Section 5: Place Shaping Policies General Comments

DLP_9

Mr A Richards

I am concerned about the adequacy of infrastructure (i.e. roads, education, health etc.) required to support the proposed increase in housing accommodation.

DLP_154

Linda Barretto

Other Comments: where is the evidence for reasons you cannot build on the many brownbelt areas around Tunbridge Wells everything today has to be evidence based so where is it TWBC?

DLP_379

Jim Kedge

para 5.15  In the light of the abandonment of the Calverley Square project following the Full Council Meeting on 8th October the map covering AL/RTW 1 should be deleted. Any replacement proposal and map should not include the large proportion of Calverley Grounds indicated in the Proposed Site Allocations Policy Boundaries. Most of the land to the east of the Great Hall car park was included in the site in the original proposals for Calverley Square as working space and temporary offices for contractors plus an amount of land for temporary storage of top soil from necessary excavations on the site of the proposed car park. Most of the northern half of the site to the east of the existing park boundary was required for the construction of this underground structure. This will not now be required.

The relevant boundaries for any proposals should be limited to the Mount Pleasant Avenue surface car park and the Great Hall Car Park. Any proposal should not encroach into Calverley Grounds nor should it require the felling of trees currently within the boundary of Calverley Grounds.

para 5.16 Given the decision of the Full Council the 'allocation (will need to be) reviewed and potentially amended ....' Yes it should be.

The car park strategy TP4 requires, in effect, that if Calverley Square is abandoned then both the Great Hall and Mount Pleasant Avenue car parks be retained (see para 5.14). The allocation of the Mount Pleasant Avenue Car park for B1 and A2 use in the 2016 Site Allocations Plan should not be carried forward into the new Local Plan.

In the words of para 5.16 it is suggested, perhaps implicitly, that the Planning Permission for the site released by the abandonment of Calverley Square can be used as a reference for future proposals for the site. This is surely a misjudgement. The existing Planning Permission was granted for the whole development as a single entity. This was done partly to allow the harm being done to Calverley Grounds to be justified by economic and community benefits to the Borough emanating from the whole development considered as one project. Any future proposals would need to stand on their own merits.

paras 6.172-6.199 The policies EN17 Local Green Spaces and EN18 Landscape within the Built Environment do not specifically mention the large town centre parks and commons by name. This is a weakness in the Plan. The paragraph seems to suggest that these green spaces are sufficiently well protected so as not to need any specific policies or statements by way of protection. In 2018 this assumption was tested to destruction when Planning Permission was given to build on part of Calverley Grounds. A judgement was made that..'no significant harm would be caused..'  This was a subjective assessment. In order to eliminate the risk to our parks in the future I suggest that the large parks ( Dunorlan, Grosvenor and Hilbert, and Calverley Grounds) should be totally protected to the extent that no development will be allowed under any circumstances. This should be written into the Local Plan. The granting of Planning Permission was also at odds with the Green Infrastructure Guidance which asks for the protection and enhancement of Green Infrastructure assets. Building on and under Calverley Grounds is at odds with this guidance,

DLP_499

Robert Atwood

I wish to make a general comment concerning Section 5 - Place shaping policies.

It appears that a very considerable proportion of the entire housing target for the Borough has been allocated to Capel, Tudely and Paddock Wood including the creation of an entirely new "garden village".  This would seem to be a very high risk strategy with a strong liklihood that all or substantial elements of these allocations will be rejected by the Inspector at Public Enquiry.  Should this happen, there is likely to be a free for all scramble for sites drawn from those submitted but currently rejected, which the Council will have great difficulty in controlling.  With this in mind, it could be said that there is no sustainable strategy or immediate land supply.and that the entire Local Plan is substantially flawed.

DLP_713

Gerald Ellard

capel parish also paddock wood

green belt is and should stay green belt. it was designated so for a reason and should be kept as such.  there are many town centre sites which can be built on, high rise if neccessary

DLP_1587

Mrs S Sheldrake

I object to so many large areas of new houses on farm land,

I particularly object to so many houses being allocated to Capel and to Tudeley.

also i object to the Dandara Sprattsbrook  plans, the Eridge Road does not seem right for a school-- Sprattsbrook is in East Sussex anyway,

does the council know how many houses are empty in TW?or underoccupied--- i.e one person in a 3 or4 bedroomed house?And are efforts being made to teach English to the many many mothers who take their children to local schools here but do not speak English?

DLP_1630

Ms Nicola Gooch

AL/RTW 27, AL/CA 1, AL/CA 3, AL/CRS 4,

AL/RTW 27

I wholeheartedly support this allocation, which is progressing well. It might be worth considering increasing the number of allocated dwellings, given the recent planning application for additional units. Please can you push KCC to provide a two form entry school as part of this allocation - there is a strong demand for primary school places in this part of Tunbridge Wells and it would be helpful to have expanded provision at St Peters - particularly as Claremont is oversubscribed.

AL/CA1

Tunbridge Wells is highly constrained, with large parts of the borough covered by either the High Weald AONB or Metropolitan Green Belt - so there are limited opportunities for development of the scale required to meet the growing housing needs of the borough.

This new Garden Village would be well connected and the provision of a new settlement would also allow for significant improvements to local infrastructure. There is also a lot to be said for taking a holistic approach to planning for housing delivery - starting from the ground up gives a real opportunity to build a properly functioning, sustainable, community, which is a rare prospect these days.

The new village will need to be carefully masterplanned, following Garden Village principles, and accompanied by signficant infrastructure investment, but it has the opportunity to be something really special. It would also make a significant contribution to the Borough's housing land supply.

AL/CA3

The proposed extension of Paddock Wood is extremely sensible. It is one of the few areas of the borough that can absorb the proposed number of additional homes relatively well, from a spatial planning perspective. There will be significant challenges in bringing forward such a transformational allocation; but if it is well master-planned and supported with strong infrastructure delivery and an integrated, holistic, approach to delivering that the additional roads, jobs and services required to support the housing numbers it will be worth the effort involved. Given the likely need for the use of CPO powers to delivery this allocation - I would recommend excluding it from the policy on two year implementation periods for planning consents that is included in section 6 of the plan.

AL/CRS4

Turnden Farm has the potential to operate extremely well as a functional extension to Cranbrook, as well as providing improvements and enhancements to the public rights of way network and local biodiversity. If it were possible to increase the densities of this allocation and the two other larger allocations in Cranbrook a little (perhaps by another 10 to 20 units) this would take the pressure off the smaller sites and allow a more strategic approach to be taken to growth in the village.

AL/HA1

Hawkhurst Golf Course is a very sensible location for strategic growth; properly designed a residential development here would fit very naturally with the wider settlement and would offer opportunities to secure enhancements to the wooded areas and habitats, which are currently of fairly low ecological value considering the location. Concentrating housing growth on sites such as this, where it can be properly and holistically planned, will reduce the need for in-fill or 'garden grabbing' developments which when viewed cumulatively can pose a greater threat to the character of the area.

TWBC: the above comments have also been placed against the relevant site allocation policies.

DLP_1770

Mr Raymond Moon

Section 5: Place Shaping Policies

Policy STR/CA1 OBJECT.

It is important to understand that the proposed houses in Capel and Paddock Wood will affect the infrastructure of Capel & PW and could have a major impact on both areas with shared services. The proposed new development in Capel & Paddock Wood should be joined up in the Masterplan and not be to detriment of either area.

Policy STR/PW 1 OBJECT. 

The Strategy for Paddock Wood

1. The number of 4,000 houses allocated for PW is not represented in the individual sites so how was this number derived at in the Draft Plan? More detail should be provided in the Draft Plan. Also the allocation is predominately in high risk flooding areas and with mitigation against flooding the cost of the houses build will be high and potentially reduce the amount of 106 monies available for infrastructure improvements.

Masterplanning & Delivery & Flooding.

A major concern of PW residents is the threat of increased surface water flooding and foul water flooding in PW. The Masterplan must deliver the required infrastructure to cope with the new houses with real proposals and TWBC commitment to ensure that happens. This issue should be mentioned in stronger terms in the Draft Plan. All of the proposed houses will have their own impact on the infrastructure and on the other houses proposed in the Draft Plan. The Masterplan must have a joined up strategy to deliver these houses without failures within the proposed infrastructure.

