Section 6: Development Management Policies – Transport and Parking

DLP_1802

Royal Tunbridge Wells Town Forum

Transport Policies Paragraphs 6.506 to 6.540

We have the following General Observations on these Paragraphs:

1. Unsustainable infrastructure: The required approach of this Draft Local Plan is to prioritise new housing development and its related infrastructure to enable sustainable communities. It does not seem sufficiently to consider the sustainability of existing communities and their infrastructure. As a result, it is conceptually incomplete since it does not seem to plan for changes to existing communities that will be damaged by their historic infrastructure being used to accommodate new planned phases of growth.
2. Mitigation but not for all? Whilst the new communities will be more sustainable than the existing ones nearby, there is a recognition that they will negatively impact on the latter. This is evident in the need for developer funded ‘mitigation’ measures to reduce their impact and provide new or extended infrastructure. However, this mitigation may only cover the impacts in the immediate vicinity of the development while the existing and often distant communities, that will particularly bear the impact of additional traffic, may receive proportionately less of the developers’ funds. We should like to see it explicitly stated that Sec 106 contributions may be directed in mitigation of problems faced by existing communities, whether nearby or at some distance.
3. The timescale is too long: Funding from developers for the necessary transport infrastructure is unlikely to be available until the housing developments are decided and the ground has been broken. Highways and cycling and walking infrastructure that may be provided in RTW as a direct result of the planned developments will most likely be at least 5-10 years away even if funding can be achieved. (See Infrastructure Development Plan Timing 2.22 ). This includes those that are ‘critical ‘or ‘essential’ (see Infrastructure Delivery Schedule p87: RTW). Funding which may be available will prioritise infrastructure related to new housing developments and civic energy will be directed to the ‘new’ not ‘existing’ communities.
4. Transport revolution: The Local Plan does not sufficiently recognise that a transport revolution is upon us whether there are thousands of houses planned to be built or not. The Plan may be ineffective because it is tied to a development and construction timetable rather than a transport/infrastructure based one and fails fully to recognise how much time it will take to persuade everyone to make changes to their modes of travel. By the end of this plan period in 2036, it is likely that sale of both diesel and petrol driven vehicles will have been banned six years earlier (recent news suggests that 2030 rather than 2040 will be the deadline). We believe that creating realistic and accessible opportunities for everyone in RTW, Paddock Wood, and other village and rural communities to make alternative travel choices where none exist now, will make more efficient use of existing road infrastructure and cut costs and pollution.  In Paragraph 513 – rather than “enables sustainable travel”, the text should therefore read “prioritises sustainable travel”.  Schemes should incentivise active travel and dis-incentivise travel by private car by making short journeys far easier and more convenient on foot or by bicycle than in a private car.
5. Pollution: The Draft does not take full account of the Climate Change Emergency and the need rapidly to reduce damaging air pollution arising from transport activities. (Climate Change Emergencies declared in Kent and RTW 2019.) It needs to refocus on the now as well as the future. It is commendably visionary in imagining the potential of future modes of transport to achieve sustainable communities with less pollution, traffic and parking. The TWBC Transport Strategy Review states: ‘Transport now accounts for 28% of the UK’s greenhouse gas emissions and is the largest emitting sector in the UK. Cars, vans and HGVs are the three main sources of emissions.’ Sadly, neither KCC nor TWBC has an accurate picture of how polluted its streets are outside the AQMA. This is particularly so in Tunbridge Wells town centre where the most people and most heavily congested traffic are in very close proximity without being adequately monitored.
6. Peak capacity: There is plenty of evidence that RTW is at peak vehicle capacity and is already renowned for its traffic congestion, the generally poor quality and unsafe environment for pedestrians and cyclists, its high charges for car parks and its residential roads and pavements being blighted by commuter parked cars.

   Furthermore, this Plan will be delivering as yet unquantified additional vehicles to the Pembury Road gateway into the town via the proposed Colts Hill bypass. However, a fraction of the £46m cost of this new road could be spent on transforming journeys of up to 2 miles within the town and between its satellite communities to deliver significant modal change, and buses, uber-style taxi and other public transport services to provide options for longer distances. That such an alternative policy would be realistically deliverable is evidenced in the transformation of Waltham Forest into a sustainable transport community at a cost less than that earmarked for the proposed Colts Hill bypass. In a seminal report published in March 2017 (‘The end of the road? Challenging the road-building consensus’) the Campaign to Protect Rural England analysed 12 such road schemes promising similar results undertaken over the last 40 years. In 10 out of the 12 cases the promised benefits of reduced congestion and economic prosperity clearly failed to materialise, and in the other 2 the evidence for any benefit was weak. The lesson of the last 40 years is that building new roads and widening existing ones only attracts more traffic. It is a classic case of induced demand. Better results might be achieved by introduction of peak hour road pricing at some locations to incentivise alternative travel choices.

7. Outdated data: We find the TWBC Transport Strategy Review to be well considered and useful and it sets the ground for taking more positive steps towards a more sustainable future. However, it relies too heavily on outdated data and will be finalised before the latest 2021 census data is available.  Key documents include:
   • 2011 census for population and travel to work data
   • 2016 Economic Needs Study which also relies on the 2011 census data
   • DfT Future of Mobility 2019, which whilst more up to date, relies on national data which does not necessarily translate into our local experience.
   • a Transport Assessment for the Local Plan which has not yet been completed.

   This has led to assumptions about a need to accommodate growing car ownership in the Plan while, in the same document, insufficient attention is paid to a much wider range of travel options. It would be better to see how our communities can achieve targets and timescales for reducing car use for shorter ‘in town’ journeys, or to estimate the potential take up for better and cleaner public buses serving all parts of RTW and its feeder communities.

8. Change now not later: There will be opportunities for modal change for the largest number of people if a strong lead is given on a transport vision for the existing as well as the new communities. Change is needed and needed fast to give the most value to the whole community. Different travel options – bus, cycling, walking, taxi/uber, club cars etc – need to be in place first so that anyone - but particularly those unable to afford to own personal vehicles in future as they have in the past - can continue to travel for leisure, work or education. The danger is that this transport revolution could bring wider social division and more isolation.  Encouragement for cheap, efficient and low polluting bus services that serve local communities throughout the borough as they do in cities, together with uber style taxis, car clubs etc, must be a priority. There would be less need for huge infrastructure investment and reliance on untried, developing technologies.
9. No map yet: The Draft Plan’s commitment to ‘active travel’ is most welcome as it would appear that every one of the new developments is to have ‘active travel’ as a priority. However, there is not yet a picture of what in reality this will look like on the ground. There is a fundamental need for a map of the projected network of cycle paths and walking routes linking the new and existing communities that can inspire people to change their mode of travel and incite funders from all sectors, public and private, to provide the necessary finance. RTW has a disjointed, patchy and poorly maintained and signed selection of underused cycleways and shared paths within the town and nothing to connect them to other local villages and communities let alone the new housing that is planned.  A map must show how communities will connect to each other and to employment, leisure, education, medical and other services which already exist or are planned for the growth of the town. When in place, all of these new routes should be publicised to prospective users on appropriate apps and internet links. Even existing physical links are largely unknown to the general public. The Town Forum produced a map as part of its Green Network Report in 2015 showing some of the existing and potential links for walking and cycling within RTW.
10. Local needs:  The Draft Local plan deals primarily with the distribution and type of housing needed in the Borough for its next phase of growth. Though the aspirations expressed about transport are largely commendable, they unfortunately bear witness to the reality that our transport infrastructure now and in the future is not under local control and not meeting local needs. It depends on financial decisions taken by developers, government, transport authorities, county councils and others which to date have not served us well. Given that unsatisfactory context, the Draft Plan does at least set out in a direction that is an improvement on the current Local Plan.

Safeguarding the future: We are strongly supportive of the policy of safeguarding the Tunbridge Wells to Eridge Railway Line because a future re-opening of the line for commercial passenger services, with a re-opened  station at West Station, could significantly improve  travel opportunities from West Kent to the Sussex Coast and also provide an alternative commuter route to the saturated Ashford to London line and the Royal Tunbridge Wells to Tonbridge line with its single track tunnel restriction at Somerhill which prevents increases in service frequency. It is important that safeguarding should adequately provide for a mainline double track alignment and passenger station facility.

DLP_2928

Chris Gow

Transport and Parking 6.506 - 6.540

Transport and Parking 6.506 - 6.540

The local plan does not seem to contain any radical policies to address the following:

Traffic congestion,

Rat-running through side streets,

Speed control,

Car ownership in the borough,

Parking problems,

Pavement parking,

Commuter parking,

Public transport delivery and sustainability,

Existing policies do little to restrict car ownership and discourage traffic movements.

Existing policies do not encourage alternative travel methods.

DLP_5256

Tunbridge Wells Friends of the Earth

Transport and Parking

We support the General Observations made by the Tunbridge Wells Town Forum in their response to the draft local plan

6.506 - §6.509 We welcome the mention of “focus on sustainable transport” options, yet little is actually said in these paragraphs about truly sustainable travel that can be facilitated by improving and/or creating infrastructure for active travel and by expanding clean public transport options and services. Instead, it seems LPA is resigned to accept increased car traffic and admits that with the current plans for development in rural areas, they will be contributing to this increase. As long as LPA accommodates and prioritises private car use over sustainable transport, we are unlikely to deal with future congestion, air pollution (and its negative health impacts) and effects of climate change. It also does not tally with the Climate Emergency Declaration by TWBC in July 2019. It certainly will not encourage residents to change their mode of transport to more sustainable ones. Sustainable travel should not just be in focus; it should be the main focus.

DLP_6068

Mr C Mackonochie

TP1 to TP5

Support

Policy Number: TP1 to TP5

DLP_7408

Mr John Telling

Section 6: Development Management Policies: Transport and Parking

These paragraphs seem to play little more than lip service to the imperative need to radically reform our ways of getting about. The statement (para 6.507) that private car ownership is expected to increase is followed by the recognition (para 6.508) that parts of the borough are already severely congested does not seem to be addressed by any real vision for change. With incontrovertible evidence of climate change and the consequences for health from particulate pollution haven't we moved on from favouring the private car? Planning policy has to embrace the need for radical change in our transport arrangements.

The only truly 'sustainable' method of movement is walking. Cycling comes second, followed by public transport. Moving about in a carapace of two tons of metal whilst throwing the lithosphere (carbon) into the atmosphere is irresponsible, and to use this plan’s jargon, unsustainable. We are witnessing the environmental consequences of uncontrolled carbon emissions now. Electric cars are not a panacea. They place heavy demands on the environment from power generation to recharge, and for the need for finite  materials to make batteries and other components. They also emit particulates from brake, tyre and road wear.

The climate crisis requires a new vision for people moving about, and for their lifestyles, with walking, cycling and public transport at its heart, not tinkering with existing arrangements.

