Land at Tunbridge Wells Golf Course a Vision

Land at Tunbridge Wells Golf Course A Vision

November 2019 All plans produced by LSH are based upon Ordnance Survey mapping with the permission of Her Majesty’s Stationery Office. © Crown Copyright reserved. License number 100022432. All aerial mapping images are courtesy of Google Maps All images © LSH unless otherwise stated. Land at Tunbridge Wells Golf Course A Vision

Executive summary Introduction 1 Experience 2 The site 3 Local facilities and connectivity 4 Context 5 Inspiration 6 Concept 7 Illustrative masterplan 8. Transport

9. Delivery 10. Policy assessment summary

3 Executive summary

The draft plan identifies an overall housing A full planning assessment of the site is outlined in need of 13,560 (including 5,865 affordable) section 9 of this report. The assessment concludes that dwellings across the plan period. 5,967 units at present there is a risk that the draft Local Plan will are identified and there is a consequent need not be found sound due to an over reliance on large for the draft plan to allocate sites to provide a strategic allocations to meet the required housing need minimum of 7,593 dwellings. and the under provision of units to meet the assessed TWBC recognises that the release of Green Belt land older persons housing need. The Tunbridge Wells Golf is required to meet housing demand and therefore the Course site is located in a sustainable location and draft plan proposes the release of approximately 5% of would contribute to meeting the required housing need Green Belt land in the Borough for development. across the Borough. Tunbridge Wells Golf Course, which is capable The proposed new public open space and community of supporting additional housing need, is located facilities would also significantly improve access to local within the Green Belt and at this stage in the plan amenity space, which would also have Village Green process has not been allocated for development. This status. As such, we request that the Golf Course site is representation, therefore, promotes the land for a allocated within the draft Local Plan and the wording for residential led allocation, together with public open a proposed site policy is set out below: space, a new cricket pavilion and pitch, for use by the local community. It is also proposed that a significant ‘Policy RU 2 proportion of the residential allocation within the draft Tunbridge Wells Golf Course, Langton Road Local Plan will be required to provide retirement living accommodation (C3 use class). The new public open The site, as defined in the Land Use Plan on page 6, space within the site will also be registered as a Village is allocated for residential (C3 development) providing Green, which will preserve its open nature and prevent approximately 62 retirement housing dwellings and encroachment of development in future. 36 dwellings, public open space alongside community facilities including a cricket pitch and pavilion. In determining that the site is suitable for limited release from the green belt, we have undertaken a Development on the site shall accord with the following detailed assessment of the key characteristics of requirements: the site and prepared an indicative masterplan that 1. Vehicular access shall be taken from the existing demonstrates how the development could provide accesses onto Langton Road (see Criterion 5 of Policy limited infill sites that would not harm the overall EN 1: Design and other development management function of the green belt in this location. A summary criteria); of the assessment of the site and the proposed 2. Pedestrian linkages shall be provided into wider development’s contribution to the Green Belt principles network (see Policy TP 1: Transport Design and against the Borough’s Green belt Assessment is Accessibility); outlined in the table on the following page. Further 3. Proposals to conserve and enhance the Conservation details are outlined in section 9 of this representation. Area (see Policy EN 7: Heritage Assets); On balance we consider that an overall harm rating 4. Improvements to existing allotments, amenity/natural of moderate would be a more appropriate conclusion. green space, parks and recreation grounds, children’s Additionally, the Green Belt boundary strength of play space and youth play space in accordance with the the site has been reviewed against the Borough’s requirements of Policy OSSR 2: Provision of publicly assessment, which concludes that ‘The existing Green accessible open space and recreation. Belt boundary follows the settlement edge along roads or back gardens. There are no alternative boundaries It is expected that contributions will be required towards within the parcel which could form an alternative strong the following if necessary, to mitigate the impact of the Green Belt boundary’. Contrary to the assessment, development: there is arguably scope to amend the Green Belt a. Improvements to public realm; boundary to exclude the proposed development parcels b. Any other highway related works; as outlined in the proposed land use plan on page 6. c. Improvements to pedestrian links or bus services’.

4 Green Belt Purpose Comments Rating LSH Comments LSH Rating

1- Check the The parcel is adjacent to the Moderate The parcel is adjacent to the large built-up area and relates more strongly to this than to the Relatively weak unrestricted sprawl large built-up area and has wider countryside. contribution of large built-up a degree of separation from The proposed layout of the site has been designed to ensure that the two development areas the settlement and wider parcels represent an extension of the existing built form of Tunbridge Wells and Rusthall countryside. (i.e. low density housing). It is proposed that a large portion of the site (the proposed Village Green and existing ancient forest) will remain as open land and therefore continue to act as a natural barrier separating to the two built up areas. The northern edge of the site will continue to connect to the wider countryside. Further protection of the gap could be achieved through the designation of the undeveloped parcels of land as Village Green Land. Due to the positioning of the site as existing and the proposed layout of the site, it relates more strongly to the built up areas than to the countryside. We therefore consider the rating of relatively weak contribution to be more appropriate.

2- Prevent The parcel plays an Weak or no Development of this parcel would result in little or no perception of the narrowing of the gap Weak or no neighbouring towns important role in providing contribution between towns. contribution merging into one a gap between Rusthall As outlined in the assessment TWBC do not consider Rusthall a town for the purpose of the another and Royal Tunbridge Wells. study and therefore the rating of weak or no contribution is appropriate. However, Rusthall is not considered a town for the purposes of this study and therefore is not considered as part of the assessment.

