Green Belt Study Stage Two Report (August 2018)

Tonbridge & Malling Borough Council

Local Plan

Green Belt Study: Stage Two Report

August 2018

Table of Content

1. Introduction ...... 1

2. The Wider Context – Delivering Sustainable Development in Tonbridge and Malling ...... 2

3. Exceptional Circumstances for the removal of land from the Green Belt Designation – Sustainable Patterns of Development ...... 6

4. Exceptional Circumstances for the extension of the Green Belt Designation ...... 12

5. Summary and Conclusions ...... 13

Green Belt Stage Two Report – Appendix 1: Proposed Amendments ...... 15

Green Belt Stage Two Report August 2018

Green Belt Study: Stage Two Report (August 2018)

1. Introduction

1.1. The borough of Tonbridge and Malling has 71% coverage of Green Belt. The Local Plan is bound to address significant needs for development and in so doing the Council has considered the case for amending the boundary of the Green Belt. This has been carried out within the context of some clear objectives that have emerged for the Local Plan strategy which provide a clear context for such a review.

1.2. The purpose of this report is to establish the exceptional circumstances for amending the Green Belt boundary in Tonbridge and Malling as part of the preparation of the Local Plan, having already considered the relative merits of the Green Belt across the borough in the Stage One Green Belt report (September 2016).

1.3. This Stage Two report complements the Stage One Green Belt Study, which assessed the current extent of the Green Belt in the borough and concluded that in general it continues to perform well in response to the purposes of including land with the designation as set out in the National Planning Policy Framework (NPPF, March 2012).

1.4. The Stage One report also set out options for the next stage in plan-making (para 8.1.3):

Option 1 – Review the Study in light of other emerging evidence, and outcomes from consultation exercises in respect of the Local Plan.

Option 2 - As part of the need to promote sustainable patterns of development (paragraph 84 in the NPPF, March 2012), more detailed study into land identified as having a limited contribution to the purposes of the Green Belt could be carried out, so that specific areas can be studied at a closer scale.

Option 3 – As part of the Local Plan and collection of evidence, more detailed study of those areas performing well could be carried out, in order to consider ways of strengthening/protecting the designation/boundaries where assessed as being successful/clear, perhaps by improving access for recreation for example or by meeting other objectives.

1.5. This report aims to respond to this by taking into consideration other parts of the Local Plan evidence base and responses to the public consultations (option 1, see

1 Green Belt Stage Two Report August 2018

above) in making the case for exceptional circumstances for removing the designation from sufficient sites to deliver a sustainable pattern of development in accordance with national planning policy (option 2, see above) and also for an extension of the designation to prevent the coalescence of settlements and to protect heritage assets (option 3, see above).

1.6. Appendix 1 illustrates the proposed amendments to the Green Belt boundaries applying the general principles for exceptional circumstances established in this report.

2. The Wider Context – Delivering Sustainable Development in Tonbridge and Malling

2.1. Housing - Tonbridge and Malling borough is located in west Kent and is covered by two Housing Market Areas (HMAs). The eastern part of the borough is located within the Maidstone HMA while the western part falls within the Sevenoaks, Tonbridge and Tunbridge Wells HMA which also includes the districts of Sevenoaks and Tunbridge Wells. The borough also shares administrative boundaries with Gravesham Borough Council and Medway Council to the north but the A2/M2 corridor and the Kent Downs represent a natural and functional boundary which effectively means, for planning purposes, that the borough is covered by the two main HMAs. The housing need for the Local Plan period (2011-31) is evenly distributed between the two HMAs (51% Maidstone HMA; 49% Sevenoaks, Tonbridge and Tunbridge Wells HMA).

2.2. The Maidstone HMA – Planning and other Constraints - That part of the borough in the Maidstone HMA is constrained less by Green Belt designation but more so by the Kent Downs Area of Outstanding Natural Beauty (AONB). In the Council’s adopted Development Plan, the Local Development Framework (LDF), there is also a Strategic Gap policy (CP5), a designation shared with the now superseded Maidstone Borough- Wide Plan (2000), which has the objective of seeking to prevent the coalescence of the built-up areas of Maidstone with Aylesford/Ditton/New Hythe (an area known as the Medway Gap).

