TONBRIDGE AND MALLING BOROUGH LOCAL PLAN EXAMINATION

Written Statement MATTER 2 Spatial Strategy, Settlement Hierarchy, Distribution of Development and Site Selection

Representations on behalf of Wealden Homes Representor ID: 2018/0000224L

October 2020

TONBRIDGE AND MALLING BOROUGH LOCAL PLAN EXAMINATION

WRITTEN STATEMENT - MATTER 02 SPATIAL STRATEGY, SETTLEMENT HIERARCHY, DISTRIBUTION OF DEVELOPMENT AND SITE SELECTION

REPRESENTATIONS ON BEHALF OF WEALDEN HOMES REPRESENTOR ID: 2018/0000224L

OCTOBER 2020

Project Ref: 29662/A3 Status Final Issue/Rev: 01 Date: 09 October 2020 Prepared by: RC/JF

Checked by: JF Authorised by: JF

Barton Willmore 26 Avenue Kings Hill ME19 4AE

Tel: 01322 374660 Ref: 29662/A5/JF/RC Email: [email protected] Date: 09 October 2020

COPYRIGHT

The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore LLP. All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks. CONTENTS

PAGE NO.

1.0 INTRODUCTION 01

2.0 RESPONSE TO MATTER 02 – SPATIAL STRATEGY, SETTLEMENT HIERARCHY, DISTRIBUTION OF DEVELOPMENT AND SITE SELECTION 02

Introduction

1.0 INTRODUCTION

1.1 This Matter Statement has been prepared by Barton Willmore LLP on behalf of Wealden Homes. Wealden Homes is promoting two parcels of land at Church Lane, East Peckham – as allocated in the submitted Local Plan for 35no. dwellings (LP25 – t) and 23no. dwellings (LP25 – v) respectively.

1.2 Notwithstanding our Client’s interests, this Statement has been prepared in objective terms in accordance with the NPPF and PPG. With regard to Matter 02 MIQs, this Statement confirms:

- The Local Plan meets housing needs in full through an even distribution of growth across both the West Kent and HMAs in the Borough. - The Local Plan achieves a flexible supply of housing land meeting needs across the entire Plan period (in years 1 – 5 and 6 – 10). The Wealden Homes site will contribute to meeting housing needs in the first 5-years of the Plan. - The Local Plan spatial strategy is therefore sound. - Site selection, through the SA and SLAA processes has broadly been a robust process, including locating development to least constrained areas of Green Belt.

29662/A5/JF/RC 1 October 2020 Response to Matter 02 – Spatial Strategy, Settlement Hierarchy, Distribution of Development and Site Selection

2.0 RESPONSE TO MATTER 02 – SPATIAL STRATEGY, SETTLEMENT

HIERARCHY, DISTRIBUTION OF DEVELOPMENT AND SITE SELECTION

QUESTIONS

Q.1 Does the Local Plan set out clear strategic priorities for the area? Are the vision and spatial objectives clearly articulated and specific to the Borough? How do the strategic priorities, vision and spatial objectives relate to the proposed spatial strategy and distribution of development?

1.1 Policy LP2 (Strategic Objectives) sets out the strategic priorities for the area, which are embedded in the SA process and have informed the spatial options for growth and the distribution of development (Options 1 – 5 of the SA).

1.2 In particular, in the context of the objectives to “support the delivery of new homes that meets the needs of the community” and to “support and strengthen the hierarchy of settlements” we note the Local Plan meets housing needs in full. Moreover, that in doing so, allocations are proposed at Tonbridge, , and East Peckham, comprising the four principal settlements in the West Kent HMA. We consider that TMBC has correctly dispersed development within the main settlements in the West Kent HMA, including at East Peckham, where the Local Plan proposes the delivery of 58no. dwellings at the Church Lane sites.

1.3 We consider this to be broadly acceptable, however our technical studies for the sites demonstrate that the allocation can be slightly larger than identified and can therefore accommodate more growth than this – i.e. up to 68no. dwellings and we will return to this in our Matter 03 Statement.

