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Tudeley Village 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.
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