Sustainability Appraisal

This response report contains comments received on the Sustainability Appraisal that accompanies the Draft Local Plan (Regulation 18 stage).

Contents

General comments

Comment No.

Name/Organisation

Section, paragraph number or site

Response

SA_3

William Adamson

Spratsbrook farm

Apart from this being green belt, AONB, adjacent to a conservation area and beyond the limit to build the main objections are regarding traffic and air pollution. Between 8pm and 9pm every weekday morning traffic is backed up to Broadcaster Down and you want to introduce another 300 cars and school traffic. The objectors will require to see your traffic and air pollution assesments and compare them with our own experts figures

SA_4

William Adamson

Spratsbrook Farm

Traffic is already backed up to Broadcaster Down between 8 and 9 am every morning and it is proposed to introduce another 300 cars and school traffic.Objectors will wish to compare the Council's traffic and air pollution figures with those of our own experts

SA_6

Thomas Weinberg

Table 13

Comments on Table 13

Why did Horsmonden not have a Sustainability Appraisal? It is outside the AONB and the Green Belt. The claim “severe access difficulties” to site 144 is a false one. The B2162 (Maidstone Road) and Yew Tree Green Road and there are plenty of other sites put forward that could link to it. I am aware the Deputy Leader of the Council lives there but I am sure she would have declared that as a possible conflict.

See images (map and site plan).

SA_7

Thomas Weinberg

Table 16 (Garden Settlement in Capel Parish) p.45

Comments on Table 16 (Garden Settlement in Capel Parish) p.45

[see image]

Air Quality

Scoring Air Quality as Unknown/Mixed is nonsense. This is at best disingenuous. This will cause significant pollution and cause serious health implications. My son’s health will be impacted for the gain of developers and landowners.

The impact on Air Quality in both options should score “Very Negative” as both options will increase traffic substantially on the B2017; an extremely congested road that cannot be widened without numerous CPOs on Grade 2 listed dwellings and the destruction of land within the High Weald AONB.

Biodiversity

You have scored Biodiversity as Neutral/Slightly Negative in Option 1 and Slightly Negative in Option 2. This will destroy Green Belt land and be carried out next to an RSPB Reserve. The impact in both options should score “Very Negative”.

Here is some evidence of the extraordinary biodiversity on the sites you propose to destroy:

There is a healthy population of ash trees within CA1, young & mature. According to UK Chief Plant Health Officer, Professor Nicola Spence, since 2012 the Government has spent £6 million on ash dieback research and finding and preserving healthy trees is vital. There are also some 20 veteran oak trees on the site.

The following specifically protected species are on the garden settlement site:

Noctule, serotine, brown long-eared, common pipistrelle and soprano pipistrelle bats (recorded flying).

There is evidence of BAP, KRDB or other notable species on site:

* House sparrow (red list & KRDB)

* Peregrine falcon (KRDB)

* Spotted flycatcher (red list & KRDB)

Kent Ornithological Society Records show that 70 species of birds regularly rely upon the area within the proposed Tudeley site boundary either over winter or during the breeding season. 53 bird species are considered to breed within the proposed site. 12 of the breeding species are Species of Principle Importance as listed under section 41 (England) of the NERC Act (2006). These species need to be taken into consideration by a public body when performing any of its functions with a view to conserving biodiversity. 10 of the species breeding within the proposed site are also red list Birds of Conservation Concern (BoCC), largely due to significant population decline as a result of habitat loss and change in agricultural practices. Yellowhammer, linnet and skylark (all Species of Principle Importance and Red List BoCC) occur within the proposed site in high densities and all three species are undergoing significant population declines.

Four species of owl also occur in the area – Tawny, Little, Barn and Long-eared - itself an unusually high number. There are only a few breeding pairs of Long eared owls recorded in Kent, two of which may be resident in the area. This would represent a significant number and would be a serious consideration for developers.

Red List is the highest conservation priority, with species needing urgent action. Red List criteria includes (RSPB):

* Species is globally threatened

* Historical population in UK decline during 1800-1995

* Severe (at least 50%) decline in UK breeding population over last 25 years, or longer-term period (the entire period used for assessments since the first BoCC review, staring in 1969)

* Severe (or at least 50%) contraction of UK breeding range over last 25 years, or the longer-term period

21st June 2019: 07:20-11:05

Alphabetical list of bird species observed (by sight or sound)

(UK Red Listed birds highlighted Red / Amber (RSPB) asterisked birds Natural Environment and Rural Communities NERC Act 2006, Section 41: Series of Principal Importance)

Blackbird
Blue Tit
Carrion Crow
Chaffinch
Chiffchaff
Collared Dove
Common Buzzard
Goldcrest
Goldfinch
Great Tit
Green Woodpecker
Greenfinch
Great Spotted Woodpecker
House Sparrows* (red)
Kestrel (amber)
Magpie
Robin
Skylark (red)
Song Thrush* (red)
Starlings* (red)
Stock Dove
Swallow
Swift (amber)
Whitethroat
Wood Pigeon
Yellowhammer * (red)
Butterfly & Moth Species
Cinnabar Moth
Common Blue
Meadow Brown
Peacock
Red Admiral
Speckled Wood

22nd June 2019

Very high numbers of linnet, yellowhammer and skylark present across much of the area; all red list birds. Although late in the breeding season, all three of these species were recorded demonstrating breeding behavior.

Note: Whilst the surveys were carried out in CA1, the situation is broadly similar in terms of bird species in the East Capel site. An annual breeding bird survey is conducted for the BTO and many of the key species are present in this area too.

European Protected Species (EPS)

BATS: records show four species in the area (common pipistrelle, soprano pipistrelle, brown long-eared and noctule); all EU protected species. (KMBRC)

GREAT CRESTED NEWT: recorded at the centre of the proposed Tudeley site. Significant measures would need to be put in place prior to any development, such as a translocation and other additional mitigation.

DORMICE: traps have been seen around the proposed quarry sites, implying that their presence has been identified in the area. The dormice will use hedgerows to migrate into CA1. KMBRC already has records of dormice in East Capel.

NOTE: The presence of these EPS requires mitigation licenses from Natural England for development to go ahead. For each license application developers need to provide a 'reasoned statement'; which needs to state why development must go ahead in these locations, and why suitable, less damaging alternatives are not available with less of an impact on wildlife.

The National Planning Policy Framework states that:

174. To protect and enhance biodiversity and geodiversity, plans should:

a) Identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks….; and

b) promote the conservation, restoration and enhancement of priority habitats…and pursue opportunities for securing measurable net gains for biodiversity.

175. When determining planning applications, local planning authorities should apply the following principles:

a) if significant harm to biodiversity resulting from a development cannot be avoided… adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;

c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists;

d) development whose primary objective is to conserve or enhance biodiversity should be supported; while opportunities to incorporate biodiversity improvements in and around developments should be encouraged, especially where this can secure measurable net gains for biodiversity.

177. The presumption in favour of sustainable development does not apply where the plan or project is likely to have a significant effect on a habitats site…unless an appropriate assessment has concluded that the plan or project will not adversely affect the integrity of the habitats site.
There is no up-to-date Biodiversity Assessment of CA1 to support this Local Plan. The Local Plan and Sustainability Appraisal for Tudeley is therefore unsound.

Climate Change

You score the impact on Climate Change as slightly negative for Option 1 and Slightly Negative/Negative for Option 2. In the current context of a climate emergency this is absolutely ridiculous. The masterplanning will inevitably claim retention of some of these as mitigation, but reducing them to islands surrounded by development is as good as destruction. It is an ecosystem, not individual flora. There should be a deep sense of shame at entirely avoidable destruction of nature and creation of needless pollution.

Heritage

The impact on Heritage has been scored as slightly negative for Option 1 (Tudeley) and Slightly Negative/Negative for Option 2 (Tudeley and the hamlet of Capel). Again this is inaccurate.

Capel and Tudeley are small hamlets, with traditional buildings clustered around the Grade I Listed sandstone churches and full of Grade 2 listed barns and oasthouses. Tudeley’s All Saints Church has windows designed by Marc Chagall. The views are of outstanding beauty and heritage.

The proposals are against central government’s objectives in relation to the historic environment which are to deliver sustainable development by ensuring that policies and decisions concerning the historic environment recognize that heritage assests are a non-renewable resource.

The proposals would significantly alter and impact on the settings of our Parish’s listed buildings which are an important part of our local historic environment. As our historic farmsteads and other listed buildings and local hamlets would be altered forever, this would be, in effect, damaging a non-renewable resource. The Government’s policy statements advise that the historic landscape’s fragile and finite nature is a particularly important consideration in planning. In both options, there are at least 70 Grade 2 listed buildings, 1 Grade 2* and 2 Grade 1 listed buildings.

Landscape

You score the impact on Heritage as Negative for Option 1 (Tudeley) and Negative/Very Negative for Option 2 (Tudeley and the hamlet of Capel). This is incorrect. They are both “Very Negative”.

Site CA1 has a diverse landscape pattern on undulating slopes around Tudeley.

There is no up-to-date Landscape Assessment of CA1/Tudeley to support this Local Plan. The Local Plan and Sustainability Appraisal is therefore unsound.

Travel

You score the impact on Travel as Positive for both Options. This is laughable.

If traffic is travelling from Paddock Wood to Tonbridge they won’t use the Colts Hill bypass or its new link road carved through AONB (FOG bypass). They will still go along the B2017, even if there are bollards or kerbs to deter them from rat running through FOG. The situation at Lamberhurst after their bypass demonstrates that clearly.

And finally… how will you provide rapid bus transfer to Tonbridge Station from Tudeley if the B2017 cannot be widened in to a dual carriageway (with cycle lane and pavement)? The buses will just sit in congested traffic.

SA_8

Thomas Weinberg

6.2.19 (Garden Settlement in Capel Parish) p.46

Comments on 6.2.19 (Garden Settlement in Capel Parish) p.46

Your assertion that adverse effects could be reduced by developing a garden settlement at a similar scale to option 1 is incorrect.

Both Option 1 and Option 2 are completely unsustainable and should be removed from the Local Plan.

SA_9

Thomas Weinberg

6.2.22 (Urban Extension Development Scale) p.46

Comments on 6.2.22 (Urban Extension Development Scale) p.46

You state that extending development westwards (on to East Capel) affects Green Belt which contributes weakly to Green Belt objectives. This is absolute nonsense. East Capel is the most clearly defined part of the Green Belt preventing convergence between Five Oak Green and Paddock Wood.

SA_10

Thomas Weinberg

Table 17 (Four Urban Extension Growth Options at Paddock Wood)

Comments Table 17 (Four Urban Extension Growth Options at Paddock Wood)

Air Quality

You have scored Air Quality as Unknown/Mixed. This is borderline provocative.

The impact on Air Quality in options 1 and 3 should score “Very Negative” as all options will increase private car use and levels of traffic substantially. The creation of the Colts Hill bypass won’t improve air quality. It will encourage more traffic in to the area to cut through to the A21 and it will push more traffic to Pembury where it will still get tuck and sit idling, creating more pollution in a neighbouring Parish.

Biodiversity

You have given all options similar biodiversity scores. This is incorrect. Options 2 and 4 should score as “Very Negative” for biodiversity due to the impact on wildlife in East Capel (see bird surveys above on page 5). Options 1 and 3 would be slightly negative (due to the impact of roaming cats).

Climate Change

Your scores on Climate Change are incorrect.

The impact on Climate Change for options 2 and 4 should be “Very Negative” as soils, mature hedgerows and mature trees will be destroyed during the development of both options. This will happen regardless of the green spaces and clusters of mature trees retained in masterplanning. To facilitate the development of both options you will be creating a Colts Hill bypass that will result in AONB land including fertile soils being covered in hard surfaces and mature trees and hedgerows being destroyed.

The impact on Climate Change for options 1 and 3 should remain as Negative.

SA_11

Thomas Weinberg

6.2.28 (Urban Extension Development Scale) p.49

Comments on 6.2.28 (Urban Extension Development Scale) p.49

You state that Options 1 and 2 have similar outcomes overall.

Your selection of Option 2 is then completely and totally unjustifiable as the NPPF requires you to show “exceptional circumstances” to include the East Capel Green Belt land and you have clearly not demonstrated that there is anything exceptional to cause you to choose Option 2 over Option 1.

SA_12

Thomas Weinberg

6.2.29 (Urban Extension Development Scale) p.49

Comments on 6.2.29 (Urban Extension Development Scale) p.49

You clearly imply that housing numbers and the improvement of flood risk to existing local residents resulted in choosing Option 2. You are presumably referring to leveraging funds for a flood alleviation scheme in Five Oak Green re Option 2 when you could do that via Option 1 as Five Oak Green would be affected by the additional infrastructure strains from building in PW in any case.

Your choice of Option 2 is incorrect, possibly aiming to cram as many houses in as possible. This cannot be justified.

SA_13

Thomas Weinberg

6.2.30 (Urban Extension Development Scale) p.49

Comments on 6.2.30 (Urban Extension Development Scale) p.49

Your choice of Option 2 is incorrect. You should have chosen Option 1 as it does not require use of Green Belt land but delivers many of the economic and social growth attributes that TWBC is seeking from this urban extension.

You have no “exceptional circumstances” to justify the selection of Option 2 with regard to the release of Green Belt land.

SA_14

Thomas Weinberg

General comments

I am writing this out of deep concern caused by reading the Draft Local Plan, Regulation 18 Consultation Draft (20 September to 1 November 2019). I am made even more anxious after reading the Sustainability Appraisal of that plan. I am worried on a personal level, as the unavoidable pollution and noise will affect the health of my son. I am also distressed that historic communities will be carelessly and needlessly destroyed.

The two documents are incomplete and worryingly misleading in a number of aspects which makes them entirely unfit for review by those who will be affected. They are also deeply compromised by being the product of a series of committees all chaired by one individual. That is not an allegation of corruption but one of alarm at the clear impossibility of fair and impartial assessment.

I am also shocked that in the current environmental context that development which has not been evidenced to be necessary will destroy Green Belt land unnecessarily. It is astonishing that this plan has been shared when its impact is both environmentally and morally unsupportable.

I hope that it will be withdrawn and reconsidered with far greater input from those this Council aims to serve.

SA_16

Rex Wakeling

Will require Fewer Vehicles in this Draft Plan. A greater reduction of Ommisions for the future development. We require a great Inferstructure of Electric Charging Points for Vehicles and Electric Publice Transport in the Area, before this draft plan is implemented. Also better footpaths,cycleways. As well the Right to Roam in Tunbridge Wells. More planting of Trees and set a side Wild Life Area etc. Better Insulation of Houses within the Paddock Wood and surrounding Area.

SA_18

Roger Bishop

Summary

Summary

It is claimed, p3 of the Sustainability Appraisal that, “All Strategic Objectives were compatible with multiple Sustainability Objectives.” I do not believe that this is an accurate statement. Many of the objectives appear to have been ignored in the plan, or might be met, but on only the most optimistic of assumptions. I believe that he is being kind to TWBC, but John Wootton, Chair of CPRE’s West Kent Branch, stated at a recent presentation that, “the Council’s housing objective is compatible with only 5 of the 19 sustainability objectives they have set themselves and incompatible with 9 of them”. It was noticeable that neither TWBC’s Chief Executive nor its Chief Planning Officer, both of whom were present, chose to disagree with him.

SA_19

Roger Bishop

Sustainability Objectives

Sustainability Objectives, followed by Comment

Air….Reduce air pollution.

4000+ homes in the countryside with an inadequate and expensive bus network cannot fail to create a huge increase in car journeys in the parish. Also, the destruction of trees and hedgerows will have a negative impact on air quality.

Biodiversity….Protect and enhance biodiversity and the natural environment.

TWBC plan to allow building not just on farmland and open countryside, but on land within the Green Belt. This land contains healthy ash trees (especially important given the impact of ash die-back), mature oaks, plus other important trees and hedgerows. It provides a natural habitat for a range of birds (at least five species of which are on the RSPB list requiring urgent action), owls, mammals, butterflies and moths, among which are several European Protected Species.

The stated Objective is not simply to protect biodiversity and the natural environment, which the plan clearly does not, but to enhance it. There is no hint that the plan might come close to doing that.

Business Growth….Encourage business growth and competitiveness.

No comment.

Climate Change….Reduce carbon footprint and adapt to predicted changes.

As noted above, 4000+ homes in the countryside cannot fail to create a huge increase in car journeys in the parish, and the destruction of trees and hedgerows and the covering of acres of soil with tarmac will mean the absorption of much less carbon.

Deprivation….Reduce poverty and assist with regeneration.

Only a relatively small proportion of any homes built are likely to be “affordable”, and since, for the most part, productive farmland is to be built on, where is the regeneration?

Education….Improve educational attainment and enhance the skills base.

It is difficult to see how the destruction of open space and countryside, with the reduction in opportunities for students to learn about nature, contributes to improving educational attainment and enhancing the skills base.

Employment….Facilitate and support employment opportunities.

TWBC have claimed that a minimum of 35 acres of additional “employees land” is needed. With increasing automation and uncertainty about business intentions many years ahead, it can only be wild conjecture as to how many jobs might be created.

Equality….Increase social mobility and inclusion.

Where is there any evidence that the planned developments might do this? It is difficult to imagine how it could.

Health….Improve health and wellbeing, and reduce health inequalities.

Reducing access to the countryside and open spaces will be harmful to mental health and wellbeing, and air quality will be significantly reduced. Much greater use of the already overcrowded road network will significantly increase the likelihood of accidents and injury.

Heritage….Protect and enhance cultural heritage assets.

Tudeley New Town will do nothing to enhance the heritage assets of this rural area; indeed, quite the reverse. These assets include the world-renowned Tudeley church, and many old buildings typical of the Weald, including various timber-framed buildings and oast houses. The beautiful open countryside which will be destroyed, together with its diversity of flora and fauna is a heritage asset in itself.

Housing….Provide sufficient housing to meet identified needs.

It is well-known that needs have not been properly identified, as out of date ONS figures have been used as a basis.

Land use….Protect soils, and reuse previously developed land and buildings.

The plan is to concrete over farmland and build on Green Belt, so all elements of this Objective are missed.

Landscape….Protect and enhance landscape and townscape.

Beautiful ancient landscape is to be replaced with houses and “employment units”. So, no protection and no enhancement.

Noise….Reduce noise pollution.

The construction of 4000+ homes will in itself create huge noise pollution, followed by the noise pollution created by a vast increase in the number of cars on the overcrowded roads in the parish.

Resources….Reduce the impact of resource consumption.

Yet the building of 4000+ new homes and associated infrastructure is totally inconsistent with this.

Services & Facilities….Improve access and range of key services and facilities.

There is no evidence that the planned developments will in any way do this. Increased traffic congestion will hinder access to services and facilities.

Travel….Improve travel choice and reduce the need to travel by private vehicle.

Building 4000+ homes in the countryside will not improve travel choice or the need to travel by private vehicle. It has already been made plain that our local train lines are at capacity, and what evidence is there that regular, frequent, reliable and affordable bus services will be available to all new (and old) residents to mitigate the need for car use?

Waste….Reduce waste generation and disposal.

Yet the creation of 4000+ new homes cannot but generate more waste, and once they are built the increase in waste in the parish will be massive given the huge rise in the number of homes.

Water…Manage flood risk and conserve, protect and enhance water resources.

Tudeley New Town is to be built on an area that floods, and waste and fresh water resources are already severely stretched before a huge increase in the number of houses in the parish. Building on a substantial site in Paddock Wood has had to be halted because the local sewage system lacks the capacity to take more. That development and the two others with planning permission in Paddock Wood will further stretch the water/waste water resources locally.

SA_20

Gregg Newman

I look forward to you restoring my faith in common decency and human nature. Thank you.

SA_21

Jim Vousden

AL/RTW 24 Site Number 237

The council have a responsibility to improve quality of life for it's residents, this proposed development will achieve the opposite!

SA_22

Gregg Newman

Opening Comments

I have submitted detailed comments on the Concerned Resident Draft Local Plan Response Form.

I am aware of the following response from another concerned resident. In the interests of clarity and accuracy, and to avoid any allegation of plagiarism or laziness, I endorse every word in the submission below 100%.

Particularly in so far as concerns wildflife and bio-diversity, no wonder the current younger generation are so angry at our stewardship of the planet !!

There can only be one reason for your amazingly inaccurate assessments of the impacts of this plan, namely that you are trying to bulldoze this through without actually understanding in the slightest what you are doing not only to future generations but also to all other inhabitants of our planet who you are set upon wiping out.

I sincerely hope and trust that there are no other reasons there could possibly be for such actions, bearing in mind the wealth of the landowner/developer and the residences/wards of the Leader and Co-Leader of TWBC.

I repeat also my other submission, as referred to, that this plan WILL result in deaths or serious injuries to children and vulnerable people.

I would urge you in the name of simple and common humanity, as inhabitants of our green and pleasant land, the Garden of England, and your stated commitment to « tackle climate change » to reject this plan in its entirety and have a serious rethink of your entire strategy before it is too late.

Please make no mistake about the anger of local residnets and our desire to fight this by every means at our disposal.

QUOTE

Comments on Table 13

Horsmonden did not have a Sustainability Appraisal as there were “severe access difficulties” to site 144 (Land adjacent to Yew Tree Green Road, Maidstone Road and Furnace Lane, Horsmonden). On a map, the site looks easily accessible from the B2162 (Maidstone Road) and Yew Tree Green Road and there are plenty of other sites put forward that could link to it. It seems very remiss to not conduct a Sustainability Appraisal on a site where a large amount of land outside of AONB and Green Belt has come forward in the Call for Sites.

Was its proximity to the Deputy Leader of the Council’s house a factor in the decision? She lives on Yew Tree Green Road at Swigs Hole Farm. Or was it just easier to deal with one landowner in Tudeley that multiple landowners in Horsmonden? Either way, the omission of a Sustainability Appraisal for Horsmonden is a grave error.

Air Quality

You have scored Air Quality as Unknown/Mixed. This is incorrect.

The impact on Air Quality in both options should score “Very Negative” as both options will increase traffic substantially on the B2017; an extremely congested road that cannot be widened without numerous CPOs on Grade 2 listed dwellings and the destruction of land within the High Weald AONB.

Stating that inhabitants of the new houses will be discouraged from using private cars will not improve the air quality, it just may make the reduction in air quality marginally less awful.

Biodiversity

You have scored Biodiversity as Neutral/Slightly Negative in Option 1 and Slightly Negative in Option 2. This is incorrect.

The impact on Biodiversity in both options should score “Very Negative”. Here is some evidence of the extraordinary biodiversity on the sites you propose to destroy:

There is a healthy population of ash trees within CA1, young & mature. According to UK Chief Plant Health Officer, Professor Nicola Spence, since 2012 the Government has spent £6 million on ash dieback research and finding and preserving healthy trees is vital. There are also some 20 veteran oak trees on the site.

25% of the adult population own at least one cat or one dog. In the garden settlement there could be hundreds of cats. Cats have a strong intrinsic hunting urge, even those that are well fed, and in a rural environment prey items will be more abundant. A cat will roam to hunt; farm and country cats will range anywhere from 100M to 3km. A recent Mammal Society study found that 987 cats over a period of 5 months brought home 11,537 items of prey including a minimum of 20 species of wild mammal, 44 species of wild birds, furs species of reptile and three species of amphibians. The RSPB nature reserve at Tudeley Woods is 750m from the proposed garden settlement.

The following specifically protected species are on the garden settlement site:

Noctule, serotine, brown long-eared, common pipistrelle and soprano pipistrelle bats (recorded flying).

There is evidence of BAP, KRDB or other notable species on site:

House sparrow (red list & KRDB)
Peregrine falcon (KRDB)
Spotted flycatcher (red list & KRDB)

Kent Ornithological Society Records show that 70 species of birds regularly rely upon the area within the proposed Tudeley site boundary either over winter or during the breeding season. 53 bird species are considered to breed within the proposed site. 12 of the breeding species are Species of Principle Importance as listed under section 41 (England) of the NERC Act (2006). These species need to be taken into consideration by a public body when performing any of its functions with a view to conserving biodiversity. 10 of the species breeding within the proposed site are also red list Birds of Conservation Concern (BoCC), largely due to significant population decline as a result of habitat loss and change in agricultural practices. Yellowhammer, linnet and skylark (all Species of Principle Importance and Red List BoCC) occur within the proposed site in high densities and all three species are undergoing significant population declines.

Four species of owl also occur in the area – Tawny, Little, Barn and Long-eared - itself an unusually high number. There are only a few breeding pairs of Long eared owls recorded in Kent, two of which may be resident in the area. This would represent a significant number and would be a serious consideration for developers.

Red List is the highest conservation priority, with species needing urgent action.

Red List criteria includes (RSPB):

Species is globally threatened
Historical population in UK decline during 1800-1995
Severe (at least 50%) decline in UK breeding population over last 25 years, or longer-term period (the entire period used for assessments since the first BoCC review, staring in 1969)
Severe (or at least 50%) contraction of UK breeding range over last 25 years, or the longer-term period

21^st June 2019: 07:20-11:05

Alphabetical list of bird species observed (by sight or sound)

(UK Red Listed birds highlighted Red / Amber (RSPB) asterisked birds Natural Environment and Rural Communities NERC Act 2006, Section 41: Series of Principal Importance)

Blackbird
Blue Tit
Carrion Crow
Chaffinch
Chiffchaff
Collared Dove
Common Buzzard
Goldcrest
Goldfinch
Great Tit
Green Woodpecker
Greenfinch
Great Spotted Woodpecker
House Sparrows* [red]Kestrel [amber]Magpie
Robin
Skylark [red]Song Thrush* [red]Starlings* [red]Stock Dove
Swallow
Swift [amber]Whitethroat
Wood Pigeon
Yellowhammer * [red]

Butterfly & Moth SpeciesCinnabar Moth
Common Blue
Meadow Brown
Peacock
Red Admiral
Speckled Wood

22^nd June 2019

Note: Whilst the surveys were carried out in CA1, the situation is broadly similar in terms of bird species in the East Capel site. An annual breeding bird survey is conducted for the BTO and many of the key species are present in this area too.

European Protected Species (EPS)

BATS: records show four species in the area (common pipistrelle, soprano pipistrelle, brown long-eared and noctule); all EU protected species. (KMBRC)

GREAT CRESTED NEWT: recorded at the centre of the proposed Tudeley site. Significant measures would need to be put in place prior to any development, such as a translocation and other additional mitigation.

DORMICE: traps have been seen around the proposed quarry sites, implying that their presence has been identified in the area. The dormice will use hedgerows to migrate into CA1. KMBRC already has records of dormice in East Capel.

NOTE: The presence of these EPS requires mitigation licenses from Natural England for development to go ahead. For each license application developers need to provide a 'reasoned statement'; which needs to state why development must go ahead in these locations, and why suitable, less damaging alternatives are not available with less of an impact on wildlife.

The National Planning Policy Framework states that:

To protect and enhance biodiversity and geodiversity, plans should:
a) Identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks….; and

b) promote the conservation, restoration and enhancement of priority habitats…and pursue opportunities for securing measurable net gains for biodiversity.
a) if significant harm to biodiversity resulting from a development cannot be avoided… adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;
c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists;
d) development whose primary objective is to conserve or enhance biodiversity should be supported; while opportunities to incorporate biodiversity improvements in and around developments should be encouraged, especially where this can secure measurable net gains for biodiversity.
The presumption in favour of sustainable development does not apply where the plan or project is likely to have a significant effect on a habitats site…unless an appropriate assessment has concluded that the plan or project will not adversely affect the integrity of the habitats site.

When determining planning applications, local planning authorities should apply the following principles:

There is no up-to-date Biodiversity Assessment of CA1 to support this Local Plan. The Local Plan and Sustainability Appraisal for Tudeley is therefore unsound.

Climate Change

You score the impact on Climate Change as slightly negative for Option 1 and Slightly Negative/Negative for Option 2. This is incorrect.

The impact on Climate Change for both options is “Very Negative” as soils, mature hedgerows and mature trees will be destroyed during the development of both options. This will happen regardless of the green spaces and clusters of mature trees retained in masterplanning. To facilitate the development of both options you will be creating link roads and road within the settlements that will result in soils being covered in hard surfaces and mature trees and hedgerows being ripped up and most probably burnt (based on the Hadlow Estate’s propensity to burn tree prunings for days on end, often close to dwellings, with a complete disregard for the impact on residents and wildlife).

The most effective climate change solution available to the world right now is trees. https://www.bbc.co.uk/news/science-environment-48870920

Soil is an important — and often neglected — element of the climate system. It is the second largest carbon store, or ‘sink’, after the oceans.

https://www.eea.europa.eu/signals/signals-2015/articles/soil-and-climate-change

Heritage

You score the impact on Heritage as slightly negative for Option 1 (Tudeley) and Slightly Negative/Negative for Option 2 (Tudeley and the hamlet of Capel). This is incorrect.

The impact on Heritage for both options is “Very Negative”.

Capel and Tudeley are small hamlets, with traditional buildings clustered around the Grade I Listed sandstone churches. The stained-glass windows at Tudeley’s All Saints Church were designed by the early modernist artist Marc Chagall. The hamlets have strong vernacular character and focal points with frequent glimpsed views to the surrounding agricultural landscape.

A variety of building styles ranging from groups of oasts, which are highly visible, to more modern suburban houses and bungalows.

There are a large number of historic oast houses which are frequently visible throughout the landscape. Many are associated with small hamlet groupings, with many hamlet groupings surviving from the medieval period, 17th and 18th centuries. They are very distinctive features within this open landscape. (Note:

There are numerous traditional historic buildings typical of the Weald, including timber framed houses and farmsteads.

Open views across this intensively farmed landscape are frequently punctuated by the cowls of clustered groups of oast houses and extensive farm building complexes. The Greensand Ridge to the north provides a distinctive skyline, whilst the High Weald to the south provides wooded enclosure.

The proposals are against central government’s objectives in relation to the historic environment which are to deliver sustainable development by ensuring that policies and decisions concerning the historic environment recognize that heritage assests are a non-renewable resource. The proposals would significantly alter and impact on the settings of our Parish’s listed buildings which are an important part of our local historic environment. As our historic farmsteads and other listed buildings and local hamlets would be altered forever, this would be, in effect, damaging a non-renewable resource. The Government’s policy statements advise that the historic landscape’s fragile and finite nature is a particularly important consideration in planning. In both options, there are at least 70 Grade 2 listed buildings, 1 Grade 2* and 2 Grade 1 listed buildings.

Of key significance are the Chagall windows in All Saints’ Church, Tudeley. The impact of change in light through these windows by encroaching development could significantly alter their impact. These windows are a unique national, and global asset. Chagall was commissioned to design one commemorative window in the church, however, he considered the light and setting so perfect he designed and made every window; All Saints’ is the only church in the world to have a complete set of Chagall windows.

Option 2 abuts the hamlet of Capel, site of the Church of St Thomas a Becket, a medieval, Grade 1 listed church in the care of the Churches Conservation Trust.

Listed buildings are irreplaceable, any harm or loss should require clear and convincing justification.

Landscape

You score the impact on Heritage as Negative for Option 1 (Tudeley) and Negative/Very Negative for Option 2 (Tudeley and the hamlet of Capel). This is incorrect. They are both “Very Negative”.

Site CA1 has a diverse landscape pattern on undulating slopes around Tudeley.

There is no up-to-date Landscape Assessment of CA1/Tudeley to support this Local Plan. The Local Plan and Sustainability Appraisal is therefore unsound.

Travel

You score the impact on Travel as Positive for both Options. This is incorrect.

The score for Travel should be Negative. 58% of Capel residents have 2 or more cars (according to your Transport Evidence Base). Both Options are at least a 45 minute walk from the nearest train station. Network Rail have ruled out building a train station at Tudeley. If you add 2,800 homes to Tudeley, many of the residents will have 2 private cars in their household. Many residents will commute to London. Very few commuters (less than 1%) use bikes and buses to get them to the station each day. This won’t change. Their behaviour is based on anxiety over missing their trains (they can control private car use more easily than bus timetables/capacity) and the weather (riding a bike in January? Clothing, footwear and bags?). Creating a settlement in Tudeley will just create chaos while bus and cycle lanes are constructed and then no-one will use them.

That leaves things neutral. Here’s the negative. If you use the developments at Tudeley to gather developer contributions for the Colts Hill Bypass (offline A228) then you will simply be pushing fast flowing traffic up to a very congested Pembury, which may be even more congested by then if the Hendy development goes ahead. Traffic to the A21 will still use the B2017 or the road through the middle of Matfield.

Comments on 6.2.19 (Garden Settlement in Capel Parish) p.46

Your assertion that adverse effects could be reduced by developing a garden settlement at a similar scale to option 1 is incorrect.

Both Option 1 and Option 2 are completely unsustainable and should be removed from the Local Plan.

Comments on 6.2.22 (Urban Extension Development Scale) p.46

You state that extending development westwards (on to East Capel) affects Green Belt which contributes weakly to Green Belt objectives. This is absolute nonsense. East Capel is the most clearly defined part of the Green Belt preventing convergence between Five Oak Green and Paddock Wood. You have rejected sites in Five Oak Green 451; AS12; 450; 216; 307 on Green Belt grounds; some of which are less important to preventing convergence. Can you explain your logic (or lack of it)?

Comments Table 17 (Four Urban Extension Growth Options at Paddock Wood)

Air Quality

You have scored Air Quality as Unknown/Mixed. This is incorrect.

The impact on Air Quality in options 1 and 3 should score “Very Negative” as all options will increase private car use and levels of traffic substantially. The creation of the Colts Hill bypass won’t improve air quality. It will encourage more traffic in to the area to cut through to the A21 and it will push more traffic to Pembury where it will still get tuck and sit idling, creating more pollution in a neighbouring Parish.

Biodiversity

You have given all options similar biodiversity scores. This is incorrect.

Options 2 and 4 should score as “Very Negative” for biodiversity due to the impact on wildlife in East Capel (see bird surveys above on page 5). Options 1 and 3 would be slightly negative (due to the impact of roaming cats).

Climate Change

Your scores on Climate Change are incorrect.

The impact on Climate Change for options 1 and 3 should remain as Negative.

Comments on 6.2.28 (Urban Extension Development Scale) p.49

You state that Options 1 and 2 have similar outcomes overall.

Your selection of Option 2 is then completely and totally unjustifiable as the NPPF requires you to show “exceptional circumstances” to include the East Capel Green Belt land and you have clearly not demonstrated that there is anything exceptional to cause you to choose Option 2 over Option 1.

Comments on 6.2.29 (Urban Extension Development Scale) p.49

You clearly imply that housing numbers and the improvement of flood risk to existing local residents resulted in choosing Option 2. You are presumably referring to leveraging funds for a flood alleviation scheme in Five Oak Green re Option 2 when you could do that via Option 1 as Five Oak Green would be affected by the additional infrastructure strains from building in PW in any case.

Your choice of Option 2 is incorrect, possibly aiming to cram as many houses in as possible. This cannot be justified.

Comments on 6.2.30 (Urban Extension Development Scale) p.49

Your choice of Option 2 is incorrect. You should have chosen Option 1 as it does not require use of Green Belt land but delivers many of the economic and social growth attributes that TWBC is seeking from this urban extension.

You have no “exceptional circumstances” to justify the selection of Option 2 with regard to the release of Green Belt land.

I think that you chose Option 2 because you think it will give you enough developer contributions to finance the £40m Colts Hill bypass. Think again. Option 2 is a dead duck. You can widen Colts Hill for much less than £40m (nearer to £20m) and you’ll save a large area of AONB and Green Belt in the process.

SA_24

Susan Vangucci

Hawkhurst golf club

This is just one of many sites in the Weald of Kent which seems destined for destruction! No-one seems to be remotely bothered by the fact that Hawkhurst can not sustain this level development and the detrimental effect it has on current residents who are losing a once beautiful and desirable place to live. The village is at a standstill due to excessive traffic the doctors surgeries are full and raw sewage is pouring into our streams because the existing system cannot even support the current population. These are just a few of the reasons why there should not be any large developments of any size. Is there in fact any concrete evidence that the proposed level of house building in West Kent is in fact needed as this seems to be largely unsubstantiated. Once these Kent villages are completely ruined, which they will be there will be no going back. In spite of having chosen to live in rural England we are now obliged to live in concrete jungles. It’s is a sad time for everyone and the planners need to listen to the people whose lives will be dramatically affected.

SA_25

David Summers

Policy AL/CRS 7 Land at Golford Road, Cranbrook

AC/CRS 7 LAND AT GOLFORD ROAD CRANBROOK

FINAL DRAFT

BASIS OF OUR OBJECTION

My wife and I have lived at Fir Tree Farm, Golford Road, Cranbrook TN17 3NW since 1977. Our property, which includes working agricultural land, faces the agricultural land in question: Site 7, Land at Golford Road (hereafter referred to as “the Land”) .We have long experience of trafﬁc, pedestrian, and environmental issues relating to its development potential. We do not believe the Sustainability Analysis has given proper weight to these and that taken as a whole it is our view that the site is unsuitable for the large scale development of 150 houses as proposed. According to Post Ofﬁce data the development would be half the size of the Frythe estate and slightly larger than the Turner Ave estate that abuts it. 1 Connectivity issues 1.1 Pressure on T junctions The land is situated on a speed unrestricted main road outside the limits of built development. Direct access to places west and north is principally achievable by passing through Cranbrook via the T junction at Waterloo Road. Alternative access to the north , and in particular to Staplehurst Station may be achieved via accessing Chapel Lane at the Golford cross roads and emerging onto the A262 at the T junction facing The Milkhouse pub. Both these T junctions constitute major pressure points in trafﬁc ﬂow, especially during school and working hours. The successful growth of Dulwich Preparatory School has led to a substantial increase in fast, closely packed trafﬁc along the road at peak times.

The situation in Cranbrook is exacerbated by the position of the public car park at The Tanyard which provides a single entry and exit point directly onto the stem of the T junction. Sissinghurst’s existing trafﬁc problems are well documented and increased ﬂow from the “ the Land”, whether to access the local junior school, Staplehurst Station, or the A262 west can only add to them.

The SA takes no account of the Sissinghurst T junction which is frequently preferred by commuters on this side of Cranbrook to avoid congestion and speed bumps in Cranbrook.It is a weakness that it does not examine the allocation in the wider setting.

1.2 Dangerous bends

The road between “the Land” and Cranbrook winds directly along what is in effect a causeway between a large pond on one side and steeply falling land on the other and is cambered towards the falling land which encourages motorists to take a more central road position in both directions. The safety rails on the downward edge show signs of serial repairs caused by trafﬁc hitting them. It is fringed by a narrow pavement on the pond side elevated to a two tiered step down to the road in places

Large sewage tankers enter and exit the road at the eastern end of the bend

An example of the repeated appeals made by local residents is reproduced here:

“I ﬁrst wrote to the council about trafﬁc three months after we moved here, in December 2009, after our ﬁrst scrape with an overhanging car mirror on the pavement. I suggested extending the 30 mph zone (to the end of the houses) as well as making some sort of effort to enforce it where it already exists. I've contacted them again over the years, especially after we’ve witnessed major incidents, such as the one on 1 February 2014 (which was reported in the newspapers. The driver and passenger had critical injuries and the driver had to be cut out of the car which was upturned and had knocked out the electricity supply for this area).”

But there have been other incidents only some of which have been recorded by KCC

Another relatively blind bend with warning posts in the verge - at least those which have been left standing; others have been demolished by trafﬁc -starts opposite our own property providing an additional hazard for both motorists and pedestrians.

Given the increased volume of cars and commercial vehicles that would result from the development- commuters, mothers taking their children to school in the town, tradesmen, delivery and council vehicles - these trafﬁc problems can only become more intractable and a marketing disadvantage to any development.

1.3 Pedestrian access to and from “the Land”

1.3.1 Since 1977 I have walked into Cranbrook virtually daily to participate in the local community. but virtually no other local residents make the walk. It was more common practise when we ﬁrst lived here with older people too walking to the cemetery to pay respects. Now the common way of accessing the town is by car whether shopping or socialising.Walkers are generally tourists these days accessing local footpaths or D of E students from Swattenden.

The present ”rural” public footpath on the south side from Cranbrook extends only to our house and although laid by a public authority is not maintained. The Plan envisages extending the path eastwards to the end of the developed land, I understand that this would have to pass over privately owned ditches fronting agricultural land and would therefore be opposed by the owner.

The path is only rarely used after hours of darkness and users need a torch to pass safely as there are only 3 “Parish” lamp-posts between Bakers Cross and the end of the rural path at Fir Tree Farm. The last of these is on the north side. This has always raised the issue of personal safety for single pedestrians.

To illuminate the proposed extension along its length on the south side would lead to unnecessary light pollution and a waste of energy.

We object to this extension to the existing path on the south side as the expenditure cannot t be justiﬁed in terms of both feasiblity and the beneﬁt it brings to the community.

1.3.2 Originally there was no footpath at all around the bends at Bakers Cross and we took our lives in our hands pushing the pram, but the present inadequate footpath was created about 20 years later. We made representations to KCC at the time that it was too narrow: people cannot pass each other without stepping into the road and it is impossible to wheel a pram along it, let alone a mobility vehicle or a wheelchair.

Over the years the wheelbases of lorries and buses have got longer and a danger now is that the front offside of buses travelling to Cranbrook overlap the pavement if taking the bend sharply or to avoid on coming trafﬁc. I have personal experience of narrowly avoiding being hit from behind.

1.4 Stone Street

Although the SA makes reference to the Waterloo Road junction, the real obstacle to development to the east of the town is the chaotic trafﬁc situation in Stone Street where vehicles frequently ride on pavements to avoid each other and buses and heavy lorries lock horns.. Solving this problem is at the heart of breathing continuing life into Cranbrook’s commercial activities.

The injection of trafﬁc from any large development on “the Land” can only elevate the chaos to new levels. It is not as if the is signiﬁcant car parking in the eastern quarter from which motorists can proceed on foot into Stone Street.

It is essential that consideration to this allocation is given in the context of its impact on Cranbrook town as a whole.

2 Environmental issues

2.1 Sewage Works

“The Land “ borders the Cranbrook Sewage Works which would have received planning permission because of its situation beyond the existing built development and its ability to discharge directly into the Crane Brook at the point at which it entered open countryside, to minimise nuisance.

These Works have had a chequered relationship with local residents during our residency with strong feelings about smell, noise, high level of tanker trafﬁc, treating waste from other towns and National River Authority involvement. Southern Water was ﬁned £13,500 in 2013 for an incident relating to industrial waste there and in 2014 spent £4m updating the plant.

Although the Plan mentions obviating the risk of ‘’obnoxious smells”, it takes no account of the potential expansion of the works to cope with the additional sewage inﬂow result from the creation of 900+ houses in the area. Our research indicates that 150 houses would generate a 20% increase in the sewage the works currently deal ,with an accompanying increase in tanker trafﬁc.

Large capacity sewage tankers already ply the concrete track to the main road and it is hard not to image the marketing challenges for developers of being next to this site.. Even the address listing for our post code shows “The Sewage Works” having pride of place. No matter what more picturesque names are given to the streets in any future development , I suspect they will always be known locally collectively as “the houses by the sewage works”.

Heaven forbid that that section of land should be allocated only to affordable housing!

The plan creates a “ sewage sandwich” with the Works placed in an envelope between two communities of residents. This cannot have been the intention when planning permission was granted for the Works originally. The Works were intended to be situated outside the town.

2.2 Flooding

Treated water from the works ﬂows into the Crane Brook which runs at the northern and lowest point of the Land. The volume of ﬂow can only increase with the sewage outﬂow from the land, and other developments in the area.

With experience of tramping through the watery mud I can offer assurance that there is ﬂooding on“the Land” every year where it falls away to the Crane Brook. Indeed part of it is covered by the Environment Agency's Flood Zone 3 . Whilst it is ofﬁcial policy to build on ﬂood zones, even though ﬂooding is on the increase is it sensible in this case? Whilst it may be argued that building should be avoided on the part that ﬂoodable land, the building on the rest of the ﬁeld will surely increase the ﬂooding issue as the built up area will soak up less rainwater, and that increased ﬂooding would be right next to the sewage works.

2.3 Area of Outstanding Natural Beauty

The arable land is actively farmed . This is major development in an AONB, which is contrary to national policy, see NPPF para 172: It is debatable whether the tests it sets out have been met.

One footpath runs alongside the sewage works boundary and crosses the Crane Brook onto private agricultural land where it meets the High Weald Landscape trail. The development would be locked in on the other two sides as this is the only way of accessing open countryside from the developed land and heads away from Cranbrook . Over the years however at least one other unofﬁcial footpath to Cranbrook has been walked over this private land and given the proximity of the developed Land, the owner may be likely to experience an even higher rate of trespass in future.

CONSIDERED OBJECTION

The development of “the Land”- which is not a natural extension to existing built development since it abuts a large ﬁeld belonging to a private house - would provide a stimulus for the further development of Cranbrook in an easterly direction. We would argue that this is the worst possible strategic option for the town’s growth given the wider connectivity issues.

SA_28

Terry Cload

Appendix 'A' Landscape P 156

Almost, it seems, as an afterthought there is a feeble superscript note (12) that meekly suggests that protecting and enhancing landscape and townscape 'includes a consideration of light pollution'. This is pathetically inadequate.

All artificial light pollution is wasted energy. It is also wasted money. Children are growing up rarely if ever never having witnessed the wonder of the night sky, the universe and understanding something of our place in it.

There should be strong policies to take action to reduce existing light pollution, to ensure that new developments do not increase local light pollution, and to protect and enhance existing dark sky areas such as the High Weald AONB. In 2016 the South Downs Park became an International Dark Sky Reserve. We should follow that example for the High Weald AONB and adjoining areas of the MGB.

In consultation with the local community street lighting should be switched off completely from midnight to dawn in the AONB and other enlightened (please excuse the pun!) areas. Continuous artificial lighting has a seriously deleterious effect on people, animals, and plants.

SA_29

Andrew Chandler

Site reference 120 / Policy Reference AL/CRS 13: Land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road, Sissinghurst

It is inexplicable that the Council does not recognise the historical significance of this site and also the historical significance of the adjacent Mill Lane. Both are worthy of specific consideration in formulating the new Local Plan and in particular in the Sustainability Appraisal for this site. I suggest that the Historic Landscape Characterisation and Historic Environment Review carried out by external consultants (as referred to in Table 2 of the Sustainability Appraisal) are defective in failing to note that:

This site was the location of a windmill in the 18th and 19th centuries, a fact that is plainly apparent on detailed Ordnance Survey maps from 1801 (Mudge Ordnance Survey map of Kent, surveyed in 1790s), 1813 (Ordnance Survey first series map, sheet 5) and the 1821 (Greenwood map of Kent, surveyed in 1819-20). These are all available to view online but I can provide extracts if required and can also demonstrate from contemporary documents that it was this windmill which gave its name to Mill Lane (not the later windmill built on the other side of Mill Lane in the 1840s).
Due to the two windmills that have existed on either side of the lane, Mill Lane is designated a rural lane in the top 5% of rural lanes in the borough for historical / archaeological value and thus requires specific consideration as regards any development that may have an impact on its setting (see TWBC Rural Lanes Supplemental Planning Guidance, January 1998 - Mill Lane is lane number 16 in the Rural Lanes Study attached as Appendix 2). In fact Mill Lane is by far the top scoring lane in the entire borough for historical / archaeological value, being the only one out of 167 lanes studied to score 12 out of 12 for its historical / archaeological value. No other rural lane scored even close to this (nine of them were rated 8 out of 12, all others were below this).

This site cannot be considered for development without having regard to both the historical significance of the site itself and also the impact of any development on the adjoining Mill Lane. Consequently, I challenge various aspects of the sustainability appraisal that has been done for this site (Table 29 / Appendix I of the Sustainability Appraisal):

The Heritage impact is rated as Slightly Negative, but this is without consideration of the above. This negative rating should be much higher. Your Decision-aiding questions (Appendix A of the Sustainability Appraisal) note that the protection of sites, features, areas and settings of archaeological, historical and cultural heritage importance has a HIGH weighting, because such assets and settings are finite and hard to restore once lost. This is precisely the purpose of the TWBC Rural Lanes Supplemental Planning Guidance as it applies to Mill Lane. I suggest that the impact should be rated as Very Negative, as not only would development at this site destroy the archaeological, historical and cultural heritage of the site, it would also severely impact on the highly historical setting of Mill Lane, contrary to the TWBC Rural Lanes Supplemental Planning Guidance.
The Landscape impact is rated as Slightly Negative, presumably because of the adjoining AONB but again this is without consideration of the above. Your Decision-aiding questions note that “great weight” attaches to not only the protection and enhancement of the High Weald AONB, but also to the protection and enhancement of the historic landscape. For the same reasons as above, I suggest that the impact should be rated as Negative or Very Negative.
The Health impact is rated as Neutral / Slightly Positive. Looking at your Decision-aiding questions, the only relevant factor that I can see is that residents of a development at this site would have access to heritage assets, presumably elsewhere in Sissinghurst and Cranbrook. I suggest that such access must be weighed against the loss of heritage assets associated with development at this site. I suggest that the impact should be rated as Slightly Negative, given the negative impact of any development at this site on the local historical setting.

I also question various other aspects of the sustainability assessment for this site:

The Services and Facilities impact is rated as Slightly Negative. Looking at your Decision-aiding questions, which note that improvement in availability and access to facilities carries a HIGH weighting and that this is a critical issue, I would point out that TWBC itself has recognised that Sissinghurst only has very limited facilities and even some of those we have are expected to be unavailable to residents of any development at this site. In February 2017 the TWBC ranked our services and facilities 15th= in its review of 20 similar settlements across the borough (in the Settlement Role and Function Study). Currently, doctors, dentists, hospitals, secondary schools, supermarkets, the railways station, etc are only realistically accessible by car. However, in addition, I note that KCC’s have made clear in relation to planning application 19/00308/FULL for this site that children on the development should expect to travel to Cranbrook to attend primary school. I suggest that this aspect should be rated Negative.
The Equality impact is rated as Slightly Positive. Looking at your Decision-aiding questions, the only relevant factor that I can see is that that residents of a development at this site may benefit from independent access to facilities for people with mobility, sensory and cognitive impairments. It is not clear to me what is meant by the comment/limitation in Appendix A about “distances of 1 mile or greater were considered inconvenient and scored negatively”, but I would point out as above that doctors, dentists, hospitals, the only primary schools likely to have any availability, secondary schools, supermarkets, the railways station are all more than 1 mile away. I suggest that this aspect should be rated Neutral.
The Travel impact assessment is rated as Neutral / Slightly Negative. It is not clear why this would be any different from the assessment for site 29 / AL/CRS 15, which is actually closer to a bus stop than this site. I suggest that this aspect should be rated Slightly Negative / Negative.

You will of course want to take account of these comments in relation to planning application 19/00308/FULL for this site, which is currently under consideration. These point should also feed into the overall assessment of the sustainability of the proposed development in Cranbrook and Sissinghurst Parish, the Local Plan’s proposed Place Shaping Policies as applicable to this site and the proposed extension of the Sissinghurst Limits to Built Development, on which I will comment separately. As a general point though, I note that every single one of the sites under consideration for development in Sissinghurst has already been subject to discussions with / applications by developers and as such can be expected to be developed in the short term if included in the Local Plan. I trust that your assessment will be carried out based on strategic planning for need across the borough for the period to 2036, not just as a response to the applications that you know are or will imminently be before you.

SA_30

Andrew Chandler

Policy Reference AL/CRS 12: Land on east side of Mill Lane, Sissinghurst TN17 2HX (Cranbrook and Sissinghurst Parish Site reference 54)

The Council does not seem to recognise the historical significance of Mill Lane, which is worthy of specific consideration in formulating the new Local Plan and in particular in the Sustainability Appraisal for this site.

I suggest that the Historic Landscape Characterisation and Historic Environment Review carried out by external consultants (as referred to in Table 2 of the Sustainability Appraisal) are defective in failing to note that, due to the two windmills that have existed on either side of the lane, Mill Lane is designated a rural lane in the top 5% of rural lanes in the borough for historical / archaeological value and thus requires specific consideration as regards any development that may have an impact on its setting (see TWBC Rural Lanes Supplemental Planning Guidance, January 1998 - Mill Lane is lane number 16 in the Rural Lanes Study attached as Appendix 2). In fact Mill Lane is by far the top scoring rural lane in the entire borough for historical / archaeological value, being the only one out of 167 lanes studied to score 12 out of 12 for its historical / archaeological value. No other rural lane scored even close to this (nine of them were rated 8 out of 12, all others were below this).

This site cannot be considered for development without having regard to the historical significance of the lane. Consequently, I challenge various aspects of the sustainability appraisal that has been done for this site (Table 29 / Appendix I of the Sustainability Appraisal):

- The Heritage impact is rated as Neutral, but this is without consideration of the above. Your Decision-aiding questions (Appendix A of the Sustainability Appraisal) note that the protection of sites, features, areas and settings of archaeological, historical and cultural heritage importance has a HIGH weighting, because such assets and settings are finite and hard to restore once lost. This is precisely the purpose of the TWBC Rural Lanes Supplemental Planning Guidance as it applies to Mill Lane. I suggest that the impact should be rated as Negative or Very Negative, as development at this site would severely impact on the highly historical setting of Mill Lane, contrary to the TWBC Rural Lanes Supplemental Planning Guidance. I would emphasise that this site adjoins Mill Lane at the only point on the lane which is completely uncompromised by development, such that the impact is particularly undesirable and that the Local Plan’s proposed Place Shaping Policies as applicable to this site are for terraced housing on the lane, meaning that the impact would be significantly high.

- The Landscape impact is rated as Neutral / Slightly Negative, but this is without consideration of the above. Your Decision-aiding questions note that “great weight” attaches to the protection and enhancement of the historic landscape. For the same reasons as above, I suggest that the impact should be rated as Negative or Very Negative.

- The Health impact is rated as Neutral / Slightly Positive. Looking at your Decision-aiding questions, the only relevant factor that I can see is that residents of a development at this site would have access to heritage assets, presumably elsewhere in Sissinghurst and Cranbrook. I suggest that such access must be weighed against the loss of heritage assets associated with development at this site. I suggest that the impact should be rated as Slightly Negative, given the negative impact of any development at this site on the local historical setting.

I also question various other aspects of the sustainability assessment for this site:

- The Equality impact is rated as Slightly Positive. Looking at your Decision-aiding questions, the only relevant factor that I can see is that that residents of a development at this site may benefit from independent access to facilities for people with mobility, sensory and cognitive impairments. It is not clear to me what is meant by the comment/limitation in Appendix A about “distances of 1 mile or greater were considered inconvenient and scored negatively”, but I would point out as above that doctors, dentists, hospitals, the only primary schools likely to have any availability, secondary schools, supermarkets, the railways station are all more than 1 mile away. I suggest that this aspect should be rated Neutral.

- The Travel impact assessment is rated as Neutral / Slightly Negative. It is not clear why this would be any different from the assessment for site 296 / AL/CRS 15, which reflects the “limited transport options in Sissinghurst” when that site is actually closer to a bus stop than this one. I suggest that this aspect should be rated Slightly Negative / Negative.

These points should also feed into the overall assessment of the sustainability of the proposed development in Cranbrook and Sissinghurst Parish, the Local Plan’s proposed Place Shaping Policies as applicable to this site and the proposed extension of the Sissinghurst Limits to Built Development, on which I will comment separately.

SA_31

Carter Jonas for SGN

Having just read the Tunbridge Wells Draft Local Plan (Regulation 18) the following is what I concluded:

SGN are most interested about the housing and employment developments in the plan. After reviewing the developments on the Medium Pressure (MP) and Intermediate Pressure (IP) SGN Network Analysis Model, I can confirm that the vast majority of developments would be well supported by the gas network. Therefore, for the most part any developments connecting to the gas network will require no reinforcement on the IP/MP network. Where the individual developments are to connect to our Low Pressure (LP) system, reinforcement will be dependent on the nature and location of the requested load(s) and will only become clear once a developer’s request has been received.

One area that could trigger reinforcement on the IP/MP network are the developments at Paddock Wood (Policy STR/PW 1-4, pg170-pg198). The location of the town is located at one of the tails of the network and if these developments are to connect to the gas network it will likely cause a high pressure loss over this tail and require significant reinforcement to mitigate the loss caused by these developments.

SA_34

Matt Rook

Hello,

I live on Reynolds Lane and my house backs on to one of the proposed sites. I believe it is site 100 - listed as "Land to the south of Speldhurst Road, adjacent to Whitegate Close, Royal Tunbridge Wells ".

As I understand it there are no approved plans for housing in this area, although the landowner has proposed a development of around 400 new homes.

I strongly object to this idea on the grounds that the local roads are totally unable to cope with the current level of traffic. I can't imagine how the junction of Reynolds Lane and Speldhurst could possibly cope with more local traffic. The road directly outside my home - which is close to St Greggs School - is already a no-go zone at school pick-up and rop off times. On any given day it's gridlock and negotiating this 300m stretch regularly can take 20 to 30 minutes. Most mornings the traffic from each direction on Reynolds Lane meets outside my house and gets stuck. Until someone takes it upon themselves to get out of their car and organise one side to somehow reverse enough to ease the flow. As you may well imagine, matters often get heated and I've witnessed on several occasions incidents that have nearly come to blows. Successfully organising this is not easy task. It takes cool, sensible heads and time - often as much as 15 mins before a situation is resolved. More often than not this will require the southbound cars to mount the pavement outside Stonewood Colse and stay on it until Whitegate Close. The childen walking to school at St Greggs, and indeed those walking from their homes in Reynolds Lane, have long realised that the pavement on this side of the road is a no-go zone, for fear of the steady flow of cars that drove on it every day.

If 400 houses were added, and the likely 400 to 800 additonal cars this would bring, I dread to imagine the chaos this would bring.

In addition to this of course, Reynolds Lane quickly becomes a single track on its path to Cluverden Down. It's already an extremely treacherous road and nothing should be done that adds any further traffic.

I appreciate the opportunity to share my thoughts.

Kind regards,

Matt Rook

SA_36

Fiona Pengelley

I OBJECT TO the proposal to build a new town of nearly 3,000 homes at Tudeley in the parish of Capel and OBJECT TO the proposals for even more housing on Greenbelt land.

The sustainability appraisal refers to “some loss of green belt’ but it is actually 600 acres adjoining AONB and including AONB which will be harmed by the developments and associated transport infrastructure.

There has been no detailed report on the implication of the impact of so many more cars on the roads.

There is no acknowledgement of the extra pollution that will arise and the impact that pollution has on people’s health especially children.

