Section 6: Development Management Policies – Transport and Parking
This response report contains comments received on Section 6: Development Management Policies - Transport and Parking.
Contents
General comments
Comment No. | Name/Organisation | Section or paragraph number(s) | Response |
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DLP_1802 | Royal Tunbridge Wells Town Forum | Transport Policies Paragraphs 6.506 to 6.540 | We have the following General Observations on these Paragraphs:
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. |
Policy TP 1: Transport Assessments, Travel Plans, and Mitigation
Comment No. | Name/Organisation | Object/support/support with conditions/general observation | Response |
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DLP_1610 | Maggie Fenton | Policy TP1 Transport Assessment, travel plans & mitigation
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:
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.
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: 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 Public transport, Maidstone – 1 bus per hour via Staplehurst Station (45 – 50m) 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 |
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: 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): 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] |
Policy TP 2: Transport Design and Accessibility
Comment No. | Name/Organisation | Object/support/support with conditions/general observation | Response |
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DLP_75 | The Access Group |
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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:
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: 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” | |
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]. |
Policy TP 3: Parking Standards
Comment No. | Name/Organisation | Object/support/support with conditions/general observation | Response |
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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:
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 | 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. | |
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. 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. |
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 [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. |
Policy TP 4: Public Car Parks
Comment No. | Name/Organisation | Object/support/support with conditions/general observation | Response |
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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 | 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. |
Policy TP 5: Safeguarding Railway Land
Comment No. | Name/Organisation | Object/support/support with conditions/general observation | Response |
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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. |
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 | |
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 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. [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. |
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. |
Policy TP 6: Safeguarding Roads
Comment No. | Name/Organisation | Object/support/support with conditions/general observation | Response |
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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 | 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 | |
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: 6.536 Land is safeguarded for a [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: 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. |