Tonbridge & Malling Borough Council Local Plan proposal

Consultation response by Tonbridge & Malling Green Party November 2016

Tonbridge & Malling Green Party welcomes the opportunity to comment on this draft of the Local Plan.

We have responded to each of the 15 specific consultation questions (see p8). In addition we set out below our vision for a greener approach to planning and our position on the major issues that must be addressed by the new Local Plan.

We hope the Borough Council will pay due regard to these wider points as they inform our responses to the narrower set of consultation questions.

We will be making this document available to our members and the wider public as a contribution to debate as the Local Plan process continues.

1 Vision A plan with a timeframe of 15 years, for an area of more than 90 square miles and with a population of over 120,000, should set out a vision for the kind of place it could be. While we understand the limits of the planning regime imposed by central government, the Tonbridge & Malling draft Local Plan lacks ambition for our borough.

The Local Plan development process should be an opportunity to involve the public in a real discussion about about the type of communities that people would like to live and work in; the competing pressures on land; creating opportunities to work closer to home; smart ways to produce and use energy or how to reduce our dependency on cars.

Tonbridge & Malling could be a place that people visit to see how planning can contribute to a better quality of life for everyone while protecting the natural environment.

Instead the draft Local Plan appears to be the result of a largely technical exercise, taking as its starting point deeply debateable housing targets and sites identified by landowners and developers. The flawed market-driven, not planning driven, Call for Sites process has created understandable anxiety in communities, with sites identified as “suitable” that should never have been brought forward, while more suitable sites remain invisible to the process. TMBC Local Plan Consultation response by Tonbridge & Malling Green Party 1

2 Sustainable development The word “sustainable” is used 40 times in the draft Local Plan. Government introduced, through the National Planning Policy Framework (NPPF), a “presumption in favour of sustainable development”.

It’s important to understand what “sustainable development” really means. The NPPF refers to the definition in Resolution 42/187 of the United Nations General Assembly:

“Meeting the needs of the present without compromising the ability of future generations to meet their own needs.”

Future generations will need open spaces, clean air and affordable homes. We would argue that much current and planned development is unsustainable. Large isolated housing developments, without facilities or services, force people to rely on cars. This weakens community cohesion, exacerbates congestion, increases pollution and contributes to ill- health more generally as walking and cycling decrease.

Building regulations do not require best-practice levels of energy or water efficiency. Many housing schemes are poorly designed and built, dominated by roads, with inadequate gardens or other green space. TMBC should build into the next iteration of the Local Plan a requirement that all new housing meets best-practice standards on energy efficiency, water use and design.

Although the government has discontinued support for Zero Carbon Homes and the Code for Sustainable Homes, several local authorities and housing providers continue to use CfSH.

Development should respect the character of existing communities and the Council’s Character Area Assessments are a useful tool for this. We call for much higher standards of design for commercial developments as well as housing. The Council should consider increased densities where appropriate to protect greenfield sites and to respect the footprint of existing communities and urban areas.

One model for improving housing developments is Building for Life 12, a government- endorsed industry standard for well-designed homes and and neighbourhoods. Local communities, local authorities and developers are encouraged to use it to guide discussions about creating good places to live. Some local authorities have adopted it in their Local Plans1.

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It covers 12 key elements under three headings of what makes “a good place to live” at the design stage:

Integrating into the neighbourhood 1 Connections Does the scheme integrate into its surroundings by reinforcing existing connections and creating new ones, while also respecting existing buildings and land uses around the development site?

2 Facilities and services Does the development provide (or is it close to) community facilities, such as shops, schools, workplaces, parks, play areas, pubs or cafes?

3 Public transport Does the scheme have good access to public transport to help reduce car dependency?

4 Meeting local housing requirements Does the development have a mix of housing types and tenures that suit local requirements?

Creating a place 5 Character Does the scheme create a place with a locally inspired or otherwise distinctive character?

6 Working with the site and its context Does the scheme take advantage of existing topography, landscape features (including water courses), wildlife habitats, existing buildings, site orientation and microclimates?

7 Creating well defined streets and spaces Are buildings designed and positioned with landscaping to define and enhance streets and spaces and are buildings designed to turn street corners well?

