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TUNBRIDGE WELLS BOROUGH DRAFT LOCAL PLAN (REGULATION 18)

Consultation 20 September to 15 November 2019

RESPONSE FORM

This response form is for use with the Draft Local Plan (Regulation 18) consultation document.

Your details (please give full contact details)

Name Marieke de Jonge

Company/organisation (if relevant)

Tunbridge Wells Friends of the Earth

Are you responding as an individual or organisation, or as an agent on behalf of somebody else?

On behalf of an organisation or group

If you are an agent, please specify who you are representing

Email address [email protected]

Postal address 44 Mount Ephraim

Town Tunbridge Wells

Post Code TN4 8AU

Telephone Number 07523 527823

We would like to acknowledge the support in guiding us through the process of responding to the LDP given by Mark Booker from the Tunbridge Wells Town Forum. In addition, I am grateful for the input from our Tunbridge Wells Friends of the Earth members, specifically John Hurst and Myriam Ruelle. Lastly, we like to stress our agreement with and approval of the response to the LDP submitted to you by Tunbridge Wells Bicycle Users Group (TWBUG).

Draft Local Plan (Regulation 18) Response Form 20 September to 15 November 2019 1

COMMENTS ON A PARTICULAR SECTION OR PARAGRAPH

COMMENT BOX 1A

Please state which section or paragraph number(s) you are commenting on.

Section Number: Section 2: Setting the Scene Section 4: The Development Strategy and Strategic Policies Section 5: Place Shaping Policies Section 6: Development Management Policies

Paragraph Number(s):Specified with each comment

COMMENT BOX 1B

Please enter your comments in the box below.

Section 2:

Sustainable development §2.14 We welcome the assurance that the new Local Plan will follow sustainability principles and carry out Sustainability Appraisals to assess the impact of its policies. We feel that the statement: “Where potential adverse impacts are identified, mitigation measures may be set out by the Sustainability Appraisal to remove or reduce the adverse effect and enhance beneficial effects.” needs further clarification though.

§2.15 We are pleased that climate change is recognised as a major issue and that the policies contained within this Draft Local Plan will seek to support carbon reduction and the transition to a low carbon future to help to counteract the impacts of climate change. However, we strongly object to the promotion of biomass as if a renewable form of energy generation. [Please, see document on biomass research attached].

Transport §2.25 We strongly support the intention to improve air quality not only within the AQMA but throughout the urban area of RTW, but question whether proposed measures will be sufficient.

§2.26 We challenge whether ‘predict and provide’ in relation to parking will allow the transition to active travel promoted elsewhere in the Draft and are worried that instead it will increase car traffic.

Demographics and housing §2.32 We support the efficient use of land which will generally require higher housing densities than have previously been the case, while seeking to avoid adverse impact on the character and setting of the natural and built environment.

Natural, built and historic environment §2.40 - §2.44 The constraints of the Green Belt and AONB mentioned in §2.40 should be cross-referred to §2.10 where they are also described as having balancing attributes which should be given their full weight in restraining inappropriate development.

§2.40 We recognise the value of the Metropolitan Green Belt and consider it right that it should pose a significant constraint to development. We would oppose to any development in Green Belt land.


§2.41 We encourage the protection of the wide network of biodiversity sites in the borough.

§2.43 We agree with the explicit recognition that pressure for new built development across the borough, including on greenfield land, could have direct impacts on landscape and environmental assets and their settings, and that the Draft Local Plan needs to ensure that, in facilitating development, proposals take full account of, and reflect, each site's landscape and environmental sensitivities.

§2.44 When balancing the competing pressures of housing, employment, and other development with the preservation and enhancement of local character and distinctiveness of sites, we maintain that conservation of Green Belt, High Weald AONB, Sites of Special Scientific Interest, Wildlife Sites, Nature Conservation sites and Nature Reserves should prevail and be excluded from development.

