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'It will destroy local communities and ruin residents’ lives. It must be stopped'... Chairman's speech highlights appalling Tunbridge Wells council plans

Elementary Admin
By Elementary Admin &
8th October 2019

This landscape will be lost to housing if proposals from Tunbridge Wells Borough Council come to fruition

It’s been described as “the biggest threat to Tonbridge and our Green Belt in a generation” and indeed plans from Tunbridge Wells Borough Council for mass housebuilding seem set to change landscape and life in west Kent in an almost unimaginable way.
The proposals for 2,800 new houses at Tudeley and another 1,500 at East Capel sparked the creation of Save Capel and last month John Wotton, CPRE Kent chairman, gave a speech to the campaign group pledging this organisation’s support in the bid to halt a policy destined to ruin the quality of life for so many.
Here is that speech, made on Wednesday, September 18, in full:
“CPRE is the countryside charity. It exists to protect the English countryside, to make sure it is valued and accessible to all and that it supports a viable and sustainable rural economy.
“Here in Tunbridge Wells, we are privileged to live in the beautiful and historic farmed and wooded landscape of the Weald of Kent. We are all custodians of the countryside, none more so, I would suggest, than our local planning authority.
“So, how does the draft Tunbridge Wells Local Plan measure up in terms of protecting our cherished countryside? Not well, in my estimation.
“The plan is, of course, the product of a broken planning system, driven by political and commercial interests that are wholly divorced from the needs of the population as a whole and wishes of local communities, including this one.
“It is inconceivable that Tunbridge Wells Borough Council would have come up with a plan of this nature in the absence of the housing and other targets imposed by national planning policy.
“There is now no pretence that the targets are based on genuine predictions of household growth and housing need, for the most up-to date Office of National Statistics data on population growth and household formation have been ignored by national government, in order to adhere to a totally arbitrary and unachievable target of building 300,000 homes a year (that is homes built anywhere and of any type, regardless of housing need).
“The rationale for this target has been challenged in recent research by Ian Mulheirn, published by the UK Collaborative Centre for Housing Evidence, which concludes that no more than 160,000 homes per year need to be built to cater for housing need.
“This topic is highly controversial, but for us in Tunbridge Wells, the key point is that the right homes for the people in this borough are built in the right places.
“The homes which are built should be affordable to those in need of a home and built in the most environmentally sustainable places, not simply the sites that yield the highest profit to developers.
“This means that houses should preferably be built on brownfield or urban infill sites, or as limited urban extensions, always making the most efficient use of land, rather than in new settlements on greenfield sites, and especially not in protected landscapes.
“The council seems to agree with this in principle, but not in practice. CPRE naturally wishes to see Tunbridge Wells adopt a sound Local Plan as this will give the local authority a measure of control over future development and better defences against inappropriate, speculative development proposals. “However, a sound Plan is not a panacea. Factors beyond the council’s control may (and probably will) undermine the Plan during its 15-year life, probably sooner rather than later.
“These factors include changes in the deliverability of individual sites, failure to build out planning applications which have been granted and, in these febrile political times, changing requirements of national policy.
“As soon as the council’s housing policies are shown to be out of date, the developers will again have the whip hand.
“A ‘Sound Plan’ is therefore not to be bought at any price and the price of this draft Plan is, in CPRE’s view, far too high.
“Tudeley Village is just the most egregious example of the sacrifice of greenfield sites for substantial housing development in the Green Belt, in the High Weald Area of Outstanding Natural Beauty and elsewhere in the borough.
“This sacrifice is made in pursuit of housebuilding objectives that, even in the unlikely event of their being achieved, would do little to meet the genuine local need for housing, at prices local people can afford.
“The council say that they place the highest priority on protecting the AONB and then the Green Belt, but this is not the impression I gain from the proposed site allocations throughout the borough.
“If Tudeley Village is intended to relieve the pressure on the rest of the borough, it does not achieve this, even in protected areas. In my own parish of Cranbrook and Sissinghurst in the AONB, for example, the housing allocation exceeds assessed local needs by about 50 per cent.
“What can the council do, though, in the face of seemingly implacable national policy requirements?
“In our view, national planning policy does allow Tunbridge Wells to provide for less than the so-called objectively assessed housing need, in view of the high proportion of the land in the borough which is protected as Green Belt or AONB.
“This ability is fundamental to the effective protection of the Green Belt and AONBs. If it were not there, the Green Belt and AONB would be less protected in those districts in which they form a large proportion of the land area than in those where only small areas are protected.
“This is not the law, or the policy of government.
“The council say that they have not even considered the possibility of providing for less than assessed housing need, because their Strategic Housing Land Assessment shows that the borough can accommodate this need. However, it is hard to see how they have reached this conclusion.
“Their Sustainability Assessment shows that the council’s housing objective is compatible with only five of the 19 sustainability objectives they have set themselves and incompatible with nine of them.
“It is the only objective in the Plan which fails the council’s sustainability tests in this way. This is a fundamental contradiction in the Plan. It does not provide for sustainable development in Tunbridge Wells on the council’s own terms, and it must be changed.
“I haven’t said much about how the technicalities of planning policy apply to the overarching subject of the climate emergency, which rightly moves ever higher up the political agenda, including the planning agenda.
“It is far from clear to me that the council gives adequate weight to mitigating climate change in this Plan. That is a wider topic than we can embark upon today, but an aspect of it is specifically relevant to the Tudeley Village proposal.
“Under the government’s climate change guidance, planning authorities are advised that the distribution and design of new settlements and sustainable transport solutions are particularly important considerations that affect transport emissions.
“The planning inspectors have within the past week rejected the draft West of England Spatial Plan, saying that high levels of dispersed development across the West of England, unguided by any strategy, would not be sustainable. I understand that this Plan included a number of so-called ‘garden settlements’ on greenfield sites.
“It would seem that garden settlements are going to be looked at closely by inspectors and this should make Tunbridge Wells Borough Council think twice before trying to meet its housing objectives in this way.
“Tudeley Village is the poster child for the unsustainability of this draft Plan. It represents unsustainable, environmentally harmful destruction of the countryside, replacing a beautiful, unspoilt and protected site with a dormitory for City commuters and their families, heavily reliant on their private cars for transport.
“It will destroy local communities and ruin local residents’ lives. It must be stopped and CPRE Kent will support you in your campaign.”

