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Representations to Tonbridge & Malling Local Plan Examination on behalf of Kitewood Estates in relation to Matters 2 and 3 in the Inspector’s Agenda for discussion at the Examination on 3 to 5 November 2020 Date: October 2020 The Elms, Oakwood Park Business Centre, Bishop Thornton, Harrogate HG3 3BF Tel: +44 (0)1423 206620 Email: [email protected] Registered in England No.12096560 Representations Contents 1.0 Introduction .............................................................................................................................. 2 2.0 Response to Inspectors’ questions on Matter 2 – the Spatial Strategy, settlement hierarchy; distribution and site selection (Policies LP2; LP3; LP4 and LP5 ................................................ 5 3.0 Matter 3 – Metropolitan Green Belt Policy LP3 ......................................................................11 Appendices Appendix 1: Extract from Reg 19 representations – site plan and overhead photographs Appendix 2: Masterplan from Reg 19 representations Appendix 3: Figure D from Reg 19 representations report Appendix 4: Study of Green Belt purposes performed by Kitewood site from Reg 19 representations report Reference: SC035 1 Representations 1.0 Introduction 1.1 This statement has been prepared on behalf of Kitewood Estates relating to its objections to the Tonbridge & Malling submitted (Regulations 19) Local Plan. These were originally submitted by consultants, WYG, in a document dated 16 November 2018. 1.2 These representations have been made taking account of the Inspectors’ guidance (Doc ED50) on representations to Matters 2 and 3 (and indeed all other Matters). They do not, therefore, seek to repeat in detail the previous representations made by WYG as many of the points made in those representations apply to the discussion on Matters 2 and 3 – and particularly the questions that are asked by the Inspectors in doc ED56. In these terms, certain conclusions in the WYG report will be relied upon in the further discussions at the Examination in response to the Inspectors’ questions. 1.3 Since the closure of the deadline for submissions in relation to the Regulation 19 version of the Plan, the objectors have been aware of the ongoing correspondence between the Inspectorate and the Council in relation to a number of matters relating to the soundness of the Plan. This includes the Inspectors’ concerns relating to the justification and evidence base to support key elements of the Plan, including its Spatial Strategy; the approach to the Green Belt and also co-operation issues. 1.4 Kitewood shares those concerns and welcomes that the Inspectors have raised important questions (similar to the position set out in the WYG report) particularly relating to the issues of the Spatial Strategy in the Local Plan and justification for it in their correspondence. The Council has not yet, in Kitewood’s view, adequately responded to such queries and it is hoped the Examination sessions will allow further clarification on key points. 1.5 Kitewood controls land to the south of the Tesco depot which lies to the west of Hays Road in Snodland. A site location plan together with some overhead photographs of the site are set included in Appendix 1. The site is some 2.42 hectares in size and is located immediately to the east of Hays Road lying between the Tesco depot to the north and the Sandhole Veterinary Centre to the south. As the plans in Appendix 1 show, there is therefore built development to the north and south of the site. The western site boundary comprises a substantial hedge line beyond which lies the Oast Park Golf Centre and open land. The boundary of the AONB is located further to the west. The potential development capacity Reference: SC035 2 Representations of the site shown on in Appendix 2 are that a mix of uses could be accommodated with approximately 1.2 hectares being for housing; 0.5 hectares for alternative uses, eg small scale employment, and then open space. Further discussion in relation to the characteristics of the site and its contribution to the Green Belt is set out under Matter 3 later in this statement. 1.6 Snodland is one of the defined five main urban areas in Tonbridge & Malling. Notwithstanding the status of Snodland as one of the principal urban areas within the Borough it is proposed to make no new allocations for housing in the settlement in the Local Plan up to 2031. The settlement framework of Snodland is such that it lies mainly to the east of the railway line with the main A228 road running north-south through the eastern part of the settlement. Much of the land to the east of the railway line is in either flood zones 2 and 3, so there is no realistic potential for expansion of the settlement in that direction. Residential and commercial development is contained on the southern side by the A228 (and mainly onto the east as well). The settlement extends west along a number of estate roads – including Paddlesworth Road and St Catherine’s Way. The built-up framework of the settlement extends considerably further west than the Kitewood site – including the Tesco distribution centre immediately to the north of it. It is proposed to allocate four new site allocations for employment purposes. 