With regard to the proposal for development at Capel (Tudeley and to the west of Paddock Wood); Development would:

1. put enormous pressure on services in Tonbridge;

2. destroy the rural character of this part of the Medway Valley;

3. eat into the Greenbelt, destroying agricultural land and natural habitats;

4. increase flood risk downstream in the Medway Valley;

5. overload the limited road capacity in this area and generate a great increase in vehicle movements.

6. ruin the historic rural setting of Tudeley Church.

DLP_7275

Mrs Katie Lee-Amies

Comments on Section 2 & 3

I object to the proposed Vision and Strategic Objectives, the provisions of STR1 and STR/PW1, AL/PW1, AL/PW2, AL/PW3, AL/PW4, STR/CA1, AL/CA2, AL/CA3, for the reasons explained above [TWBC: See comments DLP_7265-7267]. To summarise:

the evidence base is inadequate and inconsistent,
the evidence base does not support a new settlement allocation in Tudeley,
the growth option 5 development strategy is not justified,
‘exceptional circumstances’ to release Green Belt are not provided – housing need is not an exceptional circumstance,
the strategic site selection process is skewed to favour an area with one landowner,
the AONB setting and High Weald National Character Area are given low priority
The low priority placed on Green Belt, the HW AONB and its setting and the environment conflicts with the high priority placed on the natural environment in the previous Local Plan, the NPPF, Core Strategy 2010, Public Consultation Boards and by local residents,
Grade 2 and grade 3 agricultural land at site CA1 is not acknowledged,
A settlement 3-5km from the nearest town and train station creates unsustainable transport patterns, current residents are predominantly car dependent and current road network is at capacity.
Tudeley Garden Village will harm the landscape character, and have significant impact on long distance and panoramic views of the locality. Green Belt will be released and the HW AONB and its setting will be considerably harmed,
The existing land within site CA1 is undeveloped agricultural land, rich in ecosystems and biodiversity.
There are no existing or proposed transport links to support a new settlement at Tudeley,
The railway divides the proposed new settlement at Tudeley into two settlements, north and south of the railway,
The proposed location for a new secondary school on the Somerhill roundabout is unsustainable. It is too far from any settlement and train station and it will encourage further car-dependency, congestion and air pollution. Children cannot be safeguarded on a school site with a railway line running across it.
The expectation that new cycle paths will attract hundreds of new cyclists away from their cars is unrealistic given the local topography and British weather,
The Climate Emergency should be driving development away from the countryside and focussing on built-up areas and extending settlements – Objective 8 cannot be met with the current Draft Local Plan,
The flood risk will increase in Paddock Wood, East Capel and Tudeley with the loss of hundreds of hectares of woods, trees, hedges and fields,
The setting of 71 Listed buildings in Tudeley, including the Grade 1 Listed Tudeley Church visited by thousands each year, will be harmed by the new settlement and associated infrastructure,
The TWB is too constrained to accommodate the OAN 2014 housing growth and TWBC should challenge the figures,
6,000+ proposed new homes within 5 miles of each other in Paddock Wood and Tudeley is unreasonable and far exceeds TWBC’s evidenced local need. With additional homes proposed at Mabledon Farm/Bidborough, and the loss of Green Belt to proposed quarry sites and existing Solar Farm in Capel parish, the local area will be swamped, unrecognisable and destroyed. Strategic site allocations are being considered in isolation and their cumulative impact is not being assessed or considered,
Increasing the number of homes in a small parish by 500% is unreasonable, unnecessary and unjustified,
A new settlement with 2,500-2,800 homes close to the boundary of TMB warrants consultation with Tonbridge residents. Tonbridge will bear the impact of the development and its infrastructure. A new settlement should not follow the same planning procedure as a development of 10-20 homes. Use some common sense.
Tudeley Garden Village is a vague outline on a plan in the Reg 18 Draft Local Plan. A schematic or zoning diagram indicating transport links, railway crossings, footpaths and green infrastructure should be included for a large new settlement comprising 63% of TWBC’s new homes. Too much information has been held back for the ‘masterplanning phase’ to enable objective assessment. TWBC are seeking comments on an incomplete Draft.

DLP_7488

Colin Leake

I am a local resident who has lived in Five Oak Green for over fifty years and more significantly am a long serving member of the Parish Council Flood Committee.

I would like to make further objections to the plan.

When this plan was first put forward the developer sent a letter to all the residents making the development sound like the Garden of Eden rather that the Lost City of Atlantis which over the long term, taking into the effects of global warming, it is more likely to resemble!

In that letter he stated that steps would be taken to alleviate the problem of flooding in Five Oak Green. As a long-term member of the Parish Flood Committee I well know that there are only two ways to achieve this.