3 -Assist in The parcel has a degree of Moderate The parcel relates more strongly to the settlement than to the wider countryside. Relatively weak safeguarding the separation from both the contribution Whilst it is acknowledged that the site is located adjacent to a large area of open countryside from settlement and the wider countryside to the north, the site boundaries naturally restrict encroachment of encroachment countryside. development on the countryside. The northern boundary provides a narrow opening to the open countryside whilst the site is bound by residential development on the southern, eastern and western borders. The site is therefore considered to relate more strongly to the existing settlements rather than to the wider countryside. Furthermore, the proposed layout of the site has been designed to ensure that the two development parcels represent an extension of the existing built form of Tunbridge Wells and Rusthall (i.e. low density housing). It is proposed that a large portion of the site (the proposed village green and existing ancient forest) will remain as open land and therefore continue to act as a natural barrier separating the two built up areas, whilst maintaining the openness of the countryside. Further protection of the gap could be achieved through the designation of the undeveloped parcels of land as Village Green Land. This would prevent future development of the land and therefore prevent encroachment on the open countryside. Due to the positioning of the site as existing and the proposed layout of the site, it is considered that the site makes a relatively weak contribution in assisting in safeguarding the countryside from encroachment.

4 - To preserve the The parcel is an important Strong It is recognised that the existing site’s openness contributes to the setting and character Moderate special character part of the landscape setting of Tunbridge Wells and Rusthall Conservation Areas. However, it is considered that the of historic towns of the historic town of Royal proposed layout on site would preserve and enhance the setting of the Conservation Areas. Tunbridge Wells. The parcel The setting of the Conservation Areas will be preserved as the proposed housing will be lies adjacent to Tunbridge in the form of low density housing that will be located to the east and west of the site, Wells Conservation Area, and adjoining the existing settlement boundaries. The centre of the site will continue to remain parts of the Conservation as open land, ensuring that the Conservation Areas continue to be set against an open Area extend into the parcel. landscape. The adjacent Common is a fundamental part of The proposed masterplan will enhance the setting of the Conservation Areas, as it proposes the special character of the replacement of the outdated and unattractive clubhouse with a sensitively designed Tunbridge Wells and the community facility. parcel provides an important Development would therefore have minimal impact on the historic character of the link between this and the Conservation Areas. Rating of moderate is therefore considered to be more appropriate. wider landscape.

5- Encouraging Individual parcels are Not As this criterion was not independently assessed within the review, no further commentary Not Assessed the recycling of considered to make an equal Assessed is provided at this stage. derelict and other contribution and therefore urban land. this criterion has not been independently assessed.

Overall Harm Rating Very High Moderate

Summary assessment of the site against the Borough’s Green Belt Assessment

5 Proposed site allocation Proposed Green Belt & Village Green boundary CONISTON ROAD Proposed development parcel boundary Indicative principal street Indicative path * Indicaive location for community hub Indicative location for cricket and sports BISHOP’S DOWN PARK ROAD * pavillion

WOODSIDE ROAD

Lifestyle homes / affordable / retirement living

2.36 ha Lifestyle homes / affordable / RUSTWICK retirement living

1.12 ha

RUSTHALL PARK

Community Hub Lifestyle homes / affordable / retirement living

1.16 ha

MANOR PARK

Cricket and sports pavilion

Rusthall Common

RUSTHALL ROAD

Residential LANGTON ROAD Tunbridge Wells 0.3 ha Common

Proposed land use plan

6 Introduction

The land at Tunbridge Wells Golf Course is The TWBC Housing Needs Survey (2018) details that available for development and deliverable in there is expected to be an approximate 40% increase in the short term, and can significantly boost the population of over 65s within the Borough across the housing delivery within the District. plan period. This equates to approximately an additional 9,200 older residents. Based on the data within the The land is under the control of Targetfollow, one of needs survey approximately 10% of older residents (920) the UK’s leading property experts with long standing will consider relocating to sheltered accommodation/ commitments in Tunbridge Wells. Extra Care units. The draft allocations equate to the Providing high quality living environments is about provision of a minimum of 69 units and a maximum of much more than building houses. Targetfollow believes 159 units. This is a significant increase when compared that new housing should bring additional benefits with the number of units allocated in the draft plan. to existing local communities and economies, while As a mixed us for older peoplee community, helping to meet the housing shortage. Creating a sense the illustrative masterplan has the potential to of place, an attractive area for the whole community, accommodate circa 80-100 homes, a mix of elderly accessible open space and environmental benefits retirement homes, affordable and private, supported require a holistic vision. This is the approach that we by a community hub and a cricket / sports pavilion (net will bring. 4.64ha). The community hub overlooks an existing pond This document provides an initial impression of what and lies at the intersection of a number of key routes. we might achieve. Our vision is to provide much needed The indicative mix is as follows: new housing, especially for older people, new sports and community facilities and public open space on land which currently has no public access. Site area: 14.60 ha Both Targetfollow and LSH are adept at working collaboratively with landowners, local authorities, Lifestyle homes / public agencies and commercial organisations to create sustainable places that deliver a legacy that will affordable / stand the test of time. The plan identifies a housing retirement living / need of 13,560 dwellings across the plan period and a community hub / consequent need for the Local Plan to allocate sites to cricket and sports pavilion: 4.64 ha provide a minimum of 7,593 dwellings. Tunbridge Wells Borough Council recognises that the release of Green Belt land will be required to meet Public open space 9.96 ha housing demand. The Draft Local Plan proposes the release of approximately 5% of Green Belt land in the Borough for development. Indicative mix:

Retirement living: 62 dwellings (@26 dph on 2.36 ha)

Affordable/private housing, community hub and cricket/ sports pavilion: 36 dwellings (@16 dph on 2.28ha)

7 1 Experience

Targetfollow is a leading privately-owned commercial property company, specialising in the acquisition and management of investment and development properties in both the U.K. and the rest of Europe. Targetfollow has a dedicated in-house professional team of over 30 staff, as well as strong relationships with leading professional advisors and consultants including planners and architects, which together with regular engagement with local council executives, business and local communities has contributed to enhancing the local area, economy and unlocked the investment and development potential. Selected The Pantiles, Tunbridge Wells projects include:

The Pantiles, Tunbridge Wells Transformed under Targetfollow’s strategic asset management and sensitive regeneration approach from a tertiary retail pitch into a premier boutique shopping location, prime eating area and venue for live entertainment and high quality innovative events.

