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Tunbridge Wells Local Plan chops Green Belt to allow for housing development

Elementary Admin
By Elementary Admin &
9th September 2019

Tunbridge Wells countryside (pic Gabrielle Ludlow)

To a mixture of horror at what it
includes and relief that it has finally seen the light of day, the Tunbridge
Wells draft Local Plan has finally been published.
Covering the period 2016-2036, the Plan is aimed at replacing the local authority’s
2010 core strategy, 2016 site allocations plan and saved policies from its 2006
Local Plan.
Most contentiously, the draft looks to axe more than 5 per cent of the
borough’s Green Belt, primarily to accommodate 14,776 new homes, a figure that
includes a 9 per cent buffer above the government’s Objectively Assessed Need
total of 13,560.
The homes are apparently going to be built at a rate of 678 a year, a target
substantially more than double the 300-a-year featured in the 2010 core
strategy, produced in line with the former South East Plan.
Disappointingly, the draft does not designate any land to compensate for the
Green Belt that is set to be lost, which, as it stands, amounts to 5.35 per
cent of the current total.
The largest housing allocations are at Paddock Wood (4,000 dwellings in addition to the 1,000
already allocated) and Tudeley (2,500-2,800, with some 1,900 to be built
during the Plan period), as well as some 800 dwellings in the AONB at Cranbrook and 700, also in
the AONB, at Hawkhurst.    
Liz Akenhead, chairman of CPRE Kent’s Tunbridge Wells committee, said: “The Plan states that, overall, some
5.35 per cent of the Green Belt within the borough is to be de-designated and
that ‘in accordance with the NPPF the Plan does not designate other land as
“replacement” Green Belt to replace that to be removed, but rather sets out how
compensatory improvements to the environmental quality and accessibility of
remaining Green Belt land can be made’. 
“On a first reading, I have not noticed any evidence in the Plan that these
improvements will actually materialise.”
Consultation on the draft Plan begins on Friday, September 20, and is scheduled
to end on Friday, November 1. It is anticipated that the Plan will be adopted
in December next year.

  • For more on the Tunbridge Wells Local Plan, see here

Monday, September 9, 2019


  • 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