Tunbridge Wells Borough Council Draft Local Plan - Regulation 18 Representation on behalf of the Hadlow Estate – Tudeley Village

November 2019

1 2 Contents

1. Introduction 4

2. The Case for Tudeley 5 –– Housing Need –– Spatial Strategy –– Proposed Vision

3. Delivery 11

4. Sustainability Appraisal 16

5. Amendments to Policies 18

Appendices

Appendix A – Review of Housing Need 24

Appendix B – Overview of Garden Villages in the UK tradition 44

List of figures

Figure 1 – ‘Figure 5.4: Business Premises in Tunbridge Wells, 6 February 2016’

Figure 2 – Existing green networks at Tudeley 11

Figure 3 – NHLE-designated heritage assets within study site 12 and 1km search buffer shown

3 1. Introduction

1.1. This representation is submitted on behalf of the specific and targeted objections. Notwithstanding Hadlow Estate concerning Tunbridge Wells Borough this, the changes suggested in this representation are Council’s spatial strategy and specifically, the easily remedied and we clearly set out how the Plan allocation of a new village at Tudeley under Policy can be improved to enhance the clarity of the Spatial AL/CA 1. Vision and its delivery.

1.2. The Estate recognises the acute housing shortage 1.7. Our representation is structured as follows: In facing the Borough, indeed the country, and has Section 2 we set out the case for Tudeley Garden supported the principle of a new community at Village with particular emphasis on ensuring the Tudeley on the basis that it will be seen in the same supporting evidence base is clearly expressed i.e. context of the approach adopted by the Prince’s justified and effective in accordance with the tests Foundation at Poundbury, Tregunnel Hill and of Soundness. In support of this analysis, we explain Truro, as well as other landowners in Scotland at why Tudeley goes beyond the general garden Tornagrain and Chapelton. settlement principles set out in the draft Plan.

1.3. To rank alongside these projects, Tudeley Village 1.8. We then discuss the additional evidence Hadlow requires a long-term commitment and involvement Estate is collecting in support of the proposal within throughout the planning and construction process. Section 3 which will move us towards a delivery plan At the conclusion of the project, the new village for the proposed development. will be regarded as nationally significant in terms of UK town planning: that is the standard that will 1.9. Sections 2 and 3 have informed specific changes we be delivered. This is consistent with the values and would like to make to the wording of the Draft Plan tradition of the Hadlow Estate which has a 170 year to ensure its Soundness and these are set out in connection to the history and stewardship of the Section 4. land and will live alongside Tudeley Village once the project completes.

1.4. Freed from the burden of purchasing land or retuning dividends to shareholders, the Hadlow Estate can invest in placemaking and create an exceptional and vibrant community with high quality housing. Tudeley Village is therefore distinct from any other strategic proposition in the Draft Plan.

1.5. Therefore, whilst we naturally support the general aspirations and content of the Plan which has been positively prepared, it is important for the emerging policies to align completely with the aspiration of the Estate and our intended delivery process so that the Council’s spatial vision and aspiration for Tudeley Village are fully realised. On that basis we make a series of corrections and adjustments to the Draft Plan.

1.6. The following comments should therefore be registered as Conditional Support for the overall Draft Plan, whereby our client would likely raise no objections, provided our suggested modifications are incorporated in order to put the Draft Local Plan on a Sound footing. However, there are some Development Management Policies where we raise

4 2. The case for Tudeley

2.1. We have reviewed the Draft Plan and its supporting additional housing need. This should be material to assist the Council in ensuring the resolved now in advance of Submission. evidential basis for the Plan is both robust and justified, particularly in its identification of Tudeley 2.4. The Draft Plan is therefore positively prepared, but as a new village for 2,500 – 2,800 homes. We begin further work is needed to ensure it is consistent with with the macro issues which drive the need for the national policy and justified. new Local Plan i.e. Housing Need, before moving to the response to that need, the Spatial Strategy and the clear justification for selecting the site. Spatial Strategy We conclude with some commentary on how the principles of a new garden community at Tudeley 2.5. The Council has undertaken a rigorous process to are expressed and what it actually means in terms of construct an evidence base that justifies its proposed Tudelely becoming an exemplar development in the Development Strategy: tradition of notable UK Garden Villages. a. The Borough constraints have been mapped:

Housing Need b. Development Constraints Study; The potential for expansion of existing settlements has been 2.2. Appendix A, Stantec have undertaken an audit of assessed: Limits to Built Development Topic the Council’s approach to assessing housing need Paper; to ensure that it accords with National Planning Guidance. Although the approach has been found c. In particular, the capacity of the landscape to be positively prepared, there are areas which the around the principal urban centres at Council need to address to ensure the Plan is as Tunbridge Wells and Southborough has been robust as possible before Submission. reviewed: Landscape Sensitivity Assessment;

2.3. These matters include: d. Consultation on growth options has taken place: Distribution of Development Topic a. More headroom in terms of overall housing Paper; numbers is required to manage potential risks such as for example, addressing unmet e. The relative sustainability of the Growth need arising from neighbouring authorities or Options has been assessed: Interim future revisions to the Standard Method; Sustainability Report;

b. The Plan period may need to be extended to f. An understanding of the quantum and address potential delays so it is compliant location of land that could come forward for with paragraph 22 of the NPPF which requires development has been established: Call-for- a 15 year plan period from adoption; sites and SHELAA.

c. An extension of 5 years to the plan period 2.6. The Distribution of Development Topic Paper would give the Council additional ‘headroom’ helpfully brings these matters together to explain to manage these risks before the shortfall the steps that led to the proposed Development requires to be plugged; Strategy within the Draft Plan. It should be noted however, that the Issues and Options consultation, d. The Council should not include its housing whilst highlighting the constraints associated backlog in the Standard Method: its housing with the different growth options, did not directly need should be re-set from submission; and spatially relate the Growth Options to the Development Constraints. The responses to the e. Finally, the Council needs to update its Growth Options are therefore potentially abstract, economic evidence which is not in step with particularly when contrasted with the detail of the its housing evidence and may point towards responses in the Issues and Options Consultation

5 Figure 5.3: Business Premises in Sevenoaks – February 2016

Source: CoStar, 2016; Turley, 2016

Figure 1 - Figure 5.4: Business Premises in Tunbridge Wells – February 2016 ‘Figure 5.4: Business Premises in Tunbridge Wells – February 2016’

Source: CoStar, 2016; Turley, 2016

Statement which prioritise the preservation of the 2.9. Although economic factors are assessed within AONB and therefore directly aligns with paragraph the individual options for new communities in 172 of the NPPF demanding ‘great weight’ is Table 3 of the Distribution of Development Paper, attached to conserving their landscape and scenic as a key principle influencing development 70 beauty. strategy, this point is not expressed sufficiently. Locating development distant from these strategic 2.7. Limiting the extent of development within the AONB employment and service centres, irrespective of the should therefore be a key finding of the Issues and degree of containment sought for new communities, Options consultation and should be highlighted as would not be sustainable as it would give rise to such to ensure the Development Strategy is situated higher out-commuting and would not be sustainable. on a firm, evidential and justified basis. This is not the case at present, although the assessment 2.10. The need to relate new development to these of allocated sites inside the AONB within the economic centres prevents effective consideration Distribution of Development Topic Paper appears of areas east of Paddock Wood, which are not robust. constrained by Green Belt. Therefore, whilst the Distribution of Development Paper sets out a 2.8. The other key factor to consider in locating clear case for the release of land from the Green development is proximity to the key employment Belt, identifying the Exceptional Circumstances at hub of Tunbridge Wells, Paddock Wood and Paragraph 6.48, this must be amended to make clear Tonbridge, as evidenced in the Economics Needs the need to locate development sustainably, i.e. in Study (August 2016) and in particular, Figure 5.4 (see amongst existing economic centres. This clarity will Figure 1, above). complete the evidential base on which the proposed

6 Development Strategy is based, justifying it and 2.16. In that document they identified the following: therefore making the Draft Plan Sound. a. Clear identity – a distinctive local identity 2.11. We have undertaken an independent analysis of as a new garden community, including at its the Council’s evidence base in respect of the review heart an attractive and functioning centre and of the Green Belt and this analysis is set out in public realm. Section 3. It reaffirms the findings of the Council in this respect, but we return to this report later in b. Sustainable scale – built at a scale which terms of its main focus on identifying a defensible supports the necessary infrastructure to allow boundary for the proposed allocation. the community to function self-sufficiently on a day to day basis, with the capacity for future 2.12. However, we do consider that the Exceptional growth to meet the evolving housing and Circumstances should be elevated into the Draft economic needs of the local area. Plan, at the end of Section 2 so they provide a link between Challenges and Opportunities c. Well-designed places – with vibrant mixed and the response, i.e. the Vision, Objectives and use communities that support a range of Development Strategy. This would clearly evidence local employment types and premises, retail and justify the spatial strategy in response to the opportunities, recreational and community survey of the Borough. facilities.

2.13. Therefore, whilst we have suggested modifications d. Great homes – offer a wide range of high to how portions of the evidence base need corrected quality, distinctive homes. This includes or enhanced to make the proposed spatial strategy affordable housing and a mix of tenures for all Sound, we are in support of the principle that stages of life. Tudeley Village, as a new community, is the least harmful, yet most sustainably located spatial e. Strong local vision and engagement – response to accommodating housing need in the designed and executed with the engagement Borough. and involvement of the existing local community, and future residents and businesses. This should include consideration Proposed Vision for the Draft Plan: Upholding of how the natural and historic environment of the local area is reflected and respected. the principles of a Garden Community f. Transport – integrated, forward looking and 2.14. On the basis the overall spatial strategy is sound, accessible transport options that support subject to evidential changes and enhancements, we economic prosperity and wellbeing for now examine the proposed Vision in the Draft Plan residents. This should include promotion of insofar as it relates to Tudeley Village. public transport, walking, and cycling so that settlements are easy to navigate, and facilitate 2.15. The Vision is very specific in referring to Tudeley simple and sustainable access to jobs, Village as a ‘garden settlement’ that will be subject education, and services. to garden settlement principles. These principles are not defined in the draft Local Plan but in the g. Healthy places – designed to provide the Distribution of Development in Table 3, the selection choices and chances for all to live a healthy criteria for a site is linked to paragraph 72 of the life, through taking a whole systems approach NPPF. The assessment of Tudeley Village is related to key local health & wellbeing priorities and to the Garden City principles in this paragraph, strategies. as articulated by the Town & Country Planning Association and reflected in the Government’s h. Green space – generous, accessible, and good request for Garden Community proposals in their th quality green and blue infrastructure that Prospectus dated 4 June 2019. promotes health, wellbeing, and quality of

7 life, and considers opportunities to deliver environmental gains such as biodiversity net gain and enhancements to natural capital.

i. Legacy and stewardship arrangements – should be in place for the care of community assets, infrastructure and public realm, for the benefit of the whole community.

j. Future proofed – designed to be resilient places that allow for changing demographics, future growth, and the impacts of climate change including flood risk and water availability, with durable landscape and building design planned for generations to come. This should include anticipation of the Letchworth Garden City opportunities presented by technological change such as driverless cars and renewable energy measures.

2.17. It is recognised that many developments around the country will state they comply with these principles and this will be the case to a greater or lesser extent. However, the Hadlow Estate are seeking to place Tudeley Village firmly within the tradition of Garden Village planning in the UK as seen in Letchworth Garden City, Welwyn Garden City, Port Sunlight and Bournville, now protected as Conservation Areas with many Listed Buildings and visited by town planners from around the world. An overview of the history and significance of these communities, and why they matter today, is provided in Appendix B.

Tornagrain 2.18. The legacy of these communities has inspired others, including the Hadlow Estate who ally themselves with the work of other estate landowners at, for example, Poundbury, Chapelton and Tornagrain.