2.3. Following the publication of the National Planning Policy Framework (NPPF) in March 2012 and the abolition of Regional Spatial Strategies in 2013, there is no longer a policy context for such a designation. As a consequence such a policy will not be included in the new Local Plan. It does not feature in the recently adopted Maidstone Borough Local Plan (October 2017).

2.4. The area covered by the Strategic Gap on both sides of the boundary has seen significant development during the current plan period with further development planned in the new Maidstone Borough Local Plan, particularly in the vicinity of Hermitage Lane. The Tonbridge and Malling Borough Local Plan seeks to address some of the capacity issues that have emerged by allocating a proportionate amount of development in south Aylesford in order that significant new road infrastructure can be delivered here.

2 Green Belt Stage Two Report August 2018

2.5. The Tonbridge and Malling Housing Delivery Study (September 2017) prepared by GL Hearn and Partners concludes that the market capacity of this area to deliver significantly more development over and above what is planned and proposed is limited because of the number of existing commitments (extant permissions and allocations). To significantly increase delivery would require annual growth rates in the dwelling stock that have not been sustained beyond the short-term in any part of the country, especially since the recession in 2008.

2.6. It is clearly evident that while this part of the borough will have fewer constraints in terms of Green Belt and other designations, there are market capacity issues that will provide a check on how much housing could be realistically delivered.

2.7. The Sevenoaks, Tonbridge and Tunbridge Wells HMA – Planning and Other Constraints - The part of the borough covered by the Sevenoaks, Tonbridge and Tunbridge Wells HMA is almost exclusively Green Belt, with the exception of the built confines of the larger settlements. This is a situation shared with Sevenoaks District to the west, which is 93% Green Belt. Tunbridge Wells to the south has less Green Belt (22%) but has a greater proportion of the High Weald Area of Outstanding Beauty (70%).

2.8. The Housing Delivery Study prepared by GL Hearn and Partners adopted a ‘policy off’ assessment with regard to the existing Green Belt designation, i.e. it did not take account of the Green Belt and other policies that are shaped during the plan-making stage. The Study found that this HMA has more market capacity for delivering additional housing growth compared with the Maidstone HMA. This is a reflection of its strong market characteristics and proximity/links to London.

2.9. In summary, both HMAs face a number of challenges in terms of planning and other constraints in meeting future assessed housing needs. These have been taken into account in the proposed development strategy in the Local Plan as explained below.

2.10. Employment - In addition to meeting future needs for housing, the Employment Land Review (November 2017) prepared for the Local Plan has identified a need for 46.8 hectares of additional employment land over the plan period (Update of Employment Land Needs in Tonbridge & Malling, November 2017). Some of this need is planned to be accommodated by the intensification of uses on existing economic development sites and some is planned to be met on new sites that have been identified through the plan-making process.

2.11. As a consequence of the Green Belt boundaries not being altered significantly since they were established in 1983, there are limited opportunities for new employment sites in appropriate locations such as Tonbridge, the principal town in the borough.

2.12. Past Performance - Despite the extent of Green Belt, two Areas of Outstanding Natural Beauty and other planning constraints, Tonbridge and Malling has a good track record of housing delivery averaging 604 dwellings per annum for the last 10 years (2007/08 – 2016/17). This contrasts with the annual housing target of 450 dwellings per year in the Local Development Framework, adopted between 2007 and

3 Green Belt Stage Two Report August 2018

2010, reflecting the then South East Plan Regional Spatial Strategy (abolished in 2013).

2.13. The Strategic Housing Market Assessment (SHMA) for the new Local Plan has identified an Objectively Assessed Need of 696 new dwellings per annum, which represents a significant uplift of the previous South East Plan target and past delivery rates. The Local Plan evidence base demonstrates that this level of delivery can be achieved, if sufficient sites are identified.

2.14. The LDF included a number of major brownfield development sites, including the former airfield at Kings Hill, the former Leybourne Grange hospital site and Holborough Quarry. These sites together with a range of smaller and medium-sized sites enabled a sustained level of delivery over the early part of the plan period and helped maintain a five year housing land supply until 2017.

