Tunbridge Wells Borough Council Draft Local Plan (Regulation 18) Consultation – Group Response DATA PROTECTION AND FREEDOM OF INFORMATION The information collected via this response form will be used by Tunbridge Wells Borough Council to inform future stages of Local Plan preparation. When you send your response to this consultation, your contact details will be added to the consultation database and you will be kept informed of all future consultations on Planning Policy documents. Please note that your responses will be published by the Borough Council, including on its website. The Council will publish names and associated responses but will not publish personal information such as telephone numbers, e-mails or private addresses. Your details (please give full contact details) Name Simon Gentry This response is made on behalf of the Residents Against Ramslye Responding on behalf of Development group and the 669 signatories on the petition delivered to Kate Jelly, Planning Services, TWBC Email address [email protected] Postal address 4 Summervale Road Town Tunbridge Wells Post Code TN4 8JB Telephone Number 07599 819487 Signature Sent by email Date 14 November 2019 Section 4: The Development Strategy and Strategic Policies Policy STR 1 – The Development Strategy 1b states “An enhanced town centre development at RTW, including... the provision of flexible retail, leisure, and cultural uses, as well as new office provision…”. In December 2018 Kent Live reported “Empty shops in Tunbridge Wells could be the start of town centre shrinking as shopping habits change”. Last year the Courier reported that nearly a third of the RVP units were empty. There are still numerous empty shops so there is little point planning to build more until the current supply is exhausted. The same is true for office space. In past years office space in the town has been converted into residential space, the most obvious example being the Union House development of 127 luxury flats (none of which are affordable). Maybe AXA PPP healthcare would like to consolidate its offices at North Farm but it is not at all clear who would fill the existing/old ones if that were the case. TWBC needs to think more carefully about what the future of retail and office work is in an increasingly digitalised world rather than wishing for a return to the turn of the century’s shopping and working patterns. Page 1 of 25 Policy STR 1 – The Development Strategy – Scale and distribution of development – Table 3 We challenge the need for such a large number of new dwellings in the Borough. Office for National Statistics data predicts the population of Tunbridge Wells will grow from 117,140 in 2016 to 131,092 in 2036 (the planning period). TWBC reports that housing stock in 2016 was 49,880. If the occupancy rate of dwellings remains at the 2016 level (i.e. 2.35 people per dwelling) then the need by 2036 will be a further 5,937 dwellings to the stock. Even if one were to allow for a decrease in the occupancy rate to two people per dwelling, the need would still be lower than 7,000, i.e. less than half of the number of dwellings the plan allows for. The Housing Supply and Trajectory Topic paper (September 2019) reports “Between 1st April 2016 and 31st March 2019, 1,552 dwellings were completed and, as of 31st March 2019, 3,127 dwellings have extant planning permission.” This leaves a need of 1,258 (@ 2.35 occupancy) to 2,297 (@ 2 occupancy) new dwellings between now and 2036. While we appreciate the housing requirement is set by national policy, we do not consider TWBC has appropriately represented the interests of its residents. The policy is eminently challengeable because it is fundamentally flawed. It effectively only considers supply side solutions to housing affordability when much of the house price inflation experienced in the last 10 years is a consequence of the macro–economic environment (principally interests rates at an historic low for over 10 years) i.e. demand side issues that do not relate to population growth. By accepting the allocation, TWBC has not acted to protect the rural nature and the associated landscape of the borough that is valued by its residents and is protected under law. The approach to date has been supine and cavalier with our environment and interests. TWBC must take steps to challenge the allocation on our behalf so as to protect our interests. Policy STR 2 - Presumption in favour of sustainable development “4.42 As set out within the NPPF, the role of the Local Plan is to plan for development over the plan period in a sustainable way in accordance with the Development Strategy. Accordingly, in planning for new development, consideration should be given to all three elements of sustainable development; the economic, social, and environmental objectives.” Your policy has taken this statement and presumed development, not that development where it takes place will be done in a sustainable way. The policy should not presume there will be development. The policy as drafted is too heavily in favour of development and in particular developers whose motives and incentives are often misaligned with the council and more importantly the residents. Policy STR 3 - Masterplanning and use of Compulsory Purchase powers Compulsory Purchase Orders (CPOs) must only be used in very exceptional circumstances. The bar must be set an appropriately high level. Where a CPO is used, the market rate must be paid to the land owner. The use of CPOs must be monitored, to ensure particular individuals are not hounded over a period of time. Policy STR 4 – Green Belt “The release of Green Belt land has been undertaken through this Local Plan, and is detailed where relevant in the place shaping policies in Section 5. In order to protect the remaining Green Belt, as defined on the draft Policies Map, the Council will consider the proposal against the relevant policy in the National Planning Policy Framework, or the national planning policy at the time a planning application is being determined.” Your policy simply doesn’t adequately protect Green Belt. Your plan dedesignates 5.35% of the borough’s Green Belt, with no alternative land being protected. Will another 5% be dedesignated in 2036? The South East of England is already more densely populated than other parts of the country. The borough cannot build and build, and maintain what is special to this area. The policy should be more explicit about protecting those areas of Green Belt that are either more sensitive or contribute more to the Green Belt policy objectives. In addition, given the number of local plans around the country that propose the development of Green Belt land, we find it very difficult to believe that each district or borough can be exceptional – we think you must agree that would be an exceptional number of exceptional circumstances. Page 2 of 25 Policy STR 5 - Essential Infrastructure and Connectivity – Education & Health There is no need for a new secondary school in Tunbridge Wells. Tunbridge Wells already has six secondary schools: Tunbridge Wells Girls’ Grammar, Bennett Memorial, Skinners’, Skinners’ Kent Academy, St Gregory’s and Tunbridge Wells Grammar for Boys. In addition to these academy and maintained schools, there are a number of independent and special schools. The Draft Local Plan proposes that part of the land at site 137 / AL/RTW 18 should be used for the provision of a new secondary school (at an estimated cost of £30 million). The issues and options paper published by TWBC in 2017 is largely silent on the associated infrastructure development required with such a large house building program. Instead it is noted in the Consultation Statement that responses identified the need for appropriate infrastructure development (including but not limited to schools) if that many new houses are built. The case for a new secondary school in RTW has not been persuasively made at all. Clearly the need for an additional secondary school must take account of current (over) capacity and projected need. The KCC Education and Infrastructure Needs and Requirements (EINR) document would have been a useful document for you to refer to in your consultation document. In that document it reports there is currently 12.4% spare capacity in Tunbridge Wells secondary schools, which is above average for Kent, more than twice the KCC target capacity and makes Tunbridge Wells 5th out of 13 areas in terms of capacity. The EINR document goes on to project a need for an additional 1644 secondary school places in Tunbridge Wells by 2031. Given the current capacity has approximately 500 places before breaching the 5% target, the need for additional places is likely to be nearer 1100. The Tunbridge Wells Infrastructure Delivery Plan sets out plans to expand four secondary schools in the next few years by five forms of entry (classes) (i.e. 150 additional places per year group, so 750 new places), thus further reducing the additional capacity required. Of the planned expansion, four out of five of the new forms of entry will be in RTW. Given that less than 10% of the planned housing development will be in RTW, siting a new school at the south west edge of the borough is simply not appropriate (and in clear contravention of your own transport policies) when the need will be in the north. Given all of this, we are surprised that in conversation with your planning officers at the 26/28 September 2019 Royal Victoria Place exhibition they talked about an “urgent need” for a new secondary school in RTW. Indeed the Infrastructure Development Plan says “Land reserved for the establishment of a new secondary school in RTW post 2030 (Spratsbrook)”.