Transport.

It is essential that the new ring/access roads required are built from the East of PW to the North and to the West via Eastlands. More detail must be included in this section of the draft plan.

Infrastructure.

Many infrastructure areas are mentioned but again there is lack of detail in the Draft Plan. Who’s is going to provide these improvements and where is the Capital Expenditure coming from?

Policy AL/PW 1 OBJECT.

Land at Capel and Paddock Wood. Allocation Policy.

This policy outlines the proposal of 4,000 new homes within 12 parcels of land from PW1-1 to PW1-12.

The allocation of the type of houses should have more emphasis on the provision of Social Housing and Affordable housing along with the allocation of more “ Bungalow” type houses. Data should be included to confirm that these types of housing are required in the Draft Plan. There is also a lack of rented flat accommodation in PW for single parents.

The provision of a new medical centre is dependent on the provision of new GP’s and no indication this demand can be met in the Draft Plan.

Housing based on Social care provision is lacking in the Draft plan.

No mention made to provision of charging facilities for electric cars in the future within the proposed new houses.

All of the proposed development must have the key qualities listed but no real detail in the submission and again who will enforce and provide these key qualities? Fine words in the document but no real process for delivery. Obviously a major issue to be addressed within the Masterplan.

Land allocation Parcels.

PW1-1.Parcel 1. Whetsted wood is included in this parcel and over the years has declined due to the lack of woodland management. To provide an healthy environment for wildlife and the woodland it should be protected within the Draft Plan and potentially managed by PWTC and local residents. The Parcel needs to be protected with a sound management plan and a clear buffer zone of no less than 100 metres to any potential development.

Historically this area has flooded in the past and incudes Flood Zone 3 and 2. Flooding mitigation should be implemented with in the draft Plan for any new houses and is likely to increase the costs of the new houses.

Improvements to the Eastlands track could be reallocated and improved to serve any potential development in this parcel. Access to the area should not be via the Maidstone road running through PW.

PW1-2 Parcel 2. Whetsted wood by being North of the railway has fared better over the years as natural woodland and in this Parcel needs to be protected with a sound management plan and a clear buffer zone of no less than 100 metres to any potential development.

Historically this area has flooded in the past and incudes Flood Zone 3 and 2. Flooding mitigation should be implemented within the draft Plan for any new houses and is likely to increase the costs of the new houses.

PW1-3 Parcel 3. The allocation within the draft plan includes mention of the Neighbourhood Plan and allocation of a Sports Hub. This area in the past has flooded and if it includes outside sports facilities on the same location they will be liable to flooding and not full use. The location will also increase traffic on the Maidstone for residents accessing the Hub South of the railway line and bridge. The Neighbourhood Plan has not yet been agreed so allocation of the Sports Hub within the Draft Plan should include another area South of the railway line and within the area of the proposed 4,000 new houses. For this reason the site is not suitable for new residential housing.

PW1-4 Parcel 4. The area within the parcel incorporating Nursey Road has a history of significant surface water flooding. Any new development in this parcel would have a major impact on the exiting access to Nursey road and Eldon Way business estate. Access to this area should only be contemplated if a new roundabout is provided at the entrance to Transfesa Industrial Estate and a new access road to any new development in this parcel. The area is only really suited for new Business development in the town and not residential housing.

PW1-5 Parcel 5.

This area incorporating Lucks Lane off the Maidstone road and is totally unsuited for residential development as the land regularly has surface water flooding with evidence from the Lambert & Foster Auctions that take place on the surrounding field where there is always flooding. New Business development in this location should be considered. Lucks lane is not suitable at present for increased traffic movements and would required major road improvements if new development is allowed.

PW1-6 Parcel 6.

This allocation is not clear what type of development is required and where the new houses may be located in the parcel. The site is close to high density Business units and would be subject to disturbance form the site in the form of noise and light pollution. Road access to this parcel would be costly as a access new road would be required.

PW1-7. Parcel 7.

There are many similar problems within this parcel as with the other parcels concerning surface water flooding. This area should also incorporate a new sewage ring main around PW and should be part of the Masterplan.

PW1-8. Parcel 8.

This area lends itself to be an inbuilt wildlife and natural green open space to the new build proposed for PW. It would maintain the status of PW and not merge into the surrounding hamlets and parish.

PW1-9. Parcel 9.

This parcel seems an odd allocation as there is no natural rounding off with any existing residential area in PW. It could link up with parcels 7 & 8 but still does not fit into the overall picture of PW.

PW1-10. Parcel 10.

This parcel is liable to flooding and lies below the level of the road and will prone to flooding if it is developed.

PW1-11. Parcel 11.

Again this parcel has no natural rounding off with existing housing in PW and is located some distance from the town centre and any new residents would find it tempting to use a car and not walk to the town centre. This would again make parking in PW more difficult and cause disruption to existing residents in the street around the town centre.

PW1-12. Parcel 12.

This parcel once again is not expressing any natural rounding off from the existing housing in PW and has the same problems of access to the town centre. There appears to be no allocation of any small retail areas beyond the town centre to serve this parcel and others in the area.

Policy AL/PW 2 OBJECT.

Paddock Wood Town Centre

At present the town centre would be unable to cope with the increased footfall of 4,000 new homes. There is derelict land behind Barsleys and been so for many years and not developed. This area needs to be developed with a mix of new house/flats and new retail outlets and the introduction of a pedestrianised area between the two car parks and the war memorial. This should form part of the Masterplan. Any new development should “ fit” into the present allocation of residential and business property’s.

Policy AL/PW 3 OBJECT.

Land at Mascalls Farm

This appears to be an additional allocation of the agreed new development on the Badsell road of 300 new houses but with 115 additional new houses. This extra number of houses should be rejected in the Draft Plan as per the previous objections to the site at the Inspectors Enquiry for the original 900 new houses in PW.

TWBC: comments have also been entered against individual site allocations.

DLP_2018

Dr David Parrish

Allocation Policies

Section 5 Paragraph 5.60 (Allocation Policies) p.159

The Main Railway Line runs through the CA/1 site – and will prevent effective design and layout of a garden village at the proposed site.

This site is unsuitable for a garden settlement because it has a main railway line running through the middle of it. No amount of crossings can join the garden settlement in to one settlement. It is two settlements divided by a railway line, neither of which satisfy garden settlement principles.

The LP states that this site is under single ownership. This appears to be the overriding factor in its selection as a site for a large development. The landowner has a very poor track record maintaining leased properties and leasing land out for quarrying, abandoning it to become derelict, contaminated land. Not developing it further as a Leisure Centre (Wetlands) as promised at the planning stage? They are not suitable partners for master planning (regardless of the number and nature of agents they employ) and the subsequent development of the site. Nobody in this community trusts them. No-one has had any positive form of engagement with them since the development was disclosed. They appear to be evicting tenants to sell houses to pay their master planners and/or make way for link roads.

There is no clear plan for Flooding Risk

Development on the site will adversely affect flood risks in Tudeley and neighbouring Golden Green, East Peckham, Hadlow and Tonbridge. The River Medway is rising. The rapid increase in sea levels and other Climate Change factors have not been fully considered. The Five Oak Green flood risk will be reduced by damming the Alders Stream, not by building thousands of houses. This can be delivered and funded independently of the garden settlement.

DLP_2059

Canterbury Diocesan Board of Finance Ltd

Section 5: Para 5.70- 5.91

The omission of the current housing site allocation at Cranbrook Vicarage cannot be justified having regard to the principles of sustainable development as set out in the National Planning Policy Framework. The existing housing allocation should be maintained to reflect the sustainability credentials of the locality which are vastly superior to some of the Draft allocations which lie in open countryside remote from community services and facilities and public transport provision.

DLP_2346

Sarah Coulstock

There is too much development in the Local Plan for a rural area with much of it in AONB – TWBC should challenge the housing target it has been given in view of this & get it reduced.

The number of new dwellings proposed for the parish of Brenchley & Matfield is too high. All of proposed development is in Matfield – Brenchley should share the burden & take at least half, especially as has a school, 2 shops, a post office, a doctor’s surgery & a dentist.