The first option is to ensure that flood water passes through the village to reduce the build-up of water. With the help of the Environment Agency this has been largely achieved. They have taken over control of what was the Alders Stream by upgrading it to a river. The stream is kept clear of vegetation, the grill over the start of the culvert is monitored by a remote camera and kept clear, the culvert has been cleared and relined and the ditches from the culvert outlet are regularly dredged. All this has to a large extent been successful though were we to suffer the sort of rainfall event that has been all to common in other parts of the country it would still be unable to cope.

The second, and only other practical option is to slow the rate of flow by holding back the water before it reaches the village. This was the proposal put forward by the EA. Now we learn that this option will not be adopted and instead are told that steps will be taken on the site of the proposed development to improve the situation in Five Oak Green. This is quite frankly impossible and indeed the development would almost certainly make the situation worse.

It clearly demonstrates how the developer is prepared to back track on his commitments. Clearly he takes the residents for fools and is prepared to treat us with contempt. It’s obvious he cannot be trusted with any aspect of this unnecessary and impractical development.

DLP_7535

William Fisher

I am writing to object to The Strategy for Capel Parish (Policy STR/CA1).

I think that the installation of a garden settlement at Tudeley resulting in 2,800 dwellings will cause immense harm to the residents of the Parish of Capel and to the residents of Tonbridge.

There will be a significant increase in traffic in to Tonbridge from the B2017, exacerbating the extreme traffic congestion that exists on this road every morning. The already unacceptable levels of traffic between 7.45am to 9am on Woodgate Way, Vale Road and Pembury Road coincide with the site of a proposed new 6 form entry senior school to sited next to the Woodgate Way roundabout.

This proposed school will be on the border with Tonbridge, split by a main line railway and alongside a heavily used road. This appears to be a terrible site for a school, surrounded by heavy traffic and requiring children to cross a busy train line to access both sides of the site. It is extraordinary to consider siting a school on a split site that is so close to already overused roads and opposite the entrance to The Schools at Somerhill. I would have serious concerns at the siting of the school in such a location because of the safety issues and the fact that Tonbridge hosts many schools already, all of them of an high standard.

No amount of infrastructure improvements will assist in reducing the already overflowing roads at peak school times in the morning and afternoon if a further 1000+ pupils are heading to and from the school and Tonbridge town and the B2017 to the east. If a second senior school is to be developed as part of the Local Plan a better and more
secure location has to be found. People living in Tudeley will use Tonbridge Station for commuting and Tonbridge services that will need more parking. The increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times and can’t be made wider in most places. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable, especially in view of the plans to build more houses further down the line at Marden, Staplehurst & Headcorn.

In a transport infrastructure study there is shown a new roundabout at the junction of Hartlake Road and Tudeley Road/Crockhurst Street but there is a lack of any proper detail at present on the transport planning for the Tudeley town development. The plan remains incomplete in this critical aspect and that is unacceptable. This appears to be an apparent breach of garden settlement guidance in terms of infrastructure provision and consultation relating to proposed garden settlements.

There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape.

Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saints Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in sight of a big roundabout. It would be an egregious folly to permit the possibility of an enormous housing estate to be built around All Saints Church with consequential bus lanes, roundabouts and an increased road capacity. That will cause great harm to its value as a heritage asset of world renown, due to the crowning jewel of its Marc Chagall windows that are unique to place and setting and represent the only installation of its type in the world. It is one of the most popular Churches in Kent by reference to visitor numbers.

Creating so much housing in Capel 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, including rare species. This area should remain rural with agricultural land that can be used to provide food. The landscape is ancient and Tudeley was listed in the Domesday Book. There appears to be very little thought given to the conservation of the landscape in the area as per the High Weald AONB management principles.

I believe that housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan.

TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Taking 1,216 (the upscale) from the 2,800 planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant. The Green Belt Strategic Study commissioned by TWBC states that building houses at Tudeley and East Capel would cause the maxium level of harm possible to the Green Belt.

DLP_7539

Colin Clarke

I object to “The Strategy for Capel Parish”.

There is no mention of new access to the A21, which means Tudeley village residents will be funnelled westward along Tudeley Road to the A26, putting immense pressure on an already busy roundabout.

Furthermore, none of the council tax revenue from these new homes would support infrastructure in Tonbridge.

These are fundamental flaws in the planning process. TWBC cannot be allowed to make decisions of this magnitude in a vacuum.

Vague and Inaccurate Targets

In addition, the portion of these new homes designated as “affordable” is also unacceptably vague. This country does not need more over-priced housing.

Flooding

Pollution

There will be an increase in air, light and noise pollution that will spread across the boundary into Tonbridge & Malling and create a visual scar across the landscape.

Heritage Assets

Green Belt

No exceptional circumstances have been demonstrated. Housing need is not an exceptional circumstance.

The plan preparation process didn’t include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan didn’t go through most of the plan preparation process. There is no detailed Green Belt Study for these sites, no Landscape Assessment, no Biodiversity Assessment. This version of the draft Local Plan isn’t complete enough to be ready for public consultation when the land for such a big proportion of the housing hasn’t had the same level of assessment as the rest of the plan. The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they didn’t know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was a key priority for people who participated in the Issues and Options consultation. I think that the plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough.