There is no in depth detailed proposal to handle the extra traffic. Why would cars travel south out of the new town at Tudeley to Colts Hill. Where are they going? If they wish to go to Tonbridge or Tunbridge Wells then they will use the existing road and the A21. If they wish to go to Paddock Wood and Maidstone then they will travel through Five Oak Green. A new A228 will only cause considerable extra traffic on minor roads in the Parish especially Alders Road. Alders Road will be used as a clear run through to other villages like Matfield, Brenchley and Horsmonden where the traffic should be forced onto the A21 road.

The characteristics of the area will be destroyed and not enhanced.

The site of the new town at Tudeley was not even considered in the first appraisal.

I strongly object to this proposal by Tunbridge Wells Borough Council as there are no exceptional circumstances shown as to why the destruction of green belt and AONB land should be allowed. The law needs to be adhered to.

SA_37

Martin Pengelley

OVERVIEW COMMENTS

I OBJECT TO the proposal to build a new town of nearly 3,000 homes at Tudeley in the parish of Capel and OBJECT TO the proposals for even more housing on Greenbelt land.

The land to be used is Greenbelt and adjacent to AONB. To use Greenbelt land there needs to be “exceptional circumstances” and housing need is NOT sufficient to overrule Greenbelt.

In recent press, TWBC has been quoted as saying “If the Draft Local Plan is agreed it will allow the Council to meet government-imposed housing targets in the way that is considered to be the most appropriate for the Borough as a whole.” This confirms that the Council have been lead by the government targets, not by local housing needs. There is insufficient evidence that the local housing needs exist such that a new town at Tudeley, on Greenbelt land, is justified.

Any consideration of this ill-thought through plan should take account of the fact that it comes from a council that proposed running up significant debt to finance a hugely costly theatre, a reckless proposal that was palpably not wanted by the people of the borough.

FULL COMMENTS

I OBJECT TO the proposal to build a new town of nearly 3,000 homes at Tudeley in the parish of Capel and OBJECT TO the proposals for even more housing on Greenbelt land.

The land to be used is Greenbelt and adjacent to AONB. To use Greenbelt land there needs to be “exceptional circumstances” and housing need is NOT sufficient to overrule Greenbelt.

In press/BBC TV in Oct 2019, TWBC has been quoted as saying “If the Draft Local Plan is agreed it will allow the Council to meet government-imposed housing targets in the way that

is considered to be the most appropriate for the Borough as a whole.” This confirms that the Council have been lead by the government targets, not by local housing needs. There is insufficient evidence that the local housing needs exist such that a new town at Tudeley, on Greenbelt land, is justified.

Jake Berry (Minister DHCLG) stated in April 2019 that: “the housing need figure is not a mandatory target. Local Authorities should make a realistic assessment of the number of homes their communities need, using the standard method as the starting point in the process. Once this has been established planning to meet that need will require consideration of land availability, relevant constraints and whether the need is more appropriately met in neighbouring areas... The NPPF is clear that only in exceptional circumstances may a Green Belt boundary be altered, through the Local Plan process. Last year we strengthened Green Belt policy in the revised NPPF”.

Brandon Lewis (Housing Minister 2015) stated clearly that “maintaining strong protection for the Green Belt is national policy and LAs are required to observe this. In the context of planning applications or appeals, the policy is that unmet housing need alone will not amount to the “very special circumstances” to justify planning permission for inappropriate development on Green Belt. We have repeatedly made clear that demand for housing alone will not change Green Belt Boundaries.”

69% of the borough is designated as an Area of Outstanding Natural Beauty (AONB)
There are 10 Sites of Special Scientific Interest (SSSI)
22% of the borough's land is designated as Green Belt (Source: TWBC website, Key Borough Statistics)

Consequently, Government imposed housing targets are disproportionate for a borough with such a high proportion of land being Greenbelt and/or AONB. TWBC should push back on this imposition from central government as Sevenoaks Council have done.

Government targets are based off 2014 ONS data not the updated 2016 numbers which are at a lower level.

Roger Gough, leader of the Conservative Party at Kent County Council and likely new leader of Kent County Council, has said about housing plans in Kent: “the consensus is housing has moved ahead of infrastructure. We are talking about roads, we are talking about schools……we do need to work together to present to government what is required in terms of a balanced approach. People must not feel that housing is coming on such a scale in places that it is not balanced with the infrastructure that comes with it.” (Courier October 11 2019, page 14)

Local needs. What level of diligence has been applied to the work to identify local needs? Not just in numbers of houses, but also in the type of housing? Building a new town at Tudeley is highly likely to generate executive homes which are far more profitable for the developer, than social or affordable housing. Yet the local need is for affordable or social housing.

Has TWBC undertaken its work to identify all the brownfield sites with similar diligence as they have asked landowners to put up greenfield sites for development? Did they initiate visits to potential land owners to encourage the provision of brownfield land, as they did for greenfield categories? Para 137 NPPF requires local planning authorities to “examine fully all other options for meeting its identified need for development” before concluding whether exceptional circumstances exist to justify changes to Green Belt boundaries. If TWBC used greater efforts in seeking out landowners for greenfield land than brownfield, the draft plan fails that test.

Enfield is an example showing that the process that councils use to assess brownfield land is often inadequate. The council in Enfield identified a brownfield register for 2,700 homes. Local resident groups identified non-green sites and visited each site to assess its suitability as brownfield. This found space for 37,000 homes.

Housing density. What assumptions have been used by TWBC on housing density in the new town at Tudeley? The destruction of Greenbelt land should certainly justify a high level of housing density to reduce the irreversible loss of the valuable natural landscape. Insufficient housing density is a ground for refusal of a Local Plan.

Transport considerations. Para 138 NPPF states that: “Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.” It is quite obvious that the new town at Tudeley is not well served by existing public transport. Extra car usage will be generated on roads that are already congested at peak hours.

Whilst a new road is proposed south of Five Oak Green, this too is in Greenbelt land, resulting in yet more destruction of the natural environment. The roundabout at the Colt’s Hill end of Alders Road will encourage ease of access onto the proposed Colt’s Hill bypass, thus driving traffic down Alders Road at peak times rather than along the proposed new road south of Five Oak Green. Additionally, the proposed Colts Hill bypass is in both Greenbelt and AONB land.

Hospital capacity and extra needs. A new town and 4,000 new homes in Capel will put great pressure on the services at the Kent & Sussex hospital at Pembury. What work has been done to assess the extra demand and the current capacity of the hospital to cope with this? How can the TWBC guarantee the extra resources needed to fund the necessary hospital expansion?

Natural environment. The destruction of greenfield land and Greenbelt land will impact adversely on the natural environment and the wildlife in the area. There is an RSPB nature reserve south of Alders Road less than one mile from the proposed new town in Tudeley. The rise in birds of prey, Buzzards and Sparrow Hawks in particular, that we have witnessed within the last few years, will be impacted adversely given the range of land they cover. The agricultural heritage of the parish will be lost for ever.

Soil quality. The Greenbelt, agricultural land that will be forever destroyed is of what quality? What proportion of the good quality agricultural land in the TWBC area will be lost? Has there been sufficient consideration of such issues?

Flooding and water supply. There is already much known about the issue of flooding in Five Oak Green and other parts of Capel parish. The proximity of the new town to the natural flood plain of the Medway should be properly assessed, including the impact downstream of faster run off. How much increase is there in the likelihood of damaging floods in Yalding, which already suffers regularly in times of heavy rain?

As well as flooding considerations, research should be done on water supply. The whole of the South East is a region of stress for water supply. What professional research has been done on the extra demand from the new town and 4,000 extra homes. Where will the water supply come from? Are there sufficient supplies available?

Air quality, light and noise pollution. The extra housing, cars, street lighting and all that goes with a new town, will lead to increased levels of pollutants in the air and poorer air quality, coupled with noise and light pollution in what is now a rural, Greenbelt area. The quality of the environment in Capel will be irreparably damaged and changed for the worse; for ever. Is this consistent with a desire for betterment of the parish? It is certainly a total destruction of the existing way of life.

Listed buildings and historic site of Tudeley church. Marc Chagall is a world-renowned artist and only one church in the world has all its windows designed by him; Tudeley church. A key contributor to the ambience of this historic church is its setting in the green fields of Kent. This will be lost when the fields are destroyed and the church is surrounded on three sides by the new town at Tudeley. What assessment has there been on this historic site and the other listed buildings in the parish and its surroundings?

Sustainability assessment. As per the TWBC Sustainability Assessment, the housing objective is compatible with only 5 of the 19 sustainability objectives and is incompatible with 9 of them. Even in the situation here of marking one’s own home work, this shows a dramatic lack of sustainability and poorly thought through planning.

Mitigating climate change. There is little evidence that adequate weighting has been given to the topic that is getting widespread coverage now, that of climate change. As the ultimate threat from climate change is negative for every human being, everything that can be done to mitigate the adverse impact from development on climate change should be done. Under government NPPF guidelines, proposed development needs to consider the impact of climate change. In the area of the proposed new town for Tudeley, flood risk is an issue for consideration. As well as the impact of extra carbon emissions in the construction of the new town and the existence of greater population density afterwards. Has sufficient work be done by TWBC on this issue?

CONCLUSION

In conclusion, I contend that this draft Local Plan and the concept of the new town to be built on Greenbelt land in Capel, has been poorly thought through, is a ‘convenient’ solution to meeting government imposed targets rather than addressing local needs and provides no justification for the destruction of Greenbelt land and riding roughshod over the long established precedents to protect the Greenbelt.

SA_38

Beth Evans

Site 122

I agree with the conclusions of the Sustainability Appraisal for draft Local Plan (Regulation 18) report for proposed site 122 and I would object to the site being included in this or any future Local Plan.

SA_39

Lee Prebble

Introduction

I am not a resident of Tunbridge Wells Borough but live near to the Borough boundary with Tonbridge. I do visit the Borough on a regular basis and enjoy the significant benefits of the countryside and Green Belt that should both be protected and enhanced as required by National Planning Policy.

The Draft Local Plan documents produced are vast and complex. As an individual I do not have the time and resources to examine each and every part and policy in detail. I have, therefore, concentrated on consideration of two particular aspects of the Draft Plan that concern me most (the proposed development at Tudeley and the proposed secondary school on land in west Capel). That is not to say that I support other policies in any way. Indeed, I am aware of some of the concerns of others and agree with many of them.

I may also add that I am a retired member of the Royal Town Planning Institute and have some considerable experience of the production of local plans. I have to say that I would not be at all happy to put documents like these to the public. In essence, I consider the approach has been shoddy and the output both dubious and faulty in many respects. I would go so far as to say I would be ashamed to have these as part of my legacy.

My comments are in relation to three documents: the Distribution of Development Topic Paper; the Sustainability Appraisal and the Draft Local Plan.

Sustainability Appraisal

Table 8 (para 5.3.1) purports to test compatibility of objectives. However, in relation to item 1 (Development needs) the table shows compatibility in every area but this is not possible to assess in relation to at least 2 (Biodiversity and Landscape) as full assessments of the current situation were not undertaken for key development areas. Table 9 demonstrates very high levels of uncertainty in relation to key objectives, especially in relation to the proposed Garden Settlements.
It is, therefore, totally wrong to simply conclude (para 5.3.3) that nine out of ten Local Plan Objectives are more compatible than incompatible with the Sustainability Appraisal objectives. If the outcome is uncertain then it may very well be that objectives are incompatible. The approach is wrong and the SA is therefore unsound.
Para 5.3.6 is based on speculation. If the Neighbourhood Plan content is dictated by the Strategic Policies of the Local Plan, given the high levels of uncertainty previously identified, it cannot be claimed that there will be compatibility. For this reason the SA is unsound.
Table 15 is also speculative in relation to biodiversity. Given the paucity of information on biodiversity in general it is simply not possible to justify the statement of small losses and potential gains. This is unsound.
Similar concerns relate to Tables 16 and 17 given the lack of base information in relation to biodiversity. Again, on this basis the SA is unsound.
Para 8.1.4 states that landscape considerations form one of the filters. What is totally unclear is what this is based on given that there has been no comprehensive Borough wide landscape assessment. On this basis the SA cannot be sound.
There is no filter for biodiversity interests beyond considerations relating to designated sites. For this reason the SA is unsound.
Figure 10 demonstrates the significant and excessive proportion of Capel parish being considered for development. No other parish is subjected to such pressures for development. It is completely disproportionate. The designation ‘Reasonable’ is wrong. In my opinion the approach is unreasonable and for this reason the SA is unsound.
Table 25 suffers the same faults as earlier tables in relation to biodiversity, reinforcing the conclusion that the SA is unsound.
The commentary in Table 25 is biased. Without proper assessments of some factors in the first instance and given that there is an emphasis on development rather than conservation and respect for natural beauty and existing ecosystems there is bound to be a greater number of positives. In this respect the SA is unsound.
Table 73 suffers from the same speculation as other tables with regard to factors where the base data has not been properly assessed such as landscape and biodiversity. Again this reinforces the contention that the SA is unsound.
The comments in Table 74 in relation to biodiversity are dependent on tables that are faulty for reasons given above; namely that without the proper initial assessment it is not possible to understand the impact on this key issue. As such the SA is unsound.
Similar comments also apply to landscape.
Appendix A demonstrates that no consideration whatsoever has been given to biodiversity and the natural environment outside of designated sites. Clearly the SA is unsound.
With regard to landscape no weighting has been given and the comment suggests that there has been some judgement yet there has been nothing to base that judgement on given that there has been no comprehensive Borough wide landscape assessment. In this respect the SA is unsound.
Appendix G suffers from the faults previously identified; in particular in relation to biodiversity and landscape. Again the SA is unsound in this respect.
Given the above the overall SA is based on incomplete information and is therefore unsound.

SA_41

Nigel Bragg

Site 45 - Land adjoining Birchwood Avenue/Dower House Crescent, Southborough

As a local resident, I want to commend the council and put on record my support for its decision to not include this site in the Draft Local Plan. This land is clearly unsuitable for development as it is within an AONB and adjacent to ancient woodland. Additionally, the area already suffers from a lack of nearby facilities within easy walking distance, meaning any additional housing development would necessarily generate significant extra traffic simply in order to access basic local amenities such as shops and schools.

I look forward to the Local Plan moving from Draft to Final, with confirmation that Site 45 has been removed from consideration for future development.

With kind regards

Nigel Bragg

[TWBC: personal postal address has been removed]

SA_42

Peter Chapman

STR/CA1 I object to concreting over 600 acres of greenbelt in Tudeley/Capel.

Grotesque plan completely unsustainable.

Wildlife/bird poulation will be at best disturbed at worst habitat and numbers destroyed forever.

Light pollution- hundreds of lamposts, house lights,

Flooding- area already floods- where will the run off for 600 acres of concrete go?

Traffic- already gridlocked into Tonbridge at peak times. A new bus lane/cycle Lane? Will still join the gridlock just closer to Tonbridge. "discourage private car use"? Yeah right its raining today "shall we take the bikes to school today or take the Volvo V70 SUV?" TWBC can put in 50 bike and bus lanes 99.9% os new residents will NEVER use them.

Tonbridge is a medieval market town its roads are FULL

Trains- New development wil attract Londoners/out of area new residents. How will this benefit locals? Trains from Tonbridge are fill. Car parks at the station are FULL.

School at a gridlocked/busy roundabout with no train access? Crazy. Air quality for school children attending?

Water/gas/sewage- no infrastructure in place- Huge job to put it in ,further disruption and huge cost.

Traffic- Tonbridge roads alreadty gridlocked at peak times- thousand of new private cars will bring the town to a standstill.

New populationwill 100% gravitate to Tonbridge for their needs- NOT Tunbridge Wells.

Totally lazy planning by TWBC together with a greedy inherited landowner. Imposing a huge dvelopment on Tonbridge that will have profound effects on Tonbridge residents whilst having zero effect on Tunbridge Wells residents.

No special circumstances for building on green belt- just ease for TWBC councillors. Green belt is there for a reason- it is the lungs of towns and forms a break between Tonbridge and Paddock Wood.

There are much better places to build houseds and this ill conceived plan should never have been contemplated.

SA_44

Mr and Mrs Leach

Sustainability Appraisal Table 25 (Capel Parish sites)

2.8 Our points in-relation to the Sustainability Appraisal Table 25 (Capel Parish Sites):

a) We have the view that some of the Sustainability Objective scores are questionable and may not take account of wider impacts. For instance, Employment - there will be a loss of local rural employment, with relatively little new retail/service jobs created at in Tudeley and so the outcome is more likely to be neutral on this basis. However, when you consider the impact on Tonbridge, with the resulting congestion likely to harm the viability of many local businesses (see Section 1) that offsets increased commuter trade, this score could actually be slightly negative.

b. Travel should not be shown as positive, since it is a car reliant development (1.11c).

c. We agree that the Capel parish Environmental Objectives have mostly negative scores, with some of these issues highlighted above (in item 1.11diii). However, when considering the wider impact of the development, for instance air quality limits likely to be exceeded in Tonbridge - with the loss of trees and resulting town centre congestion; a more realistic outcome should be a double negative score (i.e. "--").

d. Due to the poor scoring of the Environmental Objectives, such a large development in the Capel parish is questionable; as it could be argued that there are insufficient net gains across the two other overarching Objectives (economic and social) to offset the immense environmental harm of the current proposals. Thus, we do not believe that the proposed massive village expansions can be considered as being sustainable developments and so are contrary to the NPPF (2019), Paragraph 8.

e. In addition, these garden village proposals are also incompatible with the strategic objectives set out in this Draft Local Plan, including Objective 8 (see item 1.11).

f. Land use rightly scores the worst (typically double / triple negative, i.e. "--/--"). This helps to both highlight how unsustainable this development is and shows that the proposed development strategy is at odds with National planning policy, which promotes brownfield development and the protection of the Green Belt (item 2.6).

g. Some of these comments also apply to the other garden village in Paddock Wood.

SA_45

Mr John Hurst

There has clearly been a lot of work put into this exercise, and whilst respecting that, I see several significant flaws in the analysis and conclusions.

1. Most seriously, how can the overall Climate Change impact given in Table 73 on page 129 be virtually neutral, when upward of 13,000 houses are to be built and lived in?

And what is the comparison with?

- the accommodation new residents have come from will continue to create emissions, and the replacement residents there will likewise travel and consume etc. There is bound to be a nett increase in Climate Change effects.

- improvements from low-emission vehicles will come anyway, so their impact cannot be accounted to the DLP

2. The discussion of alternative growth strategies is interesting, but the choice of Strategy 3&5 (Table 11 and para 6.2.9) is not the best one, now we have recognised we are facing a Climate Emergency.

Strategies 1&2 offer the best approach, ie incremental expansions from existing main hubs, with some minor expansions in villages.

3. Ref the Tudeley proposal, Garden Settlements are not the solution; please see this article by Essex-based Dr Rosie Pearson of Cambridge University:

https://medium.com/@stjohnscamalumni/spotlight-on-garden-towns-96027a927a37

4. Para 6.2.11 appears to put Growth before the Environment - we have to change that priority; the world has finite resources, and we now have to plan in accordance with that fact.

5. Para 7.2.3 acknowledges the DLP's negative impacts on the Green Belt.

But Table 9 on page 33 is surely wrong with its "0 Incompatibilities" in the Green Belt impacts line - the DLP proposes some 50%+ of future dwellings being placed on Green Belt land.

As I have commented in the main DLP consultation, there is no need to even think about using Green Belt land; the number of dwellings proposed is too high, and a reduced figure could be accommodated on brownfield sites, and outside the Green Belt.

There are no "exceptional circumstances" justifying using Green belt land for housing in the TWBC area.

6. Appendix A mentions biomass development - that should be off the table. We need to plant trees, not cut and burn them!

SA_46

Douglas Carroll

Site No. 304

Land to the north east side of Tonbridge Road, Pembury, Tunbridge Wells - K50612.

FUTURE DEVELOPMENT FOR HOUSING.

SUSTAINABILITY - Submission to Draft Local Plan Appraisal

The Borough Council’s criteria for building a sustainable housing development will be met. There will of course be the following objections which I could easily be overcome or arguably disregarded:-

1. ACCESS.

We already have a ‘farmyard style' metal gate at the southern end of the plot providing access off the A228. Southern Water, who have their own key, use it when servicing the main drains which pass east/west across the land to the hotel area.

As an alternative, a northern safer access off the A228 adjacent to Marshleyharbour Woods would be proposed with the provisions for a suitable Turning Lane whilst adhering to all Highway safety rules.

2. LAND OF OUTSTANDING NATURAL BEAUTY.

The land in question, now Plot 304, has been designated as Land of Outstanding Natural Beauty.

I can only question this as I know this was meadowland during the time when it was part of the Dower House’s 13 acre estate. The family moved here just after the war in 1947. As a boy, I used to help to bring in the hay every year. I also remember there used to be a caravan parked here and a model railway that used to provide much entertainment for family members and their guests. Therefore Pot 304 had no formal trees growing on it at all.

3. GREEN BUILT.

This is scrubland now that used to be part of the Dower House grounds. Plot 304 is a piece of discarded land left over after the 'cut through' B2015/A228 road was constructed through the land to Paddock Wood. Any allowable development here adjacent to Woodsgate Corner on the A21 would serve as a necessary ‘Infil’ between Pembury village to the east and the Hotel and Pembury Hospital to the west.

The sustainable positive points on the other hand are:-

A) This will be new development designed to meet all planning requirements, properly landscaped and providing adequate parking, loading and turning for all vehicles.

B) There are growing job opportunities along the A21 enterIng Pembury specifically and at the junction to the A228.

C) All three possible objections 1, 2 and 3 above can certainly be overcome.

D) All Utility connections from telecommunication to main drains are already available in this area and ready for connecting.

E) Land clearance in preparation for building to commence would be a straightforward operation. There are no protected trees as this site

F) there are excellent transportation links already in place.

G) There would be no noise, loss of light or pollution hindrances caused to either the local residents in the nest door estate to the east nor to the hotel to the west.

H) To the south is Woodsgate Corner and a large 24 hour Supermarket store just beyond.

All essential public services, Pembury village shops, pubs, amenities and social life are on the doorstep with a Garden Centre and of course Pembury Hospital just minutes away.

I) Due to the size of the proposed estate (24 to 36 dwellings), there would be very little impact on traffic volumes in this area.

I trust this submission will be considered in due course as part of the Local Plan.

Douglas Carroll.

SA_47

Mr Andrew Binnendijk

General: Road Safety

Most country lanes have not been planned to handle the volume and speed of traffic which they are currently carrying. This proposal will result in a significant increase in local traffic and this can only be considered if there is considerable investment in the local road infrastructure. This plan does not go far enough to balance the housing need with the need to improve road safety and sustainable transport. The plan should be supported with a comprehensive plan to widen roads, add pedestrian pavements and include a network of segregated cycle paths.

Specific Sites:

Site 128, 129, 130, 131, 132, 133, 409

These sites are linked to local schools and shouild be protected for education at all costs. Losss of sportsfields and school land has had detrimental effects on local communities in more urbanised parts of the country and the council should not succum to this short term approach when considering sites for development.

SA_48

Rachel Gritt

AL/RTW24- Cadogan Sports field, St Johns Rd

I dont want the council to build more houses on these playing fields.

I think we need to look after our environment, trees and green spaces.

Young people dont want more cars on the roads near the schools we want more buses and cycle lanes instead.

We need more local spaces to play games not moving fields far away.

I would like the council to focus on the environment and make Tunbridge Wells a much more green and healthy place to live.

SA_50

Peter Scrimshaw

My comments on the TWBC Draft Local Plan.

I live on Badsell Road and work from home, so I am very well placed to comment on how I feel these proposals will affect the local area. Other than the outrageous destruction of green belt land, I am very concerned about how traffic levels will change on what are quite minor roads in this area.

Badsell Road (B2017), Colts Hill and Five Oak Green village are already often at a standstill during the busy rush hour periods and this is before the extra traffic which will be generated by the 900 new homes already being built on the three development sites around Paddock Wood town. Paddock Wood has a fire station, police station and the ambulance service centre on Eldon Way, so there is a regular stream of emergency vehicles using all the roads out of the town. Colts Hill / Whetsted Road (A228) is known to be an important road link between the Tunbridge Wells and Maidstone hospitals and I see that the Colts Hill bypass is being resurrected, with the destruction of yet more old farmland which this will require. But this scheme was first deemed necessary before the current expansion of Paddock Wood, so how can this possibly be a sufficient solution to all of the extra traffic which this daft Local Plan will doubtlessly generate? At the very least you will need to wait and re-assess local traffic flow after all of the current new housing around Paddock Wood is finished and fully occupied.

Building a new garden village at Tudeley along the B2017 (basically a country lane) is frankly preposterous, as the vast majority of new residents will need to drive from there; parking at either Paddock Wood or Tonbridge railway stations will be totally impossible, if not already! I am also very concerned that this idea would eventually result in a continuous corridor of urban sprawl, from Tonbridge, through Tudeley and Five Oak Green to Paddock Wood, completely destroying the green belt buffer around Tonbridge.

I regularly walk my dog along the footpaths to the north of Badsell Road, up to the railway line and Whetsted Wood; this is an important area which is used by many other walkers & dog walkers, especially from Paddock Wood. Whetsted Wood itself is a small pocket of remaining ancient woodland, linked to the surrounding habitats by the existing field boundary hedges; it would become completely isolated by the new housing proposals.

I am also staggered by the outrageous hypocrisy of the proposal to build on green belt land at all, with other local planning applications often turned down for “inappropriate and harmful development which would have a greater impact on the openness of the Metropolitan Green Belt”, for example 18/01767/FULL (Erection of building for six B&B rooms associated with The Poacher, Tudeley) and 18/03915/FULL (Demolition of existing buildings and erection of detached dwelling at Builders Yard, Five Oak Green).

I do appreciate that there is a requirement to plan for future housing needs, but sincerely urge you to re-assess all available brownfield sites. Being able to deal with a single landowner is not any kind of justification for the destruction of such a large area of green belt land and the location is rather inappropriate anyway, being on the Medway flood plain and right on the boundary of Tonbridge & Malling BC.

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

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

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

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

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

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

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

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

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

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

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

Yours sincerely, Peter Scrimshaw

SA_52

Mr Andrew Perkins

Re - AL/RTW24 - Cadogan Playing Fields

I wish to register my objection to the planned construction of approximately 40 dwellings, as detailed by the council under this application number. In essence, my concerns are two-fold.

1) Pollution - The proposed dwellings are very close to the main A26 St John's Road that leads into Tunbridge Wells centre. This is a road that has 5 schools either on or very close to the road and the pollution created by all of the traffic is already known to be very high and at unacceptable levels. Further housing in this area will further exacerbate this problem with an additional 60-80 vehicles added to the local community that will likely use the A26 and local roads at peak time. This is hugely concerning given the current levels of pollutants measured on or very close to St John's Road.

2) I am concerned about the ongoing safety of pedestrians who currently use the A26 pavements, who already have to navigate significant traffic flows at peak times (and increasingly during other times of the day). A large proportion of these pedestrians are school children and a further increase in housing and the additional traffic this proposal will create will add to the danger that the pedestrians already face on a day-to-day basis.

Aside from these two issues, I am dismayed that the fields at Cadogan are not utilised more frequently than they are. There is a lack of school sports field facilities, in Tunbridge Wells, particularly for the new 'Free' School on the old hospital site and Skinners Boys school who currently have to travel all the way up to the Showfields grounds for their sports lessons. Providing access to Cadogan to schoolchildren would be a far better use of the fields rather than selling them for private development.

SA_53

John Kilkenny

AL/RTW24

We are against this proposal to Cadogen Playing Fields as we feel these fields could be better used for more local sports use and for the local schools in the area - which is what they were intended for when they were gifted to council.

Skinners would be one of these schools who would make good use of this facility along with the current local football teams who in reality will not travel to the proposed new central fields or will diminish by having to travel to these new fields and therefore diminsih the sports growth and facilities for locals.

The increase to polllution is also another massive concern by adding more houses to a busy road - the air has physical particles in it already and it would be negligent of council to propose increasing this health issue.

Drainage is already an issue to surrounding properties and my back gardeen is a swamp in winter.

No - to this proposal and focus on improving the facility that exists for the ebenfit of the locals and all for sports - take your housing proposals outside the congested town and build outwards - don't infill the few spaces we have in the town left for locals. |the town is too big to consider centralising to one facility.

SA_55

Gary Wheeler

Site45.Having seen the plan for development for 207 houses on Camp Hill it is very clear to many in the area that the infrastruture could not cope with more houses where there is conjestion already. Being in the area of AONB it would be a blight on this site in the green belt and for any further re-inclusion to the draft plan is unacceptable.

Gary Wheeler Bidborough resident

SA_56

Tom Ireson

site ref 100:Land to the south of Speldhurst Road, adjacent to Whitegate Close, Royal Tunbridge Wells

Hello,

I live in Stonewood Close off Reynolds Lane and my house backs on to 100 - listed as "Land to the south of Speldhurst Road, adjacent to Whitegate Close, Royal Tunbridge Wells ".

It is currently listed as 'Not allocated' although as I understand it the landowner has proposed a development of anything up to 400 homes

I urge that this remain not allocated due to the traffic situation both on the Speldhurst Road and on Reynolds lane. Regularly cars have to mount the pavement to negoitiate their way down Reynolds Lane and the situation before and after school near St Gregorys is complete chaos. Also the traffic on the Speldhurst Road pre school is extremely heavy. There is just not the road infastructure to support a massive new development of this size

Your Sincerely,

Tom ansd Penny Ireson

SA_57

Elle Arscott
Hangman's Hill Residents Association

This area is teaming with wildlife, ancient woods and farm life that will be affected or possibly lost forever (badgers, deer, woodpeckers, owls, hedgehogs and endangered stoats). Once you build on it, it is gone - that's it, game over! When will you recognise the fact that once we've built all over our countryside there will be nowhere left to go. We destroy the environment, we destroy ourselves - money will not save you!

SA_58

Mr John Wotton

I agree with the comments on this document which have been submitted by the Campaign for the Protection of Rural England's Tunbridge Wells District Committee. I am a member of that committee and chair of the Kent County Branch of CPRE. I am a resident of Cranbrook & Sissinghurst Parish.

Table 8 (under para 5.31) shows that the Housing objective is incompatible with considerably more of the sustainability appraisal objectives (9/19) than it is compatible with (5/19). It is the only objective in the draft plan which is incompatible with more sustainability objectives than it is compatible with. This serves to demonstrate the unsustainability of the Council's attempt to meet the artificially-calculated OAN set by government. This cannot be achieved sustainably, or in conformity with the NPPF, in this Borough.

The suggestion in para 6.1.8 that there is capacity in the borough to meet housing targets whilst still having “due regard” to AONB and Green Belt policies is demonstrably incorrect. The proposed strategy clearly fails to comply with national AONB and Green Belt policies by de-designating Green Belt to build several thousand homes in Capel Parish and allocating several sites for major development in the AONB and its setting for which no, or no adequate justification under planning law and policy is provided. Even if much higher density housing development were to take place on the allocated brownfield and greenfield sites outside the Green Belt and AONB (and its setting), I doubt that the Council’s planned housing targets could be achieved without harm to the Green Belt and AONB, contrary to the NPPF. Therefore the alleged compatibility has not been demonstrated. I strongly dispute the statement that growth that only partially meets “identified needs”, i.e. the Government-imposed formula plus a buffer of 9%, is not a reasonable alternative in the circumstances that apply in this borough.

I do not consider that the "garden settlement" proposed in Capel Parish is sustainable. Indeed, I do not believe that a garden settlement at any location in the Borough is necessarily an appropriate or sustainable means of contributing to the local need for housing, particularly affordable and social housing, in the borough. Nonetheless, having regard to paragraph 6.1.11 and Table 13, summarising the assessment of potential garden settlement sites, I wish to record my agreement with the Council's conclusion that location 9, land between Cranbrook and Sissinghurst (late site 22) is not a reasonable alternative. The adverse impact on the AONB and on Cranbrook, Sissinghurst and, potentially, Wilsley Conservation Areas of such a settlemnt would be very severe and incapable of satisfactory mitigation.

On the basis of my study of the draft Local Plan and certain Supporting Documents, I consider that the preferred growth development strategy summarised in paragraph 6.2.9 is not supported by the evidence the Council has relied on.

I consider that the assessment in Table 73 is incorrect in not showing that the draft Local Plan would have adverse efffects on climate change (notably by developing many greenfield sites, thereby losing their ability to absorb greenhouse gases and the lack of a sustainable transport policy) and on heritage (notably by destroying or obliterating historic settlement and land use patterns, including ancient field boundaries and by harming many heritage assets, including through changes to their setting).

SA_61

Carol Thorpe

Site number AL/PW4 land at Memorial Field west of Maidstone Road

i object to any development on this site, it was originally purchased by residents of Paddock Wood to provide an open space for leisure, recreation, and sport, in memory of the lives of those lost from families of Paddock Wood during the two Workd Wars.

As part of the Draft Local Plan TWBC have deemed this land as 'surplus to requirements' I can say as a resident of Paddock Wood for the past 30 years plus, this is a well used recreation area, not only for rganised sports but for residents to safely exercise their dogs, and for families to picnic and children who just wish to let off steam.

in view of the proposed housing developments in and around Paddock Wood, these open green spaces should be preserved, as the surrounding countryside is disappearing under tarmac and concrete.

PLEASE ADD OUR CONTACT DETAILS TO YOUR CONSULTATION DATABASE SO THAT WE CAN BE KEPT INFORMED OF ALL FUTURE PLANNING POLICY DOCUMENTS? WE UNDERSTAND THAT OUR COMMENTS WILL BE PUBLISHED BY THE BOROUGH COUNCIL, INCLUDING ON ITS WEBSITE.

SA_62

David Lovell

Sustainability Appraisal

This is just one of many documents associated with the Local Plan. In conjunction with other linked documents, this amounts to over a thousand pages the public is expected to digest and comment upon. This is entirely impractical and appears to be a deliberate ploy to inhibit objection. But of all those documents, this is the most impenetrable; 219 pages of planning phraseology and obfuscation, and appendices and tables which make assertions that are not explained or justified.

For example, table 15 is full of speculative claims that all will be well for air quality, biodiversity and climate change, and many other aspects, simply through investment or policy, without informing how that will be the case. Once the dressage is removed from this paper there appears to be little of substance to evidence ‘sustainability’ in the plans, but plenty of predisposition towards the aims of development, particularly in relation to the sites at CA1 and PW1.

For example, sewage is a constant problem within Paddock Wood, breaching drains and running down roads. The water infrastructure is beyond capacity, yet building work continues and the Local Plan proposes even more new housing without detailing what, if any, mitigation measures will be put in place. Those problems will be exacerbated by the developments in PW1 and CA1. The speculative nature of water supply and treatment is replicated by uncertainty over roads and transport, medical facilities and provision of communications. A school to cover education has been sited in a wholly inappropriate place, divided by a railway line and alongside a busy and air polluting main road. Like all the other vague and hopeful assertions, this is also unsustainable, although TWBC currently claim otherwise claiming, wrongly, approval from Kent County Council.

I am not able to devote the time needed to try and fully understand this document, but that is not to imply that I agree with it. Instead I rely on the comments and objections I raised in relation to the Local Plan, specifically to the proposals to develop on Green Belt land in Capel sites CA1 (and CA2) and PW1. However, from my initial examination, what comes over is a document that is manipulative and built on bias, and is therefore unrealistic and as unsound as the Local Plan itself.

SA_64

Jane Pyne

115 Land forming part of the Hawkhurst Golf Club, High Street Hawkhurst Kent AL/HA1

I will comment on just this plan as it is the one that will cause the most problems with Hawkhurst.

There are many comments about the benefit of a relief road in Hawkhurst. I and many who actually live here know that this is far from the truth. Even if the traffic went to Flimwell and knowing by experience Highways England does not always carry out what it suggests when you want it to. There is plenty of traffic that goes to Rye Road and down Highgate not everything needs the A21. There will be no relief whatsoever by putting in a relief road. This is a service road for the 400 plus houses so why destroy the golf course even more and put Hawhurst in a unsustainable position with even more traffic problems and fumes and even more queues?.

If that amount of housing was undertaken on a very sensitive area within the AONB and the undulating ground that is the golf course it would cause so much traffic because the amount of cars all the houses would produce is beyond reasonable, 1500 cars is the estimate and a reasonable one as there are many ocassions where there are three or four cars to a house you only have to walk round any village or town.

You would need cars as it is too far for many to walk in and do their shopping. It is a good jaunt from most area of the golf course.

The fumes are too much and with a further amount of cars from such a dense area would be too much. Trees will be removed and that is not what I would want to see happen to trees and they take a long time to grow, if you look at Robertsbridge by pass at the size of the trees and you will see how fast they grow in 30 years that is not very fast. The trees are needed to help sustain cleaner air.

There is also the srpings underground as well as over and has been shown in other sites that more flooding has ocurred as the footings are sunk into the ground and they are disturbed. This is a very wet area and with the different levels the area presents.

Hawkhurst is not the ideal place for such large areas of houses and you this must be accepted that this is a sensitive area within the AONB.

I feel that the relief road is an excuse to build as it is know that Hawkhurst has a traffic problem. There is no need for the unsustainble traffic alterations if the majority of lorries were taken out of Hawkhurst and directed elsewhere. If a different traffic system was used as has been intimated. Maybe the cars in Cranbrook Road are banned from parking from say 8am until 6pm then that would make the flow of traffic so much better. Alternative parking would need to be found.

If all else failed and consultation was made with the many bodies of what to do with the golf course and all that it encompasses and with no road then a good alternative could be found but not as it is. Hawkhurst cannot sustain such a large developement and a road that is not needed. You still need to have Cranbrook Road open so that you do not cut off that part of Hawkhurst to the north of the traffic lights including new developments and social housing. The emergency services and more.

The design of the golf course is flawed in every way.

The AONB and fields for cereal and cattle cannot keep being taken for housing.

Hawkhurst in no way shape or form can sustain these large developments,

SA_65

Myriam Ruelle

Sustainability - Paragraph 6.2.11 and 7.2.3 and generic comments

Putting quantitative growth as a priority is WRONG on many bases.

1. It goes against the Climate Emergency declaration by pushing for quantity over quality. We need to shift our economy from promoting quantities to qualitative grading of goods, services and housing.

2. The figures used by Central Government and set to local authorities are INCORRECT as per the ONS - these figures were reviewed down in 2016 but the figures obtained using incorrect methodology are being used (2014 figures). Moreover, using the logic of building more houses to tackle the housing crisis if wrong: it only goes to exacerbate it. Just like building new roads create more traffic. This has been demonstrated at lenght. So why carry on falling into the same pit? We need to address two housing problems as a priority: affordability and lengthening of life expectancy. Young people cannot afford new homes and old people cannot afford to move out of their homes that are too big. The issue is how to ensure these problems are tackled but I could not see this mentioned anywhere in the DLP.

3. The exisiting problems of lack of regeneration for local businesses and housing are simply ignored to make way for building new homes and business parks. Brownfields need to be prioritized and this is not happening enough in the DLP. There is no mention of what is being done with the hundreds of empty houses either.

4. The World's resources are finite, as is our local land and water supply. Aiming to loose more land to building is suicidal. Poor air quality is already killing 10K people a year in London alone, soil is being degraded due to intensive agricultural practices, the fresh water supply must be maintained and improved, not put in jeopardy, food grown and consumed locally must be encouraged rather than made difficult through loss of arable and pasture land.

For paragraph 7.2.3, negative impacts on the Green Belts are acknowledged. It is worth mentioning that the Green Belt is protected, as are AONBs and no development should be made on Green Belt unless exceptional circumstances can be demonstrated. There are NO exceptional circumstances for Tunbridge Wells at all! Inciting London workers to come and live in Green Belt settlements so local authorities get an extra financial income and big developpers line their pockets is NOT a goal to pursue. It is destruction on a grand scale and will have huge negative cummulative effects on quality of human life, pollution, biodiversity, soil, food safety and water supply. The financial costs of pollution are HUGE and neglecting to tackle the causes is wasting money as well as life!

Appendix 6: Biomass. This is currently the burning of wood pellets that are usually imported. It is not a long term solution at all, especially as one of the main CO2 capturing solution is to plant more trees. Liaising with KCC on how to produce clean electricity is a must. Some good ideas were outlined in the ELES consultation, like possible microgrids and using universities to develop research and development partnerships. Biomass using animal and human waste should be used as a good solution, as well as creating electricity from the natural composting processes. This could be developed to become a good starting point for micro-grids in rural areas.

SA_66

Mr Matthew Wilson

Appendix F - Site 45 (Land adjoining Birchwood Avenue/Dower House Crescent)

I wish to comment about the exclusion of Site 45 as a potential housing development site in the Draft Local Plan. I support the exclusion of Site 45 at Appendix 6 of the Draft Local Plan, as detailed in Appendix F of the Sustainability Appraisal of the Draft Local Plan (September 2019) (“the Appraisal”) and in the Site Assessment Sheets for Southborough in the Strategic Housing and Economic Land Availability Assessment (July 2019) (“the Assessment”)

However, I do not think that the Appraisal and Assessment go far enough in respect of their justification for exclusion of this site, for the reasons set out below.

Site 45 is within Southborough, however its geographic positioning is much more closely associated with the village of Bidborough. Accordingly the site should also be assessed by reference to the characteristics identified for Bidborough within the TWBC Settlement Role and Function Study (February 2017). It is not clear that this parallel appraisal has been carried out, which would undoubtedly highlight increased unsuitability of the site for development.

The Appraisal and Assessment note that development of the site would represent “a loss of a greenfield site in the AONB in an historic landscape”. However this conclusion should be enhanced to reflect that development would be in breach of both The Tunbridge Wells Borough Landscape Character Appraisal (December 2017) (“the TWBLCA”) and The High Weald AONB Management Plan 2019-2024 (“the Management Plan”).

In respect of the TWBLCA

Site 45 is within the Speldhurst Wooded Farmland Landscape Character Area (“the LCA”) and is specifically identified as being a Semi-Natural Landscape and Priority Habitat (see paragraph 2 at p71 of the TWBLCA).

Site 45 is currently a pasture field, which is used by local farmers primarily for sheep grazing and hay production. The site slopes away from the ridgeline at the NE boundary and existing houses at the ridgeline are well screened from view by mature trees and hedging. Any development would therefore be highly visible from within the LCA and AONB from the direction of Speldhurst and the SW, resulting in an urban as opposed to rural vista.

The scenic and distinctive topography of the ridges are stated as being particularly valued features of the LCA within the High Weald AONB (paragraph 1 - Valued Features and Qualities at pp71/72 of TWBLCA), along with the distinctive field pattern (paragraph 5) and the extensive views across the High Weald to pasture fields (paragraph 6). There are no realistic ways in which the adverse effects on these key characteristics could be avoided or mitigated. Section 2 of the TWBLCA sets out the decision tree criteria for considering landscape character, by virtue of which planning consent for Site 45 must inevitably be refused.

In respect of the Management Plan

Development of Site 45 would breach the following objectives:

“To protect the distinctive character of towns [and] villages…and to maintain the hinterlands and other relationships (including separation) between such settlements that contribute to local identity.” (Objective S2). The juxtaposition of Site 45 between Southborough and Bidborough means development would markedly diminish the separation between these settlements and effectively merge the two areas of urban development into one contiguous developed area. This would be in breach of the Proposed Action of “protect[ing] the relationship between historic settlement and its associated green spaces…”

“To enhance the ecological quality and functioning of woodland at a landscape scale. To increase the viability of the woodland habitat for wildlife, by identifying and extending the area of appropriately managed woodland (including restoring plantations on ancient woodland) to link and enhance isolated habitats and species populations, providing greater connectivity between woodlands and other important wildlife areas, and helping to facilitate species’ response to climate change.” (Objective W2). Site 45 would introduce an urban blockage between the Ancient Woodlands of Birch Wood to the north and Whortleberry Wood (part of Southborough Common) to the south-east, thus reducing connectivity and ecological functioning, and would serve to isolate Birch Wood from all but a narrow strip of undeveloped access across the adjacent Brookhurst Field. This would be in breach of the Proposed Action of “secur[ing]… buffer zones to protect ancient woodland and veteran trees from the detrimental effects of nearby developments”

“To secure agriculturally productive use for the fields of the High Weald…as part of sustainable land management” (Objective FH1). Site 45 is currently used for sheep grazing and hay production by local farmers. Development of Site 45 would remove this agriculturally productive resource in breach of Objective FH1.

The Appraisal and Assessment identify that the site is “let down by a lack of key services and facilities within a desirable walking distance from the site”. The TWBC Settlement Role and Function Study (February 2017) identifies Southborough as having a population of 12,459 and 5,037 households, whereas the population of Bidborough is only 1,163 with 409 households (Table 3 at pages 7-8). Bidborough is the second smallest development and the fourth worst served settlement across the borough (Table 4 at page 16) and whilst Southborough is identified as part of the Main Urban Area, Bidborough is identified in Group D in the Suggested Settlement Groupings (Table 5 at page 23). Consideration of development of Site 45 must have regard to the direct and indirect impact on Bidborough and its markedly different characteristics. Development of Site 45 with 200+ houses would result in a 50% increase in the number of households in Bidborough, which would have an exacerbated impact on the already limited local facilities and be unsustainable.

The Appraisal and Assessment should also take specific account of the impact on Bidborough Primary School, which would be unable to support the increased numbers of pupils necessitated by development of Site 45. This is the only primary school within walking distance of Site 45. The Education factor should therefore be scored negatively (and not positively as in the Appraisal).

The Appraisal and Assessment note that the site location is “adjacent to…Ancient Woodland [and] a Local Wildlife Site”. In fact the site is immediately adjacent to two areas of Ancient Woodland (Birch Wood and Whortleberry Wood) and two designated Local Wildlife Sites (“LWS”): Bidborough Woods & Pastures (TW26) and Southborough Common (TW27), plus it is in very close proximity to the Southborough Cemetery LWS (TW28). Under the existing Local Plan these LWS locations are also identified as Sites of Nature Conservation Interest (“SNCI”), which is not currently reflected in the Appraisal and Assessment. The adverse impact of development on these designated areas is therefore even greater than suggested by the Appraisal and Assessment wording.

The Appraisal and Assessment state that the site “scores positively in terms of…transport”. However the Tunbridge Wells Borough Development Plan Transport Strategy 2015-2026 (July 2015) already notes that the A26 between Southborough and Royal Tunbridge Wells is adversely affected by poor air quality, is designated an Air Quality Management Area (“AQMA”) and is congested at peak periods (paragraph 4.17). Once an AQMA has been declared, the local authority has a statutory requirement to work towards achieving the air quality objective (paragraph 4.31). On 1^st September 2018 the AQMA was extended northwards on along the A26 to the war memorial near the junction of Birchwood Avenue, having previously finished at Park Road. This extension is indicative of an ongoing deterioration in air quality near the junction with Birchwood Avenue.

Access into Site 45 would principally be off the A26 at this junction with Birchwood Avenue. Development of upwards of 200+ additional houses at Site 45 would necessarily result in a meaningful increase in traffic on the A26, both to the north of and within the AQMA area, with consequent adverse impact on air quality and the already congested local traffic conditions. This would put the Borough Council in conflict with its statutory duty in respect of the AQMA.

Furthermore, immediate access to Site 45 would be through narrow residential streets in the surrounding area of Southborough/Bidborough, which are not designed for or capable of absorbing a significant increase in traffic volume. This does not appear to have been reflected in Assessment and the Appraisal.

From a transport perspective Site 45 would therefore not be a sustainable development and the Travel factor should therefore be scored negatively (and not positively as in the Appraisal).

SA_67

Christine Spicer

6.2.26 Table 17 Paddock Wood

More needs to be done to make sure that overall we reach carbon zero.

All new houses should have solar panels fitted as standard. This needs to be implemented NOW, as houses are already going up.

Mitigation for loss of biodiverstity needs to be specified in detail

Exact detail of flood risk management, particularly with increased surface water drainage, needs to be specified.

6.2.29 Paddock Wood

The housing targets for the council must not override other considerations such as climate change.

Houses being built must be the right kind of houses:

1. Social housing, properly built and insulated, also with non-fossil-fuel heating [ground source heat pumps] and solar panels.

2. Affordable housing must be truly affordable and consist mainly of 2-3 bedroom houses, 1-2 bedroom flats, and 1 bedroom retirement bungalows, properly built and insulated, also with non-fossil-fuel heating [ground source heat pumps] and solar panels.

3. Few, if any 4+ bedroom houses need to be built

These comments apply to ALL building in the borough.

4. For Paddock Wood in particular:

Exact detail of flood risk management, particularly with increased surface water drainage, needs to be specified AND MUST BE FOLLOWED THROUGH.

SA_68

Mrs Sandra Robbins

Table 28 Cranbrookn & Sissinghurst

My comments are related to Sissinghurst in general and specifically to sites AL/CRS 12 and AL/CRS13.

When you weigh up the pro's and con's of any proposal one side should be more positive to act upon, Thus.....

Has the Government requested and stipulated more affordable housing ? - YES

Is the nation, and are local people happy that quintessential Sissinghurst village is being eroded ? - NO

Are affordable houses being built in the village percentage-wise ? - NO

Are they needed, given that current house sales are stagnating ? - NO

Are they being built in safe locations traffic-wise ? - NO

Is there available local work ? - NO

Is there local schooling where placements exist ? - NO

Is the current sewage system adequate ? - NO

Is there a sufficient medical system ? - NO

Are the plans sympathetic to surrounding properties ? - NO

Are bungalows being built for the increasing elderly population ? - NO

Is it right that single story properties are overlooked by two-story new-builds ? - NO

Is it fair that Sissinghurst is required to accept a greater percentage of new dwellings than Tunbridge Wells ? - NO

Can Sissinghurst cope with increased traffic ? - NO

Is local public transport adequate for all out-of-village needs ? - NO

Are there plans to build a few dwellings and then to take stock before continuing, maybe years later ? - NO

Is there a sufficient local Police presence to deal with the obvious rise in local crime ? - NO

Has this Consultation site been easy, simple and user-friendly ? - ABSOLUTELY NOT

NB: It could be argued that this site has deliberately been made more difficult, in order to minimise people's ability to provide a feedback !

SA_69

Mr Andrew McConnell

Site 285 Misty Meadow, Furnace Lane, Lamberhurst

I would like to comment on the very apparent inconsistencies in scoring for reasonable sites when recommending site 285, Misty Meadow for development.

In the commentary, several sites are noted to be let down by a lack of key services, facilities and public travel options. This would be exactly the same for site 285 if not more so, as this is one of the furthest sites from the village, but no consideration of this is mentioned in the table.
For site 423, Lamberhurst winery, a negative score is given for heritage regarding impact on heritage and landscape informed by location adjacent to Lamberhurst historical settlement and a loss some greenfield land in the AONB. This is exactly the same for site 285 if not more so, as the proposed site is also on a ridge line. However only a neutral score is given to 285
Again for sites 423 and AS_36 a negative score is given for landscape where 285 receives only a neutral score despite the fact that is within the AONB, adjacent to ancient woodland with a high biodiversity and is completely out of sync with the typical linear settlement pattern typical of the village.
Site AS_36 receives negative scores for both Services & Facilities and Travel. In the commentary this attributed to the location of the site relative to the settlement. The proposed site 285 is equally as far away from the settlement if not further away.
Finally in the commentary for AS_36 the number of negative scores is stated as reflecting the loss of an historic field in an AONB adjacent to historic settlement. This is exactly the case with site 285 but not mention is made of any of this.

SA_70

Mr Andrew McConnell

Appendix P Site 285

[TWBC: duplicate comment submitted - see Comment No. SA_69]

I would like to comment on the very apparent inconsistencies in scoring for reasonable sites when recommending site 285, Misty Meadow for development.

In the commentary, several sites are noted to be let down by a lack of key services, facilities and public travel options. This would be exactly the same for site 285 if not more so, as this is one of the furthest sites from the village, but no consideration of this is mentioned in the table.
For site 423, Lamberhurst winery, a negative score is given for heritage regarding impact on heritage and landscape informed by location adjacent to Lamberhurst historical settlement and a loss some greenfield land in the AONB. This is exactly the same for site 285 if not more so, as the proposed site is also on a ridge line. However only a neutral score is given to 285
Again for sites 423 and AS_36 a negative score is given for landscape where 285 receives only a neutral score despite the fact that is within the AONB, adjacent to ancient woodland with a high biodiversity and is completely out of sync with the typical linear settlement pattern typical of the village.
Site AS_36 receives negative scores for both Services & Facilities and Travel. In the commentary this attributed to the location of the site relative to the settlement. The proposed site 285 is equally as far away from the settlement if not further away.
Finally in the commentary for AS_36 the number of negative scores is stated as reflecting the loss of an historic field in an AONB adjacent to historic settlement. This is exactly the case with site 285 but not mention is made of any of this.

SA_71

Sarah Wilson

“Appendix F - Site 45 (Land adjoining Birchwood Avenue/Dower House Crescent)”

I support the Council's decision not to include this site in the local plan. Please DO NOT consider re-including it. The site is Green Belt in an AONB in a historic landscape. It significantly lacks key services and facilities within a desirable walking distance from the site. It adjoins Ancient Woodland, a local Wildlife Site and a Wildflower Meadow. The impact of development would be unacceptable loss of all the above which we have a human duty to preserve and maintain for the future.

SA_72

Sallyanne Clark

On reading the Sustainability Appraisal, I have a number of additional points to make.

On page 26, you list a number of sustainability objectives that can only be impacted negatively by the garden village development:

1- reduce air pollution

2- protect and enhance biodiversity and the natural environment

9- improve health and well-being

10- protect and enhance cultural heritage assets

12- protect soils and reuse previously developed land and buildings

13 protect and enhance landscape and townscape

14- reduce noise pollution

15 – improve travel choice and reduce need to travel by private vehicle

19 – manage flood risk

All this, in order to meet just one objective – provide sufficient housing to meet identified needs. But many people in the borough won’t be able to afford to live in these houses, so many of the people buying them will come from other parts of the county and London, as usual. The only other beneficiaries will be the construction companies – again, as usual.

The Appraisal document appears to justify why the garden village development ticks all the right boxes. But I fear that the scores have been incorrectly calculated.

One example is in respect of air pollution. On page 130, you admit that air pollution will be worse, but could be offset by ‘embracing technology such as electric vehicles.’ This is wishful thinking. The cost of electric vehicles will not reduce in the foreseeable future to a level that most people could afford one.

Another example is in the statement on page 131 that ‘negative biodiversity scores will be offset by biodiversity gains elsewhere.’ I’m sorry, but that does not help the residents of Tudeley or people like myself who want to walk in the area.

Thirdly, the gains to health are fulfilled (on page 136) by all the new residents ‘having access to green spaces.’ This does not make any sense when you consider all the green space that has been lost in creating the development, thus removing access for existing residents. The deterioration in air quality just makes this statement even more incomprehensible.

With regard to the table 14 on page 39, why are there frequent references to the unmet needs of Sevenoaks borough? Are we building houses for them as well?

Finally, I disagree with the assessment that DEFRA’s 25 year plan for the environment has ‘No Implication for the Sustainability Appraisal,’ as stated on page 23 of that document.

The targets in the 25 year plan include the following:

* safeguarding and enhancing the beauty of our natural scenery and improving its environmental value while being sensitive to considerations of its heritage

* making sure that there are high quality, accessible, natural spaces close to where people live and work, particularly in urban areas, and encouraging more people to spend time in them to benefit their health and wellbeing

* creating or restoring 500,000 hectares of wildlife-rich habitat outside the protected site network, focusing on priority habitats as part of a wider set of land management changes providing extensive benefits

* increasing woodland in England in line with our aspiration of 12% cover by 2060: this would involve planting 180,000 hectares by end of 2042

* meeting legally binding targets to reduce emissions of five damaging air pollutants; this should halve the effects of air pollution on health by 2030.

I should be grateful if you could explain why these targets are not relevant, while the housing needs target apparently is.

SA_73

Deb Clarkson

Site 45

We strongly support the council decision to not include the field in the Draft Plan.

The Field is of historic significance .The adjacent fields have a wildlife site and a wildflower meadow.

The site has a significant lack of key services and facilities within a desirable walking distance.Any development would put a considerable strain on existing services .

The loss of greenbelt to the area would cause harm to all the aforementioned points.

SA_74

Maggie Fenton

Non Tech Summary

Objection- this document is based on incomplete information and must therefore be considered unsound. The case for VSC for the release of MGB has not been made.

p. 2 “some loss of green belt’ is an understatement as it means 600 acres; the adjoining AONB will be harmed by the associated transport infrastructure.

p.2/3 Environmental scores seem to be overwhelmingly negative in the strategic sites

p. 3 Tudeley is the only “reasonable location” – there are no assessments for alternative locations e.g. Horsmonden site 177; so, this is an assertion rather than something clearly based on evidence. The “robust evidence’ base of 2017 did not make this a preferred Option. This lack of evidence makes the DLP unsound.

“land take to the West of Paddock Wood on the Green Belt “provides a suitable scale of extension with benefits for the economic, environmental and social elements of sustainability” even on your evidence environmental and social elements are negatively impacted compared to the non Green Belt Options. How is this a “suitable” scale? Suitable to what?

p. 4. cumulative impact assessment for each parish - chapter 8 shows Capel but lacks detail and underplays the local impact. The methodology is simplistic and crude. The environmental impact on Capel will be significantly harmful, including loss of BMV, heritage aspects, landscape and loss of MGB.

SA_75

Maggie Fenton

Introduction

p. 13 1.3.1 The report was then updated to take into account consultees’ comments and a final version prepared in October 2016. The Stage A Scoping Report should be referred to for a description of the original baseline, relevant plans, policies and programmes and the justification for the sustainability objectives that are being implemented in this report.

Capel Parish Council comments on the scoping report were not changed by TWBC despite them being told by CPC several times that it contained material inaccuracies.

SA_76

Maggie Fenton

Section 4

p. 20 4.1.2 Green Belt study stage 2; historic landscape characterisation; historic environment review – The local parish council was not consulted or made aware of these studies at the time they were done. Therefore, neither they nor the local community had the opportunity to contribute.

p.21 Landscape Sensitivity Assessment (RTW, Paddock Wood, Horsmonden, Hawkhurst and Cranbrook) done spring 2017 and July 2018 but does not include Capel where 4000+ houses are proposed to be built on the Green Belt. Once again the evidence base is unsound

p.24 KCC draft mineral and waste local plan. This is incorrect - Moat Farm and the entrance to and part of Stonecastle are within the borough and are adjacent to the proposed site in Tudeley

p.26 4 Climate Change: Reduce carbon footprint and adapt to predicted changes - the proposals for the Green Belt do not reflect this objective or the policy adopted by TWBC in July 2019. In fact the proposals will make a mockery of this.

11 Housing Provide sufficient housing to meet identified needs – identified needs of who? The government? TWBC? The Local community? Objective 12, 13, 14, 15, 17, 18 are all negatively affected by the strategic sites

4.3.2 How is it fair to score a biodiversity objective against the Ashdown Forest when the strategic sites have a very different geology, and therefore ecosystem, flora and fauna. They are sites of local biodiversity and should be measured on their own terms. Again the evidence base is lacking and smacks of smoke and mirrors to hide the real impact and loss of biodiversity that would ensue.