8 Easy to find your way around Is the scheme designed to make it easy to find your way around?

Street & Home 9 Streets for all Are streets designed in a way that encourages low vehicle speeds and allows them to function as social spaces?

10 Car parking Is resident and visitor parking sufficient and well integrated so that it does not dominate the street?

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11 Public and private spaces Will public and private spaces be clearly defined and designed to be attractive, well managed and safe?

12 External storage and amenity space Is there adequate external storage space for bins and recycling as well as vehicles and cycles? http://www.builtforlifehomes.org

As a minimum we would like to see TMBC promote the idea of a low-energy, sustainable community on one of the proposed development sites - see our response to question 4. One example is Derwenthorpe near York by the Joseph Rowntree Housing Trust http://www.jrht.org.uk/communities/derwenthorpe

Looking at the bigger picture, this plan addresses a critical time period for efforts to tackle climate change. All levels of government need to contribute, yet the plan contains no information on where Tonbridge & Malling is today on emissions and where they have to get to.

T&M will need to act responsibly in order to deliver its fair share of the UK’s legally binding target2 to reduce carbon emissions to 57% of 1990 levels by 2030.

Tonbridge & Malling Green Party members and supporters would be willing to work with TMBC on the next iteration of the Local Plan, to help develop a more community-authored vision to underpin the process, in particular investigating and helping design ways to achieve a low carbon future.

3 Issues Development pressures It is clear that the country is out of balance. The south-east is overheating, with pressure on land, infrastructure and water resources. The result is unaffordable housing, extended commuting, pollution and loss of natural environment and wildlife habitat.

The Green Party believes local politicians and professional planners need to push back against Government imposed targets for development in the south-east. Tonbridge & Malling should work with other local authorities, Kent County Council and possibly the Local Government Association to agree a cross-party position on regional development which reduces pressure on the south-east.

The housing target for Tonbridge & Malling should be revisited. According to the Office of National Statistics the population of the borough grew by 14% between 2001 and 2013 to 123,000. However 58% of the net increase (about 750 people a year) was internal migration, mostly from London. Natural growth accounted for 33% and international migration for just 9%.3 TMBC Local Plan Consultation response by Tonbridge & Malling Green Party 4

It is clear that much of the demand for housing (and other development) in the borough is being driven by movement out of London, partly due to the difficulty of buying a house, as well as the search for a better lifestyle.

This is not sustainable and limits must be set to ensure that housing in Tonbridge & Malling is affordable for local people. It is clear that a borough by borough solution is inadequate. At the moment houses are being built and marketed to attract people moving out of London. The housing crisis in London needs to be addressed as part of a regionally balanced solution.

Housing As acknowledged in the plan (4.2.6) Tonbridge & Malling has a need for more affordable homes. According to KCC data, just 70 additional 'affordable rented' dwellings were provided by TMBC in the financial year 2014/154. We support the Council’s aim “to strive to seek more traditional forms of social rented accommodation” and urge it to prioritise social housing over other types of tenure.

We call on TMBC to be courageous and to resist a lowest common denominator approach which might suit developers but not the needs of the borough and the people who live and work in it. The Local Government Association has collated examples of innovative approaches to housing provision5.

TMBC should be more active in tackling the problem of empty homes – according to KCC figures there were 1,132 vacant dwellings in the borough.

Providing homes isn’t always about building more. For instance, underused spaces in existing homes could be rented and TMBC could do more to encourage this. Rent a Room schemes exist that could be copied and although by no means a panacea, every little helps.

Imbalance in the borough Within Tonbridge & Malling the Local Plan identifies several large development sites in the north of the borough along the A20 – at Borough Green, Aylesford and near East & West Malling. Taken together with recent developments (Leybourne Chase), those approved (Kings Hill phase 3) and those to come (Aylesford Newsprint and Hermitage Lane sites) these would place an unsupportable strain on local infrastructure, particularly roads and rail services.

We call on TMBC to pursue a strategy of greater coordination with neighbouring authorities and more equitable distribution of development across the borough on a smaller, more sustainable scale. The Council needs to protect local communities and the environment from excessive development.

Far more weight must be given to the ability of facilities, services and other infrastructure to cope with new development.