2.15. The number and size of suitable and deliverable brownfield sites for the new Local Plan is less assured. The Call for Sites exercise identified only sufficient sites to deliver 267 new dwellings on brownfield sites across the whole borough. The amount of brownfield land in Tonbridge, Hadlow, Hildenborough, East Peckham and Borough Green combined is 2.16ha, likely to produce a yield of 80 to 100 dwellings.

2.16. The delivery of employment uses has been similarly successful. The Employment Land Review (NLP, 2014) notes that:

‘Tonbridge and Malling has a relatively successful local economy which has recorded significant job growth over the last 16 years. The business base is dominated by small and medium-sized enterprises and characterised by relatively good levels of entrepreneurial activity. Workforce productivity is relatively low which may in part reflect a mismatch between lower skilled jobs available and a more highly qualified resident workforce, many of which commute out of the Borough to higher paid employment elsewhere.’

2.17. A key objective of the new Local Plan is to continue to deliver sustainable development to meet future needs where they are identified and to re-establish a robust five year housing land supply by building on the successful strategy and performance of the LDF.

2.18. The Tonbridge and Malling Borough Local Plan - The Way Forward Regulation 18 consultation document prepared in September 2016 and subject of a public consultation exercise that followed, proposed a strategy for meeting the objectively assessed needs that reflected the guiding principles for delivering sustainable development. The objectives and principles were:

4 Green Belt Stage Two Report August 2018

Plan Objective 1: As far as possible to provide for homes and jobs that are best suited to meet identified local needs.

Plan Objective 2: Support and sustain local communities across the borough, big and small, by planning to meet identified needs, including needs for community facilities.

Plan Objective 3: Protect high value, important natural and heritage assets.

Plan Objective 4: Deliver sustainable growth to support urban and rural economies, making the best use of infrastructure.

The principles identified to guide decisions about the location of future development are as follows:

1. Focussing opportunities adjacent to the principal urban areas of the Medway Gap and Tonbridge, in each housing market area 2. Focussing opportunities adjacent to a range of settlements across the borough to help support and sustain local communities, big and small 3. Locating new development in reasonable proximity to transport hubs, utilising and building upon existing infrastructure 4. Locating new development in the least constrained parts of the borough 5. To provide a mixed portfolio and location of sites, big and small, to meet a range of needs throughout the duration of the plan period up to 2031, over the short-term (up to 5 years), medium-term (6-10 years) and over the long- term (11-15 years) 6. To deliver a level of growth at key locations to facilitate significant improvements to support infrastructure, eg schools, highways and healthcare, for the benefit of local communities 7. Focussing development on the contribution that larger potential sites could deliver in a proportionate way to meet wider plan objectives and ensure delivery in the plan period.

2.19. The document explained that:

‘To meet the needs we have identified we start by looking at the sites and the opportunities that the Government and our own residents would expect us to prioritise, for example, any sites that have been previously developed (also known as ‘brownfield’ sites) and other sites located within built up areas that are at the least risk from flooding. There are also sites in the current Plan that have been previously identified as having potential for meeting future needs, safeguarded sites and opportunity areas. We have called these the building blocks for the strategy. They are the obvious starting point, but they alone will only meet about a third of our needs.

To meet the remainder we have applied a number of guiding principles based on national and local planning policy objectives. These include meeting needs where they arise across the two housing market areas and making the most of existing

5 Green Belt Stage Two Report August 2018

infrastructure by locating development around transport hubs, for example in locations close to railway stations and bus routes.

It is also important to ensure that there is a range of sites, both large and small, so that the benefits of new growth can sustain local services and businesses in some of our smaller settlements while also delivering a higher volume of new homes through larger developments to sustain our 5 year housing land supply which we are required to make available.

Some of those larger sites may also provide opportunities to deliver much needed, strategic infrastructure improvements, such as relief roads or new schools, the funding for which from more traditional sources is falling. However, such sites should be of a proportionate size capable of delivering the infrastructure to meet the needs of the new community. ‘

2.20. The proposed strategy included a number of sites in the Green Belt, where a case could be made for the designation to be removed to allow development to take place. In addition, an extension to the designation was proposed to the east of West Malling.