This issue also has implications for the planning of housing to maximise public transport access and use. 

I believe it is now time to consider whether we should be adopting policies for building 'up' within the existing boundaries of development rather than 'out', to enable people to live closer to key public transport links and services, thus reducing the need  for personal motorised  transport.

DLP_1610

Maggie Fenton

Policy TP1 Transport Assessment, travel plans & mitigation

1. Demonstrate that the impacts of trips …are accommodated, or mitigation to prevent significant residual impact
2. Demonstrate the development complies with Policy EN23 Air Quality

The transport assessment conducted  by SWECO has no solution to congestion on the A264 at Pembury, other than to make more use of buses or cycling & alter the traffic signal timings at Halls Hole junction.  The Colts Hill Strategic link is a road to a traffic jam, which will be even larger with the influx of thousands of extra cars.

Where are the mitigation proposals for traffic to Tonbridge from  Capel and Paddock Wood?

Where are the details of how the proposals for Capel able to demonstrate compliance with Policy EN23?

DLP_1881

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Number: TP1 Transport Assessments & Travel Plans

Policy TP1 needs strengthening:

• There is no inevitability about car ownership levels rising. Journeys by car are generated because the facilities for them are provided.  The Local Plan should include an aim to reduce the need for car ownership and then implement policies to achieve that aim.  Additional wording such as “All new development must demonstrate that active travel is prioritised over non-active travel” is needed to ensure that the Local Plan prescribes measures to put the Borough’s climate emergency resolution into effect across the whole Borough, including the rural areas.
• The words ‘active or sustainable’ need to be added in front of transport in the sentence "Where adequate transport infrastructure is not available to serve the development...".
• The reality is that the Highway Authority has limited powers and is rarely able to say that a development will cause a problem for the road network, because
  1. each development is judged incrementally; and
  2. the problems need to exist close to the development

The result is inadequate s106 funding for active travel.  We suggest that it should be made explicit that developers’ responsibility for s106 contributions to support active travel solutions is not limited to locations near the development.

• The current methodology is still ‘predict and provide’, whereas the Borough Council could decide on appropriate levels of motor traffic within the Borough and take action accordingly. The Government’s Science and Technology Committee report of 22^nd August 2019 on policies needed to meet the Government’s commitment to net-zero emissions by 2050 stated that ‘widespread personal vehicle ownership does not appear to be compatible with significant decarbonisation’. The increase in car use which the local plan is seeking to accommodate is not compatible with the Government’s climate commitment, nor is it compatible with TWBC’ climate emergency declaration and aim to make the borough carbon neutral by 2030. Similarly to the policy that new developments have to show a net reduction in water outflow, the transport policy should state that all additional traffic movements have to be compensated by the developer funding infrastructure to enable motor traffic reduction elsewhere.

Although we welcome the requirement for travel plans to be produced for new developments, we are concerned that the thresholds based on m² do not reflect the scale of activity to be undertaken within or the likely number of employees and the number of HGVs and other vehicles attending the site daily. Further, use class D2 Stadia has a threshold of 1500 seats which is relevant to the proposed re-siting of the Culverden football stadium which may not be 1500 seats but should require a transport assessment for its proposed location. We should like to see some specified sanctions in the event of travel plans not being maintained in practice.

DLP_3381

Kent County Council (Growth, Environment and Transport)

Highways and Transportation

Paragraph 6.511 - Instead of this paragraph and subsequent table, following text should be provided:

Transport assessments and travel plans will be expected to accompany all planning applications for new developments where the location of the development has existing traffic issues or lack of transport infrastructure, or in any circumstances at the request of KCC Highways. Where appropriate, new development proposals will be expected to enter into legal agreements to secure the delivery of mitigation to address both their direct and cumulative impacts on the transport network. The Local Planning Authority may also seek to secure construction and environment management plans (as requested and developed with Kent County Council) to minimise impacts from new major developments during construction.

Policy TP 1

The Local Highway Authority conditionally supports this policy.

The following amends should be made:

Paragraph 1 – “Demonstrate that the impacts of trips generated to and from the development are accommodated or mitigated to prevent significant impacts, including where necessary an exploration of delivering mitigation measures ahead of the development being occupied; and”

Paragraph 2 “Provide a satisfactory Transport Assessment for proposals as required by KCC Highways “ (see paragraph 6.511 above).

The County Council also requests the inclusion of the following wording:

Where adequate transport infrastructure is not available to serve the development, the Local Planning Authority will seek the provision of, or contributions towards, appropriate measures that will address the identified inadequacy, and which will enable active travel and provide other highway improvements. As such, where a proposal necessitates highway improvements, the developer will be required to meet the cost of the improvements and deliver the identified scheme where these are fairly and reasonably related to the development.

It should also be noted that the County Council considers that point 3 should be deleted as a development should comply with all relevant policies, not just this one. KCC also considers that is no need for paragraph beginning “Furthermore, all development...” as this is repetition of paragraph 2.

Public Rights of Way and Access Service

While the general content of this Transport Policy is supported, additional consideration should be given to the impact of development on Non-Motorised Users (NMUs) along rural lanes. This is because rural lanes provide useful connections for NMUs travelling between off-road PRoW routes. The potential for increased vehicular traffic along these quiet country lanes, resulting from development, is therefore a concern. Increased vehicle movements could introduce safety concerns for NMUs and potentially deter public use of the PRoW network. Applications for development should therefore be expected to include traffic impact studies. Where negative impacts are identified, developers should provide or contribute towards appropriate mitigation measures.

DLP_3715

Capel Parish Council

Object

Capel Parish Council objects to this Policy and to the following paragraphs of the accompanying commentary, for the reasons stated.

Paragraph 6.500 (p.484) states that “A new Neighbourhood Centre is planned to be designated as part of the proposed development at Paddock Wood/including on land in the east of Capel parish”

Paragraph 6.501 (p.484) states that “The provision of a new Village Centre will be made at Tudeley as part of the proposed Tudeley Village”

Why is Five Oak Green missing from this core policy? There is no detail on how TWBC intend to help retain local services and facilities.

DLP_4211

Tunbridge Wells District Committee Campaign to Protect Rural England

Support with conditions

CPRE supports this policy’s attempt to address the serious problems that cumulative small or larger developments, none of which are large enough individually to cause severe problems, can cause on already overloaded rural roads, within the unfortunate limits imposed by current Government policy. However, in the last paragraph “will seek” is too weak and should be replaced by “will require”.

DLP_4313

White Young Green Planning for Standard Life Investments UK Real Estate Fund

Object

Policy TP1 – Transport Assessment, Travel Plans and Mitigations 

Standard Life Investments UK Real Estate Fund object to the current wording of Policy TP1 on the basis that the policy applies unjustified thresholds on the requirement for new development to provide Transport Assessments (TA) and Travel Plans (TP).

Policy TP1 currently states: “Development proposals must:…Provide a satisfactory transport assessment for proposals that reach the required threshold levels set by Kent County Council’s Guidance on Transport Assessments and Travel Plans and in Highways England guidance (see Table 8 above)”. Table 8 identifies planning applications for retail and for assembly and leisure over 1,000 sqm would be required to be supported by a TA and TP. The NPPF states: “All developments that will generate significant amounts of movement should be required to provide a travel plan, and the application should be supported by a transport statement or transport assessment so that the likely impacts of the proposal can be assessed” (paragraph 11). Similarly, the NPPG states: “Local planning authorities must make a judgement as to whether a proposed development would generate significant amounts of movement on a case by case basis (ie significance may be a lower threshold where road capacity is already stretched or a higher threshold for a development which proposes no car parking in an area of high public transport accessibility)” (Travel Plans, Transport Assessments and Statements, Paragraph: 009 Reference ID: 42-009-20140306).

As such, it is considered the requirement should therefore be determined on the local circumstance (i.e. relevant to the individual proposal/s) and the arbitrary threshold approach should be removed. The Council already maintain their ability to request such reports by the inclusion of the following wording within the policy: “…all development will be required to be accompanied by a transport assessment and a travel plan if the location of the development has existing traffic issues or lack of transport infrastructure, as identified by the Local Highway Authority”.

The threshold approach to the assessment / mitigation of highways impact remains ‘ineffective’ and therefore is ‘unsound’. Each proposal should be assessed on a case-by-case basis, and discussions had with the Local Highways Authority if necessary. In addition, as mentioned in respect of other policies, it is not considered necessary to repeat matters relating to planning contributions within this policy, as such matters are appropriately dealt with by Policy ST 5 Essential Infrastructure & Connectivity.

DLP_4722

CBRE Ltd for Dandara Ltd

Support with conditions

Dandara Comment 

Dandara support mitigation measures for the impact of development but consider that this policy should note that Kent County Council’s Highways Department and/or Highways England will collaborate with developers to establish and plan to achieve the required mitigations.

Suggested Policy Amendment(s) 

Suggested policy rewording:

“Demonstrate that the impacts of trips generated to and from the development are accommodated, remedied, or mitigated to prevent significant residual impacts, including where necessary an exploration of delivering mitigation measures, in conjunction with Kent County Council’s Highways Department and/or Highways England, ahead of the development being occupied”.

DLP_5047

Sue Wood

General Observation

Policy Number: TP1 Transport Assessments, Travel Plans & Mitigations p483

Cranbrook – situated 6 miles from nearest railway station, Staplehurst

Nearest towns, Maidstone 14m, Tunbridge Wells, 15m

Public transport, Maidstone – 1 bus per hour via Staplehurst Station (45 – 50m)

Tunbridge Wells – 1 bus per 1.5 hrs/2hrs (duration 1-2 hrs depending on traffic)

Currently neither getting to the train station or either town is conducive to using Busses.

To get from Cranbrook to the A21 /Tunbridge Wells etc, all traffic goes through Goudhurst.

When large vehicles meet at the right angled bend at the top of Goudhurst, the traffic stops & the chaos is overwhelming with huge tailbacks occurring.

With the proposal of 800 new houses in Cranbrook, with a vast majority no doubt working outside the town, there could easily be an additional ***? vehicles compacting on the already horrendous situation in Goudhurst High Street.

The only viable answer (excluding a bypass which would be difficult & expensive) might

be to put a one way system in place?

DLP_6693

Gladman

6.18 Policy TP1: Transport Assessments, Travel Plans, and Mitigation

6.18.1 This policy sets out the Council’s overarching approach to assessing highways impact and mitigation. Gladman is concerned with part 1 of the policy which sets out that development proposals must “demonstrate that the impacts of trips generated to and from the development are accommodated, remedied, or mitigated to prevent significant residual impacts..”. The wording set out in relation to highway impact differs from that outlined within the NPPF which sets out that development prevented or refused on highways grounds only if the residual cumulative impacts on the road network would be severe (see Paragraph 109). The draft wording of Policy TP1 sets a higher bar than national planning policy in relation to highways impact and is not sufficiently justified. To address this the Council should revise the policy to adopt the wording of the NPPF.