The Limits to Build Development should not be changed; it should be strengthened to prevent or severely restrict any more intrusive inappropriate development within the Parish. The dark skies, wildlife, landscape & rural character need to protected against the destruction of the surrounding countryside & the detrimental impact on the High Weald AONB. The amount of development suggested in the AONB is contrary to the objectives of the High Weald AONB Management Plan & the TWBC’s statutory duty to conserve & enhance the High Weald AONB.

The proposed extra housing would put additional pressure on already stretched infrastructure & services, both within the parish of Brenchley & Matfield, & in the borough. I understood that TWBC had previously favoured focused growth in sustainable locations, however, the Local Plan is for dispersed growth in places with poor infrastructure & facilities, which are therefore not sustainable.

The proportional development distribution proposed in the Local Plan is unfairly distributed, with some areas expected to suffer a higher volume of development than is appropriate.

DLP_2488

Mr John Wotton

Policies STR/CA 1 and AL/CA 1 Capel Parish and "Tudeley Village"

I object to these policies, which provide for a new settlement of 2,500-2,800 new homes on greenfield sites in the Green Belt, misleadingly named "Tudeley Village", for the reasons given by CPRE Kent in their response to this consultation. I have visited the sites, had detailed discussions with the Save Capel campaign group and spoken at a public meeting which they convened. I support their objections to this proposed development.

Policy STR/CRS 1 The Strategy for Cranbrook and Sissinghurst Parish

I object to this policy. Cranbrook & Sissinghurst Parish has a number of characteristics which militate against significant growth in population or employment. Cranbrook lies wholly within the AONB. It is a town of immeasurable historic and architectural interest, replete with listed buildings and other heritage assets and having an important Conservation Area at its historic core. As the Conservation Area assessment recognises, the rural setting of the town contributes greatly to its interest and importance. It is a small town with narrow streets, both features which contribute to its architectural interest and to its attraction as a place to live and a destination for visitors, who contribute to the local economy.

In addition to the historic core of the town, there are nearby settlements in the Parish of great architectural and historic interest, notably Sissinghurst and Wilsley, each of which contains a Conservation Area, the rural setting of which merits protection. Elsewhere in the Parish, both inside and outside the AONB, are small settlements, such as Collier's Green and Hartley and isolated farmsteads, all reflecting the historically dispersed settlement pattern of this part of the High Weald. Throughout the Parish are traces of the field boundaries of the medieval farming landscape, which is I understand better preserved in the High Weald AONB than anywhere else in the country.

Having regard to these considerations, growth in Cranbrook & Sissinghurst Parish should be limited to well-designed, small scale developments, either (i) on brownfield sites within existing LBDs, (ii) on sustainable greenfield sites well-related to existing settlements; or (iii) on existing historic farmsteads in sustainable locations and in accordance with the Council's policies on farmstead developments. No such development should harm the AONB or any of the Conservation Areas in the Parish.

No major development site in the AONB should be allocated in the Parish. The tests of exceptional circumstances and public interest under paragraph 172 NPPF, which must be met for any such developments to be permitted, are not satisfied. My reasons for reaching this conclusion are set out in my comments on the Distribution of Development Topic Paper

This approach would require a much lower housing allocation than the 713-803 new homes provided in this Policy. I consider that it requires a lower allocation than the 612 new homes estimated by consultants retained by the NDP Group. Neither level of expansion of Cranbrook & Sissinghurst could be achieved, making use of the sites put forward for development, without (1) permitting a number of major developments within the AONB, for which no exceptional circumstances exist and on sites with a negative sustainability assessment; and/or (2) allowing some or all of the distinct settlements of Cranbrook, Wilsley, Sissinghurst and Hartley to coalesce and thereby prejudice the historic settlement pattern of this part of the AONB.

I support the comments made by CPRE Kent on Local Plan Policies relating to the Parish and those made by the High Weald AONB Unit. I support the general approach taken by the Cranbrook & Sissinghurst NDP Group to development in the Parish, though not necessarily all the allocations they propose.

I declare interests as a member of the Cranbrook Conservaion Areas Advisory Committee and a Trustee of Cranbrook School. I do not comment on any allocation policies affecting land owned by Cranbrook School Trust or Cranbrook School..

AL/CRS 4 Turnden

Object

This would be a major development within the AONB (see Distribution of Development Topic Paper (“DDTP”), para 6.35) of 160-170 new homes (of which 36 already have permission). It is a greenfield site (apart from the area which is subject to an existing permission) and is outside the LBD. There are no exceptional circumstances within the meaning of NPPF 172 which would justify this development. Together with policy AL/CRS 9 (carried forward from the existing plan) this development would eliminate the green gap between Cranbrook and Hartley, thereby obliterating and historic distinct settlement pattern. The site has a highly negative sustainability score (particularly on environmental grounds. I oppose this policy and consider that no development should be permitted on this site in addition to the 36 new homes already permitted on brownfield land.

AL/CRS 6 Gate Farm, Hartley

Object

This would be a major development within AONB (see DDTP, para 6.35) of 90 new homes. The three sites allocated under this policy are partly greenfield and outside the LBD. There are no exceptional circumstances within NPPF 172 justifying the major development on these sites, which are prominent within the AONB landscape. They would constitute an extension to the existing settlement of Hartley, where there are limited shopping facilities (a farm shop, fishmonger and café). It is a long walk to Cranbrook town centre from the sites and, although the sites are on a bus route, it is likely that most daily trips from the sites would be made by car. We note that the policy has a mixed sustainability score. The sites are also close to Robin’s Wood SSSI and would lead to the loss of some best and most versatile farmland. I oppose major development on these sites.

AL/CRS 7 Land off Golford Road

Object

This would be a major development within AONB (see Distribution of Development Topic Papaer, para 6.35) of 150 new homes, on a greenfield site outside the LBD. No exceptional circumstances within NPPF 172 justify this policy. The site is detached from the existing settlement (Cranbrook) and is poorly related to it. It is partly in Flood Risk Zone 3. I oppose this policy, as it would represent a substantial eastward extension of Cranbrook into protected AONB countryside.

AL/CRS 9 Land adjacent to Crane Valley (includes Brick Kiln Farm and Corn Hall Oast)

The sites allocated by this policy are already allocated for residential development in the existing plan and are allocated under the present draft plan for 200-250 homes. My home is on the opposite side of Angley Road to the development. Outline planning permission for 180 homes on Brick Kiln Farm has been sought, but not yet granted. This would represent a major development in the AONB, on mostly greenfield land and outside the LBD. Because the sites were allocated previously, they have not been assessed for sustainability for the purposes of the present draft plan. I recall that the sustainability assessment previously undertaken was negative, particularly on environmental to a greater extent than some sites not allocated under the current plan. There are no exceptional circumstances within NPPF 172 justifying this policy. Taken together with policy AL/CRS 4, this policy would eliminate the green gap between Cranbrook and Hartley, thereby obliterating historic distinct settlement patterns.

I objected to the inclusion of this policy in the current Plan and continue to object to it. I consider that the harm it would cause to the AONB landscape and to the setting of heritage assets, including my home, Goddards Green, were underestimated when the current policy was adopted. The harm is especially marked when looking at the view north west across the Crane Valley from the public footpath between Mount Ephraim and Charity Farm. The should be reassessed substantively in current circumstances, having regard to heightened concerns about sustainability in the light of the climate emergency, continuing loss of biodiversity and the other sites put forward under the call for Sites. Should the allocation under this policy be carried forward, however, a substantial green space between any housing development and Hartley Road must be a requirement, as it is under the current plan, on grounds of impact on the AONB and effect on nearby heritage assets.

AL/CRS 13 Land east of Camden Lodge, adjacent to Mill Lane

Object

This development of 40 new homes would be on a greenfield site outside the LBD and adjoining the AONB boundary. I object to this policy on grounds of harm to the setting of the AONB and the reduction it causes to the green gap between Sissinghurst and Wilsley, thereby blurring distinct, historic settlement patterns.