4.3.6 higher weightings given to issues legislatively driven, …of critical importance to the borough- this surely has skewed the appraisal in favour of the maximum number of houses in all cases – the appraisal has been thus predetermined by the council, as housing need according to TWBC outweighs all environmental and other considerations.

p.27 4.3.9 noted in the case of the strategic sites it is challenging to predict effects accurately – if the predictions are wrong the effects will be felt by the local community and not by the planners. The evidence base should be robust enough (which it is not) to more accurately predict …not just tell us its difficult!

4.3.10 realistic mitigation measures in line with the Draft Local Plan were assumed to be in place when scores were applied. But these are not in place and there is no guarantee they will ever be in place. Scores should reflect the current situation. Unsound evidence – again!

Table p.28 Biodiversity

Consideration was given to the requirement for net gains for nature when scoring the biodiversity objective for borough-wide strategies. This reflects the changes to the NPPF since the Issues and Options stage. A more precautionary approach was adopted for site level assessments, as the policy is in its infancy and it was not clear whether benefits would be delivered on or off site. Not clear what approach was taken by TWBC here; no net gain for nature when 600 acres of Capel Parish is covered by housing nor from TWBCs own evidence base regarding Growth Strategy 5 as an option!

p.29 4.3.13 what is the point of scores if they can’t be added up? They are masquerading as objective criteria but in reality, the subjective written commentary is the basis on which decisions are made. Crude in the extreme. You are dealing with OUR HOMES here and making decisions that will affect our lives!

SA_77

Maggie Fenton

Section 5

p.30 5.2.3 Where the term ‘appropriate’ in used in relation to Green Belt release, it refers to the land that contributes weakly to Green Belt objectives – the ‘weakly’ seems subjective and in the case of PW1/CA3 not borne out by evidence moreover it is not clear which ‘part’ of the MGB is being referred to. One of the differences between Paddock Wood and Capel is that Capel is in the Metropolitan Green Belt and Paddock Wood is not. The parish boundary is also the limits to built development of PW and the MGB boundary. This is the most important part of the MGB in Capel parish as it prevents the convergence of Paddock Wood and Five Oak Green. It maintains a sense of openness and separateness between the two communities which is the whole point of the MGB – it does not therefore ‘weakly’ contribute to the MGB. The stretch of the road further west of AL3 between Five Oak Green and the A228 does not give this impression to the same degree, it doesn’t give a clear sense of separateness between the village and its surroundings. But once you cross the A228 it is very different – after a few houses near the roundabout there is open countryside right up to the LBD of Paddock Wood. The boundary between the two parishes is at its clearest here – yet the proposal of the planners to end the MGB at the A228 would destroy this clear distinction between rural and urban which is the main function of the MGB. This most strategic section of the MGB would be destroyed and the two settlements would to all appearances have converged.

Please refer to your own Green Belt Assessessment regarding PW1 and were more land to be used than just this site as is now the intention!

Table 8 (para 5.3.1) purports to test compatibility of objectives. In relation to item 1 (Development needs) the table shows compatibility in every area but this is not possible to assess in relation to at least 2 (Biodiversity and Landscape) as full assessments of the current situation were not undertaken for key development areas.Table 9 demonstrates very high levels of uncertainty in relation to key objectives, especially in relation to the proposed Garden Settlements.

It is, therefore, totally wrong to simply conclude (para 5.3.3) that nine out of ten Local Plan Objectives are more compatible than incompatible with the Sustainability Appraisal objectives. If the outcome is uncertain then it may very well be that objectives are incompatible. The approach is wrong and the SA is therefore unsound.

Para 5.3.6 is based on pure speculation. If the Neighbourhood Plan content is dictated by the Strategic Policies of the Local Plan, given the high levels of uncertainty previously identified, it cannot be claimed that there will be compatibility.

Table 13 shows 13 possible garden settlement locations & indicates that only Capel and Paddock Wood (EAST CAPEL) were to be taken forward. However in March 2018 it was indicated to Parish Chairmen that 3 sites were shortlisted for appraisal, Horsmonden, Paddock Wood & near Frittenden BUT not Capel. Why does this not correspond?

Table 15 is also speculative in relation to biodiversity. Given the paucity of information on biodiversity in general it is simply not possible to justify the statement of small losses and potential gains. Without detailed studies and information of the ACTUAL biodiversity in the proposed sites, this is a ridiculous generalisation. This is unsound.

Similar concerns relate to Tables 16 and 17 given the lack of base information in relation to biodiversity.

p.31 6. Environment valued heritage not being protected e.g. Grade I Listed Somerhill; ‘net gains for nature’ this is far from being evidenced at all.

7. Green Belt – increase public accessibility unclear how this is to be achieved unless it means building access roads over the remaining MGB; no measures to protect the remaining MGB land. The purpose of MGB is NOT to give the general public somewhere to roam – it is to stop inappropriate development by LPAs, developers & landowners!

8. This totally conflicts with TWBC’s recently adopted policy as a climate change council.

9. It is troubling to see this as a model for even more development in the future presumably in the same parish

p.32 To argue the local plan objective on climate change is compatible with all the SA is just an assertion. How can that be when 600 acres of open farmland is to be built over and a road to be driven through the AONB?

The compatibility of local plan objective on Garden Settlements with SA objectives is a series of ?’s What does that tell us except that the whole thing is questionable!

p.34 5.3.8 “a clearer picture is now available on what sort of development would be created in a garden settlement. However, no presumption about potential locations for garden settlements is made for this element of the Local Plan thus several uncertain impacts are still predicted.”

There are no details on ‘what sort of development’ apart from that it will follow a master planned approach’; ‘no presumptions’ you are proposing development at Tudeley, Capel and PW – why are there no presumptions???????

SA_78

Maggie Fenton

Section 6

p.36 how many responses were there to this consultation which provided only a ‘slight’ preference for option 5? There was no preference for Option 5, the largest level of support was for Option 4 at 60%. This is twisting facts & data to suit. Unacceptable.

p.37-8 2 Capel/4 Horsmonden there is only very limited information on why alternative strategic sites to Capel were rejected (far less information than on small scale sites rejected ) e.g. there is no comparison between site 177 in Horsmonden and its ‘severe access difficulties’ [not explained] and the sites chosen; it is not measured against the comparative negative criteria in Tudeley and East Capel despite the later being in the Green Belt and in Tudeley’s case also bordering on AONB

12. This also refers to sites in Capel as well as PW. Land is outside of key constraints (except flooding and Green Belt) and has useful transport links – as if these constraints are conveniently less important? Not to those areas that flood TWBC! - and the transport links are already overused. The reference presumably includes the Colts Hill bypass which the SA conveniently fails to mention, would require significant damage to the AONB if it were to be built

6.2.4 – States that the final interim SA showed that Option 5 NSG had the highest positive scores and lowest number of negative scores. This is disingenuous given that it also had at least 6 sections unknown (?) score AND the presumption that any site chosen would be free of constraints including the greenbelt. Revisiting the scores given that both sites are now known and are in MGB, Flood risk zones, are comprised of BMV soils, rich in heritage assets, poorly served with bus services, highly rural, no train station, dependant on new infrastructure driven through the AONB etc would show them to be completely unsustainable.

p.41 6.2.9 – the views of Capel Parish Council were only sought after this strategy had been adopted. At no point has the council expressed a view supportive of this strategy. The council’s view is that there is no need to build housing in the Green Belt and the Borough Council’s strategy is flawed.

p.42 Table 15 the negatives for air, biodiversity, climate change, heritage, land use, landscape, noise, travel and waste would be considerably higher in a measure of the cumulative impact on Capel Parish where 4300 (50%) of the proposed housing shortfall is planned. Much of this will have very limited impact on other parts of the borough so this cross borough impact measurement is flawed. Furthermore it refers to SMALL biodiversity losses which could be offset elsewhere. This is at odds with the ‘significant’ impact mentioned elsewhere.

p.43 6.2.14 there is no detailed explanation as to why other large scale sites were rejected. Tudeley was not the original choice as a stand alone garden settlement, and that the choice was more to do with the single landownership than the absence of constraints. The nature of land ownership is not a good argument for rejecting a site outside the Green Belt for one inside it.

p.44 The bigger Tudeley site appears to have been rejected, but the concern remains that the council even envisaged large scale building in the AONB and that there is a high risk of this option returning at some later date to destroy virtually all the MGB between Tonbridge and Five Oak Green.

p.45 Table 16 Regarding CA1 it refers to ‘High Risk deterioration in air quality. Traffic will increase substantially (new settlement discouraging car use will bring large benefits)’. Presumably the existing settlements & residents are the ones who will suffer this high risk & only the influx of Londoners in CA1 enjoy those benefits. This is unreasonable and unacceptable.

p.45 6.2.18/19 Justifies a smaller settlement on the grounds that a larger one would be even worse: most of the adverse effects are caused by the nature of the development itself – mitigating this by not building something even larger is ridiculous. The only sustainability comparison is between the two Tudeley options – there are no comparisons with other options the council considered, particularly those outside the Green Belt.

p.47-8 Urban extension 6.2.20 -30 there are two options which would not have involved building on the Green Belt – the council have rejected these in favour of one that does. Option 1 has least impact in terms of a range of environmental factors. The effect on local biodiversity will be much greater than stated (even if it has no effect on the Ashdown Forest – surely this is a flawed and ludicrous measurement given that it is miles away with a completely different geology soils, and flora and fauna!). 1500 houses on option 3 is not going to enhance biodiversity as stated – the presence of several hundred more domestic cats (some 30% of households own a cat) will see to that! Dogs too are likely to decimate wildlife.

Option 1 has the least effect on climate change – but the council seems only paying lip service to this goal despite proclaiming themselves a climate change council. Option 1 has less effect on heritage than 2 and the setting of the Medieval moated Badsell Manor needs to be accounted for. Not clear whether this was included in the assessment.

Option 1 would have less effect on land use and noise than option 2; and giving 1 and 2 the same score for landscape seems illogical given the 201 acres extra lost to this scheme. The environmental scores are much more negative overall for option 2 than 1 and there is an argument that the difference has been underplayed in this assessment

6.2.28 Approximately similar outcomes for Options 1 and 2 – but clearly not on environmental measures see above.

p.49 6.2.29 It is clear that housing is the factor that motivates the council despite the impact on the Green Belt of option 2. This reads like the council chose the option they wanted and skewed these criteria to justify it. Environmental factors should have been taken more seriously and have been underweighted for the Green Belt section to the west of Paddock Wood. No exceptional circumstances have been put forward for building on the Green Belt outside Paddock Wood in Capel Parish when even the council realises there are alternatives which would leave the MGB intact.

6.2.29 but also improve the flood risk for existing residents must be highly weighted. This refers to Five Oak Green Flood Alleviation as well as PW. This has been used twice in this SA both in East Capel and Tudeley to justify development. This despite option 2 having been selected before TWBC were aware in Feb 19 of this scheme. Option 2 would ALSO require building on the most flood prone part of Capel Parish – so improving the flood risk as a highly weighted factor for the choice does not make any sense.

SA_79

Maggie Fenton

Sections 7 & 8

Section 7. SA of SP

p. 50 7.1.4 no specific alternative approach is identified – therefore impossible to judge chosen strategic sites against any possible alternative.

p.52 Table 18 highlights negative impact of Green Belt policy across the Borough. The impact on Capel Parish where all the Green Belt development is planned will be disproportionately greater. Why no cumulative impact assessment on Capel Parish alone as all the lost Green Belt is here?

Section 8. SA of Potential sites

p.55 8.1.4 sites were rejected including significant proportion of the site is Ancient Woodland, significantly reducing the developable area of the site CA2 has a significant portion of ancient woodland but has been included. This para also states that landscape considerations form one of the filters. What is totally unclear is what this is based on given there has been no comprehensive Borough wide landscape assessment. On this basis alone the SA is unsound

p.67 cumulative assessment for Capel Parish notes the negative scores for environmental objectives. Which the council clearly believe are a cost worth paying; and therefore, ultimately less important in the assessment.

Positive biodiversity score for AL/CA3 hard to believe if this referred to Capel section alone. There is no filter for biodiversity interests beyond consideration for designated sites.

This chart is assessing cumulative effects on Capel but includes an area mostly in Paddock Wood. The betterment for flooding in Five Oak Green could still be paid for under option 1 for PW.

Figure 10 demonstrates the significant and excessive proportion of Capel Parish being considered for development. No other parish is subjected to such pressures for deveopment. It is completely disproportionate. The designation “reasonable” is wrong.

Figure 25 suffers the same faults as earlier tables in relation to biodiversity. The commentary is biased. Without proper assessments of some factors in the first instance and given that there is an emphasis on development rather than conservation and respect for natural beauty and existing ecosystems there is bound to be a greater number of positives. Table 73 suffers from the same speculation as other tables with regard to factors where the base data has not been properly assessed such as landscape and biodiversity. The comments in Table 74 in relation to biodiversity are dependent on tables that are faulty for reasons given above; namely that without the proper initial assessment it is not possible to understand the impact on this key issue.

Similar comments also apply to landscape.

How can heritage for CA2 be 0 when it affects the views to and from Somerhill Grade 1 listed building?

It is clear that one parish is bearing a hugely disproportionate impact of this plan even on the Council’s figures. The environmental impact of the development in the Green Belt (with these three sites CA1; CA2 and PW1) in one small parish, when set alongside the impact of TP6 on the AONB with the associated transport infrastructure for these schemes which will carve its way through the remainder of the parish in a way this appraisal has yet to spell out, will disproportionately damage the quality of life for Capel residents over the coming years. Essentially the council needs to rethink its strategy and avoid building on the Green Belt, to protect the quality of life for its residents in Capel who cannot be expected to bear the full burden of development for the whole borough. This SA is based on the needs of the Borough as a whole it pays little attention to the cumulative effect on Capel Parish. Even this table envisions the positive impact for future residents. It does not reflect the impact for current residents.

p.70 note the negative score on climate change off AL/CA3 which contrasts with the limited impact of the other sites in the town.

p.87-8 Site 177 in Horsmonden originally seen an option for strategic development according to p. 37 has not been included in the assessment.

SA_80

Maggie Fenton

Sections 10 & 12

p.129 Table 73 score for climate change is a? – is this really sustainable for a climate change council? The impact of development in the Green Belt must be a big negative contribution.

p.131 The Biodiversity objective is compatible with (or has no relationship/an uncertain relationship with) all strategic objectives in the Draft Local Plan except Strategic Objective 4 (Housing) – see Table 8. This is principally because the large area of greenfield land take that would be required for construction of new dwellings is likely to create pressure on existing habitats. However, Strategic Objective 6 (Environment) offers protection to “valued natural environment” and expects net gains for nature thus any losses would be more than offset” There is no evidence presented for this assertion and the impact on biodiversity must be measured on each parish not across the borough. The flora and fauna of the Low Weald of Tudeley and East Capel cannot be replaced by compensatory measures elsewhere – it is a unique landscape with its own species.

p.139 the heritage effects on Capel Parish will be wholly negative – pattern of low weald farmsteads and the damage to the setting of listed buildings cannot be replaced.

p.140 housing it is not clear how this will benefit the residents of Capel or of Tunbridge Wells. It will result in the building of houses attractive to the London market which will put more pressure on existing infrastructure.

p.142 landscape - As for the cumulative impact from release of Green Belt sites, the cumulative impact on the Landscape objective of all allocated sites (equivalent to STR 1) is expected to be highly negative TWBC is urged to remove Green Belt development and refocus the plan in line with its environmental objectives. The commentary moves from highly negative to negative by the conclusion; the mitigation ‘to some extent’ is an assertion that has not been evidenced.

Appendix A demonstrates that no consideration whatsoever has been given to biodiversity and the natural environment outside of designated sites.

With regard to landscape no weighting has been given and the comment suggested that there has been some judgement yet there has been nothing to base that judgement given that there has been no comprehensive Borough wide landscape assessment.

Appendix G suffers from the faults previously identified; in particular in relation to biodiversity and landscape.

Appendix G p.177-9 The reason given for the rejection of many sites refers to their contribution to the Green Belt, the setting of Five Oak Green, and contribution to the landscape. These are the very reasons that have been ignored in the adjoining strategic sites. In particular the plan refers to the ‘weak’ contribution to the MGB part of CA3 makes – but it adjoins some of these sites, and its contribution is crucial as explained above.

Section 12 Appendices

Appendix O p.204-6 Horsmonden makes no reference to site 177 considered as strategic see p.37

SA_81

Bernard Couchman

Draft Local Plan and Sustainability Appraisal

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Misty Meadow, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.

With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage, and this has a direct influence on the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services as a result. The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal. These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops: There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is 7.6 miles away, and really only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service: There is only a very limited bus service for the village, with the bus to Tunbridge Wells taking 35 minutes, costing £6.00 per journey, and with limited frequency. Furthermore, the bus is always full with school children in the morning. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work. New residents are therefore likely to be using the private motor car for both work and transporting children to school (as the current bus is already over capacity)

Doctors: There is a very small and busy Doctors surgery that is at full capacity trying to cope with the amount of patients they have from Lamberhurst but also other villages.In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan. The Neighbourhood Plan is promoting developments that are well designed and reflect local character. The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above, there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Misty Meadow, Furnace Lane site.

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The proposed allocation of the Misty Meadow site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would be to allow for a series of small developments to be allowed within Lamberhust village nearer to the services. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant on the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

Our Parish occupies one of the most dramatic areas in the High Weald AONB with views across ancient landscapes that are enjoyed by residents and visitors alike. Protecting this unique landscape is important to our community.

We trust that these comments will be taken into account.

SA_82

Andrew Pinhorn

Policies AL/CA 1 and AL/CA 2

I am not a resident of Tunbridge Wells Borough but live near the Borough boundary with Tonbridge. I have lived at my current address for 22 years and prior to that for 5 years in Golden Green. I know the area around Paddock Wood, Capel and Tudeley well. This is an attractive rural landscape and an important reason why I choose to live here.

I am writing to object to The Sustainability Appraisal, particularly as it relates to AL / CA1 and AL / CA2. I know these sites well and have a number of criticisms and queries as follows:

The Sustainability Appraisal (SA) in my opinion, is extremely long at 221 pages and quite a difficult read. This makes it extremely challenging to formulate cogent comments.

I struggled to understand what facts underpinned the scores shown in various tables. Were these based on expert, independent input and if so, when were they done? Are they based on up-to-date information? It is notoriously difficult to compare a future, post development situation with a current, pre development situation, especially as the former requires very optimistic (favourable) interventions by parties who are not under the control of Tunbridge Wells Borough Council.

I am particularly interested in the scores in paragraph 5.3.1, Table 8, “Compatibility testing of Local Plan objectives with SA objectives”. I think that the SA objectives Air, Biodiversity, Climate, Change, Health, Heritage, Land Use, Landscape, Noise, Services / Facilities, Travel, Waste, Water, should all be marked as ”Objectives incompatible and/or conflict with one another” in relation to certain Local Plan Objectives, namely Infrastructure Needs, Travel, Distinctive Environment, Green Belt, Climate Change. If correct this would affect the scoring seen in paragraph 5.3.2, Tables 9 and 10. It would also invalidate the comment in paragraph 5.3.3, which currently states that Table 9 shows that “the majority (nine out of ten) of the Local Plan Objectives are more compatible than incompatible with the Sustainability Appraisal objectives.” By my reckoning the figure would be 5 at best, and cannot be described as a majority.

If I am right in saying that the SA objectives are significantly less compatible with the Local Plan Objectives than stated in the SA document, I would argue that the SA document is not a credible document and requires further work.

SA_83

High Weald AONB Unit

The NPPF, para 172, requires ‘Great weight to be given to conserving and enhancing landscape and scenic beauty in … AONBs …’. Section 85 of the Countryside and Rights of Way (CROW) Act 2000 requires all local authorities to have regard for the purpose of conserving and enhancing the AONB ‘in exercising or performing any functions’ that might affect land in these areas. This includes the preparation of an SA. Government guidance on the fulfilment of this duty states that ‘relevant authorities are expected to be able to demonstrate that they have fulfilled these duties’ (Defra 2005, p.4).

It is our view that TWBC does not give proper regard to impact on the AONB as required by NPPF, Para 172 and Section 85 of the CROW Act 2000, and that consideration of the AONB is not demonstrated for the following reasons:

The statutory High Weald AONB Management Plan is not included in Table 2 (para. 4.1.2) which lists sources of evidence for the SA.
Impact on the AONB is not specifically addressed in the SA, although one (of the 19) sustainability objectives identified in the SA (p. 26) relates to landscape with an objective to ‘protect and enhance landscape and townscape. However, impact on landscape, or how well the policy or site contributes to the landscape objective, is not assessed consistently. For example:

- All sites allocated in Hawkhurst lie within the High Weald AONB and development will permanently alter the characteristic AONB landscape yet only one of these (115, AL/HA1) is identified as having a ‘negative’ impact (i.e. a score of ‘ - - ‘ or ‘ ---‘) on landscape. The remaining sites score ‘slightly negative’ (‘0/-‘ or ‘-‘) despite development at one, Fowlers Park (413, , AL/HA4 allocated for 100 houses), resulting in the loss of a notable historic parkland.

- Similarly, in Cranbrook sites 59, 70, 323, 345 and 53 (together forming Gate Farm, AL/CRS6) score only ‘slightly negative’ (‘-‘), as their impact on landscape despite the Site Assessment Sheet noting that all five core components of the AONB’s natural beauty are present, including historic field systems with rare undisturbed grassland habitat. All will be lost under development.

- These inconsistencies are further compounded by a failure to include impact on soil carbon. Under the 'Climate Change’ SA objective of reducing carbon footprint, large allocations at Golford (AL/CRS7, 150 dwelling), Turnden (AL/CRS4, 170 dwelling) and Hawkhurst (AL/HA1, 450 dwelling), are recorded has having an Climate change impact score of unknown (?/-). These are greenfield sites with significant carbon stores present in the soil. Development represents significant loss of these carbon stores. Even under a development scenario delivering passivhaus standards and with no additional car movements, soil carbon will be lost to the atmosphere and the opportunity to increase soil carbon storage through regenerative agriculture or rewilding will be lost. All greenfield allocations should score ‘Negative’ or ‘Very Negative’ for SA’s Climate Change objective.

NPPF, para 172 emphasises that conservation of wildlife is also important in AONBs, and TWBC’s own AONB Management Plan includes policy to enhance the ecological function of fields (Objective FH3), woodland (Objective W2) and routeways (Objective R2), yet, for each allocation in Hawkhurst, Benenden, and Brenchley and Matfield the impact on the Biodiversity objective is rated at zero (0). Most of these sites are greenfield sites including three large sites (AL/HA1, AL/HA4, AL/HA6) allocated for a total of 629 dwellings) with valuable grassland, hedgerows and trees. For Cranbrook, the impact on Biodiversity is rated mostly as zero (0) to slightly negative despite including large sites with valuable undisturbed grassland, hedges and mature trees (such as Gate Farm). Loss of these habitats and species characteristic of the AONB, compounded by loss of soil biodiversity, will have a very negative impact on the SA’s Biodiversity objective ‘to protect and enhance biodiversity’. The SA score for each of these site/ policies should be ‘Negative’ (- - ) or ‘Very Negative’ (- - -). Net gain through development will not be achievable on these sites.
The almost universal highest sensitivity ratings applied by TWBC’s Landscape Sensitivity Assessment (July 2018) to landscape parcels around historic settlements in the AONB are not properly reflected in the SA; impact on landscape is not universally shown to be ‘Negative’ or ‘Very Negative’. For larger greenfield sites in the AONB the SA should show an impact score on Landscape as ‘Very Negative’ (- - -).

The NPPF, Para 8 describes what sustainable development means in relation to pursuing the three overarching objectives [economic, social and environmental] - ‘so that opportunities can be taken to secure net gains across each of the different objectives’. If accurate assessments had been made of impact on environmental SA objectives relating to the AONB, the majority of which would be ‘Negative’ or ‘Very Negative’, it would be clear that many of these sites – particularly the larger greenfield sites – would be unsuitable and unsustainable.

It is our contention that these apparent inconsistencies and under-rating of impact scores have led to inappropriate sites being wrongly found to be suitable for allocation. And further, that these inappropriately allocated sites include sensitive sites representative of the distinctive medieval character of the AONB for which it is nationally designated.

SA_84

Capel Parish Council

Section, paragraph number(s), or site (including page number)	Comment
Non-Technical Summary p.2	“Both of these concepts would involve some loss of Green Belt land” – “some” is understated. 600 acres will be lost and adjoining AONB will be harmed by the associated transport infrastructure.
Non-Technical Summary p.2-3	“The environmental objectives were found to produce either highly mixed, neutral or negative scores” – the scores are overwhelmingly negative in the strategic sites.
Non-Technical Summary p.3	“Tudeley village was the only reasonable location for a new settlement” – there are no published assessments for alternative locations such as Horsmonden site 144; so, this is an assertion rather than something clearly based on evidence. “Paddock Wood was the only reasonable location for an extension […] but with land take in the Green Belt to the west of Paddock Wood, would provide a suitable scale of extension with benefits for the economic, environmental and social elements of sustainability” – even on your evidence, environmental and social elements are negatively impacted compared with the non-Green Belt options.
Non-Technical Summary p.4	“a cumulative impact assessment was undertaken for each parish or settlement location” – Table 25 (Chapter 8, page 67), contains the assessment scores for Capel Parish but lacks detail and underplays the local impact. The scores for AL/CA1, TP6 and AL/CA3 appear to be totally fabricated and bear to relation to the evidence base. Further comments can be found in the relevant section below.
Chapter 1: Introduction – Purpose of this Report para 1.3.1 p.13	“The report was then updated to take into account consultees’ comments and a final version prepared in October 2016. The Stage A Scoping Report should be referred to for a description of the original baseline, relevant plans, policies and programmes and the justification for the sustainability objectives that are being implemented in this report.” Capel Parish Council’s comments on the scoping report were not changed by TWBC despite being told by CPC that it contained material inaccuracies.
Chapter 4: Methodology – Updates to baseline data para 4.1.2 and Table 2 p.20-21	“Table 2 below provides a list of additional relevant evidence studies that became available for consideration during Stage B following publication of the Issues and Options Sustainability Appraisal in July 2017.” Evidence studies outlined in Table 2 include; Green Belt Study (Stage 2); Historic Landscape Characterisation and; Historic Environment Review. Capel parish council was not consulted or made aware of these studies at the time they were done. Therefore, the local community had no opportunity to contribute. Table 2 also refers to a Landscape Sensitivity Assessment (RTW, Paddock Wood, Horsmonden, Hawkhurst and Cranbrook) completed during Spring 2017 and July 2018 but the assessment did not include Capel where 4000+ houses are proposed to be built on the Green Belt – why?
Chapter 4: Methodology – Updates to Plans, Policies and Programmes para 4.2.1 and Table 4 p.22-24	Table 4 refers to the KCC Draft Minerals and Waste Local Plan but incorrectly states that “Sites at Moat Farm and Stone Castle, Five Oak Green are adjacent to the boundary with TWB”. Both Moat Farm and the entrance to and part of Stone Castle are within TWB and adjacent to the proposed site in Tudeley STR/CA 1.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method Table 6 p.26	The Sustainability Objectives for Tunbridge Wells Borough are outlined in Table 6 and include the following: No. 1 “Reduce air pollution” No. 2 “Protect and enhance biodiversity and the natural environment” No. 4 “Reduce carbon footprint and adapt to predicted changes” No. 10 “Preserve and enhance historical and cultural heritage assets” No. 12 “Protect soils, and reuse previously developed land and buildings” No. 13 “Protect and enhance landscape and townscape” No. 14 “Reduce noise pollution” No. 15 “Reduce the impact of resource consumption” No. 17 “Improve travel choice and reduce the need to travel by private vehicle” No. 18 “Reduce waste generation and disposal” No. 19 “Manage flood risk and conserve, protect and enhance water resources” Policies AL/CA 1, AL/CA 2, AL/CA 3 & AL/PW 1 and TP6, are incompatible with all of the above objectives and therefore should be removed from the Draft Local Plan. Objective No. 4 in particular reflects the resolution made by Tunbridge Wells Borough Council on 17 July 2019 in which it recognised “that it has a responsibility to take a firm lead on reducing the council’s and the wider borough’s carbon emissions” and resolved to “Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030.” Not only are Policies AL/CA 1, AL/CA 2, AL/CA 3 & AL/PW 1 and TP6, incompatible with the Sustainability Objectives outlined above, but they are incompatible with the declaration made by Tunbridge Wells Borough Council on 17 July 2019 to recognise global climate and biodiversity emergencies and its ambition to make the Council’s operations carbon neutral by 2030. These policies should be removed from the draft Local Plan.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method Table 6 p.26	With regard to Sustainability Objective No. 11 “Provide sufficient housing to meet identified needs” – this is unclear. To meet whose identified needs? The government? TWBC? The local community?
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.2 p.26	“Scoring for the biodiversity objective was determined by the following three indicators; Sites of local biodiversity value included undesignated habitat; The Ashdown Forest SAC and SPA; Sites of Special Scientific Interest and associated risk zones” – how is it fair to score a biodiversity objective against the Ashdown Forest when the strategic sites have a very different geology, and therefore ecosystem, flora and fauna. They are sites of local biodiversity and should be measured on their own terms.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.6 p.27	“Higher weightings were given to issues that were legislatively driven, of critical importance to the borough and where finite assets were concerned.” - this surely has skewed the appraisal in favour of the maximum number of houses in all cases – the appraisal has been thus predetermined by the council, as housing need according to TWBC outweighs all environmental and other considerations
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.9 p.27	“Every effort was made to predict effects accurately; however, in some cases this was inherently challenging given the high level nature of the alternatives under consideration.” – if the predictions are wrong the effects will be felt by the local community and not by the planners.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.9 p.27	“realistic mitigation measures in line with the Draft Local Plan were assumed to be in place when scores were applied” – but these are not in place and there is no guarantee they will ever be in place. Scores should reflect the current situation.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.11 and Table 7 p.28	Table 7 outlines the alterations to the scoring method during Stage B. Under Sustainability Objective “Biodiversity” it states that “Consideration was given to the requirement for net gains for nature when scoring the biodiversity objective for borough-wide strategies” the reasoning being “This reflects the changes to the NPPF since the Issues and Options stage. A more precautionary approach was adopted for site level assessments, as the policy is in its infancy and it was not clear whether benefits would be delivered on or off site.” – it is not clear what approach was taken by TWBC here; where is the net gain for nature when 600 acres of Capel Parish is covered by housing?
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.13 p.29	“Because topics and objectives cannot be directly weighed against one another, readers are discouraged from ‘adding up’ positive or negative scores to give an overall score for a policy, strategy or site” – what is the point of scores if they can’t be added up? They are masquerading as objective criteria but in reality, the subjective written commentary is the basis on which decisions are made.
Chapter 5: Compatibility Testing of Strategic Objectives – Method para 5.2.3 p.30	“Where the term ‘appropriate’ in used in relation to Green Belt release, it refers to the land that contributes weakly to Green Belt objectives or to the strategic reasons outlined in the Green Belt Topic Paper.” – “weakly” is subjective and in the case of PW1/CA3 not borne out by evidence. Moreover it is not clear which ‘part’ of the Metropolitan Green Belt (MGB) is being referred to. One of the differences between Paddock Wood and Capel is that Capel is in the MGB and Paddock Wood is not. The parish boundary is also the limit to built development of PW and the MGB boundary. CPC would argue this is the most important part of the MGB in Capel parish as it prevents the convergence of Paddock Wood and Five Oak Green. In other words, it maintains a sense of openness and separateness between the two communities which is the whole point of the MGB – it does not therefore ‘weakly’ contribute to the MGB. The stretch of the road further west of AL/CA 3 between Five Oak Green and the A228 does not give this impression to the same degree; it doesn’t give a clear sense of separateness between the village and its surroundings. But once you cross the A228 it is very different – after a few houses near the roundabout there is open countryside right up to the LBD of Paddock Wood. The boundary between the two parishes is at its clearest here – yet the proposal of the planners to end the MGB at the A228 would destroy this clear distinction between rural and urban which is the main function of the MGB. This most strategic section of the MGB would be destroyed and the two settlements would to all appearances have converged.
Chapter 5: Compatibility Testing of Strategic Objectives – Method para 5.2.3 and Figure 4 p.30-31	Figure 4 outlines the Strategic Objectives of the new Local Plan. Capel Parish Council has the following concerns in relation to these: Objective 6 is “To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature” – the valued heritage and natural environments in Capel Parish are not being protected, for example the Grade 1 Listed Somerhill; There is no evidence of any net gains for nature either. Objective 7 is “To strategically release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land” – it is unclear how an increase in public accessibility can achieved unless it means building access roads over the remaining MGB; there are no measures to protect the remaining MGB land. Objective 8 is “To tackle climate change and minimise the impact of development on communities, the economy and the environment with carefully considered design and by embracing technology such as renewable energy generation” – this conflicts with TWBC’s recently adopted policy as a climate change council (see notes above) Objective 9 is “To establish garden settlements as a model for the future delivery of development in the borough” – it is troubling to see this as a model for even more development in the future, presumably in the same parish.
Chapter 5: Compatibility Testing of Strategic Objectives – Results para 5.3.1 and Table 8 p.32	Table 8 Table 8 purports to test compatibility of Local Plan objectives with Sustainability Appraisal Objectives. In relation to Local Plan Objective 1 (Development needs), Table 8 shows compatibility with all Sustainability Appraisal Objectives but it would not have been possible to assess compatibility with either Sustainability Appraisal Objective 2 (Biodiversity) or 13 (Landscape) as full assessments of the current situation were not undertaken for the strategic sites. To argue that Local Plan Objective 8 (Climate Change) is compatible with all the Sustainability Appraisal Objectives is just an assertion. How can that be when 600 acres of open farmland is to be built over and a road to be driven through the AONB? The compatibility of the Local Plan Objective on Garden Settlements (Objective 9) with Sustainability Appraisal Objectives is a series of ?’s What does that tell us?
Chapter 5: Compatibility Testing of Strategic Objectives – Results Table 9 and para 5.3.3 p.33-34	Table 9 outlines the number of Sustainability Objectives that are compatible with Local Plan Objectives. There is a very high level of uncertainty in relation to key objectives. For example; Local Plan Objective 2 (Infrastructure) is compatible with only 8 out of 19 Sustainability Appraisal Objectives (42% compatible) Local Plan Objective 3 (Travel) is compatible with only 8 out of 19 Sustainability Appraisal Objectives (42% compatible) Local Plan Objective 4 (Housing) is compatible with only 4 out of 19 Sustainability Appraisal Objectives (21% compatible) Local Plan Objective 7 (Green Belt) is compatible with only 4 out of 19 Sustainability Appraisal Objectives (21% compatible) Local Plan Objective 9 (Garden Settlements) is compatible with only 5 out of 19 Sustainability Appraisal Objectives (26% compatible) It is, therefore, totally wrong to simply conclude that “the majority (nine out of ten) of the Local Plan Objectives are more compatible than incompatible with the Sustainability Appraisal objectives.” If the outcome is uncertain then it cannot be ruled out that it is incompatible. The approach is wrong, and the Sustainability Appraisal is therefore unsound.
Chapter 5: Compatibility Testing of Strategic Objectives – Results para 5.3.6 p.34	“Strategic Objective 10 (Neighbourhood Planning) is also deemed to be compatible with all sustainability objectives because locally-led policies within Neighbourhood Plans are expected to demonstrate how they will contribute to achieving sustainable development” – this is speculation. If the Neighbourhood Plan content is dictated by the Strategic Policies of the Local Plan, given the high levels of uncertainty previously identified, it cannot be claimed that there will be compatibility.
Chapter 5: Compatibility Testing of Strategic Objectives – Results para 5.3.8 p.34	“Compatibility of sustainability objectives with Local Plan Strategy 9 (Garden Settlements) are based on those applied to Growth Strategy 4 in the Issues and Options Sustainability Appraisal” – why is compatibility of sustainability objectives with Local Plan Strategy 9 based on those applied to Growth Strategy 4 (the ‘Growth-Corridor Led Approach’) and Growth Strategy 5 (New Settlement Growth)? The same paragraph goes on “a clearer picture is now available on what sort of development would be created in a garden settlement. However, no presumption about potential locations for garden settlements is made for this element of the Local Plan thus several uncertain impacts are still predicted” There are no details on “what sort of development would be created” apart from that it will follow a master-planned approach. if, as the Sustainability Appraisal states on page 5, “Tudeley village was the only reasonable location for a new settlement” and this led to the inclusion of the site in Tudeley in the DLP as Policy AL/CA 1, then it is unclear why a presumption was not made that the location would be used in order to assess compatibility (or otherwise) of Local Plan Objective/Strategy 9 with the Sustainability Objectives. A proper assessment of a potential site would have led to certainty about compatibility. There is no justification for failing to properly assess the site at Tudeley against the sustainability criteria to achieve certainty.
Chapter 6: SA of the Spatial Development Strategy – Background and Method para 6.1.5 p.36	“Although these recommendations were felt to be the most useful output from the Issues and Options SA, it was noted that a slight preference was recorded for Growth Strategy 5 and that Growth Strategy 3 was slightly less positive than the other strategies” – this is misrepresentation. The Issues and Options Consultation Statement, available on the Tunbridge Wells Borough Council website at https://beta.tunbridgewells.gov.uk/local-plan/issues-and-options provides an overview of the Issues and Options consultation which ran from 02 May to 12 June 2017. This consultation included the question “Please let us know your preferred option or combination of options in order of preference”. The statement provides a summary of responses which states: “289 responses were received to this question in terms of ranking Strategic Options in order of preference. However, a significant number of these respondents stated they preferred a combination of Options as set out in Question 10a below. One respondent stated they did not agree with any of the Options. Of those who ranked the Strategic Options: 116 respondents (about 60%) ranked Option 4 (Growth Corridor-led Approach) as their most preferred Option; 34 respondents (about 18%) ranked Option 5 (New freestanding settlement) as their most preferred Option; 26 respondents (about 13%) ranked Option 1 (Focused Growth) as their most preferred Option; 16 respondents (about 8%) ranked Option 3 (Dispersed Growth) as their most preferred Option; 2 respondents (about 1%) ranked Option 2 (Semi-dispersed Growth) as their most preferred Option. From these responses, it can be concluded that of those who ranked the Strategic Options, the majority of 60% of respondents chose Option 4 (Growth Corridor-led Approach) as their preferred Option.” It is clear from this statement that rather than a slight preference for Growth Strategy 5, Three times as many people preferred Growth Strategy 4. Only 8% preferred Growth Strategy 3.
Chapter 6: SA of the Spatial Development Strategy Background and Method para 6.1.8 p.36	“Consideration was also given to a further option: growth that only partially meets identified needs. However, the iterative process through which sites were selected for development potential, including through the SA of sites, indicate that there is capacity in the borough to meet housing targets whilst still having due regard to AONB and Green Belt policies. Therefore, this option is not considered to be a reasonable alternative in the context of the NPPF at this point” If there is capacity in the borough to meet housing targets whilst still having due regard to AONB and Green Belt policies, why is development proposed which has a significant and detrimental impact on AONB and which results in the loss of 600 acres of Green Belt land? Option 9: Growth that only partially meets identified needs MUST be considered properly in the context of a Garden Settlement with a specified location which has been assessed against the sustainability objectives.
Chapter 6: SA of the Spatial Development Strategy Background and Method para 6.1.11, Figure 5 and Table 13 p.36-37	“Potential sites for garden settlements and urban extensions in the borough are shown in Figure 5. The locations underwent the same filtering process as that for sites with potential for small scale development (see section 8.1) and are described in Table 13 with an explanation of why options were not considered reasonable where applicable” The explanation of the approach taken by SA in relation to Capel (Ref 2 in Table 13) is “Land is outside of key constraints (except Green Belt) with potential for useful transport links” The ‘potential’ for useful transport links cannot be realised. There will be no new railway station and plans for the A228 strategic transport link (Colts Hill bypass) (Policy TP 6) and the proposed link route which is to run from the proposed development at Tudeley (Policy AL/CA 1) to the Colts Hill Bypass (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. The explanation of the approach taken by SA in relation to Horsmonden (Ref 4 in Table 13) is “Landscape sensitivity would require further consideration because the site is outside (but adjacent to) the AONB. However, the site was considered to have severe access difficulties that would render this alternative unviable and thus not a reasonable alternative.” There is thus only very limited information on why alternative strategic sites to Capel were rejected (far less information than on small scale sites rejected ) e.g. there is no comparison between site 144 in Horsmonden and its ‘severe access difficulties’ [not explained] and the sites chosen; it is not measured against the comparative negative criteria in Tudeley and East Capel despite the latter being in the Green Belt and in Tudeley’s case also bordering on AONB Paddock Wood (Ref 12 in Table 13) includes sites in Capel as well as PW. The explanation of the approach taken by the SA is “Land is outside of key constraints (except flooding and Green Belt) and has useful transport links” it appears that these constraints are conveniently less important for the purposes of the SA? The transport links are already overused and improvements are required. Please see our comments above in relation to the damage to the AONB in the event that the A228 strategic transport link (Colts Hill bypass) (Policy TP 6) and the proposed link route which is to run from the proposed development at Tudeley (Policy AL/CA 1) to the Colts Hill Bypass (Five Oak Green Bypass) are to go ahead.
Chapter 6: SA of the Spatial Development Strategy Results para 6.2.9 p.41	“in the light of the various options, together with the findings of further studies, consideration of availability of sites and the views of parish and town councils, a preferred growth development strategy has been formulated” This is misleading. The view of Capel Parish Council was only sought after this strategy had been adopted. At no point has CPC expressed a view supportive of this strategy. CPC’s view is that there is no need to build housing in the Green Belt and that Tunbridge Wells Borough Council’s strategy is flawed. Para 6.2.9 sets out that the Spatial Development Strategy has the following elements: “Provision for infrastructure-led, housing needs in line with Growth Strategies 3 and 5 including significant expansion of Paddock Wood and a new, standalone garden settlement in Capel Parish allowing for approximately 14,000 new homes over the plan period” “Provision for economic needs based on Growth Strategies 1, 2 and 4 including provision for approximately 14 hectares of employment land” “Provision of new local facilities and services where required to support residential development in smaller settlements “
Chapter 6: SA of the Spatial Development Strategy – Results para 6.2.10 and Table 15 p.42	Table 15 shows the scoring for the SA of the Draft Local Plan spatial distribution strategy referred to above. The score for Biodiversity is 0 or ‘neutral’ with the commentary “Small losses offset by potential large gains on strategic sites. Net gains policy will also bring benefits. Not considered at site level as gains could be offsite or out of parish” – this is speculative. Given the paucity of information on biodiversity in general it is simply not possible to justify the statement of small losses and potential gains. This is unsound. Biodiversity should be ‘very negative’ (---) not ‘neutral’ (0) given the loss of Biodiversity resulting from Policies AL/CA1, TP6 and AL/CA3. Only Air, Climate Change, Heritage, Land use and Landscape are scored as ‘negative’ or ‘very negative’. Noise, Resources, Services, Travel and Water are all marked with a question mark which TWBC represents a ‘mixed’ score. These scores do not reflect the negative impact on Capel Parish where 4,300 (63%) of the proposed housing shortfall is planned. Much of this will have very limited impact on other parts of the borough so this cross borough impact measurement is flawed. Travel should be ‘very negative’ (---) not ‘?’ as there will be an additional 25,000 cars on the borough’s roads with inadequate public transport (no new railway stations). Water should be ‘very negative’ (---) not ‘?’. Clearly there will be huge demand on existing resources and an increased flood risk for hundreds of homes. It is unacceptable to simply state that the impact is ‘uncertain’ in order to massage the data.
Chapter 6: SA of the Spatial Development Strategy – Results para 6.2.11 p.42	“the environmental objectives score well relative to alternative strategies” This is only because TWBC has chosen to score the majority of the environmental objectives as a ? in order to ensure the outcome of the Sustainability Appraisal reflects its chosen strategy.
Chapter 6: SA of the Spatial Development Strategy – Results para 6.2.14 p.43	“it was logical to assess Paddock Wood for a potential urban expansion and especially because the other, larger settlements of RTW, Southborough, Hawkhurst and Cranbrook have many constraints. Similarly, the largely constraint-free area of land submitted in Capel parish was logical to assess as a potential garden settlement location” There is no detailed explanation as to why the other large scale sites were rejected. Capel Parish Council believes that Tudeley was not the original choice as a standalone garden settlement, and that the choice was more to do with the single landownership than the absence of constraints. The nature of land ownership is not a good argument for rejecting a site outside the Green Belt for one inside it.
Chapter 6: SA of the Spatial Development Strategy – Results Garden Settlement Development Scale paras 6.2.15-6.2.14 p.43	These paragraphs relate to proposals for a larger scale development at Tudeley (Option 2) which consists of approximately 5,000 dwellings extending southwards further into the Green Belt and into AONB. Capel Parish Council strongly objects to any proposal to consider the larger development within the Local Plan, which, if it were to occur, would destroy virtually all the MGB between Tonbridge and Five Oak Green. Capel Parish Council is extremely concerned that Tunbridge Wells Borough Council ever considered a development of this scale on MGB and AONB, and seeks reassurance that Option 2 will not be reconsidered at a later date.
Chapter 6: SA of the Spatial Development Strategy Results Garden Settlement Development Scale para 6.2.17, Table 16 and paras 6.2.18-6.2.19 p.44-46	The sustainability appraisals for the two options at Tudeley are shown in Table 16 and the findings summarised in paragraphs 6.2.18-6.2.19 which appear to justify a smaller settlement on the grounds that a larger one would be even worse: most of the adverse effects are caused by the nature of the development itself – mitigating this by not building something even larger is ridiculous. The only sustainability comparison is between the two Tudeley options – there are no comparisons with other options the council considered, particularly those outside the Green Belt. As with Table 15, the use of ? as a score for any/all of the potentially negative scores is designed to skew the Sustainability Appraisal in favour of TWBC’s chosen strategy. It is absurd to suggest that a development of either size would have an uncertain or ‘mixed’ effect on Air Quality, particularly when the commentary goes on to acknowledge the high risk of deterioration to air quality which, in Tudeley is already on the cusp of exceeding the WHO target for acceptable levels of Fine particulate matter (PM2.5). Option 2 should be ‘very negative’ {---) and Option 1 ‘negative’ (--). The scoring for Biodiversity is understated with no consideration of the location in question. The commentary simply states “There is no risk the Ashdown Forest and neither option is within an SSSI Impact Risk Zone” which demonstrates the lack of diligence and understanding when scoring this Objective. Travel is scored as ‘very positive’ with commentary “The Travel scores are applied following a similar logic to air quality whilst also considering new bus routes and relatively easy access to train stations” this is not logical. There is no access to train stations, there are no bus routes in place and no pavements. The infrastructure will not be in place for several years after building begins. Option 2 should be ‘very negative’ {---) and Option 1 ‘negative’ (--).
Chapter 6: SA of the Spatial Development Strategy Results Urban Extension Development Scale paras 6.2.20-6.2.26, p.46	These paragraphs contain details of the four options considered for Urban Extension Development. There are two options which would not have involved building on the MGB – TWBC has rejected these in favour of one that does. Option 1 has least impact in terms of a range of environmental factors.
Chapter 6: SA of the Spatial Development Strategy Results Urban Extension Development Scale Figure 7 and Table 17 p.46-48	The sustainability appraisals for all four options are shown in Table 17. Capel Parish Council has the following comments: The effect on local biodiversity will be much greater than stated (even if it has no effect on the Ashdown Forest – surely this is a flawed and ludicrous measurement given that it is miles away with a completely different geology soils, and flora and fauna!). 1,500 houses on option AL / CA 3 is not going to enhance biodiversity as stated – the presence of several hundred more domestic cats will see to that! Option 1 has the least effect on climate change – but the council seems only paying lip service to this goal despite proclaiming themselves a climate change council Option 1 has less effect on heritage than 2 and the setting of the Medieval moated Badsell Manor needs to be accounted for. Not clear whether this was included in the assessment. Option 1 would have less effect on land use and noise than option 2; and giving 1 and 2 the same score for landscape seems illogical given the 201 acres extra lost to this scheme. The environmental scores are much more negative overall for option 2 than 1 and there is an argument that the difference has been underplayed in this assessment.
Chapter 6: SA of the Spatial Development Strategy Results Urban Extension Development Scale paras 6.2.27-6.2.30 p.49	The findings of the SA of the four options are summarised in paragraphs 6.2.27-6.2.30. “It is fair to conclude that Options 1 and 2 have approximately similarly outcomes overall” – this is based on a flawed assessment, see our comments above. “housing is of great importance to the council in meeting targets and options” - It is clear that housing is the factor that motivates the council despite the impact on the MGB of option 2. This reads like TWBC chose the option they wanted and skewed these criteria to justify it. Environmental factors should have been taken more seriously and have been underweighted for the MGB section to the West of Paddock Wood. No exceptional circumstances have been put forward for building on MGB outside Paddock Wood in Capel Parish when even the council realises there are alternatives which would leave the MGB intact. “but also improve the flood risk for existing residents must be highly weighted” – this refers to Five Oak Green Flood Alleviation as well as PW. This has been used twice in this SA both in East Capel and Tudeley to justify development. This despite option 2 having been selected before TWBC were aware in Feb 2019 of this scheme. Option 2 would ALSO require building on the most flood prone part of Capel Parish – so improving the flood risk as a highly weighted factor for the choice does not make any sense.
Chapter 7: SA of the Strategic Policies Background and Method para 7.1.4 p.50	“Policy STR 4: The NPPF provides thorough coverage of Green Belt issues although, as stated above, the policy is based on making the releases set out in the Draft Local Plan, so is appraised on that basis, effectively as a cumulative assessment of the relevant individual development allocations. As this is a cumulative assessment, no specific alternative approach is identified. Rather, the appraisal provides an indication of the sustainability impacts of the proposed releases, which are each subject to their own appraisal” No specific alternative approach is identified, therefore, it is impossible to judge the chosen strategic sites against any possible alternatives.
Chapter 7: SA of the Strategic Policies Results para 7.2.1 and Table 18 p.51-52	Table 18 details the SA findings for Strategic Policies; STR 2 Sustainable Development; STR 3 Master planning; STR 4 Green Belt and; STR 5 Infrastructure This Table highlights the negative impact of Policy STR 4 Green Belt across the Borough. The impact on Capel Parish where all the Green Belt development is planned will be disproportionately greater. Why was there no cumulative impact assessment on Capel Parish alone as all the lost Green Belt is here? Once again TWBC has substituted realistic scores (which would all be negative) for 0 or ‘neutral’ scoring for the key environmental Sustainability Objectives; Air; Biodiversity; Landscape; Noise; Services and facilities; Travel; Waste and; Water. This drives the SA scoring closer to supporting their chosen strategy.
Chapter 8: SA of the Potential Development Sites Background and Method para 8.1.4 p.55	“Sites filtered out at this initial first stage assessment stage include sites: […]That are wholly Ancient Woodland or a significant proportion of the site is Ancient Woodland, significantly reducing the developable area of the site” The site for Policy AL / CA 2 has a significant portion of ancient woodland and should have been filtered out at the initial first stage assessment. Why therefore was it included? “Sites filtered out at this initial first stage assessment stage include sites: […] About which there is significant landscape concern, which it is considered is unlikely to be overcome” What is totally unclear is what this is based on given that there has been no comprehensive Borough wide landscape assessment. On this basis the SA cannot be sound. There is no filter for biodiversity interests beyond considerations relating to designated sites.
Chapter 8: SA of the Potential Development Sites Capel (including Tudeley Village) Figure 10 p.66	Figure 10 demonstrates the significant and excessive proportion of Capel parish being considered for development. No other parish is subjected to such pressures for development. It is completely disproportionate. The designation ‘Reasonable’ is wrong.
Chapter 8: SA of the Potential Development Sites Capel (including Tudeley Village) Table 25 p.67	Table 25 details the SA scores for allocated sites in Capel Parish. With regard to Policy TP 6, the scores in Table 25 cannot be reconciled with the evidence. A bypass of this nature which displaces AONB land, will necessitate CPOs and includes roundabouts onto single lane, unsuitable for HGV, weight restricted roads should be scored as either ‘negative’ or ‘very negative’ for the following sustainability objectives; Air, Biodiversity, Climate Change, Health, Heritage, Land use, Landscape, Noise and Water. With regard to STR / CA 1, the scores in Table 25 appear to have been totally fabricated. The SA should be scored as either ‘negative’ or ‘very negative’ for the following sustainability objectives; Air, Biodiversity, Climate Change, Health, Heritage, Land use, Landscape, Noise, Travel, Waste and Water. The commentary is biased. Without proper assessments of some factors in the first instance and given that there is an emphasis on development rather than conservation and respect for natural beauty and existing ecosystems there is bound to be a greater number of positives. With regard to AL / CA 2, how can Heritage be 0 or neutral when the Policy affects the views to and from Somerhill – a Grade 1 listed building? With regard to AL / CA 3 a positive biodiversity score for AL / CA 3 is hard to believe if this referred to the Capel section alone. As with AL / CA 1, the SA should be scored as either ‘negative’ or ‘very negative’ for the following sustainability objectives; Air, Biodiversity, Climate Change, Health, Heritage, Land use, Landscape, Noise, Travel, Waste and Water. The cumulative assessment for Capel Parish – STR/CA 1 (cumulative) – notes the negative scores for environmental objectives which TWBC clearly believe are a cost worth paying; and therefore, ultimately less important in the assessment. This chart is assessing cumulative effects on Capel but includes an area mostly in Paddock Wood. The betterment for flooding in Five Oak Green could still be paid for under option 1 for PW. It is clear that one parish is bearing a hugely disproportionate impact of this plan even on TWBC’s figures. The environmental impact of the development in MGB (with these three sites under Policies AL / CA 1; AL / CA 2 and AL / CA 3) in one small parish, when set alongside the impact of Policy TP 6 on the AONB with the associated transport infrastructure for these schemes which will carve its way through the remainder of Capel Parish in a way this Sustainability Appraisal has yet to spell out, will disproportionately damage the quality of life for Capel residents over the coming years. Essentially the council needs to rethink its strategy and avoid building on MGB, to protect the quality of life for its residents in Capel who cannot be expected to bear the full burden of development for the whole borough. This SA is based on the needs of the Borough as a whole it pays little attention to the cumulative effect on Capel Parish. Even this table envisions the positive impact for future residents. It does not reflect the impact for current residents.
Chapter 8: SA of the Potential Development Sites Paddock Wood Table 27 p.70	Table 27 SA scores for allocated sites in Paddock Wood Parish. Our comments above in relation to Policy AL / CA 3 (Table 25) are repeated here under Policy AL / PW 1; The SA should be scored as either ‘negative’ or ‘very negative’ for the following sustainability objectives; Air, Biodiversity, Climate Change, Health, Heritage, Land use, Landscape, Noise, Travel, Waste and Water. What justification is there for scoring Biodiversity “as slightly positive overall to reflect the large improvements that can be made with AL / PW 1” – when there are no ‘large improvements’ proposed? Note the negative score for Climate Change in relation to AL/CA3 which contrasts with the limited impact of the other sites in the town.
Chapter 8: SA of the Potential Development Sites Horsmonden Table 39 p.87-88	Table 39 lists ‘reasonable alternative sites in Horsmonden Parish’ but is missing site 144, which is referred to on page 38 of the SA and was originally seen an option for strategic development. Why was this site not properly assessed? See our comments above.
Chapter 10: Conclusion para 10.1.1 and Table 73 p.129	Table 73 outlines a complete SA of all elements of the Draft Local Plan. In this SA, the score for climate change is a ? – is this really sustainable for a climate change council? The impact of development in the MGB must be a big negative contribution. Table 73 suffers from the same speculation as other tables in that the baseline data has not been properly assessed / scored and the majority of environmental objectives score as mixed with neutral scores. It is unacceptable to simply put a question mark out of reluctance to acknowledge a clear negative impact. It is obvious that the following sustainability objectives should record a negative score for the reasons outlined in this response; Air, Biodiversity, Climate Change, Heritage, Noise, Travel, Waste and Water. If these objectives had been properly scored, the SA would be more credible and accurately reflect the poor sustainability of the Local Plan.
Chapter 10: Conclusion Table 74 – Biodiversity p.131	Table 74 outlines the impact of the overall Draft Local Plan on each Sustainability Appraisal objective. Under Biodiversity, it is stated that “The Biodiversity objective is compatible with (or has no relationship/an uncertain relationship with) all strategic objectives in the Draft Local Plan except Strategic Objective 4 (Housing) – see Table 8. This is principally because the large area of greenfield land take that would be required for construction of new dwellings is likely to create pressure on existing habitats. However, Strategic Objective 6 (Environment) offers protection to “valued natural environment” and expects net gains for nature thus any losses would be more than offset” There is no evidence presented for this assertion and the impact on biodiversity must be measured on each parish not across the borough. The flora and fauna of the Low Weald of Tudeley and East Capel cannot be replaced by compensatory measures elsewhere – it is a unique landscape with its own species. The comments in Table 74 in relation to biodiversity are dependent on tables that are faulty for reasons given above; namely that without the proper initial assessment it is not possible to understand the impact on this key issue. Similar comments also apply to landscape.
Chapter 10: Conclusion Table 74 - Heritage p.139	Under Heritage, it is stated “The heritage objective is compatible with (or has no relationship/an uncertain relationship with) all strategic objectives in the Draft Local Plan except Strategic Objective 4 (Housing) – see Table 8. This is because the large amount of residential development planned in both rural and urban locations is likely to result in a risk of harm to designated or non-designated heritage assets. Strategic Objective 6 (Environment) addresses heritage issues directly by offering ‘protection to value heritage’” The heritage effects on Capel Parish will be wholly negative – pattern of low weald farmsteads and the damage to the setting of listed buildings cannot be replaced.
Chapter 10: Conclusion Table 74 – Housing p.140	Under Housing, it is stated “The Housing objective is compatible with (or has no relationship/an uncertain relationship with) all strategic objectives in the Draft Local Plan (Table 8). This is because the large amount of residential development planned is fundamental to the Draft Local Plan.” “The impact of STR 1 (Spatial Development Strategy) on the housing objective can be seen in Table 14. A highly positive score is recorded to reflect the reasons given above.” “As would be expected, across the parishes and sites, the most positive effects on the Housing objective are assigned to the sites that would deliver the highest numbers of housing. For this reason, policies AL/CA 1 and AL/CA 3 (aka AL/PW 1) are extremely beneficial to the borough. Highly positive effects are recorded in many rural settlements too for example Horsmonden, Hawkhurst and Cranbrook. No negative effects are expected from the site allocation policies. “ It is not clear how this will benefit the residents of Capel or of Tunbridge Wells. It will result in the building of houses attractive to the London market which will put more pressure on existing infrastructure.
Chapter 10: Conclusion Table 74 – Landscape p.142	Under Landscape, it is stated “As for the cumulative impact from release of Green Belt sites, the cumulative impact on the Landscape objective of all allocated sites (equivalent to STR 1) is expected to be highly negative” TWBC is urged to remove Green Belt development and refocus the plan in line with its environmental objectives. The commentary moves from highly negative to negative by the conclusion; the mitigation ‘to some extent’ is an assertion that has not been evidenced.
Appendix A - Decision-aiding questions used for scoring SA objectives Table 76 p.153	Appendix A demonstrates that no consideration whatsoever has been given to biodiversity and the natural environment outside of designated sites. With regard to landscape no weighting has been given and the comment suggested that there has been some judgement yet there has been nothing to base that judgement given that there has been no comprehensive Borough wide landscape assessment.
Appendix G – Capel Scores for Reasonable Sites p.177.179	The reason given for the rejection of most smaller sites in Capel parish refers to their contribution to the Green Belt, the setting of Five Oak Green, and contribution to the landscape. These are the very reasons that have been ignored in the adjoining strategic sites. In particular the plan refers to the ‘weak’ contribution to the MGB part of AL / CA 3 makes – but it adjoins some of these sites, and its contribution is crucial as explained above. Appendix G suffers from the faults previously identified; in particular in relation to biodiversity and landscape.
Appendix O – Horsmonden Scores for Reasonable Sites p.204-206	Horsmonden makes no reference to site 144 considered as strategic.
Conclusion	Given the above Capel Parish Council believes the overall SA is based on incomplete information and is therefore unsound. It fails to justify the extensive building within the Green Belt envisaged by the dLP, which Capel Parish Council maintains is unsustainable.

