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Tunbridge Wells housing numbers too high
We have responded to the latest consultation on Tunbridge Wells local plan challenging the huge housing numbers planned which would cause severe environmental damage, loss of countryside, green space and ancient woodland.
CPRE Kent’s Tunbridge Wells committee has raised many concerns in its comments on the Issues and Options consultation.
We dispute the need to provide 650 to 700 houses per year. Given that employment growth in the borough in the 21 years from 1991 to 2013 was zero, the jobs forecasts which project an ever-rising volume of employment seem unduly optimistic and if the increase in jobs is not forthcoming, this volume of housing development could turn the borough into a dormitory for businesses elsewhere. The population and household formation forecasts on which the housing need assessment is based may also be too high.
Committee chairman Elizabeth Aikenhead said: “Most importantly, housing development on this scale together with its infrastructure clearly cannot be accommodated in a borough with so many environmental constraints without causing serious damage to the environment.”
It is also contrary to the requirements of the National Planning Policy Framework. CPRE Kent does accept that there will have to be new development within the borough but this should continue to be at no more than the rate previously required under the Core Strategy. Even that amount of development will be very difficult to provide without serious environmental damage.
Taking the proposed Strategic Options one by one,
Option 1 (focused growth) would result in the loss of large areas of exceptionally beautiful and supposedly protected countryside around Tunbridge Wells and Southborough, Cranbrook and Hawkhurst. It would lead to the erosion or indeed the possible total loss of the remaining green spaces between Tunbridge Wells/Southborough and Rusthall, Bidborough, Pembury and Tonbridge, contrary to Green Belt and Area of Outstanding Natural Beauty (AONB) policies. The area between Tunbridge Wells/Southborough, Pembury and Tonbridge contains rare lowland heathland, ancient woodland and the new woodland which is being planted to replace the loss of ancient woodland to the A21 dualling. An attempt to concentrate the development within the towns could destroy the towns’ historic centres by requiring high-rise buildings and garden grabbing, and in any case given the very limited availability of brownfield sites this would be insufficient to meet the proposed housing requirement.
Option 2 (semi-dispersed growth) would have much the same effect as Option 1 but would also destroy countryside around Brenchley, Five Oak Green, Goudhurst, Lamberhurst, Pembury and Rusthall, all of which is either in the AONB or the Green Belt, or both. The large amount of new housing would substantially alter the character of these villages.
Option 3 (proportionally dispersed growth) would have many of the same disadvantages as Options 1 and 2, with the addition of loss of countryside around the other villages in the Borough. While all the villages will need to be allowed to grow to some extent, the development that could be required of them under this option may be excessive.
Option 4 (growth corridor along the A21) would lead to ribbon development with many of the same disadvantages in terms of loss of valuable countryside as Options 1, 2 and 3. It would also absorb Pembury into the Royal Tunbridge Wells/Southborough conurbation, contrary to the purposes of the Green Belt. Given the amount of land required for the number of houses envisaged, it is unlikely to provide enough land without the loss of large areas of AONB and green belt land, including lowland heathland, ancient woodland and new woodland planted as mitigation for the loss of ancient woodland to the A21 dualling, and some exceptionally beautiful AONB countryside south of the A21 between Pembury and Kippings Cross. The ancient monument at Castle Hill could be affected. For houses built close to the A21 there would be noise, light and probably air pollution.
Option 5 (a new “garden village” settlement), far from being a village, involves creating a new town at least twice the size of Paddock Wood. We cannot see a suitable location within the Borough for such a huge greenfield development, which in order to be successful should have its own railway station or else a very good connection to an existing station or major road, which in turn would require the loss of further countryside for a tramway and/or large new road. In any case, given the lead-in time required for such projects, this option would not meet the housing and employment requirement in the earlier years of the plan period so it would have to be combined with major development elsewhere in the Borough. It only scores well in the Council’s Sustainability Appraisal on the assumption that it will not affect the AONB or the Green Belt, which leaves the area to the east of Paddock Wood (floodplain), the north of Horsmonden and Goudhurst parishes (both of which are former Special Landscape Areas and affect the setting of the AONB) or the Frittenden-Sissinghurst area (former Low Weald SLA and setting of AONB). As it is the only option which does not specify a location, the Council should treat any public support for Option 5 with great caution, since it represents a vote for “anywhere but here”.
To read the full response click here.
June 14th 2017.
- 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