STR/HA 1 Strategy for Hawkhurst Parish and allocation policies for Hawkhurst

I object to this policy to the extent that it provides for major development within the AONB, on the grounds that the tests for such development under paragrpah 172 NPPF are not satisfied (see my comments on the Distribution of Development Topic Paper). I also object to each of the allocation policies for Hawkhurst which would constitute such major development.

TWBC: these comments have also been entered against individual site allocations

DLP_2695

St. John's Road Residents association

In paragraph 5.7, mitigation of transport impact from new development is mentioned. In practice this will prove very difficult to achieve to the required extent in the case of major developments. Mentioned is the failure of mitigation policy in relation to the Berkeley Homes site at Hawkenbury., It requires a more robust policy in the new Local Plan to improve on the present lack of effective mitigation on major development.

Paragraph 5.9 will have to be redrafted in the light of the political decision not to proceed with the Calverley Square development.  We would prefer to see this paragraph deleted so that there is no possiblility of continuance of development of the Calverley Square project with its threat to the integrity of the Calverley Grounds boundaries, entrance and existing buildings and trees.

DLP_2727

Paddock Wood Labour Party

Section 5: Place Shaping Policies

Policy STR/CA1

It is important to understand that the proposed houses in Capel and Paddock Wood will affect the infrastructure of Capel & PW and could have a major impact on both areas with shared services. The proposed new development in Capel & Paddock Wood should be joined up in the Masterplan and not be to detriment of either area.

Policy STR/PW 1 OBJECT.

The Strategy for Paddock Wood

Transport

Additional development proposed under the Local Plan places greater strain on existing infrastructure so it is crucial that there is a focus on making substantial investment in sustainable transport options including walking and cycling. The plan should be more aspirational in trying to reduce dependency on the car, particularly in central locations where public transport links can be improved with reliability, frequency and cost. Greater investment is needed in infrastructure to encourage cycling and encourage a shift away from modes of transport that cause congestion and air pollution.

1. The number of 4,000 houses allocated for PW is not represented in the individual sites so how was this number derived at in the Draft Plan? More detail should be provided in the Draft Plan. Also the allocation is predominately in high risk flooding areas and with mitigation against flooding the cost of the houses build will be high and potentially reduce the amount of 106 monies available for infrastructure improvements.

Masterplanning & Delivery & Flooding.

A major concern of PW residents is the threat of increased surface water flooding and foul water flooding in PW. The Masterplan must deliver the required infrastructure to cope with the new houses with real proposals and TWBC commitment to ensure that happens. This issue should be mentioned in stronger terms in the Draft Plan. All of the proposed houses will have their own impact on the infrastructure and on the other houses proposed in the Draft Plan. The Masterplan must have a joined up strategy to deliver these houses without failures within the proposed infrastructure.

Transport.

It is essential that the new ring/access roads required are built from the East of PW to the North and to the West via Eastlands. More detail must be included in this section of the draft plan.

Infrastructure.

Many infrastructure areas are mentioned but again there is lack of detail in the Draft Plan. Who’s is going to provide these improvements and where is the Capital Expenditure coming from?

Policy AL/PW 1 OBJECT.

Land at Capel and Paddock Wood. Allocation Policy.

This policy outlines the proposal of 4,000 new homes within 12 parcels of land from PW1-1 to PW1-12.

The allocation of the type of houses should have more emphasis on the provision of Social Housing and Affordable housing along with the allocation of more “ Bungalow” type houses. Data should be included to confirm that these types of housing are required in the Draft Plan. There is also a lack of rented flat accommodation in PW for single parents.

The provision of a new medical centre is dependent on the provision of new GP’s and no indication this demand can be met in the Draft Plan.

Housing based on Social care provision is lacking in the Draft plan.

No mention made to provision of charging facilities for electric cars in the future within the proposed new houses.

All of the proposed development must have the key qualities listed but no real detail in the submission and again who will enforce and provide these key qualities? Fine words in the document but no real process for delivery. Obviously a major issue to be addressed within the Masterplan.

Land allocation Parcels.

PW1-1.Parcel 1. Whetsted wood is included in this parcel and over the years has declined due to the lack of woodland management. To provide an healthy environment for wildlife and the woodland it should be protected within the Draft Plan and potentially managed by PWTC and local residents. The Parcel needs to be protected with a sound management plan and a clear buffer zone of no less than 100 metres to any potential development.

Historically this area has flooded in the past and incudes Flood Zone 3 and 2. Flooding mitigation should be implemented with in the draft Plan for any new houses and is likely to increase the costs of the new houses.

Improvements to the Eastlands track could be reallocated and improved to serve any potential development in this parcel. Access to the area should not be via the Maidstone road running through PW.

PW1-2 Parcel 2. Whetsted wood by being North of the railway has fared better over the years as natural woodland and in this Parcel needs to be protected with a sound management plan and a clear buffer zone of no less than 100 metres to any potential development.

Historically this area has flooded in the past and incudes Flood Zone 3 and 2. Flooding mitigation should be implemented within the draft Plan for any new houses and is likely to increase the costs of the new houses.

PW1-3 Parcel 3.

PWLP is supportive of the provision of new sport and recreation facilities in Paddock Wood but the location of a sports hub must be sustainable and support all of the community. The present location North of the railway needs to be looked at in regard to access from the Maidstone road and suitability of the Outfield facilities in an historical flood area. Other options South of the railway should be considered.

The allocation within the draft plan includes mention of the Neighbourhood Plan and allocation of a Sports Hub. This area in the past has flooded and if it includes outside sports facilities on the same location they will be liable to flooding and not full use. The location will also increase traffic on the Maidstone for residents accessing the Hub South of the railway line and bridge. The Neighbourhood Plan has not yet been agreed so allocation of the Sports Hub within the Draft Plan should include another area South of the railway line and within the area of the proposed 4,000 new houses. For this reason the site is not suitable for new residential housing.

PW1-4 Parcel 4. The area within the parcel incorporating Nursey Road has a history of significant surface water flooding. Any new development in this parcel would have a major impact on the exiting access to Nursey road and Eldon Way business estate. Access to this area should only be contemplated if a new roundabout is provided at the entrance to Transfesa Industrial Estate and a new access road to any new development in this parcel. The area is only really suited for new Business development in the town and not residential housing.

PW1-5 Parcel 5.

This area incorporating Lucks Lane off the Maidstone road and is totally unsuited for residential development as the land regularly has surface water flooding with evidence from the Lambert & Foster Auctions that take place on the surrounding field where there is always flooding. New Business development in this location should be considered. Lucks lane is not suitable at present for increased traffic movements and would required major road improvements if new development is allowed.

PW1-6 Parcel 6.

This allocation is not clear what type of development is required and where the new houses may be located in the parcel. The site is close to high density Business units and would be subject to disturbance form the site in the form of noise and light pollution. Road access to this parcel would be costly as a access new road would be required.

PW1-7. Parcel 7.

There are many similar problems within this parcel as with the other parcels concerning surface water flooding. This area should also incorporate a new sewage ring main around PW and should be part of the Masterplan.

PW1-8. Parcel 8.

This area lends itself to be an inbuilt wildlife and natural green open space to the new build proposed for PW. It would maintain the status of PW and not merge into the surrounding hamlets and parish.

PW1-9. Parcel 9.

This parcel seems an odd allocation as there is no natural rounding off with any existing residential area in PW. It could link up with parcels 7 & 8 but still does not fit into the overall picture of PW.

PW1-10. Parcel 10.

This parcel is liable to flooding and lies below the level of the road and will prone to flooding if it is developed.

PW1-11. Parcel 11.

Again this parcel has no natural rounding off with existing housing in PW and is located some distance from the town centre and any new residents would find it tempting to use a car and not walk to the town centre. This would again make parking in PW more difficult and cause disruption to existing residents in the street around the town centre.

PW1-12. Parcel 12.

This parcel once again is not expressing any natural rounding off from the existing housing in PW and has the same problems of access to the town centre. There appears to be no allocation of any small retail areas beyond the town centre to serve this parcel and others in the area.

Policy AL/PW 2 OBJECT.