[TWBC: see full representation attached].

[TWBC: see also Comment Nos. DLP_6656-6695]

DLP_6934

Barton Willmore for Crest Nicholson

Object

7.36 Paragraph 6.511 of the Local Plan Regulation 18 Consultation Draft (15 August 2019) states that:

“Transport assessments and travel plans (…) will be expected to accompany all planning applications for new developments that reach the required threshold...”

7.37 Policy TP1 requires that proposals demonstrate the impacts of trips from the development, provide a transport assessment where they reach KCC threshold levels, and demonstrate that the development complies with EN23. The policy then goes on to require that all proposals in areas where there is an identified traffic issue should provide a transport assessment and travel plan.

7.38 Furthermore, while improvements to public transport services between Paddock Wood and Tonbridge would be expected, some additional clarity on the intention for a ‘bus-only’ link should be provided, including the costs and expected patronage that such new public transport facilities would be expected to generate in justifying the scheme described.

7.39 The policy as currently written lacks the required precision and clarity in respect to traffic issues, and should be clearer on when a travel plan and transport assessment is required. At this stage, Policy TP1 does not make such a distinction between the cumulative and stand- alone assessment of developments in clarifying how the Transport Assessment process will be applied when a planning application is being prepared. For these reasons, the policy is considered currently unsound.

[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_7339

Campaign to Protect Hawkhurst Village

Object

This policy provides that applications for developments of less than 10 dwellings will not be required to produce Transport Assessments.

This is an arbitrary figure and ignores the cumulative impact of several small schemes on the local highway network.

The policy should make clear that Transport Assessments will be required for small schemes (less than 10 dwellings) where there are subsisting local traffic issues.

In turn the policy should explicitly require all Transport Assessments to provide a cumulative assessment of the proposed scheme when taken together with other relevant committed but not yet built or occupied developments.

DLP_7957

Wendy Owen

Object

Transport and Parking

Any development of site 137 cannot demonstrate “that the impacts of trips generated to and from the development are accommodated, remedied or mitigated to prevent significant residue impacts” because of the volume of traffic already using the A26 road.

DLP_8139

Ashley Saunders

Object

I objects to this Policy and to the following paragraphs of the accompanying commentary, for the reasons stated.

Policy TP 1 states that Development proposals must:

“1. Demonstrate that the impacts of trips generated to and from the development are accommodated, remedied, or mitigated to prevent significant residual impacts, including where necessary an exploration of delivering mitigation measures ahead of the development being occupied; and”

“3. Demonstrate that the development complies with the requirements of Policy EN 23: Air Quality and the ‘emissions mitigation assessment and cost calculation’.”

The commentary at paragraph 6.506 (p.486) states “It is an essential objective within national planning policy, as well as in this Local Plan, to ensure that there are sufficient opportunities for sustainable travel as an alternative means of transport to the private car, such as active travel and public transport. New developments will therefore be directed towards areas that are highly accessible, within reasonably close proximity to public transport infrastructure and services”

DLP_8206

Mrs Suzi Rich

Object

I object to this Policy for the following reasons:

Policy TP 1 states that Development proposals must:

“1. Demonstrate that the impacts of trips generated to and from the development are accommodated, remedied, or mitigated to prevent significant residual impacts, including where necessary an exploration of delivering mitigation measures ahead of the development being occupied; and”

“3. Demonstrate that the development complies with the requirements of Policy EN 23: Air Quality and the ‘emissions mitigation assessment and cost calculation’.”

The commentary at paragraph 6.506 (p.486) states “It is an essential objective within national planning policy, as well as in this Local Plan, to ensure that there are sufficient opportunities for sustainable travel as an alternative means of transport to the private car, such as active travel and public transport. New developments will therefore be directed towards areas that are highly accessible, within reasonably close proximity to public transport infrastructure and services”

The sites of proposed developments at Tudeley (AL/CA 1) and the new 8FE secondary school (AL/CA 2) are neither ‘highly accessible’ nor close to any form of ‘public transport infrastructure and services’. They should be removed from the dLP for this reason.

The SWECO Local Plan Transport Evidence Base contains no solution to congestion on the A264 at Pembury, other than to make more use of buses or cycling & alter the traffic signal timings at Halls Hole junction. The proposed A228 strategic transport link (Colts Hill bypass) will lead only to a traffic jam, which will be even larger with the influx of thousands of extra cars. Traffic already backs up to East Peckham on the A228 in the morning due to the volume of traffic attempting to navigate the roundabouts linking this road to the A21 or travel into Royal Tunbridge Wells. A Bypass will not improve this.

The SWECO Local Plan Transport Evidence Base Figure 9-2 shows the ‘Mitigation Interventions Mapped’ (p.142) which shows the proposed routes for the following ‘highway measures’ detailed in Table 9-2 (p.138):

“202 New bypass link of Colts Hill - Reduce congestion at key junctions + match link capacity and link quality to adjoining Pembury bypass standard”

“203 Link road to new Colts Hill Bypass Will remove through highway trips through Five Oak Green”

It is unclear why TWBC believes that people living at Tudeley New Town will need to travel to the Colts Hill Bypass via a link road. They can access Tonbridge, Tunbridge Wells, London or the South via the A21 which runs almost parallel to the proposed route. To travel West to Paddock Wood or Maidstone, a more sensible route for a link road would be North of the railway line to meet the A228 where it is dualled before East Peckham. Why would anyone need to travel to Colts Hill? A link route following the current proposed route would be disastrous.

[TWBC: See comments DLP_8189-8214 for full representation]

DLP_75

The Access Group

• The introduction of electric vehicles and greater use of cycles will require a major design change in all our highways. The Department for Transport have made clear that pedestrians must be protected from all vehicles. The use of shared space is to be banned as existing figures indicate that in the UK it is too dangerous. Electric vehicles are currently silent making them a serious danger to people with hearing and visual impairments. Until such time as the DfT introduce a regulation under the Construction & Use Regulations to introduce a "limited noise", they like pedal cycles will need to be kept totally separate from both pedestrians and other vehicles. This will require a total redesign of our road network

DLP_1882

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Number: TP 2 Transport Design and Accessibility

We support the phrase ‘safety for all users’, but it is vulnerable road users – pedestrians and cyclists – whose safety must be prioritised above other road users and whose needs are currently relegated below those in motor vehicles – witness unsuccessful attempts to improve pedestrian safety features at Carrs Corner.

TP2 is too prescriptive in its adherence to specific guidance documents. The Manual for Streets (published 2007 and updated 2011) is now outdated and the Plan should instead refer to the latest second generation design standards the CROW manual (2017 edition) and/or the London cycle infrastructure design standards. Since this Local Plan has a 20 year life it seems unwise to prescribe by documents that are already over 10 years old in a fast changing transport environment.  Furthermore, a one size fits all approach in the context of the constraints of the transport environment in RTW is not appropriate when better design advice is available. While the prescribed documents are an essential reference, officers should have the ability to reference other relevant advice as appropriate.   We suggest therefore the text of TP2 should be amended from ‘in accordance with’ (specific documents), to ‘with reference to (specific documents) and later guidance as appropriate.’

TP2 ignores the safety benefits to cyclists and pedestrians of 20mph speed limits introduced with or without other traffic calming features.  Speed limits in new developments should be no higher than 20mph.

TP2 needs to ensure that new developments do not permit rat-running but ensure permeability for walking, cycling and sustainable travel.

The use of the phrase "swept path" should not be an excuse for unnecessarily wide ‘bellmouth’ junctions. The latest design standards emphasise junctions which have radii as tight as possible to ensure slow turning speeds and, therefore, safety and convenience for vulnerable road users, increasing the likelihood of people choosing active travel.

A  Policy on Transport Design and Accessibility should specifically provide that storage areas for bicycles should be provided in all cases and that the areas should be covered, suitable and easily accessible on the level to encourage maximum use.

The phrases ‘if located on’ and ‘development is accessible to all and permeable to all modes of transport, with priority to active travel’ are too weak.  Being accessible to all means that residents in a new development must be able to reach their destination by active or sustainable travel.  The developer should pay for / make contribution to:

• Complete walking and cycling routes to likely destinations within (say) 2 miles. (E.g. Developers at Hawkenbury should have had to pay for / made substantial contribution to a route to the station / town centre);
• Contributions to walking / cycle routes in places which are likely to receive traffic from the new development. For example, improved cycling infrastructure on the Pembury Road from new developments in Paddock Wood; and/or
• Contribute to establishment and maintenance of bus routes to enable sustainable journeys of up to (say) 10 miles

There is a moratorium from the DfT on shared space.  While it can work in certain circumstances and may be a useful compromise, the preference should always be to provide safe and convenient infrastructure for pedestrians and cyclists and public transport.

DLP_3383

Kent County Council (Growth, Environment and Transport)

Highways

Paragraph 6.512 - The recommended amendments are as follows:

“The design of new development plays an important role in making it a sustainable place. Good design will ensure it is safe for all users and reduce the impact on the surrounding road network, as well as creating a high quality built environment that enhances the public realm and conserves the character of historic routes and the public realm, which greatly contribute to the attractive character of the borough. Equally, the design of our neighbourhoods can influence physical activity levels, travel patterns, social connectivity, mental and physical health, and wellbeing outcomes. The Council will apply the appropriate highway guidance on an individual scheme basis that takes into account local context….”

The above amendment has removed the list of documents for reference as this is not a conclusive list and is likely to change during the plan period.

Paragraph 6.513

The recommended amendments are as follows:

“All developments must also be designed in a way that accommodates and enables sustainable travel, including active travel and public transport as alternative modes of transport to the private car. Developments must therefore have safe and secure accessibility for all modes of transport, as well as ensuring permeability through the site, including, where possible, maintenance and enhancement of, and/or linkages to, public footway network, public rights of way or the local strategic cycle network.”

The rest of the paragraph is not considered required by KCC as it repeats that which has already been covered.