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Transport The issue of housing and employment infrastructure cannot be adequately addressed in isolation. The Council needs to work to reduce car-dependency, improve public transport and promote walking and cycling. Decisions on development have major implications for transport use. Wherever possible large-scale housing developments should be serviced by public transport.

The Local Government Association says subsidised bus services in England have been reduced by more than 12% in the past year, blaming government cuts to councils' budgets.6

Tonbridge & Malling should join the LGA’s call for the Government to fully fund the concessionary fares scheme to protect the routes which act as a lifeline for vulnerable and non-driving residents to go shopping, pick up medication, attend doctor appointments or socialise with friends.

Within urban areas, pedestrians and public service vehicles should have priority over car drivers. In town centres, residential areas and on many rural lanes the speed limit should be 20mph.

15.5 million people live in local authorities which have rejected 30mph in favour of 20mph as the default speed limit on streets where people live and work. Such local authorities are finding multiple economic, health, social and environmental benefits from implementing wide-area 20mph schemes.

We recommend incorporating the response of the 20’s Plenty For Kent campaign to Kent County Council’s consultation on Active Travel. It provides well-documented evidence of the benefits and examples of cost-effective implementation.7

Many people are put off cycling by poor road design and aggressive driving. In the 1970s, Holland had a similar car culture to us. Now it doesn’t – because it made a choice to change. TMBC should look at examples such as Walthamstow’s successful “mini-Holland” trial8 or Cambridge’s Making Space for Cycling9 initiative to see how town centres can be reclaimed from the car.

Where cycle routes are provided they must be genuine “end-to-end” solutions. A cycle route that dumps riders back onto the road will not attract users who are deterred by riding in traffic.

TMBC should work with other local authorities to investigate the feasibility of a tram or light-rail scheme to link communities along the congested A20 corridor. Such a solution might also improve connections between the north and south of the borough.

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Green Belt and Brownfield land The Local Plan says that brownfield sites have been prioritised but states that “the opportunities for locating new development on brownfield land are becoming few and far between.”

We are not convinced that sufficient effort has been made to identify brownfield sites or to make sure that development on existing brownfield sites is brought forward.

MPs on the Communities and Local Government Select Committee said: “We have particular concerns about the risk that developers will delay developing brown field sites because local authorities will be required to release more profitable green field sites if insufficient housing is delivered to meet local needs.” 10

The Committee recommended that ministers should consider giving local authorities the power to block developments on greenfield sites if brownfield land is unused by developers.

It is clear that owners are sitting on some brownfield sites. There is provision in the new Housing & Planning Act for a register but we urge TMBC to identify and publicise all brownfield land in the borough for which development permission has been granted but where building has not commenced, such as the Tonbridge Gateway site near the sorting office.

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4 Consultation questions

Q1. Do you agree or disagree with this set of objectives for the new Local Plan? (p.17) We agree with the four objectives listed. It should be also recognised that local people often appreciate and wish to safeguard facilities and places that do not necessarily have a “high value” or an official designation – these need protecting too.

Q2. Do you agree or disagree with this set of building blocks for the Local Plan strategy? (p.19) We agree with the three principles outlined.

Q3. Do you agree or disagree with this set of guiding principles? (p.22) We agree with the seven principles listed but the borough council should recognise that “focusing opportunities adjacent to … settlements … big and small” whilst it may support local communities also imposes strains.

For example, further large-scale development of Kings Hill will lead to the merging of Kings Hill with West Malling, East Malling, Larkfield and Leybourne, to the detriment of all these communities.

We also believe that undertakings must be secured for supporting infrastructure (point 6) and that this must be in place either before development is commenced or as soon after as is practically possible.

It is not clear that “growth at key locations” will deliver benefits for existing local communities. On the contrary, the evidence from major developments to date is that they place greater demand on community facilities and local infrastructure, without bringing additional investment.

The Council’s strategy of “focussing development on the contribution that larger potential sites could deliver” is flawed. The sites identified are all in the north of the borough, placing pressure on the M20/A20 corridor.

With a focus on a few very large sites, it is not clear how the Borough Council can control the release of land to ensure development is phased over the plan period.

