A scheme for 165 new houses near Cranbrook in the High Weald AONB has been ‘called in’ for review by a planning inspector after Tunbridge Wells Borough Council’s planning committee resolved to approve the scheme. Berkeley Homes had been granted permission to build 36 homes at Turnden, in the Crane Valley between Cranbrook and Hartley back in February 2019. The developer then expanded its proposed scheme to add 165 more homes – which was also backed by the council. The development follows the council’s granting of outline permission for 180 dwellings at nearby Brick Kiln Farm. CPRE Kent supported Natural England in objecting to the proposal and asking Robert Jenrick, Secretary of State for Housing, Communities and Local Government, to call in the decision. This has now happened. John Wotton, chair of CPRE Kent, said: “Major developments on greenfield sites in the High Weald AONB should not be happening. Allowing the Turnden scheme would set a precedent that could lead to harm to our precious protected areas throughout the country. “This scheme will destroy a piece of medieval farming landscape, obliterate historic settlement patterns and suburbanise the rural setting of Cranbrook. Spreading spoil from the development over adjoining fields will only cause further harm to the environment and the enjoyment of the countryside by local people.” CPRE will be working with the local action group, Hartley Save our Fields, to oppose the granting of permission and will support Natural England and the High Weald AONB Unit when the case comes before a planning inspector later this year. We are also opposing the allocation of the site for development in Tunbridge Wells’s new Local Plan.
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It’s been described as “the biggest threat to Tonbridge and our Green Belt in a generation” and indeed plans from Tunbridge Wells Borough Council for mass housebuilding seem set to change landscape and life in west Kent in an almost unimaginable way. The proposals for 2,800 new houses at Tudeley and another 1,500 at East Capel sparked the creation of Save Capel and last month John Wotton, CPRE Kent chairman, gave a speech to the campaign group pledging this organisation’s support in the bid to halt a policy destined to ruin the quality of life for so many. Here is that speech, made on Wednesday, September 18, in full: “CPRE is the countryside charity. It exists to protect the English countryside, to make sure it is valued and accessible to all and that it supports a viable and sustainable rural economy. “Here in Tunbridge Wells, we are privileged to live in the beautiful and historic farmed and wooded landscape of the Weald of Kent. We are all custodians of the countryside, none more so, I would suggest, than our local planning authority. “So, how does the draft Tunbridge Wells Local Plan measure up in terms of protecting our cherished countryside? Not well, in my estimation. “The plan is, of course, the product of a broken planning system, driven by political and commercial interests that are wholly divorced from the needs of the population as a whole and wishes of local communities, including this one. “It is inconceivable that Tunbridge Wells Borough Council would have come up with a plan of this nature in the absence of the housing and other targets imposed by national planning policy. “There is now no pretence that the targets are based on genuine predictions of household growth and housing need, for the most up-to date Office of National Statistics data on population growth and household formation have been ignored by national government, in order to adhere to a totally arbitrary and unachievable target of building 300,000 homes a year (that is homes built anywhere and of any type, regardless of housing need). “The rationale for this target has been challenged in recent research by Ian Mulheirn, published by the UK Collaborative Centre for Housing Evidence, which concludes that no more than 160,000 homes per year need to be built to cater for housing need. “This topic is highly controversial, but for us in Tunbridge Wells, the key point is that the right homes for the people in this borough are built in the right places. “The homes which are built should be affordable to those in need of a home and built in the most environmentally sustainable places, not simply the sites that yield the highest profit to developers. “This means that houses should preferably be built on brownfield or urban infill sites, or as limited urban extensions, always making the most efficient use of land, rather than in new settlements on greenfield sites, and especially not in protected landscapes. “The council seems to agree with this in principle, but not in practice. CPRE naturally wishes to see Tunbridge Wells adopt a sound Local Plan as this will give the local authority a measure of control over future development and better defences against inappropriate, speculative development proposals. “However, a sound Plan is not a panacea. Factors beyond the council’s control may (and probably will) undermine the Plan during its 15-year life, probably sooner rather than later. “These factors include changes in the deliverability of individual sites, failure to build out planning applications which have been granted and, in these febrile political times, changing requirements of national policy. “As soon as the council’s housing policies are shown to be out of date, the developers will again have the whip hand. “A ‘Sound Plan’ is therefore not to be bought at any price and the price of this draft Plan is, in CPRE’s view, far too high. “Tudeley Village is just the most egregious example of the sacrifice of greenfield sites for substantial housing development in the Green Belt, in the High Weald Area of Outstanding Natural Beauty and elsewhere in the borough. “This