Policy TP 2

The following amends are recommended:

Paragraph 1 – “The development is accessible to all and permeable by all relevant modes of transport, with priority given to active forms of travel in accordance with the Kent County Council’s Design Guide . This will include suitable arrangements for access by large vehicles. This will take account of public transport (buses), goods, emergency, and waste collection vehicles for delivery, servicing, and drop-off. The development must also be able to accommodate the swept path of vehicles on proposed new infrastructure. This should include the largest vehicles expected to access the area; and”

Paragraph 2 - There is pedestrian access to public transport services and infrastructure;

Paragraph 3 – “If located on, or adjacent to, an identified cycle route, the development will provide a segregated link to (via the development site), the cycle route with reference to the Council's latest Cycling Strategy. Maintenance will be delivered through commuted sums to Kent County Council; and)”

Paragraph 4 - The existing public footway network and the public rights of way network should be safeguarded. Any re-routing of these will be permitted provided that the network is overall enhanced. The development should provide new footway links to connect to or enhance the existing local network. Where appropriate, financial contributions to improvements to off-site public rights of way, including signage, will be sought; and

Paragraph 5 - “Roads and junctions within the development, and those to be altered or added as a result of the development, are designed and delivered in…”

Public Rights of Way and Access Service

Paragraph 4 reads that PRoW diversions to enable development will only be permitted if the overall network is enhanced. While the intentions of this statement maybe positive, the text will need to be revised. This is because it may not always be feasible for development to positively enhance the overall PROW network. Suggested text below:

“Where already in existence, the PRoW network should be safeguarded. Development should secure positive outcomes for the PRoW network, adhere to good design principles and contribute towards the delivery of ROWIP objectives. Opportunities should be taken through development to enhance the PRoW network, including improvements to signage, surfacing and the creation of new path links that improve connectivity. Where appropriate, financial contributions for off-site PRoW improvements will be sought”

It is also requested that additional text is inserted into the policy wording, stipulating that applicants for new developments engage with the KCC PRoW and Access Service at the earliest opportunity. This would allow the County Council to review proposals for access improvements (including PRoW diversions) and consider appropriate financial contributions for off-site PRoW network enhancements.

DLP_4212

Tunbridge Wells District Committee Campaign to Protect Rural England

Support with conditions

The wording in paragraph 4 should be strengthened by deleting “consider creating” and inserting “create” and by deleting “sought” and inserting “required”.

In paragraph 7 developers should not only be required to investigate amending external speed limits but also to fund such amendment, where amendment is necessary.

DLP_4378

British Horse Society

Support with conditions

Point 4 should include a requirement particularly to improve horse riding routes.    As regards point 6, the importance of Riding for the Disabled for people with disabilities is worth noting.  It is often the only outdoor sport that people with severe disabilities that mean they are unable to self-propel a wheelchair are able to undertake.

DLP_6627

AAH Planning for Future Habitat Ltd

Transport

Policy TP 2 – Transport Design and Accessibility

Policy TP 2 sets out a range of criteria which every development is required to meet. Whilst our Client is broadly supportive of this policy, we would like to reiterate that the requirements must be subject to viability to ensure that new development can be deliverable.

Our Client is committed to ensure that new development is supported by suitable infrastructure to ensure that schemes are highly accessible and sustainable long-term. This means supporting access by all modes of transport to ensure permeability and integration with adjacent uses. This needs to be set against viability and our Client therefore seeks flexibility in the wording of the policy.

Other Policies

Our Client does not have any specific comments in relation to other policies within this section of the Consultation Draft but reserve the right to comment at a later date.

[TWBC: see full representation and site plan attached].

[TWBC: see also Comment Nos. DLP_6606-6620, 6622-6627].

DLP_6694

Gladman

6.19 Policy TP2: Transport Design and Accessibility

6.19.1 The policy establishes the transport related design and accessibility principles for all new developments and requires full compliance of listed criteria. As set out above, this universal requirement ignores the variation in scale, type and scope of developments which might be submitted and considered within the plan period. As such there is need for flexibility with the policy for criteria to apply only where relevant to the submitted development and stage of the planning application process.

6.19.2 It should be recognised within the policy that the diversion of public rights of way or highways forms a separate process to the planning application system with advice provided as to how and when to engage in this process. This will improve transparency and reduce the potential for misunderstanding. It is acknowledged that there are material planning issues related to the diversion or stopping up of public rights of way or highways and as such the reference made in the policy is considered sound.

[TWBC: see full representation attached].

[TWBC: see also Comment Nos. DLP_6656-6695]

DLP_6935

Barton Willmore for Crest Nicholson

Support with conditions

7.40 We are encouraged by the requirement to embed good transport design into new development, however as written the policy is lengthy and lacks precision, and much of the contents read more as guidance rather than a policy. On this basis we consider the policy should be refined to better reflect National policy and consider whether some of the info should be relocated into supporting text rather than policy.

[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_7340

Campaign to Protect Hawkhurst Village

Object

For the purpose of paragraph 2 the Council needs to be far clearer on what it considers will constitute “reasonable close proximity” and specify different distances for different types of infrastructure – for example distances to primary schools.

DLP_8169

Highways England

Para 6.511

This paragraph addresses the issue of cumulative development and states: Where appropriate, new development proposals will be expected to enter into legal agreements to secure the delivery of mitigation to address both their direct and cumulative impacts on the transport network.

This needs to be combined with text emphasising that as part of all submitted Transport Assessments or Transport Statements, the cumulative impact of both proposed and programmed development is assessed, and as necessary supported by WebTAG compliant modelling work.

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

DLP_1708

Brenchley and Matfield Parish Council

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

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

[TWBC: part of whole comment number DLP_1683].

DLP_1764

Horsmonden Parish Council

PolicyTP3- Parking standards: We welcome this policy’s introduction of higher parking standards for housing development in rural areas, including the provision of electric vehicle charging points. In the past, KCC standards have under-provided parking, resulting in increased pressure for on-street parking, more congestion for traffic, and road safety problems.

DLP_1883

Royal Tunbridge Wells Town Forum

Support with conditions

Policy Number: TP3 Parking Standards

We broadly support the Residential Parking Standards Topic Paper and recognise that considerable work has gone into extracting data from the 2011 Census.  However, we consider that much more evidence is needed about the total supply and demand for parking in Royal Tunbridge Wells at different times of the day and on different days.  For example, not only is it recognised that there are many spare spaces in the Multi Storey Car Parks at present,  but it is also true that at ‘off-peak’ times, MSCPs are frequently almost empty.

Parking needs to be considered as part of the overall policy to increase active travel.  "Providing adequate parking" is exactly the type of policy which will ensure more car travel.  More car parking => less dense developments => more land taken => more car use (distances are further).  The Local Plan should give preference to developments that enable a reduction in car use.

We recommend a detailed study into the car parking needs of Royal Tunbridge Wells as a matter of urgency and the proposed parking standards should not be adopted within the Local Plan before the results of that study can be assessed.

However, we recognise that the constraints on parking within RTW are incorporated into TP3 and that the new zones A, B and C reflect different parking standards. So:

1. We are concerned that some flexibility is needed beyond that stated. For example, RTW needs many more affordable homes which are likely to be 1 or 2 bedrooms for which one parking space is provided. This fails to take account of potential occupants such as tradesmen and service personnel whose workplace/office is often their van which may need to be parked near their home together with a family car thus 2 spaces.
2. We are concerned that the table “Maximum Parking Standard Per Use Class” does not fully take account of the known trend in office design and technology to reduce office space per person. The UK average office space per person is now at 5sq m as a minimum. Using the Plan’s standards without also recognising the likely occupier use and staffing levels results in under provision of onsite parking and the damaging overspill on street parking in residential roads as experienced in Hawkenbury.

We are concerned that use class D1 which includes schools is not included particularly as primary and secondary schools are required to be built to accommodate the growth in this plan period.

The words ‘where possible’ in ‘cycle parking where possible' should be deleted and ‘encourage’ should be replaced by 'enable'.  We would recommend adoption of Cambridge City Council “Cycle Parking guide for new residential developments” February 2010 instead of Kent County Council's SPG4. This guidance includes provision of easy to access secure cycle parking for residential and commercial developments. All residential cycle parking should be sited in a manner that encourages the use of a cycle as first choice for short trips. It should always be placed as close as possible to the main entry/exit points with step free access.

The Policy should prevent EV charging points on pavements and prevent cables across pavements.

DLP_1968

Ms Jacqueline Stanton

Support

TP3:

The Plan must ensure adequate parking which has not been the case in the past.

DLP_1984

Mr Jeremy Waters

Support

Support

DLP_2383

TWBC Property and Estates

TWBC

Object

TP3

It should be made clear that this policy is for new developments and will not be applied retrospectively as it would result in the loss of parking spaces. If it is intended to be applicable to existing car parks, some guidance as at what point it would apply would be useful, where for example, existing public car parks are being adapted or upgraded.

DLP_2658

Benenden Parish Council

Support

Policy TP 3 - Benenden Parish Council supports this policy for parking and the specific reference to a "made NDP" taking priority on parking standards.

DLP_3390

Kent County Council (Growth, Environment and Transport)

Highways and Transportation

It would be beneficial if KCC standards and Borough Council’s proposed standards converged. In line with proposed new KCC parking standards, this would mean a requirement of two spaces where TP3 asks for 1.5 spaces, and bringing the 2.5 spaces for a 4-bed house down to 2 spaces. It is suggested that the word 'Mandatory' is changed to 'Maximum' to allow less parking where appropriate.

Also, it should be noted that the new KCC Parking standards state: In suburban and rural locations in particular, the Local Highway Authority will not count garages as formal car parking spaces.

DLP_3669

Lynne Bancroft

Support with conditions

Purely on observation, it would appear that car parking facilities for new developments are inadequate so the number of parking spaces for each type of residence should be increased.

DLP_4018

Lamberhurst Parish Council

Support

TP3 – Parking Standards

Support higher parking standards, and the provision of electric vehicle charging points for developments in rural areas. Rural developments need more car parking spaces per dwelling, and also visitor parking areas, as there is limited access to public transport alternatives.

DLP_4213

Tunbridge Wells District Committee Campaign to Protect Rural England

Support with conditions

We generally support this policy but suggest that for clarity and particularly in view of the Borough’s ageing population it should also state the proportion of parking spaces that will be required to meet the parking standards for wheelchair adaptable or accessible dwellings (Building Regs M4(2) and M4(3)), both for market housing and for affordable housing.

DLP_4314

White Young Green Planning for Standard Life Investments UK Real Estate Fund

Object

Policy TP3 – Parking Standards

Similar to other policies within the Draft Local Plan, the Policy TP3 (Parking Standards) includes an unnecessary level of guidance, rather than forming a concise and deliverable policy. Listing out parking standards within policy is unwarranted. It is recommended that a Supplementary Planning Guidance (or an appendix of the Plan) is prepared to expand on a condensed policy. For example:

“Secure and well-designed parking will be sought in accordance with the Council’s Parking Standards Supplementary Planning Guidance”.

The wording of the policy is not deemed ‘positively prepared’ or ‘effective’ and therefore remains ‘unsound’ in its current form, therefore should be amended as advised above.

DLP_4724

CBRE Ltd for Dandara Ltd

Support with conditions

Dandara Comment 

Dandara supports the Council’s Parking Standards, including the acknowledgement that there may be justification for reduced standards as part of the comprehensive approach to the sustainable expansion of Paddock Wood However, the requirement for 15% of spaces to accommodate light goods vehicles should be removed as it is too prescriptive and such requirements should be determined on a site by site basis.