2.19. These developments have three characteristics which the majority of other planned garden communities cannot deliver and the principles set out above by Government do not adequately capture:

a. Landowner-led: the presence of a single, long-term landowner with a vested interest in the site and an aspiration towards leaving a legacy is in contrast to the majority of new development schemes where a developer has no long-term financial stake in the land. Their Poundbury priorities lie in the immediate satisfaction of

8 their shareholders. The difference this makes is enormous. Development by a single, long-term landowner is, arguably, the only route that allows an extended, measured view of development. The ability to adopt a patient perspective on financial returns creates considerable opportunity to innovate beyond the norm. With it, the premium that highly crafted construction, well-considered design and mixed use will reap over time can be appreciated. Ultimately, this will secure a better place in the long run. This approach is grounded in the principle of capturing uplift that informed the original Garden Cities and model villages. Both Letchworth and Welwyn were, for example, delivered by single bodies acting as the landowner, which were able to capture the land value uplift resulting from development. This uplift then financially supported the delivery of the towns’ physical and social infrastructure. The process of capturing land value gains takes time, Landowner legacy: Letchworth Garden City though, and thus is often not attractive to conventional investors. b. Mixed use: Commercial and employment uses are firmly integrated within the residential fabric of the community, including the ability to ‘live over the shop’. This level of integration is often too complex for more simplistic developments to accommodate as they inevitably rely on larger contractors delivering single-use development plots. This leads to a physical separation and disaggregation between housing and non-residential uses. The free-standing neighbourhood centre clustered around a car park is anathema to a square, high street or high road. Moreover, developments such as Poundbury would boast that it has as many jobs as it has residents, whilst Chapelton had 30 employees by the time it had only 125 occupations. Conventional housing developments cannot deliver these statistics. Mixed use: Chapelton

9 2.20. Their roles can be summarised under two main functions:

• Design regulation, via building codes applicable during initial development and any subsequent alterations

• Maintaining common, unadopted areas of the community

2.21. In so doing, they act as a vehicle for sustaining and protecting in perpetuity the unique features of the settlement – its buildings, public realm, facilities and their characteristics and identity – that encourage civic pride, identity and interaction. This in turn leads to greater value being placed upon community spirit, encouraging sound investment and creating benefits for those who live, work or visit the settlement.

2.22. This long-term, guardianship role is very different from the objectives of the private management companies set up to service residential estates that are found across the country. The latter are used by developers as a means of disposing of the obligation Stewardship: Welwyn Garden City and liability of maintaining non-adopted space without the cost of providing resources for future maintenance, such as an endowment or commuted c. Stewardship: Long-term landownership also sum. facilitates long-term stewardship. It captures the original ethos of Garden City governance, 2.23. These principles in operation are illustrated with which meant that stewardship was Case Studies in Appendix B. We therefore see undertaken for the benefit of the community the new community set out in the Vision as going and that the community had a stake in the beyond ‘garden settlement principles’ and will seek settlement’s future. For the original Garden the appropriate changes to the text to ensure it the Cities, model villages and contemporary Vision is Effective. exemplar planned settlements, having a collective vision was fundamental to building 2.24. The Estate therefore has the means and control momentum in the creation of community over the land to deliver the Vision in the Draft Plan identity. Stewardship bodies have historically, against the benchmark of those which sit firmly and continue to be, valuable means of within the historic tradition of garden villages, as supporting this vision. opposed to the broader principles articulated by the Government.

10 3. Delivery

3.1. Notwithstanding the draft status of the Plan, the species rich hedgerows; scrub; traditional orchard; Estate has progressed with its own evidence base to and tree canopies (outside of woodland) as support delivery, namely: interpreted from aerial photos.

Ecological Appraisal: 3.5. The Appraisal has identified sites of existing high ecological value including veteran trees and four 3.2. A preliminary ecological appraisal has been areas of ancient woodland, which will be retained undertaken to inform the development of the and protected as part of any future development. To Tudeley Village proposal. This comprises a Phase 1 this end, buffers are suggested around key habitats habitat mapping survey and a desk-based ecological based on best practice (Woodland Trust) guidance assessment and builds on recent review of existing that suggests a minimum 50m no development biological information for the Site and local area stand-off buffer around ancient woodland. Further provided by the Kent and Medway Biological Records ecological work in line with seasonal timings and Centre. accepted practice for gathering survey data is underway. 3.3. No land within the Site is designated by any statutory or non-statutory wildlife site designation, and the Site is not located close to any Site of Special Scientific Interest (SSSI) or other statutory designated wildlife site.

3.4. Figure 2 shows the Site’s existing network of high ecological value habitats – namely: woodland; Tudeley Village Kent Figure 2 - Existing green networks Tudeley Village KeExistingnt green networks at Tudeley Site boundary Existing green networks Ancient woodland (with 50m buffer) Woodland, species-rich hedgerows, scrub, and neglected traditional orchard (with 15m buffer) Site boundary indicative tree canopies based on Ancient woodland (with 50m buffer) ! aerial photograph interpretation (with 5m buffer) Woodland, species-rich hedgerows, scrub, and neglected traditional ponds orchard (with 15m buffer) indicative tree canopies based on ! aerial photograph interpretation (with 5m buffer) ponds

Figure XX

Map Scale @ A3: 1:6,500

Figure XX Surveyed by: RJH Survey date: n/a Map Scale @ A3: 1:6,500 Drawn by: RJH ´ 0 150 300 metres Checked by: DP Status: Draft Surveyed by: RJH

Reproduced from Ordnance Survey digital map data © Crown copyright 2016. All rights reserved. AEL1707_003-00_woodedhabitats_20191015 A3 15/10/2019 Survey date: n/a Drawn by: RJH ´ 0 150 300 metres Checked by: DP Status: Draft

Reproduced from Ordnance Survey digital map data © Crown copyright 2016. All rights reserved. AEL1707_003-00_woodedhabitats_20191015 A3 15/10/2019

11

10 3.0 Heritage Baseline Introduction and scope of study 3.1 This appraisal will consider the potential effects of development within the study site on the significance of designated heritage assets, including through effects to their settings. This will include any heritage assets within the study site, and those in the surroundingHeritage Appraisal: area, whose setting may be affected. This section3.7. Theof the above appraisal constraints will were carefully considered also consider potential design responses which may be taken toand avoid it was impacts found that, and provided approrpiate spatial reduce3.6. An potential initial Heritage harm. Constraints Appraisal has been design responses are provide for within the proposed undertaken, which established a ‘heritage baseline’ new settlement, it would be possible to deliver the 3.2 Heritagefor assetsthe site areaand (pluspotential a 1km impacts buffer zone), will be identifying assessed using bestdevelopment practice, of including Tudeley Village while preserving the that setareas out ofin particularHistoric England’s value as shown Good on Practice Figure 3. AdviceSuch Note 3,significance The Setting of ofthe Heritage Church of All Saints’, Somerhill Assetsareas (HE include:2017). The heritage assets which require assessmentHouse have and been registered selected park and the buildings in with reference to the National Heritage List for England (NHLE)Tudeley database and heldTudeley by Hall. Any residual harm to the Histori•c England,The grade as well I listed as Churchinformation of All Saints’held by and the LPA on conservationlisted buildings areas at Bank and Farm, Lilley Farm and those heritage assets.nearby Not listed all assets buildings will require detailed assessment;present in accordance along the southernwith boundary of the site on paragraph 189 of the NPPF, the level of detail will be proportionatethe Five to theOak heritageGreen Road would be kept to a low level asset’s• significanceThe listed and buildings no more at Bank than Farm is needed and Lilley to understandof the less potential than substantial impact harm,of with the potential to Farm in the centre of the study site avoid harm and/ or provide enhancements in some development on their significance. instances. 3.3 A basic• searchThe area listed of buildings 1km from present the study along sitethe boundary (the study area) was used to identify any designatedsouthern boundary heritage of theassets study which site, along may be affecte3.8. d Theby theremaining development designated of heritage assets in the the study siteFive (see Oak Fig. Green 2). RoadThe study site and surrounding areasurrounding were also subjectarea were to also a appraised and it is not site visit in October 2019, to assess the setting of the assets identified.considered that these would constrain the delivery of • The listed buildings in Tudeley the proposed new settlement. However, they would 3.4 There are 78 listed buildings and one registered park and gardenstill wit requirehin the assessment study and consideration as the area. In• addition,The listed the widerbuildings area at beyondTudeley Halethe buffer was also reviewedproposed for settlement any highly design is developed further and sensitive assets with wider settings which could be affected andin asany a future result planning Somerhill application. House• and theViews Hadlow from Somerhill Tower are house also and considered. park

Figure 3 - NHLE-designated heritage assets within study site and 1km search buffer shown

Figure 2 NHLE designated heritage assets within study site and in wider area, with 1km serach buffer shown (mapping: ©OpenStreetMap contributors) 12

Land proposed for a new October 2019 settlement at Tudeley, Kent

Archaeological Appraisal: evident that development at the site would be seen from the AONB and seen within the setting of the 3.9. An initial review of archaeological potential has AONB. However, whilst being in the foreground confirmed that the study site has a moderate of views out from the AONB, the assessment has potential to contain prehistoric, Saxon and Medieval demonstrated that only a very small part of the evidence and known heritage assets from the Post- new development would be visible and from only a Medieval period. There is also potential for remains very limited number of locations. The assessment associated with the Saxon and Medieval occupation considers that these visual effects would also be at Tudeley to be present in the westernmost part capable of being substantially moderated through of the study site, primarily close to the Church of suitable mitigation proposals (e.g. the precise All Saints’. Post-Medieval remains would comprise location of the development, landscape planting and buried remains associated with the occupation of its early phasing) and, consequently, any adverse the farmsteads at Bank Farm and Lilley Farm, which effects on the setting of the AONB are capable of would be focussed on the extent of the historic being moderated. farmsteads. Green Belt Review 3.10. The assessment of archaeological potential on site concluded that any remains are likely to be of no 3.14. The NPPF envisages that plan-making authorities more than local interest. Given this, it is considered may move Green Belt boundaries in order to deliver that the loss of any archaeological remains within sustainable and objectively assessed development the study site could be adequately mitigated via a needs, where there are fully justified exceptional staged programme of archaeological works including circumstances. Authorities must have regard to mitigation works to adequately record any remains the likely permanence of any revised Green Belt which would be lost as a result of the proposed boundaries which should reflect the strategy development. Approrpiate recording and publication for meeting identified requirements and for would enhance our understanding of these periods safeguarding land outside the revised Green Belt of settlement. that may be required for future development needs beyond the plan period. Landscape and Visual Appraisal: 3.15. The Council has defined in the Distribution of 3.11. An initial appraisal of the landscape setting for Development Topic Paper, September 2019, the Tudeley has been prepared. exceptional circumstances that they consider exist for the release of Green Belt land within the borough. 3.12. The High Weald Area of Outstanding Natural These include, the extent of Green Belt and AONB Beauty Management Plan 2019-2024 defines five constraints, the acute need for development land components of character that make the High Weald a to be brought forward through the Local Plan and recognisable, distinct and homogenous area. These the inability for neighbouring authorities to assist include the following; (1) Geology, Landform, Water in meeting Council’s need. They consider that they Systems and Climate, (2) Settlement, (3) Routeways, have maximised the use of urban sites, optimised (4) Woodland and (5) Field and Heath. A further development densities and they have considered category of Other Qualities is also highlighted, which all suitable sites outside of the Green Belt (and, for include ‘People value the wonderful views and scenic major sites, outside of the AONB). beauty of the High Weald with its relative tranquillity’. It is considered that none of these components are 3.16. The council also consider further exceptional capable of being directly or significantly affected by circumstances exist for the release of the land for the Tudeley Village proposals, which lie outside the Tudeley Village. These are to provide mitigation AONB. measures to reduce flood risk associated with Five Oak Green and to offer an opportunity to deliver 3.13. Whilst Tudeley Village would lie outside the High development of exemplar design quality, with Weald AONB and, at this stage, the exact nature exceptional permeability and low levels of private of the development proposals is not known, it is car use. The Hadlow Estate is seeking to place