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Q4. Do you agree or disagree that this potential approach to a development strategy could provide a sound direction for the new Local Plan to take? (p.33)

This is a very broad question and the section it refers to includes several specific proposed development sites. We must therefore look at each area separately rather than endorse the whole approach.

1 East Bank of Medway and Aylesford Quarry Although Bushey Wood is in the current development plan and was earmarked as an Area of Opportunity, careful consideration must be given to the size and extent of the development particularly in relation to the delivery of much needed infrastructure investment for this area – especially for education and health.

We support Aylesford Parish Council’s position that improvements to the road infrastructure are needed at the Bull Lane/Pilgrims Way/Rochester Road junction and for improved access to the A229, the new bridge and A228.

Similarly we support the Parish Council’s views on development at Aylesford Quarry: “The site provides a great opportunity for the provision of leisure and community use. It is not appropriate that housing is provided at this site unless it is considered necessary as the only means of delivering a leisure and community project which provides significant and much needed community benefit. Housing can never be considered or provided in isolation. Any development at this site will have to give serious consideration to road infrastructure improvements.”

Any development should be accompanied by positive habitat and landscape enhancements to address land degraded by quarrying in addition to other infrastructure.

2 South Aylesford and Ditton Development either side of Hermitage Lane, on the scale proposed by Tonbridge & Malling and Maidstone councils, would place unsupportable pressures on local infrastructure. The draft plan mentions a new road, improvements to Barming rail station and new education and healthcare facilities, without any indication as to how these would be brought forward and financed.

A large part of this proposed development area would be on land currently part of the East Malling Research Station (EMRS). The total site was submitted as part of the Call for Sites exercise. We strongly urge that the remaining part of EMRS be given the best possible protection to safeguard its continued operation in Kent.

This can be achieved by extending the Green Belt as we recommend in our response to question 12. This would also preserve the setting of the historic settlement of East Malling including its Bradbourne and Village Conservation areas.

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3 Broadwater Farm We are opposed to any development of Kings Hill (5.9.7) beyond the boundaries of the old airfield for three principle reasons:

1. It breaks assurances given to the community at the time Kings Hill was developed and therefore undermines trust in both the local planning system and local democracy.

2. It sets a precedent for expansion of Kings Hill over some or all of the area identified in the Call for Sites exercise – site 358.

3. The facilities of West Malling and local infrastructure (in particular the rail service) cannot cope with the existing demands of the Kings Hill population. New houses (up to 1,500 using the Council’s methodology) on an additional 50 hectares would be unsupportable.

4 Borough Green & Platt The scale of development envisaged by the promoted Borough Green Gardens proposal is clearly excessive and we note that TMBC has identified a much smaller site to the west of the A227. This scale of development does not appear to have local support and would completely change the character of the area.

Borough Green has a range of services as mentioned in the plan and of course, it is always positive to have more people using the locally run high street shops, but the parking, bus services, train service, doctor surgery etc would all need to be enhanced/expanded to accommodate a large rise in local population.

We seek confirmation that any sites used for landfill or mineral extraction (previously, currently or in the future) have restoration requirements and will therefore be treated as either Green Belt or greenfield land when applications for development are considered.

The planning status of the new road (indicated by a blue line in figure 8 p29) is not clear but it will not act as a “relief road” for communities along the A25 – it is a spine road for the proposed development and as such will self-generate new traffic.

5 Tonbridge We support a continued focus on higher density residential development in and close to Tonbridge town centre (5.9.10) and other more urban locations. We have concerns about a number of sites in and around Tonbridge identified as suitable for development and included in the Potential Development Strategy map:

Fishponds Farm, Upper Haysden Lane (266) - this triangle of green fields contains a pond, rich in wildlife. Building up to 136 units of housing here will contribute to urban sprawl affecting Haysden Country Park and the Conservation Area of the nearby hamlet of Haysden.

Drayton Road Industrial Estate (248) - although we support the decision to build on previously developed land (“brownfield” land ) access will be a major problem throughout construction and afterwards due to the extreme congestion in Lavender Hill. TMBC Local Plan Consultation response by Tonbridge & Malling Green Party 10

South of Vauxhall Gardens (334) - this site is designated to be the location for up to 61 units of housing. Part of it is the closest patch of recreational land in the Vauxhall Ward and much prized by families and dog owners. Any development here will be subject to noise pollution from the nearby road. The development of this land will be a great loss to its community and will extend the urban limits of South Tonbridge to the A21.

