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. TMBC Local Plan Consultation response by Tonbridge & Malling Green Party 2 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? TMBC Local Plan Consultation response by Tonbridge & Malling Green Party 3 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.