2.21. The Regulation 18 consultation responses generated in excess of 3,000 representations. These were grouped into themes, taken into consideration and a response prepared, which was the subject of a report to the Council’s Planning and Transportation Advisory Board on 25th July 2017.

2.22. In relation to the Green Belt, the Council received 198 representations overall; 152 of these related specifically to the proposed Green Belt extension at West Malling/Kings Hill. 86% were representations of support for the extension with 14% objecting to the proposal. The remainder of the comments were made in respect of individual sites and a general objection to the release of any land from the Green Belt for development. There was a small number of comments that recognised and supported the need to release land from the Green Belt in order to meet development needs.

2.23. The strategy was refined in the light of new evidence as it became available, the responses to the consultation and other relevant information such as changes in land ownership. These refinements did not change the general objectives and principles underpinning the new Local Plan, which have remained constant.

3. Exceptional Circumstances for the removal of land from the Green Belt Designation – Sustainable Patterns of Development

3.1. National Planning Policy Context - Paragraph 84 of the NPPF (March 2012)sets out the factors to consider when reviewing green belt boundaries:

‘When drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. They should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns

6 Green Belt Stage Two Report August 2018

and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary’.

3.2. It is very clear that when reviewing Green Belt boundaries the outcome of the process needs to allow sustainable patterns of development to take place. Meeting assessed development needs wholly beyond the unaltered outer extent of the Green Belt would not necessarily comply with this national policy if the resultant pattern of development is proven to be unsustainable.

3.3. One significant measure of a sustainable pattern of development is how the location of new homes relates to existing centres of population and services within the respective Housing Market Areas. Such centres are focal points for a significant amount of daily activity eg places of work/education/shopping etc. Against this measure, locating new homes close to where the need is generated, is the strategy most likely to result in a sustainable pattern of development because the length of trips, especially by the car, is minimised and overall the activities of people in communities can be more conveniently built around local services and contacts.

3.4. Identifying the Objectively Assessed Needs for Housing - Taking into account dwellings that have been completed since 2011, sites with planning permission or under construction, remaining allocations in the current LDF, addressing the shortfall of supply accrued since the base date of the Local Plan and a modest allowance for windfalls, the net housing need that the new Local Plan is required to address in allocating future sites for development is approximately 6,500 dwellings (up to 2031). The SHMA evidence demonstrates that approximately half of the objectively assessed need for new housing over the plan period (49%) is located in the Sevenoaks, Tonbridge, and Tunbridge Wells HMA, which is almost exclusively Green Belt.

3.5. Meeting assessed need outside of the Green Belt - The Way Forward looked first at the contribution that brownfield sites, safeguarded sites, areas of opportunity and other sites within the built confines of settlements could contribute to meeting future needs. It concluded that these ‘building blocks’ of the strategy could only deliver an estimated 2,363 dwellings based on an estimated yield of 30 dwellings per hectare over the developable area.. 3.6. The most significant potential (from the building blocks) is from safeguarded sites (already removed from the Green Belt in the LDF) and the area of opportunity at Bushey Wood, Eccles. The latter is located beyond the outer extent of the Green Belt within the Maidstone HMA. The potential contribution from the building blocks located within the Sevenoaks, Tonbridge and Tunbridge Wells HMA only, is not significant. Consequently, in order to deliver a sustainable pattern of development, i.e. meet the needs arising in the part of the borough in the Sevenoaks, Tonbridge, Tunbridge Wells HMA, sites within the Green Belt will have to be considered.