Suggested Policy Amendment(s) 

No revised wording proposed.

DLP_4819

DP9 Planning Consultants for Prime Finance (Tunbridge Wells) SARL (Elysian Residences)

Support with conditions

Whilst we are supportive of the majority of the parking standards outlined within TP3, some of the targets are considered to be an overprovision, especially in town centre locations, where sustainable forms of transport including public transportation should be encouraged.

Within Zone A, the Royal Tunbridge Wells Town Centre Parking Area, Policy TP3 prescribes a mandatory 1 car parking space per unit, for 1-bedroom flats and houses. It is considered that at present and within this central location, this quantum would represent an overprovision. Furthermore, it is considered that providing this level of provision in a central and well-connected area would not represent the most efficient use of land, contrary to policy H4 in relation to Housing Density. As such, we recommend that this quantum of provision be relaxed and amended, so that 1 car parking space per 1-bedroom unit marks a maximum provision, rather than a mandatory one.

Furthermore, it is considered that the parking quantums targeted for commercial developments also represent an overprovision. Policy TP3 states that for A1/A2/A3/A4/A5/B1 development, 1 car parking space per 2 staff should be provided. We consider this to be a large overprovision, especially in town centre areas that are well connected by public transport. Again, meeting this targeted quantum in town centre locations would be contrary to Policy H4, and would not represent the most efficient use of land within these locations. As such, we recommend the following wording amendment to the policy within the ‘Non-Residential Parking Standards’ section:

‘’* These use classes are also required to deliver one space per two staff in addition to the standard set out above, when located outside of town centre areas.’’

We are supportive of the ‘Exceptional Circumstances’ section of Policy TP3, which affords some flexibility to the standards as outlined in the event that they cannot be met. In particular part 3, which states that where an occupier or potential operator requires either more or less parking spaces to cater for their specific needs, a justification for a departure from policy may be acceptable. It is considered that this element of Policy TP3 is positive, as it allows for the future demands of the market in relation to parking standards to be met through the policy.

In relation to cycle parking quantums, Policy TP3 states that for both residential and non-residential development, all developments must accord with the minimum standards outlined within Kent County Council’s SPG4. As worded, the policy is unclear as to whether the exceptional circumstances apply to cycle parking standards, as well as car parking standards. It is considered that some flexibility should be afforded to cycle parking standards, because it is not always achievable, nor required, that all development provisions the relevant standards. For example, if a specific operator did not have a need for the targeted quantum of cycle parking, but was forced to provision it in line with the policy, this may result in unused space within the development, which would be contrary to Policy H4 in relation to density. As such, it is recommended that the wording of the policy is clear, so that the exceptional circumstances section applies to both car and cycle parking, in line with the amended wording below:

‘’In exceptional circumstances, the Local Planning Authority may require proposals to depart from the car and cycle parking standards of both residential and non-residential developments if any of the following apply…’

DLP_6414

Hawkhurst Parish Council

Object

Hawkhurst should not be included in Zone B. Residents in Hawkhurst are reliant on their cars. There are limited employment opportunities, especially those that would enable residents to afford to buy the houses in the village. The bus service cannot be relied upon to get to work. There is no bus service to the local train station. The roads are too dangerous for cycling and the topography is not conducive to walking or cycling. Parking is already a significant issue - many residents have no option but to park on the roads. Any future development must be able to fully accommodate all of the parking requirements. Given its location, Hawkhurst needs to be part of Zone C. In practice, the Zone C residential minimum parking standards are too low for Hawkhurst.

DLP_6936

Barton Willmore for Crest Nicholson

Support

7.41 The approach adopted in Policy TP3 is reflective of and consistent with the NPPF Policy 105, as it takes account of a range of factors when determining parking provision, including accessibility, the type of housing and the opportunities for promoting sustainable transport alternative.

[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_7014

Turnberry for Hadlow Estate

Object

[TWBC: this comment relates to representations on AL/CA 1: Tudeley Village].

Policy TP3 - Parking Standards

Accommodating the motor car is a key challenge in any development, particularly those which are seeking to reduce the impact of the simplification and reducing effect that the car has on our urban environments. In responding to this challenge, masterplanners need more flexibility and the capacity to innovate and demonstrate how their solutions can achieve a balance between convenience and good quality design.

We are therefore concerned that Policy TP3 is going beyond specifying standards and is trying to preconfigure the design process with immoveable redlines such as:

- Banning tandem parking unless no onstreet parking is available;

- Specifying how many open sides a parking barn must have; and

- Suggesting parking courts should be located next to open spaces.

The Policy is going beyond guidance to stipulating a design response and this is not positive planning. It also fails to acknowledge the principle of using design to steer people towards a pattern of use or activity that is more beneficial. For instance, a lack of use of tandem spaces may increase onstreet parking which is desirable in terms of providing ‘side-friction’ which in turn, slows down drivers. If there is insufficient parking then residents have the choice to utilise their tandem driveways. Excessive, convenient parking has the contrary effect of increasing speed along roads with limited ‘side-friction’ and reducing the definition of front boundaries. The current policy is too simplistic and negative and therefore is unsound. We suggest these matters are best left to a supplementary guidance document which can explore good and bad examples of the issues identified above.

[TWBC: see full representation].

[TWBC: see also Comment Numbers DLP_6996, 7003-7009, 7013-7017 and SA_128]

DLP_7065

Sigma Planning Services for Rydon Homes Ltd

Object

39. The proposed policy is too restrictive and will result in car dominated designs and layout which is not an efficient use of land, runs contrary to good design practice and encourages the use of the private car - particularly accepting and encouraging the trend for cars to be larger and more cumbersome.

40. The policy is too detailed and complex, leaving little scope for flexible design approaches tailored to the individual circumstances and character of the development proposal. It is also inconsistent in seeking soft landscaping to ameliorate the domination of new development that is created by the policy itself. The combination of larger and a greater number of spaces together with soft landscaping to compensate will result in very poor quality, car dominated and land hungry development.

41. The policy is at odds with objectives that seek to reduce the use and need for the private car and creates a confusion as to what the plan is seeking to achieve - contrary to NPPF guidance.

42. The need to identify exceptional circumstances is an admission of the shortcomings of the proposed policy but does not address the problem because it cannot envisage all such circumstances and therefore is not an exclusive list. Furthermore, it makes a judgement as to compliance with the policy more complicated and complex which is contrary to the objective of making planning policy clear, effective and comprehensible to all users.

43. The policy requires radical revision to make it simpler and clearer and to avoid the inevitability of creating repetitive, car dominated housing layouts.

[TWBC: See attachment for full response]

DLP_7087

Brown & Co Planning Ltd for The Hendy Group

Support with conditions

Policy Number: Policy TP 3 - Parking Standards

Comments; Support with conditions

1.105 Our Client supports the parking standards, however, this policy needs to be flexible where there is limited land available in urban areas, such as our Clients site on Mount Ephraim, which is in a sustainable location.

Exceptional circumstances

1.106 The exceptional circumstances could potentially cause problems down the line as overcomplicating the standards could lead to sites not being deliverable and stifling development.

Support subject to the following amendments:

* The parking standards should be a maximum to encourage sustainable travel.

* Simplify/remove the exceptional circumstances case.

[TWBC: see full representation and supporting documents; Park and Ride Feasibility Review and Site Location Plan].

DLP_7100

Richard Hopkinson Architects for J Murphy & Sons and SGN

Object

Policy Number: TP 3 Parking Standards

JMS and SGN question whether the approach to residential parking standards set out within draft Policy TP3:

a) Appropriately reflects the findings of the Residential Parking Standards Topic Paper for Draft Local Plan within the Proposed Residential Parking Standards.

b) Gives sufficient flexibility to allow for the delivery of high-density housing development on appropriately accessible sites.

c) Provides a policy framework that would allow developers and the local authority to maximise opportunities to reduce car ownership levels and increase sustainable transport modes, given that the proposed minimum standards are driven by existing car ownership levels.

In terms of the Standards, the draft Local Plan advises that there are lower levels of vehicle ownership per household in what it defines as Zones A and B compared to the remainder of the Borough but Policy TP3 requires the same parking provision for 1 bed properties (as Mandatory and Minimum rates) across all Zones. This issue is identified in the ‘Residential Parking Standards Topic Paper for Draft Local Plan – Regulation 18 Consultation’ report dated August 2019 on which the Policy TP 3 parking standards are based. In relation to 1-bed properties the Topic Paper also identifies that the level of car ownership for these types of property in Zones A and B is below 1. Having identified the requirement and trend for less parking provision for the central zones and 1 bed properties, draft Policy TP 3 does not provide any flexibility to allow for lower parking provision where there is highly likely to be less demand. This misses the opportunity to provide development suitable for sites with more sustainable transport modes available and with parking appropriate for their size.

This is particularly relevant to the former Gas Works on Sandhurst Road. As noted in representations to draft site allocation Policy AL/RTW29, this site lends itself to high-density residential development that would attract commuters using the High Brooms rail services between London, Tunbridge Wells and Hastings. The Station gives access to the centre of Tunbridge Wells within four minutes and Tonbridge within six minutes. The site is a short distance from the shops, facilities and employment opportunities of the North Farm / Knights Park estates, which could be accessed by active modes of travel. It therefore presents prime opportunity to provide high-density sustainable residential living based on low car usage. It is recognised that this would require a sustainable transport and parking strategy that would put in place robust transport measures to support lower car parking provision, which would be developed through discussion with the Local Planning Authority and Kent County Council. Notably, the Site Assessment Sheet for the former Gas Works on Sandhurst Road within the July 2019 Strategic Housing and Economic Land Availability Assessment states that the “location of site near mainline train station [means] private car use is not essential.”

The minimum parking standards proposed by draft Policy TP3 could undermine the ability to deliver housing at an appropriate density for this site.

Further, it is questionable whether the “exceptional circumstances” listed in the draft Policy are sufficiently broad, as they currently fail to give full regard to the importance of making optimum use of accessible brownfield sites as a planning benefit that, in itself, could override the requirement to deliver the full minimum parking standards.

It is also considered that the national evidence that car clubs lead to a reduction in car ownership should be reflected in the policy, in support of reduced car parking provision (see separate comments on Paragraph 6.525).

JMS/SGN therefore request that:

1. The PolicyTP 3 residential parking standards be reviewed such that they better promote sustainable transport options for accessible sites, including through lowering standards and/or providing greater flexibility in appropriate circumstances; and

2. The exceptional circumstances listed in Policy TP3 be reviewed such that the Council gives greater weight to the delivery of higher density development in appropriate locations and to the opportunity that sites in these locations offer to reducing car ownership levels; and

3. The provision of appropriate access to car club services be incorporated in the Policy as justification for reduuced car parking provision in residential development based on national evidence.