13 Tudeley Village firmly within the tradition of Garden developed at an early stage. As further Village planning in the UK and they ally themselves analysis is undertaken, the access strategy with the work of other estate landowners at, for may change from that suggested in the example, Poundbury, Chapelton and Tornagrain. Policy and alternative approaches may come These developments have characteristics which forward. It is therefore important to allow for the majority of other planned garden communities that flexibility in the draft policy; cannot deliver and the principles set out above by Government do not adequately capture. These • Establishing the nature of flooding issues characteristics, of being long term landowner-led at Five Oak Green and the hydrological with long-term stewardship, will be fundamental to relationship between that area and land in the delivery of the required exemplar design quality. and around the site identified for Tudeley Village; 3.17. The suggested Green Belt boundary, revised to accommodate Tudeley Village, is considered to • Related to the above, a strategy for provide for enough land to meet with TWBC’s Sustainable Urban Drainage, as well as strategic requirement for identified need and the waste water. This will include the necessary boundaries proposed by the Hadlow Estate are mitigation measures to protect the clear, using physical features that are recognisable Groundwater Source Protection Area. and permanent. No land has been included which is unnecessary to keep permanently open or that 3.21. This work is ongoing and discussions will be held is safeguarded between the urban area (as yet with key stakeholders, including the Highway undefined) and the new Green Belt boundary. Authority and Environment Agency. The Estate wishes to move towards a specific delivery plan for 3.18. Evidently, the development of the land for Tudeley Tudeley to support the Submission version of the Village would have a direct effect on the existing Local Plan. Green Belt and impact to some degree on the first three of the five purposes set out at Paragraph 134 of 3.22. The early involvement of our engineers has been the NPPF. However, the retained Green Belt between helpful in clarifying some aspects of Policy AL/CA 1 Tonbridge, Tudeley Village and Paddock Wood would so it is clearer and therefore Effective. These minor be clearly and robustly defined and would prevent modifications are set out in the following section. urban sprawl, neighbouring towns from merging with one another and safeguard the countryside Agricultural Classification from encroachment, into the long term. 3.23. Prior to 1988 different versions of the ALC system 3.19. We will be working with the Council to precisely existed. The original system dates from the 1970s define the new Green Belt boundary. and the grade criteria are different to those now in use. Moreover, there was no division of grade 3 into Infrastructure: subgrades 3a and 3b. The only national coverage of ALC information is made using this earlier system. 3.20. The Estate has commissioned advice on They are published at small scale (1:1,250,000) the necessary infrastructure to support the reflecting the fact they are based on very limited implementation of Tudeley Village, such as: density of field survey observations (often as low as 1 per square km) and rely on interpolation of published • The development of an active travel soil and geological maps. For these reasons and public transport strategy to ensure Natural England Statutory consultee advice is that: sustainable connectivity with key ‘these maps are not sufficiently accurate for use in employment centres to reduce demand for assessment of individual fields or development sites’. car-based travel; 3.24. Provisional mapping shows most of the site as • An access strategy that responds to the grade 3, with grade 2 in the north-west. However, requirements of Policy AL/CA 1 is being as explained above, this does not give an accurate

14 Relevant Ministry of Agriculture, Fisheries and Food detailed Agricultural Land Classification surveys in the locality of the Site:

Survey location Recorded BGS Recorded Soil ALC land grade Natural England geology Survey of England Report ref. and Wales soils West of Paddock Drift deposits (silt Park Gate All subgrade 3b R200/93 Wood and clay) Association

North-east of Drift deposits (silt Park Gate and All subgrade 3b R199/93 Paddock Wood and clay) Fladbury 3 Associations

East of Paddock Drift deposits (silt Park Gate series Subgrade 3b with R0628/91 Wood and clay) west Wickham series subgrade 3a (32%) Wealden Sandstone in east South-east of Wealden Sandstone, Whickham series Subgrade 3b with R528/91 Paddock Wood Head and Alluvium Denchworth series subgrade 3a (35%)

indication of the existence or otherwise of best and 3.28. The land to the north of the railway, including the most versatile land. smaller area of fruit production in the north-west is operated by a tenant as part of a wider holding 3.25. Several detailed surveys (to the current guidelines) which extends beyond the site. The loss of this have taken place in the local area. Those most land would have some impacts on the operation of relevant to estimating the grade of the (unsurveyed) their business, but this area of the site will not be land at the Site are those recorded on the same needed for some time. This allows sufficient time geology and/or soil type. for the tenant to plan or adjust operations. Indeed, the tenancy may revert back to the Estate before 3.26. The land at the site seems most likely to be development commences in this area. dominated by a mixture of subgrade 3b and 3a land. This is typical quality for the local area. The exact Consultation: proportions of each could only be determined by a detailed land survey, but this is the case with any 3.29. The Estate is keen to engage with the local proposed site. The effect on best and most versatile community and other stakeholders to begin a agricultural land is likely to be limited in the local visioning process for Tudeley Village. This process context and most of the site is likely to have soils of will commence alongside the Local Plan process no particularly high value. and will help inform the draft policies insofar as they relate to Tudeley Village. 3.27. The majority of the land is farmed by the land owners as part of a wider holding. The loss of this 3.30. These workstreams underline the commitment land would not compromise the sustainability of the of the Estate to be an effective delivery partner in wider farming business. There is a livery business implementing the Vision of the Draft Plan. owned by the Estate, but this is likely to be relocated ahead of development.

15 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.

16 Revised SA Appraisal for Garden Settlement Growth Option 9 - Table 16, SA of the Spatial Strategy

Sustainability Objective Garden Settlement Commentary Growth Option 1 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.

17 5. Amendments to Policies

5.1. The following proposed amendments have iii. A range of local services and facilities appropriate to arisen in response to the specific issues regarding the scale and function of the settlement; Soundness identified above. The following changes are considered necessary to ensure intentions are iv. The provision of appropriate open space, leisure, clearly expressed and the policies are Effective and and recreational areas, including informal and Consistent with National Policy: formal space, children’s and youth play space, sports pitches and allotments/food growing areas (see Policy OSSR 2: The provision of publicly accessible 5.2. Vision and Objectives 1 open space and recreation).

Vision Proposals shall accord with the following requirements:

A new garden settlement will have been established 1. All The development to shall be delivered through at Tudeley Village, including homes, employment, and a comprehensive masterplan approach led by the community facilities: this will continue to develop into landowner in consultation with the community, the following years. It will be well connected to other stakeholders, statutory consultees and the settlements, be an exemplar development in design, Council. The consultation process shall be clearly sustainability, and active travel, and will contribute to communicated and documented. Proposals for the strategically planned infrastructure, including reducing piecemeal development of individual sites will not (existing) alleviating flood risk to areas of Five Oak Green be supported; where possible ; i.e. resulting in ‘betterment’ for these areas; 2. All The development must demonstrate how it meets and embeds the key qualities below: 5.3. Tudeley Village i. Clear identity – a distinctive local identity as a 5.60 [Extract]: Would be subject to comprehensive new garden community, including at its heart masterplanning to ensure delivery of the allocation, an attractive and functioning centre and public including the proper provision of the necessary infrastructure, realm. including highway works, which is recognised as a major issue to be addressed by the masterplanning work, active ii. Sustainable scale – built at a scale which travel provision, a new secondary school, and a balanced supports the necessary infrastructure to allow the mix of uses, including housing, employment, and community community to function self-sufficiently on a day uses. It is likely that the land that will provide the routes of to day basis, with the capacity for future growth the transport links will be allocated within the Regulation 19 to meet the evolving housing and economic Pre-submission Local Plan; needs of the local area.

Policy AL/CA 1 Tudeley Village iii. Well-designed places – with vibrant mixed use communities that support a range of This site, as defined on the Capel draft Policies Map, is local employment types and premises, retail allocated for: opportunities, recreational and community facilities. i. Approximately 2,500-2,800 new dwellings, with approximately 1,900 to be delivered in the plan iv. Great homes – offer a wide range of high quality, period. The level and tenure mix of affordable distinctive homes. This includes affordable housing is to be determined through the Local Plan housing and a mix of tenures for all stages of life. and CIL Stage 2 Viability Assessment. This figure will be confirmed in the Regulation 19 Pre-submission v. Strong local vision and engagement – designed version of the Local Plan; and executed with the engagement and involvement of the existing local community, ii. The provision of appropriate employment within the and future residents and businesses. This should settlement; include consideration of how the natural and

18 historic environment of the local area is reflected criteria 2 and 10 of Policy EN 1: Design and other and respected. development management criteria, and Policy ED 3: Digital Communications and Fibre to the premises); vi. Transport –integrated, forward looking and accessible transport options that support 5. The masterplan shall be informed by detailed economic prosperity and wellbeing for studies within and surrounding the allocation that residents. This should include promotion of shall include land use, landscape character, visual public transport, walking, and cycling so that amenity, biodiversity and heritage. Particular settlements are easy to navigate, and facilitate attention will be given to: simple and sustainable access to jobs, education, and services. i. The grade of agricultural land and agricultural activities to minimise the effects on the rural vii. Healthy places – designed to provide the choices economy and agricultural functionality (see and chances for all to live a healthy life, through Policy EN 22: Agricultural Land); taking a whole systems approach to key local health & wellbeing priorities and strategies. ii. Key landscape characteristics, views and the setting of heritage assets and the setting of the viii. Green space – generous, accessible, and good High Weald AONB (see Policies EN 1: Design and quality green and blue infrastructure that other development management criteria, EN 20: promotes health, wellbeing, and quality of Rural Landscape and EN 7: Heritage Assets); life, and considers opportunities to deliver environmental gains such as biodiversity net gain iii. Existing habitats and species and opportunities and enhancements to natural capital. for landscape scale improvements for biodiversity to ensure a net gain for biodiversity ix. Legacy and stewardship arrangements – should focused on key locally important habitats and be in place for the care of community assets, species (see Policies EN 11: Net Gains for Nature: infrastructure and public realm, for the benefit of biodiversity and EN 12: Protection of designated the whole community. sites and habitats);

x. Future proofed – designed to be resilient places iv. The layout to particularly respect the setting of that allow for changing demographics, future heritage assets, especially All Saints’ Church, and growth, and the impacts of climate change to investigate how Hadlow Tower will be viewed including flood risk and water availability, with from within the development (see Policy EN 7: durable landscape and building design planned Heritage Assets); for generations to come. This should include anticipation of the opportunities presented by 6. The layout and design is to be of the highest technological change such as driverless cars and exceptional quality which raises the standard of renewable energy measures. design within Tunbridge Wells Borough., with exceptional The development shall be permeableility 3. The Council and the landowner/developer jointly to and with low levels of private car use within the lead the masterplanning approach; settlement. The design quality, as an exemplar, to be one of the justifications for the release of 4. The masterplanned approach is to include Green Belt land (see Policies EN 1: Design and other determining appropriate phasing of development, development management criteria and EN 20: Rural to be linked to the relevant and strategic delivery of Landscape); infrastructure, including in terms of surface water; in particular the provision of high quality, multiple 7. Opportunities to provide a higher density of benefit Sustainable Urban Drainage systems, foul development around the settlement centre and water, refuse collection, etc., utilising industry best other key points within the development should be practices and where feasible, new and emerging maximised, and structural landscaping and buffers technologies (see Water Policies EN 26 to EN 29, around perimeters of the site shall be provided (see