1.7 The focus of Kitewood’s concern about the Local Plan – set out in answer to the Inspectors’ questions in Doc ED56 – is that there is no reasoned justification for the lack of housing allocations in Snodland as one of the principal urban areas within the Borough. The Council has accepted (see Topic Paper ED10) in principle that there is a need to review Green Belt boundaries to accommodate development requirements and that development should be concentrated in the first instance within and adjacent to the main urban areas to promote sustainable patterns of development . So, on that basis, it will be logical to conclude that Snodland should be one of the principal locations for growth based upon the availability of services and accessibility to places of work and public transport. 1.8 If Kitewood’s representations are accepted, the Inspectors are recommended to advise the Council to review the potential for growth around Snodland; to accept the principle of further housing development in that settlement (together with employment growth) and to review the Green Belt boundary in a sensible way (as opposed to what has been done in Reference: SC035 3 Representations relation to the Green Belt study the Council is relying on) to arrive at a relatively small but proportionate expansion of Snodland on the Kitewood site to help meet housing and employment needs to 2031 and beyond. 1.9 Whilst Kitewood made representations to the Regulation 19 Local Plan in relation to the calculation of objectively assessed need (Matter 4) – it is content to rely on the position adopted by the HBF on this issue. However, we do consider (as appears to have been confirmed in discussions under Matter 1 at the Examination) that the Council appear to have rushed the final stages of the Plan-making stages to ensure examination under the 2012 NPPF for the purpose of avoiding the Standard Method for calculating housing need which would have resulted in the requirement for around 3,000 additional dwellings in the Plan period. Furthermore, the likelihood of housing requirements changing – particularly significantly increasing – as part of the latest Government pronouncements on the scale and nature of national housing requirements should not be ignored as part of this Local Plan process. The ability for the Borough Council’s neighbouring Local Planning Authorities to meet their own needs is questionable and proximity to London is likely to exacerbate the issues. In consideration of the considerable amount of time it has taken the Council to reach the Examination stage, it is considered that an early review of the Plan will be too late to deal with these fundamental matters. There should be a debate about the likely need for housing both in this Plan period and beyond – hence requiring a re-definition of Green Belt boundaries and the identification of safeguarded land to ensure, in accordance with the NPPF, that Green Belt boundaries endure beyond the end of this Plan period in 2031. 1.10 Kitewood would also wish to reiterate the point it made at Regulation 19 stage that it – in common with a number of other parties – is concerned about the Plan period finishing in 2031. In the context of NPPF advice about the minimum period for Plans to cover, when this Plan is adopted in, say, 2021 it is likely to have less than ten years still to run. This is of concern in itself but also highlights the need to ensure (see Matter 3) the need for Green Belt boundaries to ensure beyond this Plan period – hence the need for a more comprehensive and focused approach to the issue of safeguarded land. Reference: SC035 4 Representations 2.0 Response to Inspectors’ questions on Matter 2 – the Spatial Strategy, settlement hierarchy; distribution and site selection (Policies LP2; LP3; LP4 and LP5 2.1 It is considered the questions raised by the Inspectors are in a logical order to enable a full discussion of Matter 2. For convenience, therefore, the Kitewood response to questions has been done in the order of the questions and where convenient we have grouped the responses to several questions together. Questions 1, 2, 3 and 4 2.2 These questions relate to how the strategic policies for the area have been set out and justified (Topic Paper ED12); what evidential basis exists for them and whether Policy LP5 clearly defines the settlement tiers; that they are soundly based and supported by robust evidence. 2.3 Kitewood agree that in principle the focus for growth should be that part of Tonbridge & Malling Borough which falls within Maidstone HMA where the majority of growth within the first five years of the Plan period has been located.

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