Baskerville House, Birmingham Targetfollow secured detailed planning and listed building consent to undertake a comprehensive Baskerville House, Birmingham refurbishment and remodelling of the building, which achieved BREEAM rating of “very good” and received the British Council of Offices Award.

Peterborough One, Peterborough Targetfollow acquired the garden centre and retail park in 2016. Through strategic asset management and active engagement with Peterborough City Council to re-purpose some units to incorporate leisure use occupancy has increased to 94%. Terms have been agreed with ALDI to develop a new supermarket on adjacent land.

Peterborough One, Peterborough

8 Experience

LSH is one of the UK’s leading planning, property and real estate advisors. With 40+ offices and over 1,700 dedicated staff, our multi-disciplinary teams help fund, assemble and deliver transformational urban design, planning and regeneration projects across the UK. We have a strong track record of working in partnership with local planning authorities, regeneration bodies, landowners, businesses, investors, developers, stakeholders and communities to help unlock the investment and development potential. Our urban design team knits together commercial urban design advice and skills to deliver better places and built environments, ensuring enduring value. North Weald Park Selected projects include:

North Weald Park Working with landowner and house-builder to provide a new settlement embodying garden village principles. Provides up to 690 mixed tenure homes, new school, shops, medical centre, public house and significant sports and other outdoor open space.

Ebbsfleet Garden City Combination of town and country with great connections, including high-speed connections to London and Europe. Masterplan for 950 mixed tenure homes, including the delivery of a primary school, open space, local shop, community hall and a hotel/pub. Ebbsfleet Garden City

Silver End Contextual extension to the historic village created

by window maker Francis Crittall to house his factoryID14743-001 V6 Dartford Ebbsfleet Green DAS.indd 4 25/11/2015 19:06:03 workers in the 1920s. Our project provides new mixed tenure across a range of household types set in parkland on the edge of the existing village community hall and a hotel/pub.

Silver End

9 2 The site

The site is 14.6ha and comprises a golf course that includes an area of Ancient Woodland. The site is adjacent to the built-up area boundaries of Rusthall to the west, a medium sized village, and Tunbridge Wells to the east. To the north, beyond some residential development is RUSTHALL open countryside, to the south, beyond Langton Road is Tunbridge Wells Common.

Site Photos

10 Site location plan: Google earth The site CONISTON ROAD

BISHOP’S DOWN PARK ROAD

GRANGE ROAD

WOODSIDE ROAD

RUSTWICK

ROYAL RUSTHALL PARK TUNBRIDGE WELLS

Rusthall MANOR PARK Common

RUSTHALL ROAD

Hotel

LANGTON ROAD Golf club house Garage

Nevill Tunbridge Park Wells Common

N Site location plan: Google earth 11

lk a w e t u Local in m 0 2 / lk m a 0 w 0 3 6 e 1 t u facilities & n i m 5 1

m 0 0 lk connectivity 2 a 1 w e t u in

m 0 1 The site is within a sustainable location, within / m 0 0 walking and cycling distance of local shops, 8

Rusthall Village Centre, large open spaces, RUSTHALL the Pantiles and Tunbridge Wells Town Centre.

Rusthall Approximate distances from the centre of the Rusthall Post Office St Paul St Paul’s Rusthall Church Centre site are set-out below: Library C Of E RUSTHALLConvenience HIGH ST Store Primary & Pharmacy School • Bus stops within 250m on Langton Road Sunnyside

Community Hall Rusthall Club

• Large open spaces, local shop and pub within 400m

• Primary and secondary schools within 800-1200m

• Rusthall High Street within 800-1200m COACH ROAD

• Pantiles and Tunbridge Town Centre within 1600m

RUSTHALL COMMON

NEVILL

COURT

Local facilities and connectivity

12 Site location plan: Google earth

lk Bennett Memorial Diocesan a Secondary School and Sixth Form Site boundary w HURST e t u WOOD n Schools i m 0 Rose Hill 2 Bishops Down Community / School lk Primary School m a 0 w 0 Major open spaces 6 e 1 t u n Shops, pubs and other services i m 5 1 Public rights of way / / walking and cycling routes m 0 0 k 2 l 1 a w e t u in