19 Policy H 4: Housing Density, criterion 3 of Policy EN 1: facilitate provision of bus routes within allocated Design and other development management criteria, sites, linking into wider bus network; and Policy EN 20: Rural Landscape). In particular, the masterplanning must have regard to the need to 11. Provision shall be made for appropriate education ensure the visual separation between Tudeley Village facilities, or contributions towards such facilities. and Five Oak Green, and the potential to feasibility of Development at this site is subject to the provision ‘undergrounding’ overhead power cables; of land for a new secondary school to the west of Tudeley Village (and to the east of Tonbridge) to 8. Provision of defensible boundaries at the site edges be allocated under Policy AL/CA 2, a new primary as part of a strategic landscape strategy to protect school within Tudeley Village, and provision for the and enhance the surrounding compensatory expansion of Capel Primary School, with delivery improvements to the environmental quality and linked to an overall delivery timetable (to be accessibility of remaining Green Belt within the determined through the masterplanning process); locality shall be made, to be agreed and secured through the masterplanning approach; 12. Provision shall be made for sports and recreation facilities (see Policy OSSR 2: Provision of publicly 9. Transport provision shall be delivered on a strategic accessible open space and recreation); basis, taking The transport strategy for the site shall take account of the impact of proposed 13. Provision shall be made for appropriate health development at land at Capel and Paddock Wood, facilities, or contributions towards such facilities; with having regard to transport infrastructure links between Paddock Wood, Tudeley Village, Tonbridge, 14. The development on the site should demonstrate and Royal Tunbridge Wells. A key element will be that it will not exacerbate flooding elsewhere in the determining the most appropriate route to link to vicinity, particularly from the Alder Stream at Five the road network to the east access strategy, which Oak Green, and that as part of the wider delivery shall minimise the impact on the existing highway the development delivers storage/attenuation/ network through Five Oak Green, and should seek mitigation, to reduce the flood risk to particular to reduce traffic levels through this settlement, existing residential areas in Five Oak Green. This is and have regard to Kent County Council minerals also one of the justifications for the release of Green allocations in the vicinity and sensitive receptors Belt land; such as Capel Primary School. Contributions will be required towards local transport improvements the 15. The settlement will be expected to include the provision of the potential offline A228 and eastward provision of a scheme of management and funding link to the A228 or land at Capel and Paddock Wood; for green spaces and green infrastructure for both amenity and biodiversity for the lifetime of the 10. A strategic approach to increase walking and cycling development. permeability will be included in the masterplanning (see Policy TP 2: Transport Design and Accessibility): 16. Regard should be given to the Groundwater Source development to be structured around direct walking Protection Zone which falls within the north of and cycling routes, linking new development with the site and the Environment Agency should be existing community facilities (e.g. primary school), consulted on any planning applications coming public transport, employment, and commercial forward. centres. Improvements to pedestrian/cycle links across the railway to be sought, subject to viability issues; the provision of longer distance cycle links to land at Capel and Paddock, Tonbridge, and villages surrounding Paddock Wood (leisure and utility); embracing new and emerging technologies and maximising public transport provision (frequency, linkages, etc.) using new technology. New development to be designed appropriately to

20 5.4. Other policies present any difficulties for its implementation, but we do not consider the policy necessary 5.4.1. Policy EN22 - Agricultural Land and sufficiently positive for inclusion in the Small adjustments are necessary to ensure Draft Plan. that issues of principle are not left to resolve following adoption of the Plan. 5.4.4. Policy H5 - Affordable Housing

Policy EN 22 Agricultural Land We do not consider this Policy to be justified or effective as it is overly prescriptive in The Local Planning Authority seeks to protect terms of the phasing of affordable housing best and most versatile agricultural land from and the type of tenures anticipated. Further significant, inappropriate or unsustainable viability evidence will be required to justify development. Where development of the approach taken. Moreover, the use of the agricultural land is required, applicants higher accessibility standard on all affordable should seek to use areas of poorer quality dwellings is not proportionate and will mean agricultural land in preference to that of those dwellings will have to be designed higher quality except where this would differently to their market housing neighbours be inconsistent with other sustainability which cuts across the aspiration for being objectives or other policies within this Plan. tenure blind in the preceding part of the Policy. Planning applications that would result in the loss of best and most versatile agricultural 5.4.5. Policy H11 - Self-Build and Custom land will need to justify why the loss of the Housebuilding agricultural land is acceptable and also assess the impact of the loss of the agricultural land We object to this policy on the grounds that on the wider farming resource and ecosystem it is not effective or deliverable to have a services. Where site specific ALC studies are situation where between 125-140 dwellings not available the Local Planning Authority will sit outside the control and oversight of a assume that the site is classified as best and coordinated design and infrastructure plan. most versatile. This is particularly the case in a community where there is strong central oversight, one of 5.4.2. Policy EN23 - Air, Water, Noise, and Land Air the key features we have identified in garden Quality villages within the historic tradition (see para 2.22 above). If a need has been identified, this Although we are not opposed in principle to would be best directed towards standalone new standards in respect of these matters, the developments specifically allocated for that Council will need to bring forward evidence to purpose. support its policy to ensure these are viable and deliverable. At present, this policy is not 5.4.6. Policy ED8 - Town, Rural Service, fully Justified. Neighbourhood, and Village Centres Hierarchy

5.4.3. Policy H1 - Delivery of Housing The objective of this policy is not clear. The purpose of the hierarchy appears to restrict Although we understand the objectives of the location of retail and other services, but it the Policy, we consider this policy to be is not clear how that policy is to be operated. too inflexible for inclusion in a Local Plan. This leads to confusion, particularly as the These matters are best left to Development words ‘Neighbourhood Centre’ in everyday Management functions. Indeed, a complex meaning is very limited in scope and function. development such as Tudeley will require For example, on the basis Tudeley will grow to a long-range timing and implementation between 2,500-2,800 dwellings, we consider condition. At face value, this policy should not the status of the settlement to be similar

21 to Hawkhurst (population of circa 5,000 ‘side-friction’ and reducing the definition residents) which is a Rural Service Centre. On of front boundaries. The current policy is the basis the Hadlow Estate are seeking to too simplistic and negative and therefore is establish Tudeley as a genuinely mixed use unsound. We suggest these matters are best community with a good range of employment left to a supplementary guidance document opportunities, we are concerned that the which can explore good and bad examples of hierarchy as expressed will limit the ambition the issues identified above. to create a commercial heart that can support employment and a community of that size. 5.4.8. Policy TP5 - Railways

5.4.7. Policy TP3 - Parking Standards This Policy requires amending to ensure it works effectively with the allocation AL/ Accommodating the motor car is a key CA 1 and promotes its delivery. Under challenge in any development, particularly Safeguarding Railway Land, the following those which are seeking to reduce the impact should be added: of the simplification and reducing effect that the car has on our urban environments. In Tudeley Village responding to this challenge, masterplanners Where identified in accordance with the need more flexibility and the capacity to Masterplan to be developed in respect of innovate and demonstrate how their solutions Policy AL/CA 1, land either side of the railway can achieve a balance between convenience line within Tudeley Village will be safeguarded and good quality design. for potential bridge crossings and a potential rail halt and shall not be made available for We are therefore concerned that Policy TP3 other uses unless specifically identified in the is going beyond specifying standards and is Masterplan. trying to preconfigure the design process with immoveable redlines such as: A strip of land either side of the railway line should also be added to the relevant Policies - Banning tandem parking unless no on- Map to align with this amended Policy. street parking is available; 5.4.9. Policy TP6 - Safeguarding Roads - Specifying how many open sides a parking barn must have; and To align with changes to Policy AL/CA 1, the following adjustments to the supporting text - Suggesting parking courts should be to paragraph 6.536 is needed: located next to open spaces. A228 Colts Hill The Policy is going beyond guidance to 6.536 Land is safeguarded for an potential stipulating a design response and this is not offline (i.e. new section of) highway, which positive planning. It also fails to acknowledge runs from the dualled section of the A228 the principle of using design to steer people at the north of Pembury to a position in towards a pattern of use or activity that close proximity to the existing roundabout is more beneficial. For instance, a lack of between Paddock Wood and Five Oak Green; use of tandem spaces may increase on- again, land is safeguarded around this for an street parking which is desirable in terms associated remodelled junction. The provision of providing ‘side-friction’ which in turn, of this new section of highways is potentially slows down drivers. If there is insufficient required as a strategic mitigation for in parking then residents have the choice to order to mitigate the impact of development utilise their tandem driveways. Excessive, proposed in this Plan, particularly that around convenient parking has the contrary effect Capel and Paddock Wood and Tudeley. of increasing speed along roads with limited There is the potential that there will be a

22 link from this new section of highway to the status as the family’s private burial ground, development to be allocated at Tudeley, we reluctantly object to the designations subject to the development of an appropriate as currently proposed. In the course of the access strategy, which will be brought development of Tudeley Village there may be forward for consultation. although various minor highway works and landtake required potential routes are being considered. The which could alter the current boundaries final route of this link will be included in the of the two spaces, and so the proposed Pre-submission version of the Local Plan, designations are premature. and will be subject to consultation under Regulation 19. It is likely that land will be We would support the designation of these specifically allocated for the offline A228 spaces once the detailed extent of the strategic link (Colts Hill bypass) section in the Masterplan is known, and indeed we have Pre-submission version of the Plan. already identified the importance of these sites in our initial ecological appraisal as set 5.4.10. Policy AS/ 60 Private Burial Ground and Policy out in Section 3 of this document. Despite AS/ 64 Ancient Orchard their recognised importance and contribution to the area, we would oppose making spatial Although we are not opposed in principle to distinctions until exact boundaries are known the designation of Local Green Space and and understood. there is no question that these spaces will be retained, particularly Site AS/ 60 given its

5.5. Summary of amendments to policies

The table below lists the policies that we have commented on above, and our responses to these policies.

Policy Response AL/CA 1 Tudeley Village Support with conditions EN22 Agricultural Land Support with conditions EN23 Air, Water, Noise and Land Air Quality Support with conditions H1 Delivery of Housing Object H5 Affordable Housing Object H11 Self-Build and Custom Housebuilding Object ED8 Town, Rural Service, Neighbourhood and Object Village Centres Hierarchy TP3 Parking Standards Object TP5 Railways Support with conditions TP6 Safeguarding Roads Support with conditions AS/60 Private Burial Ground Object AS/64 Ancient Orchard Object

23 24 Appendix A - Review of Housing Need

25

Hadlow Estate

Tunbridge Wells Review of Draft Plan

Peter Brett Associates November 2019

Office Address:

Peter Brett Associates 33 Bowling Green Lane London EC1R 0BJ T: +44 20 3824 6600 E: [email protected] Document Control Sheet Project Name: Tunbridge Wells Report Title: Review of Draft Plan Project Ref: 47636 Doc Ref: v1

Name Position Signature Date

Prepared by: A Lynch Associate AL 25h Oct

Reviewed by: J Lee Senior Associate JL 1st Nov

Approved by: R Pestell Director RP 6th Nov

For and on behalf of Peter Brett Associates LLP

Revision Date Description Prepared Reviewed Approved

1 6th Nov Final draft AL JL RP

Peter Brett Associates LLP disclaims any responsibility to the client and others in respect of any matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence within the terms of the contract with the client and taking account of the manpower, resources, investigations and testing devoted to it by agreement with the client. This report has been prepared for the client and Peter Brett Associates LLP accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk. © Peter Brett Associates LLP 2019

THIS REPORT IS FORMATTED FOR DOUBLE-SIDED PRINTING .

ii Tunbridge Wells Review of Draft Plan

CONTENTS

1 INTRODUCTION AND SUMMARY ...... 1

2 BACKGROUND ...... 4

3 PLAN BASE DATE ...... 5 Introduction ...... 5 Conclusion ...... 6

4 MANAGING RISK ...... 7 Introduction ...... 7 Expected changes to the Standard Method ...... 7 Emerging unmet need ...... 8 Conclusion ...... 9

5 JOBS & HOUSES ...... 10 Introduction ...... 10 Internal inconsistencies in the Plan ...... 10 The need for a policy-on adjustment and evidence that the Plan Strategy is appropriate ...... 11 Conclusion ...... 11