DLP_7546

Helena Fisher

I live at XXX, Tudeley Road, Tudeley, Kent XXX with my family. We have been resident here for over 21 years [TWBC: House number and post code redacted]. I grew up here and have been here for nearly all my life.

I am horrified!

I am writing to object to The Strategy for Capel Parish (Policy STR/CA1).

I think that the installation of a garden settlement at Tudeley resulting in 2,800 dwellings will cause immense harm to the residents of the Parish of Capel and to the residents of Tonbridge.

This proposed school will be on the border with Tonbridge, split by a main line railway and alongside a heavily used road. This appears to be a terrible site for a school, surrounded by heavy traffic and requiring children to cross a busy train line to access both sides of the

site. It is extraordinary to consider siting a school on a split site that is so close to already overused roads and opposite the entrance to The Schools at Somerhill. I would have serious concerns at the siting of the school in such a location because of the safety issues and the fact that Tonbridge hosts many schools already, all of them of an high standard.

No amount of infrastructure improvements will assist in reducing the already overflowing roads at peak school times in the morning and afternoon if a further 1000+ pupils are heading to and from the school and Tonbridge town and the B2017 to the east. If a second senior school is to be developed as part of the Local Plan a better and more

secure location has to be found. People living in Tudeley will use Tonbridge Station for commuting and Tonbridge services that will need more parking. The increase in traffic will be more than Tonbridge can cope with. Its roads are already full at peak times and can’t be made wider in most places. The increased numbers of passengers on already packed commuter trains from Tonbridge Station will be unsustainable, especially in view of the plans to build more houses further down the line at Marden, Staplehurst & Headcorn.

There will be an increase in air, light and noise pollution that will spread across the boundary in to Tonbridge & Malling and create a visual scar across the landscape.

Views from Tonbridge to the Low and High Weald will be impaired, including the setting of historic assets like All Saints Church in Tudeley and the Hadlow Tower. The church at Tudeley may end up being surrounded by houses, bus lanes and sit next to a busy road in

sight of a big roundabout. It would be an egregious folly to permit the possibility of an enormous housing estate to be built around All Saints Church with consequential bus lanes, roundabouts and an increased road capacity. That will cause great harm to its value as a heritage asset of world renown, due to the crowning jewel of its Marc Chagall windows that are unique to place and setting and represent the only installation of its type in the world. It is one of the most popular Churches in Kent by reference to visitor numbers.

Creating so much housing in Capel 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, including rare species. This area should remain rural with agricultural land that can be used to provide food. The landscape is ancient and Tudeley was listed in the Domesday Book. There appears to be very little thought given to the conservation of the landscape in the area as per the High Weald AONB management principles.

I believe that housing need calculated by the government can be reduced if it requires development of Green Belt land unless “exceptional circumstances” exist. I would like to see TWBC use this argument to remove the garden settlement at Tudeley from this plan.

TWBC is already providing more than their housing need figure in the draft Local Plan. TWBC has taken the housing need figure of 13,560 given to them by government and upscaled it to 14,776 despite having strong grounds to lower it due to the large amount of Green Belt and AONB land in the borough. Taking 1,216 (the upscale) from the 2,800

planned for Tudeley and then asking the government to allow the housing need to fall by 1,584 to factor in the lack of “exceptional circumstances” for building on Green Belt land, would be a much better approach. Recent ONS figures show that population growth in the borough is slowing, making this proposed approach honest and relevant. The Green Belt Strategic Study commissioned by TWBC states that building houses at Tudeley and East Capel would cause the maxium level of harm possible to the Green Belt.

The plan preparation process did not include Tudeley (sites CA1 and CA2) until after the Issues and Options Process in 2017. This means that the largest housing area in the plan did not go through most of the plan preparation process. There is no detailed Green Belt

Study for these sites, no Landscape Assessment, no Biodiversity Assessment. I consider that this version of the draft Local Plan isn’t complete enough to be ready for public consultation when the land for such a big proportion of the housing hasn’t had the same level of assessment as the rest of the plan.

The Issues and Options process led to most people (60%) wanting a growth corridor led approach. Less than half wanted a garden settlement and that was when they didn’t know the garden settlement would involve destruction of Green Belt. Protecting Green Belt was

a key priority for people who participated in the Issues and Options consultation. The plan should be re-written to implement a growth corridor led approach and to protect Green Belt land within the borough.

DLP_7554

Richard Fisher

My family currently live at XXX, Tudeley Road, Tudeley, Kent XXX. We have been resident in this attractive hamlet for over 21 years at this address [TWBC: House name and post code redacted].

I am completely appalled by your proposals, which, in my opinion, have the utmost disregard and lack of proper consideration to the character, nature, situation, and historic importance of the settlement of Tudeley and surrounding areas, and also to it’s residents.