SA_85

Natural England

Natural England recognises that this plan provides strategic and development management policies which are supportive of the protections and enhancement of the natural environment. However we agree that policy requirements for measurable net gains for nature are critical in preventing the overall score for the Biodiversity objective becoming more negative. We have provided advice in relation to specific environmental policies in earlier sections of this letter, and this includes advice on developing a robust policy to secure measurable net gains for nature.

Regarding landscape, we agree with the overall conclusion of the SA that the plan results in a negative effect on the landscape objective and that this can be attributed to the quantum of development proposed within the AONB and within the setting of the AONB. We also recognise the finding that the in-combination effect of the allocation sites is expected to be highly negative.

We agree that accommodating large growth such as a garden settlement or urban extension would not be appropriate in the AONB. Nevertheless, we do not agree that the quantum of development currently proposed within the AONB demonstrates due regard to the AONB. Indeed, a negative score is attributed to landscape for the proposed spatial distribution strategy. Given the negative scores for landscape, and the significant landscape and visual impacts which will result from this level of development within the AONB, it would appear that the housing need may not be accommodated within the borough without significant adverse impacts to the AONB. We do not agree with the overview (p.142) that the impacts are being mitigated by development management policy or allocation policies. It is our advice that it is not possible to mitigate the significant adverse impacts arising from this level of development within and in the setting of the AONB. Major development should be located outside of the AONB, and designated landscapes should not be relied upon to meet housing needs within the Borough.

We refer to section 6.1.8 which mentions consideration of an option for growth which only partially meets identified needs. However, it is explained that this option is not considered as a reasonable alternative in the context of the NPPF at this point, as the site selection process indicates that ‘there is capacity in the borough to meet housing targets whilst still having due regard to AONB and Green Belt policies.’ Considering paragraph 172 of the NPPF, the AONB is afforded the highest level of protection, and great weight should be given to conservation and enhancement of the AONB. The scale and extent of development should be limited in this area. Given the requirements of the NPPF, Natural England considers the quantum of housing this plan proposes within the AONB is in conflict with national planning policy.

It is stated that allocations only occupy 0.7% of the AONB (SA, p. 142) and ‘only about one third, 17, of the allocations in the AONB are considered to be major development (Distribution of Development Topic Paper, p. 49). The wording of the reports appear to use these figures as an attempt to diminish the impact of the proposed level of development within the AONB, and this is not appropriate. The AONB designation carries equal weight across its whole extent and our objection to the principle of major development applies irrespective of the number of sites and the area impacted (cumulatively and individually).

In relation to monitoring, we provide the following advice:

Whilst it is not Natural England’s role to prescribe what indicators should be adopted, you may wish to include some of the following additional indicators, which have been adopted by other local authorities:

Biodiversity:

Percentage of the planning approvals likely to have an impact on wildlife, for which the Council negotiated provisions for a net gain in biodiversity
Number of planning applications refused or withdrawn in part due to their lack of consideration of biodiversity impacts

Landscape:

With regards to our previous comments on our position regarding the principle of major development in the AONB, we are very concerned by the indicator proposed for this objective, and furthermore it does not relate to the objective to protect and enhance the landscape. In addition to the suggestions below, we also recommend indicators which monitor how the plan is achieving positive outcomes for the protection and enhancement of protected landscapes.

New development in AONB with commentary on anticipated impact
Protection of greenbelt from inappropriate development (Although for greenbelt, this approach could also be readily adapted to protected and or wider landscapes)

Green infrastructure:

Percentage of the District’s population having access to a natural greenspace within 400 metres of their home
Length of greenways constructed
Hectares of accessible open space per 1000 population

SA_86

Ide Planning for Paddock Wood Town Council

PREFACE

Ide Planning for Paddock Wood Town Council (PWTC) thanks the borough council for staging the two local exhibitions and welcomes the opportunity to respond to the Plan and Sustainability Appraisal.

Alongside other consultees, PWTC has had limited time in which to prepare its response.

The point is made at the outset that PWTC has not been able in the time available to study in the necessary depth all that is proposed in the Plan and, in particular, the supporting documents. The PWTC also notes further work is needed on the Plan. The Town Council’s comments should be read in that light. PWTC will be looking to add to its representations at the next stage in Plan-making following what is hoped will be a meaningful and constructive dialogue with the LPA.

PWTC resolved on 11th November 2019 to OBJECT overall to the Plan and Sustainability Appraisal.

Objection is made at three levels.

Firstly, objection is made in principle which reflects 3 underlying concerns -

a. the number and extent of existing problems that have and continue to affect the town i.e. before the planning/development at Mascalls Farm, Mascalls Court Farm and Church Farm and which, in the past, appear not to have been capable of redress through the parties involved on either an individual or collaborative basis.

The most prominent of these issues being –

i. fluvial flooding;

ii. surface and foul water drainage, and their interrelationship; and

iii. the vitality and viability of the town, including its small commercial centre, across the spectrum of uses including business, health, social, leisure etc. for the benefit of the wider community.

b. that these problems will remain unaddressed, made worse or added to with the addition of 4000 new dwellings at Paddock Wood/eCapel, and (nearby) new settlement at Tudeley.

c. the loss of green belt and the need to preserve the setting of the town particularly to the west given the scale of development proposed at and around the proposed garden village at Tudeley within the Plan period and beyond.

Secondly, the objection to the Plan identifies a number of cross cutting issues common to a number of policies.

Thirdly, the response to the Plan picks out individual policies where comment is made as appropriate – these are presented either as objections or as expressions of support.

The schedule that follows addresses the Sustainability Appraisal alone.

The representations made by the Town Council have drawn upon a number of sources including a public exhibition held on 19th October 2019, from meetings of the Planning and Environment Committee and full Council during the consultation period, and specialist contributions, in particular, on flood risk.

SA_87

Ide Planning for Paddock Wood Town Council

3. Legal Compliance

OBJECT (holding objection)

It is unclear to what extent the Level 2 SFRA informed the strategy proposed for Paddock Wood/east Capel and the assessment of alternative sites elsewhere in the borough and whether therefore SEA requirements have been met.

SA_88

Ide Planning for Paddock Wood Town Council

4.1 et seq Methodology

OBJECT

1. The Plan is confined to the borough’s boundary. The strategy proposes transformational change to Paddock Wood/east Capel, and a new settlement at Tudeley, close to Tunbridge Wells and Tonbridge. Paddock Wood would no longer remain a small rural town. The strategy proposed would more sharply divide the borough into an urban west and rural east.

2. There is a Duty to Cooperate in Plan preparation concerning strategic cross boundary matters. Statements of common ground have not yet been agreed with Tonbridge and Malling BC, or for West Kent.

3. In its present form, the Plan should proceed on the basis of a joint Plan that includes Tonbridge and Malling BC (i.e. Tonbridge) and perhaps part of Maidstone BC in order -

i. to ensure cross boundary issues are fully addressed including health, transport, social care and education;

ii. in view of the planned provision of development at Tudeley beyond 2036; and

iii. to consider the possibility that development proposed at Paddock Wood/east Capel could similarly be phased over a longer time frame. This would allow for a reduction to be made in the allocations proposed under AL/PW1 – there is the additional point, in light of the physical constraints referred to elsewhere in Paddock Wood/east Capel, whether any unmet need in the borough could be more sustainably located within the Tonbridge and Malling and Maidstone boroughs under a jointly prepared Plan?

4. For development to be sustainable there is a need to identify land for the right type of development, sites must be in the right place, and development must be supported by infrastructure.

Borough wide, the allocations proposed for Paddock Wood/east Capel and Tudeley have been determined substantially on the basis of minimising the release of green belt and minimising the impact of development upon the AONB.

Objection is made to the loss of green belt to the west of Paddock Wood to accommodate development at parcels 1, 2 and part of 3 under AL/PW1.

All the housing sites identified in the Key Diagram and under AL/PW1 require flood compensation. Bringing forward development sites presently prone to flooding is arguably more contentious than releasing sites in the green belt or AONB given the costs involved (including the opportunity cost) and environmental impact i.e. given that with climate change the prospect is storage, attenuation and mitigation measures will need to be ‘topped up’ in future. Building upon the ‘wrong’ sites if, indeed, is what is proposed, is not sustainable - it absorbs developer contributions better put elsewhere and compromises the garden village ideal that underpins the strategy for Paddock Wood/east Capel.

A Strategic Flood Risk Assessment (SFRA) 2019 underpins much of what is proposed for Paddock Wood/east Capel but this is considered to be an unreliable basis for doing so. An initial review of the SFRA raises questions concerning the period over which the SFRA was undertaken, how it tied in with the Sustainability Appraisal (in particular, in assessing alternative strategies), and how robust the SFRA is in terms of the data it has relied upon and the modelling undertaken. The absence of detail concerning flood storage, alleviation and mitigation measures raises fundamental doubts about the viability and deliverability of the strategy proposed for Paddock Wood/east Capel –

a. the SFRA has been carried out on a borough wide basis. As the Plan has evolved, cross boundary issues have become more prominent. The impact of the strategy proposed at this stage, beyond the boroughs boundary, in flood risk terms, appears not to have been assessed;

b. the SFRA has not carried out a Sequential Test (ST) of potential development sites (para. 13.2, Level 1 Report). If an ST has not been carried out borough wide, it cannot be said there are not other sites that are less prone to flooding, and which may be more suitable for development;

c. further to ‘b’, it is unclear at the moment what this means for the individual parcels identified for development under AL/PW1. For example, in the Level 2 Report, for parcel 1, it was noted by the borough council’s consultants ‘Parcel 1a is located in the path of an easterly flood flow route, which continues into Paddock Wood. During initial discussions with the council, it was agreed to position the residential area in this location (and therefore not following the sequential approach for placement of development)…’ (Appendix I).

d. Information in the SFRA provides insufficient detail to satisfy the requirements of the Exceptions Test (ET) for ‘individual developments or groups of developments as part of a masterplanned or comprehensive development approach’ (para. 1.4.1, Level 2);

e. the Stage 2 SWMP for Paddock Wood noted that the town’s susceptibility to flooding is influenced by the existing surface water network being at capacity (para. 2.4.2, Level 1 Report);

f. the SFRA appears to have mixed up the Beult and the Bewl (Table 6-1, Level 1 Report). It is unclear if this is a typing error or, if intended, how this might affect the modelling undertaken by the consultants;

g. It appears that the UMIDB has, at best, had only limited involvement in the preparation of the strategy;

h. it is unclear as to how the existing/planned developments at Mascalls Farm, Mascalls Court Farm and Church Farm, and the proposed development of certain of the individual parcels under AL/PW1 will relate to one another.

Detailed comment on the SFRA is supplied under separate cover.

Comment on individual parcels under AL/PW1 follow. PWTC’s concern is the extent to which the allocations made under that policy accord with the NPPF/PPG.

5. Whilst the LPA subscribes to garden settlement principles in guiding development at Paddock Wood/east Capel and Tudeley, it is unclear whether both places could be designated as garden villages and so benefit from assistance that the government’s programme can provide.

The Plan proposes masterplanning and betterment as a cure-all. When the planning, resource and coordination that is implied by this is compared, to take one example, with Homes England’s garden community initiative in West Ifield (West Sussex), PWTC remains unconvinced that the borough council, despite its best intentions, has the capacity to deliver its strategy in its present form.

6. Homes England suggests ‘given its complexity, potential for infrastructure provision needed up front and long timeframe for delivery, CIL may not always be feasible or appropriate for a garden community scheme’ (MHCLG Land Value Capture and Funding Delivery, 27th September 2019).

7. The LPA’s assessment of housing need/provision inflates housing numbers required over the Plan period which has a bearing upon the allocations proposed for Paddock Wood/east Capel.

8. With regard the distribution of housing development, objection is made above under ‘4’ above to the loss of green belt.

It is considered there is more scope for development to be allocated elsewhere within the borough. For example, Cranbrook has escaped the development allocated in the SALP, whilst Hawkhurst (a smaller town in the Borough & the AONB) has seen considerable house building and is taking more houses than Cranbrook in the draft Local Plan. Why has Cranbrook not been allocated an increased share, when flooding is not a problem and the town centre is well established with schools that have capacity for increased student numbers? It is possible to build sympathetically within the AONB – other Boroughs have done this. It is also unclear whether some of the development proposed at Paddock Wood/east Capel could be more sustainably located at Tudeley.

9. Questions arise concerning the identification, prioritisation and phasing of specific infrastructure schemes and hence the deliverability of the strategy. In respect of their prioritisation, more infrastructure may be critical and essential than desirable. Of particular concern is how critical many of the projects are, the magnitude of cost, the uncertainty concerning their phasing and the funding position overall. For example, the IDP lists the new Colts Hill bypass as being critical (p94), as needing to be in place before sites come forward for development, yet the all-important policy STR1(2) refers to the bypass in terms of it being a potential scheme.

Comment follows [below] on improvements required to the highway network to accommodate the development proposed. These improvements are needed to add to capacity locally and to mitigate impacts upon air quality.

10. The viability of the Plan is unconfirmed – whilst the Stage 1 Viability Assessment says the consultant’s find reasonable viability prospects available borough-wide to support the Plan’s delivery, the viability of the larger/strategic site allocations has yet to be addressed in a Stage 2 assessment.

SA_89

Ide Planning for Paddock Wood Town Council

P25 Table 5

Reference is made to emerging Plans in neighbouring Tonbridge and Malling, and Maidstone indicating potential cross boundary effects that have yet to be considered by the SA. Tonbridge and Malling BC has raised concerns including location of a proposed school – these , and a host of other issues should be addressed as part of a jointly prepared Plan, and an SA should be undertaken on that basis i.e. extending beyond the narrow confines of the borough council’s administrative area. It is understood that Maidstone Borough Council is actively investigating development sites immediately adjacent to the Paddock Wood boundary, including Beltring.

SA_90

Ide Planning for Paddock Wood Town Council

P26 Table 6

OBJECT including –

Including green belt can be considered to be a laudable sustainability objective in providing for the containment of the built up area, and preventing settlement coalescence and encroachment upon countryside. It should be referred to expressly at #12 as it is a decision aiding question in Appendix A (p156). The loss of green belt should be given high weighting;
#1 should refer to improving air quality;
Under #19, flood risk should be separated from the demand for water. It is noted that adding to flood risk on/off site is given a high weighting (Appendix A, p158) – managing impacts from flooding should be afforded similar importance.

SA_91

Ide Planning for Paddock Wood Town Council

5. Compatibility testing of Strategic Objectives

OBJECT

The strategic objectives of the Plan are borough wide; no indication is provided in the Plan’s list as to their priority; whilst SO2 refers to the delivery of infrastructure, SO9 refers to the garden settlements (plural) and part of STR5(5) should be added to SO9 i.e. to say that new development at these settlements will only be supported if sufficient infrastructure capacity exists, or can be provided in time to serve the development.

An objective should be added to the Plan related to flood risk i.e. to protect people and property from flooding and to safeguard land from development that is required or likely to be required for current or future flood management.

At p48, Table 17, the scoring of options is contingent upon the provision of infrastructure about which the Town Council has concerns as expressed above under ‘4’.

SA_92

Ide Planning for Paddock Wood Town Council

6. SA of the Spatial Strategy

OBJECT on the same grounds under s4 above.

In addition –

At Table 13, the allocation of sites is not dependent upon the call for sites;
At 6.2.20, four major urban extension options are identified for Paddock Wood/east Capel. At 6.2.29, it is stated that development option 2 (5000 units?) was selected – ‘Ultimately, the scale of development…was determined in relation to the housing objective…housing is of great importance to the council in meeting targets and options that not only meet targets but also improve the flood risk for existing residents must be highly weighted’. And on p3, in the NonTechnical summary ‘For the urban extension…Paddock Wood was the only reasonable location for an extension and that a scale set away from the constraints in the south (ancient woodland and AONB), but with land take in the Green Belt…would provide a suitable scale of extension with benefits for the economic, environmental and social elements of sustainability’. No mention is made to flood risk, unlike in the preceding paragraph – ‘Tudeley village was the only reasonable location for a new settlement and that a scale limited by the flood risk to the north [my emphasis] and the AONB and Green Belt to the south would be the most preferred’ i.e. for 2500-2800 dwellings.

SA_93

Ide Planning for Paddock Wood Town Council

7. SA of the Strategic Policies

OBJECT as under ‘4’ above

SA_94

Ide Planning for Paddock Wood Town Council

8. SA of Potential Development Sites

OBJECT as under ‘4’ above.

On p65, for Capel parish, allocations to the west of Paddock Wood are prone to flooding yet the assessment in Table 25, p67 is not separated from the remainder of sites under AL/PW1 (Table 24). Comment is made elsewhere in this objection that the delivery of benefits highlighted in Table 24 remain uncertain. Objection is also made to the Plan regarding specific flood risk concerns relating to individual parcels under AL/PW1.

SA_95

Ide Planning for Paddock Wood Town Council

9. SA of Development Management Policies

OBJECT as under ‘4’ above.

On p110, holding objection - a number of local green spaces are proposed borough wide including Paddock Wood. The Town Council wishes to designate sites in its forthcoming Neighbourhood Plan.

On p112, re. ENV23, Air Quality, a deterioration in air quality appears inevitable with the scale and distribution of development proposed. It is unclear how some measures proposed in the policy can be achieved though the statutory planning process.

On p113, re. EN28, Flood Risk, see objection under ‘4’ above.

SA_96

Tunbridge Wells District Committee Campaign to Protect Rural England

General comments

In our response to the SA produced to accompany the Issues and Options consultation CPRE said:

“We disagree with the method.

The appraisal lists out 19 sustainability objectives (amongst which reducing light pollution doesn’t seem to figure!) against which each of the 5 options (plus the do nothing option) are then scored and then broadly speaking the option with the highest score is considered the most favourable from a sustainability standpoint.

The choice of the 19 sustainability objectives could easily affect the scores, by lumping certain aspects together (for example water and flooding) while separating out others (for example employment and business growth). We suspect that this downplays the importance of the environmental objectives compared with social and economic ones.”

This remains our view in the case of the current SA.

Nevertheless, table 8 (under para 5.31) shows that the Housing objective is incompatible with considerably more of the sustainability appraisal objectives (9/19) than it is compatible with (5/19). We would also question the scores given for the effects of several of the other LP objectives on SA objectives as regards biodiversity, climate change, health, heritage, land use, landscape, noise and water.

The suggestion in para 6.1.8 that there is capacity in the borough to meet housing targets whilst still having “due regard” to AONB and Green Belt policies is demonstrably incorrect. The proposed strategy clearly fails to comply with national AONB and Green Belt policies by de-designating Green Belt to build several thousand homes in Capel Parish and allocating several sites for major development in the AONB and its setting for which no, or no adequate justification under planning law and policy is provided. Even if much higher density housing development were to take place on the allocated brownfield and greenfield sites outside the Green Belt and AONB (and its setting), we doubt that the Council’s planned housing targets could be achieved without harm to the Green Belt and AONB, contrary to the NPPF. Therefore the alleged compatibility has not been demonstrated. We strongly dispute the statement that growth that only partially meets “identified needs”, i.e. the Government-imposed formula plus a buffer of 9%, is not a reasonable alternative in the circumstances that apply in this borough.

We support the conclusion that growth strategy 7 (an additional 1,900 dwellings to accommodate “need” from Sevenoaks) and Growth Strategy 8 (dispersed countryside growth) are unsustainable, though we consider that some of the scores given in table 14 to aspects of these proposals are unduly positive.

CPRE is of the view that the SA does not give sufficient and proper regard to impact on the AONB as required by paragraph 172 of the NPPF, or to paragraphs 137 and 138 of the NPPF concerning the Green Belt.

SA_97

Mrs June Bell

Table 29 Scores for allocated sites in Cranbrook and Sissinghurst Parish

Cumulative impacts for the Parish of Cranbrook & Sissinghurst:

I do not agree with the assessment of Neutral or Unknown/ slightly negative for climate change with the proposed building of 900+ dwellings and associated increase of carbon emissions to achieve delivery and will be created by the increase in traffic, heating homes and loss of hedges, trees and natural landscape.
I do not agree with the assessment of slightly positive for employment within the parish when no substantial employment provision is planned within the parish.

I do not agree that the AL/CRS 7 will have Neutral or slightly negative impact on Biodiversity when it is currently not exposed to risks of contamination from the building of and subsequent built dwellings including significant loss of green infrastructure and increased risk of flooding.

SA_98

Mill Lane and Cramptons Residents Association

Site number 54 - Land on east side of Mill Lane Sissinghurst TN17 2HX (Policy AL/CRS 12)

Loss of Greenfield land. Currently used for sheep grazing. Designated by KCC Biodiversity as “Other grassland of Importance”, owing to its careful conservation management over the years. It is an ideal companion to the Primary School Nature Reserve adjacent. Also home to a Weald Bee Unit of up to 8 hives - producing award winning honey. The Biodiversity colour on the Table should be red not blue.

Adjacent to the historic Mill Farm (the former village Miller’s house with windmill). The Heritage colour on the Table should at least be pink.

Site excluded from the Cranbrook and Sissinghurst Draft Neighbourhood Development Plan

Site number 120 - Land east of Camden Lodge, adjacent to Mill Land and Sissinghurst Road, Sissinghurst (Policy AL/CRS 13)

Loss of Greenfield land. Adjacent to High Weald AONB boundary.

Old parkland once part of the adjacent Camden Lodge (know called Camden House) estate. Left to go derelict wasting needed grazing land. Formerly used for cattle and sheep grazing. Has always been a favoured green-gap between Sissinghurst Village and Wilsley Pound.

The Biodiversity should be at least pink in the Table not blue. The surrounding mature trees are home to owls and woodpeckers and have been so for many years.

The landscape should be red in the Table – old parkland with many fine mature trees

Site excluded from the Cranbrook and Sissinghurst Draft Neighbourhood Development Plan

SA_99

Hugh and Susanna Smith

We wish to comment on the draft Local Plan and Sustainability Appraisal please. Our concern is principally with Lamberhurst and its suitability to absorb additional housing, and particularly with the appropriateness of the Land to the West of Spray Hill (Map 85 Policy AL/LA1.)

With regard to the Borough’s planning strategy and to Policy STR/LA1:

You will be aware that the recently drafted Neighbourhood Development Plan for Lamberhurst focuses on developments in keeping with and amplifying the local character of the area. The new housing identified in the TWBC draft Local Plan comprises a housing estate approach, creating a suburban feel – features which are quite foreign to the existing composition of the settlement.
The results from the Distribution of Development Topic Paper for Draft Local Plan – Regulation 18 Consultation and these proposals now for the high relative level of new housing in Lamberhurst, which is the 4th smallest settlement in the plan area, do not seem to be consistent.
Similarly, the proposals as they affect Lamberhurst comprise dispersed or semi-dispersed growth, with its suburbanising effect, in contrast to the growth corridor approach that emerges in the Topic Paper above. This is a further inconsistency with the consultation findings in the Topic Paper.
The proposals will in addition have a more negative climate-change impact than alternatives focused on locating new housing where existing population and service densities are already significant and well-established. Public transport from Lamberhurst is very limited; school capacity in the village is full; local shopping options are quite restricted.

With regard to the draft Local Plan Allocation AL/LA1, Land to the West of Spray Hill:

This allocation would have a substantial negative effect on a number of aspects of the neighbourhood.
The land is well outside the Limits to Built Development, even the LBD as recently extended, and should therefore not feature as an option in the Local Plan without compelling need. Alternative and more appropriate siting could for example be beside the revised LBD boundary adjacent to and west of the school.
The AL/LA1 land directly abuts the Lamberhurst Conservation Area, and its development would significantly diminish that Area.
In connection with Policy EN7 Heritage Assets, the properties neighbouring the land are listed buildings and include the unique and striking group of four Lamberhurst Down oast kilns. If developed, the new housing on the land would destroy the setting of these assets.
The removal of much wild woodland vegetation that would be required to develop the site would result in these historic assets being set visually within a modern housing environment. From Lamberhurst village centre itself, and from all viewpoints beyond, extending to the Goudhurst ridge, these oast kilns form a prominent and striking feature emerging from the trees and greenery of the Lamberhurst Down ridge. Development of this site would result in the oasts appearing in an incongruous semi-urban setting.
Moreover, in respect of Policy EN6 Historic Environment, these buildings on the Lamberhurst Down still comprise a contiguous series of assets, visually connected to and once part of the Old Scotney Estate, with its Scheduled Ancient Monument and its other historic buildings. The development of this site for housing would destroy the flow of this continuity.
The replacement of this woodland area with housing would diminish biodiversity in the area significantly. There would be marked habitat loss, and reduction of vegetation and tree density and diversity.
The building of 25-30 housing units on site AL/LA1 in this Area of Outstanding Natural Beauty could not be compliant with National Planning Policy, which requires exceptional circumstances / public interest for such development which are absent in this case.

We would like these comments to be taken into account as part of the consultation please.

SA_100

Mr Andrew Rankine

Sustainability Appraisal

Sustainability Appraisal:

Until very recently, adopting a New Settlement approach to the borough’s housing need was never on the horizon as a strategic intent. I believe that the voodoo analytics used in the Sustainability Appraisal assessment of the various growth options was undertaken once the council knew which option they believed was simplest to deliver and the proposed site had already been identified. This analysis was then undertaken to steer towards this answer. The initial compatibility testing (Sustainability Appraisal Issues and Options Report May 2019 p.21-26) clearly shows that Option 5 (New Settlement) is one of the least compatible growth options prior to any biasing of the test results by applying “mitigation strategies”. I note that Growth Option 5 required the most number of suggested mitigation strategies – an indication of how incompatible this option is with the council’s own Sustainability Objectives. The mitigation strategies suggested to offset the negative scores for the New Settlement approach are:

* Help turn the health and deprivation objectives positive by ensuring the settlement is positioned in a location that can achieve Accessible Natural Greenspace Standard and where a pocket of deprivation can benefit.

* Turn the air objective positive by positioning the settlement in a location that draws traffic away from the AQMA.

* Improve the noise objective through careful design and consideration of the settlement location.

* Improve the landscape objective by choosing a location well outside of the AONB.

* Improve the water objective by choosing a location inside Flood Zone 1 that eliminates impacts from flooding.

* Introduce policy for resource conservation and waste management to help turn the resources and waste objective positive.

* Turn the employment objective positive by choosing a settlement location that would provide employment opportunities for key wards.

There is no evidence within any of the supporting documents that adequately demonstrate that the Policy STR/CA1 would address any of these mitigation strategies. In fact, the proposed location of the New Settlement would actually make most of these scores considerably worse and as such, using the council’s own methodology, prove irrevocably that this Policy is totally incompatible with the Sustainability Objectives and as such it should be removed.

Figure 10 (page 66) in the Sustainability Appraisal gives a shocking indication of the proportion of Capel Parish that has been considered for development – and to call this “reasonable alternative sites” is somewhat insincere. In no sensible universe is considering development at this scale in a rural Parish “reasonable”, especially when compared to the scale of development considered in all other areas of the borough. This figure also gives a very comprehensive overview of the very reason why the Green Belt study (2017) noted that any change to designation in this broad area would cause “very high” harm. Figure 10 also clearly shows the proximity to Tonbridge to the east (a mere stone’s throw away) and the same for Paddock Wood to the west. It is clear that the proposed New Settlements would cause coalescence – forming a development “bridge” – between the two conurbations. This shows a complete disregard of the very reason that the Green Belt exists, namely “to prevent neighbouring towns merging into one another” and “to assist in safeguarding the countryside from encroachment”. I also note that this Green Belt review does not contain details of the “parcel” of land considered for the New Settlement. As such, I fail to see how TWBC could consider this policy viable with such an important piece of evidence missing and as such it should be removed from the Draft Plan.

I also note that there was no borough-wide Landscape or Biodiversity assessment undertaken by which to assess the impact that Policy STR/CA1 would have on these critical aspects, yet the Sustainability Appraisal places scores against these Sustainability Objectives. How has this been achieved when a baseline of the existing Landscape and Biodiversity in these parcels is not known? Clearly this is impossible so to place any score against either objective is unsound. On this basis the Policy should be removed from the Draft Plan.

Alternative Sites:

I note that TWBC has another consultation in progress at the moment – namely the Brownfield Register. Without this register being kept up-to-date by the council and relying solely on the owners of possible brownfield sites to register their existence, how can the council be assured that it has truly reached its threshold to consider Green Belt sites as possible options? I note that during the council’s second call for sites they proactively contacted landowners to search for suitable areas for development – it was at this stage I assume that the Tudeley site came to the fore as it was not included in the original SHELAA and therefore not considered as a possible option throughout the Issues and Options Consultation. Was there any resource devoted to searching out additional brownfield sites at this point or was all the focus on Greenfield landowners? If the latter and just one unidentified brownfield site exists that would be suitable for development then I would suggest that the threshold for development on Green Belt (as defined by the NPPF) has not been reached.

The Distribution of Development Topic Paper apparently places much weight on the responses received during the Issues & Options Consultation as guiding local strategy, citing various percentages of respondent opinions on proposals. TWBC have reached the conclusion that there is a local preference for a combination of Growth Option 4 and 5 although the location of the New Settlement was not specified. This seems to ignore the fact that the same respondents also stipulated that any New Settlement should be outside of the AONB and Green Belt, that infrastructure improvements would need to be delivered prior to commencing any building work and that all other development potential should be maximised before this was considered – in other words, as a last ditch resort. However, the Draft Local plan appears to have positioned the New Settlement as the poster child of the entire plan, in a location with little or no existing infrastructure and within the Green Belt abutting the AONB. I would suggest that if the respondents knew the location of the proposed development then the New Settlement growth option would have been rejected outright.

There are a number of other sites that have been put forward for consideration through the Call for Sites but rejected by TWBC for reasons that seem similar to those that have resulted in the inclusion of STR/CA1. Horsmonden, for example appears to have been rejected due to “access difficulties” – yet STR/CA1 has no better existing infrastructure but has the additional restrictions of being wholly contained within the Green Belt. Blantyre House may not have been put forward during the Call for Sites but did TWBC officers then contact the owners in the same way that they did other landowners “that had not been submitted through the first Call for Sites to enable them to submit sites if they wished”? These are just two examples of the seemingly inconsistent approach to identifying and rejecting sites for development that have the same (if not more) development constraints as the proposed policy.

SA_101

Historic England

Thank you for your email of 16 October 2019 inviting comments on the above Sustainability Appraisal report.

We are content that the SA report adequately assesses the issues that may arise in respect of the potential effects of proposed development on the historic environment and heritage assets. We note that the assessed scores for most options and for allocated sites in particular, are either negative or neutral. Very few would appear to offer direct positive benefits for the historic environment. In this context it is important that the local plan’s policies provide an appropriate and robust framework for protecting and enhancing the heritage of the Borough. The council should consider undertaking detailed heritage impacts assessments for all sites proposed to be allocated in the plan with particular reference to those highlighted in Historic England’s letter of representations dated 15 November 2019.

This opinion is based on the information provided by you and for the avoidance of doubt does not affect our obligation to advise you on, and potentially object to any specific development proposal which may subsequently arise from this or later versions of the plan which is the subject to consultation, and which may, despite the SEA, have adverse effects on the historic environment.

SA_102

DHA Planning for Caenwood Estates and Dandara

Comments on the Sustainability Appraisal (SA)

4.1.8 The SA assessment for Caenwood Farm scores it very negatively for noise and air quality objectives, seemingly on the assumption that it would result in the substantial use of private vehicles. It is not clear how this finding has been arrived at, given the proximity of the site to a high-frequency walking, cycling and public transport corridor and the potential for further improvements to these modes.

4.1.9 By contrast, the proposed strategic site at Tudeley is not on a public transport corridor. Whilst a railway runs through the site, there are no plans for a railway station and it is unlikely that one could be viable. Whilst it is also recognised there would be potential to improve bus services, it would take substantial investment in buses simply to equal the high frequency service which currently runs along the A26. Yet, despite this, the SA scores for air quality for the Capel strategic sites is ‘?’ (unknown – despite the commentary noting a high increase in traffic) rather than the ‘--/---’ (negative/very negative) scores attributed to Caenwood.

4.1.10 This simply lacks credibility.

4.1.11 We also question whether the SA has taken full account of opportunities for public benefits within the Caenwood Farm site, such as a new public park. Creating a new area of public open space would provide an important local amenity which would serve existing as well as new residents. It could also mean that local residents have facilities within walking distance which they would otherwise need to drive to.

SA_103

Mrs Karin Moncrieff

My husband and I have lived on Golford Road since 2001. This site has come very late in the day in the development plan and we believe firstly that there has not been given adequate time for stakeholder engagement – particularly in the wider community, as this plan would affect the residents of central Cranbrook, access to two schools and Sissinghurst village. We have further learned that the site has been offered up for major development some years before and was turned down due to environmental concerns mainly (sewage and ANOB particularly). These grounds are no less valid now. Specifically, we believe that the proposed site is ill considered and inappropriate on the following reasons:

1. Traffic junctions

The two key pinch points into town or going north towards transport links at are at the junction of Waterloo Road and at Chapel Lane, Sissinghurst for all northbound traffic. Both these have huge implications for the town itself (which already has a chaotic traffic situation in Stone Street) as well as for the residents of Sissinghurst, and the addition of the proposed amount of housing will increase the volume of cars and therefore this pressure substantially.

2. Road safety

The existing pavement is very narrow, has high camber and is on a very dangerous double bend. Despite the speed limit, there are frequently dangerous speeding drivers and accidents (as has been well documented by other respondents). Without alternative arrangements for pedestrian/cyclist/disability scooter access to the town, the existing pavement is simply totally impossible and highly dangerous. Given that the likely residents of the proposed estate are likely to be young families, it would be totally impossible to take a buggy with a child down the existing pavement without tragic consequences. I would suggest that the only alternative would be to allocate some of land belonging the Swifts estate to create a footpath to the town.

3. Environmental impact

a) Sewage works: the current sewage site at the bottom of the proposed site which currently serves the town, as well as many tankers from private septic tanks etc, is not even adequate for current use and therefore will need to be extended and upgraded as part of the plan by at least a capacity of 20% I am told. Simply the idea of locating a new estate adjacent to a sewage works I find quite laughable and extraordinary!

b) Flooding: the land is waterlogged in winter. Assuming the new houses would not be built on the flood plain itself, increased hard landscaping will nevertheless increase the risk of severe flooding – including the sewage works which is very vulnerable even now.

c) Area of Outstanding Natural Beauty: As well as being in an AONB, this is an environmentally sensitive area. The entire region – including all of Cranbrook and downstream of the Crane Brook to Sissinghurst, Frittenden, and Biddenden – has been designated a Nitrate Vulnerable Zone by the Environment Agency. In addition, it has been designated a Drinking Water Safeguard Zone (surface water) – which is reserved for ‘water sources that are “at risk” of deterioration.’ A qualified ecologist carried out a survey in 2012 and found at least 3 downstream waterbodies supporting populations of Great Crested Newts in the immediate vicinity. CRS7 also contains several badger setts

SA_104

Tunbridge Wells Friends of the Earth

Tunbridge Wells Friends of the Earth is generally positive about the systemic approach that was adopted in drafting the Local Plan with regards to sustainability criteria.

However, we are disappointed that priority is given to meeting demands for new housing (which we dispute as set out in our response to the LDP) over environmental protection.

E.g. You admit that meeting demand for new development “… would involve some loss of Green Belt land, it being found unreasonable for such large growth to occur in the AONB. However, with a view to meet housing needs, the strategy also seeks, and finds scope for, growth within the AONB, being spread across a number of settlements, having first maximised potential outside the AONB. The key findings of this process were that significant beneficial effects were expected for most economic and social sustainability objectives. The environmental objectives were found to produce either highly mixed, neutral or negative scores essentially reflecting the increased pressures that a significant number of new dwellings would put upon sensitive environmental features such as landscape and heritage.” [underlining mine].

We want to strongly object to new development on Green Belt land and in other areas where it would cause harm to the environment. Instead, we would argue that—given the serious concerns over climate change effects and the commitment made by TWBC in their Climate Emergency Declaration in July this year to achieve carbon neutrality by 2030—we need to increase our green areas and tree cover.

As such, we maintain that high-density building is the preferred option and suggest your first two strategies of 1) “growth focussed largely on urban areas” and 2) “growth focussed largely on urban areas plus some larger villages” are the best strategies to follow. It would also offer the opportunity of focusing retail/offices/houses/recreational services in one, smaller area, which reduces the need for commuting and thus reduce traffic flows.

Further questions and comments:

Other highlights we take away from your report that we feel support our position:

Table 2 and 4

Water Efficiency Background Paper (2017)

Kent Water for Sustainable Growth Study (2017)

Draft South East Water Resource Management Plan 2020 - 2080 (ongoing)

SA method has been updated to reflect the high pressures of the region and lack of capacity to support current levels of new development.

Table 3

Biodiversity 2020: A strategy for England’s Wildlife and Ecosystem Services (2018)

DEFRA. A Green Future: Our 25 Year Plan to Improve the Environment (2018)

Why are these deemed as having ‘No significant implication for Sustainability Appraisal’?

Table 6. Sustainability Objectives for Tunbridge Wells Borough

We question how the following twelve objectives are compatible with 13 and 14:

Reduce air pollution
Protect and enhance biodiversity and the natural environment
Reduce carbon footprint and adapt to predicted changes
Improve health and wellbeing, and reduce health inequalities
Protect and enhance cultural heritage assets
Protect soils, and reuse previously developed land and buildings
Protect and enhance landscape and townscape
Reduce noise pollution
Reduce the impact of resource consumption
Improve travel choice and reduce the need to travel by private vehicle
Reduce waste generation and disposal
Manage flood risk and conserve, protect and enhance water resources

versus

13. Encourage business growth and competitiveness

14. Provide sufficient housing to meet identified needs

As said before: the number of new houses you propose to build plus the intention to increase economic growth is, in our view, largely incompatible with objectives 1-12.

With respect to the 10 “Strategic Objectives” you set out we like to comment as follows:

Travel:

To prioritise active travel, but where necessary to plan appropriately for use by private motor vehicle, in particular embracing new technology.

Increasing support for infrastructure for private vehicle use directly conflicts with your intention to “prioritise” active travel. The easier private car travel is made—whilst simultaneously not creating safe alternatives in the form of segregated, safe cycle paths, linked up in an extensive network of cycle paths—the less likely it is people will choose active travel. Though we have seen instances in the LDP where you say you want to implement active travel—it is by no means treated as a ‘priority’. Quite the opposite: private car use is still best catered for.

Green Belt:

To strategically release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.

We strongly object to releasing land for the Green Belt for new housing development.

We also feel it contradicts your following other two objectives:

The borough's distinctive environment:

To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature.

Climate Change

To tackle climate change and minimise the impact of development on communities, the economy and the environment with carefully considered design and by embracing technology such as renewable energy generation.

You cannot tackle climate change by reducing green land. We also want to emphasise again (as we have in our comments on the LDP) that Biomass technology does not provide clean renewable energy generation and all recommendations for biomass burning should be scrapped from the LDP.

SA_105

Judith Ashton Associates for Redrow Homes Ltd and Persimmon Homes South East

The Sustainability Appraisal (SA)

Section 6 of the Sept 2019 SA reviews the growth strategy. It demonstrates that six options were considered at Issues and Options:

Growth Strategy 1 – Focused Growth - growth focussed largely on existing urban areas;

Growth Strategy 2 – Semi Dispersed Growth - growth focussed largely on urban areas plus some larger villages;

Growth Strategy 3 – Dispersed Growth - growth distributed proportionally across all existing settlements;

Growth Strategy 4 – Growth Corridor Led Approach - growth focussed on the A21 corridor near Royal Tunbridge Wells and Pembury;

Growth Strategy 5 – New Freestanding Settlement - growth within a new, free-standing settlement; and

Growth Strategy 6 – No Local Plan.

Following consultation two further options were considered: Growth Strategy 7- Growth including Sevenoaks Unmet Need Growth Strategy 8 - Dispersed Countryside Growth

Para 6.2.4 of the Sept 2019 SA suggests that Growth Strategy 5 had the highest number of positive scores and lowest number of negative scores. It also explains that:

‘This option, which has been taken to embrace an enlarged town or village based on garden settlement principles as well as a new freestanding garden settlement, is therefore proposed to be integral to the preferred development strategy for the borough.’

Notwithstanding the above the Sept 2019 SA also explains at para 6.2.6 that it would neither be reasonable in SA terms, nor practical, to focus unduly on new or expanded settlements as the sole focus of meeting the housing needs of the borough. And that as such, as set out in para 6.2.8 and

6.2.9 the growth strategy incorporates both growth strategies 3 and 5.

In order to fully understand the rationale behind the growth strategy, one has however to refer back to the Sustainability Appraisal Issues and Options Report May 2019, as it is chapters 4 and 5 of this documents that appraises each of the proposed growth options against the Sustainability Objectives, considers how one could mitigation adverse effects and maximise the beneficial effects, and recommends the further investigation of growth options 5 and 4. Whilst para 5.3.1 goes on to advise that: ‘it is pertinent to note that this recommendation is subject to locational constraints’ we are concerned that not only does one have to go on a paper chase to fully understand the rationale behind the chosen growth/ spatial strategy, but that the findings of the May 2019 SA differ from those of the Sept 2019 SA without any explanation. This needs to be rectified in the Reg 19 SA.

As set out in the Sept 2019 SA, further consideration was then given to the location and scale of such growth. This included considering new settlements at:

Blantyre House (former prison) Goudhurst Parish
Capel
Frittenden area
Horsmonden
Iden Green
Kippings Cross
Land adjacent to Colliers Green Primary School, Colliers Green
Land at Great Bayhall East of Royal Tunbridge Wells
Land between Cranbrook and Sissinghurst
Land between Sandhurst and Iden Green
Langton Green
Paddock Wood
Walkhurst Farm, Benenden

Of these sites only Capel and Paddock Wood were taken forward for further consideration. Whilst noting the content of table 13 of the Sept 2019 SA we are concerned that this appraisal may be seen by some as rather cursory and believe a more detailed critique of the reasonable alternatives needs to be undertaken so as to ensure the SA is robust.

The SA goes on to explain that two alternative scales of growth for a garden settlement in Capel Parish were considered. 2500-2800 dwellings and 5000 dwellings; and that option 1, 2500-2800 dwellings was chosen as the adverse effects were less than those associated with option 2. It also explains that four options for growth around Paddock wood were assessed:

Option 1 - 3,000 dwellings to the north, east and south (outside the green belt);

Option 2 - 5,000 dwellings to the north, south, east and west – i.e. including land in the green belt; Option 3 - 4,000 dwellings to the north, east and south (outside the green belt);

Option 4 - 6,000 dwellings to the north, south, east and west – i.e. including land in the green belt;

Option 2 being the preferred option as it met the councils housing needs and helped address existing flood risk issues

Table 26 of the SA lists the reasonable alternative sites in Paddock Wood Parish and highlights those taken forward and included within policies AL/PW1, 2, 3 and 4. Table 27, in providing the SA scores for the allocated sites in Paddock Wood Parish highlights the fact that:

‘Most scores for STR/PW 1 are positive with very positive scores being applied for all the social and economic objectives. Environmental objectives are mostly negative reflecting the scale of development proposed. However, the water objective has been given a mixed/positive score to reflect the betterment in flooding proposed for Five Oak Green and Paddock Wood. Likewise, biodiversity is scored as slightly positive overall to reflect the large improvements that can be made with AL/PW 1.’

Whilst the SA does in our opinion review the reasonable alternatives to the growth options/ spatial strategy, and the associated options for the scale and location of growth proposed within the new settlement/ enlarged town it does in some areas require a paperchase and in others is not perhaps as clear and robust as it could be, such that we believe the SA should be reviewed and updated when the Reg 19 plan is published.

SA_106

Mr David Summers

SITE AC/CRS 7 LAND OFF GOLFORD ROAD
SUPPLEMENTARY OBJECTIONS

1 DEVELOPMENT POLICY

1 Since submitting our original objection we have become aware that TWBC gave consideration to Late Site 22 in July 2019 which included two parcels of land now that have been resubmitted afresh as CRS7.

We further object : 1.1 that relevant findings that led to Site 22 being considered unsuitable have been set aside in the assessment of CRS 7

1.2 that CRS 7, if allocated, may in time be seen to have been a "fishing expedition to be prayed in aid of an irresistible case for further development eastwards along Golford Road. This would result in residents being settled even further away from the facilities of the town and was an integral part of the Site 22 application.

2 DRAINAGE

The central historic boundary of the two fields is a field drain that flows into the Crane Brook. This drain is a vital link in the system of local field drainage over the centuries as it conducts water from the fields at Paddocks Farm, Fir Tree Farm, and Hancocks Farm: all historic homesteads and currently working farms on the South side of Golford Road. KCC increased the size of the ducting pipe under the Golford Road because the poor rate of flow was causing farm and residential land , and the road on a bend, to flood on the South side. We object to any interference with the efficient functioning of the field drain.

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Robert Davis

Sustainability Appraisal

Whilst I cannot claim to have read, in its entirety, your Sustainability Appraisal Issues and Options Report, Final Report, May 2019 I do have some comments to make.

I am trying to match your plan with Table 2 under section 3.1 Sustainability Objectives and cannot see how you can possibly meet any of the stated 19 objectives. I therefore fell upon section 4 Sustainability Appraisal in the hope of enlightenment. Reading sections 4.1.5, 4.1.6 and your attempt to reconcile Local Plan Objectives (Table 5) with Sustainability Objectives (Table 6) I fail to see any reconciliation. You claim, in 4.1.6, that Local Plan Objectives are more compatible in seven out of eight instances with the Sustainability Objectives. However, you then admit that there is one Local Plan Objective that is more incompatible than compatible with the Sustainability Objectives. That is Objective 4 to deliver high quality housing that meets local needs. Surely this is a complete fail in respect of the proposed development!

To rub salt into the wound you go on in 4.1.7 to claim that 13 out of 19 of the Sustainability Objectives are more compatible than incompatible with Local Plan Objectives. However you then go on to say that two Sustainability Objectives are equally incompatible and compatible with the Local Plan Objectives these are Sustainability Objectives 2 (biodiversity) and 13 (landscape). There are four Sustainability Objectives that are more incompatible than compatible these are objectives 1 (air), 4 (climate change and energy), 12 (land use) and 15 (resources). Surely another fail.

How is any of this able to meet your stated Strategic Objectives shown in Figure 3 under section 4.1 Local Plan Strategic Objectives?

To say sirs, that I am outraged is beyond cliche!

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Mr C Mackonochie

It is difficult to find a scientific basis upon how items have been scored ie what is the difference between Very Negative and Negative in percentage terms

The same comment upon the weightings between the objectives eg the loss of landscape (red) equals the gain (green) in education – is that really true

I am surprised that Land use is only one objective, surely it should be split into greenfield and brownfield. Greenfield split into agriculture and waste land

Shouldn’t Green Belt be an objective in its own right

Shouldn’t AONB be an objective in its own right

If these extra objectives and others such as pollution added then certain sites such as AL/CA1 would have more red/reddish than green objectives.

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Turley for Bellway Homes Strategic

Whilst the Sustainability Appraisal appears to consider the options for a Garden Settlement, we have been unable to locate any assessment at this stage which does not include such an option as part of the distribution strategy. In our view, it would be a reasonable alternative to consider a solution which does not include a Garden Village. In particular we consider that this is essential due to the fact that the Tudeley Village site is remote, does not benefit from access to rail services, is not related to existing services/facilities and significant intervention will be required to provide any facilities in the area. In contrast, alternative sites would provide opportunities to locate development in areas which already relate to existing settlements and services.

We note that Table 20 of the Sustainability Appraisal sets out a list of reasonable alternative sites in Royal Tunbridge Wells. Site reference 53 (being the land promoted by Bellway) is referred to in that list of sites. Table 20 confirms part of the site is proposed to be allocated under AL/RTW 23.

The scoring of site 53 against the SA objectives is contained on page 164 of the Sustainability Appraisal. The SA does not appear to include any detailed explanation as to how the scores have been calculated and so it is not possible for respondents and stakeholders to analysis the impacts of one site over another.

[TWBC: see full representation and Comment Numbers DLP_6189-6198 on the Draft Local Plan].

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Victoria Settle
Nicky Scott
Isla Tompsett
Alan Bearfield
Nicholas Fogg
Maria Palmieri
Alicia Longley-Coomber
Jenny Fox

Sustainability Appraisal

TWBC: the standard response was submitted by the list of responders on the left:

2) With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

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Gladman

3.2 Sustainability Appraisal

3.2.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, policies that are set out in local plans must be the subject of a Sustainability Appraisal. Incorporating the requirements of the Environmental Assessments of Plans and Programmes Regulations 2004, the SA is a systematic process that should be undertaken at each stage of a plan’s preparation; assessing the effects of a local plans proposals on sustainable development objectives when judged against reasonable alternatives.

3.2.2 The Council should ensure that the results of the SA process conducted through the preparation of the Local Plan clearly justify policy choices made, including proposed site allocations (or decisions not to allocate sites) when considered against reasonable alternatives. In meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed and others have been rejected.

3.2.3 The SA must demonstrate that a comprehensive testing of options has been undertaken and that it provides evidence and reasoning as to why any reasonable alternatives identified have not been pursued. A failure to adequately give reasons in the SA could lead to a challenge of the Council’s position through the examination process. The SA should inform plan making. Whilst exercising planning judgement on the results of the SA in the Local Plan is expected, the SA should still clearly assess any reasonable alternatives and clearly articulate the results of any such assessment.

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DHA Planning for Axiom Developments

Policy AL/RTW 13

3.6 Comments on Sustainability Appraisal

3.6.1 We have compared the scoring attributed to Colebrooke House (site 101) with that of the neighbouring proposed allocation on Longfield Road (site 57). There appear to be inconsistencies in relation to how the sites have been treated with no clear explanation as to how this has come about. In particular:

* Colebrooke House scores ‘0/-‘ for air quality, yet the adjacent site receives a ‘0’ score, despite being a much larger development which would generate significantly more emissions. We note the purported explanation on the table that the lower score is due to Colebrooke House’s direct vehicular access with the A21, making extensions to bus routes serving the retail park more cumbersome and encouraging car use. There is a clear opportunity for pedestrian links into the neighbouring site to make use of any buses serving that site, but also as set out in section 3.2, there are opportunities to make use of new technology to support a shuttle bus service which could serve the town centre and local railway stations.

* Colebrooke House scores 0/- for biodiversity, yet the adjacent site receives a 0 score. Both sites include areas of woodland and habitat, so it is not clear why the sites score differently in this respect.

[TWBC: see full representation and Comment Nos. DLP_6777-6779 on the Draft Local Plan]

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Kember Loudon Williams for Wedgewood (New Homes) Ltd

In the table at page 206 (Appx. O) of the Sustainability Appraisal the commentary refers to an historic landscape. However, the site is not within a designated landscape and is very well contained by existing landscape features, topography, and adjacent built form. Furthermore the negative score on land use is questioned as the field is unused rough pasture which is dissected by a drainage ditch and is isolated from the wider agricultural landscape by adjacent orchard, hop garden and built form.

In the SHELAA site assessment sheets for Horsmonden (July 2019) the reference to a historic landscape is repeated, however, the ADAS Landscape Report submitted with the KLW Supporting Report in response to the Reg. 18 Local Plan Consultation confirms that the site is of low visual value with low/medium sensitivity. The Ardent Technical Report submitted with the KLW Supporting Report shows that there are two suitable options for attaining vehicular access to the site. The comment about lack of access to services and facilities would apply equally to all sites in Horsmonden (although there is a range of local services available), and this site is well located in terms of distance to the core village services.

Accordingly, the SHELAA assessment in our view does not withstand full analysis and particularly in light of the additional information now available. Accordingly, the conclusion that the site is unsuitable as an allocation is not, in our view, well founded and we would request that this is reviewed.

[TWBC: see Supporting Statement and Comment Numbers DLP_6793, 6797-6799, 6801, 6803-6804]

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Persimmon Homes South East

Sustainability Appraisal

2.11 TWBC must comply with Directive 2001/42/EC (the SEA Directive) and the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA Regulations) as required by the Planning and Compulsory Purchase Act 2004 while preparing the Local Plan.

2.12 TWBC are required under Article 4 of the SEA Directive to ensure that their environmental assessment is carried out “during the preparation of the plan”. Therefore, any changes or modifications to the emerging Local Plan prior to its adoption must be considered as part of the environmental assessment.

2.13 Regulation 12(2) SEA Regulations provide that the Sustainability Appraisal of the Local Plan must identify, describe and evaluate the likely significant effects on the environment of implementing the particular development plan and reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme.

2.14 Section 6 of the Sept 2019 SA reviews the growth strategy. It demonstrates that six options were considered at Issues and Options:

Growth Strategy 1 – Focused Growth - growth focussed largely on existing urban areas;
Growth Strategy 2 – Semi Dispersed Growth - growth focussed largely on urban areas plus some larger villages;
Growth Strategy 3 – Dispersed Growth - growth distributed proportionally across all existing settlements;
Growth Strategy 4 – Growth Corridor Led Approach - growth focussed on the A21 corridor near Royal Tunbridge Wells and Pembury;
Growth Strategy 5 – New Freestanding Settlement - growth within a new, free-standing settlement; and
Growth Strategy 6 – No Local Plan. Following consultation two further options were considered:
Growth Strategy 7- Growth including Sevenoaks Unmet Need 634/B1/CC/TA 6 November 2019
Growth Strategy 8 - Dispersed Countryside Growth

2.15 Para 6.2.4 of the Sept 2019 SA suggests that Growth Strategy 5 had the highest number of positive scores and lowest number of negative scores. It also explains that: ‘This option, which has been taken to embrace an enlarged town or village based on garden settlement principles as well as a new freestanding garden settlement, is therefore proposed to be integral to the preferred development strategy for the borough.’

2.16 Notwithstanding the above the Sept 2019 SA also explains at para 6.2.6 that it would neither be reasonable in SA terms, nor practical, to focus unduly on new or expanded settlements as the sole

focus of meeting the housing needs of the borough. And that as such, as set out in para 6.2.8 and 6.2.9 the growth strategy incorporates both growth strategies 3 and 5.

2.17 In order to fully understand the rationale behind the growth strategy, one has however to refer back to the Sustainability Appraisal Issues and Options Report May 2019, as it is chapters 4 and 5 of this documents that appraises each of the proposed growth options against the Sustainability Objectives, considers how one could mitigation adverse effects and maximise the beneficial effects, and recommends the further investigation of growth options 5 and 4. Whilst para 5.3.1 goes on to advise that: ‘it is pertinent to note that this recommendation is subject to locational constraints’ we are concerned that not only does one have to go on a paper chase to fully understand the rationale behind the chosen growth/ spatial strategy, but that the findings of the May 2019 SA differ from those of the Sept 2019 SA without any explanation. This needs to be rectified in the Reg 19 SA.

2.18 Whilst the SA does in our opinion review the reasonable alternatives to the growth options/ spatial strategy, and the associated options for the scale and location of growth proposed within the new settlement/ enlarged town it does in some areas require a paperchase and in others is not perhaps as clear and robust as it could be, such that we believe the SA should be reviewed and updated when the Reg 19 plan is published.

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Persimmon Homes South East

2.6 Finally, having regard to the issues around the Duty to Cooperate, there is the issue of Sevenoaks District Councils (SDC’s) unmet need. Whilst we note that the SA does consider a growth option that encompasses SDC’s unmet need (option 7 – see below), para 6.2.2 of the SA appears to dismiss this option on the basis that it was assumed that the additional 1,900 dwellings would essentially be located within the AONB. It is not clear how this conclusion has been reached. In addition there is nothing that allows one to undertake a like for like comparison of the SA findings on option 7 (as set out in table 14) against the options considered in the earlier SA and the chosen option – such that the rational for this decision does in our opinion require further clarification.

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Persimmon Homes South East

2.4 The housing needs survey 2018 identifies a net affordable housing need of 443dpa. As policy H5 looks to deliver 40% affordable provision on all greenfield sites of 9 (+) dwellings, and acknowledging that not all sites provide affordable housing, in order to meet 100% of the affordable requirement one would conservatively need to deliver circa 1,107 dpa over the plan period. This is clearly significantly greater than the figure generated by the standard method, (678/682dpa) and whilst the standard method takes into account affordability issues, this does beg the question as to whether TWBC need to consider whether it might be appropriate to plan for a higher housing need figure than the standard method indicates. If nothing else the SA should in our opinion assess this point.

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Barton Willmore for Obsidian Strategic

Policy AL/PE 2 Land at Hubbles Farm Pembury

Introduction

We act on behalf of Obsidian Strategic HFP Ltd (‘our client’) and have been instructed to submit representations to Tunbridge Wells Borough Council’s Draft Local Plan (Regulation 18) Consultation (‘the Draft Plan’). This follows previous representations submitted as part of the ‘Call for Sites’ Consultation in March 2018.

This representation supports the draft Local Plan strategy and in particular the allocation (Policy AL/PE 2) of land at Hubbles Farm and South of Hasting Road, Pembury (‘the Site’) for residential development.