6 RECOMMENDATIONS ...... 13

November 2019 iii

Tunbridge Wells Review of Draft Plan

1 INTRODUCTION AND SUMMARY

Peter Brett Associates (PBA) has been commissioned to review the emerging housing strategy in the Royal Borough of Tunbridge Wells Local Plan, and the supporting evidence that underpins the approach. Our client, Hadlow Estate, are promoting a sustainable new community at ‘Tudeley Village’. This is currently proposed for allocation in the emerging development plan. Given this fact, it is in both the Council’s and our client’s interest to ensure that the plan progresses to adoption as efficiently as possible. With this in mind, we have been asked to review the plan and provide independent advice which highlights any potential weaknesses, so that these can be addressed prior to submission. Our findings are that the plan has been generally been positively prepared, and the approach taken by the Council broadly accords with overall National Planning Guidance. However, we identify some areas of concern in respect of housing provision that the Council needs to address now before submission, to ensure the plan is sound. In this paper we highlight the potential issues that we consider ought to be addressed. In summary we advise that the plan is at risk because it proposes too little ‘headroom’ to manage known factors that are likely to increase the minimum housing ‘need’ above that in the draft plan. These factors include the revision to the Standard Method to secure the Government’s 300,000 dwelling ‘target’. While the exact timing of this announcement is unclear, it is almost certainly expected between now and when the plan would be submitted for examination. Related to this is the limited ‘headroom’ to absorb any ‘unmet need’ from other Councils that may emerge in the coming months. This is very much a ‘live issue’ in this area with London now confirming a shortfall, and more locally, Sevenoaks ‘failing’ the Duty to Co-operate partly due to unmet need. We are also concerned that the plan is at risk of ‘failing’ NPPF paragraph 22 – which requires a 15-year plan period from adoption. At the moment any delay to the submission of the plan or its examination could result in less than 15 years at the point of adoption. Our concerns could be mitigated should additional land be promoted in the plan. However, there are inherent difficulties in estimating how much more land, given the Standard Method is in flux. Nationally the Method will need to increase by 15% to secure the 300,000 homes, but we don’t know whether each Council will receive 15% or some more and some less. So our suggestion, to manage and best mitigate these risks, would be to extend the plan period by a further 5 years. This approach would not result in a higher ‘per annum’ housing need in advance of any formal announcements concerning the future Standard Method. Nor would it

November 2019 1 Tunbridge Wells Review of Draft Plan

explicitly address unmet need from other Council areas in advance of any request. However, it would provide useful headroom that could be brought into the land supply if or when needed. From our experience it is considerably easier to compress a plan period and speed up delivery of sites to address an increase in ‘need’ than try to add new sites into the plan at a late stage or at the Examination stages. We also have a technical concern with the approach the Council is taking to the Standard Method and ‘backlog’. Our understanding is that neither backlog nor previous over-provision should be added to the Standard Method housing need figure. The housing requirement is effectively reset at the point of submission. When the Method was introduced, not adding ‘backlog’ or previous over provision was justified partly to simplify the assessment process. MHCLG noted that any previous under/over provision should be reflected in the ‘uplift’ applied to the demographic starting point. In our opinion this was also done to prevent ‘gaming’ of the Standard Method where parties could seek to promote a base date to their respective advantage. This was a key criticism of the previous OAN process. As noted this is a technical concern and we highlight it here only to avoid a ‘last minute’ recasting of the plan policies at a later stage, as was the case with the Sevenoaks Local Plan following its Inspector advisory visit. Finally, we are concerned that the Council has not yet updated its economic evidence and cannot, at the moment, demonstrate that the housing and employment policies of the plan are mutually sound. This could have implications for the Council’s preferred plan strategy should further work show, for example, that the age profile of the residents would suggest more homes are needed to accommodate the future workforce. In our opinion it is urgent that this work, showing how the housing and employment policies are mutually sound, is undertaken. Without this key evidence the Council cannot demonstrate that the plan as a whole is sound, and the correct strategy has been adopted. In the rest of this note we expand on these points: In section 3 we outline why we don’t think ‘need’ should carry forward backlog (as per Table 1 of the Plan) and so why Table 1 should be redrafted. In section 4 we look at why and how the Council should be managing ‘risks’ associated with potential changes to the method and unmet need. In section 5 we look at why it is important that the Council updates its economic evidence without delay. Who are PBA? PBA, now part of Stantec, is a planning consultancy with considerable experience of housing need issues. We have worked for the local authorities and developers across the country advising on housing need and have also worked with the Planning Advisory Service for many years. Our work includes providing direct support to local authorities, working with officers and members to raise capacity and deliver good plan making, reviewing evidence base documents and providing review

November 2019 2 Tunbridge Wells Review of Draft Plan

and advice on the plan programme. We have prepared the Objectively Assessed Need and Housing Targets: Updated Technical Advice Note which has been well used by Inspectors at Local Plan examinations and at S78 appeals. We have produced numerous Housing Needs Assessments identifying the Objectively Assessed Need for Local Authorities, and defending our work successfully through Local Plan Examinations, most recently in Plymouth, South Hams and West Devon. In addition, we work for private landowners and developers objecting to plans and ensuring that a robust housing need figure is established. Irrespective of the client, we pride ourselves in taking a consistent and robust approach.

November 2019 3 Tunbridge Wells Review of Draft Plan

2 BACKGROUND The Council’s position The Regulation 18 consultation version of the Tunbridge Wells Borough Council Local Plan identifies a housing need figure for the Borough of 13,560 dwellings (678 per year) over the 20-year Plan period running between 2016 and 2036. The calculation of the 13,560 dwellings figure using the Standard Method approach is set out in the Council’s Housing Needs Assessment Topic Paper1. In summary, the calculation is as follows:  The Council consider it sensible to use 2020 as the base year to measure the growth over a 10-year period. The 2014-based household growth projections for 2020 and 2030 are 51,450 and 56,293 respectively. This difference is a growth of 4,843, which, over ten year’, averages to 484 pa (4,843/10).  Applying the affordability ratio (12.76 in the case of Tunbridge Wells) produces an adjustment factor of 1.55 (approx. 55%), and generates a need figure of 749 (484*1.5475).  However, this affordability adjustment factor (55%) exceeds the 40% cap, identified at stage 3 in the Standard Method. The cap is then applied to re- calculate the need and results in the 678 figure (484*140%). The Council have correctly applied the Standard Method calculations to identify an annual average. Applying this to a 20-year period leads to the 13,560 dwelling figure referred to above. However, we have a number of concerns relating the lack of flexibility or contingency in the plan to accommodate changes in the method between now and submission. There is also no contingency to manage the possibility that unmet need may arise in neighbouring Council areas between now and plan adoption. We detail both of these concerns later (in Section 4. Managing Risk), but as noted earlier given the limited plan period, any delay to the plans progress could mean the Plan has too few years at plan adoption, and we turn to this matter next.

1 Housing Needs Assessment Topic Paper for Draft Local Plan, Aug 2019

November 2019 4 Tunbridge Wells Review of Draft Plan

3 PLAN BASE DATE Introduction Table 1 of the plan outlines the Council’s approach to assessing need. As noted previously we agree with the Council’s calculation of the Standard Method, but we have one technical concern relating to the treatment of the ‘backlog’ element and the fact that it is being carried into the Borough’s ‘need’. Our reading of the Planning Practice Guidance (PPG) is that the Council is wrong to carry previous over/under delivery of homes into the assessment of need. Previous delivery has already influenced the ‘uplift’ element of the Standard Method and should not be ‘double’ counted. We raise this as a technical point, which can be simply addressed by redrafting Table 1 and the supporting text so that it is clear that the table is not reporting the ‘need’ but is reporting the Council’s policy target. In that respect the Council has, in Table 1, made a choice to address ‘backlog’ which we support given the severe lack of affordability in this area and that the Standard Method is only a minimum figure. However this runs the risk, as presented, of being confused with the Council’s true ‘Need’. We set out the rationale for this in more detail in the next sections. The Guidance In setting the base year, the PPG makes it clear that the current year should be used as the starting point to calculate the ten-year average to apply to the Plan period2. The PPG says, ‘the current year being used as the starting point from which to calculate growth over that period’. Logically the current year cannot be a year in the past, and in any event ‘past years’ may have been subject to different plan targets from older plans or previous rounds / iterations of the Standard Method. The PPG clearly notes that when applying the Standard Method, ‘backlog’ is not to be added because ‘historic undersupply’ is already factored into the assessment as part of the affordability adjustments3. We would also note that the use of ‘backlog’, ‘over provision’ and base dates were areas of evidence that many suggested was being ‘gamed’ under the OAN process. The clear instruction now in the PPG prevents this ‘gaming’. Councils cannot adopt historic base dates for their housing policies where it may benefit them, but neither are they required to recover backlog. In practice this means that through the

2 Step 1 - Setting the baseline, PPG Paragraph: 004 Reference ID: 2a-004-20190220 3 2a-011-20190220

November 2019 5 Tunbridge Wells Review of Draft Plan

Standard Method the Council’s housing targets account for any backlog when the plan is submitted. Conclusion Given the guidance was drafted and ‘simplified’ to remove backlog/oversupply from an assessment of need and subsequent (minimum), we think it is unhelpful that the plan’s housing targets are presented with ‘backlog’ (i.e. base date in the past). We suggest that the policy approach be simplified to align with the guidance and that Table 1 should not refer to ‘need’, but instead should refer to the Council’s chosen ‘requirement’.

November 2019 6 Tunbridge Wells Review of Draft Plan

4 MANAGING RISK Introduction The Council is currently proposing a small over-provision of land compared to need. This is less than 10%. This is justified on the basis that it is needed to manage supply-side risks including non-implementation / delivery of sites. We consider that this is a very limited ‘contingency’ that does not deal with any of the demand-side issues, and this means risks arise to the smooth progress of the plan through to submission and post-submission. As noted above there is little ‘slack’ in the proposed plan period to ‘compress’ the plan period to absorb any possible uplift in the Borough’s need. As we discuss below, there are sound planning reasons why the Local Plan, in its land supply, ought to consider more land being made available for new homes. This is because the majority of the factors we consider below could result in a higher need number at the critical point, just before submission. Expected changes to the Standard Method The local housing need figure identified by the Standard Method is only fixed at the point of submission of the Local Plan. The Planning Guidance says that it can be relied upon for a period of two years from the time that a plan is submitted to the Planning Inspectorate. Consequently, the housing need figure can change right up to and including the day before submission. There are already clear signs from the Government that the Standard Method is going to be adjusted upwards, and this is likely to happen before the plan is submitted. The most obvious sign is that the Government is committed to 300,000 new homes being delivered annually in the near future. Whereas the current Standard Method provides for only 266,000 new homes per annum nationally. We do not know for sure how the Method will be adjusted upwards to meet this target. It could be via removal of the 40% ‘cap’, or through a more aggressive market signal uplift nationally and/or a shift towards ‘policy-on’ headship rates as opposed to those based on long term trends. It would not be fruitful or productive to overthink how this may be achieved, but it is highly likely that the Standard Method will be adjusted upwards in the next few months. Our concern is that the plan is currently progressing without the flexibility or contingency to accommodate or absorb any uplift in the Method. This means that the Development Strategy set out in the emerging plan is at risk of misrepresenting the scale of growth likely to be required in the Borough. It follows that the possible portfolio of sites being promoted in the plan, tested in evidence, and forming the strategy does not reflect the likely scenario that more new homes will be required.

November 2019 7 Tunbridge Wells Review of Draft Plan

We note the Council’s Housing Topic Paper4 acknowledges that the Government will undertake a review of the Standard Method because of the “dated” 2014 household projections, and that this review is likely to be undertaken before the publication of the Tunbridge Wells Submission Plan. However, despite this acknowledgement, no provision is made in the emerging plan to mitigate this risk. Emerging unmet need The NPPF requires Authorities to consider if they can accommodate identified unmet need in neighbouring Authority areas. In this respect it is relevant to note that the Borough’s Consultation Draft refers to Sevenoaks “not proposing to wholly meet its housing need”, and the Council “may need to update its housing targets as the Local Plan progresses”.5 The Housing Need Topic Paper expands on this finding6, and states that of the six adjoining Authorities only Sevenoaks has an identified unmet need - 1,900 dwellings, but that the constraints that apply to Sevenoaks also apply to Tunbridge Wells, meaning that they may also have a limited ability to meet any unmet housing need from any other council. The Sevenoaks Local Plan Examiner has recently sent the Council a letter to express concerns about unmet need and Duty to Cooperate, and we consider this below. Another externality that should have always been on the Local Plan risk register, and which has now come into play, is unmet need from London, and we also consider this below. Sevenoaks unmet need Sevenoaks are an adjoining Authority and by their own admission have an unmet need of 1,900 dwellings. The Tunbridge Wells Local Plan refers to unmet need from Sevenoaks, but other than the reference to having similar constraints to Sevenoaks, there is no consideration of any adjustment to accommodate any of this need. The Consultation Draft specifically refers to the need to keep a watching brief on the Sevenoaks Local Plan Examination, as well as on the needs of other Authority areas more generally. The Sevenoaks EIP Inspector’s letter issued to the Council in mid-October, raises serious concerns that Sevenoaks Council has failed in its duty to co-operate with the other Authorities in the Housing Market Area to explore ways of addressing the unmet need. This must raise substantial concerns for all the HMA Authorities. Fortunately for Tunbridge Wells, the Plan is pre-submission and the Authority has scope to now address the matter.