7 Green Belt Stage Two Report August 2018

3.7. Extract from The Way Forward (Sept 2016):

Building Potential Description Block Yield

Meeting identified development needs on brownfield land within the built-up A 267 confines of settlements Meeting identified development needs on land safeguarded in the existing B 2,087 Development Plan for future development, including the area of opportunity Meeting identified development needs on land at low risk of flooding within C 276 existing settlements Total Potential Yield 2,363*

*excluding double-counting where there is overlap between the building blocks

3.8. Meeting unmet need elsewhere in the borough beyond the outer Green Belt boundary or in neighbouring local planning authorities - The alternative to removing sites from the Green Belt would be to channel some of the unmet need of the Sevenoaks, Tonbridge and Tunbridge Wells HMA towards locations beyond the outer Green Belt boundary in the Maidstone HMA part of the borough or further afield beyond the borough boundary in neighbouring districts. This is a less sustainable option given that the main centres (Tonbridge, Tunbridge Wells and Sevenoaks) are a significant distance from these areas but it needs further consideration.

3.9. Although less constrained by the Green Belt, the part of the borough within the Maidstone HMA has other constraints and capacity issues as noted above. In addition, this part of the borough also has to deliver its own proportion of the total OAN if sustainable patterns of development are to be achieved.

3.10. It is important to appreciate that this part of the borough is at a considerable distance from the centres for the Sevenoaks, Tonbridge and Tunbridge Wells HMA which are the towns of Tonbridge, Sevenoaks and Tunbridge Wells. With this in mind, channelling unmet need towards that part of the borough beyond the outer Green Belt boundary within the Maidstone HMA is likely to result in unsustainable patterns of development generating additional long trips by car across the borough towards Tonbridge and beyond to the west for a significant amount of daily activities, eg commuting for work.

3.11. To channel growth further afield outside of Tonbridge and Malling borough beyond the outer edge of the Green Belt is likely to exacerbate an unsustainable pattern of development for the reasons given above.. There are also serious doubts as to whether neighbouring authorities would be able to accommodate additional growth. Discussions with these authorities through the Duty to Cooperate confirm that none of Tonbridge and Malling’s immediate neighbours would be able to take unmet need and some will struggle to meet their own needs.

3.12. Maidstone Borough Council has a recently adopted Local Plan that can meet its identified needs, but the plan has to be revised by 2021. The standardised

8 Green Belt Stage Two Report August 2018

methodology for assessing housing need published in ‘Planning for the Right Homes in the Right Places’ in September 2017 indicated that Maidstone would have to plan for an additional 353 dwellings per year in their next Local Plan. It is unlikely, therefore, that Maidstone will be in a position to meet unmet need.

3.13. To the west, Sevenoaks District Council has consistently indicated that they will be very challenged to meet their needs and Tunbridge Wells faces similar challenges. Both authorities will have to take into account the uplift from the standardised methodology but these are less significant compared to the increases in the assessed needs for Maidstone and Tonbridge and Malling. Nevertheless, there is no capacity to accept unmet need from Tonbridge and Malling.

3.14. To the north, there is a similar situation with Gravesham and Medway. The former is facing similar constraints in the form of the Green Belt and Sites of Special Scientific Interest (SSSIs), while the latter has the largest uplift from the standardised methodology of any authority in Kent & Medway. In fact, no local authority in Kent has indicated that they may be able to accommodate unmet need from neighbouring areas.

3.15. The position is repeated beyond the administrative area of Kent. The draft London Plan (2018) aims to deliver 66,000 homes a year through a development strategy that looks to the outer London boroughs to take a higher proportion of the new growth through densification (increasing densities). To put this into context, the current target in the existing London Plan is 49,000 dwellings per annum. It is evident that delivering the proposed target will be challenging, providing limited scope to address unmet need from areas beyond London. In any event, the preparation of the London Plan is not subject to the Duty to Cooperate – it is subject to the duties to inform and consult – because it is not covered by the definition of a development plan document.

3.16. There is a similar position in the other home counties in the South-East.

3.17. Consequently, there are no genuine options to allow for sustainable patterns of development in Tonbridge and Malling to take place that do not involve the release of some sites from the Green Belt.

3.18. Similar arguments have been accepted as exceptional circumstances in recent Inspectors’ reports, for example Cheshire East Council Local Plan Strategy.

3.19. Identifying the Objectively Assessed Needs for Employment Land - The Employment Land Review (November 2017) has identified a need for additional employment land in the west Kent Functional Economic Market Area (FEMA). Similar arguments for the exceptional circumstances for housing sites apply to the location employment sites.