Paddock Wood Town Centre

PWLP welcomes provisions in the plan to revitalise town centres by allowing greater concentration of residential accommodation alongside a retail offer which is protected from conversion to non-retail. We support use of Article 4 Direction (A4D) as part of planning legislation which allows the Council to remove permitted development rights to protect and enhance the integrity of the retail offer in the Borough.

Development should be default mixed tenure with social rent and intermediate housing alongside full market priced housing.

At present the town centre would be unable to cope with the increased footfall of 4,000 new homes. There is derelict land behind Barsleys and been so for many years and not developed. This area needs to be developed with a mix of new house/flats and new retail outlets and the introduction of a pedestrianised area between the two car parks and the war memorial. This should form part of the Masterplan. Any new development should “ fit” into the present allocation of residential and business property’s.

Policy AL/PW 3 OBJECT.

Land at Mascalls Farm

This appears to be an additional allocation of the agreed new development on the Badsell road of 300 new houses but with 115 additional new houses. This extra number of houses should be rejected in the Draft Plan as per the previous objections to the site at the Inspectors Enquiry for the original 900 new houses in PW.

TWBC: these comments have also been entered against individual site allocations

DLP_2840

Helen Parrish

Para 5.6 Allocation Policies

Cross-referenced, detailed, reasons for my Objection:

The Main Railway Line runs through the CA/1 site – and will prevent effective design and layout of a garden village at the proposed site.

There is no clear plan for Flooding Risk

DLP_3179

Kent County Council (Growth, Environment and Transport)

Provision and Delivery of County Council Community Services

Changing Places Where developments include community/village hall/sports hall provision by developers, KCC would welcome the inclusion of facilities for disabled users to meet the Changing Places specification.

This can be found at: http://www.changing-places.org/

Youth services

The County Council notes the absence of references to youth services. There is a county wide need to make appropriate consideration for Youth Services, no less so in Tunbridge Wells – and youth services should clearly be seen as an essential element of the sustainable mix of community services. In general terms, there is a ‘need for additional resources for youth services’. In order to provide this service, s106 funding is much more usefully used to provide staffing/youth workers rather than capital for buildings as this is the way the Youth Service is now orientated.

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

Heritage Conservation

The County Council has carried out an initial appraisal of sites within the Draft Local Plan considering conservation matters.

The Preliminary Archaeological Assessment has been undertaken primarily from readily available resources held by the Kent County Council Historic Environment Record, including early OS maps, aerial photographs and British Geological Society data. It is not a detailed appraisal but merely provides a broad initial view on the sensitivity of the archaeological resource and the way in which this should be approached for each of the options. The sensitivity of particular sites may change following more detailed appraisal and in light of new information. The process of assessment will be reviewed and refined as the Local Development Framework process continues.

For each site, preliminary archaeological data, scale and notes are considered

A crude 5 point scale has been used to rank the options with regard to archaeology. This is:

Scale

1. Development of this site (or part of) should be avoided
2. Pre-determination assessment should be carried out to clarify whether development of any part of the site is possible.
3. Significant archaeology could be dealt with through suitable conditions on a planning approval.
4. Low level archaeology anticipated which could be dealt with through suitable conditions on a planning approval.
5. No known archaeological potential on the site or part of it.

Note that for each described site several ‘Scales’ may be noted reflecting the varying potential across the site. For consideration of the site as a whole the lowest numerical ‘Scale’, i.e. that with the highest archaeological sensitivity, has been used.

There are some sites which have major or sensitive archaeological issues. There are also some allocations for which KCC recommends either withdrawal on heritage grounds or that any decision for allocation needs to be supported by an Archaeological Deskbased Assessment (DBA). These sites include:

AL/RTW 18 Land to the west of Eridge Road at Spratsbrook Farm Site Number 137

This allocation site contains the designated heritage asset of High Rocks hillfort; a Scheduled Monument of Iron Age date. The Scheduled Ancient Monument boundary focuses on the hillfort earthworks themselves but there is also high potential for associated remains to survive adjacent. In accordance with NPPF, there should be no impact on designated heritage assets and as such I recommend that this scheme is removed from allocations. If it is decided to proceed with decision to allocate, KCC recommends Historic England is consulted and a full Archaeological DBA is essential prior to finalising the decision.

AL/RTW 6 Part of SALP AL/RTW 2A and Site Number 264 The Civic Complex - The Town Hall, Assembly Hall, and Police Station

This Site contains three designated heritage assets and Grade II listed buildings, therefore careful consideration of conservation issues is required, and advice should be sought from the relevant Conservation Officer. Archaeological issues are considered minimal, but if any groundworks some potential for post medieval.

Tudeley Village: STR/CA 1 The Strategy for Capel Parish

Prior to allocation, this site requires a full Archaeological, Archaeological Landscape and Historic Building Assessment and a Geophysical Survey to locate any industrial remains close to All Saints Church Tudeley. There is high potential for significant archaeology to survive on this site, some of which may need to be preserved in situ. In addition, the impact on the historic settlement pattern of this area of Capel could be highly negative. The historic landscape in this area is complex and rural and the wider impacts of this scheme need to be thoroughly considered prior to any decision on allocation made.

AL/CA 3 Land at Capel and Paddock Wood and AL/PW 1 Land at Capel and Paddock Wood Site Numbers 142, 309, 310, 311, 312, 313, 314, 316, 317, 318, 319, 51,315, 402, 340, 347, 218, 220, 374, 79, 47, late site 26, 371, 344, 376, 212, 342

Although this allocation site surrounds the existing modern town of Paddock Wood, it could have a major negative impact on the surrounding rural landscape. The scale and size of the allocation means major impacts on the surrounding land including the lanes, historic buildings, field boundaries and historic land use. Prior to allocation, KCC recommends an Archaeological DBA is undertaken to inform the process.

AL/HO 3 Land to the east of Horsmonden Site Numbers 82, 108, 297, 324

This allocation site contains part of the Hawkhurst to Paddock Wood Hop Line, a railway specifically built to serve 19th and 20th century hop pickers. The site may also contain remnants of Horsmonden Station. The railway line and station are important local heritage assets and they should be preserved in situ and preferably conserved through a programme of heritage enhancement and interpretation. This allocation needs to be supported by a full Archaeological DBA and assessment of the railway heritage.

Based on present information, all other sites or areas could be developed mostly with archaeological measures in place and in a number of cases as long as there is no impact on the setting of Listed Buildings and Conservation Areas (Scales 3, 4 and 5).

As part of the decision making process on these Site Allocations, the County Council recommends the following reports are consulted as supporting information:

• Historic Towns Survey (Kent County Council/English Heritage)
• Historic Parks and Gardens Survey (Tunbridge Wells BC/KCC/Kent Gardens Trust)
• Farmstead Survey (English Heritage Jeremy Lake)

DLP_3808

Government Team
Natural England

Section 5: Place Shaping Policies

Comments on individual allocations where development is more likely to impact on the natural environment are contained within Appendix 3. This includes advice on potential impacts, what to include in the policies, and what to consider, should the allocation be taken forward. Please note that where we have not objected to, or otherwise commented on, a policy or proposal, it should not be assumed that it would not have an adverse effect on landscape or biodiversity, because we have focused on the most important environmental issues in the plan.

Advice on environmental issues which we advise are incorporated more widely into the policies is provided below.

Incorporation of green infrastructure into new development:

A review of the place shaping policies has identified that policy wording requiring strong green infrastructure provision is not consistently applied between parish and non-parish areas. For example, this policy is applied in point seven for the parish of Capel, but is not apparent in Southborough. Natural England supports a consistent and robust approach to ensure the provision of green infrastructure and advises that place shaping policies requiring integrated approaches to create, maintain and enhance resilient and coherent ecological networks across the district, including the protection and recovery of priority species and habitats are incorporated into all parish/ non parish areas.

Landscape

Natural England advises that policies aimed at ensuring landscape gaps between individual areas of the parish are retained to prevent coalescence of development, preserve the setting of heritage assets and help protect the wider historic environment are more widely incorporated into the place shaping policies. Landscape coalescence is an important consideration in the protection of landscape and heritage assets, particularly in the case of protected landscapes such as the High Weald AONB.