4 Paragraph 17 5 Paragraph 4.8 6 Paragraph 28 onwards

November 2019 8 Tunbridge Wells Review of Draft Plan

London Plan The London Plan Submission version identified a need for 66,000 homes per annum, and considered supply was sufficient across London to meet this figure. However, the very recent Inspectors’ report identifies problems in the approach to future capacity on small sites, which produces a substantial gap between demand and supply of 13,000 dwellings per annum. This is a significant unmet need, and the Inspector recommend an immediate review of Green Belt. The Metropolitan Green Belt straddles the regional boundary, and the impact will inevitably ripple out to the adjoining Authorities in the South East, leading to higher need targets all round. The London Plan will be adopted early 2020, and so will be an important factor in Examinations in 2020 and thereafter. It will therefore, as with the Sevenoaks Local Plan’s unmet need, be material to considerations for the Tunbridge Wells Local Plan. Conclusion To manage these risks and avoid delaying the plan, more sites are needed to provide additional contingency. This contingency is needed to ensure that the plan when submitted is capable of being found sound and no delay is needed to identify more sites at a late stage of the plan process. We note that pragmatically one way to manage this is simply to increase supply versus need above the current non-implementation margin/buffer. This would leave the Council’s formal target unchanged, and only need amending when the Method is revised and generates a higher housing need. At which point any surplus land would provide additional ‘buffer’, which may be helpful for 5-year land supply purposes in the future – recognising the target is only ever a minimum. Given we know that nationally the Standard Method needs to increase by around 15% (from 266,000 to 300,000 homes per year) we consider a 15% minimum additional supply buffer would appear sensible to best ensure a sound plan at the time of submission. This will need to be kept under review. We suggest that to ensure the plan is capable of 15 years from adoption, it would be sensible to extend the plan period beyond 2036, and undertake the additional evidence to support this before submission. It is exceptionally rare that plans procced seamlessly through examination, and the lack of ‘headroom’ in the supply over the plan period is a risk requiring mitigation.

November 2019 9 Tunbridge Wells Review of Draft Plan

5 JOBS & HOUSES Introduction Guidance is clear that a housing target that at least meets the relevant Standard Method number at the time the plan is submitted should be presumed ‘sound’. However, the plan as a whole still needs to be ‘sound’, and the implications of the proposed housing number tested, and where appropriate ‘policy-on adjustments to the target promoted’. This first ‘test’, of internal consistency between policies of the plan and different land uses, is clearly a matter of soundness. The second consideration of policy-on adjustments is more arguably a matter for the Council, but one the Council cannot form a view about because the evidence to do so has not been prepared. Internal inconsistencies in the Plan As currently drafted, there is a possible disconnect between the Plan’s housing and economic strategies. In summary, we understand that the Council’s economic evidence has not yet been updated to address the population, labour supply and demand for jobs, flowing from the proposed housing target and housing land supply. Thus there could be a disconnect between the job and housing numbers, which only an update of the economic evidence can determine. This update need not revisit all aspects of the evidence or take long, but is needed to ensure the Plan is internally consistent. The housing policies are informed by the Standard Method, which includes a 40% uplift on demographic need, but at the moment this is not considered by the economic policies and evidence base. As we understand matters the economic policies remain informed by the 2016 Economic Needs report. This document was used to support the plan as it emerged from the OAN system, and not the current Standard Method. While the OAN number is similar to the Standard Method (648 OAN vs 678 SM), the method for each assessment is very different, as is the current demographic baseline. The Economic Need evidence should therefore consider the impact of the new Standard Method number. One particular issue is that recent demographic data shows that the Tunbridge Wells population is aging rapidly, and a significant share of any new homes are needed simply to accommodate this ageing population. This aging has been compounded by the reduction in working age international migration into the Borough – possibly a Brexit effect. International net migration into Tunbridge Wells has fallen from over 300 per annum in the mid-2010s to fewer than 100 in the recent past. Previous evidence recommended no uplift in OAN to meet the Borough’s economic needs, finding that the Borough’s needs could be met inside the OAN. However, this was based on a demographic baseline whereby the population and labour supply were growing.

November 2019 10 Tunbridge Wells Review of Draft Plan

Using the most recent 2018 MYE data to develop a ‘preview’ of the next round of official population projections shows that population growth and the growth of the traditional working age population has stalled. The chart below shows the Borough’s age structure in 2021 and at 2036.

Source: ONS MYE 2018

We acknowledge that the Council will be required to provide more homes than the relevant household projections suggest – 40% in this case under the current Method. The logic of this adjustment is to address the lack of affordability in the current market – the uplift cannot be relied on to delivery more people and so more labour. Further work is needed to align the Standard Method with the economic policies of the plan to ensure that the plan as a whole is internally consistent, at the moment the plan is at risk of not being internally consistent. The need for a policy-on adjustment and evidence that the Plan Strategy is appropriate Because the steps above have yet to be undertaken, there is no evidence that the economic policies of the plan are consistent with the proposed housing number. We cannot know whether an additional uplift in housing, to meet economic needs, is needed or wanted. There is no evidence to demonstrate that the draft plan is the most appropriate development strategy for the Borough. Conclusion The risk to the Plan is that the evidence base that is informing the strategy and policies is materially out of date.

November 2019 11 Tunbridge Wells Review of Draft Plan

More recent demographic data suggests that ‘trend’ based population, and so household growth will result in a population that is much older than today, and with a much smaller working age population. This raises the possibility of a disconnect between the housing and economic policies of the plan that needs addressing by updated evidence. We cannot tell whether the submitted plan is the most appropriate strategy because the evidence base is incomplete and materially out of date. Until the evidence is updated it cannot be known whether an uplift for economic needs is necessary, nor whether the uplift in housing numbers from the Standard Method will go some way to addressing this issue. While we sound a note of caution about promoting a ‘job led’ number, because to do so harks back to the long and tortuous Objectively Assessed Need process where the system was plagued by less than robust ‘methods’ to align jobs and houses, internal consistency is needed. The Council needs to evidence that the Development Strategy is sound, whether or not an uplift is warranted and the plan is positively prepared. To do this will require new updated, relevant evidence. There is a risk that unless the Council is able to evidence its Strategy as submitted is sound, it is very likely that others will promote their own alternatives, and this will lead to debate and delay. In our experience such an update can be undertaken without the need to revisit all aspects of the economic evidence, and need not be an overly time- consuming task.

November 2019 12 Tunbridge Wells Review of Draft Plan

6 RECOMMENDATIONS

At the start of this note we set out that our objective is to critically review the emerging housing strategy and housing need target, including the application of the Standard Method. We acknowledge that this is a draft plan, and the Council has time to cover off the risks to the housing need elements of the Plan prior to Submission. This note raises a number of risks from external influences that question whether the Plan’s housing supply has enough flexibility to cope should the housing need number rise without the need to incur lengthy delay while a supply gap is ‘plugged’. In summary, we are concerned that the Plan may have too little housing land to manage the likely uplift if the Standard Method and/or to absorb unmet need which may emerge. We are also concerned that the Plan is at risk of failing to look forward 15 years at adoption. As a potential solution to all these issues we suggest extending the plan period by a further 5 years. This provides ‘headroom’ to subsequently shorten the plan period should need increase. However, should this not happen, the additional land would still be available to carry into subsequent plan reviews or brought forward should the Council subsequently struggle with the delivery test or 5-year land supply. So providing additional robustness to the plan strategy. We have also highlighted the need to update the Council’s economic evidence. This is so the Council can demonstrate consistency and broad conformity between the economic and housing policies of the plan. It will also show that the plan’s Development Strategy is sound. Finally, we suggest reworking Table 1 of the plan so that it does not report to carry ‘backlog’ into the Council’s assessment of ‘need’. All these points will future-proof the emerging plan so that it stands the best chance of passing through the Examination process as smoothly as possible.

November 2019 13 26 Appendix B - Overview of Garden Villages in the UK tradition

27 Appendix B: Overview of Garden Villages in the UK tradition

1. Why Garden Villages now? 1.3. It is in this context that we have begun once again to think about the values of the Garden City movement 1.1. Britain’s towns, cities and villages are facing a and the associated tradition of Garden Villages. The double dilemma: for decades, the nation has been generation of garden city planning schemes and underbuilding, with some analysts putting the model villages embodied by Letchworth Garden backlog in England to some four million homes. City, Welwyn Garden City, Hampstead Garden However, the other half of this problem is that Suburb, Bournville, New Earswick and others have when building has taken place, it is all too often maintained a compelling hold upon the public characterised by sprawling, monocultural housing imagination since their creation. The Garden lacking in any sense of place and at odds with our Cities were the original ‘sustainable communities’ traditions of urbanity. These schemes have rarely – complete urban ecosystems, comprising been the product of an over-arching vision, more industry, offices, shops, housing, leisure options unplanned, additive change. Often their scale is and abundant open space. They have remained small – perhaps a few dozen homes, not large consistently popular with residents, attracted by the enough to merit shops, a school or employment prospect of quality homes with gardens, walkable places. Yet development follows development, and tree-lined avenues, open spaces and access to good over time this incremental creep results in housing transport links. Their designs sought to create places numbers large enough to justify shopping parades, in tune with human aspirations, and this, arguably, is leisure facilities and open spaces but, as no grand the secret of their success. vision organised it, none exist. It is a pattern which begets car-dependent dormitory estates, not the 1.4. These communities serve as valuable precedents vibrant, walkable and enduring neighbourhoods in for a new generation of Garden Villages aspiring which people want to live. to a similar model of self-sustaining, integrated communities updated for twenty-first-century living. 1.2. Yet, in this climate of endemic underbuilding, these developments sell. This knowledge enables conventional volume house builders to operate at low standards – the perceived incentives to follow good design practices within the industry are meagre. This has resulted in a situation in which public resistance to new housing development is prominent.

28 2. A Brief History of the Garden Village 2.4. Howard was, though, strongly influenced by a series of industrial ‘model villages’ that had 2.1. In recent years, growing publicity has surrounded the been developed in the nineteenth century by concept of the Garden Village, but the idea is not new philanthropic employers and social reformers in its genesis. Closely linked with the Garden City who believed that the best way to tackle the movement, the term Garden Village is used to denote problems of inner-city overcrowding was to relocate a tradition of new settlements planned as holistic manufacturing to greenfield sites outside towns. communities, smaller in scale than the two Garden Cities of Letchworth and Welwyn but emerging 2.5. As early as 1800, enlightened mill owner Robert from a shared anxiety towards the repercussions of Owen was constructing a settlement for his workers nineteenth-century Britain’s industrialisation. at New Lanark, south east of Glasgow. He was followed by the likes of Colonel Edward Ackroyd, 2.2. The Industrial Revolution of the late eighteenth who commissioned Copley and Akroydon villages and nineteenth centuries was a triumph of science, outside Halifax in the 1840s and 50s; Sir Titus inventiveness and entrepreneurship; yet it also had Salt, and his palatial village Saltaire (begun 1851); a darker side of slums, disease and degradation. soap magnate W. H. Lever’s model village Port The period transformed Britain from a primarily Sunlight, outside Liverpool (commenced 1888); agricultural country to an industrial one. Between George Cadbury, who built Bournville from 1898 1801 and 1891, the proportion of people living alongside his chocolate factory, five miles from in towns grew from 20 to 72 per cent. Combined Birmingham’s city centre; and the manufacturer, with soaring population, such rapid urban growth, Joseph Rowntree, who constructed New Earswick unchecked by building or sanitation controls, on 123 acres on the outskirts of York from 1902. caused social and environmental tolls of never- The ventures were designed to be exemplars of before-seen scale. Reformers and industrialists complete environmental planning, combining alike grew progressively disillusioned with Britain’s good-quality housing, employment, attractive overpopulated, soot-laden towns and cities. green space, community buildings and recreation facilities to foster happier, healthier and socially 2.3. Not content with merely watching on in alarm, a mixed populations. These small but pioneering handful of individuals sprung to action to realise experiments laid the foundation for the Garden tangible illustrations of urban alternatives. The Village concept. most celebrated of these is Ebenezer Howard, who, in his 1898 book To-morrow: A Peaceful Path 2.6. The holistic approach of the industrial model village to Real Reform, set out a template for the Garden to realise well-designed, economically viable and City – a new blueprint for urban life that would self-contained communities in semi-rural settings fuse all the merits of the town with the pleasures was a vital stepping stone in Howard’s ‘invention’ of of the countryside, whilst circumventing both their the Garden City. Howard’s solution was a vision for drawbacks: ‘In “Town-County” equal, nay better, a whole new civilisation informed by cooperation, opportunities of social intercourse may be enjoyed justice and equality, and in To-morrow he set down than are enjoyed in any crowded city, while yet a practical plan for achieving it. A network of new the beauties of nature may encompass and enfold planned communities would be built, combining each dweller therein… abundant opportunities for environmental and social benefits, and he called employment and bright prospects of advancement these Garden Cities. With high-density zoned layouts may be secured for all… beautiful homes and surrounded by open countryside, these would fuse gardens may be seen on every hand… [and] all the all the merits of the town with the pleasures of the best results of concert and co-operation gathered in country. Each Garden City would be characterised by a happy people.’ by a unique system of land tenure. All land was to be owned by a municipal trust on behalf of the