m 0 1 / m 0 0 8 The Wells

k Free School al w e ut n i m

5 ROYAL /

Convenience m 0 Store 0 4 TUNBRIDGE

WELLS Todd Rock

Retreat PH

MOUNT

EPHRAIM

BISHOP’S

STATION

DOWN

& TOWN

LONDON ROAD / A26

Travel Lodge CENTRE

St Paul

Spa Hotel

C Of E Church

LANGTON ROAD / A264

NEVILL

PARK

TONBRIDGE WELLS COMMON

King Charles the

Martyr Church,

Tunbridge Wells

The Pantiles

HUNGERSHALL

PARK N

Sainsbury’s Superstore

Site location plan: Google earth 13 4 Context

The Site is adjacent to the main urban area of Tunbridge Trees Wells. The Draft Local Plan states at paragraph 5.136 The masterplan has been carefully considered with “The club house for the golf club lies immediately adjacent regard to the existing trees on site. The parcels of Ancient to this allocation. It has been reported that the golf club Woodland have been a key consideration and no built will close in late 2019. If so, there is the potential that this development will be within 25m of the Ancient Woodland. allocation may be reviewed (to potentially include this Public access will be provided into the site and will allow for additional land) at Regulation 19 stage;” an increase in the public’s appreciation, and therefore the The Golf Club members approached Targetfollow regarding amenity value of the retained trees and ancient woodland. acquiring the site as the club was losing money and was not As part of development coming forward, the parcel of sustainable. Targetfollow has an option to purchase the Golf Ancient Woodland within the site boundary will be brought Club in 2020 and the consideration payments for the option under a sensitive regime of management, protecting the are enabling the Club to continue to operate in the short woodlands’ structure, quality, resilience and longevity. term. The proposal will seek to limit the loss of trees which are important in the landscape or as natural habitats, or Highways historically. Careful consideration has been given to the site’s access and subject to highways advice, the logical position would Ecology be to utilise the existing access to the Langton Road, A264, though there is the potential to achieve access from To the east is a statutory designated SSSI and the inner Rusthall Road. Access from Rusthall Road is over land protection zone extends part way into the site. The site within our ownership. The location of the site also provides includes ancient woodland, mature trees and woodlands good access to the wider strategic highway network. that will have some ecological value. The illustrative masterplan demonstrates that the principal tree groups and The site is located close to public transport routes. ponds can be retained to provide the opportunity to retain and enhance existing bio-diverse habitats. Noise The site is within the main Gatwick flight path. Landscape Flooding, Drainage, & Utilities It is envisaged that landscape assets will be integrated where possible into the proposal to make a positive The site is located wholly within Flood Zone 1, the lowest contribution to local character. Significant green risk of flooding according to the Environment Agency Flood infrastructure will be provided in the form of internal green Maps. grid spaces, tree belts, swales and street trees. Surface water runoff will be dealt with by attenuation ponds Usable public spaces will provide a wide range of and will be restricted to greenfield run-off rates. opportunities for local residents to play, exercise or relax. Restricting the site to greenfield runoff rates and In landscape and visual terms, the site has a high capacity implementing sustainable drainage systems (SUDS) will to accommodate development as the new built form would result in there being no increase in risk of flooding for the be located close to the existing settlements, and would site or downstream of the development. be set within a robust framework of retained woodland Electricity, gas, potable water and telecoms apparatus are and trees and belts of new, publicly accessible green located on or in close vicinity of the site. infrastructure.

Heritage Any development would not directly impact on the setting of listed buildings, and would have regard to the setting of the adjacent Conservation Area.

14 Context CONISTON ROAD

BISHOP’S DOWN PARK ROAD

WOODSIDE ROAD

RUSTWICK

RUSTHALL PARK

MANOR PARK

Rusthall Common

RUSTHALL ROAD

LANGTON ROAD Tunbridge Wells Common

Nevill Park N

Constraints and opportunities

15 5 Inspiration

Village green Retirement living (Patel Taylor Architects)

Cricket club Contemporary lifestyle living

Landscape setting for development Open space

Right: Stirling Prize-winning affordable housing scheme 16 Goldsmith Street in Norwich by Mikhail Riches Architects Inspiration

17 6 Concept

There are eight key design principles which underpin the proposals and are reflected in the Concept Plan:

1. Create an identifiable place. Build to impress 5. Maximise sustainable movement, health & well-being The development will establish a character, a sense The proposals seek to take full advantage of the of place that draws upon the surrounding context, sustainable location of the site. Community facilities including the conservation areas, the topography and will meet the day-to-day needs of residents, reducing landscape features. Trees, views and distinctive features the need to travel, while open space will provide walking will assist placemaking. and cycling routes.

2. A mixed use community. Places to go and 6. Make provision for a new public open space. Nature things to do for people The proposals are for new homes centred upon A landscape framework of green corridors with retained lifestyle/retirement living providing a broad range of trees and water courses will provide a significant boost accommodation / tenure opportunities supporting to public open space in Tunbridge Wells. community facilities and a sports hub, with the objective Green corridors of public open space will provide being to create vitality and a buzz to the development a setting for the new development, accommodate through the day and week. SuDs and provide a resource for the new and existing communities as well as promoting ecology. 3. Deliver quality homes, especially for older people. Homes for all 7. Streets and landscape corridors designed as places New homes will cater for a variety of household sizes The legibility of the place will be informed by the and types and will be sustainable, light and generous in experience of the street and landscape spaces, making proportions. the most of the opportunity to create attractive vistas through the development. 4. Provide community facilities. Keeping it local Community and sports will be at the heart of the 8. Connect into surrounding walking and cycling proposals and will be open to the existing and new routes. Easy to get around community benefiting health and well-being. For the benefit of the existing and new community, We are in contact with Rusthall Cricket Club regarding walking and cycling routes will be provided around how we can assist them in creating a new cricket the site creating a permeable new development and pavilion which has the scope for additional uses as per accessibility to the community, sports and public open Linden Park Cricket Club in Tunbridge Wells. One option space being explored is whether this could be relocated to the existing Golf Club site as part of the community facilities being proposed for this development.

18 CONISTON ROAD Concept

BISHOP’S DOWN PARK ROAD

WOODSIDE ROAD

Lifestyle homes / affordable /

RUSTWICK retirement living Lifestyle homes / affordable / retirement living

RUSTHALL PARK Lifestyle homes / affordable / retirement living Community Hub

Village MANOR PARK Green

Cricket and sports pavilion

Rusthall Common RUSTHALL ROAD

Residential

LANGTON ROAD

Tunbridge Wells Common

Concept Plan

19 7 Illustrative Masterplan

Landscape features are incorporated into There is potential for pedestrian and cycle access routes green corridors which provide a parkland on Bishop’s Down Park Road, Rusthall Park, Woodside setting for development. The green corridors Road and Manor Park. form a network of multi-functional green As a mixed use community, the illustrative masterplan spaces incorporating footpaths and cycle- has the potential to accommodate circa 80-100 homes paths that integrate with existing routes, (4.64ha), supported by a community hub, which lies at desire lines and access points to the site. the intersection of a number of key routes and overlooks Good quality pedestrian/cyclist facilities to integrate the the existing lake, and a cricket pitch with a cricket/ site with the surrounding area and support the principle sports pavilion. of a walkable place. The principal access into the development will be via Langton Road .

20 CONISTON ROAD Illustrative Masterplan

BISHOP’S DOWN PARK ROAD

WOODSIDE ROAD

RUSTWICK

Community RUSTHALL PARK Hub

Cricket pitch

MANOR PARK Cricket and sports pavilion

Rusthall Common

RUSTHALL ROAD

LANGTON ROAD Tunbridge Wells Common

Illustrative masterplan 21 8 Transport

MLM Consulting Engineers have prepared an Access & Trip Technical Note to support this representation.