DLP_3870

Mrs June Bell

paragraph 5.5

Misleading numbers of New Dwellings to be accommodated in the Parish available in the public domain

Reasons for comment:

Source 1: DLP 

(1) states ‘for each overarching policy sets out the approximate number of new dwellings that will be delivered through the site allocation policies for that area and the number of sites this relates to. These statistics do not include any site allocations that were previously included in, and are being carried forward from, the Site Allocations Local Plan 2016’.

STR/CRS 1 Approximately 718-803 new dwellings will be delivered on nine site

AL/CRS 9 (Land adjacent to the Crane Valley) 200-250 dwellings was allocated in the current local plan.

Source 2: LOCAL Summary Document Autumn 2019

states ‘approx. 697 dwellings in Cranbrook and Hartley (which includes approx. 225 at land adjacent to the Crane Valley allocated in the current Local Plan) and …’

DLP_4104

Tunbridge Wells District Committee Campaign to Protect Rural England

COMMENTS ON POLICIES 

CPRE Kent’s Head Office is replying to the Strategic Objectives and Strategic Policies (apart from most of the parish-based ones) and to the two main strategic allocation policies at Capel and Paddock Wood.  CPRE’s Tunbridge Wells committee has been fully consulted in the preparation of these responses.

I am replying on behalf of CPRE Kent’s Tunbridge Wells committee to the other policies. Our replies follow consultation with our members and with CPRE Kent’s Head Office.

DLP_4475

Paddock Wood Neighbourhood Plan Steering Group

These policies are set out by parish/administrative area. The policies for each area seem to be presented in full so they can be read in isolation of other areas. For Paddock Wood/east Capel, this has led to much duplication, on top of which is the laborious way in which the policies are ‘layered’ i.e. with STR1 setting out the strategy borough wide, STR1/PW setting out the strategy for Paddock Wood/east Capel, followed by AL/PW1-4 which covers the four allocations/designations for Paddock Wood (and which in part includes east Capel).

DLP_4614

CBRE Ltd for Dandara Ltd

Covering Letter and other comments

CBRE is appointed by Dandara Ltd. to submit representations relating to the Tunbridge Wells Borough Draft Local Plan (Regulation 18) Consultation which runs between 20th September to 15th November 2019.

Dandara hold specific land interests in respect of the following sites as set out in our representations:

• Badsell Farm, Paddock Wood (‘Paddock Wood’);
• Land to the west edge of Eridge Road at Spratsbrook Farm (‘Spratsbrook Farm’); * Land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road (‘Sissinghurst’); and
• Land off Copthall Avenue and Highgate Hill, Hawkhurst (‘Hawkhurst’).

The above sites are located within the administrative area of Tunbridge Wells Borough Council (‘TWBC’). The above sites are allocated sites in the Draft

Accordingly, please find the following enclosed representations which will be sent via email and secure electronic file transfer:

• This cover letter;
• Completed Local Plan Response Form; and
• Written Representations Report dated November 2019.

CBRE has spoken with TWBC’s Planning Policy Team on the 8th November 2019 who confirmed that Local Plan representations can be submitted in a formal complete report without the need to complete the separate sections of the Response Form. For completeness we have completed the enclosed Response Form to assist Officers. This Response Form requires Officers to cross refer to our enclosed Written Representations Report dated November 2019.

Dandara will continue to engage with TWBC as well as key stakeholders, to feed into and inform later stages in the plan-making process.

Dandara will also continue to monitor the progress of the emerging Local Plan and will also look to make written representations on the next stage (Regulation 19) of the Draft Local Plan.

Introduction (Written Representations Report)

1.1 CBRE Limited (CBRE) is instructed by Dandara Ltd. (‘Dandara’) to prepare written representations in relation to the Regulation 18 Consultation draft version of the Tunbridge Wells Borough Local Plan (hereafter ‘Draft Local Plan’) (September 2019). The Regulation 18 Consultation period runs between 20th September to 15th November 2019.

1.2 Dandara holds specific land interests in respect of the following sites:

• Badsell Farm, Paddock Wood (‘Paddock Wood’);
• Land to the west edge of Eridge Road at Spratsbrook Farm (‘Spratsbrook Farm’);
• Land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road (‘Sissinghurst’); and
• Land off Copthall Avenue and Highgate Hill, Hawkhurst (‘Hawkhurst’).

1.3 The above sites are located within the administrative area of Tunbridge Wells Borough Council (‘TWBC’).

1.4 Dandara has submitted written representations in respect to the previous Regulation 18 Issues and Options Consultation draft version of the Tunbridge Wells Borough Local Plan in June 2017.

1.5 These written representations provide comment on the Draft Local Plan proposed policies and strategic issues, as well as context in relation to the promotion of the four above mentioned sites as housing site allocations. Dandara wishes to achieve favourable site allocations for the above sites and is currently undertaking the relevant technical studies to enable prompt application submissions to be made where feasible and appropriate.

1.6 There is sufficient and proportionate evidence to justify the inclusion of the above sites as housing allocations in the emerging Tunbridge Wells Borough Local Plan. Each site represents a sustainable and suitable location for growth. Further technical studies will be robust to provide certainty regarding the site allocation potential and timescale for delivery for each. This will:

• Inform the evidence base, to ensure it is proportionate to support the broad allocation of the site thereby factoring in constraints and mitigation;
• Compare capacity testing to demonstrate the site allocation potential;
• Demonstrate the robustness of the approach to support TWBC through the emerging Local Plan process, and third-party stakeholders.

1.7 An advisory technical team including CBRE (planning advice), JTP (urban design), Define (landscape architects), DHA (flooding/drainage and transport/highways advice) and Turleys (heritage advice) has been appointed to commence this early assessment work, with the purpose of informing the Local Plan process. Each technical consultant has adopted a robust standard methodology and have cross-referred to TWBC’s emerging Local Plan evidence base.

1.8 For Paddock Wood, the consultant technical team are preparing a concept masterplan for the Badsell Farm site which has been informed by the technical assessment work to mitigate the site’s constraints and confirms how this expansion will link to the existing Town.

1.9 Dandara has not submitted any concept masterplan or any illustrative schemes for sites at Paddock Wood and Spratsbrook Farm at this stage. This work will be progressed in the coming months, and for Paddock Wood this will be alongside a Strategic Framework including Infrastructure Delivery Plan. They will be informed by a robust technical evidence base for each site.

1.10 This evidence base will continue to inform Dandara’s Local Plan representations and will be progressed as TWBC’s Local Plan review process advances.

1.11 The Draft Local Plan proposes to include these sites as housing allocations, and as such TWBC has drawn its own conclusions using its evidence base as to the appropriateness for housing development. The assessment work being undertaken by Dandara is independent of this, nevertheless, will be available to TWBC to help inform their plan-making process.

1.12 In addition, Dandara is also actively engaging with TWBC and the variety of landowners, developers and stakeholders through the emerging Local Plan process, to support the progress of the strategic extension to Paddock Wood, including the release of Dandara’s site from the Green Belt and allocation for residential led development. Dandara has, and will continue to participate in, the Stakeholder Forum sessions held in July and September 2019.

1.13 In relation to their land interests at Paddock Wood and Spratsbrook Farm, Dandara’s advisory team has engaged in an initial charette process, to establish the key constraints and opportunities from the perspective of several technical disciplines, including flood risk, transport, landscape and masterplanning.

1.14 Dandara has also submitted planning applications in respect of their land interests at Sissinghurst (LPA ref. 19/00308/FULL) and Hawkhurst (LPA ref. 18/01063/FULL). Robust technical work has been undertaken as part of the planning application process. Further details of these applications are set out in Section 4.0 of these written representations.

Representations Structure

1.15 These written representations are structured as follows:

• Section 2 provides a brief background to Dandara;
• Section 3 provides comment on the Draft Local Plan vision and strategic policies;
• Section 4 provides site specific comments relating to allocated sites in the Draft Local Plan in respect of which Dandara has a specific land interest;
• Section 5 provides comment on other planning policies and development management policies included within the Draft Local Plan;
• Section 6 considers the requirements of the National Planning Policy Framework (‘NPPF’) (February 2019) regarding Local Plan ‘soundness’, and whether the Draft Local Plan including the proposed site allocations are considered to be capable of being found sound; and
• Section 7 provides a written representations summary and outlines proposed next steps.