Weald of Kent Lower Fields (367) - development of these school playing fields will mean further loss of green fields to urban sprawl.

Manor Farm, Upper Haysden (393) - this is a massive site designated to take up to 332 units, on an 11.06 ha plot of open farmland. The huge encroachment into the countryside will result in the urban border of Tonbridge being substantially westwards towards the Conservation Area of the hamlet at Haysden. As well as contributing to urban sprawl this development will have serious problems as school places and local health services are already overstretched. The northern area is prone to flooding.

Coblands Nurseries, Trench Road (417) - this is a major proposal to build 319 units of housing on a plant nursery. As well as halting employment on this site leading to redundancies and the end of future employment this will mean that the urban area of Trench will be extended westwards into open countryside.

NB We have also commented on a number of other sites identified in the Call for Sites exercise because, although these are not on the Potential Development Strategy map, there may be pressure to reconsider their exclusion - see Appendix 1, p16

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6 Smaller settlements inc Hadlow, East Peckham and West Malling In Hadlow our main concern is how the village's infrastructure would cope with additional population. The primary school is already at capacity and would therefore need investment to absorb more children and each of these new developments would ultimately feed onto the A26, which is already very congested here.

At East Peckham our view is that any development on greenfield land should be subject to a clear and specific pre-condition of demonstrably enhancing the sustainability of local services and contributing to the particular housing needs of the local community.

In West Malling the only identified development site is on Green Belt land east of Offham Road (299). We do not support development of this site for speculative housing – it would remove a green space much valued by those who live around it and the wider community. Developing this site conventionally would generate additional traffic on the narrow access to West Malling at West Street.

However we would consider supporting a community-backed scheme, on part of the site, of genuinely affordable (ie not the 80% of market rate definition) housing for rent, subject to restrictions on the Right to Buy.

This site could also be suitable for a demonstration of sustainable living – showing best practice in design, energy generation and use, water conservation and the incorporation of green space and wildlife habitat.

Q5. Should the new Local Plan continue to support and focus new economic development at and around existing economic hubs such as the Tonbridge Industrial Estate, New Hythe Lane, Kings Hill, Hermitage Lane and Quarry Wood or should an alternative strategy be considered? (p.35) This focus makes sense and we support it. However there may be potential for incubator or live/work units at other locations to support the establishment and growth of small businesses.

Q6. Should we consider a wide range of employment generating uses within existing economic hubs in the borough, Yes/No? (p.36) Yes

Q7. Should the Local Plan be supportive of more mixed-use developments, including start- up units within residential schemes, Yes/No? (p.36) Yes – having due regard to noise disturbance and uses which may be incompatible with residential occupation.

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Q8. What should be the main role of Tonbridge Town Centre moving forward? Should the priority be for shopping or for social and cultural uses or a balance of these or other approaches? (p.37) Tonbridge town centre should continue to have a mix of uses. We are concerned that retail developments outside the town centre, particularly off Cannon Lane north of the River Medway, could have a negative effect on the High Street as well as increasing traffic – see response to question 10 below.

We are also concerned that some buildings and shop units in the town centre have remained empty for several years and believe the Council should do more to ensure these are brought back into productive use, including compulsory purchase where this is warranted.

Q9. Should the Local Plan include a more flexible policy framework for Tonbridge to allow the Town to respond to future market investment opportunities for a range of land uses and developments Yes/No? (p.37) Yes. We support the approach taken so far by the Borough Council in concentrating new residential developments within the town centre as this has had a positive effect on the high street and helps local businesses.

Concentrating retail development within the established town centre is important to help businesses and to cut traffic congestion and to preserve the character of the town. We also believe it is vital that any new buildings should respect the character of the town and be of the highest architectural quality.

We strongly support the retention of local employment within the town and would seek to enhance this by ensuring the availability of different sized units, especially those aimed at providing premises for start-up, 'cleantech' and creative businesses.

We would also like to see more tourist facilities within the town (including hotels and other appropriate accommodation) to enhance the potential the town has in this area.