The note assesses the site’s proximity to sustainable transport modes. The note highlights that frequent bus services are available from stops less than 100m from the existing site access and that Tunbridge Wells Railway Station is located an18 minute walk to the east of the Site. The note therefore concludes that the site is accessible by a number of sustainable transport modes.

The note concludes that the proposed use of the site for retirement housing and housing would not result in a significant impact on traffic generation when compared with the trip generation of the existing golf course use and is therefore acceptable in highways terms.

Similarly, the proposed use of the existing access onto Langton Road is acceptable on the grounds that minor amendments to the existing wing walls are made to improve visibility.

It is therefore considered that the site could support development without affecting highway safety or capacity and promote travel by sustainable modes.

22 Transport 9 Delivery

The Draft Local Plan sets out the development alternative options have been explored i.e. use of strategy for the Borough across the plan brownfield land, making use of unused land, optimising period. density and exploring whether other authorities can The current plan identifies an overall housing meet some of the need. It is clear from the Draft Local need of 13,560 (including 5,865 affordable) Proposals that the alternative options have been dwellings across the plan period. 5,967 units explored and that exceptional circumstances for Green are identified and there is a consequent need Belt release within the Borough are justified. for the Local Plan to allocate sites to provide a Green Belt Assessment minimum of 7,593 dwellings. The site presents a unique opportunity to amend the TWBC recognise that the release of Green Belt land will Green Belt boundary whilst ensuring minimal impact be required to meet housing demand. The Draft Local on Green Belt principles, retaining protected woodland Plan has undertaken a review of the Green Belt and and green space, which would be opened up for public proposes the release of approximately 5% of Green Belt benefit. land in the Borough for development. The overarching issue of altering Green Belt boundaries The National Planning Policy Framework (NPPF via the Local Plan process has informed our approach 2019) is clear that a Green Belt Boundary should to the planning strategy of the Tunbridge Wells Golf only be amended in exceptional circumstances and Course Site. It is proposed that part of the site is that amendments should be managed through the redeveloped to provide retirement living facilities (C3 Local Plan process rather than being addressed by use class, in line with the use class guidance set out in independent planning applications. The NPPF outlines Table 6 of the Draft Local Plan ), residential dwellings, that prior to concluding that exceptional circumstances a country park and a new Cricket Pavilion/pitch for the exist, a Local Authority should demonstrate that all local community.

23 9 Delivery

We seek to engage with the Council at this early stage Furthermore, the Green Belt boundary strength of of consultation in order to ensure that, moving forward, the site has been reviewed against the assessment the development potential of the site is considered in outlined in Appendix A of the report for the site (RU3). full by the Council. The assessment proforma states ‘The existing Green When considering the circumstances that justify the Belt boundary follows the settlement edge along roads amendment of Green Belt boundaries, it is important to or back gardens. There are no alternative boundaries assess the contribution of the land to the five purposes within the parcel which could form an alternative strong of the Green Belt as outlined in the NPPF (2019). TWBC Green Belt boundary’. Contrary to the assessment, undertook an assessment in the 2016-2017 Green there is arguably scope to amend the Green Belt Belt Review. Paragraphs 5.7-5.11 of the Stage 2 report boundary to exclude the proposed development outline the methodology used to assess each Green Belt parcels as outlined in the Land Use Plan on p. 6 of this purpose and apply a rating to that the purpose. For ease representation, whilst ensuring that the open space on of comparison, we have assessed and applied a rating site would remain as Green Belt land. using the same methodology criteria. The consideration of a lower overall harm rating A summary of the conclusions of the assessment and provides an opportunity to consider the site’s our analysis are outlined in the table on the following appropriateness of amending the Green Belt boundary page. of the site, in the context of the redevelopment proposals. Whilst it is acknowledged TWBC’s conclusions on the overall harm rating of ‘very high’, has been awarded in line with the assessment criteria outlined in the Stage 2 Study, the awarding of the rating based on the score for one purpose (in line with Table 5.2 in the stage 2 assessment) does not allow for a site to be assessed in the round. TWBC considers that the site is only considered to make a strong contribution to one of the purposes, whilst it makes a moderate or weak/ no contribution to the remaining purposes. We have undertaken a high level review of the site’s contribution to the Green Belt (LSH Rating), using the assessment criteria outlined in the Tunbridge Wells Green Belt Study Stage 2, and on balance consider that an overall harm rating of moderate would be a more appropriate conclusion.

24 Delivery Green Belt Purpose Comments Rating LSH Comments LSH Rating

Overall Harm Rating Very High Moderate

Summary assessment of the site against the Borough’s Green Belt Assessment

25 9 Delivery

Site Assessment Proposed Layout The proposed layout has been designed to minimise the Proposed Land Use harm of the proposals on the Green Belt. The proposed residential/ retirement accommodation is located on the It is proposed that the site is redeveloped to provide western boundary of Tunbridge Wells and the eastern retirement living (C3 use class) and housing to meet boundary, acting as logical extension to the built up the identified housing needs on the north western and settlement. The Green Belt review has acknowledged eastern boundaries of the site. New community facilities that Rusthall and Tunbridge Wells are considered to and a new cricket pitch, for use by the local community, be one settlement and therefore development on site is proposed in the central and southern portion of the would not contribute to coalescence of settlements. site. A country park will extend from the north of the site along the existing water course. The two parcels are relatively well screened from the remainder of the site due to tree planting undertaken It is proposed that the cricket pavilion and pitch will for the development of the golf course and are therefore replace the existing facilities on Rusthall Common and not considered to be a strong contributor to the that the land at Rusthall Common would be returned to openness of the site. The preservation of the existing common land. central ancient woodland and the proposed location We acknowledge that the provision of appropriate of the Cricket pavilion to the south, ensure that the facilities for outdoor sports and recreation are open nature of the site is preserved. As outlined within considered to be in principle acceptable in the Green the Green Belt Assessment, further protection of the Belt and therefore the provision of the cricket facilities gap would be achieved through the designation of the alone are not sufficient to justify an amendment to undeveloped parcels of land as Village Green Land. the Green Belt. However, at present, proposals for This would prevent future development of the land and retirement living units/ residential dwellings on site protect from future development encroachment. need to be assessed on the weight of the ‘very special An allocation in this location is not considered to circumstances’ that justify proposals within the Green contribute to urban sprawl or coalescence. This is Belt (in line with the requirements of paragraph 144 of because the proposed retirement living/ residential the NPPF) against the substantial weight accorded to units will be contained within two small development the harm of inappropriate development in the Green parcels. Given that the extent of development will be Belt. limited to the two development parcels, development It is therefore appropriate to assess the benefits of will not extend northwards beyond Grange Road amending the Green Belt boundary in order to promote and Thirlmere Road. Consequently, the proposed the use of the site for retirement living units/ residential development is not considered to contribute to units. encroachment of development on the countryside. The ‘very special circumstances’ that would be considered in respect of development proposals on site are considered to be the contribution that the development of the site would make to housing needs in terms of delivering much needed retirement accommodation, housing and community facilities.