3.20. In order to effectively deliver sustainable patterns of development, local employment opportunities should be planned alongside new housing to minimise commuting distances and therefore times, particularly by the car. To demonstrate exceptional circumstances just for housing sites and not for employment sites would be counter- productive and would not deliver truly sustainable patterns of development.

9 Green Belt Stage Two Report August 2018

3.21. Addressing Housing Affordability and Providing Opportunities to Deliver Affordable Housing - The ONS Statistical Bulletin for Housing Affordability 2017 (April 2018) identified an affordability ratio of median house prices (£340,000) to median incomes (£28,865) in Tonbridge and Malling borough of 11.78. This compares to a ratio of 9.97 in 2015 and 11.33 in 2016, indicating a worsening of housing affordability. To put this into context, the housing affordability ratio for England in 2017 was 7.91 whilst the housing affordability ration for Kent was 10.17.The affordability ratio for Tonbridge & Malling borough is slightly higher than Maidstone (10.12), but lower than Sevenoaks (14.59) and Tunbridge Wells (13.35). It is evident that housing affordability is a significant issue in Tonbridge and Malling borough.

3.22. Releasing sites from the Green Belt provides opportunities for improving housing affordability through the delivery of a sufficient number of homes where they are needed in a sustainable pattern. The delivery of homes on these sites can also provide significant opportunities to help address the identified affordable housing need, which is 277 homes per annum (Strategic Housing Market Assessment, 2014).

3.23. Other local planning authorities in the South-East have made similar arguments, for example, Elmbridge Borough Council (Elmbridge Local Plan, Exceptional Circumstances Case, September 2016).

3.24. It is considered, therefore, that exceptional circumstances exist for allowing the release of land from the Green Belt to address the significant issue of housing affordability in the borough. This action, in turn, will allow the Council to address the identified need for affordable housing. Not releasing land from the Green Belt and concentrating growth beyond the outer edge is likely to result in unsustainable patterns of development given the location of the main centres in each HMA, whilst limiting the development sites and not meeting in full the assessed need is likely to result in the worsening of housing affordability as well as curtailing the opportunities to deliver affordable housing.

3.25. Delivery of infrastructure - One of the guiding principles for the Local Plan is to deliver a level of growth at key locations to facilitate significant improvements to support infrastructure for the benefit of local communities (The Way Forward - Guiding Principle 6).

3.26. The rural service centre of Borough Green is located in the Sevenoaks, Tonbridge and Tunbridge Wells HMA. It is inset within the Green Belt designation and has an Air Quality Management Area along the route of the A25 passing through the settlement. One of the reasons for the poor air quality is traffic using the A25 road as an alternative route to the M25/M26. .

3.27. The route of a Borough Green by-pass was safeguarded in the LDF but not implemented. The economic case for adding east facing slips at junction 5 of the M25 was prepared in 2009 and revisited in 2016 but was not successful in obtaining priority funding at that time.

10 Green Belt Stage Two Report August 2018

3.28. The Local Plan provides an opportunity to deliver a new relief road for the centre of Borough Green as part of a significant housing development north of the rural service centre, utilising active and former minerals sites that are located within the Green Belt that have effectively been despoiled and inaccessible for many years. These areas of land are relatively contained and the resulting built confines and revised Green Belt boundary would result in a long-term defensible position.

3.29. No alternative funding has been identified for this important piece of infrastructure, meaning that it can only be delivered through the development plan-making and decision-taking processes. The proposed strategic development site will also provide other local infrastructure including education provision, health care and public open spaces. It will also stimulate local businesses and infrastructure providers through an injection of additional customers.

3.30. Another proposed Local Plan strategic housing site within the Green Belt is located in south-west Tonbridge. A significant part of this proposed allocation is outside of the Green Belt on safeguarded land identified in the LDF. However, two other parcels of land will need to be removed from the Green Belt to allow the full delivery of the strategic site. This quantum of development generates the need for a new primary school in an area where suitable sites for new infrastructure are challenging to find.