In accordance with the Council’s requirements, we have submitted as part of this written representation a Site Location Plan, prepared by Enplan (Drawing Ref: 01-742-001) and the duly completed Tunbridge Wells Draft Local Plan and Sustainability Appraisal response forms, which should be read in conjunction with this letter. This written representation also includes further technical assessment in support of the future allocation of the Site, including:

i. Flood Risk Assessment dated June 2018, prepared by Glanville;

ii. Landscape and Visual Appraisal dated November 2017, prepared by Enplan;

iii. Landscape and Visual Appraisal Addendum dated November 2019, prepared by Enplan; and

iv. Transport Feasibility Study dated November 2018, prepared by DHA Transport.

A proposed illustrative layout plan, prepared by thrive architects (Drawing Ref: SKL-03), has also been provided, demonstrating the ability to accommodate a residential scheme comprising circa 126 units with associated access and comprehensive landscape/open space.

Site Context and Policy Justification

The Site currently lies immediately outside the ‘Limits to Built Development’ (LBD) Boundary of Pembury. It falls within the wider Metropolitan Green Belt, wider High Weald AONB and wider Kent Special Landscape Area. The Site also lies in close proximity to the Pembury Conservation Area (to the north-west) and an existing cricket pitch (identified as Recreation Open Space).

The National Planning Policy Framework (NPPF) is clear that local planning authorities should, through their Local Plans, meet objectively assessed needs unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits (Paragraph 11).

It also confirms at Paragraph 136, that once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation of or review of the Local Plan. Prior to concluding exceptional circumstances exist to justify changes to the Green Belt boundaries a sequential approach must have been applied in seeking to meet identified housing needs, including:

a) Making as much use as possible of suitable brownfield sites and underutilised land;

b) Optimising density of development, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and

c) Informed discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.

The Local Plan confirms that TWBC has suffered from a significant shortfall in housing supply and acute affordability issues. We are aware that the Council has undertaken detailed urban capacity work and had discussions with neighbouring authorities to ascertain whether they could assist in accommodating housing requirements. However, in order to fully address the housing need, it has rightly been concluded that there is a requirement to couple high density development within ‘urbanised areas’ with the release of Green Belt Land. To this end, the sequential approach has been undertaken, and exceptional circumstances exist to justify changes to the Green Belt. We support this approach and clarity of this decision making should be made in the Evidence Base.

In addition, whilst we support the Council in meeting its Objectively Assessed Need (OAN) in full, for robustness, the Council should also consider the implications of providing more or fewer homes. This is not to say the Council should follow any other strategy, it is simply to show that other options have been considered and the Council can be aware of the issues of alternative strategies in informing the current Local Plan proposals.

Turning to the Site, it is noted that the Site’s development potential was considered in context of housing needs, the Green Belt Review and as part of the Sustainability Appraisal of the Draft Local Plan (September 2019). This ‘stepped’ assessment is supported by Paragraph 138 of the NPPF, in that when reviewing Green Belt boundaries, the need to promote sustainable development should be taken into account, whilst setting out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt Land.

The Site was considered within the Green Belt Review (GBR) Stage Two (July 2017) parcel reference PE1 and the Strategic Housing and Economic Land Availability Assessment (SHELAA) – Jul 2019 (Site Ref 50). The GBR rightly concluded that the larger land parcel (PE1) within which the Site is situated, performed ‘ relatively weakly ’ in meeting the purposes of the Green Belt. In these terms, its potential level of harm to the Green Belt associated within its release was found to be ‘ low’ , and that ‘the A21 would represent a stronger boundary than the existing settlement edge’ .

The land to the north of the Site comprises of the existing built up settlement of Pembury and would be defined by the physical and enduring boundary of the A21 to the south. The eastern boundary is defined by open Green Belt Land, also proposed as a draft allocation (AL/PE 3), bound by Henwood Green Road and to the west by safeguarded land to protect the existing community uses including the cemetery and cricket ground. This provides a clear defensible boundary between the built limits of the Settlement and the Green Belt.

The SHELAA also concluded that, ‘the Site is suitable as a potential Local Plan allocation subject to further consideration ’. The basis for this finding was that the

‘site lies mostly in proximity to the LBD and is likely to be sustainable in this context. It includes some PDL land. It would form a logical extension to the LBD in conjunction with other site submissions’ .

To supplement the detailed site assessment undertaken within the above reports, additional assessment work was carried out within the LBD (September 2019) and Distribution of Development (September 2019) topic papers. This additional assessment considered what possible contributions development included in a proposed allocation can make to Green Belt and AONB objectives in terms of improving access, providing locations for outdoor sport, landscape and visual enhancement, increasing biodiversity and improving damaged and derelict land.

A requirement to safeguard land for the potential future expansion of St Peter’s cemetery, in addition to a landscape buffer along the A21 was identified. The LBD topic paper confirms ‘ the Inclusion of site allocation AL/PE 2 (land at Hubbles Farm and south of Hastings Road) into new LBD boundaries with buffers (for noise, in relation to the A21 ) included as it is likely that some form of built development will be permitted on this part of the site in accordance with this site allocation policy in the draft Local Plan. The safeguarded land is to be excluded. This site (including noise buffers; excluding the safeguarded land) will form part of a Green Belt release’.

In accordance with Paragraph 32 of the NPPF, ‘Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal’. The SA prepared in support of the Draft Plan includes and assessment of the Site against sustainability objectives. The findings of which include a negative land use score associated with the loss of Green Belt Land (low harm) and negatively against noise objectives due to the proximity of the A21.

The enclosed indicative layout identifies the provision of pedestrian links to join existing Public Right of Ways, delivering significant benefit through increased public accessibility. The retained landscape buffer to the south and open space across the site will mitigate any ecological and biodiversity impacts, with a goal of achieving a net environmental gain. The supporting Transport Feasibility Study outlines the improvements which will be made to the highways network. The negative aspects of the Site’s development identified in the SA can therefore be mitigated. The SA should be continually updated to inform each stage of the Local Plan process and reflect the findings of additional assessment.

Overall, we consider the evidence base has been prepared in a logical and transparent manner in accordance with Paragraph 31 -33 of the NPPF. It recommends the Site for inclusion as a draft allocation for 90 residential units, within draft policy AL/PE 2. The NPPF requires LPAs to allocate sites to meet identified needs and, in line with this, it is considered that the Site will contribute towards meeting this requirement in a sustainable location. The proposed residential allocation of the Site is therefore supported in line with the identified need and the conclusions of the sustainability appraisal.

Draft Plan Representations

The OAN for the Borough was calculated as 13,560 dwellings over the plan period to 2036, or 678 dwellings per annum. Our client supports the Councils Growth strategy, combining Option 3 (dispersed growth) and Option 5 (a new ‘stand alone; garden settlement), to meet the OAN in full. This approach is required for the Local Plan to meet the soundness tests of the NPPF and meet the presumption in favour of sustainable development.

We also agree that any development strategy should first seek to make efficient use of existing previously developed land and promote regeneration. This is entirely consistent with the NPPF and Planning Practice Guidance. However, in providing a wide choice of housing and locations, such aspirations need to be balanced with greenfield release in sustainable locations as the Council proposes.

In these terms, we support the Council in proposing to allocate the Site which is fully justified through the evidence base to the Local Plan, including the Sustainability Appraisal as noted above. This approach is fully compliant with the NPPF which states that, for a local plan to be considered sound, it must comply with the legal and procedural requirements of plan making and demonstrate that it is positively prepared, justified, effective and consistent with national policy.

The Site is controlled under a single ownership and as such is immediately available to contribute towards the identified housing need. Furthermore, the Site represents a viable and deliverable option which can be brought forward within the early years of the Plan period (0-5 years).

Draft Policy AL/PE 2 ‘Land at Hubbles Farm and south of Hastings Road’

The Site is proposed, as part of draft allocation AL/PE 2, for the delivery of approximately 90 residential dwellings. The enclosed illustrative layout plan has been informed through the development requirements within the draft policy wording, alongside analysis of the wider site context, including immediate land uses, setting of adjacent Pembury Conservation Area and landscape impact.

The design concept establishes a residential layout surrounding a central green space, with strong landscape buffers comprising the peripheries of the Site. The Site already benefits from direct vehicular access from Hastings Road and this will be modified to support a ‘circular’ internal road arrangement. In this respect, discussions have already taken place with the County Highway Authority. Strong pedestrian and cycle linkages are provided within the site to the existing Public Right of Way along the southern and eastern boundaries. A further potential link could be provided through the existing Cemetery on the western boundary.

The enclosed Transport Feasibility Study, prepared by DHA, considers the traffic impact of the Site as well as the cumulative impacts of the neighbouring Countryside sites. The Study identifies that 89% of the trips, associated with the site, would route to the west towards the Pembury crossroads. The results demonstrate that the crossroads will operate over capacity in the future years with or without development coming forward. Given the forecasted capacity overload at the junction either with or without the proposed developments, the junction has been redesigned to provide an additional lane on the High Street and Pembury Road arms. The mitigation plans would have a positive impact on the junction’s operation, addressing the existing issue and mitigating future traffic generation arising from the proposed developments.

In accordance with the draft policy wording, an area of safeguarded land for the future expansion of the cemetery is maintained in the western corner of the Site. Children’s playspace is located alongside the safeguarded land to allow for the potential future function as shared recreation/amenity space. Given the Site’s location within close proximity to the A21, the development would be set back from the southern boundary. This buffer also serves as a noise barrier for the residential buildings, shielding the units from the vehicle generated noise of the adjacent A21.

All existing trees and hedgerows on the Site are identified to be retained with further enhanced planting along the southern boundary to improve noise mitigation. Improved public open space and landscaping across the Site will protect and enhance existing biodiversity. The proposed enhancements will also contribute to the existing landscape character retaining key views across the Site. The proposals provide an opportunity to contribute to the landscape character of the area and allowing public access. Please refer to the supporting Landscape and Visual Appraisal, prepared by Enplan for further detail, including the location of proposed landscape buffers. This concludes that the site has a low landscape sensitivity and there would only be limited visual effects following development through a careful masterplanned approach.

The illustrative layout has been informed through the enclosed Flood Risk Assessment and initial drainage strategy. Attenuation features are located on the lowest part of the site adjacent to the access point. An additional smaller feature within the central space and infiltration soakaways within plots and public realm, provide sufficient drainage capacity.

The illustrative layout, informed through the enclosed technical assessments, identifies a potential site capacity of circa 126 units. The total site area equates to 5.1 ha, equating to a site density of 25 u/ha, considered to be entirely in keeping with the context of the site’s location. In these terms, it is considered that the wording of draft policy AL/PE 2 should be revised as follows:

‘This site, as defined on the Pembury draft Policies Map , is allocated for residential development (C3) providing approximately 120 residential dwellings’.

Summary

The site has a potential site capacity of circa 126 units with associated strategic landscaping, with a new vehicular access point proposed from Hastings Road.

The NPPF sets out a presumption in favour of sustainable development. There are three dimensions to sustainable development: economic, social and environmental. The planning system is expected to contribute towards building a strong, responsive and competitive economy, support strong, vibrant and healthy communities and contribute to protecting and enhancing the natural, built and historic environment.

The proposed development at the Site as part of draft allocation AL/PE 2, meets with the three overarching objectives of sustainable development in accordance with the NPPF, whilst having the ability to contribute to delivering needed infrastructure for the benefit of Pembury. In summary these benefits include:

* Economic Benefits - The proposed development will make a significant and meaningful contribution to meeting housing needs within the Borough, through the provision of circa 126 units in a sustainable location. It will allow for the retention of residents in accordance with projected population growth. Resident expenditure will in turn contribute to the vitality of local amenities and services.

* Social Benefits – The proposed development would be able to contribute to local housing need. Improvements to community infrastructure through the provision of recreation space, safeguarded land for the provision of potential future community facility expansion (cemetery or cricket ground), strong connections to cycle routes and footpaths.

* Environmental Benefits – Utilising land (incorporating some previously developed land) of lesser environmental value within the Green Belt. Enhancement of site buffers and retention of the existing natural environment on the site will provide suitable habitat delivering a net gain in biodiversity on the existing.

It is considered that the Site is suitable for Green Belt release, in context of its poor performance against national Green Belt objectives meaning its release would not adversely affect the wider function of the Green Belt. The inclusion of the Site within the LBD of Pembury would therefore represent a natural extension to the existing settlement pattern. The defensible boundaries of the Site including the A21 to the South, provides a logical augmentation of the settlement boundary.

As set out above, the Site represents a deliverable and suitable opportunity to deliver residential development on a smaller site, within a sustainable and accessible location, meeting the objectives and commitments of the Development Plan. Paragraph 14 of the NPPF states that there is a presumption in favour of sustainable development and that ‘local planning authorities should positively seek opportunities to meet the development needs of the area’ in the plan making process. The Site should therefore be brought forward as part of the Local Plan Review process, for residential development, to positively contribute to housing delivery.

We trust that these representations will be fully considered and would welcome the opportunity to discuss them with the Council in more detail. We look forward to receiving acknowledgement of this submission marked for the attention of Jamie Wallace / Graeme Warriner at this office. We would also be grateful if you could keep us notified of the progress of the Local Plan and other emerging planning policy documents.

In the meantime, should you require any additional information please do not hesitate to contact us directly.

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Mrs Carol Richards

Sustainability Appraisal

All of the above points regarding site 448 demonstrate that the assessment in Table 8 of the Sustainability Assessment (Compatibility Testing of Strategic Objectives) is incorrect. Specifically, I believe the re-scoring per Exhibit 10 (TWBC Comment - see attachment) is more appropriate.

In more detail:

* Air is given a mixed/uncertain score under Garden Settlement (‘?’). Yet, how can you state in the SHELAA “traffic will increase substantially” and then say in Table 8 the outcome is uncertain. The air quality in this area is going to be hugely affected. Cars will be used - not buses and access to Tonbridge rail station (which is NOT in TWB)- will not be easy because of traffic congestion.

* Under Biodiversity - the river makes this area hugely important for wildlife-so how is this a ‘?’ . In the SHELAA you say’ biodiversity constraints are limited and then say there is no risk to the Ashdown Forest. The Ashdown Forest is miles away what are you going on about. LOOK at the site. LOOK at the WILDLIFE on the FLOODPLAIN YOU ARE PUTTING IN DANGER. There is no mention in Appendix1 of the LP of the biodiversity of this site.

* Business scores you believe will be enhanced -there is no evidence for this. There will be no employment in the garden settlement. It will be a dormitory town for LONDON.

* Climate change scores you believe will be enhanced supported through alternative fuels. Will the fuel requirements on this site be totally supported by solar or wind power? Note there is no gas supply to this area.

* Landscape is stated to be enhanced with this development and compatible with your objective. This is despite the loss of green belt and as in the SHELAA report ‘encroachment into the ANOB in the south and east.’ I think this assessment is conflicting, you can’t enhance a landscape by putting 2.800 homes on Green Belt Land. This is totally disingenuous to say the least.

* Water is stated as ‘?’, yet the SHELAA states it would represent a substantial demand for water-well 2800 homes would!

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Persimmon Homes South East

Sustainability Appraisal

4.13 The Sustainability Appraisal (SA) prepared by TWBC (dated September 2019) makes up an important part of the evidence base of the Draft Plan. The SA examines the Site within the geographical scope of Horsmonden and assesses its role in meeting the Sustainability Objectives.

4.14 It is noted that the SA notation in respect of the site specific assessment appears to be incorrect. The Site is cross referenced with draft Allocation AL/HO4 when it is in fact AL/HO3. It is therefore unclear if which assessment relates to the Site. This error needs to be resolved for the Reg 19 SA.

4.15 Notwithstanding the confusion arising from the incorrect notation, it is noted that both AL/HO3 and AL/HO4 identify that the development would deliver the major positive of meeting local housing needs. In addition the assessment identifies several other positives including access to education and employment. The majority of other objectives are neutral. Whilst a limited number of objectives scored negatively, it is considered that these can be mitigated through layout design, landscaping and sustainable travel measures – these issues are discussed further in Section 5.

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Barton Willmore for Crest Nicholson

Land west of Paddock Wood

1.0 Introduction

1.1 This report sets out the conclusions of a review of the Sustainability Appraisal (SA) process supporting the Tunbridge Wells Borough Council (TWBC) Draft Local Plan [1 September to November 2019, TWBC Draft Local Plan Regulation 18 Consultation Draft.]. The review has focused on the Regulation 18 Consultation Version SA Report [2 September 2019, TWBC Regulation 18 Consultation Version SA Report.] prepared in September 2019 (herein referred to as the 2019 SA Report). Whilst the review has focused on the latest SA material, reference has been made to earlier reports including the 2016 SA Scoping Report [3 October 2016, TWBC Local Plan, SA Scoping Report.] and the 2019 SA Issues and Options Report [4 May 2019, TWBC Local Plan, SA Issues and Options Report.], where necessary to give a view on the adequacy of the whole iterative SA process.

1.2 A review of the SA documents has been undertaken against the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 (the “SEA Regulations”) and Section 19 of the Planning and Compulsory Purchase Act 2004 (the “Act”), which sets out requirements for SA. SA is a complex and legalistic process and should be undertaken iteratively, alongside the preparation of the Plan.

1.3 A Local Plan must be prepared in accordance with Section 39 of the Act “with the objective of contributing to the achievement of sustainable development”. It should therefore be informed by the SA process, which itself must comply with the SEA Regulations.

1.4 This review has sought to identify any areas of the SA that would benefit from further focus or clarity in order to determine whether the process is robust and to identify where improvements could be made before the next stage of the Local Plan Consultation in which the Regulation 19 Version SA Report will be prepared.

2.0 Review Summary

2.1 The full review is included at Appendix 1. It uses a “traffic light” scoring system to identify areas that would benefit from improvement (amber) and those elements of the SA process that are considered to comply fully with the requirements (green). No areas of major deficiency were identified in the SA (red).

2.2 The following areas of the SA could be strengthened and would benefit from additional focus before Regulation 19 stage:

Existing environmental problems - the SA could better outline the conclusions of the Habitats Regulations Assessment (HRA) work undertaken for site alternatives and define how these have been assessed in combination with other sites or environmental effects. As the HRA had not been carried out in detail at the issues and options stage, the SA states that the precautionary principle was used when assigning scores to the biodiversity objective. However, there is no explanation of the use of the precautionary principle in the 2019 SA Issues and Options Report. There is also no reference provided for the ‘Appropriate Assessment’ mentioned in the SA. Given the need for assessments to be coordinated, it would be more transparent to include more information within the SA Report on the HRA undertaken for the Local Plan;

Environmental protection objectives - the SA framework does not refer to limits or standards including e.g. National Air Quality Objectives, Water Framework Directive, Condition of SSSIs, Carbon Emissions Targets. Inclusion of these objectives would make the framework more aligned with relevant local issues; and

Likely significant effects on the environment (cumulative effects) - the approach to the assessment of cumulative effects is well outlined within the SA, however the short, medium and long-term effects, permanent and temporary effects are considered ‘where possible’ when determining the scores given in the impact matrix and these factors could be outlined better. In addition, cumulative effects are not well assessed at the issues and options stage and it is not clear how the ‘Potential cumulative effects that must be considered by the Sustainability Appraisal’ in Table 5 of the 2016 SA Scoping Report are bought forward and how they are relevant to the assessment of cumulative effects in the subsequent SA documentation.

Reasonable Alternatives - The narrative about the alternative sites seems reasonable although Appendices E-T and the summary within the main 2019 SA Report would benefit from an explanation of how mitigation and design has been taken into account to ensure a level playing field.

2.3 Appendix A of the 2019 SA Report includes some limitations of predicting effects, however these could be better considered and outlined in the main report, including for example assumptions made about secondary data and the accuracy of publicly available information.

2.4 Additional information to address the points summarised above would increase further the robustness of the SA and assist in achieving the right outcome at Examination.

3.0 Land West of Paddock Wood

3.1 The options appraisals utilise the 19 SA Framework Objectives in matrix form with a colour coded key, which makes the comparison of the positive and negative sustainability aspects of a reasonable alternative clear and consistent. The proposed draft allocation for 4,000 residential units at Paddock Wood has been robustly and fairly assessed using appropriate methodology and scores positively against 11 out of 19 of the SA Objectives including health, housing, transport, service and facilities. Paddock Wood is served well by public transport links, including a dedicated train station and numerous bus services. There are many easily accessible amenities such as healthcare, schools, shops, leisure and sports facilities, green spaces and employment opportunities. The proximity of the sites to local facilities would lead to lower car trips, lower emissions and better air quality, as well as providing benefits for the health and wellbeing of the community and climate change.

3.2 We consider that Paddock Wood is a sustainable location for selection out of the presented garden settlement and urban extension location options (Figure 5 and Table 13 of the 2019 SA Report), particularly considering that the SA Objective criteria for air quality relates to reducing pollution, due to the site’s location in proximity to Paddock Wood train station, local employment, schools and facilities. Options 1, 3, 4, 6, 7, 9 and 13 are located a significant distance from sustainable public transport options meaning that developments in these locations would likely rely heavily on car use and would not provide a betterment for air quality.

3.3 As shown in Table 1 above, out of the four urban extension growth options at Paddock Wood (Table 17 of the 2019 SA Report), Option 2 (including Land West of Paddock Wood) presents the preferred and most sustainable option. We are also in agreement that Policy AL/PW 1 (AL/ CA 3) of the reasonable alternative sites within Paddock Wood Parish (Table 27 of the 2019 SA Report) would provide the best option when considered against the sustainability objectives, due to its location and positive impacts on air quality, climate change, facilities, health and biodiversity.

4.0 Conclusion

4.1 The conclusion reached within this report, based on the SA review in Appendix 1, is that whilst the SA process so far does not have major deficiencies, there are a number of areas that would benefit from further focus before the Regulation 19 stage so that the process is as robust as possible.

4.2 The proposed draft allocation at Paddock Wood has been included for allocation within the Local Plan based on its sustainability merits. We consider that Option 2 of the four urban extension options at Paddock Wood is the most sustainable and could arguably score more positively against the sustainability framework objectives than suggested in the 2019 SA Report.

[TWBC: see full representation, including Appendix 1 - SA Compliance Review].

SA_128

Turnberry for Hadlow Estate

Table 16

4. Sustainability Appraisal

4.1. This initial evidence will therefore have an impact on the SA Scores in Table 16 which appraises Growth Options 1 and 2 for Tudeley Village. As we are not seeking to promote a larger site, we have recalibrated the SA scores for Growth Option 1, as shown in our revised Table 16 below.

4.2. These changes produce a more accurate SA appraisal for the site. Many of these scores would of course in many instances apply to any development, but the following are unique to Tudeley Village:

The proximity of the site to strategic urban and employment areas leads to higher scores in terms of Employment, Services & Facilities, and Travel;
The site is outwith any historic or AONB landscapes;
The potential to mitigate flooding at Five Oak Green is a significant benefit under climate change;
The wider Hadlow estate can be leveraged in support of biodiversity improvements. The Estate has experience in wildlife conservation, biodiversity and habitat improvements as evidenced by the long standing partnership with the RSPB on Hadlow Estate land at Tudeley Woods, amongst other initiatives. In short, the impact of Tudeley Village is far less, if not more beneficial, than other spatial options available to the Council, with the majority of metrics scoring above neutral and only two minor negatives.

4.3. Indeed, we would question the SA scores given to isolated, rural and more distant sites, many scoring neutral on matters which relate directly to their scale and connectivity to urban centres, or in their case, a lack of it. This is a potential flaw in the SA which could make the plan unsound and we would ask that the negative locational implications of distant centres are reflected in the SA and there is greater moderating based on the themes discussed under Spatial Strategy in Section 2 above.

Revised SA Appraisal for Garden Settlement Growth Option 9 - Table 16, SA of the Spatial Strategy

Sustainability Objective	Garden Settlement Growth Option 1	Commentary
Air	?	No change
Biodiversity	+	The ecological constraints are identified and will be mitigated through sensitive masterplanning. As the site is intensively farmed and on the basis the Hadlow Estate extends beyond the allocation, there is opportunity to create net improvements in biodiversity.
Business Growth	+	No change
Climate Change	++	Potential to mitigate the impact of climate change on Five Oak Green
Deprivation	++	We note that some rural locations are scoring neutral under deprivation despite the increasing issues around fuel poverty. We have made an adjustment in response to reflect the fact there is less need to travel and that there are more non-car based solutions available.
Education	+/++	No change
Employment	+++	We note that isolated rural locations such as Frittenden were scoring a positive for employment despite its distance and lack of infrastructure, so we have adjusted the scoring to reflect that.
Equality	++/+++	No change
Health	++	No change
Heritage	0	Enhancement and public benefit will off-set any harm
Housing	+++	No change
Land Use	-	The farmland is not the most productive and therefore its loss cannot attract the most significant impact
Landscape	-	As the site is outside the AONB and historic landscapes, it cannot attract the most significant impact. The negative rating relates to its Green Belt status.
Noise	0	The sources of noise are typical of urban environments and can be mitigated
Resources	0/+	No change
Services & Facilities	+++	No change
Travel	++	No change
Waste	0	No change
Water	++	The benefits accruing to Five Oak Green arising from the development means this is a decisive enhancement.

[TWBC: for table showing colour coding, see full representation].

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

SA_129

Turnberry for Hadlow Estate

Table 23

4. Sustainability Appraisal

4.1. We have reviewed Table 23 within the SA to ensure consistency with other sites and to ensure all relevant considerations are factored in.

4.2. These changes produce a more accurate SA appraisal for the site. Many of these scores would of course in many instances apply to any development, but the following are unique to Mabledon:

The proximity of the site to strategic urban and employment areas leads to higher scores in terms of Employment, Services & Facilities, and Travel;
The wider Hadlow Estate can leveraged in support of biodiversity improvements.

4.3. The site therefore moves from scoring positively across nine Sustainability Objectives to scoring eleven, whilst negative indicators fall from seven to two, which brings it in to line with other allocations.

Revised SA Appraisal for AL/SO 3 - Table 23, SA of the Spatial Strategy

Sustainability Objective	AL/SO 3	Commentary
Air	-	No change
Biodiversity	+	The ecological constraints will be mitigated through sensitive masterplanning. On the basis the Hadlow Estate extends beyond the allocation, there is opportunity to create net improvements in biodiversity.
Business Growth	++ / +++	No change
Climate Change	0	The draft Policy insists on a comprehensive climate change strategy
Deprivation	++	We note that some rural locations are scoring neutral under deprivation despite the increasing issues around fuel poverty. We have made an adjustment in response to reflect the fact there is less need to travel and that there are more non-car based solutions available.
Education	+	No change
Employment	+++	We note that isolated rural locations such as Frittenden were scoring a positive for employment despite its distance and lack of infrastructure, so we have adjusted the scoring to reflect that, given the close proximity of employment opportunities.
Equality	0	Adjusted to align with other allocations
Health	+	No change
Heritage	++	No change
Housing	+ / ++	No change
Land Use	0 / +	No change
Landscape	++	No change
Noise	0	The sources of noise are typical of urban environments and can be mitigated
Resources	?	No change
Services & Facilities	0 / -	No change
Travel	+	No change
Waste	0	No change
Water	0	The site is not at risk of flooding from watercourses, but the site will be masterplanned in accordance with the principles of directing development to those areas of the site with the lowest risk of other forms of flooding, e.g. ground water or managing overland flow appropriately

[TWBC: for table showing colour coding, see full representation].

[TWBC: see also Comment Numbers DLP_7018 and 7020].

SA_130

Nigel Tubman

Sustainability Appraisal - section 6.2.1 Results

Table 14. Sustainabilty Objective Air: Development of the AONB to meet Sevenoaks unmet needs largely means in the settlements of Cranbrook, Hawkhurst and other smaller villages.

What has Sevenoaks got to do with Cranbrook and Hawkhurst?

The appraisal accepts that the air quality would deteriorate in these locations. Why has no notice been taken on this?

SA_131

Nigel Tubman

Table 29 SA Scores for allocated sites in Cranbrook & Sissinghurst

The scores for nearly all the sites are higher than one might expect from local knowledge.

I am particularly interested in AL/CRS 7:

An extra 150 houses must lead to a deterioration in air quality. 150 houses could equal 300 cars travelling into Cranbrook and places of work and leisure putting much greater pressure on roads and creating more congestion on local roads and villages. Plus additional gas and smoke emissions from heating systems in the houses.

A development of this size on this site must impact adversely on biodiversity, climate change, heritage, landscape, noise, services and facilities, travel, waste and water.

It is difficult to see what good this development could do for education, employment, equality, health, and resources.

In fact, it could have a negative impact on employment because it would bring in more job seekers without creating more jobs thus increasing competition for local jobs and making it more difficult for local people to find jobs. Any construction jobs are unlikely to be given to local people unless there is a major programme of training for local people.

I accept that it would probably have no impact on business growth and deprivation. And, of course, it would provide more housing, not that Cranbrook needs anywhere near as much as the draft plan suggests.

SA_132

Penny Mackenzie Dodds

Section 4 Paragraph 4.69

The Parish of Cranbrook and Sissinghurst is an AONB consisting of small Wealden settlements comprising many medieval dwellings characteristic of the historical and cultural importance of our national heritage; as witnessed by visitors pilgrimaging to the Union Windmill, St Dunstan’s Church, the Cranbrook Museum and Sissinghurst Castle.

There should be no LARGE scale developments of any kind within this Parish as the authenticity of the historic market town of Cranbrook and parish in which it is situated would be severely compromised beyond redemption.

SA_133

Penny Mackenzie Dodds

Section 2 paragraph 2.21

The infrastructure serving Cranbrook is limited, but as things stand, is in keeping with this small market town which retains its authenticity

Local resources are stretched to capacity ; Doctors Surgeries can barely keep up with the demand from the current local population. But at, as things stand, Cranbrook seems to be just about coping and is self-supporting. However, additional residents would be obliged to travel to larger towns for medical treatment. Large scale residential developments would be unsupportable. There is no railway station and roads in and out of Cranbrook are narrow and already congested.

SA_134

Penny Mackenzie Dodds

General Comment

There are NO employment opportunities in Cranbrook or Sissinghurst. New residents to this parish would be obliged to travel to town such as Tunbridge Wells where business parks are located.

I object to large scale residential developments being located in Cranbrook because it is at least 14 miles away from large towns, such as Tunbridge Wells, (which can only be directly accessed by road ). This is especially inappropriate since the roads are narrow, windy and already severely congested at peak times. It is simply not appropriate and lacks vision to imagine that anywhere in the parish of Cranbrook and Sissinghurst is a viable option for any large scale housing development.

Any new resident aiming to work in London (or anywhere attainable by rail) would find it impossible to get a parking space in any of the nearest (6 miles minimum) rail stations as these are already filled to capacity.

The character and historic authenticity of Cranbrook situated in an AONB is a national treasure and tourist attraction. Large scale housing developments, along with increased population and traffic, would invalidate the integrity of this medieval SMALL market town and render it null and void.

Of course it is understood that our Country needs to provide additional housing – but as far as Cranbrook is concerned any developments which are permitted should be SMALL, SMALL, SMALL and only SMALL.

SA_135

Nigel Tansley

Policy AL/CA1

B.4. Sustainability Assessment of CA1 – Tudeley Village

Site Characteristics

Turning to CA1 – the site earmarked for the development of Tudeley Village – itself, it is hard to imagine a site less suited to larger scale development.

Key considerations that make this site unsuitable for situating a Garden Village include:

Land Status: The land is part of the Green Belt and borders on AONB
Landscape / Use: The site predominantly consists of high-quality arable land (Grade 2 and 3) that is in agricultural production. It also includes hedging and woodland and supports several public foot paths regularly used by the both the local community and people from further afield for recreational purposes.
Infrastructure: There is no existing electricity or sewage infrastructure to support large scale development. This would have to be built from scratch at a very high cost
Services: Development of several thousand houses will lead to substantial new demand for health and educational services for which there are no existing facilities within Capel parish. Demand would likely fall on the adjacent Tonbridge and Malling (T&M) borough. Their facilities already experience very high demand and are unlikely to cope with large increases. Investment in new schools or GP practices are likely to be required.
Transportation (1 – on CA1): Apart from 1-2 narrow winding tracks, there is currently no road infrastructure on the CA1 site. Bus services are very limited / non existing. There are no cycle paths or walking paths connecting to Tonbridge. All would have to be built from scratch. Tudeley Road / B2017 which is the main East-West connection (to Tonbridge or Five Oak Green / Paddock Wood) is already heavily used with long tailbacks at the entrance to Tonbridge (especially at both roundabouts next to the Schools at Somerhill) during rush hour / school pick up times.
Transportation (2 – congestion): Given the type of development envisaged at Tudeley Village, it is highly likely that this will predominantly cater for regular commuters to London who will want to use Tonbridge Station. There are currently no suitable bus services to / from Tonbridge station, and cycle and walking options are unrealistic. It seems clear that there will be a heavy reliance on cars leading to a large-scale increase in road traffic around the site. While expanding the B2017 (or building a new road) could conceivably allow faster traffic flow to / from Tonbridge – this is likely to come to a shuddering halt at the entrance to and cause gridlock in Tonbridge where there are no opportunities for widening the road network.

In addition, the plan to build a new secondary school at CA3 is likely to further add to congestion and air pollution right at the entrance to Tonbridge which already is a traffic pinch point. TWBC’s assertion that this school will only cater for local pupils and be accessed through walking or cycling flies in the face of the reality experienced by the existing schools in Tonbridge – which already has one of the highest densities of secondary schools in the UK.
Transportation (3 – safety): We would similarly expect a heavy increase in traffic down Alders Lane to the A228, Hartlake Road as well as the ‘cut throughs’ to the A21 (e.g. Half Moon Lane). These are narrow winding country lanes with limited visibility and where cars can often not easily pass each other. Increasing traffic flow is guaranteed to lead to a much- heightened risk of accidents.
Heritage: The site includes the All Saints Church – the only Church globally with Marc Chagall designed windows – which attracts regular international visitors and would not benefit from being surrounded by large scale development. It also includes the landowner’s century old family graveyard. Neither of which is mentioned in the SHELAA assessment
Other constraints: The site is dissected by an existing railway line. This raises obvious concerns about how to adequately and safely connect North and South halves of the site. The only current connections are a small underpass in the middle of the site as well as bridge over Hartlake Road on the site boundary. Both are single lane and not suitable for the anticipated traffic increase.

The table below illustrates that from the centre of the site there are currently no direct routes to nearby key destinations. New roads through the site and to the nearest roads of suitable standard would only, as pointed out above, enable the anticipated increased traffic congestion to reach bottlenecks (largely with cross-border concerns) more easily. In addition, it is clear that full research has not been carried out to establish further critical information.

Distance from centre (miles) to:	as crow flies	by existing roads
road infrastructure of suitable capacity	1.6	2.3
railway station – Tunbridge Wells	4.8	7.6
railway station – Tonbridge (cross border)	2.6	3.7
railway station – Paddock Wood	2.6	4.3
nearest supermarket – Tunbridge Wells Asda	2.6	5.8
nearest supermarket – Tonbridge Sainsburys	2.4	3.4
nearest supermarket – Paddock Wood	2.7	4.3

Its own large supermarket similar to Asda at Kings Hill would create cross border issues

Mains water of sufficient capacity not known

Mains sewers of sufficient capacity not known

Land use productive agriculture

Land status green belt

Land contamination not known, Landscape Sensitivity Study not made

Ecological interest not known, Landscape Sensitivity Study not made

Critique of the Sustainability Assessment for STR / CA1

We have already noted that we are in broad agreement with sustainability assessments (“SA”) for most sites contained in the SHELAA documentation – unfortunately these seem to be wildly inconsistent with the assessment for CA1-3.

The scoring for CA1 in particular beggars belief. In our mind, scoring should be ‘negative’ or ‘very negative’ for all of the following sustainability objectives: Air, Biodiversity, Climate Change, Health, Heritage, Land use, Landscape, Noise, Travel, Waste and Water.

Air: How can this be given a “mixed score”? The SA correctly notes that “traffic will increase substantially” with a “high risk to deterioration of local air quality”. The intent to discourage private car usage through shared transport is laudable but is not backed up with any actionable initiatives and is both unenforceable and Increased traffic WILL lead to poorer air quality – the only question is by how much? Score should be very negative
Biodiversity: How can you say that “constraints are limited”. And it is unclear why the reference to Ashdown Forest should be relevant for this Building a large-scale new development on 100s of acres of Green Belt land can only be detrimental to biodiversity. References elsewhere to achieving a “biodiversity net gain” feel like a smokescreen that is not backed up by anything tangible. And the experience of the Tesco Site where woodland was removed for a GBP 25,000 contribution in order to score a ‘biodiversity net gain’ is frankly perverse. This is of course not directly related to CA1 but it does not give any confidence that environmental concerns will be dealt with the seriousness they deserve Score should be very negative
Business: We agree with the existing positive Though it should be noted that the low density envisaged for this site may actually make it more difficult to justify local retail outlets and/or local services (e.g. buses)
Climate Change: Similar to Air and Loss of greenfield land and the associated carbon capture will negatively impact climate change. As will the additional pollution through incremental development and traffic Score should be very negative
Deprivation: We agree with the existing positive And we note the comment that “maximum scores cannot be applied as the proposals are unlikely to address existing problems of fuel poverty”
Employment + Equality: We agree with the existing
Health: We question the positive score The provision of sports facilities is a positive. But to include a consideration that “It was also felt likely that the proposals would include provision for elderly care services.” seems very strange. This is not a fact or even a promise but an unfounded assumption that is actually unlikely to happen since the Garden Village will predominantly attract working families and not elderly people. Also, concreting over the local Green Belt will destroy the public foot paths currently used by locals for recreational purposes Score should be mixed
Heritage: Agree with the existing negative score though you could argue that this actually very TWBC do not seem to have considered All Saints Church at all
Housing: The maximum positive score for housing is of course the obvious consequence of concentrating the lion’s share of TWBC housing requirements in Capel It is hard not to believe that this is the prime criteria and that assessing / scoring for all other criteria is just ‘window dressing’
Land Use: Why is this score not very negative? Score should be very negative
Landscape: We do not understand why this is not very negative. Apart from the destruction of the Green Belt, encroaching on neighbouring AONB, the developments will also cause ‘landscape scarring’ visible from the North Downs. The existing proposals to extend development further into GB and AONB land in subsequent planning periods are even more worrying Score should be very negative
Noise: We agree with the existing negative score
Services & Facilities: How can you provide a positive score based on the “likely well thought-out provision in the new settlement as a result of the master planning process”? This is wishful thinking and not based on any evidence. A more consistent approach would be a mixed or no score until there is actually a plan to assess. Score should be mixed
Travel: The positive score feels like a joke. New bus routes would be a good idea but these have not been defined (nor any new road links to Tonbridge to start with). The feasibility of any new routes will be undermined by the excessively low density of development at Tudeley Village. And, as has already been noted, the predominant transportation vehicle will be the car anyway. The “relatively easy access to train station” comment can only have been written by someone with zero knowledge of the locality. There are no alternatives to car travel to Tonbridge station. In mornings / afternoons, Tonbridge is already in gridlock with no options to increase road width and once there Tonbridge Station and the trains are already at full capacity Score should be negative / very negative
Waste reduction: While we appreciate this may be out of TWBC’s immediate control, not applying any score seems wrong. Of course, building a large-scale development here will lead to more waste Score should be negative / very negative
Water: The mixed / positive water score is unclear and feels strange. This again seems to be based on anticipated improvements due to “substantial demand for water and wastewater treatment”. In reality, there will be greater water usage and greater waste water generation that at best will be mitigated so as to have no incremental negative effect. But even this cannot really be credited since there are no proposals to review Score should be negative

In summary, we believe the scoring methodology for CA1 to be flawed and inconsistent with the overall rationale / criteria / logic employed in other SHELAA sustainability assessments. The actual scores for CA1 should be predominantly negative or very negative as the site is entirely unsuitable for the development intended.

[TWBC: this comment comprises part of the Draft Local Plan comment: Report on Alternatives to Tudeley Garden Village (CA1/2) and East Capel (CA3) Developments - see Comment No. DLP_7118]

SA_136

Miranda Hungerford

Draft Local Plan and Sustainability Appraisal

We are writing to you to register our concerns and objections to the following:

the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy
the suitability of Lamberhurst to accommodate additional dwellings
the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for 30 dwellings (site reference AL/LA2).

Planning Strategy

1) The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 4 and 5.5 of the Topic Paper confirmed that 60% of respondents would like to see housing growth along “growth corridors”, whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. The Council would need to be able to demonstrate that it has reacted appropriately to the consultation feedback, so a far greater emphasis on growth in established centres rather than rural locations would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on private cars as a means of travel – which surely must be of paramount importance given climate change commitments.

2) With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the Limits to Build Development boundary, but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a clear and consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

As seen above, the Council’s housing strategy conflicts with the consultation responses provided at the Issues and Options stage. With this conflict in mind, we question the viability of the proposed allocation of 60 housing units in the village of Lamberhurst (and indeed similar allocations for other villages).

In addition, the strategy to create relatively large developments which are not connected to the centre of the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as one of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has evolved and developed slowly over time and has a limited range of services as a result. The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal. These are summarised below:

Schools: The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops: There is only one shop in the village. The shop is very small and useful only for essentials like milk and a newspaper. The Post Office only opens for 2 short mornings a week. The nearest supermarket for a bigger shop is being Tesco which is 7.8 miles away and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service: There is only a very limited bus service for the village with irregular times. In the mornings, the bus is always full with school children which has been a topic of much public debate with support from local MPs. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work. New residents are therefore likely to be using private cars for both work and transporting children to school (as the current bus is already over capacity).

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Lamberhurst Neighbourhood Plan. The Neighbourhood Plan is promoting developments that are well designed and reflect local character. The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

We have established that residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. We are aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds. This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.

The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

The current owners of Misty Meadow Farm have been seeking planning permission for several years (17/02042). Planning was repeatedly turned down by TWBC due to concerns about the ridge height of the building, building on a ridge line, light pollution and the impact on visual lines across the village as well as concerns about the proposed building being ‘obtrusive in the landscape setting’. TWBC Planning Department was clearly highly concerned about the impact of a single building on this site, let alone 30 new houses.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will be heavily reliant on the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

SA_137

Campaign to Protect Hawkhurst Village

Overall approach/Hawkhurst allocations

THESE COMMENTS RELATE TO THE OVERALL APPROACH TAKEN BY THE SUSTAINABILITY APPRAISAL BUT IN PARTICULAR AL/HA1 AND THE OTHER HAWKHURST ALLOCATIONS

We would make the following comments regarding the Sustainability Appraisal:

Methodology
Section 4 of the SA sets out the evidence base on which the Sustainability Appraisal relies.  Table 2 confirms that this is based on the “Transport Study” which we assume is the SWECO Transport Assessment.  There are no other transport related reports or studies mentioned in Table 2.
The SWECO Transport Assessment is wholly inadequate for the purpose of informing the SA’s conclusions regarding the impact of the Growth Strategy on Hawkhurst and the east of the Borough more generally.

This is because the SWECO report, insofar as traffic and congestion matters are concerned, is focussed solely on an assessment of the “Core” area around Tunbridge Wells.  It does not make any assessment of the impact of the proposed Growth Strategy on either the Hawkhurst village crossroads or the A21 at the Flimwell junction.
It is therefore not clear on what basis the conclusions regarding the travel impacts of the Growth Strategy have been made in respect of Hawkhurst.
From the text of the SA this appears to be based on the assumption that the relief road will actually result in the removal of traffic from the village crossroads.  However, there is no publicly available evidence to substantiate this assumption.
The only publicly available document that purports to demonstrate the impact of the relief road is the Transport Assessment submitted with the current Golf Course Planning Application.  This demonstrates that even with the relief road in place, traffic through the village crossroads is predicted to significantly increase. In turn, it predicts significant increased congestion at the Flimwell traffic lights.  Importantly this assessment does not take account of all the allocations within the DLP in Hawkhurst.  The cumulative impact is likely to be significantly worse than predicted in that report.
The conclusions of the SA regarding the Hawkhurst allocations (both individually and cumulatively) are therefore based on an incomplete and inadequate methodology.
This also demonstrates that the assessment made regarding noise, air quality and climate change have been made on a false understanding of the impact of the relief road.
As set out in our comments regarding the SWECO report.  The Council needs to undertake a proper and detailed strategic assessment of the cumulative impact of the Growth Strategy on Hawkhurst crossroads and Flimwell.
The conclusions of the SA in turn need to be revisited once a proper evidence base is available.
Approach to consideration of Paddock Wood Extension Options
The SA identifies that four options for Paddock Wood extension were considered. Option 2 is the preferred option representing 5000 dwellings whereas Option 4 proposed 6000 dwellings.
The SA undertakes a comparative analysis between all four Options. However, it fails to assess is the consequential impact on each option for the remainder of the Growth Strategy.
In particular if Option 4 were pursued it would have a dramatic impact on the quantum of land required to be released in the AONB in the east of the borough.

Given the fact that Paddock Wood is outside the AONB and a far more sustainable location (with considerable additional infrastructure now proposed) than the settlements in the east of the Borough, this specific comparison should have been undertaken.
The impact on the AONB and remainder of a Borough should have been a factor in the determination of the preferred option for Paddock Wood as a reasonable alternative to the release of additional AONB land.
Consistency of Approach
We are concerned that the SA does not appear to have adopted a consistent approach to individual sites across the Borough – and in particular between allocated sites and those that have bene rejected.
We would highlight by way of only one direct example a comparison between the findings for HA1 (the Hawkhurst Golf Course site) and Site 146 (Tunbridge Wells Golf Club).
These sites are both 9 hole Golf Courses (save that Hawkhurst is still operational whilst Tunbridge Wells has closed).  They are two direct comparator sites.
In respect of Biodiversity Site 146 it is considered -/-- whereas HA1 is neutral.
No explanation is given as to this difference given both sites will result in the loss of huge greenfield sites – albeit given its rural location the HA1 site makes a far greater existing biodiversity contribution.
In respect of Air Quality Site 146 is – whereas HA1 is +
The associated commentary explains that 146 was assessed as negative due to increased car travel that can’t be offset.  The same applies in respect of HA1 – save that the Tunbridge Wells Golf Course site is in an infinitely more sustainable location within walking distance of Tunbridge Wells station and town centre.
In respect of Climate Change Site 146 is – whereas HA1 is unknown.
In respect of Noise Site 146 is -/-- whereas HA1 is +.
The commentary for 146 explains that the noise assessment is in part considered due to a large increase of vehicle movements onto a road that already experiences high levels of road noise.
The exact same situation exists in Hawkhurst.  In particular it is predicted that there will be a 98% increase in traffic on the High Street as a result of the relief road – this road is already extremely busy and noisy within significant numbers of noise sensitive receptors in close proximity.
In respect of Travel Site 146 is 0 whereas HA1 is 0/+
The conclusions regarding HA1 (and Hawkhurst in general) are predicated on the relief road actually working.  For the reasons set out above there is no evidence to support this assertion.  The Golf Course’s own Transport Assessment advises that traffic through the crossroads will actually increase.  Furthermore, there is no consideration of any knock on impacts at Flimwell.
On any reasonable analysis site 146 is more sustainable than the Hawkhurst Golf Course – not least given the latter is still operating and the former is closed.
The Council seems to consider that the release of a site with limited public transport provision, poor accessibility to employment, education and medical facilities is preferable (and more sustainable) that a site within walking distance of the centre of Tunbridge Wells.
The SA suggests that the potential to deliver housing outside the AONB has been maximised.  This is demonstrably incorrect looking at site 146 alone.
Comments on Hawkhurst Assessment

As set out above the conclusions regarding Hawkhurst in many areas are fundamentally flawed as they are based on the erroneous assumption that the provision of the relief road will actually result in a reduction in traffic through the village.

The commentary refers to the “significant benefit” that the relief road would bring.

There is no evidence before the Council to support this assumption.

Furthermore, it fails to take into account the impact on the A21 Junction at Flimwell.

It is instructive that notwithstanding these errors the overall cumulative impact in travel terms is considered to be slightly negative. The SA acknowledges that in pure travel terms any benefit to be provided by the relief road will be offset by the traffic generated by the allocations.

Given the existing position at Hawkhurst crossroads is acknowledged to be “severe”, this conclusion demonstrates that there will be no overall “betterment” for the village. In fact, the SA confirms (even based on its inadequate methodology) that the situation will in fact get worse.

Likewise, no consideration has been given to the impact at Flimwell.

Nowhere in the DLP and supporting evidence base has this conclusion seemingly been taken into account.

This has a direct impact on the overall conclusions on Air Quality and Noise. The overall impact is considered to be positive in these areas. It is difficult to reconcile this conclusion with the assessment that the overall travel impact will be negative.

The overall assessment does not appear to have undertaken any granular precise assessment of the specific impacts of the relief road. In particular given the predicted 98% increase in traffic along the High Street (before traffic generated by the other allocations is taken into account).

In any event once the full impact of the relief road is properly understood (and the impact on Flimwell taken into account) it is clear that these conclusions do not stand up to scrutiny.

The reality is that the considerable additional traffic generated will have a material adverse impact on the air quality and noise within the village. Particularly to sensitive receptors to the west of the crossroads.

Finally, the overall conclusion on Landscape is that the cumulative impact will be “negative” and neutral in biodiversity terms.

It is difficult to know how much greenfield land in the AONB in one area would have to be lost for the authors to reach a conclusion that the impact on Landscape will be “very negative”.

All the sites have been assessed by the Council as being of high sensitivity.

The Golf Course site alone is the single largest site ever sought to be developed in the AONB not just in the Borough but in the whole of England. The Planning Application has received the strongest possible objection from Natural England.

When taken together there will be a dramatic loss of greenfield sites adjoining the current settlement boundary. This will have a profound impact on the landscape character of Hawkhurst, erode the valued rural approaches, result in the coalescence of the individual component settlements and materially harm the AONB in this single location.

On any reasonable analysis the cumulative impact in landscape terms at Hawkhurst can only fairly be considered to be “very negative”

SA_138

Wealden District Council

SA as a whole document

In terms of the Sustainability Appraisal overall, it is considered that greater justification could be provided for policies within the draft Tunbridge Wells Local Plan and their reasonable alternatives as to why certain polices were ‘selected’ and others ‘rejected’. Whilst the text has some brief explanations, this is more related to commentary in relation to explaining the scores against the SA Objectives rather than a holistic conclusion for each alternative considered.

Paragraph 018 Reference ID: 11-018-20140306 of the Planning Practice Guidance states that

“The sustainability appraisal needs to consider and compare all reasonable alternatives as the plan evolves…[and] In doing so it is important to: · outline the reasons the alternatives were selected…and · provide conclusions on the reasons the rejected options are not being taken forward and the reasons for selecting the preferred approach in light of the alternatives”.

It is considered that policies within the draft Tunbridge Wells Local Plan should consider all reasonable alternatives to the identified policies.

Section Number: 6 Paragraph Number(s): 6.1.1 – 6.1.6

Whilst these paragraphs set out the six growth strategies considered through the Issues and Options stage, a summary has not been provided to show which of the six growth strategies were considered appropriate (or not) to be taken forward in the draft Local Plan (i.e. why they were selected or rejected). Such information would be helpful and could be shown through a summary table, so as not to repeat text from the SA of the Issues and Options, which in itself is not wholly clear on which strategies were selected and rejected at that stage (i.e. not all of the strategies have reasoning/justification).

Appendix B of the SA for the Issues and Options provides the appraisal of the six growth strategies along with commentary on the effects of each on the SA Objectives, but it does not ultimately state which strategies were selected or rejected. This may have been best presented within the SA of the draft Local Plan September 2019 (Regulation 18).

It is noted that paragraphs 6.2.4 – 6.2.10 provides a discussion in general terms about some of the growth strategies considered and their relative merits, however these could be made clearer. There is a lack of explanation for all of the growth strategies that were appraised.

It is not clear throughout this section the reasons why certain options were selected and the others rejected and not taken forward in the draft Tunbridge Wells Local Plan. Some explanation is given in the supporting text but this would be much clearer to the reader, and in line with the legislation, if it were tabulated and either added to the SA matrices of the options in an additional column/row or as separate tables stating the justification for each option alone.

Section Number: 7 Paragraph Number(s): 7.1.3 and 7.1.4 (3)

Although the text states that Policy STR4 relates to the specific releases of Green Belt land (sites) and so is subject to a cumulative appraisal of all sites allocated in the draft Local Plan, there could be an appraisal of the policy in terms of the principle of releasing Green Belt Land in the first place, with the reasonable alternatives (or not as it may be) of not releasing this land. The overall thrust of the policy could be assessed against the SA Objectives and then the finer grain detail of the certain sites/land being released as allocations in the draft Local Plan.

This section could also cross refer to the evidence base used for de-designating parts of the Green Belt and consider that in an appraisal of the policy, as a policy in its own right, or the implications of taking forward the Local Plan without such a policy – even if this is just to state that not having a policy of this nature is unreasonable for whatever justification. It is considered that the appraisal of the policy and its justification should be presented here.

In addition, it could be made clearer in this section as to why specific policies were selected for the draft Tunbridge Wells Local Plan, with a greater level of detail where appropriate. The commentary in Tables 18 and 19 merely relates to the scores for each Objective rather than a final ‘conclusion’ for the selection of the policies over a ‘no policy’ approach.

Section Number: 8 Paragraph Number(s): 8.1.4

It would be helpful and informative for the reader to have a list of the sites that were filtered out at the initial stage (and a brief justification for this in relation to the criteria used).

Section Number: 8 and Appendix E

Site Number: 137

Site Address: Land to the west of Eridge Road at Spratsbrook Farm, Royal Tunbridge Wells, TN3

Although the allocations for Royal Tunbridge Wells are appraised in Table 21 on page 61 of the SA in a cumulative sense, there is a lack of sufficient and robust detail within Appendix E (as well as within Table 21) with regards to the individual appraisal of Site 137. It is considered that the appraisal does not account for the large site extending beyond the borough boundary and into Wealden District. There is no consideration of cross boundary impacts on transport infrastructure for example. In addition, there is no mention that the north western part of this allocation lies within the High Weald Area of Outstanding Natural Beauty (AONB) nor that the remainder of the site (within Wealden District) is also wholly within the High Weald AONB. The ‘Landscape’ SA Objective is given a negative score but in the commentary, no regard is given to this issue or to the allocation site potentially having a negative impact on the setting of the AONB within Wealden District.

Furthermore, there is no clear justification for why Site 137 was selected to be allocated, nor why other sites rejected in SA terms. This is applicable to both Table 21 and Appendix E.

Site Number: 236

Site Address: Land at Bayham Sports Field West, Bayham Road, Tunbridge Wells

Site Number:

249 Site Address: Cemetery Depot, Benhall Mill Road, Tunbridge wells

Site Number: 255

Site Address: Land at Hawkenbury, off Hawkenbury Road/Maryland Road

SA_139

South East Water

Sustainability Appraisal

South East Water welcomes that Tunbridge Wells Borough Council have added water as one of the objectives of their Sustainability Appraisal document and supports the view that there is more to be done apart from reducing personal water consumption to 110 litres. We are concerned and we do not agree with the following statement: “There is currently no indication that utility companies are sufficiently addressing this problem thus problems may develop where large development is planned.”

In our latest Water Resources Management Plan we have incorporated 110 litres per person per day figures for new homes and included a really ambitious long term programme to reduce personal water use. We would argue that the Sustainability Appraisal document in combination with the Local Plan should be more ambitious and seek to reduce per capita consumption in new homes further below 100 litres.

With regard to proposed large development sites within our existing longer term plans we are proposing to extend our trunk main water distribution network where necessary to supply new centres of demand as identified.
In respect of the locations selected for new development indicated on the Tunbridge Wells Borough draft Local Plan South East Water is already planning to construct a new main to bring water towards Paddock Wood from our new resource at Aylesford to meet additional demand in the area. We will need to reinforce our network between Cranbrook and Tenterden to accommodate additional demand in the Benenden and Sandhurst areas. Other local reinforcement may be required in this area. Reinforcement will also be required in the Crescent Road and Blackhurst areas of Tunbridge Wells to ensure we maintain levels of service to new and existing customers in the locality.

South East Water will work with local authorities and developers to ensure that any necessary infrastructure reinforcement is delivered ahead of the occupation of development. Where there are infrastructure constraints, it is important not to under estimate the time required to deliver necessary infrastructure.

South East Water would like to reiterate that our primary concern is the water that we abstract and treat for public supply purposes and ensuring that the surface and groundwater abstracted does not fall below the tolerances of our water treatment works or the drinking water standards set by our regulators.

South East Water would like to be kept updated with any developments relating to the Tunbridge Wells Borough Local Plan and looks forward to working with Tunbridge Wells Borough Council to ensure that drinking water supplies remain protected in the area in the future.

SA_140

Judith Marks

Firstly I would like to point out a number of inaccuracies regarding East End in the tabulated Overview:

AONB – you state that East End is outside the AONB. In fact the majority of East End (97%) is within the AONB. The exception is the “bite” into the AONB boundary made around Benenden Hospital, which is already highly visible from the AONB to the South.
Rail transport – the nearest station to East End is Headcorn (approx 7 miles) via the Castleton’s Oak crossroads (accident black spot). Staplehurst and Etchingham are not viable options.
Education facilities – there is no longer a pre-school/nursery in East End.
Retail – the small shop at the hospital was closed several years ago. There is no shop in East End.

These inaccuracies do not give confidence that they are a sound basis on which to make decisions that will have a profound impact on the rural area of East End.

Draft Local Plan

Strategy for Benenden Parish (P265)

A significant element would be provided around Benenden Hospital (approx 44-50%) would be provided around Benenden Hospital at East End. While the services provided at East End are considerably less than at Benenden, Benenden Hospital is a major employment site, contains significant areas of previously developed land, is not within the AONB, and there is good potential to increase the connectivity to Benenden.

I object to the Draft Strategy for Benenden Parish for the following reasons:

There is a completely unequal allocation of the development around the parish. Up to half of the new dwellings proposed for Benenden are allocated to the area of East End. The Draft Strategy proposes to create a whole new satellite village in East End by allocating up to a further 50 houses. Added to those already approved, this means doubling the number of households in East End and overwhelming it. As a comparison, if you doubled the number of houses in Benenden village, that would mean adding 250. I am not suggesting this should be done, but it gives an idea of the impact. The proposed development is not related in scale to the current area of East End or in location to Benenden village and its services.

There are no community services or facilities currently in East End around which to base a new settlement (see Overview comments above).

Development in East End will do little to enhance or maintain the vitality of Benenden or support services there. As residents of the proposed new settlement would have to get into their private cars to go anywhere, they would shop and use services in nearby Tenterden. The only service likely to be used in Benenden itself would be the village school, which again would be accessed by car along narrow rural lanes.