Paragraph 6.525 – Parking Standards (Car Clubs)

Paragraph 6.525 states that there is a lack of localised evidence that car clubs reduce private car ownership and, as such, concludes that under-providing parking space as an exceptional circumstance based on car club provision cannot be justified.

The draft Local Plan, however, highlights national evidence (included in the Carplus Annual Survey of Car Clubs (2015/16) for England and Wales (excluding London)) that car club schemes do reduce private car ownership levels among members of the scheme. That study also highlights the growing role that car clubs play in improving air quality.

The draft Local Plan does not provide any evidence that Tunbridge Wells falls outside the national picture in this respect. Given that the increase in parking spaces for larger homes is justified on the basis of national evidence from the National Census, it is unclear why national evidence in relation to car clubs is set aside.

In light of the lack of evidence to the contrary, it is requested that TWBC review its approach to car club usage as an effective way of reducing car ownership and, as such, as an exceptional circumstance to justify lower provision of car parking.

DLP_7117

Williams Gallagher for Canada Life Ltd

Policy TP3 – Parking Standards

The policy states a mandatory provision of parking for residential developments within the Town Centre Parking Area. It is unclear why this is set out as “mandatory” as opposed to the “minimum” requirement in other areas of the borough. It is unclear whether, for example, the Council would accept more or less parking should the developer consider it necessary for the success of the development or to meet other sustainable transport considerations.

The exceptional circumstances listed states that the Council “may require” proposals to depart from the provisions of the policy in stated circumstances however, this provision does not extend to a request from a developer where the Council does not require divergence. We would suggest that a more appropriate wording would be “…..the Local Planning Authority may accept proposals which depart from….”

In addition, a requirement that 15% of parking spaces should be larger than average to accommodate light goods vehicles is overly onerous and takes no of account individual development characteristics. For example, in a traditional housing development, dwellings will have parking spaces and there will also be street space for such vehicles for deliveries etc. For flatted development, there is usually an area of communal (including allocated) parking. The design of the parking area should include sufficient space for such a vehicle to be able to park and manoeuvre without requirement for specific sized spaces to be provided. Similarly, in other instances, an area may be designed and designated for use by delivery vehicles. This should be sufficient to not require the proposed provision.  It is therefore suggested that this element of the policy be deleted and replaced by a more general requirement for appropriate provision to be made for light goods vehicles.

It is our view that imposition of onerous parking requirements for developments within highly sustainable town centre locations that have excellent sustainable transport options could result in the restriction of development aspirations that will rely upon the densification of development in the Borough and potentially reduces the feasibility of meeting housing need in the future.

We trust that you find these comments constructive and look forward to on-going dialogue with the Council. Please keep us informed of progress with the local plan preparation.

Should you have any queries, please do not hesitate to contact us.

[TWBC: see also Comment Nos. DLP_7102-7117].

DLP_7666

Mr J Boxall

Support with conditions

Policy Number:   TP 3

Purely on observation, it would appear that car parking facilities for new developments are inadequate so the number of parking spaces for each type of residence should be increased.

DLP_8403

Mr Raymond Moon

Object

Policy TP 3 & Policy TP 4 OBJECT.

Public Car Parks

Parking Standards & Public Car Parks.

As part of the “ joined up” thinking for the TWBC retail centres and their regeneration it should be policy to reintroduce “ free” parking” in PW as was previously in place. This will increase footfall in the town centre and support our local shops. This policy should also include a Public Transport network fit for purpose and affordable to encourage more visitors not using their cars in the town centre.

DLP_8420

Paddock Wood Labour Party

Object

Policy TP 3 & Policy TP 4 OBJECT.

Public Car Parks

Parking Standards & Public Car Parks.

As part of the “ joined up” thinking for the TWBC retail centres and their regeneration it should be policy to reintroduce “ free” parking” in PW as was previously in place. This will increase footfall in the town centre and support our local shops. This policy should also include a Public Transport network fit for purpose and affordable to encourage more visitors not using their cars in the town centre.

DLP_964

Mrs A Marley

General Observation

There is no evidence of forward planning for new car parks in Cranbrook and Sissinghurst which will be essential if 900 estimated new homes will be built in the immediate future.

DLP_1884

Royal Tunbridge Wells Town Forum

Object

Policy Number: TP4 Public Car Parks

While we endorse the findings of the Parking Topic Paper which shows that the current car park capacity in RTW is more than adequate with 1279 parking spaces empty on average every day, we strongly OBJECT to this policy. It requires that any proposed developments on existing car parks should replace all spaces lost in all circumstances. This goes against the Local Plan’s ambitions for more walking and cycling, car club, cycle sharing and other schemes in RTW, and leads to the development of additional car parks in an already constrained area, adding to congestion and pollution unnecessarily, given the predicted changes in transport requirements within the Plan period.

DLP_2387

TWBC Property and Estates

TWBC

Support with conditions

TP 4

It is hoped that this policy would be applied sensibly. Where there is development potential that could be realised, with parking being reprovided elsewhere for example. Or where there is scope for rationalisation of land to achieve improvement.

DLP_3392

Kent County Council (Growth, Environment and Transport)

Support

Highways and Transportation

The Local Highway Authority is supportive of this policy.

DLP_4019

Lamberhurst Parish Council

TP4 -  Public Car Parks

The Public Car Park below the Brown Trout off the B2169 on Lamberhurst Down has been omitted from the plan. It is not provided to primarily serve a private property. Please ensure that it is included in the new plan as a public car park. It has been provided by Lamberhurst Parish Council to help alleviate parking congestion on The Down and along the road past the Brown Trout at Down Avenue corner. This is a narrow stretch of road with no pavements and little room for off road parking. It is designated as a public car park under the current plan for this reason. If the parish council decide to close it the road will become seriously compromised again

DLP_4040

Dr P Whitbourn

Object

I have very serious concerns indeed about Policy TP4 in relation to the Fairground Site car park off Major York's Road on Tunbridge Wells Common, the site in question having the notation TP4 shown on the Royal Tunbridge Wells Town Centre Draft Policies Map.

Tunbridge Wells Common is a precious asset bringing, as it does, countryside character right into the heart of the town, and planning policy should be absolutely and firmly set against any new building encroachment. Yet, as currently indicated in the Draft Plan, Policy TP4 suggests that development could be allowed if it meets just one of four criteria on offer.

Thus it would appear that a opportunity could be presented for a wily applicant to devise a mixed use scheme incorporating enough car parking, and then to manufacture an argument that it accords with the notation TP4 on the Local Plan. Such an alarming state of affairs cannot, I hope, be allowed to reach the next stage of the Local Plan. The TP4 notation on this particular site needs to be replaced with a site specific notation and a related policy especially designed to meet the particular circumstances of an almost accidental, and originally supposedly temporary, location on the Common.

A fresh notation might, for example, be TP4a, and a policy:

The fairground car park, on Tunbridge Wells Common, off Major York's Road, must not be extended or built upon and, in the event of it not being required for its present purpose in the future, the site should revert to being open common land.

Please see also separate comments under OSSR 1 [TWBC: See comment DLP_4041].

DLP_4214

Tunbridge Wells District Committee Campaign to Protect Rural England

Support with conditions

Some public car parks appear to have been omitted from the map, for example only one is shown at Brenchley whereas there are two (one in the village centre and one at Market Heath).  This needs to be corrected.

We have reservations about paragraph 4 of the draft policy.  This should be amended to read “The community benefits arising from development on the public car park substantially outweigh the harm caused from the loss of public car parking spaces”.

DLP_4289

RTW Civic Society

At first sight, this policy looks reasonable. However, we note that the car park on what was the fairground site on the common is marked on the map as being a TP 4 site.  As mentioned earlier, this draft Local Plan doesn’t make any reference to the Common and, specifically, there is no statement to say that any and every development on the common is prohibited.  Now, there may well be the feeling that the Acts of Parliament and the fact that the common is registered, should mean it is protected.  However, we understand from the Conservators that they do not have the funds to obtain a legal opinion to confirm if this is true.  The owner of the common might be in a better financial position to argue that a development would be allowed.  If what the owner wished to do was completely consistent with the adopted Local Plan then this could only strengthen his case.

The rumour is that the owner might wish to build a five-storey structure, possibly with underground parking so that there would be at least as much public car parking provided with flats on the upper storeys.  Such a development would be completely consistent with policy TP 4 as it would meet the “get out” criteria no. 1.  Other policies regarding new buildings eg. matching the height of surrounding buildings would easily be met  - the new building on Union Square would be much taller and the developer would undoubtedly use expensive bricks.

DLP_8404

Mr Raymond Moon

Object

Policy TP 3 & Policy TP 4 OBJECT.

Public Car Parks

Parking Standards & Public Car Parks.

As part of the “ joined up” thinking for the TWBC retail centres and their regeneration it should be policy to reintroduce “ free” parking” in PW as was previously in place. This will increase footfall in the town centre and support our local shops. This policy should also include a Public Transport network fit for purpose and affordable to encourage more visitors not using their cars in the town centre.

DLP_8421

Paddock Wood Labour Party

Object

Policy TP 3 & Policy TP 4 OBJECT.

Public Car Parks

Parking Standards & Public Car Parks.

As part of the “ joined up” thinking for the TWBC retail centres and their regeneration it should be policy to reintroduce “ free” parking” in PW as was previously in place. This will increase footfall in the town centre and support our local shops. This policy should also include a Public Transport network fit for purpose and affordable to encourage more visitors not using their cars in the town centre.

DLP_765

Dr P Whitbourn

Support

I strongly support Policy TP5 regarding safeguarding Railway land. The rail route to London via Sevenoaks does not have unlimited capacity, and the time will come when other possible alternative routes will have to be seriously investigated, with use made of the Tunbridge Wells to Eridge pathway. Clearly, it was very short sighted to close this line in the first place.

The Paddock Wood to Hawkhurst pathway should also be safeguarded, especially as the dispersal option seems increasingly likely to be needed if the high housing numbers required by central government are to be met.

DLP_1765

Horsmonden Parish Council

Support

Policy TP5: Safeguarding Railway Land - We strongly support the policy to safeguard the former Paddock Wood to Hawkhurst railway line (The Hop Pickers Line) as a green infrastructure corridor.

DLP_1885

Royal Tunbridge Wells Town Forum

Support

Policy Number: TP 5 Safeguarding Railway Land 

We support this policy as necessary for future development of rail links to and from Royal Tunbridge Wells particularly from West Kent to the south coast and Brighton via Crowborough, Uckfield and Lewes and to London (Victoria/London Bridge/Canary Wharf) via Croydon and Lewisham. Such new fast public transport routes could have a significant positive impact in reducing commuting by car and on through car journeys for other purposes. The detail of the Policies Map needs to ensure that sufficient land is safeguarded to enable the future restoration of a double track railway with adequate passenger facilities at the West Station, which could become the main rail interchange for RTW.