  • You can read the latest Save Capel newsletter here

Tuesday, October 8


  • A number of important documents have yet to emerge. For example, a rigorous transport plan and a finalised air-quality assessment. The latter is critical given that allocations at Teynham will feed extra traffic into AQMAs.
  • There seems to be no coherent plan for infrastructure delivery – a key component of the plan given the allocations being proposed near the already crowded Junction 7.
  • There seems to have been little or no cooperation with neighbouring boroughs or even parish councils within Swale itself.

The removal of a second consultation might have been understandable if this final version of the plan were similar to that being talked about at the beginning of the consultation process. It is, however, radically different in the following ways:

  • There has been a major shift in the balance of housing allocations, away from the west of the borough over to the east, especially around the historic town of Faversham. This is a move that raises many concerns.
  • A new large allocation, with accompanying A2 bypass, has appeared around Teynham and Lynsted, to which we are objecting.
  • Housing allocations in the AONB around Neames Forstal that were judged “unsuitable” by the council’s own officers have now appeared as part of the housing numbers.
  • Most of the housing allocations being proposed are on greenfield sites, many of them on Grade 1 agricultural land – a point to which we are strongly objecting.

Concerns about the rush to submit the plan

The haste with which the plan is being prepared is especially worrying given the concentration of housing in Faversham. If the town is to take a large amount of new housing, it is imperative that the policies concerning the area are carefully worked out to preserve, as far as possible, the unique nature of the town. The rush to submit the plan is likely to prove detrimental.

As Swale does not have a five-year land housing supply, it is open to speculative development proposals, many of which would run counter to the ideas contained in the current plan. Some are already appearing. This is a common situation, and one that, doubtless, is a reason behind Swale’s haste.

Our overriding fear, however, is that this emphasis on haste is ultimately going to prove counterproductive. This is because it is our view that the plan, in its current form, is unlikely to pass independent examination. We are urging Swale to listen to and act upon the comments being made about the plan and to return the plan to the council with appropriate modifications before submitting it to the Secretary of State.

Essentially, this means treating the current consultation not as the final one but as the ‘lost’ second consultation.

The consultation ends on Friday 30 April and we strongly urge residents to make their opinions known if they have not already done so.

Further information