The Strategic Objectives address critical environmental issues such as climate change explicitly. STR6 states that “future development will be delivered within close proximity to accessible locations of existing settlements .... to help reduce the need to travel”. By placing the proposed new settlement at such a distance from the village, residents would be entirely car-dependent, which would increase traffic and carbon emissions leading to poorer air quality. Other sites closer to the village centre would not have this impact.

East End has always been a scattered collection of farms and houses rather than a discrete village or hamlet, and any clustering has been due to Benenden Hospital building a small amount of its own staff housing. On the other hand, Benenden village and Iden Green are already distinct settlements and have been defined as conservation areas, whereas East End is not a distinct settlement and therefore remains as part of the wider landscape.

At the time of the last conservation area review in 2005, the wider landscape setting remained outside the boundary of the conservation area as “it is currently protected through Local Plan policies and other designations, particularly the High Weald Area of Outstanding Natural Beauty” (Benenden and Iden Green Conservation Areas Appraisal 2005, 1.15). It appears that any protection from Local Plan policies is now being removed from the wider landscape setting.

The TWBC Landscape Strategy is to ensure that the existing pattern of settlement i.e. small-scale dispersed rural buildings which are not visually prominent and are hidden by the landform and woodland cover, is protected. The proposed development in East End lies along the ridgeway and would be highly visually prominent.

I would dispute that there is potential to increase the connectivity to Benenden, which is 3 miles away. Residents would rely almost completely on private cars.

- There is a current 12 month trial by KCC of a weekday “Hopper Service” twice daily (not at school or working day start/end times) but there is no guarantee that this will continue beyond the trial period. This service also connects to Iden Green, which the assessment suggests is “remote” and with no potential to improve connectivity.

- There has been some suggestion of a cross-country cycle/footpath along narrow lanes and the route of n existing public footpath, but this is not a practical option for connectivity. If it were to happen, it would be purely recreational. The route crosses three steep-sided valleys and tarring or otherwise hard surfacing the existing footpath where it passes along the old green lane through undeveloped woodland and farmland would be detrimental to the landscape and environment within the AONB.

- Any suggestion that Benenden Hospital Trust could be made responsible for school transport is not credible.

The proposed Limits to Built Development around Benenden appear to have been simply redrawn to accommodate the preferred sites. It would therefore be possible to extend them to encompass other highly feasible sites in the village which would be close to and support services and improve the sustainability of the village. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.

The Strategy proposes that the LBD at Iden Green is removed “as the settlement has limited key facilities and bus services, making it unsustainable in this context”. Iden Green has considerably more services than East End and is only 1 mile from services in Benenden village with an established hard-surfaced footpath, whereas East End is 3 miles from the village. If development in Iden Green is unsustainable, surely development in East End is even more so.
The NPPF states, at paragraph 115, that “great weight should be given to conserving landscape and scenic beauty in … Areas of Outstanding Natural Beauty which have the highest status of protection in relation to landscape and scenic beauty.” Benenden Hospital and the proposed development sites at East End lie along the ridgeway and watershed between the Rother and the Medway. As such they occupy an elevated position and are highly visible from within the AONB. In fact the boundary of the AONB appears to have been drawn round the Hospital site so it impacts the views in many directions. The Hospital and its extensive car parks are already highly lit at night, despite apparent representations from the Parish. Further development on the watershed will intrude even more into the views from within the AONB, counter to the AONB Management Plan, which the Borough Council has adopted.

One reason given for the suitability of development in East End is that AL/BE4 is mostly previously developed land. The hospital has been allowed to develop its new wing and associated car parks on undeveloped land, and in fact during construction a paddock on the opposite side of Goddards Green Road was hard-surfaced to provide contractors car parking and has never been reinstated. It has now become permanent car parking and is shown as part of AL/BE4. This creeping appropriation of undeveloped land and corresponding release of previously developed land is apparently now being rewarded by TWBC by allocating it for housing development. If the issue of whether or not land has been previously developed is paramount, then the right thing to have done would have been to make the encroachment onto greenfield dependent on the hospital reinstating an equivalent amount of brownfield land, which it now says it no longer requires.

The SHELAA states that the site could be deliverable in the period of the Local Plan. This assertion is not supported by the fact that no development has taken place in the area in the south-east quadrant of the site, where planning permission was granted some time ago, and this land appears to have been “banked”.

The Sustainability Appraisal states that “the education objective does not deteriorate when considering cumulative effects as the schools in Tenterden will be a viable option for residents in East End and thus are likely to take the pressure off Benenden Primary School”. This may be a possibility for secondary schools, but both Tenterden Primary School and Infants School are already over-subscribed, and therefore these schools will not be a viable option for residents in East End. Children living in any proposed new development in East End would have to be accommodated at Benenden Primary School.

I would like to make the following counter proposals to help meet the housing allocation imposed on the parish:

That other sites in Benenden village and Iden Green be reconsidered, and in particular Sites 66, 158, 222, LS8 and 437 (part), and the LBD adjusted to take account of suitable sites.

That the 18 semi-detached houses in Wood Lane and along Goddards Green Road, which the hospital no longer requires for its own staff, be taken out of AL/BE4 and offered for sale individually as affordable housing to local people, who could refurbish them themselves. Alternatively, they could be offered to a housing association for refurbishment. These houses may be outdated and no longer required to meet the Hospital’s accommodation needs, but their current dilapidation is overstated. Rather than standing empty and eventually being demolished to make way for new housing, these empty homes could meet an immediate housing need and the Hospital could realise immediate benefit from their sale. One of the key issues for the villages highlighted in the Core Strategy is to meet local needs for affordable housing.

While I fully support the localism agenda, the neighbourhood plan for Benenden has been prepared without representation from the area of East End. I have submitted detailed objections to the neighbourhood plan, but I have no confidence in the process and my impression is that it has been prepared with a complete focus on limiting development in Benenden Village and Iden Green at the expense of the outlying parts of the parish.

I also fully subscribe to the objections put forward by the Friends of East End.

SA_141

Angela and Ian McEwen

Section 8 Table 35 Brenchley and Matfield site allocations

Section Number: 8

Paragraph Number(s): Table 35, SA for allocated sites in Brenchley and Matfield Parish

We object to the sustainability appraisal for allocated sites in the Parish of Brenchley and Matfield (all of which are in Matfield) on the basis that the scoring of some individual objectives does not reflect the true situation, and that the cumulative assessment is not a accurate reflection of the individual scores and does not justify the development proposed.
- Biodiversity. All of the proposed sites in Matfield involve building on agricultural land in the AONB. This will inevitably reduce biodiversity on those sites. Even if biodiversity in the wider local area is not affected (debatable given that the sites provide habitat for some protected species), Policy EN11 requires there to be a long-term gain in biodiversity which will not be the case. The scoring here should be negative, therefore, not neutral.
- Education. It makes no sense for this to be scored neutrally/positively when there are no educational facilities in Matfield. The nearest schools in Brenchley and Paddock Wood are not accessible on foot or by public transport and, while there are some school buses for the Paddock Wood secondary school, the pre- and primary school facilities in Brenchley are only accessible from Matfield by car.
- Employment. It is not at all clear why this is scored positively. There is no reason why housing development in Matfield should provide new employment opportunities in a village which offers very few local jobs. People will have to commute to work outside the village and are unlikely to be able to do so by public transport.
- Housing. Again, it is difficult to see why this is scored positively. The draft Local Plan does not identify any specific need for housing in Matfield and an increase of up to one third in the total numbers of households in the village would far exceed any identifiable need. One of the factors in the decision-aiding questions (Appendix A) is meeting the needs for accessible housing and housing suitable for older people. However, the appraisal for Matfield states clearly that the absence of services and facilities in the village would make any new housing less suitable for the elderly or disabled.
- Noise. This is scored neutrally but the overall objective (as stated in Appendix A) is to reduce noise. Up to 150 new houses constructed to a much greater density than the rest of the village will surely increase noise to some extent?
The scoring of some individual objectives relating to Matfield is not backed up by the facts. Specifically:
With regard to the cumulative assessment, this appears to equate neutral scores to a positive evaluation as it states that the overall assessment “is balanced between 9 neutral or slightly positive scores and 9 negative scores”. Surely that is wrong? Even leaving aside the objections above to some of the individual scores, there are 9 negative scores, 7 neutral scores and only 2 positive scores. Furthermore, of the two positive scores, only one (housing) is given a high weighting in the methodology while three of the negative scores (heritage, landscape and services with regard to rural settlements) have a high weight. On this basis, the Borough’s own assessment does not support the large development proposed in Matfield. If the scores are altered to reflect the fact that that some of the individual scores do not seem to take full account of Matfield’s situation, there would be no positive scores in this appraisal.
The commentary is also wrong in stating that “most” development in the Parish is proposed for Matfield. All four development sites are in Matfield.

SA_142

DM and SE Woodcock

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services and infrastructure as a result. The limited range/capacity of services is not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal. These are summarised below:

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Bus service:There is only a very limited bus service for the village, with the bus to Tunbridge Wells taking approximately half an hour and with an extremely limited frequency. Additionally, twice a day, and more,, the bus is full with school children. This means that the bus service could not be reliably used by anyone living in Lamberhurst and wanting to commute to work. New residents are therefore likely to be using the private motor car for both work and transporting children to school (as the current bus is already over capacity)

In addition to the above, there is concern that the Draft Local Plan is diverging from the aims and aspirations of the emerging Neighbourhood Plan. The Neighbourhood Plan is promoting developments that are well designed and reflect local character. The two local plan allocations for Lamberhurst (both for around 30 dwellings) will be far more suburban in character and will not reflect the rural location of Lamberhurst.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_143

Andrew Ashe

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_144

Helen and David Cheales

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_145

Laura Gendt

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

1) The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep hill down into the village making it almost impossible for people in wheelchairs, mobility issues, older people and people with buggies. Together, these aspects indicate that even where future residents were to consider using the limited village services, people would still be most likely to use private cars for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) We have established that residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. We are aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds. This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.

4) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

5) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

6) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species such as Great Crested Newts), and landscape. The site already ‘scores’ worse than the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

7) The current owners of Misty Meadow Farm have been seeking planning permission for several years (17/02042). Planning was repeatedly turned down by TWBC due to concerns about the ridge height of the building, building on a ridge line, light pollution and the impact on visual lines across the village as well as concerns about the proposed building being ‘obtrusive in the landscape setting’. TWBC Planning Department was clearly highly concerned about the impact of a single building on this site, let alone 30 new houses.

Conclusions

The general approach taken to the provision of housing (including relatively large allocations of housing on individual sites in small villages) is contrary to the consultation responses provided in the preparation of the draft Local Plan.

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_146

Mike Couchman

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_147

Mr and Mrs G Playfoot

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_148

John Gibson

Site 54 Land to the east of Mill Lane Sissinghurst

Site Number: 54

Site Address: Land to the east of Mill Lane Sissinghurst

Policy AL/CRS12

a. The removal of established local farming activities on this site is hardly an act of Sustainability. The field is currently used for grazing sheep and is designated by KCC Biodiversity as “Other grassland of Importance” owing to its careful conservation management over the years.

b. The biodiversity colour on the Table should be red not blue.

c. Adjoining the field is the historic Mill Farm (the former village miller’s house with windmill). The Heritage colour on the Table should be pink at least.

d. The removal of the existing group of bee-hives is not what I would expect from a Sustainability policy.

e. Granting permission to build homes on this site will see increased carbon emissions due to the resulting increase in road traffic.

f. More traffic will result from allocating all of the new resources to provide employment some distance from the Parish.

g. Any removal of hedges or trees on the site is to be avoided.

h. Housing on this site will severely impact the local species of bats, woodpeckers, owls, nightingales and other birds, hedgehogs, newts, grass snakes and slow worms etc. and have a detrimental effect on the adjacent Primary School wildlife conservation area.

i. Road hazards created on the A262 and Mill Lane by the development must be resolved without impacting Sustainability. This should include avoiding the introduction of street lighting along the A262 and avoiding the removal of any hedges and trees.

j. This site was excluded from the NDP produced by our locally elected Parish Council.

SA_149

John Gibson

Site 120 Land east of Camden Lodge, adj to Mill Lane and Sissinghurst Road, Sissinghurst

Site Number: 120

Site Address: Land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road, Sissinghurst

Policy ref: AL/CRS 13

This will result in the loss of Greenfield Land. The site is adjacent to the High Weald AONB boundary and is old parkland. It was used for grazing cattle and then sheep until fairly recently. Its use for housing is hardly an act of Sustainability. It forms a green-gap between Sissinghurst village and Willesley Green.

The Biodiversity should be at least pink in the Table, not blue. Housing on this site will severely impact the local species of bats, woodpeckers, owls and other birds, hedgehogs, newts etc. and have a detrimental effect on the nearby Primary School wildlife conservation area.

The Landscape should be red in the Table. This is old Parkland with many fine, mature trees and valuable agricultural land.

Granting permission to build homes on this site will see increased carbon emissions due to the resulting increase in road traffic.

By allocating all of the new resources to provide employment some distance from the Parish more traffic will result.

Any removal of hedges or trees on the site must not be permitted. The ancient rural countryside should be protected

The severe road hazards created on the A262 and Mill Lane by development must be resolved without impacting Sustainability. This should include avoiding the introduction of street lighting along the A262 and the removal of hedges and trees.

The site was excluded from the NDP produced by our locally elected Parish Council.

SA_150

Carolyn and Adrian Schweitzer

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_151

Jenny Couchman

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_152

Mr & Mrs Groom

OBJECTION:

As residents on the Golford Road, we regularly use the road into Cranbrook and walk along it’s rural footpaths. We have a number of serious concerns regarding road safety, the location of nearby listed houses, the impact on both the environment and its wildlife, together with the questionable suitability of locating new homes next to an already overwhelmed sewage plant.

A) SAFETY

i) Pedestrians access to Cranbrook:

The current access for pedestrians wishing to walk into Cranbrook is very narrow. Our son used to walk to school, but we quickly realised that it was far too dangerous for him to do so. The pavement adjacent to the pond (below Tilsden Lane) is not only narrow, but regularly floods. I have witnessed cars aqua-plaining across the water. In addition, the pavement stops at Fir Tree Farm and thereafter there is only a verge which runs adjacent to a drainage ditch. It often becomes waterlogged and those pedestrians who choose to walk, have to do so in the road.

ii) Pavement width:

The current width of the pavement is only 50cm. The width should be a min. of 200cm under normal circumstances or 150cm if physical constraints prevent this or 100cm if there is an obstacle (Dept of Transport). This minimum is only achieved when overgrown brambles etc. have been cleared, but for most of the year it is 50cm or less. The Council have repeatedly told residents that it cannot be widened. As a result, we no longer allow our children to walk to school, so we add to the congestion by using the car to travel into Cranbrook.

iii) Vehicular access to Cranbrook/Staplehurst

For those residents who drive to Cranbrook via Golford Road to access its schools, we have to negotiate the narrow approach road with parked vehicles to the right-hand side. Due to the congestion at the Waterloo and Stone Street T-junction, I have to drop my son at the school 40 minutes before he needs to be there.

For those needing to continue into Cranbrook town, the access is via Stone Street which is an extremely narrow road, which is only wide enough for two small hatchbacks to pass (and certainly not the usual 4 x 4's). Some cars attempt to pass one another, but one inevitably has to mount the (extremely narrow) pavement. Despite being a supporter of local businesses, I avoid coming into the town to shop because of the access problems. Increasing traffic here would exacerbate the situation and cause further safety issues for both road user and pedestrian.

With the nearest train station in Staplehurst, most cars would normally travel via Waterloo Road, but due to the congestion, most travel via Golford Road and Chapel Lane into Sissinghurst. There are regular accidents at the Golford Road crossroads. The most recent collision resulted in a car flipping onto its roof. I have also observed a number of near misses and approach the site with caution every day. The approach from Chapel Lane to The Street in Sissinghurst already has severe traffic problems regardless of the time of day. The road is narrow and residential cars park on both sides of the highway, making it difficult to proceed.

iv) Traffic speed

Golford Road is a designated rural lane.The speed limit near the proposed site is 30mph, but drivers travelling along the Golford Road towards Cranbrook rarely obey this.

v) Road width

The Golford Road narrows significantly as it approaches Cranbrook (particularly on the bend above Tilsden Lane). The railings are regularly dented and buckled where cars have collided, and many road users do not observe the speed limit. Buses and other wide vehicles frequently use the road and approaching vehicles have to mount the pavement to negotiate. I have witnessed cars almost colliding with wider vehicles and, even more worrying, I have seen a pedestrian forced to pin themselves against the railings to avoid being hurt.

We understand that the Dept. of Highways objected to the expansion of the sewage plant some years ago. The reasons sited were that the width and visibility of the rural approach roads were unsuitablefor the increase in traffic. It was ruled that the proposal was unacceptable on highway safety grounds. TWBC itself raised objections, including the unacceptable impact of additional traffic movements on highway safety.

B) SEWAGE WORKS:

Living further along the Golford Road, our boundary abuts Crane Brook and the ancient wood known as Plantation Wood. Treated water from the sewage works is discharged into the brook which sustains much aquatic life, including the Great Crested Newt.

It is well documented that the current Sewage Works is already at its maximum limit, with excessive effluent being stored in overflow tanks and with some screened effluent having to be discharged into Crane Brook. Should CRS7 go ahead, the Sewage works will not be able to cope with the additional effluent generated from an increase in properties.

C) FLOODING:

The field on the site of the proposed development is located in a flood zone and is usually waterlogged for much of the winter. Even if houses were sited above the floodplain, water will run down into it and further impact the discharge of sewage.

As a result of flooding in 2010, raw sewage was discharged into Crane Brook. A number of fish died and the impact of the discharge was observed as far away as Biddenden.

D) AONB & WILDLIFE:

In addition to the already documented Great Crested Newts and Badgers on the site of the proposal, we have personally observed Long Eared Bats (photo enclosed), which has been verified by the UK Bat Care Network.

The agricultural fields adjacent to the Golford Road support a number of wildlife species and should be preserved at all costs. The fields and hedgerows provide a natural barrier and changing this would fundamentally alter the character of this AONB.

E) LISTED BUILDINGS:

There are a number of listed buildings along the Golford Road. The setting of a listed building is an essential part of the building’s character. These buildings contribute to the landscape and their surroundings produce a visual harmony which enriches the setting of the landscape. Development proposals can have an adverse affect on the listed buildings setting, particularly if it affects views, which CRS7 would.

The majority of the homes along the Golford Road are only one storey high. These low impact homesteads are all on the opposite side of the proposed site and are far more suitable for this type of landscape.

PHOTO OF LONG EARED BAT TAKEN IN WOODLAND 10/11/2019: [TWBC: See image attached]

SA_153

Stephen Ward Town Planning and Development for Anglo Beef Processors

Site 145: WA Turner Factory Site, Broadwater Lane, Tunbridge Wells TN2 5RD

This is an objection to the omission of site reference number 145 ‘WA Turner Factory Site, Broadwater Lane, Tunbridge Wells TN2 5RD’ from the draft Local Plan. We request this site is reinstated as an allocated site under Policy AL/RTW 20. As required under Appendix 6 (p.533), please find below reference to the Sustainable Appraisal and relevant SHELAA site assessment sheet.

Sustainability Appraisal – Table 20 of the Sustainability Appraisal (SA) -List of reasonable alternative sites in Royal Tunbridge Wells, records the subject site Ref. 145 as ‘Not allocated’. The scores for Site Ref. 145 is contained at Appendix E, p.167 of the SA.

It is submitted that the Sustainability Appraisal undertaken for site Ref. 145 is flawed. The commentary provided at Appendix E of the Sustainability Appraisal document states “Business Growth score is influenced by uncertainty over existing jobs on the site and the risk to these”. This factory is nearing the end of its life and it is not viable to refurbish the factory in order for it to meet modern manufacturing requirements. This site will not be a future employment generator. A submission was made in November 2013 as part of the review of the Strategic Housing Land Availability Assessment and the site is included in the Site Allocations Local Plan 2016 (Policy AL/RTW 13). This position was reaffirmed in 2016 when it was submitted in the Call for Sites.

While it is acknowledged that sites are not simply allocated on the basis of the most favourable SA score (para. 8.2.2), the SA acknowledges the site as a “reasonable site” and it is submitted that when compared with the adjoining site (Ref. 198) which has been allocated according to Table 20 at Section 8 (AL/RTW 20), it is only the areas of employment and business growth that result in the subject site being scored lower. It is submitted that the above clarification on business growth and employment should bring this site forward for allocation under AL/RTW 20. The WA Turner site is not a strategic employment site.

SA_154

Rosie Ashe

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_155

John Bancroft

Section 8.1 para 8.1.1

Has there been an exhaustive appraisal of all brownfield sites in the Borough?

SA_156

Ian Cooper

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2). Of which we STRONGLY OBJECT to this proposed allocation, please see below rationale and reasoning why Misty Meadow should be disqualified as a proposed site.

Notwithstanding the COVENT that protects this land, which clearly states this land can only be used for Agricultural purposes...

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

A good example of this, is land on the Vineyard was rejected due to concerns over ridgeline views being affected, Misty Meadow is a minimum of 25ft higher than the Vineyard, and the ridge line can be seen from the Wadhurst road and South of Lamberhurst, notwithstanding the public footpaths that would be greatly affected by this proposed development. The proposed development on Misty Meadow is also detached from the LBD/Village envelope, so it’s surprising to see that this site qualified.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough. There are endangered species which use this habit throughout the year, which have not been taken into consideration. They are the Newt and Lesser Spotted Woodpecker.

The proposed allocation of the Furnace Lane site for 30 units of housing will have a significantly harmful impact on the Area of Outstanding Natural Beauty, and with no exceptional circumstances justifying its inclusion. The council should not be making a large housing allocation on the most visible edge of a traditional village. A far better approach would to allow for a series of small developments to be allowed within Lamberhust village. Such developments would be more likely to contribute/reinforce local character, and be more appropriate with regard to their impact on the AONB. Such development could also be promoted through the emerging Lamberhurst Neighbourhood Plan, which could identify suitable smaller sites through consultation with Parish residents.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major negative impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding our objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

We trust that these comments will be taken into account.

SA_157

Franklin Ashe

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_158

Anna Walsh

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_159

Elizabeth Daley

AL/CRS4 and AL/CRS9

The only areas in which this proposed site scores positively are employment, health, equality, housing and resources. Employment is only positive during the build.

Employment:

To say that positive effects on the employment objective are seen across the parishes and sites is disingenuous. Employment cannot be scored positively by building houses away from the targeted employment areas such as RTW1-4, RTW 12-15 and RTW 19

On being questioned, a member of the planning department said that employment was positive because people would be employed building the site. This is short term and the Draft Local Plan is targeting its new employment and businesses to the west of the Borough. People living on this site will use their cars to go to Staplehurst for trains out of the area or use their cars to go to places where there IS employment.

Business Growth

I fail to see how building large scale development out of the town of Cranbrook has a positive score for Business Growth.

Whilst there is no doubt that a certain amount of business already in the town will benefit, targeting new business to the west of Cranbrook necessitating a car journey to business centres, is clearly unsustainable and against any aspiration to reduce a carbon footprint

Climate Change and Energy:

Climate change is the single biggest factor affecting the entire planet and it is to be applauded that the DLP seeks to reduce the impact of development in this respect.

Actions however, speak louder than words and putting major development on the best and most valued green spaces (AONB) and so far from employment areas in Tunbridge Wells and London, is absolutely contradictory to this aspiration.

To say that the most important development management policies for climate change and energy objective are Policies EN 4 and EN 5 is misleading.

A major developer, on being asked to build houses with a smaller carbon footprint and towards ‘Passiv Haus’ standard, stated that they only built to Tunbridge Wells’ requirements.

These fall far short of addressing climate change issues in this respect. There was no intention to use solar energy, or glazing to the best build standards.

Education:

The statement is made that ‘negative cumulative effects are expected within Goudhurst, Hawkhurst, Cranbrook and Sissinghurst parishes.

Why then do ALCRS 1, 2, 3, 5, 6 and 8 score positively for education on Table 29?

Equality

The statement is made that ‘equality is not an issue that is addressed directly by the strategic objectives’

Why then is a positive score for these sites used as part of a justification for development?

Health and Wellbeing

The statement is made that ‘the topic of health and well being is not considered directly by the strategic objectives’

Why then is a positive score for these sites used as part of a justification for development?

Particularly as they score negatively for noise and the destruction of the AONB landscape will contribute very negatively to the health and well being of the existing settlement.

Housing:

Of course ‘highly positive’ scores are recorded for these large scale developments. The EFFECTS can not be described as highly positive as the community has indicated through research conducted by the emerging NDP, that it is AGAINST large scale development in this Parish, described in the DLP as the capital of an area of hursts and dens which by their very nature, are of a smaller scale.

Landscape:

The statement is made that ‘negative scores are recorded for many sites within the AONB with the parishes of Cranbrook and Sissinghurst…………being the worst affected’

In fact EVERY site in the parish (except ALCRS 11 which is Sissinghurst Castle) scores negatively.

The AONB is the most precious landscape, once developed it can never be reinstated.

This plan lacks sensitivity to the landscape in respect of these large scale developments which bear no relation to the character of settlements in this part of the Weald.

Noise

Both these sites score negatively for noise and I fail to see how this can be mitigated.

Travel:

Both these sites score negatively for travel, underscoring the fact that new residents would need to use their cars to access employment centres out of the area.

Yet more reason for not building such large scale developments in this area.

Biodiversity:

The DLP states that the worst effects are expected from allocating the above sites.

Yet there is still a proposal to allocate this land which is highly fragile and greatly valued by the locals. The NDP has been able to demonstrate that housing need, as assessed by an independent consultee, can be met without recourse to devastating these sites.

SA_160

Mrs J A Staines

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_161

Phillip and Maureen Ashford

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_162

Phil Smith

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_163

Joan Burns

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_164

John McNamara
The Old Down Stores

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_165

Ross Wingfield

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_166

Sarah and David Blake

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_167

Julia Goldfinch

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_168

Andrew Chandler

AL/CRS 2

I do not agree that this is a sustainable site. In particular in relation to the Education impact, how can it be appropriate to propose development on a site that is currently used by one school in Cranbrook while allocating a separate site elsewhere within the same parish for use by another school that does not need it (AL/CRS 17)? I suggest this aspect should be rated Slightly Negative. In addition, the current gap in housing along Waterloo Road is an important feature in preserving the landscape characteristic with gaps in settlement. The proposed Local Plan is filling numerous gaps in settlement in Cranbrook and Sissinghurst parish and the cumulative effect of this is appalling.

If development is still thought to be appropriate for this site, it should be clearer in both the Local Plan and the Sustainability Appraisal that the comments and conditions about development relate to the small part of the site along Waterloo Road and no more than this. This should be described as a “PART-SITE”.

SA_169

Sarah Bearfield

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_170

Andrew Chandler

AL/CRS4

I do not agree that this is a sustainable site. I challenge the purported Slightly Positive Business Growth impact in the absence of any related specific requirements for the site in the Local Plan. This will be an isolated settlement, an inconvenient distance from local facilities. It is not clear from your Decision aiding questions (Appendix A) why there would be any business growth benefit when there appear to be no significant factors present. I suggest this should be rated Neutral.

l also challenge the Slightly Positive Equality impact. It is not clear to me what is meant by the comment/limitation in your Decision aiding questions (Appendix A) about “distances of 1 mile or greater were considered inconvenient and scored negatively”, but I would point out that given the extent of this site and the proposed access, most facilities will be well over 1 mile away, even if the supermarket in Cranbrook is within this distance. Doctors, hospitals, primary and secondary schools, the railway station, the library, the leisure centre, etc are all further away. I suggest that this aspect should be rated Neutral.

I see no possible justification for the Slightly Positive / ? rating for Resources. If this refers to suggestion that development on this site may prevent unsustainable demolition and rebuild projects of existing buildings on the site, this should now be changed to Very Negative to recognise that the listed building on this site which originally dated from the 16th Century has now been destroyed in a recent “arson” attack while the currently approved development was taking place.

It is inconsistent to rate the Landscape impact as Slightly Negative when the adjacent site AL/CRS 9 has a Slightly Negative / Negative rating precisely because it is “adjacent to historic farmstead” (AL/CRS 4). This aspect should be rated consistently with AL/CRS 9.

SA_171

Andrew Chandler

AL/CRS6

I do not agree that this is a sustainable site. I challenge the purported Positive Employment impact. It is not clear from your Decision aiding questions (Appendix A) why there would be any employment benefit over and above other sites when there appear to be no significant factors present. I suggest this should be rated Slightly Positive like other sites (although I question more generally whether even a Slightly Positive assessment over-states things given the absence of any long term job creation in the Parish - please see my comments on the cumulative impact assessment for Cranbrook and Sissinghurst).

SA_172

Stephen Farris

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_173

Andrew Chandler

AL/CRS 17

This site is proposed by TWBC to be safeguarded for future expansion of the village school beyond its current location, even though the school has only recently moved to its current site. This has been done without enquiring of the school whether this is likely to be necessary or appropriate in any future scenario. This is a Voluntary Aided primary school and so expansion of the existing school is not a matter than can just be decided by TWBC (or KCC).

It is inappropriate to assess this site as providing a completely theoretical Very Positive benefit in relation to Education for Cranbrook and Sissinghurst Parish, as this distorts the overall Sustainability Appraisal for the entire parish (which, as you note, is “mixed”). Any impact of safeguarding this site would not be felt until long after the current planning timeframe (I’d suggest not even this Century) and as such any benefit for the parish now should not be rated any higher than Neutral.

It is particularly inappropriate to make the assumption that there is a positive impact from safeguarding this site as described in paragraph 8.1.9 of the Sustainability Appraisal, because the assumption about where children will go to school as described in paragraph 8.1.6 (bullet 5) of the Sustainability Appraisal does not apply in this case. As is apparent from KCC’s comments on planning application 19/00308/FULL, they are not anticipating any expansion of the village school within the current planning timeframe, certainly not one that would involve additional land, as they have made clear that they intend to double the size of Cranbrook primary in preference to expanding the school in Sissinghurst.

For Sissinghurst itself, all of the proposed development of the village and surrounding areas that is identified in the draft Local Plan is overwhelmingly negative for its Education impact and the proposed policy for this site must not be viewed as in any way balancing or outweighing that.

SA_174

Andrew Chandler

Section 8 para 8.2 (table 28)

These comments relate to the overall results of the Sustainability Appraisal in relation to Cranbrook and Sissinghurst Parish.

I consider that the cumulative assessment for Cranbrook and Sissinghurst overstates the benefits of the proposed developments in this parish and understates the disadvantages. Cranbrook and Sissinghurst are being asked to take a vastly disproportionate share of development (in the case of Sissinghurst this is on top of extensive recent development imposed on us due to the failings of TWBC’s planning department). This is contrary to the current settlement hierarchy and will forever and irretrievably change the nature of this historic rural parish. As such the overall “mixed” cumulative impacts should instead be recognised as Negative. Specifically:

The cumulative Business Growth impact is stated to be Slightly Positive / Positive, when none of the sites in the Parish is rated this high and even some of those that do have Slightly Positive ratings are overstated (see comments on individual sites). There is no basis provided for anything higher than a Neutral rating. None of the sites actually identified in the draft Local Plan for business growth are anywhere near this parish.

The Education impact is stated to be Slightly Negative but this reflects an assessment where consistently negative impacts across all sites in Sissinghurst are supposedly partly outweighed by the allocation for site AL/CRS 17. See comments on that site, which should not be rated as a positive impact. I suggest that the overall education impact is Negative.

The Employment impact is stated to be Positive but this is a complete fiction. Only one site in the entire parish has such a rating and that is questionable (see comments on AL/CRS 6). There are no proposals in the draft plan to increase employment in any way in Cranbrook and Sissinghurst or the surrounding area (other than associated with construction but that is not a sustainable position). You must recognise that, like most residents of the parish at the moment, most residents from all of the new developments in the parish will need to drive or travel to employment centres such as Tunbridge Wells, Maidstone, Hastings, Ashford or London. This is not a Positive impact for this parish.

SA_175

Jennifer Farris

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_176

Mr & Mrs Kirton

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment.

Examples include:

Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included.
Some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason.
Comments appear to not be applied with equity, some sites seemingly being discounted with statements such as ‘Lack of key services and facilities in the settlement’ and ‘Lack of options for public transport’ which would appear to apply to other sites.
The Strategic Housing and Economic Land Availability Assessment details the Site Assessments for Lamberhurst Parish (July 2019), shows that the average proposed density of housing on each of the sites offered for development was calculated at an average of 12 houses per acre, apart from the two sites (285 and 279) that are now proposed in the Local Plan. These are clear outliers at a density of 1 to 2 houses per acre.

There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner allowing comparable data of the other long list option sites for Lamberhurst Parish.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

The Local Plan identifies that Lamberhurst needs to build ‘50-60 new dwellings’ to achieve the nationally set goal (ref: Page 20 Tunbridge Wells Local Plan) but in the plan only identifies two sites (285 & 279), both of which are identified as potentially accommodating 25-30 new dwellings, meaning that in order to meet the required level of Lamberhurst housing development both sites will be required. As such the consultation in relation to Lamberhurst offers no meaningful option and as such appears to propose a level of predetermination that contravenes the first Gunning Principle. As a Local Plan, it fails to identify how the plan for Lamberhurst can be addressed if one of the two identified sites fails to progress as expected.

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Lamberhurst is a very small traditional village that has developed slowly over time and has just a limited range of services as a result. Developing two large sites, rather than a number of smaller sites will place a disproportionate rate of growth on the village.

The Lamberhurst Neighbourhood Development Plan states ‘ New housing development in Lamberhurst parish has been strictly controlled over many years by various policies in local planning documents produced by TWBC. This is because Lamberhurst is a “lower tier” settlement with relatively fewer facilities and poorer access to public transport and employment opportunities in comparison with larger, more sustainable, settlements in the Borough. In addition, Lamberhurst parish has a number of protective designations in both the village and surrounding countryside, particularly the High Weald AONB. These local planning policies seek to contain most development within “limits to built-development”, as defined in “saved” policy LBD1 of the Tunbridge Wells Local Plan (2006) … This policy aims to prevent the unrestricted sprawl of development beyond towns and villages and to restrict development in the countryside to that required by agriculture, forestry and other uses requiring a rural location. (ref: Page 48 Draft Lamberhurst Neighbourhood Development Plan)

It is noted in the Tunbridge Wells Local Plan, that ‘Minor changes are proposed to the limits of built development at Lamberhurst as set out in the Topic Paper referred to in policy STR 10 above.’ (ref: Page 313 Tunbridge Wells Local Plan).

Development of new dwellings in Lamberhurst has been ‘modest’ (ref: Page 48 Draft Lamberhurst Neighbourhood Development Plan) with an average of 4 new dwellings per year over the last 3 years. Table below extracted from Page 48 Draft Lamberhurst Neighbourhood Development Plan.

Although the Tunbridge Wells Local Plan targets of 50/ 60 new dwellings, over the lifetime of the local plan average 4.6 new dwellings per year. The fact that these are proposed to be in two large sites, will by all reasonable assumptions be built over a concentrated timeframe by developers at each site. This could mean that at best, if the two development sites were staggered, that the average increase in new dwellings could be 15 in one year, an increase of 320% on previous years rates of growth.

Period

2006-2011

(5 year period)

2011-2016

(5 year period)

2016-2019

(3 year period)

TW Local Plan proposed level of new dwellings

2020-2033

(13 year period)

Dwelling completed

Annual average completions

1.4

4.6

This will have an impact on the limited range/capacity of services but are not reflected in the assessment of sites set out in either the SHLAA or the Sustainability Appraisal. These are summarised below:

Shops: There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

As noted above [TWBC: see Comment No. DLP_7828 Policy STR 1], there are concerns regarding the Council’s general strategy for housing (pushing substantial housing quotas onto small villages that do not have the requisite infrastructure to avoid private car journeys) and Lamberhurst as a location for 60 new dwellings. Such concerns are amplified with regard to the Furnace Lane site.

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site, on a ridge, will be visible to traffic passing north bound from Wadhurst to Lamberhurst on the B2100, on their approach to the village the road looks up to views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.

The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

It is not clear how this will be a viable option, given that the farm infrastructure will have been removed in order to create a viable housing development site

The Strategic Housing and Economic Land Availability Assessment details the Site Assessments for Lamberhurst Parish (July 2019) and for site ref number 285, Misty Meadows , Page 317 it sets out requirements for the site 285, for residential development (C3). It proposes that there is ‘Single point of access using existing track’. The land that this track runs over is owned by a number of different owners and not the sole ownership of the land owners of Misty Meadows Farm.

In addition, the ‘Provision of adequate visibility splays’ will require land on either side of the existing track, which is owned by a number of neighbouring households. There is also a natural pond on land required for visibility splays and on occasion this results in surface water to the B2169, Furnace Lane. The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1), in two large sites, will have a disproportionate impact and cannot be supported by existing infrastructure as a slower growth rate of a greater number of smaller sites within the village centre, reducing reliance on car journey for daily local trips to schools and shop.

We trust that these comments will be taken into account.

SA_177

Dr Katherine Eden-Green

Lamberhurst Policy AL/LA 2

I write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Using the scoring matrix from the Local Plan I object to the proposals based on the following reasons:

Land use

There is a covenant on the larger of the two fields which restricts development. The covenant number is K575382. The land is currently designated for agricultural use only
By changing the agricultural land it would have a significant impact on the landscape and the hill top pattern
The site is firmly within the High Weald AONB who also opposes the proposal.
The AONB which is a statutory document, outlines a number of objectives which are contradicted by this proposal including:
- AONB objective FH4 to protect the archaeology and historic assets of field and health
- Objective FH2 to maintain the pattern of small irregularly shaped fields bounded by hedgerows and woodlands which characterises the High Weald AONB
- The fields and boundaries are rare survivals of a medieval landscape
- Objective LBE1 to resist the removal of agricultural occupancy conditions
A key issue identified by the AONB is the reduction of livestock grazing, leading to a loss of farm infrastructure and degradation of pasture and soil. The Misty Meadow site is currently used for livestock grazing.
One to the top issues for the AONB is the loss of green fields to development

Landscape

The proposed site is on a ridge line and so would be visible for some distance. Certainly most houses in the village would be affected in some way
A key characteristic of the AONB is the distinctive settlement pattern with dwellings built along ridge roads such as Furnace Lane. The High Weald AONB identifies a key issue where the layout and design of developments fail to respond to the AONB which is the case with this proposal. Organisations MUST fulfil their Section 85 duty to have regard to the purpose of conserving and enhancing the AONB. These proposals do not demonstrate that regard
Objective OQ4 in the AONB management plan is to protect and promote the perceptual qualities that people value
I have significant concerns about the ability to provide an appropriate means of access onto the B2169

Heritage

The development of housing behind an existing row of single dwellings along a key road is in direct conflict with the Settlement pattern as outlined by the AONB management plan which is a statutory document.
The plans would affect a significant number of listed buildings associated with the site including some pre 1750 dwellings

Climate change

Residents in this plan would have to drive into the village. Although many of these vehicle journeys would be short in duration they would be frequent. As such the carbon emissions associated with 30 householders would soon add up. Even when allowing for the rural context of the site, where opportunities to maximise sustainable transport will be inherently more limited than in urban areas, the site is not well placed with relatively easy access to services and facilities. I am aware of a case in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) where a site was rejected on these grounds
This impact would diminish as combustion engines are phased out and replaced by ultra-low emission and electric vehicles. Nevertheless, the houses, if approved, are likely to be constructed in the short term and therefore it is unlikely that the majority of future occupants would use these vehicles. Accordingly, this cannot be relied upon as a means of mitigating the inaccessible location of the site in the short to medium term. In any event, regardless of whatever vehicle is used by future occupants, the challenging accessibility of the site to services and facilities would not promote the social and health benefits conducive with safe and convenient opportunities for walking and cycling.
The increased lighting and noise is an issue to be taken into consideration. The AONB management plan which is a statutory document states clearly the importance of dark skies and dark qualities. This part of the village is not currently well lit so these proposals would change the light pollution dramatically

Biodiversity

The impact of additional cars on the B2169 to Hook Green and on to Tunbridge Wells will be significant and raises concerns about the impact on wildlife
Clay Hill Road is a cross country route which residents at Misty Meadow will use to get to the A21. This road has designated Roadside Nature Reserves which have been specially designated as a habitat at risk. Roadside Nature Reserves are home to rare or notable species and can serve as a link for wildlife enabling plants and animals to flourish. The additional traffic on Clay Hill Road would place these Nature Reserves at risk
The plans do not propose a net gain in biodiversity

Travel

Of the 8 sites identified in the Local Plan, 7 of them were discounted based on the distance from the village and the lack of public transport options. The Misty Meadow site is the furthest site from the village of all the 8 sites considered. We would like to draw attention to the scoring matrix on page 207 of the Local Plan.
The site is too far for the average homeowner to walk to the local amenities such as the shop and the school. This will generate a number of short vehicle trips into the village which would occur frequently due to the absence of a safe alternative means of travel.
I am aware of a recent planning submission in Tunbridge Wells (Appeal Ref: APP/M2270/W/18/3215766) in which an appeal was dismissed on the grounds of the inherently car-dependent nature of the location, particularly with regard to access to employment. This case was based on 8 houses whereas Misty Meadow will host 30 houses meaning the travel impact will be much greater than in this case which was turned down. We believe this sets a legal precedent.
The plans propose a single access road into the site and would have to be upgraded to serve 30 houses including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lane, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
The access is not solely within the Misty Meadow plot and affects land boundaries of more than 3 properties.
The impact of additional vehicles travelling on the already busy and dangerous B2169 raises concerns about safety. School buses regularly drop school children off on the verges of this road, which doesn’t have pavement risking danger to life.
New residents are likely to commute to London using the already overcrowded facilities at Bells Yew Green (Frant) station. The community at Bells Yew Green already has challenges with station users parking in the village and causing blockages on the roads. The car park is already at full capacity every day at Bells Yew Green
The AONB management plan Objective G3 states that developments must support travel alternatives but this site does not meet that requirement

Services & Facilities

There are no additional services or facilities planned to support this development
The site is challenging and not accessible to services and amenities
The village school is at capacity and would not be able to house the additional children from 30 houses
The village nursery reports being at full capacity with long waiting lists for prospective children
UK Power networks report 6 known power outages since July 2019 in the immediate area around Misty Meadow. All the houses in the area were without power for several hours as recent as 26^th October 2019 requiring immediate works as advised by Chris Smith at Avidety Ltd on behalf of UK Power Networks
There is no mains gas supply to the village of Lamberhurst meaning the dependence on a reliable electricity service is more important
The TWBC Local Plan identifies a need for children play areas but the nearest playground is over a mile away

Business Growth

There are no benefits to business growth in this proposal

Deprivation

There is a recognised need for affordable housing within the Village but there are no details about how this site will address that need.
All residents would require a car as the site is too far away from the village and the site is let down by poor public transport links

Noise

Naturally the levels of noise will increase in what is a very quiet part of the village. Because this development is on a ridge line, the sound (and light) will carry down into the village too

Resources

There are no plans to improve resources in this proposal

Water

The site is already very water logged. The development of an additional 30 houses raises concerns about the impact of surface water on the existing dwellings
The draft plan identifies this area as a Groundwater Source Protection Zone
The AONB Management plan which is a statutory document states in Objective G1 to avoid development close to water courses. The proposed site is adjacent to multiple water courses

Health

The Primary Healthcare / GP Practise in Lamberhurst is a major concern. The Infrastructure Plan proposes a cluster area based in Horsmonden and covering Horsmonden, Lamberhurst, Matfield, Brenchley and Goudhurst. This is not an acceptable solution

Air

The aim of Air Quality Management Areas (AQMA) Policy EN 24 is to improve and maintain levels of air pollutants in Air Quality Management Areas (AQMA) and surrounds. The area currently registers as “low “, any development will impact this

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

I trust that you will take the aforementioned concerns into consideration,

SA_178

Daniel and Amelia York

Lamberhurst (Policy STR/LA 1 and AL/PE 2

Draft Local Plan and Sustainability Appraisal - Additional dwellings in Lamberhurst

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.
Given such low support for forms of dispersed growth, it is surprising that the Council has chosen to propose relatively high levels of new housing in small villages such as Lamberhurst. For the Council to be able to demonstrate that it has reacted appropriately to the consultation feedback, a far greater emphasis on growth in established centres would be required. Not only would this more closely reflect the feedback from local residents, but also would result in more sustainable patterns of development that would have less reliance on the private motor car as a means of travel – which surely must be of paramount importance given climate change commitments.
With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then other comparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

The Furnace Lane site is located on a ridge and so is prominent in views from within the Area of Outstanding Natural Beauty, including nearby footpaths. The site will be viewed in the foreground of views towards the traditional built areas of the village, and so will have a disproportionately harmful impact on the character and appearance of the AONB.
The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.
The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.
Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:
“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).
In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurstand significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account.

SA_179

Mrs J H Fox

Policy AL/LA 2 Misty Meadow, Furnace Lane, Lamberhurst

My interest is as a walker of the footpaths in the Lamberhurst area and as a relative of a resident in Furnace Lane. It can be very uplifting and therapeutic to walk down one of the local footpaths in the Furnace Lane area, and in just a few minutes one can experience being in a ‘different place’ in the country. Currently the area has some farming and the old stone cottages on the ridge, the proposed Furnace Lane site would be located on the ridge and would detract from views of the Area of Outstanding Natural Beauty, including from nearby footpaths, and would have a harmful impact on the character and appearance of the AONB.

The village of Lamberhurst has developed slowly over time and has limited facilities. The nursery school is oversubscribed and the primary school has only a few spaces. There is one small shop in the village with a very limited range. There are only five buses a day to Tunbridge Wells and these are busy at school times.

Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by the existing infrastructure and will be heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

The proposed allocation of 30 houses on Furnace Lane (Policy AL/LA2) will have a major impact on the appearance of the AONB, with no exceptional circumstances to justify such an allocation in such a highly visible location. Development would naturally be suburban in appearance (including vehicular access arrangements) that would detract from the rural character of the village. This would be exacerbated by the site’s location away from the centre of the village. A far better approach (and notwithstanding my objection to 60 houses being proposed for the village) would be to provide for windfall development within the village, and for the emerging Neighbourhood Plan to identify smaller sites for more appropriately scaled schemes that would respect the AONB.

I trust that these comments will be taken into account.

SA_180

Barry Chamberlain

Site 52: Land at Streatley, Horns Road, Hawkhurst

Our comments on the Sustainability Appraisal (SA) are made within the context and scope of the following Site (Site Ref. 52 - Land and property at Streatley, Horns Road, Hawkhurst, hereafter referred to as the ‘Site’) which has been assessed within the Sustainability Appraisal (as accompanying the Draft Local Plan) on the basis of it being a “reasonable alternative”.

The assessment within the SA (page 188) sets a review of the performance of the site against the identified Local Plan objectives.

We note that the Site has been summarised in the SA as follows:

“This site scores mostly neutral with a positive benefit in terms of housing provision. It scores negatively in landscape and land use terms being the loss of a greenfield site in the AONB. It is further removed than some sites to a lack of key services and facilities and public transport options.” (Page 188, Site 52).

As set out and explained in the accompanying Draft Local Plan Response Form, the Site is currently subject to a planning application (19/02619/OUT) that is pending determination for 20no. dwellings together with landscape enhancements and a new access. The technical and environmental reports prepared to support this application, have where relevant been referenced to inform our analysis of the site’s assessment in the SA.

The following commentary covers the Performance Indicators we consider require representation and review:

Climate Change:

It is unclear why the Site has scored ‘?/-‘ against this objective. The pending planning application has demonstrated that development at this Site is capable of viably accommodating energy efficient new homes designed to ‘lifetime homes’ standards. Moreover, the scheme has confirmed that each home could be provided with electric vehicle charging points, thereby encouraging users of the Site to use low carbon or zero carbon vehicles for their journeys, helping to reduce the overall emissions generated and supporting renewable energy use. It is therefore considered that the score for the Site against the Climate Change objective should be revised and amended to ‘neutral’ at the very least.

Education:

We are unclear why the Site scored ‘neutral’ with regards to ‘Education’ in the SA, when other comparable Site scored positively.

The measure against ‘education’ is largely centred around local circumstances in terms of places at the nearest primary school and the scale of potential residential development. The promotion of housing on the Site would be for a relatively low quantum of development, ranging between 20-40 units, accordingly this would have little impact on the capacity of existing education facilities, generating 5 additional primary school places (as confirmed by KCC in the current pending application). In respect of education, there is a proposed Hawkhurst Primary School expansion (1 Form Entry), to increase the education provision and number of local school places within Hawkhurst. As demonstrated by the current planning application (Ref: 19/02619/OUT), development on this Site for a minimum of 20no. dwellings (including a range of typologies) would generate in excess of £54,000 (as set out by KCC) towards the identified school expansion and consequently support the increased expansion of local education facilities and number of school places.

Furthermore, the proposal would make a contribution of £5,000 per dwelling towards an identified new Community Hall, as identified in the Hawkhurst Neighbourhood Plan 2018, which could potentially help to serve and facilitate adult education provision/classes for residents in the locality. This measure would potentially help to support and encourage adult and extra-curricular education, which should be considered positively. Finally, the scheme for 20no. dwellings on this Site would make a contribution in excess of £8,000 towards the Cranbrook Community Hub, as identified and required by KCC, which would support increased demand and help facilitate extra provision for libraries and Adult learning within the locality.

In light of the above, we consider the proposal demonstrates that development on this Site for at least 20no. dwellings, based on the known contributions captured towards an identified school expansion, would score a ‘slightly positive’ grading in ‘Education’ terms and should accordingly be reviewed.

Heritage:

The SA scored the Site as ‘-‘ in respect of ‘Heritage’. However, the abovementioned pending planning application is supported by a Heritage Statement (Prepared by Consilium – June 2019) which confirms the way in which the site can accommodate 20no. dwellings with no harm to any heritage assets in respect of the Conservation Area or Listed Buildings.

In respect of the previous application (Ref: 17/02980/OUT) on the Site for 40no. dwellings, the accompanying Heritage Statement (Prepared by Consilium – June 2018) confirmed that the proposed would result in ‘less than substantial harm’ to The Moor Conservation Area and no harm to Listed Buildings Considering this, we consider the negative score for the Site for development between 20 and 40 dwellings should be neutral to slightly negative ‘0/-‘ .

Land Use:

We disagree with the ‘- -’ score for the Site against the SA ‘Land Use’ objective to protect soils, and re-use previously developed land and buildings.

As firstly, as demonstrated by the pending planning application (Ref: 19/02619/OUT) in its design and layout, the Site is capable of retaining a reasonable amount of greenfield land, which can then be secured and provide landscape enhancements to the AONB and Countryside. Development on this site for a range of 20-40no. dwellings would, even at the upper limit of this quantum, still retain greenfield land (including a wildflower meadow and green links) and limit the scale of greenfield land lost.

In respect of soils and agricultural land, as confirmed by the accompanying Agricultural Classification Report (Vaughan Redfern – March 2017) submitted in support of the pending planning application (Ref: 19/02619/OUT), the Site is of a subgrade ‘3b’ quality and of low agricultural value and consequently its loss would be limited.

Moreover, it should be acknowledged in the scoring that the small size and scale of the Site and its adjoining location to the village, is not attractive or practical for modern or larger scale farming, in respect of either arable production or livestock. Consequently, the land has effectively become a ‘redundant’ Greenfield Site, where its loss would accordingly be limited.

In light of this, we consider the scoring in respect of the ‘Land Use’ should be improved to a minimum of slightly ‘-‘ negative.

Landscape:

We disagree with the ‘- -’ score against the ‘Landscape’ objective attributed for the Site in the SA.

In this respect, a detailed Landscape & Visual Impact Assessment (LVIA) has been submitted as part of the abovementioned pending planning application (Ref: 19/02619/OUT), which concluded that the scheme for 20 new homes as proposed was capable of being accommodated at the site in a way that ensured the overall effect of the proposed development would not cause ‘significant harm’ to landscape character or visual amenity. Moreover, that the overall effect of that proposal upon the High Weald AONB would be low and not harmful to the wider AONB designation.

We therefore consider that the scoring for the Site in the SA is unreasonably negative and consider that it should be reviewed accordingly.

Notwithstanding the above, we note that a negative score against the landscape objective does not preclude a site from allocation. This factor is evident at the proposed allocation at Hawkhurst Golf Club (AL/HA1) which has been scored “Negative/Very Negative” against the landscape objective (a worse grading than the Site), as well as proposed allocations AL/HA, AL/HA 6 and AL/HA 8-10, which all score ‘slightly negative’ against the landscape objective.

Health:

We disagree with the SA scoring of ‘neutral’ against the Health objective. As demonstrated by the pending planning application (Ref: 19/02619/OUT), the Site is capable of delivering a mix of typologies including bungalows to meet the wider local needs for older residents and homes designed to Lifetimes Homes (Part M4/2) to ensure they remain accessible throughout the lifetime of the occupants to meet any changes in the occupant’s requirements/circumstances.

Moreover, the proposals include a significant provision of a high quality landscaped open space, opening up what is currently an inaccessible private field and encouraging walking and recreation, of benefit to the health and wellbeing of the local community.

In light of this, we consider the proposal demonstrates that development on this Site has the potential to score positively with regard to ‘Health’ and should accordingly be reviewed.

Services & Facilities:

We disagree with the SA’s scoring of the site against the Services and Facilities objective and consider that it has been unreasonably negatively scored. We consider that the Site should be scored more positively to neutral at the very least, and arguably neutral positive/ positive, taking into account the following factors:

The Site is located in acceptable walking distance to the centre of The Moor, where there is an established footpath link into the centre, which includes a church, a Public House, nursery, a part time post office and recreation facilities.
The site is located approximately 1.5km to the south-west of the centre of Hawkhurst. This equates to an 18-minute walk time at an average speed of 80 metres per minute, a figure that is used as the basis of the London Based Public Transport Accessibility Level (PTAL) analysis. It is noted in this respect that the walking route to the centre of the village is provided with continuous footways which are subject to natural surveillance and street lighting. A number of local services and facilities are therefore available within an acceptable walking distance. These include, but are not limited to, a supermarket, a primary school and a doctor’s surgery.
Furthermore, the Local Plan earmarks further infrastructure provision to Hawkhurst including a new medical centre, new community centre, expansion of primary school, as well as other infrastructure set out in the Infrastructure Delivery Plan. To this extent, as confirmed by the abovementioned current pending planning application (Ref: 19/02619/OUT), development on this Site could secure a contribution of £100,000 towards the delivery and enablement of a planned ‘New Community Hall’. The New Community Hall is identified within the Hawkhurst Neighbourhood Plan 2018, as an essential ‘Community Infrastructure’ for the village (Policy CM2). The contributions would make a significant payment towards the build costs and delivery of the required building. Such a provision would result in a significant enhancement for community facilities within Hawkhurst, enabled and captured by development of the subject Site. Furthermore, the provision and support of contributions towards a much-needed new Community Hall, would facilitate the scope and opportunity for a ‘community shop’ and potentially a ‘visiting post office’ within the facility. The provision of a ‘community shop’ will offer future residents of the Site and in The Moor to basic essentials and services, without the need to travel to the centre of Hawkhurst. Once delivered the Site’s access to a wide range of services and facilities will plainly be enhanced.
In accordance with the SA objective’s comments at Table 76 at Appendix A of the SA, the Site benefits from access to a ‘frequent’ bus service, which we note is defined in the SA as an ‘hourly Monday to Saturday’ service. The bus services available from the Site from bus stops in proximity to it, includes the hourly 304 and 305 service and routes 254 and 255. Collectively these routes provide direct access to the centre of Hawkhurst, as well as to a range of other towns and villages in West Kent and East Sussex. Notably, Routes 304/305 provide an hourly weekday and Saturday service between Hawkhurst and Hastings via Hurst Green and Battle, as well as onto Tunbridge Wells (via Hawkhurst - without needing to change buses), that can be used by future residents of the proposed development to access employment, education, retail and leisure facilities in these settlements, as well as onward train services to London via Tunbridge Wells. Additionally, Route 254 provides an early morning service to Tunbridge Wells that is well suited for commuters and school pupils.

Travel:

We disagree with the Site’s ‘-‘ negative rating. As explained above, in accordance with the SA objective’s comments at Table 76 at Appendix A of the SA, the Site benefits from access to a ‘frequent’ bus service, which we note is defined in the SA as an ‘hourly Monday to Saturday’ service.

The bus services available from the bus stops located in proximity to the Site include the hourly 304 and 305 service and routes 254 and 255. Collectively these routes provide direct access to the centre of Hawkhurst, as well as to a range of other towns and villages in West Kent and East Sussex. Notably, Routes 304/305 provide an hourly weekday service from Horns Road between Hawkhurst and Hastings via Hurst Green and Battle, and a direct (Same bus with no changes required in Hawkhurst – via Bus Route 254) to Tunbridge Wells on Mondays to Saturdays that can be used by future residents of the proposed development to access employment, education, retail and leisure facilities in these settlements, as well as onward train services to London via Tunbridge Wells. Additionally, Route 254 provides an early morning service to Tunbridge Wells that is well suited for commuters and school pupils.

As demonstrated by the pending planning application (Ref: 19/02619/OUT), the Site is capable of delivering a mix of typologies, including bungalows to meet the wider local needs for older persons and affordable homes. It is considered that the type and size of housing that could be accommodated on the site, would lend themselves to young families and older persons, who would be likely to use the public transport services available.

In addition, the future residents would be offered Bus Vouchers and provided with a Travel Pack, in order to further incentivise the use of local bus services. To this extent, it is considered that the proposed development would likely result in increased patronage of the Bus Service, which would support the Travel objective to retain the viability of this rural bus service.

Considering the above, we consider the Site should be scored more positively against this objective and is capable of achieving at least a ‘0/-‘ score and arguably a neutral score.

Water:

The Site scored ‘neutral’ against the ‘Water’ objective in the SA to manage the flood risk and conserve, protect and enhance water resources. In this regard, the Site is located in Flood Zone 1 (i.e.. at low risk of flooding). It is noted that the Environment Agency has raised no objection to the current planning application (Ref: 19/02619/OUT), which in the Flood Risk Assessment and Drainage strategy submitted in support of this application, confirms that the Site is capable of being developed in way that would ensure that development on this Site can positively manage the impacts of flooding, close to its original source and would not exacerbate any flood risk on or off site.

Moreover, the new homes at the Site could be delivered to include measures to reduce water consumption rates. We therefore consider that the Site is capable of scoring a more positive ‘0/+’ rating.

Conclusion

In light of the above, we consider that the scoring of the Site in the SA as an ‘Alternative Site’ should be reviewed, as we have highlighted that the Site is capable of scoring more positively against the SA objectives than has currently been identified.