There is also a case for safeguarding the Hawkhurst to Paddock Wood branch line alignment in its entirety as a future transport corridor, inter alia for use for active travel in the Borough.

DLP_1969

Ms Jacqueline Stanton

Support

TP5:

I suport the safeguarding of the Hop Pickers Line.

DLP_2927

Chris Gow

Pity about Sainsburys locating on the line...

DLP_3393

Kent County Council (Growth, Environment and Transport)

Support

Highways and Transportation

The Local Highway Authority is supportive of this policy.

Public Rights of Way and Access Service

Inclusion of this policy text, that safeguards the ‘Hop Pickers’ Line, is supported.

DLP_3629

Hop Pickers Line Heritage Group

Support with conditions

* The Hop Pickers Line Heritage Group values the help and support already given by TWBC.

* Generally the Group agree with the proposals laid out in paragraphs 6.533 and 6.534 and the conclusions reached about the current condition of the line and its potential as a long distance trail.

* Additional help to further the aims of the HPLHG could be usefully included in the Draft Local Plan:

Financial assistance to complete waymarking and erection of interpretation boards, posts and symbols along the whole route as has already been started by the Group.

Production of a detailed map showing the route and links with existing footpaths and roads so that, assuming that the route of the line itself cannot be reopened, the public can appreciate the landscape through which the route passes.

Any forthcoming developments adjacent to the route of the line should respect the route, linking it with any new rights of way if possible and acknowledging its existence by contributing to the current waymarking scheme.

Promotion of the route as a potential link with existing places of interest such as Scotney Castle and Bedgebury Forest should be encouraged.

Advice from organisations such as Sustrans and heritage groups with relevant specialist knowledge should be sought and applications made to the Heritage Lottery Fund for financial assistance.

It should be assumed that the status of the line carries the same weight along its entire length, irrespective of which parish or town it passes through. No local issues should affect the safeguarding of the line. However, if a town, parish or individual wishes to enhance its status, say with additional signage or through locally produced publicity, this should be encouraged, possibly subject to the approval of HPLHG and TWBC.

* The above comments may mirror the objectives of Paragraph Numbers 6.533 and 6.534 in places. However, their inclusion is intended to emphasise the ultimate aims of HPLHG to reopen the line as a long distance trail.

--- End of comments ---

DLP_3671

Lynne Bancroft

Support

I support this policy, in particular the safeguarding of the route from Paddock Wood to Hawkhurst along the Hop Pickers Line. Development of this will encourage greater tourism into the eastern part of the Borough and provide more economic opportunities.

Bringing the use of the former railway into a cycle path should be funded from any developments at Paddock Wood, Hawkhurst, Horsmonden, Goudhurst and Cranbrook

DLP_3976

IDE Planning for Paddock Wood Town Council

Support

SUPPORT

Para. 6.533 refers to the former Paddock Wood – Hawkhurst (Hop Pickers) Line and which the LPA will safeguard. Support.

DLP_4215

Tunbridge Wells District Committee Campaign to Protect Rural England

Support

Support

DLP_4331

Environment Agency

Fisheries, Biodiversity and Geomorphology

General Maps

A Geographic Information System layer on the Council’s website would have enabled a better review of the allocations and distribution of sites associated with different policies.

Using three similar pale blues to denote Landscape within the Built Environment EN 18, Safeguarded Railways TP 5 and Safeguarded Routes TP 6 makes it more difficult to work out what might be watercourses, other aquatic features or other things altogether.

DLP_4500

Paddock Wood Neighbourhood Plan Steering Group

Support

Para. 6.533 refers to the former Paddock Wood – Hawkhurst (Hop Pickers) Line and which the LPA will safeguard. Support.

DLP_7015

Turnberry for Hadlow Estate

Support with conditions

[TWBC: this comment relates to representations on AL/CA 1: Tudeley Village].

Policy TP5 - Railways

This Policy requires amending to ensure it works effectively with the allocation AL/ CA 1 and promotes its delivery. Under Safeguarding Railway Land, the following should be added:

Tudeley Village

Where identified in accordance with the Masterplan to be developed in respect of Policy AL/CA 1, land either side of the railway line within Tudeley Village will be safeguarded for potential bridge crossings and a potential rail halt and shall not be made available for other uses unless specifically identified in the Masterplan.

A strip of land either side of the railway line should also be added to the relevant Policies Map to align with this amended Policy.

[TWBC: see full representation].

[TWBC: see also Comment Numbers DLP_6996, 7003-7009, 7013-7017 and SA_128]

DLP_7354

Wealden District Council

Support

Policy TP 5 within the Tunbridge Wells Borough Local Plan outlines the need to safeguard railway infrastructure in response to the projected increase in the level of growth and development in the Borough. The existing Tunbridge Wells Central to Eridge railway line is to be safeguarded in the Plan in order that the opportunity to link the London-Uckfield railway line with the London-Hastings railway line is not lost.

Wealden District Council supports Policy TP 5 and similarly recognises the need to safeguard the Eridge Railway line within Policy INF 5 of the Submission Wealden Local Plan (January 2019).

DLP_7667

Mr J Boxall

Support

I support this policy, in particular the safeguarding of the route from Paddock Wood to Hawkhurst along the Hop Pickers Line.  Development of this will encourage greater tourism into the eastern part of the Borough and provide more economic opportunities.

Bringing the use of the former railway into a cycle path should be funded from any developments at Paddock Wood, Hawkhurst, Horsmonden, Goudhurst and Cranbrook

DLP_8405

Mr Raymond Moon

Support

Policy TP 5 SUPPORT.

Railways

Safeguarding Railway Land

The Former Paddock Wood to Hawkhurst (Hop Pickers) Line

6.533. 6.534. This policy is very much welcome in the Draft Local Plan as it safeguards the original Paddock Wood to Hawkhurst ( Hop Pickers) line and acknowledges the work carried out already by the Hop Pickers Line Heritage Group (HPLHG) and ensures support for the future.

DLP_8422

Paddock Wood Labour Party

Support

Policy TP 5 SUPPORT.

Railways

Safeguarding Railway Land

The Former Paddock Wood to Hawkhurst (Hop Pickers) Line

6.533. 6.534. This policy is very much welcome in the Draft Local Plan as it safeguards the original Paddock Wood to Hawkhurst ( Hop Pickers) line and acknowledges the work carried out already by the Hop Pickers Line Heritage Group (HPLHG) and ensures support for the future.

DLP_1611

Maggie Fenton

Policy TP6 Safeguarding Routes

6.535 the council will use its CPO powers to deliver strategic transport links

6.536 A228 Colts Hill. The provision of this section of highways is required to mitigate the impact of development in this plan.

6.538 regard must also be given to the sites location in the AONB & regard given to the Groundwater Protection Zone

The provision of the A228 Colts Hill Strategic link being a requirement for these proposals  suggests the inclusion of both Capel and Paddock Wood within the DLP are unsustainable.

DLP_1886

Royal Tunbridge Wells Town Forum

Object and General Observations

Policy Number: TP 6 Safeguarding Roads

Object and General Observations

We strongly OBJECT to the proposal in TP6 to safeguard land for future improvement/widening of Halls Hole Road. The use of this narrow road as a ‘rat run’ avoiding the Pembury Road at peak times has grown as a direct result of the installation of traffic lights at the Pembury Road end. These lights are themselves a main cause of the congestion that traffic on this ‘rat run’ seeks to avoid. In the recent past, Halls Hole Road and Cornford Lane simply provided access to remote hamlets and farms and could do so again to provide an active travel and leisure route between Pembury and RTW and also to Dunorlan Park. Cornford Lane/Halls Hole Road is part of Route 18 National Cycle Route from RTW to Canterbury which is planned to extend further west. Widening Halls Hole Road will only deliver increased traffic into Hawkenbury causing more danger and pollution for local pedestrians and residents.

We reserve the right to review the proposals for the A228 and A21 when further detail is available at Regulation 19 stage.

While we support the retention of the existing section of the A228 as an active travel corridor, this needs to be designed as a fast commuter route for cycling and provide a complete link from Tunbridge Wells to Paddock Wood. It will be no good as an active travel route if it just gets people through Colts Hill.

DLP_2392

TWBC Property and Estates

TWBC

Object

TP6

There are no details of the 'potential' Halls Hole Road alignments on the proposals map. Nor any guidance on proposed CIL/ s106 contributions. This vagueness makes future planning in the area difficult. Any reasons for refusal would be baseless.

DLP_3394

Kent County Council (Growth, Environment and Transport)

Highways and Transportation

KCC agrees with Colts Hill and A21 safeguarding, as work has been done on possible alignments and feasibility studies have commenced. However, if Halls Hole Road is to feature in this policy, a number of other potential road widening schemes should also feature i.e. Cornford Lane, Reynolds Lane, railway bridge at North Farm etc. Consideration of these are required.

DLP_3674

Lynne Bancroft

Support with conditions

The upgrade and dualling of the A21 from Lamberhurst to Blue Boys should occur before any further development in the Sissinghurst & Cranbrook area.

In addition, road congestion needs to be resolved in Sissinghurst and Goudhurst.

DLP_3718

Capel Parish Council

Object

Capel Parish Council objects to this Policy and to the following paragraphs of the accompanying commentary, for the reasons stated.

The commentary at Paragraph 6.535 (p.498) states that “the Council will use its Compulsory Purchase Order powers if necessary to deliver strategic transport links”.

Paragraphs 6.536-6.538 detail plans for the A228 Colts Hill Bypass stating that “Land is safeguarded for an offline (i.e. new section of) highway, which runs from the dualled section of the A228 at the north of Pembury to a position in close proximity to the existing roundabout between Paddock Wood and Five Oak Green. […] The provision of this new section of highways is required in order to mitigate the impact of development proposed in this Plan, particularly that around Capel and Paddock Wood and Tudeley […] There is the potential that there will be a link from this new section of highway to the development to be allocated at Tudeley, although various potential routes are being considered”

Paragraph 6.537 states that “The route of the new section of highway (A228) has been subject to considerable historic assessment and consideration” and paragraph 6.538 concedes that  “Regard must be given to the Groundwater Source Protection Zone on site and the Environment Agency is to be consulted for advice; regard must also be given to the site’s location in the AONB, and Natural England and other bodies must also be consulted”

The provision of the A228 Colts Hill Strategic link being a requirement for these proposals suggests the inclusion of both Capel and Paddock Wood within the dLP are unsustainable without it in place, therefore IF it is to be built, it must be built BEFORE ANY housing development in this area. At present, mitigation work is not set to start on the A228 until 2028, with mitigation work to alleviate congestion on the B2017 following that. This is too late. Capel Parish cannot be expected to suffer the consequences of thousands of houses being built with no infrastructure in place to support them.