1.16 Supporting appendices are enclosed with these written representations.

2.0 Dandara 

2.1 Dandara is a UK independent property development company established in 1988. Dandara has been at the forefront of commercial and residential property design and development for nearly three decades, creating award-winning homes and working environments throughout the UK.

2.2 Dandara has an established and experienced land and planning team and aims to work collaboratively with local councils, stakeholders and the local community to deliver developments that meet and exceed the aspirations of all involved in the process.

2.3 Dandara is passionate about quality, which is why they undertake every aspect of the development process themselves; from land buying and planning, to design, build and sales. It's an approach which has been very successful and popular with their customers.

2.4 Dandara prides itself on providing innovative homes and commercial properties, which would offer real value for money without compromising on design, durability or quality.

2.5 It is Dandara’s aim for their development sites to create:

• Attractive new communities;
• High quality homes;
• High quality working environments;
• Sounds investments; and
• Schemes that minimise the impact on the environment.

Knights Wood, Tunbridge Wells

2.6 Knights Wood is perhaps Dandara’s most well-recognised development in Tunbridge Wells borough and comprises an award-winning development that supports a new community. The site extends some 220 acres and is located on the eastern edge of Royal Tunbridge Wells. Planning permission (LPA ref. 13/02885/OUT) was granted on 27th January 2014 for up to 550 new homes, shops, community spaces and a two-entry primary school. A subsequent application (LPA ref. 18/00602/FULL) was granted on 24th January 2019 for an additional 86 residential units (Phase 4). Phases 1 and 2, including the new primary school, have been delivered to date. The development also includes the long term management of the surrounding Ancient Woodlands.

[TWBC: see Figure 1 on page 5 of full representation].

Union House, Tunbridge Wells

2.7 Dandara secured permission (ref: 16/504331/FULL) for the redevelopment of the Union House office building located at the end of The Pantiles in June 2017. This unattractive office building has now been demolished and the construction of 127 apartments along with office and retail space is currently taking place. The development is of a high quality to reflect its historic location within The Pantiles and includes The Pump House, a not for profit community space, which reflects the historic role of the site as a meeting place for the local community.

[TWBC: see Figure 2 on page 5 of  full representation].

CLIENT’S EVIDENCE BASE

4.144 In addition to the technical information that has been prepared to-date, Dandara is currently undertaking the following technical studies as set out above:

• Landscape, Visual and Green Belt Appraisal for Badsell Farm, Paddock Wood and Land to the west edge of Eridge Road at Spratsbrook Farm sites; and
• Initial heritage advice in respect to Badsell Farm, Paddock Wood and Land to the west edge of Eridge Road at Spratsbrook Farm sites.

5.0 Development Management Policies 

5.1 Dandara has reviewed the Draft Local Plan Development Management Policies to ensure they are consistent with the NPPF. Please refer to the Policy Review Matrix included at Appendix A.

6.0 Summary 

6.1 Dandara supports the overall strategic objectives of the Council’s Regulation 18 Draft Local Plan and in particular the focus on the delivery of new homes in the borough. It is evident that TWBC has to identify additional suitable sites for housing, including suitable release of Green Belt land through its new Local Plan if it is to satisfy its OAN and meet its housing target of 678 dwellings per year (more than double the current target of 300 dwellings per year).

6.2 Dandara has land interests in the below sites which are identified as site allocations for significant new growth and primarily the delivery of new homes in the Draft Local Plan:

• Badsell Farm, Paddock Wood (‘Paddock Wood’);
• Land to the west edge of Eridge Road at Spratsbrook Farm (‘Spratsbrook Farm’); § Land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road (‘Sissinghurst Road’); and
• Land off Copthall Avenue and Highgate Hill, Hawkhurst (‘Hawkhurst’).

6.3 The above site allocations all constitute suitable sites for housing and are all available and deliverable now. It is suggested that the above sites at Spratsbrook, Sissinghurst and Hawkhurst are all deliverable in the short term and within the first five years of the Plan period. Given the scale of the proposed residential development at Badsell Farm, this site would be deliverable in the short-medium term.

6.4 Although the Draft Local Plan is at relatively early stage (Regulation 18) in the Local Plan process, Dandara has already been actively engaging with TWBC, in the promotion of the strategic extension to Paddock Wood and in the allocation the above-mentioned sites at Spratsbrook, Sissinghurst and Hawkhurst.

6.5 Dandara has also been working to collate their own evidence base for the above mentioned sites in order to further demonstrate their suitability for housing and to assist with the Local Plan process.

6.6 Dandara will also sustain their collaborative approach by continuing to engage with TWBC as well as key stakeholders, to feed into and inform later stages in the plan-making process.

6.7 Dandara will continue to monitor the progress of the emerging Local Plan and will also look to make written representations on the next stage (Regulation 19) of the Draft Local Plan.

6.8 We would be grateful for confirmation that these representations have been received, and that they have been registered as duly made. We trust this submission is clear and helpful but should there be any queries please let us know.

[TWBC: see full representation].

DLP_4670

CBRE Ltd for Dandara Ltd

4.0 Site Specific Representations

4.1 Dandara has specific land interests in the following sites listed below, all of which are proposed as either site allocations or as part of wider site allocations within the Draft Local Plan:

• Badsell Farm, Paddock Wood (‘Paddock Wood’);
• Land to the west edge of Eridge Road at Spratsbrook Farm (Spratsbrook Farm’);
• Land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road (‘Sissinghurst’; and
• Land off Copthall Avenue and Highgate Hill, Hawkhurst (‘Hawkhurst’).

4.2 Site location plans for each site are included below.

4.3 All four of the above mentioned sites would contribute significantly to the overall vision of the Plan, particularly in terms of helping to meet the OAN for housing in the borough.

Site Allocation Policies

4.4 Paragraph 16 (Part d) of the NPPF requires Plans to:

“d) contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals”.

4.5 With reference to paragraph 16 of the NPPF, Dandara suggests that TWBC review the length of, and simplify, the wording of their site allocation policies. It is also confusing to have separate, but linked, strategy (STR policies) and allocation (AL policies). Dandara suggests that the strategic policies should be less prescriptive in terms of the level of detail set out. Dandara also considers that it would be more robust and straightforward to have one concise policy for each site allocation.

4.6 For example, the Badsell Farm site is covered within both site allocations Capel (CA3) and Paddock Wood (PW1), which both have separate strategic and site allocation policies (Policies STR/CA1, AL/CA3, STR/PW1 and AL/PW1), rather than one comprehensive policy for each. Whilst it is accepted that the Badsell Farm site lies in Capel rather than Paddock Wood, having two policies that largely replicate each other in respect of this site and cross-reference one another for multiple facets of the policy is unnecessarily confusing. Moreover, Tudeley Village under these strategic policies is also tied to Paddock Wood, but should have a separate strategic policy as it is a separate allocation. This is critical in the interests of not complicating the delivery of new homes and infrastructure.

4.7 In order to meet the requirements of Paragraph 16 (d), this approach should be reconsidered to ensure that the policies for each site allocation are clearly set out in one place.

[TWBC: see full representation].

DLP_4907

Woodland Trust

Section 5. Place-shaping policies

The Woodland Trust objects to ancient woodland areas being included in sites allocated as suitable for development.

We recognise the intense pressure to identify and bring forward new sites for housing and employment uses. This pressure makes it all the more important that vital protections for ancient woodland and veteran trees are upheld.

The National Planning Policy Framework (NPPF) (paragraph 175c) states: “When determining planning applications, local planning authorities should apply the following principles: …… c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists”.

Direct impacts that would lead to damage or loss of ancient woodland habitat or veteran trees must either be avoided or compensated for if the need is judged to be truly exceptional; there is no appropriate mitigation for the loss of irreplaceable habitats.

Where development sites are adjacent to ancient woodland, we recommend that as a precautionary principle, a minimum 50 metre buffer should be maintained between a development and the ancient woodland, including through the construction phase, unless the applicant can demonstrate very clearly how a smaller buffer would suffice. A larger buffer may be required for particularly significant engineering operations, or for after-uses that generate significant disturbance.