26 Delivery

Very Special Circumstances Whilst we recognise the ambitions of the Borough to aid the delivery of the draft allocations across the plan a. General Housing Need period, we consider that the draft plan is overly reliant Whilst a site’s contribution to housing need alone is not on large scale allocations. The delivery of enabling considered to be a ‘very special circumstance’, unmet infrastructure works and the scale of such proposals housing demand can be weighed against the harm to are likely to incur a level of delay during the planning the Green Belt in combination with other factors. This and construction period and therefore it is unlikely that approach has been confirmed by the Inspector in the all the units will be delivered across the plan period. In recent appeal decision for a retirement living scheme order to ensure that the Council can deliver required in West Malling (APP/H2265/W/18/3202040).The appeal market and affordable housing need across the plan also included that the provision of specialist properties period, it is important for the Council to ensure that and extra care housing contributes to housing need sufficient numbers of small and medium sites that can figures. Therefore the ability for the Borough to meet be built out in the short term, such as the Golf Course housing need is relevant to this site. site, are allocated through the Local Plan process. As outlined previously, the draft Local Plan is required Furthermore, we note that the draft Local Plan to allocate sites to provide an additional minimum allocation Policy AL/RTW 27 (Land at Hawkenbury, of 7,593 dwellings. Whilst the draft Local Plan has off Hawkenbury Road/Maryland Road) is allocated for allocated sites to meet the identified need. A significant approximately 220-250 dwellings. Planning permission proportion of the additional need is to be met through has been approved and work on site has begun. two large scale allocations at Tudeley Village (AL/ CA1) The policy wording states that if the development and Capel and Paddock Wood (AL/ CA3). Across the plan substantially completed by publication of the regulation period the sites are allocated to provide 5,900 units. 19 consultation, the policy will be deleted. Development Whilst the Paddock Wood site was allocated in the 2016 on site is well underway and the approved phasing Site Allocations Plan to provide 950 units, the site area plan estimates the sites completion in summer 2020. has been increased and the draft allocation is set to Given the progress made on site, this allocation should provide 4,000 dwellings. These two draft allocations be removed from the draft local plan allocations. The account for approximately 78% of the additional housing removal of the allocation provides further justification need. for the allocation of a number of smaller sites, such as The affordable housing contribution that is expected the Tunbridge Wells Golf Course site, in the draft Local to arise from the allocations is to be confirmed in the Plan. next round of consultation. However, assuming that the site allocations will be compliant with draft Policy H5 (affordable housing), approximately 40% of the allocated units will be affordable. The sites combined are would provide circa 3,037 affordable units, which equates to approximately a third of the affordable housing need across the plan period.

27 9 Delivery

In addition to the above, we are aware that on Paragraph 6.343 of the draft plan states that the need 28th October 2019, the Inspector undertaking the identified within the Housing Needs Survey will be examination of the Sevenoaks District Council (SDC) addressed through a combination of site allocation draft Local Plan issued a letter raising concerns policies and planning permissions being granted. Whilst over the duty to cooperate and unmet housing need. many of the larger draft site allocations have been As TWBC is a neighbouring authority of SDC, the worded to state that, if deemed appropriate, part of the Inspectors conclusions will impact on TWBC’s plan site’s residential offering could be used for delivering making process. The Inspector concluded that SDC ‘has housing for older people; there is no policy requirement not adequately undertaken constructive engagement to provide such housing within the allocation. There are with neighbouring authorities to resolve the issue of only two draft allocation sites that specifically include a unmet housing need in the District and has failed to provision for the delivery of housing for older people: plan strategically by not sufficiently examining how • Policy AL/RTW 17 allocates the site for the delivery these needs could be accommodated’. of either 65 residential dwellings or approximately 90 The absence of such engagement means that neither dwellings (C3) for older people; and the submitted plan nor neighbouring authorities’ plan- • Policy AL/RTW 32 allocates the site for the delivery making processes have been shaped by adequate of retirement housing/ and or residential care home consideration of how Sevenoaks full housing need was (C2) equating to approximately 69 units. to be met. There may be a requirement for TWBC to meet a portion of SDC’s unmet housing need within The draft allocations therefore equate to the provision of the Borough’s Local Plan. As such additional site a minimum of 69 units and a maximum of 159 units for allocations will likely be required. older people. Although the Housing Needs Survey does not detail a specific numerical housing need for the over 65s, based on the data within the survey we would b. Older Persons Housing Need expect approximately 920 older residents to seek extra In addition to the Borough’s general housing need, care units/ sheltered accommodation across the plan the TWBC Housing Needs Survey (2018) details that period. This is a significant increase when compared there is expected to be an approximate 40% increase with the number of units allocated in the draft plan. in the population of over 65s (TWBC’s definition of The survey concludes that the range of housing options ‘older people’) within the Borough across the plan available to older people within the Borough will need period. This equates to approximately an additional to be diversified to meet the projected growing need. 9,200 older residents within the Borough. Whilst the At present, the draft Local Plan is largely relying on majority of respondents surveyed expressed a desire future planning applications to meet the need, rather to remain in their homes, approximately a quarter of than through allocating sites in the Local Plan. Based those surveyed would consider living in alternative on the available data in the Housing Needs Survey, specialist accommodation. Based on the data within the this approach is likely to result in an under-supply of needs survey approximately 10% of older residents will accommodation for older residents, and an already consider relocating to sheltered accommodation/ Extra aging population, within the Borough. Care units. Therefore the Council will need to ensure that there is a sufficient supply of specialist retirement accommodation to accommodate the growth of older residents within the Borough.