3.31. In the event that the two parcels of land in south-west Tonbridge are not released from the Green Belt, the resultant reduced quantum of development would not be of a sufficient size to generate a new school in its own right but instead would simply add to the significant capacity issues that are already evident.

3.32. Elsewhere around Tonbridge land in the north-west sector at Coblands Nursery and at Stocks Green Road in Hildenborough are proposed to be allocated for housing development. In addition an area to the east at Postern Lane is allocated for employment development. Bearing in mind that Tonbridge is the principal settlement in the borough, it is a proportionate approach in addressing development needs to expect this comparatively modest quantum of housing and employment development to take place. The sites selected are relatively contained.

3.33. In the rural service centres of West Malling, Hadlow and East Peckham the emerging Local Plan has adopted a selective approach to ensure that a degree of new development comes forward in order to provide for local growth and make a reasonable contribution to the economic well-being of those centres. The sites selected in the development strategy will fulfil that function and in themselves will provide for sustainable locations for living.

3.34. It is considered, therefore, that exceptional circumstances exist for allowing the release of land from the Green Belt to facilitate the delivery of beneficial pieces of infrastructure. Without these releases, significant pieces of infrastructure would not be delivered meaning that improvements to local environments in terms of air quality, pedestrian safety and general amenity (Borough Green) and the expansion of education provision in an area of significant capacity issues (south-west Tonbridge) would not be achieved.

11 Green Belt Stage Two Report August 2018

4. Exceptional Circumstances for the extension of the Green Belt Designation

4.1. There is one proposal in the Local Plan to extend the Green Belt designation to the east of West Malling to cover an area between the settlements of West Malling, Leybourne (part of the Medway Gap urban area), East Malling and Kings Hill (excluding the proposed strategic housing allocation at Broadwater Farm, north of Kings Hill).

4.2. The Local Plan – The Way Forward document (September 2016) proposed a more modest extension to the Green Belt around West Malling. This involved re-aligning the outer Green Belt boundary to the A228 Ashton Way By-Pass, a piece of infrastructure that was constructed after the detailed boundaries were established.

4.3. The proposed extension was supported by consultation responses but many felt the extension should go further east to prevent the coalescence of settlements. With this in mind, the location of the outer boundary of the Green Belt at this location was re- examined and consideration was given to extending it east to Wateringbury Road.

4.4. When examining the coverage of the Green Belt it is important to have regard to the purposes it serves in the borough and whether or not these purposes can be strengthened through the redefining of the boundary in a way that does not put at risk the delivery of the proposed Local Plan strategy for meeting identified development needs. These are considered to be exceptional circumstances for extending the Green Belt boundary through the Tonbridge & Malling Borough Local Plan-making process.

4.5. The five purposes of the Green Belt are set out in para.80 of the NPPF (March 2012) and formed the basis of the Stage One Study (2016). In respect of the Green Belt covering Tonbridge and Malling borough the relevant purposes are:

• To check the unrestricted sprawl of large built-up areas; • To prevent neighbouring towns merging into one another; • To assist in safeguarding the countryside from encroachment; • To preserve the setting and special character of historic towns.

4.6. In order for there to be exceptional circumstances, each of these purposes needs to be strengthened by extending the Green Belt boundary whilst not frustrating the delivery of the proposed development strategy in the new Local Plan.

4.7. To check the unrestricted sprawl of large built-up areas - Extending the outer boundary to Wateringbury Road would help prevent the coalescence of Kings Hill with the conurbation of the Medway Gap area, two significant built-up areas in the borough. This extension is consistent with the proposed Local Plan strategy because it would allow for additional housing development at Broadwater Farm whilst restricting sprawl of these two urban areas.

12 Green Belt Stage Two Report August 2018

4.8. To prevent neighbouring towns merging into one another - The proposed extension would help strengthen this purpose by preventing West Malling, East Malling, Kings Hill and the Medway Gap from merging, thereby protecting their individual integrity.

4.9. To assist in safeguarding the countryside from encroachment - The proposed extension of the outer boundary would strengthen this purpose without frustrating the ability of the new Local Plan to address assessed development needs in a sustainable way. It would allow for the delivery of housing at Broadwater Farm north of Kings Hill whilst safeguarding the countryside north of this site from encroachment.