Q10. Do you have other thoughts about how planning policy should guide development in and around the town centre? (p.37) Recent and proposed development on the former B&Q and Homebase sites off Cannon Lane demonstrates that this part of Tonbridge is evolving into a convenience and comparison goods retail centre which is very different to bulky goods retailing.

This trend will inevitably have a negative effect on the viability of some High Street businesses - the two pet shops in the town centre will be seriously threatened, for example. The balance of the town will shift, there will be increased traffic (and congestion). Air quality is also a related issues and, in addition, there doesn’t appear to have been any consideration given to public transport access, only to cars and delivery vehicles.

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Longer term, the development of this site may also have a negative effect on the adoption of other, more central sites for retail development, for example the station area and Quarry Hill Parade which have far better public transport access and have the potential to be better connected to the rest of the High Street and central area.

New and redeveloped areas of retail at Cannon Lane could be linked more effectively to the town centre. The plan for a pedestrian/cycle bridge across the Medway near town lock should be re-examined.

Q11. Do you agree or disagree that the Local Plan should put land into the Green Belt east of West Malling? (p.38) We agree that the Green Belt should be extended east of West Malling to the bypass, as shown by the pink line on the map below.

Q12. Are there any other parcels of land in the borough that you think could be justifiably (as measured against the five purposes) put in, or alternatively removed from the Green Belt, without putting at risk the requirement for the Local Plan to positively address assessed needs in a sustainable way? (p.38) We would like to see the Green Belt extended further to include all the land between West Malling, East Malling, Kings Hill and Larkfield to prevent these communities coalescing. We therefore support a new eastern boundary for the Green Belt as shown by the green line on the map below.

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Q13. In delivering new development, what features are important to you locally? Please can you rank the following in order of importance, giving 1 for the most important down to 7 for the least important (p.41):

• Providing affordable housing • Providing publicly accessible open space • Stipulating car parking standards • Controlling housing densities • Applying internal space standards • Achieving greater accessibility standards • Applying water efficiency standards • Are there any other priorities that you think should be considered when delivering new development?

We do not consider it sensible to rank these features – they are all important.

Q14. Do you think the Borough Council should assess the viability of including the nationally described space standards in the new Local Plan, Yes/No? (p.43) Yes. TMBC should be seeking high design quality that enhances the local environment rather than detracting from it. New houses should be built to high energy efficiency standards, including Passivhaus http://www.passivhaus.org.uk/standard.jsp?id=122 Particular attention should be given to materials and quality of construction

Q15. Do you think the Borough Council should assess the viability of exceeding the minimum standards required by Building Regulations in respect of access and water, Yes/No? (see p.43) Yes.

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Appendix 1

Other sites in and around Tonbridge SLAA 247 Land at Tilebarn Corner. A development of 20 residential units on the Hadlow Road will allow development ruining views across the Medway Valley floodplain and access will be problematic on a road bend on the busy A26.

SLAA 275 Grange Farm This is a massive incursion into the green fields at the edge of Higham Wood. The 1,211 units covering farmland comprising 42.64ha will move the urban boundary of Tonbridge out to meet Poult Wood Golf Course. Access will be hindered by the unsuitability of Higham Lane to cope with such a massive undertaking. Schools in North Tonbridge are already oversubscribed and there is no sign of a new school to relieve the pressure. There is a similar picture when it comes to health services.

SLAA 276 Green Trees Farm Although deemed to be Unsuitable this is a massive site which is at high risk to development and urban sprawl of Tonbridge in the direction of Hadlow. The only barriers to development at this stage seems to be surface water drainage and improved access to the A26. Any development here would be a massive incursion into the green fields bordering North Tonbridge. The area is poorly served by services.

SLAA 332 North of Woodgate Way, Tonbridge Development of 22 units on this site will be despite it sitting in the High Weald Area of Outstanding Natural Beauty. Much of the site is within a floodplain and is an example of urban sprawl.

SLAA 368 North of Hilden Park Although classified as Unsuitable in the recommendations the reasons given are a cause for concern. Accessibility is one of many reasons that development here should be ruled out. The site comprises open fields divided by hedgerows and development here would effectively link Hildenborough to the estates of Trench and Longmead and contribute to the urban sprawl in a previously agricultural area. Much of this area is prone to a high risk of flooding and many TPOs exist to protect the rural scene. Access would be extremely limited through Oast Lane which is wholly unsuitable.