29 community, to whom inhabitants paid rent. As the 2.10. Today, the Garden Village concept is enjoying settlement grew and land values rose, all increment a renaissance, resulting from governmental would be fed back into the municipality, providing interest in the role new communities have to play communal amenities and welfare provisions. in addressing the national housing shortage. A renewed appreciation of Garden City principles is 2.7. In 1903, only five years after To-morrow’s driving an interest in Garden Villages as part of a publication, contracts were signed for the purchase wider government programme supporting ‘garden of land in Hertfordshire to build the first Garden community’ development of a range of scales. City, which would become Letchworth. This was followed 16 years later by a second Garden City, 2.11. As in the early twentieth century, there is a danger Welwyn, also in Hertfordshire. Both were realised that the epithet may become skin deep. Some by limited companies, which financed, planned and modern developers are jumping on this bandwagon physically built the resulting town. The shape of the by assuming the term ‘Garden Village’ in the naming Garden City was not only influenced by the social and branding of their schemes, whilst paying no and management approach of the model villages, more than lip service to the principles and standards but also their designers. Barry Parker and Raymond that underpin the Garden City planning approach. Unwin, who master planned New Earswick, were These principles are set out in the following section. also responsible for the planning of Letchworth.

2.8. Inspired by the Garden Cities and model villages, the twentieth century saw the laying out of further estates uniting principles of physical and social planning, such as Whiteley Village in Surrey, Garden Village in Kingston-upon-Hull and Harrow Garden Village in north London. It was what might be called a golden age for Garden Village design, in which landowners, enlightened capitalists and public agencies, such as the London County Council, were inspired to propose villages and suburbs intended to cater for the needs of the middle and working classes. These settlements were characterised by low development densities, high-quality materials and good design, intended to counter the perceived haphazard and unplanned development that was becoming increasingly noticeable across the country. Whereas only two true Garden Cities were ever realised, the Garden Village or Suburb was the most visible and most achievable expression of reform in urban environments, and, at its best resulted in places of enduring architectural quality and community identity.

2.9. However, the label was also shamelessly snatched up by speculative builders eager to capitalize on the reputation of the pioneering settlements. Exemplified by estates like Peacehaven in Sussex or Fernville Park in Leeds, the terms ‘garden suburb’ and ‘garden city’ were indiscriminately applied to even the most commonplace of suburban places which often bore no resemblance to Howardian principles or the Garden Cities’ aesthetic standards.

30 CASE STUDY 1: PORT SUNLIGHT

Located on the banks of the Mersey opposite Liverpool, Port Sunlight was founded in 1888 in the tradition of enlightened philanthropy by soap magnate, William Hesketh Lever, to house the workforce of his factory in response to the appalling living conditions he had witnessed. Lever’s factory was located just to the south. By 1909, over 700 homes had been completed on the 130-acre site, well protected from the sight of the industrial works.

Its planning was predicated upon three themes: health, convenience and art. Public buildings, such as a school, hospital, church, inn, art gallery and library, were interspersed amongst homes and plentiful green space with extensive tree planting. Even today, one of the lasting impressions of Port Sunlight is its quantity of well-maintained open space, including communal parks, formal tree-lined boulevards, a bowling green and private gardens. Front lawns were deliberately open to encourage neighbours to interact.

The built environment drew heavily on the Cheshire vernacular, with half-timbering, gables and tiles. Housing was intended to be economically viable but Lever employed leading architects of the day to ensure its quality remained high. Taking the form of cottages set in groupings of two to ten, houses sported a diversity of architectural treatments to ensure a sense of aesthetic variety, but all were united within a vernacular language that invested the whole with a cogent identity.

Port Sunlight was not intended to be a standalone community. Tenants were confined to company employees and pensioners. Established upon a theory of profit sharing, rental profits of the village were reinvested in its social amenities.

While the paternalistic raison d’etre of Port Sunlight has evolved – more than two thirds of housing is now privately owned – the sense of stewardship persists. In 1999, the Port Sunlight Village Trust (PSVT) was established to manage the 16 communal properties, the 292 homes not under private ownership and the landscape, aiming to ‘preserve and enhance the character of the village and retain the essential fabric of the community’. Housing is protected by restrictive covenants, held by PSVT, in the title deeds, which essentially require owners to keep homes in good repair and to obtain consent from the Trust before making alterations.

31 CASE STUDY 2: BOURNVILLE

Bournville shares a similar genesis to that of Port Sunlight. In 1894, George Cadbury purchased a 120-acre tract adjoining his chocolate factory, which he had relocated from inner-city Birmingham 15 years earlier, with the intention of building a model village to ‘alleviate the evils of modern cramped living conditions’ for the Cadbury employees.

Standards of planning and design were high. Architect William Alexander laid out a variety of housing types (detached, semi-detached and terraces) designed along Arts and Crafts, yet economical, lines. The focal point was a village green, with neighbouring shopping parade and community amenities such as a school, day school for adults and meeting houses. A large recreation ground was sited near the factory, as well as a park. Social and aesthetic priorities were thus combined.

The Bournville concept was broader than other model industrial villages, in that up to half the housing was available to non-company employees. The objective was to achieve an exemplar of how to provide decent standards of living for the working classes whilst still turning a profit, and, furthermore, of the importance of social integration. Different types of houses were spatially distributed across the village, putting the concept of residential mix into practice.

After several years it became apparent that the Bournville Building Estate was becoming threatened by encroaching urbanisation and the sale of houses by factory worker lessees for personal profit. To retain control of the Village, George Cadbury decided to turn it into a Charitable Trust; the Bournville Village Trust (BVT) was created on 14 December 1900. The BVT is bound by a Deed, which specified how the Village could develop in the future. It set aside one-tenth of the land as public open space and retained the right to review architectural designs for new development and alterations. Now a Conservation Area containing some 7,800 homes on 1,000 acres of land, it remains a popular residential area of Birmingham.

32 CASE STUDY 3: LETCHWORTH GARDEN CITY

Letchworth was the first manifesto of Howard’s Garden City concept. In 1903, 3,800 acres were purchased some 34 miles north-east of London. The new settlement was placed on 1,200 acres at in the middle, surrounded by greenbelt. Master planners Barry Parker and Raymond Unwin provided for a formal town centre from which major and minor axes radiated outwards to designated industrial and residential zones. Despite this geometric framework, the plan carefully correlated with the site’s existing characteristics, from the undulations of the land, to streams, an old Roman road, even trees and hedgerows. For example, a line of existing trees was preserved to shield the Birds Hill residential estate from the industrial area at the north-east of the plan.

A shared architectural language was a key ingredient of Parker and Unwin’s formula for communitas and unity. As early as June 1904, Unwin had drafted building regulations for Letchworth to ensure the new community had a unifying architectural identity. Specifically, traditional Hertfordshire village architecture was used as the blueprint. Chiefly, Unwin applauded the degree of unity achieved in older towns through the use of local materials. Popular Welsh slate was prohibited in favour of local red tiles; buildings were to be faced in red brick, or be pebble- dashed or colour-washed; house plots were to be defined by low hedges not walls. Building lines, groupings and standards of construction were all encompassed within Unwin’s regulations. To his thinking, the built environment and community were reciprocally entwined. Aesthetic consistency was a means towards social harmony, and the regulations he applied at Letchworth, informed by traditional village architecture, would express the values of cooperation and community that the ideal British village, for him, represented.

The town’s development was managed by a single master developer, First Garden City Ltd. Attracting business tenants was an early priority. A generous industrial area, supported by infrastructure, was laid out and a large number of businesses were attracted to Letchworth.

33 CASE STUDY 4: WELWYN GARDEN CITY

Welwyn Garden City was founded in 1919 as Britain’s second Garden City on a 962-hectare plot in Hertfordshire some 20 miles north of London to house a target population of 40,000-50,000. Master planned by Louis de Soissons, its design comprised a formal town centre surrounded by compact residential areas, less formal in layout than the centre, planned to conserve original trees and hedgerows and follow the contours of the land, plus an industrial area east of the existing railway line. Urban areas were kept as compact as possible to be in walking distance of the shopping and industrial area.

Welwyn Garden City Ltd (the Company) sought to maintain control of the Town’s development to ensure it was built in line with the Garden City concept. It aimed to achieve this in three ways: it would keep the freehold of the land thereby retaining control of it, selling only leasehold rights (on a 999-year-term) to housing and industrial sites; it would only grant short leases for retail shops and commercial premises; and it would insist that its architect had overall design control over everything built.

Under Louis de Soissons, supported by a team of consultants, Welwyn Garden City had a clear and considered masterplan complemented by a strong To avoid Welwyn becoming a dormitory suburb, the architectural identity. Roads were designed as ‘street development of the town centre and industrial area were pictures’, in which houses were planned in groups and early priorities. It was essential to the town founders to conceived in tandem with planting. As a result, moving build a varied economic base as soon as possible. through the town is a gratifying urban experience, with each composition different to the last. The Company realised that enticing industry was pivotal to the success of the Town, and it made vigorous efforts De Soissons had complete control over the aesthetics of to do so, offering manufacturers the best conditions and all development. The commercial and residential designs services: low rates and reasonable charges for utilities on a of Welwyn Garden City are exemplars of the interwar planned industrial site with good road and rail facilities. The period. They use traditional materials and forms, and well- industrial zone was laid out with plots and units of different proportioned neo-Georgian detail. Within the overarching sizes and good transport links, including private railway neo-Georgian style, residential areas were differentiated sidings. in coordinated and diverse schemes. As a promotional booklet for the Town endorsed, ‘to a greater extent than in The policies adopted towards shops and commercial any other town it has been the general practice to design premises were of major importance to the Garden City’s streets as a whole – to consider the grouping of houses practical success. The Company determined to develop and other buildings as well as the individual units’. The the commercial core itself; there would be no sites open Company supported de Soissons in upholding a firm set of to speculative development and all buildings would be architectural guidelines which ensured stylistic harmony designed and built by Welwyn Garden City Ltd. It set up and building quality. Welwyn Stores Ltd, and allotted it a 10-year monopoly, operating from a temporary building.