The Development Strategy - Introduction §4.3 No mention is made of the landscape, heritage and water provision constraints on development which may well inhibit full provision of the development needs of the Borough as defined by central government. We maintain that TWBC should refuse to accept the level of development that is proposed by central government due to the constraints posed as set out above (comments on §2.40 and §2.44).

Housing development §4.7 - §4.9 We would urge TWBC to follow Sevenoaks’ example and refuse to build the number of houses demanded by central government so as to protect the Green Belt, SSSI, AONB, etc. Instead, we would ask for a recalculation of truly local needs and an active search for brownfield land as a first option for development.

Infrastructure and other supporting uses §4.26 and §4.27 We are concerned that the resources needed to give effect to the Infrastructure Delivery Plan’s objectives will not become available in time to mitigate problems arising from the planned development in the Borough. This particularly applies to the required development of a coherent network of active travel routes in Royal Tunbridge Wells and between settlements in the Borough.

Preferred Option, Site submissions, Development Strategy for consultation §4.28 - §4.40 We consider it regrettable that a planning policy system based on a call for sites from interested landowners will not necessarily result in optimal selection of land suitable for development. We have nonetheless welcomed consultation and information workshops and meetings with TWBC Planning Policy Officers.

§4.40 We propose TWBC refuses to meet the target of some 13,560 new homes in the borough over the 2016-2036 period, and we oppose to any potential loss of Green Belt land and further development in the High Weald AONB.

Section 5: Place Shaping Policies §5.7 It is acknowledged that mitigation of impact of transport is key due to the constrained nature of some transport routes into, out of, and through the Main Urban area. A strong policy in the new Local Plan must at least improve on the present lack of effective mitigation measures, specifically with regards to air pollution and climate change impacts in general.§5.9 This paragraph will have to be redrafted in the light of the political decision not to proceed with the Calverley Square development. We are very pleased as 66 mature trees that were due to be cut down, will now be saved and the park’s landscape conserved.

Section 6: Development Management Policies - Environment Environment and Design

Design and other development management criteria Overall, we are positive about the criteria as set out in this section with regards to


sustainable development, specifically the following:

§6.11 recognition of sustainability, energy efficiency, tree planting, and landscaping as some of the key elements that make up good design

§6.12 identifying development should maintain and enhance landscape connectivity, and biodiversity and geodiversity features

§6.13 early consideration of landscaping and tree planting as integral to the overall design of a scheme

§6.14 following guidance, such as Building for Life and BREEAM

Sustainable Design and Construction §6.16 and §6.17 The positive point made in these paragraphs is that it is made explicit that sustainable development acknowledges the fundamental importance of ensuring that future generations can meet their needs and therefore the need to protect and conserve natural resources. It is claimed that the Plan’s policies seek to reduce the ecological and carbon footprint of development and promote wellbeing and we are looking forward to seeing assessment of planning applications made on this basis.

§6.18 Unfortunately, this paragraph seeks to promote a practice that is highly polluting and will contribute to CO2 emissions and is therefore contradictory to the previous paragraphs and the general objective of truly sustainable development. Biomass burning causes significant harm to the environment and should be opposed instead of promoted, and certainly not be presented as on a par with clean, renewable means of generating energy, such as solar, wind or tide. [Please, see document on biomass research attached].

§6.19 Positive appreciation of ‘ecosystem services’ to flood mitigation, crop pollination, freshwater filtration, and climate stability and how these are often undervalued in conventional economic analyses and decision making. We are looking forward to seeing assessment of planning applications that recognise these critical services to protect and enhance ecosystem services.

§6.21 - §6.22 Provisions in these paragraphs about re-use of buildings as an alternative to demolition and advocating sustainable construction methods could usefully be imported into Policy EN2.

Sustainable Design Standards §6.27 The sustainability standards referred to are said to allow some flexibility in meeting the sustainability policy requirements and that assessment is done on a site by site basis. We are very concerned with the use of the word ‘flexibility’ as that can be very widely interpreted and result in not adhering to sustainable standards. Saying you will be flexible in applying standards seems to negate the strength of these standards. Hence, we would advise scrapping this paragraph as it can be subject to abuse.