This is not to say that Capel Parish Council supports the proposals made under Policy TP 6. Please see our comments under Policy TP 1 in relation to the proposed mitigation measures detailed in the SWECO Local Plan Transport Evidence Base.

The plans for the A228 strategic transport link (Colts Hill bypass) and the bolt-on proposed link route from the proposed development at Tudeley to Colts Hill (Five Oak Green Bypass) are ill-thought out and will result in further significant detrimental impact on the local landscape with little mitigating effect or benefit to residents of the parish of Capel. Just because the route has been subject to considerable historic assessment and consideration does not mean that further consideration of the most appropriate solution for this stretch of road is no longer required. Further assessment must be completed to ascertain whether an offline link is still the most suitable improvement.

Capel Parish Council objects to any residents of this Parish being subjected to Compulsory Purchase Orders in order to deliver either the ‘Colts Hill Bypass’ or ‘Five Oak Green Bypass’. This includes properties situated between the B2017 and Alders Road, which are likely to be dramatically affected if the proposed route set out in Figure 9-2 of the SWECO Local Plan Transport Evidence Base (p. 142) is progressed.

Alternatives to the Colts Hill Bypass (such as widening) and the Five Oak Green Bypass (such as a Northern route to access the A228 nearer to East Peckham as previously suggested by Capel Parish Council) must be considered further before Regulation 19.

DLP_3977

Ide Planning for Paddock Wood Town Council

Support with conditions

Colts Hill bypass.

SUPPORT subject to provision first of a bypass for east of Paddock Wood.

[This policy safeguards land].

DLP_4216

Tunbridge Wells District Committee Campaign to Protect Rural England

Object

While it may appear reasonable to safeguard the proposed routes for the A21 Kippings Cross to Lamberhurst Improvement and the A228 Colts Hill Bypass, CPRE Kent has real reservations about these projects, both of which will involve loss of and substantial damage to important AONB countryside.  We remain to be convinced that either of these projects is really justified.  We acknowledge that there are difficulties with the narrow section of the A228 on Colt’s Hill and with the staggered crossroads with Alders Road/Crittenden Road, but these should be capable of resolution with a largely online scheme, which would be far less environmentally damaging.  Land should instead be safeguarded for a largely online scheme.

DLP_4332

Environment Agency

Fisheries, Biodiversity and Geomorphology

General Maps

A Geographic Information System layer on the Council’s website would have enabled a better review of the allocations and distribution of sites associated with different policies.

Using three similar pale blues to denote Landscape within the Built Environment EN 18, Safeguarded Railways TP 5 and Safeguarded Routes TP 6 makes it more difficult to work out what might be watercourses, other aquatic features or other things altogether.

DLP_4379

British Horse Society

General Observation

Provision needs to be made for safe crossings for horse riders and safe routes for horse riders alongside the proposed major new roads.

DLP_4502

Paddock Wood Neighbourhood Plan Steering Group

Support with conditions

SUPPORT subject to provision first of a bypass for east of Paddock Wood.

[This policy safeguards land].

DLP_6070

Mr C Mackonochie

Support

Paragraph 6.537 – it is worth noting that political and global financial constraints has prevented construction in the past 2 Fatalities with a mile of each other on Colts Hill itself in the last 2 years

DLP_7016

Turnberry for Hadlow Estate

Support with conditions

[TWBC: this comment relates to representations on AL/CA 1: Tudeley Village].

Policy TP6 - Safeguarding RoadsTo align with changes to Policy AL/CA 1, the following adjustments to the supporting text to paragraph 6.536 is needed:

A228 Colts Hill

6.536 Land is safeguarded for a npotential offline (i.e. new section of) highway, which runs from the dualled section of the A228 at the north of Pembury to a position in close proximity to the existing roundabout between Paddock Wood and Five Oak Green; again, land is safeguarded around this for an associated remodelled junction. The provision of this new section of highways is potentially required as a strategic mitigation for in order to mitigate the impact of development proposed in this Plan, particularly that around Capel and Paddock Wood and Tudeley. There is the potential that there will be a link from this new section of highway to the development to be allocated at Tudeley, subject to the development of an appropriate access strategy, which will be brought forward for consultation. although various potential routes are being considered. The final route of this link will be included in the Pre-submission version of the Local Plan, and will be subject to consultation under Regulation 19. It is likely that land will be specifically allocated for the offline A228 strategic link (Colts Hill bypass) section in the Pre-submission version of the Plan.

[TWBC: see full representation].

[TWBC: see also Comment Numbers DLP_6996, xxx and SA_12x]

DLP_7668

Mr J Boxall

Support with conditions

The upgrade and dualling of the A21 from Lamberhurst to Blue Boys should occur before any further development in the Sissinghurst & Cranbrook area.

In addition, road congestion needs to be resolved in Sissinghurst and Goudhurst.

DLP_8141

Ashley Saunders

Object

I objects to this Policy and to the following paragraphs of the accompanying commentary, for the reasons stated.

The commentary at Paragraph 6.535 (p.498) states that “the Council will use its Compulsory Purchase Order powers if necessary to deliver strategic transport links”.

Paragraphs 6.536-6.538 detail plans for the A228 Colts Hill Bypass stating that “Land is safeguarded for an offline (i.e. new section of) highway, which runs from the dualled section of the A228 at the north of Pembury to a position in close proximity to the existing roundabout between Paddock Wood and Five Oak Green. […] The provision of this new section of highways is required in order to mitigate the impact of development proposed in this Plan, particularly that around Capel and Paddock Wood and Tudeley […] There is the potential that there will be a link from this new section of highway to the development to be allocated at Tudeley, although various potential routes are being considered”

Paragraph 6.537 states that “The route of the new section of highway (A228) has been subject to considerable historic assessment and consideration” and paragraph 6.538 concedes that  “Regard must be given to the Groundwater Source Protection Zone on site and the Environment Agency is to be consulted for advice; regard must also be given to the site’s location in the AONB, and Natural England and other bodies must also be consulted”

The provision of the A228 Colts Hill Strategic link being a requirement for these proposals suggests the inclusion of both Capel and Paddock Wood within the dLP are unsustainable without it in place, therefore IF it is to be built, it must be built BEFORE ANY housing development in this area. At present, mitigation work is not set to start on the A228 until 2028, with mitigation work to alleviate congestion on the B2017 following that. This is too late. Capel Parish cannot be expected to suffer the consequences of thousands of houses being built with no infrastructure in place to support them.

This is not to say that Capel Parish Council supports the proposals made under Policy TP 6. Please see our comments under Policy TP 1 in relation to the proposed mitigation measures detailed in the SWECO Local Plan Transport Evidence Base.

The plans for the A228 strategic transport link (Colts Hill bypass) and the bolt-on proposed link route from the proposed development at Tudeley to Colts Hill (Five Oak Green Bypass) are ill-thought out and will result in further significant detrimental impact on the local landscape with little mitigating effect or benefit to residents of the parish of Capel. Just because the route has been subject to considerable historic assessment and consideration does not mean that further consideration of the most appropriate solution for this stretch of road is no longer required. Further assessment must be completed to ascertain wither an offline link is still the most suitable improvement.

I objects to any residents of this Parish being subjected to Compulsory Purchase Orders in order to deliver either the ‘Colts Hill Bypass’ or ‘Five Oak Green Bypass’. This includes properties situated between the B2017 and Alders Road, which are likely to be dramatically affected if the proposed route set out in Figure 9-2 of the SWECO Local Plan Transport Evidence Base (p. 142) is progressed.

Alternatives to the Colts Hill Bypass (such as widening) and the Five Oak Green Bypass (such as a Northern route to access the A228 nearer to East Peckham as previously suggested by Capel Parish Council) must be considered further before Regulation 19.

DLP_8207

Mrs Suzi Rich

Object

I object to this Policy for the following reasons:

Paragraph 6.535 (p.498) states that “the Council will use its Compulsory Purchase Order powers if necessary to deliver strategic transport links”.

Paragraphs 6.536-6.538 detail plans for the A228 Colts Hill Bypass stating that “Land is safeguarded for an offline (i.e. new section of) highway, which runs from the dualled section of the A228 at the north of Pembury to a position in close proximity to the existing roundabout between Paddock Wood and Five Oak Green. […] The provision of this new section of highways is required in order to mitigate the impact of development proposed in this Plan, particularly that around Capel and Paddock Wood and Tudeley […] There is the potential that there will be a link from this new section of highway to the development to be allocated at Tudeley, although various potential routes are being considered”

Paragraph 6.537 states that “The route of the new section of highway (A228) has been subject to considerable historic assessment and consideration” and paragraph 6.538 concedes that “Regard must be given to the Groundwater Source Protection Zone on site and the Environment Agency is to be consulted for advice; regard must also be given to the site’s location in the AONB, and Natural England and other bodies must also be consulted”

Please see my comments under Policy TP 1 in relation to the proposed mitigation measures detailed in the SWECO Local Plan Transport Evidence Base. The plans for the A228 strategic transport link (Colts Hill bypass) and the bolt-on proposed link route from the proposed development at Tudeley to Colts Hill (Five Oak Green Bypass) are ill-thought out and will result in further significant detrimental impact on the local landscape with little mitigating effect or benefit to residents of the parish of Capel. Just because the route has been subject to considerable historic assessment and consideration does not mean that further consideration of the most appropriate solution for this stretch of road is no longer required. Further assessment must be completed to ascertain wither an offline link is still the most suitable improvement.

Why should residents and landowners on the proposed link road routes (on Church Road/Alders Road/Sychem Lane etc) be subjected to Compulsory Purchase Orders in order to deliver either the ‘Colts Hill Bypass’ or ‘Five Oak Green Bypass’? Those that remain are likely to be dramatically affected if the proposed route set out in Figure 9-2 of the SWECO Local Plan Transport Evidence Base (p. 142) is progressed. Alternatives to the Colts Hill Bypass (such as widening) and the Five Oak Green Bypass (such as a Northern route to access the A228 nearer to East Peckham as previously suggested by Capel Parish Council) must be considered further before Regulation 19.

[TWBC: See comments DLP_8189-8214 for full representation]

DLP_8406

Mr Raymond Moon

Object

POLICY TP 6.Road Infrastructure OBJECT.

Safeguarding Roads

Mention should be made to the improvements of the existing Roads in PW and Capel to ensure the proposed new houses are sustainable in the Draft Local Plan. There is a strong argument to provide a new By Pass for PW to the east of PW.

DLP_8423

Paddock Wood Labour Party

Object

POLICY TP 6. Road Infrastructure OBJECT.

Safeguarding Roads

Mention and more detail should be made to the improvements of the existing Roads in PW and Capel to ensure the proposed new houses are sustainable in the Draft Local Plan. There is a strong argument to provide a new By Pass for PW to the east of PW.