Development which would result in the loss of ancient woodland, aged or veteran trees should not be permitted. In particular, we are concerned that the following proposed development sites include areas of ancient woodland.

These allocations are inconsistent with the enhanced protection afforded ancient woodland in the NPPF. Ancient woods are irreplaceable. They are our richest terrestrial wildlife habitats, with complex ecological communities that have developed over centuries, and contain a high proportion of rare and threatened species, many of which are dependent on the particular conditions that this habitat affords. For this reason, ancient woods are reservoirs of biodiversity, but because the resource is limited and highly fragmented, they and their associated wildlife are particularly vulnerable.

We do however also note and welcome that policy EN15 (ancient woodland and veteran trees) is referenced in the individual site allocation policies.

In addition, we are concerned about the proximity of the following site allocations to areas of ancient woodland.

DLP_5233

Tunbridge Wells Friends of the Earth

5.7 It is acknowledged that mitigation of impact of transport is key due to the constrained nature of some transport routes into, out of, and through the Main Urban area. A strong policy in the new Local Plan must at least improve on the present lack of effective mitigation measures, specifically with regards to air pollution and climate change impacts in general.

5.9 This paragraph will have to be redrafted in the light of the political decision not to proceed with the Calverley Square development. We are very pleased as 66 mature trees that were due to be cut down, will now be saved and the park’s landscape conserved.

DLP_6853

Barton Willmore for Crest Nicholson

5.0 STRATEGIC POLICIES

5.1 Firstly, TWBC is to be congratulated in not shirking its responsibilities in seeking to meet its own strategic housing requirement for this Plan period. It is unfortunate that more Councils across the South East are not similarly like-minded in recognising the importance of seeking to provide for its own residents housing and economic needs. We welcome and support TWBC in this regard.

5.2 It is acknowledged that the present housing requirement is significantly above that previously required by the earlier Kent County Structure Plan(S) and South East Local Plan (ie. circa 300dpa to 678dpa). We recognise the political challenges in providing for this step-change, and fully support the elected Members and professional Officers in actually positively approaching its plan-making objectives and in seeking to meet the identified housing and economic needs of the Borough.

5.3 The 2018 NPPF introduced the “Standard Methodology” for calculating each LPA’s housing need for subsequent plan-making and decision-making. TWBC is proposing a Plan period of 2016-2036 and an overall housing requirement of 13,560 (or 678 dpa), which takes into account allowance for a cap where OAN has increased significantly since the application of the standardised methodology. In the case of Tunbridge Wells, the need is “capped” at 678 dpa, whereas the “uncapped figure” is 754 dpa – which is the real correct figure for “actual need”.

5.4 Nevertheless, we are presently guided by the Standard Methodology and Table 1 of the supporting text assesses the standard methodology housing need against TWBC’s completions, delivery and projected future need. The table below details how TWBC proposes to conclude its residual need to 2036:

[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_6872

Barton Willmore for Crest Nicholson

6.0 PLACE SHAPING POLICIES

6.1 Section 5 of the Draft Local Plan sets out the spatial priorities and policies for the Borough. However, it does so on a parish-by-parish basis, as opposed to a settlement-by-settlement basis.

6.2 Ordinarily, this may seem a sensible approach, with individual settlements ordinarily lying within a single parish. However, and in respect of the proposed development at Paddock Wood (settlement), this has created an unnecessarily confusing plan-making situation and duplication of policy formulation.

6.3 The sites allocated around the western part of Paddock Wood lie within the parishes of both Paddock Wood and Capel. The consequence of this, and having approached matters on a parish-by-parish basis, is that both Parishes have their own “strategic growth policies”, which make reference for each area of strategic growth, ie for Capel Parish (Policy STR/CA1) and Paddock Wood (Policy STR/PW1) – albeit with substantial duplication, as far as proposed growth at (the settlement of) Paddock Wood is actually concerned.

6.4 This provides for unnecessary confusion and duplication and is far from being “effective” based upon the NPPF tests’ of soundness.

6.5 A similar consequence occurs when looking at the subsequent “allocation policies” for each parish, ie for Capel Parish (Policy AL/CA3) and Paddock Wood (Policy AL/PW1). This results in further unnecessary confusion and duplication of policy formulation.

6.6 In reviewing the Draft Plan as a whole, there are therefore 3No layers of policy formulation for the western part of the Paddock Wood allocations, albeit contained within 6No. geographically overlapping policy areas:

1. Strategic Policy STR1 sets out the overarching development strategy for Capel and Paddock Wood;
2. Both Capel and Paddock Wood have policies setting out the overall strategy for the development of the Masterplan and delivery of sites - Policy STR/CA1 and Policy STR/PW1;
3. There are then 3No site allocation policies for: Capel allocations; Paddock Wood Allocations and; Town Centre. The Capel and Paddock Wood Allocation policies are duplicates (Policies AL/CA3 and AL/PW1) and both refer to the need for town centre regeneration. In addition, there is a further standalone Town Centre allocation (Policy AL/PW2).

6.7 This may have seemed a sensible approach when drafting the Plan, however, it has caused us and no doubt others, much confusion and unnecessary duplication of work in seeking to formulate our responses to it.

6.8 It is recognised that differences do exist – but only insofar as the western sites at Paddock Wood lie within the two different administrative Parishes (Capel and Paddock Wood). We also recognise the (anticipated) political desire to seek to formulate plan-making policies in the light of parish boundaries, especially with the proposed Tudeley Garden Village also lying with Capel Parish.

6.9 However, and from a proper plan-making perspective and the realities of how Paddock Wood (as a settlement) presently operates and will operate in the future, it is far more “effective” to formulate future policies on a settlement-by-settlement basis (at least for Paddock Wood). As presently formulated, it presently appears to us to be “unsound”.

6.10 In the light of this, and to hopefully avoid unnecessary duplication in our representations, we have approached our responses to the proposed growth at Paddock Wood in the following manner:

1) We first address Policy STR/PW1, with [square bracket references to the relevant sections of Policy STR/CA1] where appropriate; and

2) Adopt a similar approach to the “allocation policies, namely Policy AL/PW1, with [relevant comments to Policy AL/CA3 in square brackets].

6.11 This enables us to focus on growth at Paddock Wood as a settlement, as opposed to two different administrative areas.

[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_8084

Department for Education

Site Allocations

14. DfE supports the inclusion of schools and school expansions as part of development site allocations, which is also highlighted in draft Policy STR5.

15. Viability assessment should inform options analysis and site selection, with site typologies reflecting the type and size of developments that are envisaged in the borough/district. This enables an informed judgement about which developments would be able to deliver the range of infrastructure required, including schools, leading to policy requirements that are fair, realistic and evidence-based. In accordance with Planning Practice Guidance, there should be an initial assumption that applicable developments will provide both land and funding for the construction of new schools. The total cumulative cost of complying with all relevant policies should not undermine deliverability of the plan, so it is important that anticipated education needs and costs of provision are incorporated at the outset, to inform local decisions about site selection and infrastructure priorities. [6]

16. While it is important to provide this clarity and certainty to developers and the communities affected by development, retaining a degree of flexibility about site specific requirements for schools is also necessary given that the need for school places can vary over time due to the many variables affecting it. DfE therefore recommends the Council consider highlighting in the next version of the Local Plan that:

- specific requirements for developer contributions to increasing capacity of existing schools and the provision of new schools for any particular site will be confirmed at application stage to ensure the latest data on identified need informs delivery; and that

- requirements to deliver schools on some sites could change in future if it were demonstrated and agreed that the site had become surplus to requirements, and is therefore no longer required for school use.

PPG on viability and planning obligations: https://www.gov.uk/government/collections/planning- practice-guidance

Forward Funding

21. DfE loans to forward fund schools as part of large residential developments may be of interest, for example if viability becomes an issue. Please see the Developer Loans for Schools prospectus for more information. [7] Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed.

⁷ Developer Loans for Schools prospectus available at https://www.gov.uk/government/publications/developer-loans-for-schools-apply-for-a-loan