Q.2 Is the approach to devising the spatial strategy as explained in the Council’s Spatial Strategy Topic Paper (ED12) robust and in line with national guidance?

1.4 We consider that the approach to devising the spatial strategy as explained in the Spatial Strategy Topic Paper (ED12) is robust and in line with national guidance, and agree with the strategic influences identified, including:

• TMBC’s housing requirement; • Housing pressure in TMBC – i.e. the affordability ratio; • Housing Market Areas exerting influence across the Borough;

29662/A5/JF/RC 2 October 2020 Response to Matter 02 – Spatial Strategy, Settlement Hierarchy, Distribution of Development and Site Selection

• Housing Market Capacity (Absorption Rate); • Settlement Hierarchy; • Availability of suitable development sites; • Employment land need; • Desire to deliver significant pieces of infrastructure to benefit local communities; and • Sustainability Appraisal.

1.5 The approach to devising the spatial strategy is considered to be “sound” and addresses the key issues for TMBC.

Q.3 What is the evidential basis for the settlement hierarchy at Figure 3 of the Local Plan? How has this been reviewed since the adoption of the Core strategy in 2007? How does it relate to the retail centres identified in Table 3?

Q.4 Are the settlement tiers in policy LP5 clearly defined? Are the groupings soundly based and supported by robust evidence? What factors have been taken into account when deciding which tier each settlement should be placed in? Are all settlements in the correct tiers?

1.6 The Core Strategy settlement hierarchy formed the starting point for assessment of TMBC’s Local Plan. The necessity for a revised hierarchy was then considered through the SA/site selection process.

1.7 Following the SA work (and the resultant spatial strategy), TMBC did not amend the settlement hierarchy in the Reg 19 Local Plan. We consider this to be an acceptable approach and that the settlement hierarchy provides an accurate account of the size of settlements and the range of services and facilities available at each – as existing and with allocated sites built out.

1.8 East Peckham comprises c. 1,350 households and contains a Co-op to meet day-to-day needs, several other shops and services including a library and a primary school, two village halls as well as commercial premises to the east of the village (adjacent the A228). We therefore consider it to be accurately defined as a “Rural Service Centre”.

Q.5 How does the distribution of housing and employment relate to the spatial strategy and the settlement hierarchy in policy LP5? Should the apportionment of development to each settlement be made clear in the Local Plan?

29662/A5/JF/RC 3 October 2020 Response to Matter 02 – Spatial Strategy, Settlement Hierarchy, Distribution of Development and Site Selection

1.9 East Peckham comprises c. 1,350 households and a population of just under 3,500 and, as mentioned above, it contains several shops/services as well as commercial premises to the east of the village. As mentioned above, given the shops, services and amenities available it is considered that East Peckham is capable of accommodating the extent of development identified in the Local Plan at Church Lane, and accordingly the distribution of development to East Peckham relates well to the spatial strategy and settlement hierarchy in Policy LP5.

Q.8 Is the spatial strategy, settlement hierarchy and distribution of development justified and sustainable, what other spatial strategies and patterns of distribution were considered and why were they discounted?

1.10 It is considered that the spatial strategy, settlement hierarchy and distribution of development is justified. The Local Plan meets housing needs in full, provides an even/dispersed distribution of growth across both HMAs in the Borough in line with evidence of where need arises, and secures an appropriate mix of small/medium sites as well as large sites.

1.11 It is considered that the Plan provides a good balance of small/medium and large sites in order to address needs across the entire Plan period, including the Wealden Homes site (considered a small – medium site), which will make a meaningful contribution to housing delivery early in the Plan period.

Q.9 To what extent does the spatial strategy seek to focus development on non- Green Belt sites? Generally, how has the Green Belt influenced the Spatial Strategy, settlement hierarchy and distribution of development?

1.12 TMBC has sought to evenly disperse development across the HMAs to provide a good dispersal of development across the Borough, responding to housing need, functional relationships and other environmental constraints including the Green Belt.