34 35 3. Successful Garden Villages for the Twenty- and elderly – has independence of movement; First Century reduces traffic congestion and pollution; and encourages social interaction. 3.1. The Garden Village concept today denotes vibrant, beautiful, diverse and affordable settlements that • Diversity of housing: includes a full range of interweave housing, community facilities and housing types reflecting a range of needs and services within a landscape setting. Drawing on the aspirations to encourage a varied and resilient lessons of the original Garden City communities, community. the key principles of modern Garden Village development can be distilled as: • Long-term stewardship: active management over the community’s lifetime via a defined • Holistically planned: guided by a arrangement that covers, for example, comprehensive master plan, flexible enough maintaining the public realm and community to evolve over the course of development. infrastructure and organising social events. Involves a defined arrangement for how • Patient investment: commitment to early assets will be looked after in perpetuity. investment in community infrastructure that reflects a long-term approach to returns. • Employment opportunities: locally accessible employment. • Single master developer: the lifespan of the development is guided by a single master • Access and connectivity: embedded developer, who ensures that the original movement network that makes walking, vision is maintained. cycling and public transport easy and attractive options. Integrated within a wider • Well-being: planned to foster healthy and strategic transport network to ensure good active living through access to green space, connections to surrounding areas and connection to nature, encouraging walking facilities. and cycling and opportunity to grow food locally. 3.2. The current standard approach to development results in perpetuating patterns of monocultural • High-quality design: a place characterised housing, largely segregated into larger clusters by keen attention to detail, high-quality containing units of similar type and cost, thereby materials and sensitivity to the architecture inhibiting socio-economic diversity. Vehicular and landscape character of the local area, traffic controls the scale and form of public space, resulting in a characterful place of unique with streets being primarily dedicated to the car. In identity. contrast, applying the principles above will result in compact, walkable and characterful neighbourhoods • Landscape: marrying town and country. A that bring together the best of the urban and natural variety of open space types, communicating environment. This provides the foundation for the power of the natural environment healthy, diverse and resilient communities with clear to enhance wellbeing and support identities and reduced dependence upon the car. environmental resilience. Development that is informed by and augments the natural 3.3. Several developments currently in progress or environment, including an extensive green nearing completion in the UK espouse these infrastructure network. principles and pay acknowledged reference to the original Garden City communities. Places such as • Services and amenities: provides a range of Poundbury in Dorset, Chapelton in Aberdeenshire services to meet day-to-day needs within and Tornagrain in the Scottish Highlands are walking distances of homes. This walkability grounded in the tenets of traditional urbanism. ensures that everyone – especially the young

36 CASE STUDY 5: POUNDBURY

Poundbury is an urban extension sited to the west of Dorchester, bounded on all but one side by farmland. It is a mixed urban development of town houses, cottages, shops and light industry built across 162 hectares of land owned by the Duchy of Cornwall developed as an opportunity to showcase an alternative model for urban development.

Following English traditions of urban design, the masterplan (initially prepared in 1988) features a phased network of four neighbourhoods, each with a commercial core. Commercial buildings are integrated amongst residential areas, shops and leisure facilities to help create a walkable community. The plan evinces a conviction that streetscapes should give priority to people rather than cars, for example, by using urban form to limit the speed of vehicles.

Social and private housing is interspersed throughout and indistinguishable from the outside. A high-quality environment has been strived for through the choice of materials, landscaping and other features, such as signage and traditional house designs. The aesthetic is tightly guided by a Building Code, which regulates architectural features, such as roof angles and chimneys. The quality of design and workmanship is also controlled by the Duchy, through legally binding Building Agreements. Homes are constructed with environmental impact in mind, incorporating, for example, high levels of insulation and market-leading sustainable technologies.

From the outset, the project has had a high profile. The architectural profession was initially quick to criticise the so-called historical pastiche of the building form. The success of the scheme lies in the structure and form of the urban design, the prioritising of pedestrian movement over vehicles, the ability to deliver mixed use and tenure in relative high density and its success in attracting a variety of businesses.

37 CASE STUDY 6: TORNAGRAIN

Built on 259 hectares of land owned by the Moray family since 1592, Tornagrain is a new town for the Scottish Highlands outside Inverness under development since 2002 by the Earl of Moray. Designed to New Urbanist principles, at completion it will provide 4,500 homes.

The masterplan takes the form of a town centre – the focal point of commercial and retail activity – flanked by three neighbourhoods, each with their own local centre providing basic services. Neighbourhoods are planned within five-to- ten-minute walking distances of local amenities, including schools, shops and sports facilities. Housing – including detached, flats, cottages and terraces – is attractive and mixed tenured, interwoven amongst plentiful green space. The plan is intended to create a compact, diverse and walkable community that minimises car use and fosters social interaction.

From the outset, the objective has been to root the new community in its regional context. It looks to town and village precedents in the local area, and slightly further afield, to inform the masterplan and architectural design. Many parks and public spaces, for instance, follow the scale and syntax found in these places, whilst the architectural variety present in Tornagrain is intended also to echo those found in these models.

The town will be developed over a period of decades and, in order to control this development, a Design Code is in force. The Code is in essence a set of instructions for the delivery of the town; it regulates aspects of the built environment to ensure delivery of the plan. These include regulating the street network, building configuration and relationship to the street, civic spaces and parks, lighting, building scale and mass, building use, materials and lighting.

38 CASE STUDY 7: CHAPELTON

Chapelton is a new town in Aberdeenshire being promoted by the Elsick Development Company (EDC), a family- controlled company representing the Duke of Fife and neighbouring landowners. Construction commenced in 2013. The community, which is anticipated to accommodate 4,045 houses by 2023 and up to 8,000 in the long-term, is designed to encourage pedestrian activity and lessen car dependence, with shops, jobs and schools all within walking distance of all residences.

Under the master plan, 840 hectares of agricultural land is transformed into a nexus of seven neighbourhoods plus a town centre, separated from existing residential settlements in the vicinity by a generous green buffer zone. A hierarchical network of roads and open spaces weaves throughout the plan, providing the structure upon which its urban form hangs and linking each of the neighbourhoods. Whilst the town centre is designed as Chapelton’s commercial and civic heart, shops, schools, dentists and other amenities are also distributed throughout the individual neighbourhoods, clustered in their highest proximity at designated neighbourhood centres. Following core principles within New Urbanism, walkability is essential to this structure. A walkable environment fosters opportunity for social interaction and community building.

Both the urban morphology and architectural language within Chapelton are inspired by Scottish precedents, and conform to a Pattern Book that ensures development adheres to the original vision. Each neighbourhood contains a mix of housing types — from flats, to terraces, to large farm steadings — to enable a rounded population from the young to the old and a range of environments progressing from the urban to the rural. The continuum of environments, from urban to rural, higher to lower density, is a sequence that is commonly encountered in the urban fabric of historic towns, but it is rarely replicated in modern development in the UK. Within each neighbourhood, there will be a transition from the quieter, outlying blocks of purely residential streets, through increasing densities and greater mix of uses, to the local centre. This rhythm is already reflected in Cairnhill, the first neighbourhood to be built.

39 4. Landowner Legacy 4.5. Their roles can be summarised under two main functions: 4.1. A common thread running through this narrative is the landowner’s aspiration to legacy. Whether the • Design regulation, via building codes historic models, like Bournville and New Earswick, applicable during initial development and any or contemporary examples, such as Chapelton subsequent alterations and Tornagrain, what unites these best-practice exemplars is the presence of a single, long-term • Maintaining common, unadopted areas of the landowner with a vested interest in the site and community an aspiration towards leaving a positive legacy. In contrast, the majority of new development schemes 4.6. In so doing, they act as a vehicle for sustaining and are carried forth on a basis by which the developer protecting in perpetuity the unique features of the has no long-term financial stake in the land. Their settlement – its buildings, public realm, facilities and priorities lie in the immediate satisfaction of their their characteristics and identity – that encourage shareholders. The difference this makes is enormous. civic pride, identity and interaction. This in turn leads to greater value being placed upon community spirit, 4.2. Development by a single, long-term landowner is, encouraging sound investment and creating benefits arguably, the only route that allows an extended, for those who live, work or visit the settlement. measured view of development. The ability to adopt a patient perspective on financial returns creates 4.7. This long-term, guardianship role is very different considerable opportunity to innovate beyond the from the objectives of the private management norm. With it, the premium that highly crafted companies set up to service small residential estates construction, well-considered design and mixed use that are found across the country. The latter are will reap over time can be appreciated. Ultimately, used by developers as a means of disposing of the this will secure a better place in the long run. obligation and liability of maintaining non-adopted space without the cost of providing resources for 4.3. This approach is grounded in the principle of future maintenance, such as an endowment or capturing uplift that informed the original Garden commuted sum. Cities and model villages. Both Letchworth and Welwyn were, for example, delivered by single bodies acting as the landowner, which were able to capture the land value uplift resulting from development. This uplift then financially supported the delivery of the towns’ physical and social infrastructure. The process of capturing land value gains takes time, though, and thus is often not attractive to conventional investors.

4.4. Long-term landownership also facilitates long-term stewardship. It captures the original ethos of Garden City governance, which meant that stewardship was undertaken for the benefit of the community and that the community had a stake in the settlement’s future. For the original Garden Cities, model villages and contemporary exemplar planned settlements, having a collective vision was fundamental to building momentum in the creation of community identity. Stewardship bodies have historically, and continue to be, valuable means of supporting this vision.

40 CASE STUDY 8: CHAPELTON

Chapelton is being delivered by the Elsick Development Company (EDC), led by The Duke and Duchess of Fife. The majority of the land making up the new town has been in their family since the fourteenth century. From the outset, the EDC has pursued a long-termist approach. This is underscored by the early decision it made to install all the initial physical infrastructure – roads, sewerage, water – itself. This was an expensive decision – it entailed an investment of some £9 million – but it meant that the EDC would not be incumbent upon a developer to put the infrastructure in place and thereby it would retain absolute control of the overall direction of the scheme and its quality.

Furthermore, it has also made early investment into the social infrastructure. One of the first tangible manifestations of Chapelton was Teacake, a café housed initially within a temporary cabin at the entrance to the town. It is not a profit-making venture for the EDC, yet it was the formation of the community before the physical reality had occurred. A nursery soon opened alongside it, followed by a hair and beauty salon. A typical volume builder would reason such commercial premises were financially unviable for a population of such a scale and make no provision for their inclusion, thereby perpetuating the prevailing pattern of car-dependent settlements lacking the critical mass of services needed to become viable communities. For the EDC, however, cultivating a vibrant atmosphere by creating opportunities for residents to interact was integral to the wider ambition, and indicative of its long-term interest in building a rounded, desirable place to live.

Since the arrival of the first residents in February 2015, the EDC has tried to engineer community feeling, organising Christmas celebrations, charity bike rides and even gin tastings. Each new resident gets invited to participate in a tree-planting event and barbeque, in which saplings are planted within a new recreational woodland at the east of the site.

41 CASE STUDY 9: TORNAGRAIN

Stewardship of the new town is assigned to the Tornagrain Owners Association, which owns all shared property or common areas at Tornagrain not owned by individual homeowners or which do not form adopted common roads, and the Tornagrain Conservation Trust, a not-for-profit private company.

The role of the Association is to maintain common open space and community facilities, such as tennis courts and encourage and promote community development through social, educational, cultural or other communal activities.

The role of the Trust is to oversee and secure the design principles and qualities of the town’s built environment by regulating alterations and new development to ensure that the distinctive vision for Tornagrain’s built environment is upheld now and in the future. It achieves this via ‘conservation burdens’, set within property owners’ legal agreements. The purpose of the burdens is to control alterations to plots and buildings and new development, ensuring that the town Design Code is adhered to. Residents wishing to make changes must seek permission in the first instance from the Trust.

42 CASE STUDY 10: BOURNVILLE

Bournville has been managed by the Bournville Village Trust (BVT) since 1900, a charitable trust independent of the Cadbury family or company set up to safeguard the direction of the village’s development.

BVT has a broad range of responsibilities that includes supporting community-based initiatives and protecting the visual amenity of the estate through its Scheme of Management. The latter ensures that any new development or alterations are considered within the context of the property, streetscape and surrounding area. It exercises strict design controls to retain the original standards of design and materials, based upon regulations encapsulated within the Bournville Estate Design Guide. The Design Guide (regularly updated) provides guidance for homeowners on the most frequent types of alterations and extensions, such as materials, garage and loft conversions, fences, garden buildings and driveways. Residents must secure permission from the BVT before applying to the Local Authority.

In terms of community-based initiatives, the Trust funds activities such as lunchtime concerts and youth clubs and manages community assets, including four community halls and Selly Manor Museum. It established a Community Hub (now run by the Busy Parents Network), that hosts language classes, yoga, pilates, tutoring sessions and more.

43 44