28 Delivery

Furthermore, we have undertaken a review of recent Additionally, as aforementioned it is proposed that and current proposals for older persons housing the cricket pavilion and pitch will replace the existing within the Borough. At present a proposed scheme facilities on Rusthall Common and therefore the for 43 retirement living units at The White House in land at Rusthall Common would be returned to Cranbrook (19/01271/FULL) has been approved subject common land. This would result in the common being to the signing of the S106 agreement and a scheme accessible to the local community and therefore for 42 retirement living units have been approved at provide a public benefit to the local community. Pinewood Court in Tunbridge Wells (17/01191/FULL). Furthermore, the proposed cricket pitch and ancient The approvals should result in a total of 85 units for forest could be designated as village green land older people being delivered within the plan period. to protect against future development of the land. However, it is important to note that the approval at This would ensure that the land is protected for Pinewood Court was for the demolition of 39 vacant community use, providing a direct public benefit of retirement flats and the erection of 42 units. The net any development on site. increase in approved provision of units for older persons is therefore 46 units. At the time of submission of this representation, there are currently no applications for older persons housing pending. The NPPF (2019) encourages the need for housing for different groups to be reflected within planning policies. Whilst it is acknowledged that draft Policy H9 (Housing for Older people) outlines the requirement for the provision of homes for older people, in line with the requirements of the NPPF and taking into account recent approvals, the draft Local Plan would be more robust if the provision for retirement units was increased further via an explicit additional site allocations in the draft Plan In establishing if there were ‘very special circumstances’ to permit development in the Green Belt, the demand for extra care housing could be attributed substantial weight (West Malling appeal decision APP/A0665/W/18/3203413). c. Public Benefits As described in section 4, the site is currently underused. A number of public benefits would arise from the proposed development on site. The proposed community facilities and cricket pitch will provide the local community with modern community facilities and access to new public open space. The proposed layout of the site will also provide improved access to the ancient woodland, improving the accessibility of this natural asset to the local community.

29 9 Delivery

Conclusions The required amendment to the Green Belt boundary, as We welcome further opportunity to engage with the set out in this representation, is considered justifiable Local Plan process based on the timescales outlined in in order to meet the Borough’s need for retirement and the draft timetable below: market/affordable housing. Draft Policy H9 requires Local Plan Document/ Stage Scheduled Dates (LDS 2016) proposals for residential care homes and retirement living properties to be located in accessible locations. Draft Local Plan Consultation R.18 20th September- 15th November 2019 The site is located in a sustainable location on the edge 2019 The parcel plays an important role in providing a gap between Rusthall and of Tunbridge Wells, approximately 1 mile from the town Royal Tunbridge Wells. However, Rusthall is centre, 0.7 miles from the Pantiles shopping centre and not considered a town for the purposes of this study and therefore is not considered 0.9 miles from the station. The site is adjacent to the as part of the assessment.

Rusthall Road bus stop, providing a regular service to Submission Version Consultation R.19 August- September 2020 both the town centre and the Pantiles. The site is also Independent Examination Summer 2021 in an accessible location and is therefore considered suitable for retirement units. Adoption Winter 2021 Through architectural design and layout it is considered that any potential impact on the historic character of the Tunbridge Wells Conservation Area can be mitigated and the heritage asset can be preserved and enhanced. The proposed country park, cricket pavilion and grounds will provide public open space and a direct benefit to the local community that can only be facilitated through the minor amendment of the Green Belt boundary and the proposed allocation of the site. The site, therefore presents an opportunity for the development of an accessible site for the provision of much needed retirement housing within the Borough. The site’s ability to contribute to the provision of this form of housing, alongside the site’s contribution to the Borough’s general housing need and provision of community facilities is considered to justify the limited amendment of the site’s Green Belt boundaries via the Local Plan process.

30 Delivery

31 10 Policy assessment summary

An assessment of the proposed development against the key relevant draft policies is outlined in the table below. Draft Policy Ref. Draft Policy Content Assessment Against Draft Allocation

STR 4 The release of Green Belt land has been undertaken through this • In line with the requirements of the NPPF (2019), we have assessed the site’s Local Plan, and is detailed where relevant in the place shaping contribution to the five purposes of the Green Belt. Our assessment criterion was policies in Section 5. In order to protect the remaining Green Belt, based on that used in TWBC’s 2016 Green Belt Study Stage Two. We conclude as defined on the draft Policies Map, the Council will consider the that, on balance, an overall harm rating of moderate would be a more appropriate proposal against the relevant policy in the National Planning Policy conclusion. Framework, or the national planning policy at the time a planning • Paragraph 144 of the NPPF requires inappropriate development in the Green Belt application is being determined. (such as the residential aspect of the proposals), to be assessed on the weight of ‘the very special circumstances’. • The site’s contribution to the Borough’s overall housing need and more specifically to meeting the requirements for dwellings for older persons are considered to be ‘very special circumstances that would justify development in the Green Belt. • The proposed delivery of a community sporting facility is also considered to be a ‘very special circumstance’ that would justify development in the Green Belt.