SLAA 371 West of Elmhurst Gardens, Tonbridge. Although deemed to be Unsuitable currently the reasons that are given are accessibility which it is implied are surmountable. The massive 31.38ha site if developed would constitute a serious loss of countryside to urbanisation. All of the site is currently agricultural and the loss of this to urban sprawl and the prospect of the northern edge of Tonbridge becoming joined to the expanding eastern border of Hildenborough is of grave concern. The pressure of any development on local schools and services would be tremendous.

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SLAA 420 Hawden Farm, Tonbridge Despite being deemed Unsuitable the guidance suggests that problems here are not insurmountable. This site is wholly unsuitable due to its being at High Risk of Flooding and having awful accessibility issues - it needs to be completely ruled out now.

SSLA 421 North of Tonbridge Road, Hildenborough. This site has been ruled out as Suitable but Undeliverable but the guidance states that the issues are not such that development in the future is ruled out. The site has issues with surface water flooding. This is a massive 14 ha area able to accommodate 434 units of housing. The result would be an incursion into open countryside leading to urban sprawl.

SSLA 422 A large plot of amenity land including the Tonbridge Angels Football Ground and football pitches covering 23.04ha. The entire area is subjected to regular flooding by the Hilden Brook Stream making it entirely unsuitable yet it is stated that it could accommodate 455 units of housing.

SLAA 423 Frogbridge Road Tonbridge This area contains substantial Ancient Woodland and is prone to flooding. Despite this it has been deemed suitable for 146 units of housing which will push the northern boundary of Tonbridge further into the countryside.

SLAA 430 South of Lower Haysden Road Although deemed unsuitable the remarks in the report suggest that this site will be considered at a later date if access can be improved. Any development here would encroach on the Haysden Conservation Area and push the urban border of Tonbridge westwards right out to the A21. There would be issues of noise pollution from this major highway.

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References 1 South Derbyshire Adopted Local Plan, Chapter 8 paragraph 8.11, June 2016 “’Building for Life’ is a well-founded and commonly understood methodology for assessing the design of new residential areas, and all new housing development will be expected to perform well against it, or any successor standards.” http://www.south- derbys.gov.uk/planning_and_building_control/planning_policy/local_plan/local_plan_part1 /default.asp

2 Carbon Budgets, Department for Business, Energy & Industrial Strategy July 2016 https://www.gov.uk/guidance/carbon-budgets

3 Population Estimates for UK, England and Wales, Scotland and Northern Ireland, ONS https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populat ionestimates/datasets/populationestimatesforukenglandandwalesscotlandandnorthernirela nd

4 Housing Case Studies, Local Government Association http://www.local.gov.uk/housing/-/journal_content/56/10180/3845114/ARTICLE

5 Affordable housing 2014/15 Kent Local Authorities, KCC http://www.kent.gov.uk/__data/assets/pdf_file/0003/7356/Affordable-housing-in-Kent.pdf

6 Bus services - new figures reveal reductions forced on councils, LGA November 2016 http://www.local.gov.uk/web/guest/media-releases/- /journal_content/56/10180/8040405/NEWS

7 Response to Kent County Council’s consultation on Active Travel, 20’s Plenty for Kent, June 2016

8 Mini-Holland, Waltham Forest Council, December 2013 https://branding.walthamforest.gov.uk/Documents/mini-holland-tender-13-dec.pdf

9 Making Space for Cycling, Cambridge Cycling Campaign, 2014 http://www.makingspaceforcycling.org

10 Department for Communities and Local Government’s consultation on national planning policy, Communities and Local Government Committee Third Report of Session 2015–16, March 2016 http://www.publications.parliament.uk/pa/cm201516/cmselect/cmcomloc/703/703.pdf

Written & edited for Tonbridge & Malling Green Party by Richard Byatt BSc (Hons) Urban & Regional Planning with input from Howard Porter, Mark Hood, Fran Long, Steve Jackson, Phil Green, Janet Moore, David Nicholls, Ralph Ruge and other Green Party members and supporters.

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