APPENDIX 1 KG CREATIVE CONSULTANCY Evidence On

APPENDIX 1 KG CREATIVE CONSULTANCY Evidence on behalf of West Malling and East Malling and Larkfield District Councils on the Consideration of the Extension of the Green Belt in Tonbridge and Malling District Council. 1. This Tonbridge and Malling draft Local Plan has been submitted to the Secretary of State for Examination. The new Local Plan will provide planning policies until 2031. The Regulation 18 version of the draft Local Plan proposed the extension of the Green Belt eastwards from the current boundary at West Malling as far as the A228. 2. The Submission version of the draft Local Plan now proposes the extension of the Green Belt boundary further east to broadly Wateringbury Road. The representations submitted by West Malling and East Malling and Larkfield Parish Councils seek the extension of the Green Belt further east again, to Kiln Barn Road, as shown on page 49 of the Councils document - Tonbridge & Malling Borough Council Local Plan Green Belt Exceptional Circumstances Topic Paper (ED10). 3. The first hearings (Stage 1) into the local plan on a topic basis have been arranged and will hear evidence between October and November 2020. Matter 3 deals with the Metropolitan Green Belt (Policy LP 3) and evidence is scheduled to be heard on 4th and 5th November 2020. 4. I am instructed by West Malling and East Malling and Larkfield Parish Councils in respect of the proposals in the draft Tonbridge and Malling Local Plan for the extension of the existing Green Belt, generally in an eastern direction from its current boundary. It is worth noting here that the proposals by both the Borough Council and by the Parish Councils for their respective eastwards extensions, are 1 seeking an extension to an existing Green Belt boundary and not to the creation of an entirely new area of Green Belt. 5. My evidence is set out in the following manner within this Statement: • How the Framework approaches the designation of the Green Belt; • How the current Green Belt came about and when; • The context of the area that is subject to the proposed extension; • The draft Local Plan approach to the proposed extension; • The assessment that I have undertaken to underpin the proposed extension; • The alternative policy approach considered to protect the land in the absence of a Green Belt extension; • My response to the Councils comments on the more eastern boundary extension; • Conclusions. National Planning Policy Framework (NPPF) 2019 6. Section 13 of the Framework deals with ‘Protecting the Green Belt’. Paragraph 133 states: The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence. 7. Paragraph 134 sets out the five purposes that the Green Belt serves: a) to check the unrestricted sprawl of large built-up areas; b) to prevent neighbouring towns merging into one another; c) to assist in safeguarding the countryside from encroachment; d) to preserve the setting and special character of historic towns; and e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 8. Paragraph 135 then states: The general extent of Green Belts across the country is already established. New Green Belts should only be established in exceptional circumstances, 2 for example when planning for larger scale development such as new settlements or major urban extensions. Any proposals for new Green Belts should be set out in strategic policies, which should: a) demonstrate why normal planning and development management policies would not be adequate; b) set out whether any major changes in circumstances have made the adoption of this exceptional measure necessary; c) show what the consequences of the proposal would be for sustainable development; d) demonstrate the necessity for the Green Belt and its consistency with strategic policies for adjoining areas; and e) show how the Green Belt would meet the other objectives of the Framework. 9. It should be noted that this paragraph deals specifically with the designation of ‘new’ Green Belts. It is provided for context with what the Framework says on this particular topic of the Green Belt. It does not directly apply as this proposal is not for a new Green Belt, but an extension. Rather the proposal needs to be considered against the wording of paragraph 136. 10. Paragraph 136 states: “Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans”. 11. Here the local plan is being updated and so that part of the paragraph is complied with. 12. Paragraph 139 states: When defining Green Belt boundaries, plans should: a) ensure consistency with the development plan’s strategy for meeting identified requirements for sustainable development; b) not include land which it is unnecessary to keep permanently open; c) where necessary, identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period; 3 d) make clear that the safeguarded land is not allocated for development at the present time. Planning permission for the permanent development of safeguarded land should only be granted following an update to a plan which proposes the development; e) be able to demonstrate that Green Belt boundaries will not need to be altered at the end of the plan period; and f) define boundaries clearly, using physical features that are readily recognisable and likely to be permanent. Current Green Belt Boundary 13. The Green Belt in Tonbridge and Malling was established through its interim designation in 1983. The Council’s Green Belt Study 2016 refers to the history of the designation in this area in paragraph 1.1.3 of that document. It states: In the 1960’s, Kent County Council in the Kent Development Plan Review proposed extending the MGB to include much of Tonbridge and Malling but this was not approved by Central Government. Instead, the corresponding area was defined as an area over which Green Belt policy would apply pending further studies. Those studies were taken forward by Kent County Council in preparing the first Kent Structure Plan which was approved in 1980. This indicated that the MGB would extend for some 15 miles from the outer edge of London and confirmed, for the first time, that much of Tonbridge and Malling was to be covered by the MGB. However, the outer boundary was only shown diagrammatically on the Key Diagram and described in general terms as going to the west of West Malling and east of Wateringbury. It was not until the adoption in 1983 by the County Council of the Kent Countryside Plan that a clear outer boundary to the MGB was defined around the western edges of Snodland and West Malling, but this was only on an interim basis until such time as Local Plans were prepared by the Borough Council. (my emphasis) 14. The history of the development plans that first set the areas to be designated is set out further in paragraphs 1.1.4 and 1.1.5 of the Study. These were all superseded by the adoption of the 1998 Tonbridge and Malling Local Plan. Aside from some minor changes, the boundaries adopted through the earlier plans were adopted at that time. I have not been able to identify any comprehensive review that was undertaken; simply an adoption of what had gone before. The extent of the boundary around West and East Malling was therefore last considered nearly 4 40 years ago and in my view it is therefore appropriate to revisit those decisions today, through this local plan update. 15. The timing of the approach to a boundary review here is also relevant as since the original boundary identification nearly 40 years ago, Kings Hill as a new settlement has been developed on the former RAF West Malling airfield to the south of the subject area. This area continues to develop and expand, with the proposed strategic housing allocation to the north of Kings Hill. 16. This significant change is in itself a reason to consider the extent of the eastern boundary of the Green Belt at this time. This is an example as other development, although not to the same degree, has occurred in the same timeframe in relation to the other settlements within this study area closing the gap between settlements. 17. This boundary in the adopted local plan currently extends around the south side of Kings Hill, infilling between that settlement and the Borough boundary. It then changes direction on a broadly north-south alignment through parts of the south side of West Malling before hugging the west side of the existing village. From there it follows the A20 until the western edge of Leybourne, before again turning broadly north at the A228 and over the M20, again following the A228. 18. As a consequence this in my view leaves a large area, broadly enclosed by West Malling to the west, Kings Hill to the south, Leybourne, Larkfield, East Malling and Ditton to the north and the Borough boundary to the east, vulnerable to extreme pressure for housing development. It is my view that this area is a finite resource, in many forms for the local area – visually, recreationally, historically, etc, that is being gradually eroded and if it were to be lost, would be lost for ever. 19. Whilst I look at this wider area later in this evidence in smaller area parcels, it needs to be considered both in that manner and also as a whole.

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