In this context, we highlight that our representation to the Draft Local Plan has suggested that the Council should be seeking to allocate additional sites, including this Site, for housing, in order to ensure that it better addresses the shortage against “uncapped need”/ affordable housing need, as well as accommodating unmet need from neighbouring authorities. Given our comments on the SA above, we consider that this Site can make a valuable and sustainable contribution towards housing supply in the Borough in the short term.

[TWBC: see site location plan attached].

SA_181

Wendy Owen

Site 137

This submission is made primarily in respect of site 137 but its content relates additionally to sites:

30 (with 100, 199 & 205) Land at Caenwood Farm & Whitegates Farm Reynolds Lane;
73 Land at Pembury Road South;
99 Land at Pembury Road;
114 Land at Sandown Park west of A21;
116 Land South of Pembury Road;
146 Tunbridge Wells golf club Langton Road;
280 Land at The Midway Nevill Court;
384 Land at Great Bayhall;
411 Land at Sandown Park between Pembury Grange & A21;
434 Tutty’s Farm Hawkenbury; &
459 (with 23, 111, 214, 326, 333, 341, 383 & additional land [300 & 65?]) Land at Kipping’s Cross.

We wish to challenge the ‘unsuitable’ decisions for the sites listed above, either because the sustainability scores are inconsistent (sites 30, 73, 99, 114, 116, 146, 411 and 434) or because no sustainability assessment was even completed (sites 280, 384 and 459). At least some of these sites are suitable for a school and therefore site 137 cannot be considered exceptional.

We wish to challenge the content and conclusions contained within the Sustainability Appraisal for Draft Local Plan (Regulation 18), which as a consequence, we consider will change the ‘suitable’ conclusion contained in the SHELAA in respect of site 137 / AL/RTW 18 to ‘unsuitable’.

We consider many of the scores in the sustainability appraisal understate the negative impact of the development of site 137. In addition, we do not consider the appraisal has been consistently carried out when compared to sites in similar positions with a similar level of sensitivity. On reading the detail, some other sites appear to have been appraised as unsuitable because a developer is no longer interested in the site (e.g. 459), whereas site 137 is considered suitable because a developer is still interested. This is not an appropriate way to develop a plan of this magnitude and developer interest should not be a contributory factor to making the case for exceptional circumstances required to release Green Belt or to develop on AONB designated land.

We attach a spreadsheet (below) which compares the sustainability objective scores and issues to consider across a selection of sites which TWBC has deemed unsuitable. As you can see from the spreadsheet, there are number of unexplainable inconsistencies. In particular we would draw your attention to the scores for:

Air: It is not clear how this score has been arrived at for site 137. “Air quality is scored as negative overall because of the large size of the development and likelihood that new vehicles will utilise the A26 as a through route”. “There is also a need to meet nitrogen dioxide reduction targets along the A26 in Royal Tunbridge Wells, which is identified as an Air Quality Management Area.” We can see no reason why the score should not be --/--- as per site 30 (“the substantial use of private vehicles in this location causes the noise and air objectives to score very negatively”).
Biodiversity: It is not at all clear why site 146 has scored so much worse than site 137. Even though site 137 is technically undesignated, the presence of protected species such as bats, dormice, adders and great crested newts should increase the negative score. The draft plan makes reference to site 137 being a Biodiversity Opportunity Area. The site provides wildlife corridors between Hargate Forest, Friezland Wood & Broadwater Warren. In addition, the site is only just outside the Ashdown forest 7km protection zone and we would expect a proper impact assessment to be carried out given the negative air quality score, as to our knowledge NO2 does not respect lines drawn on maps.
Education/Employment/Equality: It would appear these all score very positively compared to other sites because of the proposed siting of a secondary school. Other sites in the attached spreadsheet were also assessed for schools (sites 30, 73 & 146; 384 & 459 (mixed use) were omitted from appraisal) but they have not been scored anywhere near as positively. These scores should be reviewed and made consistent. Site 146 should also be considered alongside RTW9 (Lifestyle Motor Europe) which neighbours it & could be developed together, providing more flexibility.
Heritage: this score is too low and does not adequately take account of the Scheduled Monument (Historic England) that is in part in the site, along with other heritage constraints (listed buildings and historic farmstead). It is not clear why site 99 scores --/---.
Housing: the appraisals contain errors. With the exception of site 280, all sites listed here should be scored +++ as >150 dwellings are possible.
Land use: the land is ALC Grade 3a and 3b and therefore subject to the greatest level of protection under the “Best and Most Versatile” rules; as such it should be scored as - - - . Site 146 is already developed (it’s a golf course) so should score 0 or maybe - as loss of green space.
Landscape: Given the site is high value Green belt, in the AONB and is so visually prominent, it should be scored consistently with other sites (30, 99 & 116) at - - -
Noise: Sites 137, 30 & 146 are impacted by the Gatwick flight path to a similar extent. The A26 (site 137) currently gets 23496 motor vehicles per day; the A264 (site 146) currently gets 9034 motor vehicles per day. No data for Reynolds Lane (site 30). Site 137 should score --- or --/---. Site 30 should score much more favourably given its likely current traffic volume. Site 146 should score somewhere in between.
Services and facilities: It is not clear why this has been scored more positively than sites 30 and 146; all are similar distances to the town centre and housing (with site 30 close to a school and sports centre) so they should be scored consistently.
Travel: It is not clear why this has been scored so positively in comparison to sites 30, 73 & 146 (& 99). The site is on the borough/county boundary. Increased traffic is acknowledged, as is the borough’s low bus usage, and the existing cycle lanes on other sites are listed as issues not positive factors in relation to active travel. Site 146 is on the A264 which gets 62% less traffic (9034 vehicles per day) than the A26 (23496 vehicles per day). Development here would give a fairer distribution of traffic and less congestion; this should score ++. Site 146 also has good existing access as it’s to a golf course. There is some overlap here with services and facilities.

We also challenge why sites were omitted from the sustainability appraisal – surely the purpose of the appraisal process is to fully consider the positives and negatives, in a structured and documented way. Sites 459 and 384 are noted as “within the AONB and landscape impacts were considered too severe to warrant consideration”; can the same not be said for the sites we have listed here? We can find no mention of site 280; why was there no appraisal of this site?

On further detailed examination of the sample of sites we have used for comparison purposes, we note all are listed as being in the High Weald AONB. However, based on the maps available on the High Weald AONB website and as confirmed by the HW AONB team the following sites are within the TW conurbation and are NOT in the AONB - sites: 30, 99, 114, 146, 280, 411 and 434. That being the case, these sites previously rejected must be considered ahead of site 137 / AL/RTW 18 in order to comply with the NPPF.

We would also like to make the following factual corrections to the SHELAA for site 137 / AL/RTW 18. Firstly, the size of the site is not 55.79 ha; c.15 ha is available in the borough (with the remaining area in Wealden (with no defined boundary on the site) which has deemed it unsuitable for development). The ‘issues to consider’ section incorrectly grades the land as ALC Grade 4, Urban, when in fact the land is agricultural grade 3a and 3b – an assart field which is actively farmed. The heritage matters should more accurately record that the site includes part of a Scheduled Monument with archaeological potential (which further reduces the developable area). It is also adjacent to listed buildings and a historic farmstead. The site includes and is adjacent to ancient woodland.

We consider that any objective assessment of the site with the corrections we have highlighted, coupled with the appropriate sustainability scores as set out in the attached spreadsheet, will result in the SHELAA assessment concluding the site is unsuitable.

Furthermore, the spreadsheet we have included shows a small selection of sites with reasonable scale which have been excluded. While all of these sites appear to have been excluded at least in part because they are in the AONB/Greenbelt (which we are querying), they appear to be no more sensitive to development than site 137 / AL/RTW 18 and in some cases, as we have demonstrated, have fewer constraints. That being the case we consider that TWBC has failed in its duty to carry out an objective and thorough assessment and failed to demonstrate that all other sites have been exhausted before including site 137 / AL/RTW 18 in the Draft Local Plan (Regulation 18) and as such has not met the requirements of the NPPF.

Site 137 does not meet the sustainability requirements and is therefore unsuitable for development.

General comment

The Sustainability Appraisal of the Draft Local Plan states “To make meaningful progress towards a more sustainable way of living, it is essential that Local Plans are developed with a detailed consideration of sustainability issues from the outset. This is the purpose of a Sustainability Appraisal (SA). The process is a legal requirement under the Planning and Compulsory Purchase Act 2004…”

Table 8. Compatibility testing of Local Plan objectives with Sustainability Appraisal objectives.

[TWBC: for Table 8, see full representation attached].

This table gives a misleadingly positive view of the compatibility of the local plan objectives with the sustainability appraisal objectives. For example, development needs will almost certainly be incompatible with heritage, landscape and noise; it is not obvious why climate change would have a positive relationship with employment and business growth. The compatibility test should be revisited. Given the significant deficiencies in preparing this compatibility test, we consider the sustainability appraisal does not meet the legal requirements.

SA_182

Ashley Saunders

Sustainability Appraisal

Section, paragraph number(s), or site (including page number)	Comment
Non-Technical Summary p.2	“Both of these concepts would involve some loss of Green Belt land” – “some” is understated. 600 acres will be lost and adjoining AONB will be harmed by the associated transport infrastructure.
Non-Technical Summary p.2-3	“The environmental objectives were found to produce either highly mixed, neutral or negative scores” – the scores are overwhelmingly negative in the strategic sites.
Non-Technical Summary p.3	“Tudeley village was the only reasonable location for a new settlement” – there are no published assessments for alternative locations such as Horsmonden site 144; so, this is an assertion rather than something clearly based on evidence. “Paddock Wood was the only reasonable location for an extension […] but with land take in the Green Belt to the west of Paddock Wood, would provide a suitable scale of extension with benefits for the economic, environmental and social elements of sustainability” – even on your evidence, environmental and social elements are negatively impacted compared with the non-Green Belt options.
Non-Technical Summary p.4	“a cumulative impact assessment was undertaken for each parish or settlement location” – Table 25 (Chapter 8, page 67), contains the assessment scores for Capel Parish but lacks detail and underplays the local impact. The scores for AL/CA1, TP6 and AL/CA3 appear to be totally fabricated and bear to relation to the evidence base. Further comments can be found in the relevant section below.
Chapter 1: Introduction – Purpose of this Report para 1.3.1 p.13	“The report was then updated to take into account consultees’ comments and a final version prepared in October 2016. The Stage A Scoping Report should be referred to for a description of the original baseline, relevant plans, policies and programmes and the justification for the sustainability objectives that are being implemented in this report.”
Chapter 4: Methodology – Updates to baseline data para 4.1.2 and Table 2 p.20-21	“Table 2 below provides a list of additional relevant evidence studies that became available for consideration during Stage B following publication of the Issues and Options Sustainability Appraisal in July 2017.” Evidence studies outlined in Table 2 include; Green Belt Study (Stage 2); Historic Landscape Characterisation and; Historic Environment Review. Capel parish council was not consulted or made aware of these studies at the time they were done. Therefore, the local community had no opportunity to contribute. Table 2 also refers to a Landscape Sensitivity Assessment (RTW, Paddock Wood, Horsmonden, Hawkhurst and Cranbrook) completed during Spring 2017 and July 2018 but the assessment did not include Capel where 4000+ houses are proposed to be built on the Green Belt – why?
Chapter 4: Methodology – Updates to Plans, Policies and Programmes para 4.2.1 and Table 4 p.22-24	Table 4 refers to the KCC Draft Minerals and Waste Local Plan but incorrectly states that “Sites at Moat Farm and Stone Castle, Five Oak Green are adjacent to the boundary with TWB”. Both Moat Farm and the entrance to and part of Stone Castle are within TWB and adjacent to the proposed site in Tudeley STR/CA 1.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method Table 6 p.26	The Sustainability Objectives for Tunbridge Wells Borough are outlined in Table 6 and include the following: No. 1 “Reduce air pollution” No. 2 “Protect and enhance biodiversity and the natural environment” No. 4 “Reduce carbon footprint and adapt to predicted changes” No. 10 “Preserve and enhance historical and cultural heritage assets” No. 12 “Protect soils, and reuse previously developed land and buildings” No. 13 “Protect and enhance landscape and townscape” No. 14 “Reduce noise pollution” No. 15 “Reduce the impact of resource consumption” No. 17 “Improve travel choice and reduce the need to travel by private vehicle” No. 18 “Reduce waste generation and disposal” No. 19 “Manage flood risk and conserve, protect and enhance water resources” Policies AL/CA 1, AL/CA 2, AL/CA 3 & AL/PW 1 and TP6, are incompatible with all of the above objectives and therefore should be removed from the Draft Local Plan. Objective No. 4 in particular reflects the resolution made by Tunbridge Wells Borough Council on 17 July 2019 in which it recognised “that it has a responsibility to take a firm lead on reducing the council’s and the wider borough’s carbon emissions” and resolved to “Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030.” Not only are Policies AL/CA 1, AL/CA 2, AL/CA 3 & AL/PW 1 and TP6, incompatible with the Sustainability Objectives outlined above, but they are incompatible with the declaration made by Tunbridge Wells Borough Council on 17 July 2019 to recognise global climate and biodiversity emergencies and its ambition to make the Council’s operations carbon neutral by 2030. These policies should be removed from the draft Local Plan.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method Table 6 p.26	With regard to Sustainability Objective No. 11 “Provide sufficient housing to meet identified needs” – this is unclear. To meet whose identified needs? The government? TWBC? The local community?
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.2 p.26	“Scoring for the biodiversity objective was determined by the following three indicators; Sites of local biodiversity value included undesignated habitat; The Ashdown Forest SAC and SPA; Sites of Special Scientific Interest and associated risk zones” – how is it fair to score a biodiversity objective against the Ashdown Forest when the strategic sites have a very different geology, and therefore ecosystem, flora and fauna. They are sites of local biodiversity and should be measured on their own terms.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.6 p.27	“Higher weightings were given to issues that were legislatively driven, of critical importance to the borough and where finite assets were concerned.” - this surely has skewed the appraisal in favour of the maximum number of houses in all cases – the appraisal has been thus predetermined by the council, as housing need according to TWBC outweighs all environmental and other considerations
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.9 p.27	“Every effort was made to predict effects accurately; however, in some cases this was inherently challenging given the high level nature of the alternatives under consideration.” – if the predictions are wrong the effects will be felt by the local community and not by the planners.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.9 p.27	“realistic mitigation measures in line with the Draft Local Plan were assumed to be in place when scores were applied” – but these are not in place and there is no guarantee they will ever be in place. Scores should reflect the current situation.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.11 and Table 7 p.28	Table 7 outlines the alterations to the scoring method during Stage B. Under Sustainability Objective “Biodiversity” it states that “Consideration was given to the requirement for net gains for nature when scoring the biodiversity objective for borough-wide strategies” the reasoning being “This reflects the changes to the NPPF since the Issues and Options stage. A more precautionary approach was adopted for site level assessments, as the policy is in its infancy and it was not clear whether benefits would be delivered on or off site.” – it is not clear what approach was taken by TWBC here; where is the net gain for nature when 600 acres of Capel Parish is covered by housing?
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.13 p.29	“Because topics and objectives cannot be directly weighed against one another, readers are discouraged from ‘adding up’ positive or negative scores to give an overall score for a policy, strategy or site” – what is the point of scores if they can’t be added up? They are masquerading as objective criteria but in reality, the subjective written commentary is the basis on which decisions are made.
Chapter 5: Compatibility Testing of Strategic Objectives – Method para 5.2.3 p.30	“Where the term ‘appropriate’ in used in relation to Green Belt release, it refers to the land that contributes weakly to Green Belt objectives or to the strategic reasons outlined in the Green Belt Topic Paper.” – “weakly” is subjective and in the case of PW1/CA3 not borne out by evidence. Moreover it is not clear which ‘part’ of the Metropolitan Green Belt (MGB) is being referred to. One of the differences between Paddock Wood and Capel is that Capel is in the MGB and Paddock Wood is not. The parish boundary is also the limit to built development of PW and the MGB boundary. CPC would argue this is the most important part of the MGB in Capel parish as it prevents the convergence of Paddock Wood and Five Oak Green. In other words, it maintains a sense of openness and separateness between the two communities which is the whole point of the MGB – it does not therefore ‘weakly’ contribute to the MGB. The stretch of the road further west of AL/CA 3 between Five Oak Green and the A228 does not give this impression to the same degree; it doesn’t give a clear sense of separateness between the village and its surroundings. But once you cross the A228 it is very different – after a few houses near the roundabout there is open countryside right up to the LBD of Paddock Wood. The boundary between the two parishes is at its clearest here – yet the proposal of the planners to end the MGB at the A228 would destroy this clear distinction between rural and urban which is the main function of the MGB. This most strategic section of the MGB would be destroyed and the two settlements would to all appearances have converged.
Chapter 5: Compatibility Testing of Strategic Objectives – Method para 5.2.3 and Figure 4 p.30-31	Figure 4 outlines the Strategic Objectives of the new Local Plan. I Have the following concerns in relation to these: Objective 6 is “To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature” – the valued heritage and natural environments in Capel Parish are not being protected, for example the Grade 1 Listed Somerhill; There is no evidence of any net gains for nature either. Objective 7 is “To strategically release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land” – it is unclear how an increase in public accessibility can achieved unless it means building access roads over the remaining MGB; there are no measures to protect the remaining MGB land. Objective 8 is “To tackle climate change and minimise the impact of development on communities, the economy and the environment with carefully considered design and by embracing technology such as renewable energy generation” – this conflicts with TWBC’s recently adopted policy as a climate change council (see notes above) Objective 9 is “To establish garden settlements as a model for the future delivery of development in the borough” – it is troubling to see this as a model for even more development in the future, presumably in the same parish.
Chapter 5: Compatibility Testing of Strategic Objectives – Results para 5.3.1 and Table 8 p.32	Table 8 Table 8 purports to test compatibility of Local Plan objectives with Sustainability Appraisal Objectives. In relation to Local Plan Objective 1 (Development needs), Table 8 shows compatibility with all Sustainability Appraisal Objectives but it would not have been possible to assess compatibility with either Sustainability Appraisal Objective 2 (Biodiversity) or 13 (Landscape) as full assessments of the current situation were not undertaken for the strategic sites. To argue that Local Plan Objective 8 (Climate Change) is compatible with all the Sustainability Appraisal Objectives is just an assertion. How can that be when 600 acres of open farmland is to be built over and a road to be driven through the AONB? The compatibility of the Local Plan Objective on Garden Settlements (Objective 9) with Sustainability Appraisal Objectives is a series of ?’s What does that tell us?
Chapter 5: Compatibility Testing of Strategic Objectives – Results Table 9 and para 5.3.3 p.33-34	Table 9 outlines the number of Sustainability Objectives that are compatible with Local Plan Objectives. There is a very high level of uncertainty in relation to key objectives. For example; Local Plan Objective 2 (Infrastructure) is compatible with only 8 out of 19 Sustainability Appraisal Objectives (42% compatible) Local Plan Objective 3 (Travel) is compatible with only 8 out of 19 Sustainability Appraisal Objectives (42% compatible) Local Plan Objective 4 (Housing) is compatible with only 4 out of 19 Sustainability Appraisal Objectives (21% compatible) Local Plan Objective 7 (Green Belt) is compatible with only 4 out of 19 Sustainability Appraisal Objectives (21% compatible) Local Plan Objective 9 (Garden Settlements) is compatible with only 5 out of 19 Sustainability Appraisal Objectives (26% compatible) It is, therefore, totally wrong to simply conclude that “the majority (nine out of ten) of the Local Plan Objectives are more compatible than incompatible with the Sustainability Appraisal objectives.” If the outcome is uncertain then it cannot be ruled out that it is incompatible. The approach is wrong, and the Sustainability Appraisal is therefore unsound.
Chapter 5: Compatibility Testing of Strategic Objectives – Results para 5.3.6 p.34	“Strategic Objective 10 (Neighbourhood Planning) is also deemed to be compatible with all sustainability objectives because locally-led policies within Neighbourhood Plans are expected to demonstrate how they will contribute to achieving sustainable development” – this is speculation. If the Neighbourhood Plan content is dictated by the Strategic Policies of the Local Plan, given the high levels of uncertainty previously identified, it cannot be claimed that there will be compatibility.
Chapter 5: Compatibility Testing of Strategic Objectives – Results para 5.3.8 p.34	“Compatibility of sustainability objectives with Local Plan Strategy 9 (Garden Settlements) are based on those applied to Growth Strategy 4 in the Issues and Options Sustainability Appraisal” – why is compatibility of sustainability objectives with Local Plan Strategy 9 based on those applied to Growth Strategy 4 (the ‘Growth-Corridor Led Approach’) and Growth Strategy 5 (New Settlement Growth)? The same paragraph goes on “a clearer picture is now available on what sort of development would be created in a garden settlement. However, no presumption about potential locations for garden settlements is made for this element of the Local Plan thus several uncertain impacts are still predicted” There are no details on “what sort of development would be created” apart from that it will follow a master-planned approach. if, as the Sustainability Appraisal states on page 5, “Tudeley village was the only reasonable location for a new settlement” and this led to the inclusion of the site in Tudeley in the DLP as Policy AL/CA 1, then it is unclear why a presumption was not made that the location would be used in order to assess compatibility (or otherwise) of Local Plan Objective/Strategy 9 with the Sustainability Objectives. A proper assessment of a potential site would have led to certainty about compatibility. There is no justification for failing to properly assess the site at Tudeley against the sustainability criteria to achieve certainty.
Chapter 6: SA of the Spatial Development Strategy – Background and Method para 6.1.5 p.36	“Although these recommendations were felt to be the most useful output from the Issues and Options SA, it was noted that a slight preference was recorded for Growth Strategy 5 and that Growth Strategy 3 was slightly less positive than the other strategies” – this is misrepresentation. The Issues and Options Consultation Statement, available on the Tunbridge Wells Borough Council website at https://beta.tunbridgewells.gov.uk/local-plan/issues-and-options provides an overview of the Issues and Options consultation which ran from 02 May to 12 June 2017. This consultation included the question “Please let us know your preferred option or combination of options in order of preference”. The statement provides a summary of responses which states: “289 responses were received to this question in terms of ranking Strategic Options in order of preference. However, a significant number of these respondents stated they preferred a combination of Options as set out in Question 10a below. One respondent stated they did not agree with any of the Options. Of those who ranked the Strategic Options: 116 respondents (about 60%) ranked Option 4 (Growth Corridor-led Approach) as their most preferred Option; 34 respondents (about 18%) ranked Option 5 (New freestanding settlement) as their most preferred Option; 26 respondents (about 13%) ranked Option 1 (Focused Growth) as their most preferred Option; 16 respondents (about 8%) ranked Option 3 (Dispersed Growth) as their most preferred Option; 2 respondents (about 1%) ranked Option 2 (Semi-dispersed Growth) as their most preferred Option. From these responses, it can be concluded that of those who ranked the Strategic Options, the majority of 60% of respondents chose Option 4 (Growth Corridor-led Approach) as their preferred Option.” It is clear from this statement that rather than a slight preference for Growth Strategy 5, Three times as many people preferred Growth Strategy 4. Only 8% preferred Growth Strategy 3.
Chapter 6: SA of the Spatial Development Strategy Background and Method para 6.1.8 p.36	“Consideration was also given to a further option: growth that only partially meets identified needs. However, the iterative process through which sites were selected for development potential, including through the SA of sites, indicate that there is capacity in the borough to meet housing targets whilst still having due regard to AONB and Green Belt policies. Therefore, this option is not considered to be a reasonable alternative in the context of the NPPF at this point” If there is capacity in the borough to meet housing targets whilst still having due regard to AONB and Green Belt policies, why is development proposed which has a significant and detrimental impact on AONB and which results in the loss of 600 acres of Green Belt land? Option 9: Growth that only partially meets identified needs MUST be considered properly in the context of a Garden Settlement with a specified location which has been assessed against the sustainability objectives.
Chapter 6: SA of the Spatial Development Strategy Background and Method para 6.1.11, Figure 5 and Table 13 p.36-37	“Potential sites for garden settlements and urban extensions in the borough are shown in Figure 5. The locations underwent the same filtering process as that for sites with potential for small scale development (see section 8.1) and are described in Table 13 with an explanation of why options were not considered reasonable where applicable” The explanation of the approach taken by SA in relation to Capel (Ref 2 in Table 13) is “Land is outside of key constraints (except Green Belt) with potential for useful transport links” The ‘potential’ for useful transport links cannot be realised. There will be no new railway station and plans for the A228 strategic transport link (Colts Hill bypass) (Policy TP 6) and the proposed link route which is to run from the proposed development at Tudeley (Policy AL/CA 1) to the Colts Hill Bypass (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. The explanation of the approach taken by SA in relation to Horsmonden (Ref 4 in Table 13) is “Landscape sensitivity would require further consideration because the site is outside (but adjacent to) the AONB. However, the site was considered to have severe access difficulties that would render this alternative unviable and thus not a reasonable alternative.” There is only very limited information on why alternative strategic sites to Capel were rejected (far less information than on small scale sites rejected ) e.g. there is no comparison between site 144 in Horsmonden and its ‘severe access difficulties’ [not explained] and the sites chosen; it is not measured against the comparative negative criteria in Tudeley and East Capel despite the latter being in the Green Belt and in Tudeley’s case also bordering on AONB Paddock Wood (Ref 12 in Table 13) includes sites in Capel as well as PW. The explanation of the approach taken by the SA is “Land is outside of key constraints (except flooding and Green Belt) and has useful transport links” it appears that these constraints are conveniently less important for the purposes of the SA? The transport links are already overused and improvements are required. Please see our comments above in relation to the damage to the AONB in the event that the A228 strategic transport link (Colts Hill bypass) (Policy TP 6) and the proposed link route which is to run from the proposed development at Tudeley (Policy AL/CA 1) to the Colts Hill Bypass (Five Oak Green Bypass) are to go ahead.
Chapter 6: SA of the Spatial Development Strategy Results para 6.2.9 p.41	“in the light of the various options, together with the findings of further studies, consideration of availability of sites and the views of parish and town councils, a preferred growth development strategy has been formulated” This is misleading. The view of Capel Parish residents was only sought after this strategy had been adopted. At no point has Capel residents expressed a view supportive of this strategy. My view is that there is no need to build housing in the Green Belt and that Tunbridge Wells Borough Council’s strategy is flawed. Para 6.2.9 sets out that the Spatial Development Strategy has the following elements: “Provision for infrastructure-led, housing needs in line with Growth Strategies 3 and 5 including significant expansion of Paddock Wood and a new, standalone garden settlement in Capel Parish allowing for approximately 14,000 new homes over the plan period” “Provision for economic needs based on Growth Strategies 1, 2 and 4 including provision for approximately 14 hectares of employment land” “Provision of new local facilities and services where required to support residential development in smaller settlements
Chapter 6: SA of the Spatial Development Strategy – Results para 6.2.10 and Table 15 p.42	Table 15 shows the scoring for the SA of the Draft Local Plan spatial distribution strategy referred to above. The score for Biodiversity is 0 or ‘neutral’ with the commentary “Small losses offset by potential large gains on strategic sites. Net gains policy will also bring benefits. Not considered at site level as gains could be offsite or out of parish” – this is speculative. Given the paucity of information on biodiversity in general it is simply not possible to justify the statement of small losses and potential gains. This is unsound. Biodiversity should be ‘very negative’ (---) not ‘neutral’ (0) given the loss of Biodiversity resulting from Policies AL/CA1, TP6 and AL/CA3. Only Air, Climate Change, Heritage, Land use and Landscape are scored as ‘negative’ or ‘very negative’. Noise, Resources, Services, Travel and Water are all marked with a question mark which TWBC represents a ‘mixed’ score. These scores do not reflect the negative impact on Capel Parish where 4,300 (63%) of the proposed housing shortfall is planned. Much of this will have very limited impact on other parts of the borough so this cross borough impact measurement is flawed. Travel should be ‘very negative’ (---) not ‘?’ as there will be an additional 25,000 cars on the borough’s roads with inadequate public transport (no new railway stations). Water should be ‘very negative’ (---) not ‘?’. Clearly there will be huge demand on existing resources and an increased flood risk for hundreds of homes. It is unacceptable to simply state that the impact is ‘uncertain’ in order to massage the data.
Chapter 6: SA of the Spatial Development Strategy – Results para 6.2.11 p.42	“the environmental objectives score well relative to alternative strategies” This is only because TWBC has chosen to score the majority of the environmental objectives as a ? in order to ensure the outcome of the Sustainability Appraisal reflects its chosen strategy.
Chapter 6: SA of the Spatial Development Strategy – Results para 6.2.14 p.43	“it was logical to assess Paddock Wood for a potential urban expansion and especially because the other, larger settlements of RTW, Southborough, Hawkhurst and Cranbrook have many constraints. Similarly, the largely constraint-free area of land submitted in Capel parish was logical to assess as a potential garden settlement location” There is no detailed explanation as to why the other large scale sites were rejected. I believe that Tudeley was not the original choice as a standalone garden settlement, and that the choice was more to do with the single landownership than the absence of constraints. The nature of land ownership is not a good argument for rejecting a site outside the Green Belt for one inside it.
Chapter 6: SA of the Spatial Development Strategy – Results Garden Settlement Development Scale paras 6.2.15-6.2.14 p.43	These paragraphs relate to proposals for a larger scale development at Tudeley (Option 2) which consists of approximately 5,000 dwellings extending southwards further into the Green Belt and into AONB. I strongly objects to any proposal to consider the larger development within the Local Plan, which, if it were to occur, would destroy virtually all the MGB between Tonbridge and Five Oak Green. I am extremely concerned that Tunbridge Wells Borough Council ever considered a development of this scale on MGB and AONB, and seeks reassurance that Option 2 will not be reconsidered at a later date.
Chapter 6: SA of the Spatial Development Strategy Results Garden Settlement Development Scale para 6.2.17, Table 16 and paras 6.2.18-6.2.19 p.44-46	The sustainability appraisals for the two options at Tudeley are shown in Table 16 and the findings summarised in paragraphs 6.2.18-6.2.19 which appear to justify a smaller settlement on the grounds that a larger one would be even worse: most of the adverse effects are caused by the nature of the development itself – mitigating this by not building something even larger is ridiculous. The only sustainability comparison is between the two Tudeley options – there are no comparisons with other options the council considered, particularly those outside the Green Belt. As with Table 15, the use of ? as a score for any/all of the potentially negative scores is designed to skew the Sustainability Appraisal in favour of TWBC’s chosen strategy. It is absurd to suggest that a development of either size would have an uncertain or ‘mixed’ effect on Air Quality, particularly when the commentary goes on to acknowledge the high risk of deterioration to air quality which, in Tudeley is already on the cusp of exceeding the WHO target for acceptable levels of Fine particulate matter (PM2.5). Option 2 should be ‘very negative’ {---) and Option 1 ‘negative’ (--). The scoring for Biodiversity is understated with no consideration of the location in question. The commentary simply states “There is no risk the Ashdown Forest and neither option is within an SSSI Impact Risk Zone” which demonstrates the lack of diligence and understanding when scoring this Objective. Travel is scored as ‘very positive’ with commentary “The Travel scores are applied following a similar logic to air quality whilst also considering new bus routes and relatively easy access to train stations” this is not logical. There is no access to train stations, there are no bus routes in place and no pavements. The infrastructure will not be in place for several years after building begins. Option 2 should be ‘very negative’ {---) and Option 1 ‘negative’ (--).
Chapter 6: SA of the Spatial Development Strategy Results Urban Extension Development Scale paras 6.2.20-6.2.26, p.46	These paragraphs contain details of the four options considered for Urban Extension Development. There are two options which would not have involved building on the MGB – TWBC has rejected these in favour of one that does. Option 1 has least impact in terms of a range of environmental factors.
Chapter 6: SA of the Spatial Development Strategy Results Urban Extension Development Scale Figure 7 and Table 17 p.46-48	The sustainability appraisals for all four options are shown in Table 17. I have the following comments: The effect on local biodiversity will be much greater than stated (even if it has no effect on the Ashdown Forest – surely this is a flawed and ludicrous measurement given that it is miles away with a completely different geology soils, and flora and fauna!). 1,500 houses on option AL / CA 3 is not going to enhance biodiversity as stated – the presence of several hundred more domestic cats will see to that! Option 1 has the least effect on climate change – but the council seems only paying lip service to this goal despite proclaiming themselves a climate change council Option 1 has less effect on heritage than 2 and the setting of the Medieval moated Badsell Manor needs to be accounted for. Not clear whether this was included in the assessment. Option 1 would have less effect on land use and noise than option 2; and giving 1 and 2 the same score for landscape seems illogical given the 201 acres extra lost to this scheme. The environmental scores are much more negative overall for option 2 than 1 and there is an argument that the difference has been underplayed in this assessment.
Chapter 6: SA of the Spatial Development Strategy Results Urban Extension Development Scale paras 6.2.27-6.2.30 p.49	The findings of the SA of the four options are summarised in paragraphs 6.2.27-6.2.30. “It is fair to conclude that Options 1 and 2 have approximately similarly outcomes overall” – this is based on a flawed assessment, see our comments above. “housing is of great importance to the council in meeting targets and options” - It is clear that housing is the factor that motivates the council despite the impact on the MGB of option 2. This reads like TWBC chose the option they wanted and skewed these criteria to justify it. Environmental factors should have been taken more seriously and have been underweighted for the MGB section to the West of Paddock Wood. No exceptional circumstances have been put forward for building on MGB outside Paddock Wood in Capel Parish when even the council realises there are alternatives which would leave the MGB intact. “but also improve the flood risk for existing residents must be highly weighted” – this refers to Five Oak Green Flood Alleviation as well as PW. This has been used twice in this SA both in East Capel and Tudeley to justify development. This despite option 2 having been selected before TWBC were aware in Feb 2019 of this scheme. Option 2 would ALSO require building on the most flood prone part of Capel Parish – so improving the flood risk as a highly weighted factor for the choice does not make any sense.
Chapter 7: SA of the Strategic Policies Background and Method para 7.1.4 p.50	“Policy STR 4: The NPPF provides thorough coverage of Green Belt issues although, as stated above, the policy is based on making the releases set out in the Draft Local Plan, so is appraised on that basis, effectively as a cumulative assessment of the relevant individual development allocations. As this is a cumulative assessment, no specific alternative approach is identified. Rather, the appraisal provides an indication of the sustainability impacts of the proposed releases, which are each subject to their own appraisal” No specific alternative approach is identified, therefore, it is impossible to judge the chosen strategic sites against any possible alternatives.
Chapter 7: SA of the Strategic Policies Results para 7.2.1 and Table 18 p.51-52	Table 18 details the SA findings for Strategic Policies; STR 2 Sustainable Development; STR 3 Master planning; STR 4 Green Belt and; STR 5 Infrastructure This Table highlights the negative impact of Policy STR 4 Green Belt across the Borough. The impact on Capel Parish where all the Green Belt development is planned will be disproportionately greater. Why was there no cumulative impact assessment on Capel Parish alone as all the lost Green Belt is here? Once again TWBC has substituted realistic scores (which would all be negative) for 0 or ‘neutral’ scoring for the key environmental Sustainability Objectives; Air; Biodiversity; Landscape; Noise; Services and facilities; Travel; Waste and; Water. This drives the SA scoring closer to supporting their chosen strategy.
Chapter 8: SA of the Potential Development Sites Background and Method para 8.1.4 p.55	“Sites filtered out at this initial first stage assessment stage include sites: […]That are wholly Ancient Woodland or a significant proportion of the site is Ancient Woodland, significantly reducing the developable area of the site” The site for Policy AL / CA 2 has a significant portion of ancient woodland and should have been filtered out at the initial first stage assessment. Why therefore was it included? “Sites filtered out at this initial first stage assessment stage include sites: […] About which there is significant landscape concern, which it is considered is unlikely to be overcome” What is totally unclear is what this is based on given that there has been no comprehensive Borough wide landscape assessment. On this basis the SA cannot be sound. There is no filter for biodiversity interests beyond considerations relating to designated sites.
Chapter 8: SA of the Potential Development Sites Capel (including Tudeley Village) Figure 10 p.66	Figure 10 demonstrates the significant and excessive proportion of Capel parish being considered for development. No other parish is subjected to such pressures for development. It is completely disproportionate. The designation ‘Reasonable’ is wrong.
Chapter 8: SA of the Potential Development Sites Capel (including Tudeley Village) Table 25 p.67	Table 25 details the SA scores for allocated sites in Capel Parish. With regard to Policy TP 6, the scores in Table 25 cannot be reconciled with the evidence. A bypass of this nature which displaces AONB land, will necessitate CPOs and includes roundabouts onto single lane, unsuitable for HGV, weight restricted roads should be scored as either ‘negative’ or ‘very negative’ for the following sustainability objectives; Air, Biodiversity, Climate Change, Health, Heritage, Land use, Landscape, Noise and Water. With regard to STR / CA 1, the scores in Table 25 appear to have been totally fabricated. The SA should be scored as either ‘negative’ or ‘very negative’ for the following sustainability objectives; Air, Biodiversity, Climate Change, Health, Heritage, Land use, Landscape, Noise, Travel, Waste and Water. The commentary is biased. Without proper assessments of some factors in the first instance and given that there is an emphasis on development rather than conservation and respect for natural beauty and existing ecosystems there is bound to be a greater number of positives. With regard to AL / CA 2, how can Heritage be 0 or neutral when the Policy affects the views to and from Somerhill – a Grade 1 listed building? With regard to AL / CA 3 a positive biodiversity score for AL / CA 3 is hard to believe if this referred to the Capel section alone. As with AL / CA 1, the SA should be scored as either ‘negative’ or ‘very negative’ for the following sustainability objectives; Air, Biodiversity, Climate Change, Health, Heritage, Land use, Landscape, Noise, Travel, Waste and Water. The cumulative assessment for Capel Parish – STR/CA 1 (cumulative) – notes the negative scores for environmental objectives which TWBC clearly believe are a cost worth paying; and therefore, ultimately less important in the assessment. This chart is assessing cumulative effects on Capel but includes an area mostly in Paddock Wood. The betterment for flooding in Five Oak Green could still be paid for under option 1 for PW. It is clear that one parish is bearing a hugely disproportionate impact of this plan even on TWBC’s figures. The environmental impact of the development in MGB (with these three sites under Policies AL / CA 1; AL / CA 2 and AL / CA 3) in one small parish, when set alongside the impact of Policy TP 6 on the AONB with the associated transport infrastructure for these schemes which will carve its way through the remainder of Capel Parish in a way this Sustainability Appraisal has yet to spell out, will disproportionately damage the quality of life for Capel residents over the coming years. Essentially the council needs to rethink its strategy and avoid building on MGB, to protect the quality of life for its residents in Capel who cannot be expected to bear the full burden of development for the whole borough. This SA is based on the needs of the Borough as a whole it pays little attention to the cumulative effect on Capel Parish. Even this table envisions the positive impact for future residents. It does not reflect the impact for current residents.
Chapter 8: SA of the Potential Development Sites Paddock Wood Table 27 p.70	Table 27 SA scores for allocated sites in Paddock Wood Parish. Our comments above in relation to Policy AL / CA 3 (Table 25) are repeated here under Policy AL / PW 1; The SA should be scored as either ‘negative’ or ‘very negative’ for the following sustainability objectives; Air, Biodiversity, Climate Change, Health, Heritage, Land use, Landscape, Noise, Travel, Waste and Water. What justification is there for scoring Biodiversity “as slightly positive overall to reflect the large improvements that can be made with AL / PW 1” – when there are no ‘large improvements’ proposed? Note the negative score for Climate Change in relation to AL/CA3 which contrasts with the limited impact of the other sites in the town.
Chapter 8: SA of the Potential Development Sites Horsmonden Table 39 p.87-88	Table 39 lists ‘reasonable alternative sites in Horsmonden Parish’ but is missing site 144, which is referred to on page 38 of the SA and was originally seen an option for strategic development. Why was this site not properly assessed? See our comments above.
Chapter 10: Conclusion para 10.1.1 and Table 73 p.129	Table 73 outlines a complete SA of all elements of the Draft Local Plan. In this SA, the score for climate change is a ? – is this really sustainable for a climate change council? The impact of development in the MGB must be a big negative contribution. Table 73 suffers from the same speculation as other tables in that the baseline data has not been properly assessed / scored and the majority of environmental objectives score as mixed with neutral scores. It is unacceptable to simply put a question mark out of reluctance to acknowledge a clear negative impact. It is obvious that the following sustainability objectives should record a negative score for the reasons outlined in this response; Air, Biodiversity, Climate Change, Heritage, Noise, Travel, Waste and Water. If these objectives had been properly scored, the SA would be more credible and accurately reflect the poor sustainability of the Local Plan.
Chapter 10: Conclusion Table 74 – Biodiversity p.131	Table 74 outlines the impact of the overall Draft Local Plan on each Sustainability Appraisal objective. Under Biodiversity, it is stated that “The Biodiversity objective is compatible with (or has no relationship/an uncertain relationship with) all strategic objectives in the Draft Local Plan except Strategic Objective 4 (Housing) – see Table 8. This is principally because the large area of greenfield land take that would be required for construction of new dwellings is likely to create pressure on existing habitats. However, Strategic Objective 6 (Environment) offers protection to “valued natural environment” and expects net gains for nature thus any losses would be more than offset” There is no evidence presented for this assertion and the impact on biodiversity must be measured on each parish not across the borough. The flora and fauna of the Low Weald of Tudeley and East Capel cannot be replaced by compensatory measures elsewhere – it is a unique landscape with its own species. The comments in Table 74 in relation to biodiversity are dependent on tables that are faulty for reasons given above; namely that without the proper initial assessment it is not possible to understand the impact on this key issue. Similar comments also apply to landscape.
Chapter 10: Conclusion Table 74 - Heritage p.139	Under Heritage, it is stated “The heritage objective is compatible with (or has no relationship/an uncertain relationship with) all strategic objectives in the Draft Local Plan except Strategic Objective 4 (Housing) – see Table 8. This is because the large amount of residential development planned in both rural and urban locations is likely to result in a risk of harm to designated or non-designated heritage assets. Strategic Objective 6 (Environment) addresses heritage issues directly by offering ‘protection to value heritage’” The heritage effects on Capel Parish will be wholly negative – pattern of low weald farmsteads and the damage to the setting of listed buildings cannot be replaced.
Chapter 10: Conclusion Table 74 – Housing p.140	Under Housing, it is stated “The Housing objective is compatible with (or has no relationship/an uncertain relationship with) all strategic objectives in the Draft Local Plan (Table 8). This is because the large amount of residential development planned is fundamental to the Draft Local Plan.” “The impact of STR 1 (Spatial Development Strategy) on the housing objective can be seen in Table 14. A highly positive score is recorded to reflect the reasons given above.” “As would be expected, across the parishes and sites, the most positive effects on the Housing objective are assigned to the sites that would deliver the highest numbers of housing. For this reason, policies AL/CA 1 and AL/CA 3 (aka AL/PW 1) are extremely beneficial to the borough. Highly positive effects are recorded in many rural settlements too for example Horsmonden, Hawkhurst and Cranbrook. No negative effects are expected from the site allocation policies. “ It is not clear how this will benefit the residents of Capel or of Tunbridge Wells. It will result in the building of houses attractive to the London market which will put more pressure on existing infrastructure.
Chapter 10: Conclusion Table 74 – Landscape p.142	Under Landscape, it is stated “As for the cumulative impact from release of Green Belt sites, the cumulative impact on the Landscape objective of all allocated sites (equivalent to STR 1) is expected to be highly negative” TWBC is urged to remove Green Belt development and refocus the plan in line with its environmental objectives. The commentary moves from highly negative to negative by the conclusion; the mitigation ‘to some extent’ is an assertion that has not been evidenced.
Appendix A - Decision-aiding questions used for scoring SA objectives Table 76 p.153	Appendix A demonstrates that no consideration whatsoever has been given to biodiversity and the natural environment outside of designated sites. With regard to landscape no weighting has been given and the comment suggested that there has been some judgement yet there has been nothing to base that judgement given that there has been no comprehensive Borough wide landscape assessment.
Appendix G – Capel Scores for Reasonable Sites p.177.179	The reason given for the rejection of most smaller sites in Capel parish refers to their contribution to the Green Belt, the setting of Five Oak Green, and contribution to the landscape. These are the very reasons that have been ignored in the adjoining strategic sites. In particular the plan refers to the ‘weak’ contribution to the MGB part of AL / CA 3 makes – but it adjoins some of these sites, and its contribution is crucial as explained above. Appendix G suffers from the faults previously identified; in particular in relation to biodiversity and landscape.
Appendix O – Horsmonden Scores for Reasonable Sites p.204-206	Horsmonden makes no reference to site 144 considered as strategic (see our comments above)
Conclusion	Given the above I believe the overall SA is based on incomplete information and is therefore unsound. It fails to justify the extensive building within the Green Belt envisaged by the dLP, which I maintain is unsustainable.