sacrifice is made in pursuit of housebuilding objectives that, even in the unlikely event of their being achieved, would do little to meet the genuine local need for housing, at prices local people can afford. “The council say that they place the highest priority on protecting the AONB and then the Green Belt, but this is not the impression I gain from the proposed site allocations throughout the borough. “If Tudeley Village is intended to relieve the pressure on the rest of the borough, it does not achieve this, even in protected areas. In my own parish of Cranbrook and Sissinghurst in the AONB, for example, the housing allocation exceeds assessed local needs by about 50 per cent. “What can the council do, though, in the face of seemingly implacable national policy requirements? “In our view, national planning policy does allow Tunbridge Wells to provide for less than the so-called objectively assessed housing need, in view of the high proportion of the land in the borough which is protected as Green Belt or AONB. “This ability is fundamental to the effective protection of the Green Belt and AONBs. If it were not there, the Green Belt and AONB would be less protected in those districts in which they form a large proportion of the land area than in those where only small areas are protected. “This is not the law, or the policy of government. “The council say that they have not even considered the possibility of providing for less than assessed housing need, because their Strategic Housing Land Assessment shows that the borough can accommodate this need. However, it is hard to see how they have reached this conclusion. “Their Sustainability Assessment shows that the council’s housing objective is compatible with only five of the 19 sustainability objectives they have set themselves and incompatible with nine of them. “It is the only objective in the Plan which fails the council’s sustainability tests in this way. This is a fundamental contradiction in the Plan. It does not provide for sustainable development in Tunbridge Wells on the council’s own terms, and it must be changed. “I haven’t said much about how the technicalities of planning policy apply to the overarching subject of the climate emergency, which rightly moves ever higher up the political agenda, including the planning agenda. “It is far from clear to me that the council gives adequate weight to mitigating climate change in this Plan. That is a wider topic than we can embark upon today, but an aspect of it is specifically relevant to the Tudeley Village proposal. “Under the government’s climate change guidance, planning authorities are advised that the distribution and design of new settlements and sustainable transport solutions are particularly important considerations that affect transport emissions. “The planning inspectors have within the past week rejected the draft West of England Spatial Plan, saying that high levels of dispersed development across the West of England, unguided by any strategy, would not be sustainable. I understand that this Plan included a number of so-called ‘garden settlements’ on greenfield sites. “It would seem that garden settlements are going to be looked at closely by inspectors and this should make Tunbridge Wells Borough Council think twice before trying to meet its housing objectives in this way. “Tudeley Village is the poster child for the unsustainability of this draft Plan. It represents unsustainable, environmentally harmful destruction of the countryside, replacing a beautiful, unspoilt and protected site with a dormitory for City commuters and their families, heavily reliant on their private cars for transport. “It will destroy local communities and ruin local residents’ lives. It must be stopped and CPRE Kent will support you in your campaign.”
You can read the latest Save Capel newsletter here
To a mixture of horror at what it
includes and relief that it has finally seen the light of day, the Tunbridge
Wells draft Local Plan has finally been published.
Covering the period 2016-2036, the Plan is aimed at replacing the local authority’s
2010 core strategy, 2016 site allocations plan and saved policies from its 2006
Most contentiously, the draft looks to axe more than 5 per cent of the
borough’s Green Belt, primarily to accommodate 14,776 new homes, a figure that
includes a 9 per cent buffer above the government’s Objectively Assessed Need
total of 13,560.
The homes are apparently going to be built at a rate of 678 a year, a target
substantially more than double the 300-a-year featured in the 2010 core
strategy, produced in line with the former South East Plan.
Disappointingly, the draft does not designate any land to compensate for the
Green Belt that is set to be lost, which, as it stands, amounts to 5.35 per
cent of the current total.
The largest housing allocations are at Paddock Wood (4,000 dwellings in addition to the 1,000
already allocated) and Tudeley (2,500-2,800, with some 1,900 to be built
during the Plan period), as well as some 800 dwellings in the AONB at Cranbrook and 700, also in
the AONB, at Hawkhurst.
Liz Akenhead, chairman of CPRE Kent’s Tunbridge Wells committee, said: “The Plan states that, overall, some
5.35 per cent of the Green Belt within the borough is to be de-designated and
that ‘in accordance with the NPPF the Plan does not designate other land as
“replacement” Green Belt to replace that to be removed, but rather sets out how
compensatory improvements to the environmental quality and accessibility of
remaining Green Belt land can be made’.
“On a first reading, I have not noticed any evidence in the Plan that these
improvements will actually materialise.”
Consultation on the draft Plan begins on Friday, September 20, and is scheduled
to end on Friday, November 1. It is anticipated that the Plan will be adopted
in December next year.