1.13 To this extent, it is noted that 55% of development proposed in the new Local Plan is to occur on non-Green Belt land (in Maidstone HMA) including strategic allocations at Bushy Wood (Eccles), South and Broadwater Farm (Kings Hill).

1.14 However, with 70% of the Borough area and almost all of the West Kent HMA parcel (aside from inset areas of Tonbridge, Borough Green, Hadlow and East Peckham) being located in the Green Belt, suitable and sustainable locations for new housing occur within Green Belt. Moreover, it is clear from TMBC’s Green Belt Exceptional Circumstances Topic Paper (ED10) and the Stage 2 Green Belt Review (LG8) that housing needs cannot be met in full (or even close to) on recycled or other urban land.

29662/A5/JF/RC 4 October 2020 Response to Matter 02 – Spatial Strategy, Settlement Hierarchy, Distribution of Development and Site Selection

Q.13 Will the spatial strategy provide a sufficient mix of large, small and medium size sites to achieve a flexible land supply?

1.15 Yes, the Local Plan does provide a sufficient mix of large, small and medium sites. This results in a flexible land supply during the first five years of the Plan, as well as from years 6 – 10.

1.16 The Housing Topic Paper (HO1) advances a 5.9 years supply of land to be achieved in the first 5-years of the Plan. The Wealden Homes land can contribute 68 units within this period, as anticipated to come forward and be built within 2021 – 2022.

1.17 Large-scale strategic sites are anticipated to commence towards the end of the five-year period/beginning of 6 – 10-year period. This has the effect of achieving a balanced and flexible supply across the duration of the Plan period.

Q.14 Is the site assessment/selection methodology as explained in the Site Selection Topic Paper (ED11) robust, based on an appropriate set of criteria and consistent with national policy? Are the reasons for selecting site options, and rejecting others, clearly set out and justified?

1.18 The Site Selection Topic Paper (ED11) sets out that sites were selected based on several parameters as formulated through the SA. These include an appropriate set of criteria that is consistent with national policy, including with regard to impacts on “transport”, “heritage”, “landscape”, “ecology”, “flood risk”, etc.

1.19 The assessment of the Church Lane sites as including all other sites is set out at Appendix 4 of the final SA (LPS18). While we do not comment on other sites, we consider that the reason for selecting the land at Church Lane, East Peckham is clearly set out and justified, and is therefore “sound” and in line with the NPPF.

Q.18 Has the sequential test, and exception test where necessary, been correctly applied in the assessment of flood risk on potential sites? Is this adequately evidenced? Are there any outstanding concerns from the Environment Agency?

1.20 The Sequential/Exception Test is addressed in the SFRA (NHE13), which outlines that “a Sequential risk based approach has been adopted to the preparation of the Level 1 SFRA which has involved an interactive process for the selection of appropriate potential development sites for the Local Plan” (para 4.2). It is noted that para. 4.2 of the SFRA further identifies that due

29662/A5/JF/RC 5 October 2020 Response to Matter 02 – Spatial Strategy, Settlement Hierarchy, Distribution of Development and Site Selection

to the “relatively extensive areas of land available for potential housing development in Zones 1 and 2” it has been “possible to align the selection of housing land when performing the Sequential Test so all potential new housing sites can be located on land outside of the high risk Flood Zone.” Moreover, para. 4.2 highlights that that “where potential housing sites are shown to comprise some land in a high-risk Flood Zone, proposed development will only be allowed to take place on land zoned as medium or low risk.”

1.21 It is noted that the SFRA outlines how the Sequential Test can be undertaken as part of a Local Plan Sustainability Appraisal, a free-standing document or as part of strategic housing land or employment land availability assessments. To this extent, it is noted that the Strategic Land Availability Assessment (H10), SA (LPS18) and Site Selection Topic Paper (ED11) all included flood risk as matter for consideration in the appraising and selection of sites, and it is clear from the evidence that this has informed the allocation of the Church Lane sites. The approach to the sequential test is therefore considered to be adequately evidenced.

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