H5 (1) Sites comprising predominantly greenfield land (i.e. non previously • It is proposed that the site will provide 40% affordable housing. This equates to developed land) delivering a net increase of more than nine approximately 40 units. dwellings will be expected to include a minimum of 40% of the gross number of residential units as on-site affordable housing provision. Where this percentage is not a whole number, it will be rounded up to the next whole number.

H9 Housing suitable for meeting the varying needs of older people • The site is located in a sustainable location, in close proximity to the facilities in should be integrated with all major housing schemes, particularly Rusthall, The Pantiles and central Tunbridge Wells. those that are close to local services, notably shops for day-to- • It is proposed that 40% of the proposed older persons housing will be affordable day purchases, healthcare and social/community facilities, and/ housing. or regular bus routes. Depending on the scale and location of development, this may be achieved by housing that meets the higher accessibility (M4(2) standard, bungalows and sheltered or other age-specific schemes. In addition, large schemes with good access to services may be required to set land aside for residential/nursing care (C2) purposes.

EN 7 The parcel is an important part of the landscape setting of the • The site is located adjacent to the Tunbridge Wells and Rusthall Conservation Areas. historic town of Royal Tunbridge Wells. The parcel lies adjacent to Heritage Assets • The proposed layout of the site has been designed to ensure that the proposals Tunbridge Wells Conservation Area, and parts of the Conservation conserve the character of both Conservation Areas. Area extend into the parcel. The adjacent Common is a fundamental part of the special character of Tunbridge Wells and the parcel • The proposed masterplan outlines three development parcels. Two of the parcels provides an important link between this and the wider landscape. are sited to the east of the site on the edge of the Tunbridge Wells Conservation Area. The boundary between the site and the Tunbridge Wells Conservation Area is well screened by existing trees and planting and therefore the development proposals will not impact on the character of the Conservation Area. • The third development parcel is located to the west of the site, adjacent to the Rusthall Conservation Area. As this development parcel is visible from the Conservation Area, it is proposed that the impact on the Conservation Area will be mitigated through the design and siting of the units.

STR/RU 1 At the parish of Rusthall, as defined on the draft Policies Map, • The site is considered to be a suitable development site within Rusthall and proposals shall accord with the following requirements: therefore aligns with the wider strategy of Rusthall 1. Approximately 15 new dwellings will be delivered on one site allocated in this Local Plan in the plan period (Policy AL/RU 1); 2. Additional housing may be delivered through the redevelopment of appropriate sites and other windfall development in accordance with Policy STR 1;

Assessment of the proposed development against the key relevant draft policies

32 Policy assessment summary

Key changes required to the plan This representation has highlighted the issue of In summary, we request that the Golf Course site is deliverability related to such sites and therefore calls allocated for residential uses (up to 100 dwellings), into question the effectiveness of the draft Local Plan at together with public open space, a new cricket pavilion present. Questions on the justification and effectiveness and pitch, for use by the local community. A significant of the draft Local Plan would therefore allow an proportion of the residential allocation within the draft Inspector to call into question the soundness of the plan Local Plan will be required to provide retirement living at examination stage. accommodation (C3 use class). The new public open In order to ensure that the Local Plan would be found space within the site will also be registered as a Village sound at examination, we urge the Council to allocate Green, which will preserve its open nature and prevent the site at Tunbridge Wells Golf Course, for older encroachment of development in future. persons housing and standard housing together with Paragraph 35 of the NPPF states that ‘Local plans and public open space, to ensure that the housing need spatial development strategies are examined to assess across the Borough can be met and delivered within the whether they have been prepared in accordance with plan period. As such, we request that the Golf Course legal and procedural requirements, and whether they site is allocated within the draft Local Plan and our are sound. Plans are ‘sound’ if they are: wording for a proposed site policy is set out below: a. Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively ‘Policy RU 2 assessed needs; and is informed by agreements Tunbridge Wells Golf Course, Langton Road with other authorities, so that unmet need from neighbouring areas is accommodated where it is The site, as defined in the Land Use Plan on page 6, practical to do so and is consistent with achieving is allocated for residential (C3 development) providing sustainable development; approximately 62 retirement housing dwellings and 36 dwellings, public open space alongside community b. Justified – an appropriate strategy, taking into facilities including a cricket pitch and pavilion. account the reasonable alternatives, and based on proportionate evidence; Development on the site shall accord with the following requirements: c. Effective – deliverable over the plan period, and based on effective joint working on cross-boundary 1. Vehicular access shall be taken from the existing strategic matters that have been dealt with rather accesses onto Langton Road (see Criterion 5 of Policy than deferred, as evidenced by the statement of EN 1: Design and other development management common ground; and criteria); d. Consistent with national policy – enabling the 2. Pedestrian linkages shall be provided into wider delivery of sustainable development in accordance network (see Policy TP 1: Transport Design and with the policies in this Framework.’ Accessibility); It is acknowledged that TWBC has sought to positively 3. Proposals to conserve and enhance the Conservation prepare the Local Plan, with an appropriate overall Area (see Policy EN 7: Heritage Assets); strategy. However, at this stage, the effectiveness and 4. Improvements to existing allotments, amenity/natural suitably of the proposed strategy can be questioned. As green space, parks and recreation grounds, children’s outlined in this representation, the current allocations play space and youth play space in accordance with the do not provide sufficient allocations for older persons requirements of Policy OSSR 2: Provision of publicly housing when compared with the assessed housing accessible open space and recreation. need across the Plan period and is therefore arguably It is expected that contributions will be required towards not based on proportionate evidence, a requirement for the following if necessary, to mitigate the impact of the soundness outlined in the NPPF. Furthermore, there is development: an over reliance on two large strategic sites (Tudeley a. Improvements to public realm; Village (AL/ CA1) and Capel and Paddock Wood (AL/ CA3)) to provide a significant proportion of the required b. Any other highway related works; housing need. c. Improvements to pedestrian links or bus services’.

33 Dr Steve Norris National Head of Planning, Development & Regeneration +44(0)20 7198 2281 [email protected]

Colin Pullan Urban Design Director +44 (0)20 7107 0016 [email protected]

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