For more on the Tunbridge Wells Local Plan, see here
Tunbridge Wells Borough Council is in the process of completing its Local Plan, a key part of which is meeting a housing target in line with government methodology. This will mean a huge increase in housebuilding. Under the new formula imposed by the government, the borough will be required to build 13,500 dwellings by 2036 more than double the number required under the previous Core Strategy. Many housing developments have already been permitted on valuable Area of Outstanding Natural Beauty (AONB) and Green Belt land, such as at Brick Kiln Farm, Cranbrook, resulting in the loss of part of one of the finest remaining medieval landscapes in Europe. The proposed new ‘garden village’ (or new town) at Capel has already been announced, but this is the tip of the iceberg: smaller developments will happen across our rural areas.
A chance to protect the AONB and Green Belt missed The planning system allows TWBC to protect the Green Belt, but in the case of Capel it appears it has chosen not to do so. This is despite the council’s Green Belt Study identifying “release” of this broad area from the Green Belt as causing a very high level of harm to the Green Belt (Tunbridge Wells Green Belt Study Stage 2, Land Use Consultants, 2017). Paragraph 11b and Footnote 6 of the National Planning Policy Framework (NPPF) 2019 provide an exception to the requirement to meet housing ‘needs’ where the application of policies in the NPPF protecting Green Belt, AONB, irreplaceable habitats, heritage assets and areas at risk of flooding provide a strong reason for restricting development. Some 70 per cent of the borough is designated as AONB and 22 per cent as Green Belt, while Flood Zone 3 covers almost 7 per cent. This compares with some 25 per cent of England that is National Park or AONB, and 12.5 per cent of England that is Green Belt.
Land lost based on incorrect housing need forecasts There is a prevailing false assumption that simply building more homes, of any kind, will bring down prices. Councils are placed under ever-increasing pressure to meet unrealisable housing targets, compelled to release more land for development and grant more planning permissions, even while many sites (such as the brownfield cinema site in Tunbridge Wells) that already have permission are not built out. Last year, the final report of Sir Oliver Letwin’s review of build-out rates found that the largest housebuilders were consistently delivering expensive homogenous homes only as fast as the open market could absorb them without lowering prices. This business model deliberately and explicitly fails to result in the reduction in house prices assumed by those who advocate unconstrained market housebuilding as a solution to the affordability crisis. It does not and cannot deliver the kind of homes that communities need; rather, it will continue to cover the countryside in poor-quality, piecemeal development. Worse still, because the ‘standard method’ for estimating local housing need is based on the relationship between house prices and incomes, building more expensive homes, especially in rural areas, leads to an increase in the apparent demand for housing calculated using this method and the cycle of unaffordable speculative housebuilding continues. The most recent figures from the Office for National Statistics on housing affordability in England and Wales show worsening levels of affordability over a five-year period across most of the country, despite the consistent weakening of the planning system. At present, the planning system actively reinforces market trends. The standardised method for calculating ‘objectively assessed need’ for housing in each local planning authority area, which takes household growth projections as a baseline and adjusts them according to market signals, concentrates growth and investment in areas that are already economically buoyant and have overheated housing markets. In the long run, this simply stokes more demand, further inflating rents and house prices, straining local services and exacerbating the oppositional nature of the planning process. Moreover, it further unbalances the national economy. Government planning policy, as set out in the revised and updated 2019 National Planning Policy Framework (NPPF), prioritises driving up the overall quantum of homes delivered over other considerations, including tenure mix. It also holds local authorities to account for things outside their control, such as the failure of the volume housebuilders to build out sites quickly. The introduction of the Housing Delivery Test (recently failed by 108 authorities) places councils under such pressure to deliver more homes that it is difficult for them to reject proposals for inappropriate developments, including those that do not comply with local affordable housing policies. Moreover, many applications that initially propose to meet local affordable housing requirements are later renegotiated by developers on the grounds of viability. CPRE’s 2018 research with Shelter found that rural sites where a viability assessment was used saw a 48 per cent drop in the number of affordable homes delivered. CPRE’s report on the State of the Green Belt 2018 demonstrated that building on the Green Belt was not solving the affordable housing crisis and would not do so. Last year, 72 per cent of homes built on greenfield land within the Green Belt were unaffordable by the government’s own definition. Of the 460,000 homes that were planned at the time of the report to be built on land released from the Green Belt (a figure that doesn’t include the 4,500 additional houses now planned for Capel and Paddock Wood), the percentage of unaffordable homes would increase to 78 per cent. Local authorities with Green Belt land have enough brownfield land for more than 720,000 homes, the report found, much of which was in areas with a high need for housing and existing infrastructure.