SA_183

Mrs Suzi Rich

Sustainability Appraisal

Section, paragraph number(s), or site (including page number)	Comment
Non-Technical Summary p.2	“Both of these concepts would involve some loss of Green Belt land” – “some” is understated. 600 acres will be lost and adjoining AONB will be harmed by the associated transport infrastructure.
Non-Technical Summary p.2-3	“The environmental objectives were found to produce either highly mixed, neutral or negative scores” – the scores are overwhelmingly negative in the strategic sites.
Non-Technical Summary p.3	“Tudeley village was the only reasonable location for a new settlement” – there are no published assessments for alternative locations such as Horsmonden site 144; so, this is an assertion rather than something clearly based on evidence. “Paddock Wood was the only reasonable location for an extension […] but with land take in the Green Belt to the west of Paddock Wood, would provide a suitable scale of extension with benefits for the economic, environmental and social elements of sustainability” – even on your evidence, environmental and social elements are negatively impacted compared with the non-Green Belt options.
Non-Technical Summary p.4	“a cumulative impact assessment was undertaken for each parish or settlement location” – Table 25 (Chapter 8, page 67), contains the assessment scores for Capel Parish but lacks detail and underplays the local impact. The scores for AL/CA1, TP6 and AL/CA3 appear to be totally fabricated and bear to relation to the evidence base. Further comments can be found in the relevant section below.
Chapter 1: Introduction – Purpose of this Report para 1.3.1 p.13	“The report was then updated to take into account consultees’ comments and a final version prepared in October 2016. The Stage A Scoping Report should be referred to for a description of the original baseline, relevant plans, policies and programmes and the justification for the sustainability objectives that are being implemented in this report.”
Chapter 4: Methodology – Updates to baseline data para 4.1.2 and Table 2 p.20-21	“Table 2 below provides a list of additional relevant evidence studies that became available for consideration during Stage B following publication of the Issues and Options Sustainability Appraisal in July 2017.” Evidence studies outlined in Table 2 include; Green Belt Study (Stage 2); Historic Landscape Characterisation and; Historic Environment Review. Capel parish council was not consulted or made aware of these studies at the time they were done. Therefore, the local community had no opportunity to contribute. Table 2 also refers to a Landscape Sensitivity Assessment (RTW, Paddock Wood, Horsmonden, Hawkhurst and Cranbrook) completed during Spring 2017 and July 2018 but the assessment did not include Capel where 4000+ houses are proposed to be built on the Green Belt – why?
Chapter 4: Methodology – Updates to Plans, Policies and Programmes para 4.2.1 and Table 4 p.22-24	Table 4 refers to the KCC Draft Minerals and Waste Local Plan but incorrectly states that “Sites at Moat Farm and Stone Castle, Five Oak Green are adjacent to the boundary with TWB”. Both Moat Farm and the entrance to and part of Stone Castle are within TWB and adjacent to the proposed site in Tudeley STR/CA 1.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method Table 6 p.26	The Sustainability Objectives for Tunbridge Wells Borough are outlined in Table 6 and include the following: No. 1 “Reduce air pollution” No. 2 “Protect and enhance biodiversity and the natural environment” No. 4 “Reduce carbon footprint and adapt to predicted changes” No. 10 “Preserve and enhance historical and cultural heritage assets” No. 12 “Protect soils, and reuse previously developed land and buildings” No. 13 “Protect and enhance landscape and townscape” No. 14 “Reduce noise pollution” No. 15 “Reduce the impact of resource consumption” No. 17 “Improve travel choice and reduce the need to travel by private vehicle” No. 18 “Reduce waste generation and disposal” No. 19 “Manage flood risk and conserve, protect and enhance water resources” Policies AL/CA 1, AL/CA 2, AL/CA 3 & AL/PW 1 and TP6, are incompatible with all of the above objectives and therefore should be removed from the Draft Local Plan. Objective No. 4 in particular reflects the resolution made by Tunbridge Wells Borough Council on 17 July 2019 in which it recognised “that it has a responsibility to take a firm lead on reducing the council’s and the wider borough’s carbon emissions” and resolved to “Ensure that forthcoming plans and strategies (including the Local Plan and the next iteration of the Five-Year Plan) set out ways in which the Council can make its contribution to reduce carbon emissions, the degradation of the environment and combating climate change by agreeing an ambition to make the Council’s operations carbon neutral by 2030.” Not only are Policies AL/CA 1, AL/CA 2, AL/CA 3 & AL/PW 1 and TP6, incompatible with the Sustainability Objectives outlined above, but they are incompatible with the declaration made by Tunbridge Wells Borough Council on 17 July 2019 to recognise global climate and biodiversity emergencies and its ambition to make the Council’s operations carbon neutral by 2030. These policies should be removed from the draft Local Plan.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method Table 6 p.26	With regard to Sustainability Objective No. 11 “Provide sufficient housing to meet identified needs” – this is unclear. To meet whose identified needs? The government? TWBC? The local community?
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.2 p.26	“Scoring for the biodiversity objective was determined by the following three indicators; Sites of local biodiversity value included undesignated habitat; The Ashdown Forest SAC and SPA; Sites of Special Scientific Interest and associated risk zones” – how is it fair to score a biodiversity objective against the Ashdown Forest when the strategic sites have a very different geology, and therefore ecosystem, flora and fauna. They are sites of local biodiversity and should be measured on their own terms.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.6 p.27	“Higher weightings were given to issues that were legislatively driven, of critical importance to the borough and where finite assets were concerned.” - this surely has skewed the appraisal in favour of the maximum number of houses in all cases – the appraisal has been thus predetermined by the council, as housing need according to TWBC outweighs all environmental and other considerations
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.9 p.27	“Every effort was made to predict effects accurately; however, in some cases this was inherently challenging given the high level nature of the alternatives under consideration.” – if the predictions are wrong the effects will be felt by the local community and not by the planners.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.9 p.27	“realistic mitigation measures in line with the Draft Local Plan were assumed to be in place when scores were applied” – but these are not in place and there is no guarantee they will ever be in place. Scores should reflect the current situation.
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.11 and Table 7 p.28	Table 7 outlines the alterations to the scoring method during Stage B. Under Sustainability Objective “Biodiversity” it states that “Consideration was given to the requirement for net gains for nature when scoring the biodiversity objective for borough-wide strategies” the reasoning being “This reflects the changes to the NPPF since the Issues and Options stage. A more precautionary approach was adopted for site level assessments, as the policy is in its infancy and it was not clear whether benefits would be delivered on or off site.” – it is not clear what approach was taken by TWBC here; where is the net gain for nature when 600 acres of Capel Parish is covered by housing?
Chapter 4: Methodology – Sustainability Objectives and Scoring Method para 4.3.13 p.29	“Because topics and objectives cannot be directly weighed against one another, readers are discouraged from ‘adding up’ positive or negative scores to give an overall score for a policy, strategy or site” – what is the point of scores if they can’t be added up? They are masquerading as objective criteria but in reality, the subjective written commentary is the basis on which decisions are made.
Chapter 5: Compatibility Testing of Strategic Objectives – Method para 5.2.3 p.30	“Where the term ‘appropriate’ in used in relation to Green Belt release, it refers to the land that contributes weakly to Green Belt objectives or to the strategic reasons outlined in the Green Belt Topic Paper.” – “weakly” is subjective and in the case of PW1/CA3 not borne out by evidence. Moreover it is not clear which ‘part’ of the Metropolitan Green Belt (MGB) is being referred to. One of the differences between Paddock Wood and Capel is that Capel is in the MGB and Paddock Wood is not. The parish boundary is also the limit to built development of PW and the MGB boundary. CPC would argue this is the most important part of the MGB in Capel parish as it prevents the convergence of Paddock Wood and Five Oak Green. In other words, it maintains a sense of openness and separateness between the two communities which is the whole point of the MGB – it does not therefore ‘weakly’ contribute to the MGB. The stretch of the road further west of AL/CA 3 between Five Oak Green and the A228 does not give this impression to the same degree; it doesn’t give a clear sense of separateness between the village and its surroundings. But once you cross the A228 it is very different – after a few houses near the roundabout there is open countryside right up to the LBD of Paddock Wood. The boundary between the two parishes is at its clearest here – yet the proposal of the planners to end the MGB at the A228 would destroy this clear distinction between rural and urban which is the main function of the MGB. This most strategic section of the MGB would be destroyed and the two settlements would to all appearances have converged.
Chapter 5: Compatibility Testing of Strategic Objectives – Method para 5.2.3 and Figure 4 p.30-31	Figure 4 outlines the Strategic Objectives of the new Local Plan. I Have the following concerns in relation to these: Objective 6 is “To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature” – the valued heritage and natural environments in Capel Parish are not being protected, for example the Grade 1 Listed Somerhill; There is no evidence of any net gains for nature either. Objective 7 is “To strategically release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land” – it is unclear how an increase in public accessibility can achieved unless it means building access roads over the remaining MGB; there are no measures to protect the remaining MGB land. Objective 8 is “To tackle climate change and minimise the impact of development on communities, the economy and the environment with carefully considered design and by embracing technology such as renewable energy generation” – this conflicts with TWBC’s recently adopted policy as a climate change council (see notes above) Objective 9 is “To establish garden settlements as a model for the future delivery of development in the borough” – it is troubling to see this as a model for even more development in the future, presumably in the same parish.
Chapter 5: Compatibility Testing of Strategic Objectives – Results para 5.3.1 and Table 8 p.32	Table 8 Table 8 purports to test compatibility of Local Plan objectives with Sustainability Appraisal Objectives. In relation to Local Plan Objective 1 (Development needs), Table 8 shows compatibility with all Sustainability Appraisal Objectives but it would not have been possible to assess compatibility with either Sustainability Appraisal Objective 2 (Biodiversity) or 13 (Landscape) as full assessments of the current situation were not undertaken for the strategic sites. To argue that Local Plan Objective 8 (Climate Change) is compatible with all the Sustainability Appraisal Objectives is just an assertion. How can that be when 600 acres of open farmland is to be built over and a road to be driven through the AONB? The compatibility of the Local Plan Objective on Garden Settlements (Objective 9) with Sustainability Appraisal Objectives is a series of ?’s What does that tell us?
Chapter 5: Compatibility Testing of Strategic Objectives – Results Table 9 and para 5.3.3 p.33-34	Table 9 outlines the number of Sustainability Objectives that are compatible with Local Plan Objectives. There is a very high level of uncertainty in relation to key objectives. For example; Local Plan Objective 2 (Infrastructure) is compatible with only 8 out of 19 Sustainability Appraisal Objectives (42% compatible) Local Plan Objective 3 (Travel) is compatible with only 8 out of 19 Sustainability Appraisal Objectives (42% compatible) Local Plan Objective 4 (Housing) is compatible with only 4 out of 19 Sustainability Appraisal Objectives (21% compatible) Local Plan Objective 7 (Green Belt) is compatible with only 4 out of 19 Sustainability Appraisal Objectives (21% compatible) Local Plan Objective 9 (Garden Settlements) is compatible with only 5 out of 19 Sustainability Appraisal Objectives (26% compatible) It is, therefore, totally wrong to simply conclude that “the majority (nine out of ten) of the Local Plan Objectives are more compatible than incompatible with the Sustainability Appraisal objectives.” If the outcome is uncertain then it cannot be ruled out that it is incompatible. The approach is wrong, and the Sustainability Appraisal is therefore unsound.
Chapter 5: Compatibility Testing of Strategic Objectives – Results para 5.3.6 p.34	“Strategic Objective 10 (Neighbourhood Planning) is also deemed to be compatible with all sustainability objectives because locally-led policies within Neighbourhood Plans are expected to demonstrate how they will contribute to achieving sustainable development” – this is speculation. If the Neighbourhood Plan content is dictated by the Strategic Policies of the Local Plan, given the high levels of uncertainty previously identified, it cannot be claimed that there will be compatibility.
Chapter 5: Compatibility Testing of Strategic Objectives – Results para 5.3.8 p.34	“Compatibility of sustainability objectives with Local Plan Strategy 9 (Garden Settlements) are based on those applied to Growth Strategy 4 in the Issues and Options Sustainability Appraisal” – why is compatibility of sustainability objectives with Local Plan Strategy 9 based on those applied to Growth Strategy 4 (the ‘Growth-Corridor Led Approach’) and Growth Strategy 5 (New Settlement Growth)? The same paragraph goes on “a clearer picture is now available on what sort of development would be created in a garden settlement. However, no presumption about potential locations for garden settlements is made for this element of the Local Plan thus several uncertain impacts are still predicted” There are no details on “what sort of development would be created” apart from that it will follow a master-planned approach. if, as the Sustainability Appraisal states on page 5, “Tudeley village was the only reasonable location for a new settlement” and this led to the inclusion of the site in Tudeley in the DLP as Policy AL/CA 1, then it is unclear why a presumption was not made that the location would be used in order to assess compatibility (or otherwise) of Local Plan Objective/Strategy 9 with the Sustainability Objectives. A proper assessment of a potential site would have led to certainty about compatibility. There is no justification for failing to properly assess the site at Tudeley against the sustainability criteria to achieve certainty.
Chapter 6: SA of the Spatial Development Strategy – Background and Method para 6.1.5 p.36	“Although these recommendations were felt to be the most useful output from the Issues and Options SA, it was noted that a slight preference was recorded for Growth Strategy 5 and that Growth Strategy 3 was slightly less positive than the other strategies” – this is misrepresentation. The Issues and Options Consultation Statement, available on the Tunbridge Wells Borough Council website at https://beta.tunbridgewells.gov.uk/local-plan/issues-and-options provides an overview of the Issues and Options consultation which ran from 02 May to 12 June 2017. This consultation included the question “Please let us know your preferred option or combination of options in order of preference”. The statement provides a summary of responses which states: “289 responses were received to this question in terms of ranking Strategic Options in order of preference. However, a significant number of these respondents stated they preferred a combination of Options as set out in Question 10a below. One respondent stated they did not agree with any of the Options. Of those who ranked the Strategic Options: 116 respondents (about 60%) ranked Option 4 (Growth Corridor-led Approach) as their most preferred Option; 34 respondents (about 18%) ranked Option 5 (New freestanding settlement) as their most preferred Option; 26 respondents (about 13%) ranked Option 1 (Focused Growth) as their most preferred Option; 16 respondents (about 8%) ranked Option 3 (Dispersed Growth) as their most preferred Option; 2 respondents (about 1%) ranked Option 2 (Semi-dispersed Growth) as their most preferred Option. From these responses, it can be concluded that of those who ranked the Strategic Options, the majority of 60% of respondents chose Option 4 (Growth Corridor-led Approach) as their preferred Option.” It is clear from this statement that rather than a slight preference for Growth Strategy 5, Three times as many people preferred Growth Strategy 4. Only 8% preferred Growth Strategy 3.
Chapter 6: SA of the Spatial Development Strategy Background and Method para 6.1.8 p.36	“Consideration was also given to a further option: growth that only partially meets identified needs. However, the iterative process through which sites were selected for development potential, including through the SA of sites, indicate that there is capacity in the borough to meet housing targets whilst still having due regard to AONB and Green Belt policies. Therefore, this option is not considered to be a reasonable alternative in the context of the NPPF at this point” If there is capacity in the borough to meet housing targets whilst still having due regard to AONB and Green Belt policies, why is development proposed which has a significant and detrimental impact on AONB and which results in the loss of 600 acres of Green Belt land? Option 9: Growth that only partially meets identified needs MUST be considered properly in the context of a Garden Settlement with a specified location which has been assessed against the sustainability objectives.
Chapter 6: SA of the Spatial Development Strategy Background and Method para 6.1.11, Figure 5 and Table 13 p.36-37	“Potential sites for garden settlements and urban extensions in the borough are shown in Figure 5. The locations underwent the same filtering process as that for sites with potential for small scale development (see section 8.1) and are described in Table 13 with an explanation of why options were not considered reasonable where applicable” The explanation of the approach taken by SA in relation to Capel (Ref 2 in Table 13) is “Land is outside of key constraints (except Green Belt) with potential for useful transport links” The ‘potential’ for useful transport links cannot be realised. There will be no new railway station and plans for the A228 strategic transport link (Colts Hill bypass) (Policy TP 6) and the proposed link route which is to run from the proposed development at Tudeley (Policy AL/CA 1) to the Colts Hill Bypass (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. The explanation of the approach taken by SA in relation to Horsmonden (Ref 4 in Table 13) is “Landscape sensitivity would require further consideration because the site is outside (but adjacent to) the AONB. However, the site was considered to have severe access difficulties that would render this alternative unviable and thus not a reasonable alternative.” There is only very limited information on why alternative strategic sites to Capel were rejected (far less information than on small scale sites rejected ) e.g. there is no comparison between site 144 in Horsmonden and its ‘severe access difficulties’ [not explained] and the sites chosen; it is not measured against the comparative negative criteria in Tudeley and East Capel despite the latter being in the Green Belt and in Tudeley’s case also bordering on AONB Paddock Wood (Ref 12 in Table 13) includes sites in Capel as well as PW. The explanation of the approach taken by the SA is “Land is outside of key constraints (except flooding and Green Belt) and has useful transport links” it appears that these constraints are conveniently less important for the purposes of the SA? The transport links are already overused and improvements are required. Please see our comments above in relation to the damage to the AONB in the event that the A228 strategic transport link (Colts Hill bypass) (Policy TP 6) and the proposed link route which is to run from the proposed development at Tudeley (Policy AL/CA 1) to the Colts Hill Bypass (Five Oak Green Bypass) are to go ahead.
Chapter 6: SA of the Spatial Development Strategy Results para 6.2.9 p.41	“in the light of the various options, together with the findings of further studies, consideration of availability of sites and the views of parish and town councils, a preferred growth development strategy has been formulated” This is misleading. The view of Capel Parish residents was only sought after this strategy had been adopted. At no point has Capel residents expressed a view supportive of this strategy. My view is that there is no need to build housing in the Green Belt and that Tunbridge Wells Borough Council’s strategy is flawed. Para 6.2.9 sets out that the Spatial Development Strategy has the following elements: “Provision for infrastructure-led, housing needs in line with Growth Strategies 3 and 5 including significant expansion of Paddock Wood and a new, standalone garden settlement in Capel Parish allowing for approximately 14,000 new homes over the plan period” “Provision for economic needs based on Growth Strategies 1, 2 and 4 including provision for approximately 14 hectares of employment land” “Provision of new local facilities and services where required to support residential development in smaller settlements
Chapter 6: SA of the Spatial Development Strategy – Results para 6.2.10 and Table 15 p.42	Table 15 shows the scoring for the SA of the Draft Local Plan spatial distribution strategy referred to above. The score for Biodiversity is 0 or ‘neutral’ with the commentary “Small losses offset by potential large gains on strategic sites. Net gains policy will also bring benefits. Not considered at site level as gains could be offsite or out of parish” – this is speculative. Given the paucity of information on biodiversity in general it is simply not possible to justify the statement of small losses and potential gains. This is unsound. Biodiversity should be ‘very negative’ (---) not ‘neutral’ (0) given the loss of Biodiversity resulting from Policies AL/CA1, TP6 and AL/CA3. Only Air, Climate Change, Heritage, Land use and Landscape are scored as ‘negative’ or ‘very negative’. Noise, Resources, Services, Travel and Water are all marked with a question mark which TWBC represents a ‘mixed’ score. These scores do not reflect the negative impact on Capel Parish where 4,300 (63%) of the proposed housing shortfall is planned. Much of this will have very limited impact on other parts of the borough so this cross borough impact measurement is flawed. Travel should be ‘very negative’ (---) not ‘?’ as there will be an additional 25,000 cars on the borough’s roads with inadequate public transport (no new railway stations). Water should be ‘very negative’ (---) not ‘?’. Clearly there will be huge demand on existing resources and an increased flood risk for hundreds of homes. It is unacceptable to simply state that the impact is ‘uncertain’ in order to massage the data.
Chapter 6: SA of the Spatial Development Strategy – Results para 6.2.11 p.42	“the environmental objectives score well relative to alternative strategies” This is only because TWBC has chosen to score the majority of the environmental objectives as a ? in order to ensure the outcome of the Sustainability Appraisal reflects its chosen strategy.
Chapter 6: SA of the Spatial Development Strategy – Results para 6.2.14 p.43	“it was logical to assess Paddock Wood for a potential urban expansion and especially because the other, larger settlements of RTW, Southborough, Hawkhurst and Cranbrook have many constraints. Similarly, the largely constraint-free area of land submitted in Capel parish was logical to assess as a potential garden settlement location” There is no detailed explanation as to why the other large scale sites were rejected. I believe that Tudeley was not the original choice as a standalone garden settlement, and that the choice was more to do with the single landownership than the absence of constraints. The nature of land ownership is not a good argument for rejecting a site outside the Green Belt for one inside it.
Chapter 6: SA of the Spatial Development Strategy – Results Garden Settlement Development Scale paras 6.2.15-6.2.14 p.43	These paragraphs relate to proposals for a larger scale development at Tudeley (Option 2) which consists of approximately 5,000 dwellings extending southwards further into the Green Belt and into AONB. I strongly objects to any proposal to consider the larger development within the Local Plan, which, if it were to occur, would destroy virtually all the MGB between Tonbridge and Five Oak Green. I am extremely concerned that Tunbridge Wells Borough Council ever considered a development of this scale on MGB and AONB, and seeks reassurance that Option 2 will not be reconsidered at a later date.
Chapter 6: SA of the Spatial Development Strategy Results Garden Settlement Development Scale para 6.2.17, Table 16 and paras 6.2.18-6.2.19 p.44-46	The sustainability appraisals for the two options at Tudeley are shown in Table 16 and the findings summarised in paragraphs 6.2.18-6.2.19 which appear to justify a smaller settlement on the grounds that a larger one would be even worse: most of the adverse effects are caused by the nature of the development itself – mitigating this by not building something even larger is ridiculous. The only sustainability comparison is between the two Tudeley options – there are no comparisons with other options the council considered, particularly those outside the Green Belt. As with Table 15, the use of ? as a score for any/all of the potentially negative scores is designed to skew the Sustainability Appraisal in favour of TWBC’s chosen strategy. It is absurd to suggest that a development of either size would have an uncertain or ‘mixed’ effect on Air Quality, particularly when the commentary goes on to acknowledge the high risk of deterioration to air quality which, in Tudeley is already on the cusp of exceeding the WHO target for acceptable levels of Fine particulate matter (PM2.5). Option 2 should be ‘very negative’ {---) and Option 1 ‘negative’ (--). The scoring for Biodiversity is understated with no consideration of the location in question. The commentary simply states “There is no risk the Ashdown Forest and neither option is within an SSSI Impact Risk Zone” which demonstrates the lack of diligence and understanding when scoring this Objective. Travel is scored as ‘very positive’ with commentary “The Travel scores are applied following a similar logic to air quality whilst also considering new bus routes and relatively easy access to train stations” this is not logical. There is no access to train stations, there are no bus routes in place and no pavements. The infrastructure will not be in place for several years after building begins. Option 2 should be ‘very negative’ {---) and Option 1 ‘negative’ (--).
Chapter 6: SA of the Spatial Development Strategy Results Urban Extension Development Scale paras 6.2.20-6.2.26, p.46	These paragraphs contain details of the four options considered for Urban Extension Development. There are two options which would not have involved building on the MGB – TWBC has rejected these in favour of one that does. Option 1 has least impact in terms of a range of environmental factors.
Chapter 6: SA of the Spatial Development Strategy Results Urban Extension Development Scale Figure 7 and Table 17 p.46-48	The sustainability appraisals for all four options are shown in Table 17. I have the following comments: The effect on local biodiversity will be much greater than stated (even if it has no effect on the Ashdown Forest – surely this is a flawed and ludicrous measurement given that it is miles away with a completely different geology soils, and flora and fauna!). 1,500 houses on option AL / CA 3 is not going to enhance biodiversity as stated – the presence of several hundred more domestic cats will see to that! Option 1 has the least effect on climate change – but the council seems only paying lip service to this goal despite proclaiming themselves a climate change council Option 1 has less effect on heritage than 2 and the setting of the Medieval moated Badsell Manor needs to be accounted for. Not clear whether this was included in the assessment. Option 1 would have less effect on land use and noise than option 2; and giving 1 and 2 the same score for landscape seems illogical given the 201 acres extra lost to this scheme. The environmental scores are much more negative overall for option 2 than 1 and there is an argument that the difference has been underplayed in this assessment.
Chapter 6: SA of the Spatial Development Strategy Results Urban Extension Development Scale paras 6.2.27-6.2.30 p.49	The findings of the SA of the four options are summarised in paragraphs 6.2.27-6.2.30. “It is fair to conclude that Options 1 and 2 have approximately similarly outcomes overall” – this is based on a flawed assessment, see our comments above. “housing is of great importance to the council in meeting targets and options” - It is clear that housing is the factor that motivates the council despite the impact on the MGB of option 2. This reads like TWBC chose the option they wanted and skewed these criteria to justify it. Environmental factors should have been taken more seriously and have been underweighted for the MGB section to the West of Paddock Wood. No exceptional circumstances have been put forward for building on MGB outside Paddock Wood in Capel Parish when even the council realises there are alternatives which would leave the MGB intact. “but also improve the flood risk for existing residents must be highly weighted” – this refers to Five Oak Green Flood Alleviation as well as PW. This has been used twice in this SA both in East Capel and Tudeley to justify development. This despite option 2 having been selected before TWBC were aware in Feb 2019 of this scheme. Option 2 would ALSO require building on the most flood prone part of Capel Parish – so improving the flood risk as a highly weighted factor for the choice does not make any sense.
Chapter 7: SA of the Strategic Policies Background and Method para 7.1.4 p.50	“Policy STR 4: The NPPF provides thorough coverage of Green Belt issues although, as stated above, the policy is based on making the releases set out in the Draft Local Plan, so is appraised on that basis, effectively as a cumulative assessment of the relevant individual development allocations. As this is a cumulative assessment, no specific alternative approach is identified. Rather, the appraisal provides an indication of the sustainability impacts of the proposed releases, which are each subject to their own appraisal” No specific alternative approach is identified, therefore, it is impossible to judge the chosen strategic sites against any possible alternatives.
Chapter 7: SA of the Strategic Policies Results para 7.2.1 and Table 18 p.51-52	Table 18 details the SA findings for Strategic Policies; STR 2 Sustainable Development; STR 3 Master planning; STR 4 Green Belt and; STR 5 Infrastructure This Table highlights the negative impact of Policy STR 4 Green Belt across the Borough. The impact on Capel Parish where all the Green Belt development is planned will be disproportionately greater. Why was there no cumulative impact assessment on Capel Parish alone as all the lost Green Belt is here? Once again TWBC has substituted realistic scores (which would all be negative) for 0 or ‘neutral’ scoring for the key environmental Sustainability Objectives; Air; Biodiversity; Landscape; Noise; Services and facilities; Travel; Waste and; Water. This drives the SA scoring closer to supporting their chosen strategy.
Chapter 8: SA of the Potential Development Sites Background and Method para 8.1.4 p.55	“Sites filtered out at this initial first stage assessment stage include sites: […]That are wholly Ancient Woodland or a significant proportion of the site is Ancient Woodland, significantly reducing the developable area of the site” The site for Policy AL / CA 2 has a significant portion of ancient woodland and should have been filtered out at the initial first stage assessment. Why therefore was it included? “Sites filtered out at this initial first stage assessment stage include sites: […] About which there is significant landscape concern, which it is considered is unlikely to be overcome” What is totally unclear is what this is based on given that there has been no comprehensive Borough wide landscape assessment. On this basis the SA cannot be sound. There is no filter for biodiversity interests beyond considerations relating to designated sites.
Chapter 8: SA of the Potential Development Sites Capel (including Tudeley Village) Figure 10 p.66	Figure 10 demonstrates the significant and excessive proportion of Capel parish being considered for development. No other parish is subjected to such pressures for development. It is completely disproportionate. The designation ‘Reasonable’ is wrong.
Chapter 8: SA of the Potential Development Sites Capel (including Tudeley Village) Table 25 p.67	Table 25 details the SA scores for allocated sites in Capel Parish. With regard to Policy TP 6, the scores in Table 25 cannot be reconciled with the evidence. A bypass of this nature which displaces AONB land, will necessitate CPOs and includes roundabouts onto single lane, unsuitable for HGV, weight restricted roads should be scored as either ‘negative’ or ‘very negative’ for the following sustainability objectives; Air, Biodiversity, Climate Change, Health, Heritage, Land use, Landscape, Noise and Water. With regard to STR / CA 1, the scores in Table 25 appear to have been totally fabricated. The SA should be scored as either ‘negative’ or ‘very negative’ for the following sustainability objectives; Air, Biodiversity, Climate Change, Health, Heritage, Land use, Landscape, Noise, Travel, Waste and Water. The commentary is biased. Without proper assessments of some factors in the first instance and given that there is an emphasis on development rather than conservation and respect for natural beauty and existing ecosystems there is bound to be a greater number of positives. With regard to AL / CA 2, how can Heritage be 0 or neutral when the Policy affects the views to and from Somerhill – a Grade 1 listed building? With regard to AL / CA 3 a positive biodiversity score for AL / CA 3 is hard to believe if this referred to the Capel section alone. As with AL / CA 1, the SA should be scored as either ‘negative’ or ‘very negative’ for the following sustainability objectives; Air, Biodiversity, Climate Change, Health, Heritage, Land use, Landscape, Noise, Travel, Waste and Water. The cumulative assessment for Capel Parish – STR/CA 1 (cumulative) – notes the negative scores for environmental objectives which TWBC clearly believe are a cost worth paying; and therefore, ultimately less important in the assessment. This chart is assessing cumulative effects on Capel but includes an area mostly in Paddock Wood. The betterment for flooding in Five Oak Green could still be paid for under option 1 for PW. It is clear that one parish is bearing a hugely disproportionate impact of this plan even on TWBC’s figures. The environmental impact of the development in MGB (with these three sites under Policies AL / CA 1; AL / CA 2 and AL / CA 3) in one small parish, when set alongside the impact of Policy TP 6 on the AONB with the associated transport infrastructure for these schemes which will carve its way through the remainder of Capel Parish in a way this Sustainability Appraisal has yet to spell out, will disproportionately damage the quality of life for Capel residents over the coming years. Essentially the council needs to rethink its strategy and avoid building on MGB, to protect the quality of life for its residents in Capel who cannot be expected to bear the full burden of development for the whole borough. This SA is based on the needs of the Borough as a whole it pays little attention to the cumulative effect on Capel Parish. Even this table envisions the positive impact for future residents. It does not reflect the impact for current residents.
Chapter 8: SA of the Potential Development Sites Paddock Wood Table 27 p.70	Table 27 SA scores for allocated sites in Paddock Wood Parish. Our comments above in relation to Policy AL / CA 3 (Table 25) are repeated here under Policy AL / PW 1; The SA should be scored as either ‘negative’ or ‘very negative’ for the following sustainability objectives; Air, Biodiversity, Climate Change, Health, Heritage, Land use, Landscape, Noise, Travel, Waste and Water. What justification is there for scoring Biodiversity “as slightly positive overall to reflect the large improvements that can be made with AL / PW 1” – when there are no ‘large improvements’ proposed? Note the negative score for Climate Change in relation to AL/CA3 which contrasts with the limited impact of the other sites in the town.
Chapter 8: SA of the Potential Development Sites Horsmonden Table 39 p.87-88	Table 39 lists ‘reasonable alternative sites in Horsmonden Parish’ but is missing site 144, which is referred to on page 38 of the SA and was originally seen an option for strategic development. Why was this site not properly assessed? See our comments above.
Chapter 10: Conclusion para 10.1.1 and Table 73 p.129	Table 73 outlines a complete SA of all elements of the Draft Local Plan. In this SA, the score for climate change is a ? – is this really sustainable for a climate change council? The impact of development in the MGB must be a big negative contribution. Table 73 suffers from the same speculation as other tables in that the baseline data has not been properly assessed / scored and the majority of environmental objectives score as mixed with neutral scores. It is unacceptable to simply put a question mark out of reluctance to acknowledge a clear negative impact. It is obvious that the following sustainability objectives should record a negative score for the reasons outlined in this response; Air, Biodiversity, Climate Change, Heritage, Noise, Travel, Waste and Water. If these objectives had been properly scored, the SA would be more credible and accurately reflect the poor sustainability of the Local Plan.
Chapter 10: Conclusion Table 74 – Biodiversity p.131	Table 74 outlines the impact of the overall Draft Local Plan on each Sustainability Appraisal objective. Under Biodiversity, it is stated that “The Biodiversity objective is compatible with (or has no relationship/an uncertain relationship with) all strategic objectives in the Draft Local Plan except Strategic Objective 4 (Housing) – see Table 8. This is principally because the large area of greenfield land take that would be required for construction of new dwellings is likely to create pressure on existing habitats. However, Strategic Objective 6 (Environment) offers protection to “valued natural environment” and expects net gains for nature thus any losses would be more than offset” There is no evidence presented for this assertion and the impact on biodiversity must be measured on each parish not across the borough. The flora and fauna of the Low Weald of Tudeley and East Capel cannot be replaced by compensatory measures elsewhere – it is a unique landscape with its own species. The comments in Table 74 in relation to biodiversity are dependent on tables that are faulty for reasons given above; namely that without the proper initial assessment it is not possible to understand the impact on this key issue. Similar comments also apply to landscape.
Chapter 10: Conclusion Table 74 - Heritage p.139	Under Heritage, it is stated “The heritage objective is compatible with (or has no relationship/an uncertain relationship with) all strategic objectives in the Draft Local Plan except Strategic Objective 4 (Housing) – see Table 8. This is because the large amount of residential development planned in both rural and urban locations is likely to result in a risk of harm to designated or non-designated heritage assets. Strategic Objective 6 (Environment) addresses heritage issues directly by offering ‘protection to value heritage’” The heritage effects on Capel Parish will be wholly negative – pattern of low weald farmsteads and the damage to the setting of listed buildings cannot be replaced.
Chapter 10: Conclusion Table 74 – Housing p.140	Under Housing, it is stated “The Housing objective is compatible with (or has no relationship/an uncertain relationship with) all strategic objectives in the Draft Local Plan (Table 8). This is because the large amount of residential development planned is fundamental to the Draft Local Plan.” “The impact of STR 1 (Spatial Development Strategy) on the housing objective can be seen in Table 14. A highly positive score is recorded to reflect the reasons given above.” “As would be expected, across the parishes and sites, the most positive effects on the Housing objective are assigned to the sites that would deliver the highest numbers of housing. For this reason, policies AL/CA 1 and AL/CA 3 (aka AL/PW 1) are extremely beneficial to the borough. Highly positive effects are recorded in many rural settlements too for example Horsmonden, Hawkhurst and Cranbrook. No negative effects are expected from the site allocation policies. “ It is not clear how this will benefit the residents of Capel or of Tunbridge Wells. It will result in the building of houses attractive to the London market which will put more pressure on existing infrastructure.
Chapter 10: Conclusion Table 74 – Landscape p.142	Under Landscape, it is stated “As for the cumulative impact from release of Green Belt sites, the cumulative impact on the Landscape objective of all allocated sites (equivalent to STR 1) is expected to be highly negative” TWBC is urged to remove Green Belt development and refocus the plan in line with its environmental objectives. The commentary moves from highly negative to negative by the conclusion; the mitigation ‘to some extent’ is an assertion that has not been evidenced.
Appendix A - Decision-aiding questions used for scoring SA objectives Table 76 p.153	Appendix A demonstrates that no consideration whatsoever has been given to biodiversity and the natural environment outside of designated sites. With regard to landscape no weighting has been given and the comment suggested that there has been some judgement yet there has been nothing to base that judgement given that there has been no comprehensive Borough wide landscape assessment.
Appendix G – Capel Scores for Reasonable Sites p.177.179	The reason given for the rejection of most smaller sites in Capel parish refers to their contribution to the Green Belt, the setting of Five Oak Green, and contribution to the landscape. These are the very reasons that have been ignored in the adjoining strategic sites. In particular the plan refers to the ‘weak’ contribution to the MGB part of AL / CA 3 makes – but it adjoins some of these sites, and its contribution is crucial as explained above. Appendix G suffers from the faults previously identified; in particular in relation to biodiversity and landscape.

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Highways England

Whole SA

In accordance with the Highways England Licence, in exercising our legal duties and other obligations we will act in a manner best calculated to, inter alia,

Minimise the environmental impacts of operating, maintaining and improving the network and seek to protect and enhance the quality of the surrounding network; and
Conform to the principles of sustainable development i.e. encourage economic development while protecting the environment and improving safety and quality of life for current and future generations.

In accordance with national policy and normal practice, it is for each statutory consultee to comment on matters under their jurisdiction. Therefore, any comments regarding topics such as air quality, noise and vibration come within the remit of the statutory environmental bodies. However, Highways England would wish to work with all parties to fully understand any environmental implications of highways proposals or consequences, in order so assist the Council to reach evidence based conclusions and holistic decisions.

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Ms Karen West

Policy Number(s): AL/CRS 4; AL/CRS6; Al/CRS 7; AL/CRS9

I object to the large-scale developments of the above areas in the Parish of Cranbrook.

I am linking my objections to the Sustainability Objectives:

1. Air pollution. Whilst there are mentions of developers trying to encourage active transport within new developments (eg cycling or walking) the reality is that these developments are so large and so far out of the town that people would have to use private vehicles in order to do their shopping. Even if new residents used the town of Cranbrook to shop (and those of us who live here know how limited the choice is) the increase in the amount of car use would automatically increase air pollution. Given the limited employment opportunities and the very limited public transport in Cranbrook, anyone who needs to be in employment (and living in these new developments) will need to drive to the nearest large town – Maidstone or Tunbridge Wells or drive to the nearest railway station in order to earn a living. The cost of electric cars is exorbitant, so their use is minimal. This means that with around 600 new dwellings there will be at least 500 new petrol/diesel vehicles on the road. The objective of the Sustainability Appraisal with regard to air pollution is to reduce air pollution. There is no way that building around 600 new dwellings in a small country town will achieve the objective of reducing air pollution. I object to the large-scale developments proposed because they will inevitably increase air pollution for current residents and those who wish to live in the town in the future. There will be concentrated pockets of air pollution in the mornings and evenings as people leave for work/to drop children off to school/return home in the evening.

9. Improve health and wellbeing. The medical facilities in Cranbrook are limited. There are three GP practices in the town. There are limited spaces for new residents. Two practices are being run by GPs who are on the cusp of retirement. In common with many GP practices it is difficult to recruit partners because of the huge responsibilities placed upon partners. There is a high use of locum GPs which does not lead to continuity of care. The Tunbridge Wells Hospital at Pembury is already under stress and would not be able to cope with extra residents in the vicinity. The whole of the proposed developments in the area will mean that hospital facilities are stretched beyond their capacity. There are no satellite clinic areas or minor injuries units nearby. Public transport is limited which means that anyone living in Cranbrook, wanting to visit a GP practice in surrounding villages, would need to drive to the medical facility. The local sports centre and any sports clubs such as rugby/cricket/badminton/tennis/swimming are all privately funded. There are very few free activity sessions offered in the town. There is one NHS dentist in the town. There are no NHS mental health facilities in the town. I object to the large-scale developments proposed because there are not the health/medical facilities available in the town to enable a large amount of people to access good healthcare. There are not facilities to address health inequalities for lower income families. It seems unbelievable that TWBC are allowed to even offer the option of building large-scale developments to developers given that there are so few health facilities on offer. To attract a large amount of people into the town to live when there are no facilities for them is surely a failure in the local authority’s duty of care to residents. There is not even a physical community hub in the town. The Sustainability Appraisal and plans make reference to there being space allocated for such a community centre, but no insistence that this be a condition for developers.

13 To protect and enhance the landscape and townscape. By the draft plan’s own admission these large-scale developments are being proposed for areas of outstanding natural beauty (AONB). TWBC seem to be saying that they have weighed this up in a costs/benefits analysis. However, how can it be beneficial for current and future residents to eat up and build on beautiful areas of the countryside? One of the only things we have that contributes to the mental wellbeing of residents is that we live in a beautiful environment. I object to TWBC not exercising their option to refuse to build on AONB. It appears that the cost/benefits analysis has been calculated as the cost being to the local people and the benefits in the form of central government grants to TWBC. The stated objectives of the Sustainability Appraisal with regard to enhancing the landscape is to protect it AONB, and ancient woodland and to protect and enhance the landscape, quality and character of the area. Building 0ver 600 new homes in AONB, on the edge of ancient woodland, where there are tree preservation orders and in areas that have wildlife dependent upon their natural environment cannot possible achieve the objectives set. Once we have built on the AONB, encroached on wildlife and changed the Eco structure, it cannot be undone.

17. Travel – the objectives stated in the Sustainability Appraisal are that TWBC wants to increase travel choice and reduce the need for private vehicle travel across the borough. As stated before in my objections, I believe that the proposed large scale developments are so far out of the town centre that people will not be encouraged to walk into town to shop or work. I object to the larger scale developments because the local environment is not conducive to the safety of road users. The car parks in the town are already full most days. Sixth formers from Cranbrook School have cars, shop workers have cars, school workers have cars, shoppers have cars and all of them need to be parked. If the car parks are full people will use the residential roads in the town. This in turn will endanger people living in those areas. Older people and children trying to cross residential roads with parked cars increases the risk of harm. The narrow vehicular access roads currently leading to the farmsteads that are the planned areas of the large-scale developments mean that there is likely to be traffic jams if the road system is not changed. There is no incentive to cycle along the country lanes at present as the level of traffic and twisty nature of the roads means that this is highly dangerous for cyclists. There is no mention in the Appraisal document about making building cycle paths compulsory.

In summary then, I believe that large-scale developments should be refused in Cranbrook. The current meagre health, social and transport facilities will quickly collapse with the injection of large scale housing developments. The quality of life for those who already live in the town will suffer. Those who are attracted into the town to purchase beautiful looking houses will quickly realise that TWBC’s ambition for the number of houses is not matched by their commitment to ensuring that there are adequate health, social and transport facilities. I object to these large scale developments on behalf of those who already live in the town and for those who might be attracted into a town that cannot sustain their needs. If small scale housing developments were proposed offering a high level of truly affordable housing then this would be ideal. It would mean that those young people who already live in the town either with parents or having to pay high rents would be able to stay in the area. There would not be a huge influx of new residents to the area, but instead a traditional small scale growth of young families and a good contribution to the variety of the population, as is the tradition for country towns in the County. This would be sustainability in action. Slow and realistic but responsive to local needs.

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Ms Yvonne Settle & Mrs Olive Settle

Draft Local Plan and Sustainability Appraisal

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

1) The Council’s Topic Paper “Distribution of Development”, provides an overview of the Issues and Options consultation that was carried out previously. 5.4 and 5.5 of the Topic Paper confirmed that the most preferred option for housing growth was for a “growth corridor led” approach (60% of respondents), whilst the least favoured options (dispersed growth and semi dispersed growth) attracted the support of just 8% and 1% of respondents.

2) With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then othercomparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

(insert footpath photo)

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

3) The existing access road to the site would have to be upgraded to serve 30 houses, including allowing access for emergency services and refuse collection vehicles. Given the size of such vehicles, and the speed and frequency of vehicles using Furnace Lance, the junction into the site is likely to be highly engineered – which will have a harmful urbanising influence.

4) Given the above, the scoring for the site that is contained within the SHLAA and the Sustainability Appraisal is debatable (note the site is defined as site 285 in these documents). The site seems to have been included because a number of identified constraints have been identified as “neutral” (with no guidance given on how such constraints are measured in a consistent manner with other sites). However, for major development in the AONB, “neutral” is not a high enough requirement. Paragraph 172 of the National Planning Policy Framework gives AONB areas the “highest status of protection” and states:

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

5) In addition, development of the site would clearly have significant negative impacts in terms of climate change (given the reliance on private car use), biodiversity (with the site providing important habitats and migratory routes for protected species), and landscape. The site already ‘scores’ worse that the majority of other identified sites within Lamberhurst and significantly worse than other sites across the Borough.

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

We trust that these comments will be taken into account and would appreciate confirmation of receipt of this email.

SA_187

Ann Gibson

a) The removal of established local farming activities on this site is hardly an act of Sustainability. The field is currently used for grazing sheep and is designated by KCC Biodiversity as “Other grassland of Importance” owing to its careful conservation management over the years.

b) The biodiversity colour on the Table should be red not blue.

c) Adjoining the field is the historic Mill Farm (the former village miller’s house with windmill). The Heritage colour on the Table should be pink at least.

d) The removal of the existing group of bee-hives is not what I would expect from a Sustainability policy.

e) Granting permission to build homes on this site will see increased carbon emissions due to the resulting increase in road traffic.

f) More traffic will result from allocating all of the new resources to provide employment some distance from the Parish.

g) Any removal of hedges or trees on the site is to be avoided.

h) Housing on this site will severely impact the local species of bats, woodpeckers, owls, nightingales and other birds, hedgehogs, newts, grass snakes and slow worms etc. and have a detrimental effect on the adjacent Primary School wildlife conservation area.

i) Road hazards created on the A262 and Mill Lane by the development must be resolved without impacting Sustainability. This should include avoiding the introduction of street lighting along the A262 and avoiding the removal of any hedges and trees.

j) This site was excluded from the NDP produced by our locally elected Parish Council.

SA_188

Ann Gibson

I SUPPORT the proposals on these two sites as it would:-

Be much more preferable to sites AL/CRS 12 & 13
The access/exit is safe onto the A229
Not so damaging to the landscape
Not adjacent or close the High Weald AONB
Very close to the Ashwal Garage Shop for day to day essentials
Very close to the Cranbrook/Maidstone/Tunbridge Wells bus stop
Within walking distance to Sissinghurst Primary School and High Weald Academy
Cars commuting to Maidstone and Tunbridge Wells would not clog up Sissinghurst Centre
Cars are unlikely to use Mill Lane – a designated rural lane with very limited visibility and dangerous exit onto the A262

SA_189

Ann Gibson

Paragraph Number(s): Appendix 1 Site Number: 120 Site Address: Land east of Camden Lodge, adjacent to Mill Lane and Sissinghurst Road, Sissinghurst Policy ref: AL/CRS 13

This will result in the loss of Greenfield Land. The site is adjacent to the High Weald AONB boundary and is old parkland. It was used for grazing cattle and then sheep until fairly recently. Its use for housing not an act of Sustainability. It forms a green-gap between Sissinghurst village and Wilsley Green.

The Landscape should be red in the Table. This is old Parkland with many fine, mature trees and valuable agricultural land.

Granting permission to build homes on this site will see increased carbon emissions due to the resulting increase in road traffic.

By allocating all of the new resources to provide employment some distance from the Parish more traffic will result.

Any removal of hedges or trees on the site must not be permitted. The ancient rural countryside should be protected

The site was excluded from the NDP produced by our locally elected Parish Council.

SA_190

Andrew Richards

Table 13 – Garden Settlement options

INTRODUCTION

I am not a resident of Tunbridge Wells Borough, but I live near to the Borough boundary just outside Tonbridge.

I visit the Borough regularly and enjoy the benefits of its countryside, notably the Green Belt and the Areas of Outstanding Natural Beauty, which need to be preserved in line with National Planning Policy. I also drive around Tonbridge regularly and am shocked at the impact the proposals in your draft Local Plan (LP) would have on Tonbridge and its environs.

The LP is vast and complex and has clearly consumed a significant amount of effort; I congratulate the officers for their diligence in seeking to balance the various competing demands of policy, legislation and local constraints. As a private individual I do not have similar resources or expertise; I have therefore confined my comments to a small number of topics. This is not to say I endorse the remainder of the LP and its associated material; I am aware of some of the concerns raised by others and support many of them.

Notwithstanding the level of effort that has gone into the LP, I’m afraid my overall assessment is that the Borough has fallen short of the diligence needed. Sadly, it seems to have taken the easy way out of its obligations in a number of areas. It has:

Failed to challenge the standard method for determining the housing need;
Failed to widen its search for housing sites beyond those yielded in the voluntary Call for Sites;
Analysed poorly those comments raised against the Issues and Options paper;
Failed in its Duty to Co-operate with Tonbridge and Malling Borough Council (TMBC);
Been selective in its application of the ‘exceptional’ burden of proof;
Opted for the easy route of selecting sites for large scale development owned by a single or small number of landowners;
Failed to take account of commuting habits and the pressures resulting from its proposals on rail services, notably but not exclusively in Tonbridge;
Failed in its duty of care to students by proposing the establishment of a new school spanning a busy railway line;
Failed to provide housing suitable for an increasingly aging population

I conclude that the Borough has failed to meet the required standard for a Regulation 18 consultation and should repeat the exercise, having first addressed some of the fundamental concerns raised. I believe this plan requires too substantial a series of amendments to proceed directly to a Regulation 19 consultation.

My comments are in relation to a number of documents identified below.

36. I object to the exclusion of sites 1 (Blantyre House), 3 (Frittenden) and 4 (Horsmonden), and the failure to identify land extending further to the east of site 12 (Paddock Wood), from consideration as potential sites for garden settlements.

37. Planning policy requires:

a. “The assessment needs to identify all sites and broad locations (regardless of the amount of development needed) in order to provide a complete audit of available land” (PPG 3-008)

b. “When preparing strategic policies, it may be concluded that insufficient sites / broad locations have been identified to meet objectively assessed needs, including the identified local housing need. . . . If insufficient land remains, then it will be necessary to investigate how this shortfall can best be planned for” (PPG 3-025)

38. Whereas:

a. The SA excludes certain sites (serials 1 and 3) on the grounds that they were not submitted in the call for sites or were too small, despite noting that they lie “outside of key constraints” and are within easy reach of rail services. Frittenden, in particular, has particular merit as it lies to the extreme east of the Borough, and therefore offers the potential for access to Ashford and its alternative rail routes into London, avoiding congestion on the Tonbridge line. The map below shows the absence of key constraints. I’m afraid this failure to consider the Frittenden area in more detail is just lazy.

b. The SA also excludes serial 4 (site 144) on the grounds of access, an infrastructure problem, yet seems to have no difficulty assigning considerable infrastructure investment in support of serials 2 and 12. This is not consistent and is therefore unsound.

c. It should further be noted that there is a discrepancy between the summary provided in the SA and the underlying SHELAA site assessment for site 144. Specifically:

(1) The SA quotes “severe access difficulties”, yet the SHELAA assessment makes no such assertion. In contrast, it states “There is vehicular access into the site from Maidstone Road and Yew Tree Green Road where there is a metal gate and wide access”. This lack of consistency between the underlying assessment and the subsequent analysis underpinning policy calls into question the whole validity of the exercise and renders the LP unsound.

(2) The SA quotes “severe access difficulties”, yet the SHELAA assessment provides the following very different reason for judging the site unsuitable “This would be a very large scale strategic allocation that would be disproportionate to the size of the settlement, with concern about landscape and heritage”. Again, this lack of consistency between the underlying assessment and the subsequent analysis underpinning policy calls into question the whole validity of the exercise and renders the LP unsound.

d. The LP and SA, together, fail to consider sites not offered through the Call for Sites process, which I believe is again just lazy. To offer a specific example, land further to the east of site 12 is free of most constraints and would contribute to the growth of Paddock Wood as a hub – see map (but to note, this is not optimum as it would contribute to the growing unsustainability of rail travel on the Tonbridge line):

Conclusion

39. In conclusion, to reiterate the point made in opening, I conclude that the Borough has failed to meet the required standard for a Regulation 18 consultation. It should therefore repeat the exercise, having first addressed some of the fundamental concerns raised.

40. I believe this plan requires too substantial a series of amendments to proceed directly to a Regulation 19 consultation.

[TWBC: See attached file for full representation]

SA_191

James and Emma Young

TWBC: correspondent submitted the following comments on 27/11/19, after the close of consultation on 15/11/19:

Draft Local Plan and Sustainability Appraisal

We write regarding the draft Local Plan and Sustainability Appraisal (together with other background topic papers), particularly with regard to the Council’s proposed housing strategy, the suitability of Lamberhurst to accommodate additional dwellings, and the proposed allocation of a site on the south side of Furnace Lane, Lamberhurst for around 30 dwellings (site reference AL/LA2).

Planning Strategy

2) With regard to the Council’s Strategic Housing Land Availability Assessment and the Sustainability Appraisal, concern is expressed at the lack of consistency in how sites have been appraised (and then accepted or rejected) and the subjective nature of the assessment. Certain sites have been rejected for being detached from the LBD boundary (“limits to built development”), but then othercomparable sites have been included. Similarly, some sites have been accepted despite comments such as “slight negative scores most reflect dependency on private car use”, whilst other sites have been rejected outright for the same reason. There does not appear to be an accurate quantifiable methodology used that measures settlements and sites in a consistent manner.

Lamberhurst as a Location for Additional Housing (Policy STR/LA1)

In addition, the Council’s strategy of allocating large poorly connected sites within the village is severely detrimental to the overall character of Lamberhurst and the High Weald AONB settlement pattern. The High Weald AONB’s Statement of Significance identifies its dispersed settlement pattern as on of the five defining components of the character of the High Weald. Many of the settlements across the High Weald area occur in clusters of homes around the junction of routeways – and the allocation proposed would relate extremely poorly to the character of the High Weald that gives the area its unique historic significance and settlement pattern.

Schools:The nursery school is already oversubscribed, and the primary school has only 4 spare spaces. There is no secondary school. There is no headroom for major development and additional children that will likely result from the addition of 60 new houses will not therefore be able to be taught within the village but will have to be transported further afield.

Shops:There is only one shop in the village. The shop is very small and not much use for anything other than daily “top ups” such as milk or a newspaper. Weekly shopping has to be done away from the village, with the nearest supermarket being Tesco – which is approximately 8 miles away, and only reachable by car. The village shop is generally inaccessible as cars are always parked outside, meaning that most villagers simply drive past the shop and continue on to Tesco for service.

Draft Local Plan Allocation AL/LA2 (Land at Furnace Lane, Lamberhurst)

(insert footpath photo)

2) The site is remote from the village (see also earlier comments about the remoteness of Lamberhurst), and not readily accessible by pedestrians. The limited services available within the village are 1.5km walking distance from the site. Whilst pedestrian access to the village along Furnace Lane and the B2100 is theoretically possible, the required route it is narrow, largely unlit, substandard, features many step changes where driveways cross it and requires a number of road crossings without formal crossing points. There is a steep incline/decline between the site entrance and the village. Together, these aspects indicate that even where future residents were to consider using limited village services, people would still be most likely to use the private motor car for access. With limited parking available within the village, people would then be just as likely to continue driving further afield for services where parking is available.

“Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”

For the Furnace Lane site, no exceptional circumstances exist (the fact that many areas of harm are, in the council’s opinion, “neutral” is not an exceptional circumstance).

Conclusions

Lamberhurst is a small rural village with very limited services and accessibility. Proposals for 60 houses within the village (policy STR/AL1) cannot be supported by existing infrastructure and will by heavily reliant of the private motor car. Focusing development in established urban areas that have more services and public transport is a far more appropriate method of increasing housing land supply whilst acknowledging climate change commitments.

SA_192

Andrew Ford

The statutory High Weald AONB Management Plan is not included in Table 2 (para. 4.1.2) which lists sources of evidence for the SA.
Impact on the AONB is not specifically addressed in the SA, although one (of the 19) sustainability objectives identified in the SA (p. 26) relates to landscape with an objective to ‘protect and enhance landscape and townscape. However, impact on landscape, or how well the policy or site contributes to the landscape objective, is not assessed consistently. For example:

NPPF, para 172 emphasises that conservation of wildlife is also important in AONBs, and TWBC’s own AONB Management Plan includes policy to enhance the ecological function of fields (Objective FH3), woodland (Objective W2) and routeways (Objective R2), yet, for each allocation in Hawkhurst, Benenden, and Brenchley and Matfield the impact on the Biodiversity objective is rated at zero (0). Most of these sites are greenfield sites including three large sites (AL/HA1, AL/HA4, AL/HA6) allocated for a total of 629 dwellings) with valuable grassland, hedgerows and trees. For Cranbrook, the impact on Biodiversity is rated mostly as zero (0) to slightly negative despite including large sites with valuable undisturbed grassland, hedges and mature trees (such as Gate Farm). Loss of these habitats and species characteristic of the AONB, compounded by loss of soil biodiversity, will have a very negative impact on the SA’s Biodiversity objective ‘to protect and enhance biodiversity’. The SA score for each of these site/ policies should be ‘Negative’ (- - ) or ‘Very Negative’ (- - -). Net gain through development will not be achievable on these sites.
The almost universal highest sensitivity ratings applied by TWBC’s Landscape Sensitivity Assessment (July 2018) to landscape parcels around historic settlements in the AONB are not properly reflected in the SA; impact on landscape is not universally shown to be ‘Negative’ or ‘Very Negative’. For larger greenfield sites in the AONB the SA should show an impact score on Landscape as ‘Very Negative’ (- - -).

SA_194

Euan Burrows, Mockbeggar Lane and group of East End residents

Introduction

These representations are made on behalf of Euan Burrows, Mockbeggar Lane and a group of residents who all live in East End, Benenden.
The focus of these representations is site allocation policy AL/BE4, which seeks to allocate 44-50 further dwellings at the land at Benenden Hospital, SHELAA references: site 424 and late site 41.
The land subject to policy AL/BE4 is situated approximately 4km to the north east of Benenden. It is connected to Benenden by Goddard’s Green Road / Benenden Road (a designated rural lane). There is currently permission for 22 new dwellings on the. It contains land which is previously developed for a limited use, being land previously used by the hospital.
The site is unsustainable. There are no amenities on the site. There are no bus services which serve the East End. Access is via the narrow Goddard’s Green Road. There are no community facilities.. Simply put, aside from the houses currently on site and the hospital (with associated buildings), there is nothing else on site.

The Sustainability Appraisal (‘SA’)

It is our view that the approach taken to selecting sites for the proposed allocations in the Local Plan is fundamentally flawed. As such, at present it is the case that the Local Plan cannot be considered sound with regards to policy AL/BE4.
Section 8 of the Sustainability Appraisal concerns the SA of the Potential Development Sites. Paragraph 8.1.1 of the Sustainability Appraisal states that:

“All sites submitted to the Council’s Call for Sites process were assessed against a robust methodology which is set out in the Strategic Housing and Economic Land Availability Assessment (SHELAA). This included all sites received through two Call for Sites processes and sites received since then but prior to the 22^nd February 2019 (known as ‘late sites’ or ‘additional sites’ and ‘A_S’ on all figures in this chapter).”

Paragraph 8.1.3 of the SA provides that:
“A number of sites were filtered out during a first stage initial assessment of sites. For the purposes of this SA report, these are sites that are not considered to be reasonable alternatives requiring a sustainability appraisal.”
Paragraph 8.1.4 of the SA provides a list of criteria by which sites were initially filtered out.[1] It appears to be the case that the list of sites which made it past this initial filtering (such that they were considered ‘reasonable alternatives’ for the purposes of the SA) are listed at Table 32 of the SA (pg. 32). It should be noted that whilst there are 11 site references included in the list of reasonable alternatives, 6 of these sites constitute the 4 proposed allocations for Benenden, including sites 424, AS_40 and AS_41 which form policy AL/BE4.
However, this approach is flawed and, in any event, has been misapplied in relation to Benenden.
First, there is no good reason provided for why these filters have been provided. Whilst some of them make clear sense (bullet points 1 and 2, for example), others require justification yet none is provided. In particular, no reasoning is provided in either the SA or the SHELAA as to why sites which are likely to provide less than 10 residential units were filtered out. Whilst this may, in principle, be appropriate for the larger settlements affected by the Local Plan, this should not be applied across all potential sites. This criteria serves to neutralise a number of potential sites in and around Benenden without good reason. It is clear that smaller sites can be appropriate – policy AL/BE1 is an allocation for approximately 12 dwellings. Without justification, it is wholly untenable to immediately filter out all sites which will provide a yield of less than 10 residential units.
Second, the initial filtration has been misapplied. Specifically bullet points 1 and 2 of paragraph 8.1.4 provide that sites that will be filtered out include sites that are:

“* Located in remote locations away from existing settlements; such sites considered unlikely to be sustainable in this context; in some instances some remote sites have been considered in the context of a new garden settlement where applicable or as urban extensions; (Bullet Point 1)

Not well related to a settlement; this has included sites that may be in relative close proximity to a settlement but are not well related to the built form of the settlement for example because they are cut off / separated from the settlement / built form in some way; (Bullet Point 2)

If these points were to have been correctly applied, it is inconceivable that AL/BE4 would have emerged as a preferred option.
With regards to Bullet Point 1, AL/BE4 cannot sensibly be said to be a settlement given the small number of houses and the complete lack of facilities. This is acknowledged in the SHELAA when it states that AL/BE4 is “remote from a settlement centre.” Indeed, the nearest settlements to AL/BE4 are Benenden or Biddenden, both of which are 4km away (pg. 263 of the Local Plan). Applying the methodology set out in both the SA and the SHELAA, as is the required approach, AL/BE4 should not have made it past the initial filtering stage.
With regards to Bullet Point 2, it follows from the above that AL/BE4 is not well related to a settlement. The relation between East End and Benenden is along the narrow Goddard’s Green Road. There is no walking path and no cyclepath between East End and Benenden. Indeed, this fundamental deficiency in relation to Benenden is clearly acknowledged by the wording of AL/BE4, and would not change even if attempts to introduce measures required by this deficiency such as an ‘active travel link’ were introduced.
From the above, it is clear that the sites which form AL/BE4 should not have been capable of making it past the initial filtration stage. Both site 424 and late site 41 are too remote to meet the criteria of the SA.
The unsustainable nature of site AL/BE4 is demonstrated in Table 33 of the SA (pg. 79). AL/BE4 scores as being very negative to negative on the sustainability topic of Services and Facilities and as being negative on the sustainability topic of Travel.
Appendix K to the SA provides the scoring for each of the sites against each of the sustainability topics concluded to be reasonable alternatives.[2] The improper inclusion of AS_41 means that there are a number of reasonable sites which have not been allocated. These sites are sites 158, 222, 425, AS_8 and AS_21. Notably, sites 158 and 222 have no very negative scores.
There is a different and unjustified approach taken to the sustainability topic of Services and Facilities for AS_41 compared to other sites. The commentary to site AS_41, which scores very negative on services and facilities, makes no reference to the lack of provision of services. Instead, it states that “Although promoted by the policy, shared transport and active travel options are unlikely to take precedence over private vehicle use thus air quality and climate change also score negatively.” This failure to reference the lack of services is wrong, either because it has failed to take it into account, or because it is operating from the assumption that services will be provided once the allocation is built out.
Both of these approaches are improper. In practice the primary negative of the site has been discounted in the allocation assessment, which is clearly wrong. This site is fundamentally incompatible with sustainable use and this should obviously have weighted heavily against both (i) its inclusion at all and (ii) as would appear beyond reasonable debate, the extraordinary and inflated scale of development that is now proposed.
Second, any attempt to discount this on the basis that a future allocation can compensate for it is plainly wrong. First, because this could be true for any potential issue for any site, thereby making the evidential base of the allocation process otiose.. Second, because the proposed services are clearly inadequate to address this issue. The proposed cycle path fails to have regard to the fact that it is roughly a 4km journey from East End to Benenden. Given there are not any shops at East End, and AL/BE4 solely makes provision for a ‘small retail unit, the use of this path would require residents to walk or cycle a round trip of 8km. This clearly will be ineffective. The minibus service is, during the week, a school run which wouldn’t meet the needs of other residents of the East End. These provisions are clearly inadequate in addressing the unsustainability of the site. In comparison, the commentary to both sites 158 and 222 notes a “lack of services and facilities including public transport at the settlement”, making no reference of the possibility of future development providing these services. They also miss the point in that in practice developments of this scale are strictly discouraged in rural and isolated location precisely because they inevitably encourages car use.
Finally, there is a failure in the SA to take account of the planning permission that has already been granted for this site.[3] This granted permission for the development of 24 dwellings at land adjacent to Benenden Hospital. In our view, the Hospital is seeking to bring forwards a large scheme of residential development in multiple phases on this site of which that planning permission was the first stage. The failure to take account of the overall scale of this scheme in the Local Plan process is a fundamental failing.
To conclude on the SA, the approach taken by the SA is flawed and inconsistent. Site AS_41 (as described in Appendix K) should not have made it past the initial filtering stage as a result of its remoteness and lack of connectivity with any established settlement. This is especially true when the allocation is for 66-72 houses with few notable facilities to be added, meaning AL/BE4 would create an isolated outpost reliant upon travel to Benenden along Goddard’s Green Road. The SA provides reasonable alternatives that are better sites and can accommodate the 44-50 houses AL/BE4 seeks to provide.
Insofar as AL/BE4 is based on the SA, the Local Plan is not justified and ineffective. For these reasons it cannot be considered sound.

Strategic Housing and Economic Land Availability Assessment (‘SHELAA’)

Insofar as relevant to this representation, the role of the SHELAA is to identify land which may be suitable to allocate for housing (paragraph 001 PPG Housing and Economic Land Availability Assessment[4]).
Paragraph 3.2 of the SHELAA states that:

“The outcomes of the SHELAA should be to identify sites and broad locations with potential for development, assess their development potential, assess their suitability for development and the likelihood of development coming forward.”

The SHELAA provides a site summary assessment of each of the sites. The conclusions of the SA feed into this. Paragraph 4.5 of the SHELAA notes that:
“The outcome of the SHELAA is not a list of sites that will be allocated for development in the Local Plan, but forms part of the evidence base to support policies in the new Local Plan. For some of the sites considered by the SHELAA to be suitable for further consideration, the production of this Draft SHELAA does not rule out the possibility that additional issues may arise during this process, or subsequently through the consultation on the Draft Local Plan, that then preclude a site being considered suitable for allocation for development. The converse may also be true, with the possibility that further information or amended, or new, site proposals coming forward that make them more suitable. A final SHELAA will be prepared to inform the Pre-Submission Local Plan to be prepared under Regulation 19.”
However, in our view the conclusions of the SHELAA as currently reached are fundamentally flawed. The focus of these representations are the site assessment sheets for Benenden Parish, dated July 2019, as these are the most recent SHELAA documents.
We note that the SHELAA states it applies the same initial considerations to stage 1 site assessments as the SA (paragraph 3.23 SHELAA). In accordance with the representations made above, the sites comprising AL/BE4 should not have made it past this initial assessment stage.
Site AL/BE4 is correctly identified as being “remote from a settlement centre.” However, this remoteness fails to feature in the remainder of the site assessment. The sustainability assessment notes that “residents will rely heavily on private cars and thus air, equality and travel objectives score negatively” yet makes no reference to the Services and Facilities objective which, as discussed above, receives the lowest score possible for a sustainability objective. The site assessment sheet concludes that the site is suitable as a potential site, for the reason that “This is mostly a PDL site that already benefits from an extant planning consent.” This conclusion is significantly flawed for three reasons.
First, the SHELAA adopts a different approach to the remoteness of AL/BE4 to other sites. Sites 289, 295, 397 and 425 are all identified as being remote from settlement centre. In each case this weighs heavily against each site. However, the remoteness of AL/BE4 doesn’t feature in the conclusions on whether it is a suitable site. The fact that those sites are not considered reasonable alternatives under the SA is not relevant to whether the site is too remote to be a potential site in the terms of the SHELAA. This inconsistent approach to remoteness within the SHELAA infects the conclusion that AL/BE4 is a suitable site.
Second, the SHELAA site assessments places undue emphasis on AL/BE4 being mostly previously developed land. The Land Use topic in the SA includes the objective of using previously developed land.[5] It is reasonable to read this across to the SHELAA. As such, use of previously developed land is clearly a material factor in judging the suitability of a site. However, it should only be one factor among others, not an overriding principle. In this case, the fact that the land is mostly previously developed is one of the two reasons given, notwithstanding the fact that the remoteness of the previous use of the site was justified by its connection to the hospital. The proposed use, however, would be a number of houses not dependant upon or linked to the hospital. This fails to properly consider the use of the site in accordance with the stated methodology of the SHELAA (c.f. paragraph 3.14).
Properly understood, there is far less benefit from the use of previously developed land for this site than is stated in the SHELAA. The approach currently adopted by the SHELAA makes the remainder of the assessment otiose insofar as allocations will necessarily be made on previously developed land, regardless of the other relevant factors including those encapsulated by the sustainability objectives.
Third, there is no good basis for placing significant weight on the extant planning permission for this site in terms of the achievability of development. The furthest that the extant permission goes is to demonstrate that 24 residential units are achievable on the site. It does not show that a further 44-50 units are achievable on the site. This reasoning would result in the exponential growth of settlements with extant permissions and non-allocation of sites where, for example, all permissions have been built out. This is clearly flawed.
Furthermore, this fails to have regard to the broader point with regards to this site, namely the fact that the Hospital are in the process of bringing a large scheme of development across multiple phases. The approach currently taken in the SHELAA would justify a cascade of development from this single application whilst failing to have regard to the sustainability reasons for not allocating the site. A holistic approach is required in order to appreciate the totality of development proposed by the Hospital for the site, the acceptable upper limit for residential development in this isolated rural area and why, therefore, no further allocation should be made.
To conclude on the SHELAA, it adopts an inconsistent approach between different sites. Furthermore, whilst purporting to analyse the sites against a range of factors it in fact has been carried out such that previously developed land will necessarily be allocated before greenfield land, notwithstanding any other factors relating to that site including the nature of the previous use and any other nearby uses.
Insofar as AL/BE4 is based on the SHELAA, the Local Plan is not justified and ineffective. For these reasons it cannot be considered sound.

Policy AL/BE4

Furthermore, reflecting its fundamental unsuitability, Policy AL/BE4 also conflicts with other policies in the Local Plan.
At present the site is wholly without services.[6] It is isolated from any settlement and has no regular transport links to established settlements. The SA notes that most access to AL/BE4 will be via private car, yet this conflicts with policies STR2 and TP2 of the Local Plan.
Table 3 of the Local Plan sets out the scale and distribution of development for each Parish / Settlement covered by the Local Plan. For development in East End it states that all significant infrastructure is set out within the Infrastructure Delivery Plan (‘IDP’). This table is repeated in the IDP. In this context, infrastructure has a broad meaning. It covers both physical infrastructure and community infrastructure. Table 1 of the IDP sets out the detail of different types of infrastructure. The Infrastructure Delivery Schedule, Appendix 1 of the IDP, lists all Infrastructure to be delivered. The only Infrastructure that relates to Benenden is the provision of additional youth and children’s play space (pg. 104). There is no transport infrastructure to be provided. This conflicts starkly with Policies STR2 and TP2 of the Local Plan. It cannot be said that AL/BE4 is sustainable or accessible at present, and significant and unacceptable (and unplanned) road and other infrastructure would be required to make it so. The furthest the Local Plan goes to addressing these issues is to state in Policy AL/BE4 that any development shall provide an active travel link between East End and Benenden. However, this falls far short of what is required to make the isolated East End a sustainable settlement location. This therefore conflicts with both the Local Plan and the NPPF.
To conclude on this point, Policy AL/BE4 is in conflict with other policies in the Local Plan and the NPPF. It is therefore ineffective and inconsistent with national policy. For these reasons, Policy AL/BE4 cannot be considered sound.

The Principle of Development

It is important to emphasise that we do not object to the principle of limited development on a sustainable scale on this site reflecting and commensurate with the existing hospital related residential accommodation. However, it is clear that the Hospital is seeking to build out a significant scheme of residential development in a staged fashion by first obtaining a discrete and existing planning permission on an adjacent site and then seeking to allocate additional permissions on ancillary hospital land under the guise of ‘brownfield’ development, despite the fact what is now proposed has no relation to that which previously existed. The Local Plan is request to look at the impact of this scheme in a holistic fashion which, when properly considered, is fundamentally inconsistent with the sustainable land policies TWBC is required to apply in its overall impact of what is fundamentally a rural area. It is clear that this is a site which has significant constraints on the possibility of development at present. Aside from the hospital and a number of houses, there are no facilities or services on this site. Indeed, it is clear from the Local Plan and the documents submitted with the Local Plan that the only reason this site is in consideration at all as a potential allocation is because of its status as previously developed land.
We therefore invite Tunbridge Wells to remove AL/BE4 from the Local Plan.

[1] This is the same list applied to the SHELAA filtering process (paragraph 3.23 SHELAA) although different results were achieved, as commented on below

[2] Sites 424 and AS_40 are included in the analysis of AS_41

[3] Ref: 17/00951/FULL

[4] https://www.gov.uk/guidance/housing-and-economic-land-availability-assessment

[5] Table 6 SA

[6] Noting the inaccurate statement in the Local Plan that there are educational facilities on the site

[TWBC: this response has been duplicated under Section 5: Benenden (Policy AL/BE4), Appendix 5 (SHELAA) and the Sustainability Appraisal]