4.10. To preserve the setting and special character of historic towns - West Malling and East Malling are historic settlements including several Listed Buildings and being covered by Conservation Areas. The proposed extension of the outer boundary to Wateringbury Road would strengthen this particular purpose of the Green Belt by protecting the setting of these settlements which would help preserve their special characters.

4.11. It is clear from this analysis that exceptional circumstances exist for extending the outer boundary east to Wateringbury Road because such a change would strengthen the four purposes the Green Belt serves in Tonbridge & Malling in a way that is consistent with the Local Plan strategy for meeting identified requirements for sustainable development. The Local Plan proposals in this part of the borough therefore constitute an integrated and complementary strategy that can serve the area well in the long-term. From a strategic perspective, this extension would ensure a closer alignment with the outer boundary defined in the boroughs of Maidstone and Gravesham.

5. Summary and Conclusions

5.1. This report sets out the exceptional circumstances for the proposed amendments to the Green Belt boundaries that are necessary to deliver a sustainable pattern of development that will meet assessed needs and achieve wider planning objectives set out in the Local Plan.

5.2. If implemented the amendments would lead to a net increase of Green Belt land of approximately 200 hectares.

5.3. Appendix 1 illustrates the proposed amendments to the Green Belt designation that are supported by the exceptional circumstances set out in this report.

13 Green Belt Stage Two Report August 2018

14 Green Belt Stage Two Report August 2018

Green Belt Stage Two Report – Appendix 1: Proposed Amendments

Sites where there are exceptional circumstances for removing land from the Green Belt

1. Tonbridge a) North of Upper Haysden Lane b) South of Vauxhall Gardens c) South of Postern Lane d) Sites in North West Tonbridge (Coblands Nursery and Tonbridge Farm)

2. Hildenborough a) South of Stocks Green Road

3. Hadlow a) East of Carpenters Lane b) South of Court Lane

4. East Peckham a) South of Church Lane

5. West Malling a) South of London Road b) East of Offham Road

6. Offham a) Barfield House

7. Borough Green and Platt a) Land to the north of the rural service centre and settlement

15 Green Belt Stage Two Report August 2018

Site where exceptional circumstances are made for extending the Green Belt Designation

8. Land east of West Malling to Wateringbury Road

16 Green Belt Stage Two Report August 2018

Sites where there are exceptional circumstances for removing land from the Green Belt Map 1a Tonbridge – North of Upper Haysden Lane

17 Green Belt Stage Two Report August 2018

Map 1b Tonbridge – South of Vauxhall Gardens

18 Green Belt Stage Two Report August 2018

Map 1c Tonbridge – South of Postern Lane

19 Green Belt Stage Two Report August 2018

Map 1d Tonbridge – Sites in North-West Tonbridge (Coblands Nursery and Tonbridge Farm)

20 Green Belt Stage Two Report August 2018

Map 2a Hildenborough – South of Stocks Green Road

21 Green Belt Stage Two Report August 2018

Map 3a Hadlow – East of Carpenters Lane

22 Green Belt Stage Two Report August 2018

Map 3b Hadlow – South of Court Lane

23 Green Belt Stage Two Report August 2018

Map 4a East Peckham – South of Church Lane

24 Green Belt Stage Two Report August 2018

Map 5a West Malling – South of London Road

25 Green Belt Stage Two Report August 2018

Map 5b West Malling – East of Offham Road

26 Green Belt Stage Two Report August 2018

Map 6a Offham – Barfield House

27 Green Belt Stage Two Report August 2018

Map 7a Borough Green and Platt – Land north of the rural service centre and settlement

28 Green Belt Stage Two Report August 2018

Site where exceptional circumstances are made for extending the Green Belt Designation Map 8 Land east of West Malling to Wateringbury Road

29 Green Belt Stage Two Report August 2018

Local Plan Team Email: [email protected] Telephone: 01732 876268

If you have difficulty reading this document and would like the information in another format, please call 01732 876268 or email [email protected]