Land lost due to low-density housebuilding TWBC may do its best to put homes on ‘brownfield’ sites, and on areas outside the Green Belt or AONB, but the target is so high that many houses will have to be on Green Belt or AONB land. An important way to reduce the amount of land required is to maximise the density of each development. There are two reasons this is difficult in practice. The first is that it is more profitable for developers to build big houses with plenty of land. Secondly, neighbours, faced with a planning application, often ask for the number of homes to be built on a site to be reduced, minimising the impact. We all need to realise the result of that: another piece of land will need to be sacrificed to take the houses not built here. The Campaign to Protect Rural England and TWBC both recognise 30 homes per hectare as a fair target for new developments. Many of the planning applications received are for 15-20 homes per hectare. This means that up to twice as much land is needed for the same number of homes. Somewhere else? No, your village will have to provide some of the land. Future generations will ask why we sacrificed land in this way – land that might still be green. There is another reason density is important. The borough desperately needs more affordable housing. Many parish councils have heard from residents that their children are being priced out of the area, and the supply of new affordable homes in the villages is way below the need. Low density simply means more expensive housing. Higher-density housing does not need to be ugly. Some of the most desirable properties in our area are terraced cottages on village streets: the high-density housing of the past. There are clusters of homes in converted buildings around old farmyards that use land very efficiently. Even in modern developments a village atmosphere can be created with terraces, while maisonettes and other three-storey developments can be an attractive part of the development. Higher-density development makes public transport more viable. Some sites are not suitable for higher-density housing. The answer in most cases is not to accept the low density but to leave the land green. Over the planning period, the amount of land sacrificed by low-density development could be up to 1,000 hectares – 1,400 football pitches. We suggest that an opportunity cost should be applied to proposals for low- density development: the land to be sacrificed in the future. A five-hectare plot built at 15 to the hectare has sacrificed 2.5 hectares of land that might still be green. Meanwhile, despite clear government guidance that “where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities, and ensure that developments make optimal use of the potential of each site” (NPPF para 123), TWBC has been granting planning permission on many sites at low densities. For example, on a partially brownfield site in the Green Belt at Five Oak Green the borough council is applying to grant itself permission for three four-bedroom and two five-bedroom market houses on a half-hectare plot, a rate of a mere 10 dwellings per hectare, with no affordable housing (19/01586/OUT Land West Of Sychem Place Five Oak Green). Future generations will ask why we both sacrificed land in this way – including some of our most precious landscapes – and failed to build the homes our young people need.
The Blue Boys Inn… work is under way although it would appear that not all planning conditions have been fulfilled
Coming soon… burgers and chips
The latest chapter in the long and colourful tale of the Blue Boys Inn at Kippings Cross, Matfield, appears to be winding to its conclusion.
After any number of planning applications, proposals and exchanges of views about its future, the Grade II-listed building is being transformed into a Burger King take-away.
Whatever your views on such an outcome, it does at least mean the inn’s dilapidated state is being addressed, even if the demolition of its oldest part cannot be reversed and some aspects of the redevelopment are less than satisfactory.
At one point, demolition of the entire inn was on the table, but now the new outlet will be built into the remaining structure, ensuring some element of its historical significance.
CPRE Kent’s Tunbridge Wells and historic buildings committees had been watching, with growing concern, the situation unfold, last year writing to the chief executive of Tunbridge Wells Borough Council in a bid to halt the building’s decline.
You can read about this here and here, but Lady Akenhead, chairman of the Tunbridge Wells CPRE committee, brings us up to date with proceedings.
“Both the Tunbridge Wells and historic buildings committees objected to the details of recent applications connected with the approved plan to turn the Blue Boys into a fast-food take-away, now to be occupied by Burger King,” she said.
“Following our objections, some amended details were submitted that satisfied the council’s conservation officer regarding the listed building and advertisement applications.
“Some of the applications still await approval, presumably while the applicant seeks a solution that will satisfy the council concerning the various points raised.
“Meanwhile, construction of the extension to the Blue Boys continues apace, although the details concerning contamination and landscaping whose approval was required prior to commencement of the development under the planning permissions granted in 2016 have not yet been approved!
“The planning officer records having visited the site on three occasions in September and October this year but appears to have made no effort to enforce the landscaping condition, merely appending it again to the delegated approval he has granted for the recent listed-building application.”
Not wholly desirable, by any stretch, but the fact the Blue Boys Inn still exists at all (even if as a burger joint) is thanks in to small part to the work of CPRE Kent’s Tunbridge Wells and historic buildings committees. Well done!