Climate Change Mitigation We are encouraged by the recognition of climate change impacts and the need to take mitigation measures.

§6.31 - §6.32 should be updated to reflect the new targets set by the government to reach carbon neutrality by 2050 at national and KCC level and by 2030 for TWBC (following the respective Declarations of Climate Emergency).

§6.33 The statement in this paragraph that the planning system has a key role to play in meeting the challenge of reducing CO2 emissions, and must do more needs to be followed up with concrete actions and demonstrable efforts.

§6.34 identifies that emissions associated with energy use and transport are by far the two


largest contributors to CO2 emissions in Tunbridge Wells borough. Please, also see research done by Friends of the Earth that identifies the following for Tunbridge Wells: “In Tunbridge Wells 39% of emissions come from housing, 35% from transport, and 26% are industrial and commercial emissions.”

§6.37 In light of the above research mentioned, we agree that retrofitting the existing building stock presents an opportunity to help meet the carbon reduction targets for the borough.

§6.41 As stated above with §6.18, we disagree that biomass is specifically mentioned as part of a solution to reduce CO2 emissions when in fact it significantly contributes to CO2

emissions. We would therefore like to see the reference to biomass scrapped here. [Please, see document on biomass research attached]. Provisions in this paragraph encouraging combined heat and power and district heating in new developments could usefully be imported into Policy EN5.

Heritage Assets and Conservation Areas§6.52 - §6.54 As we nearly lost 66 mature trees for the now cancelled Calverley Square project and ran the risk of substantial damage to Calverley Grounds, we would like reassurance that the assets listed in this paragraph, such as conservation areas and historic parks and gardens, are properly protected from new development and that ‘wholly exceptional’ development is clearly defined, as we see no justification for development of these sites. Also, we maintain that “Substantial harm to or loss of heritage assets of the highest significance” should not be permitted full stop. Economic development should not be prioritised over environmental conservation. The Draft Local Plan seems to acknowledge this in §6.62.

Conservation Areas §6.62 - §6.64 We support the provisions concerning conservation areas and the need mentioned in §6.64 to prioritise reviews to cover areas of vulnerability or development pressure as stated in §6.62 We would therefore like to see the draft Urban Design Framework SPD reviewed and implemented at the earliest opportunity.

Historic parks and gardens §6.78 We are encouraged by the acknowledgement of the role of historic parks and gardens in maintaining biodiversity and environmental improvement.

Ancient semi-natural woodland and veteran trees §6.80 We support the provision that loss of ancient semi-natural woodland and veteran trees should only occur in wholly exceptional circumstances. The High Weald is characterised by such woodland, which should be strongly protected against development. Therefore, even in the event of projects run by regional and/or national government requiring loss of ASNW and veteran trees, TWBC’s first response and effort should be to object to such development.

Outdoor Lighting and Dark Skies §6.112 - §6.122 We support that most of the borough will be treated as Zone E1 “ intrinsically dark with natural surroundings” to deal with light pollution and protect nocturnal animals.

Natural Environment

Net Gains for Nature: biodiversity §6.123 - §6.128 Whereas we are positive about the commitment to net biodiversity gains for all new developments, we identify serious problems in §6.127.

§6.127 seems to contradict the very commitment to net biodiversity gains and turns it into mere ambition. Giving developers the opportunity to ‘offset’ biodiversity loss ‘off site’ and/or through ‘offsetting schemes’ offers no protection whatsoever to maintaining biodiversity on site, let alone deliver a ‘net gain’. Quoting ‘exceptional circumstances’ gives an excuse not to commit to increasing biodiversity and, besides, it is unclear what ‘exceptional circumstances’ entail. In addition, it is unclear how biodiversity can on balance be improved on a site where


https://takeclimateaction.uk/climate-action/how-climate-friendly-your-area-enter-your-postcode-see-results-your-community

the majority of land is taken out of use as a nature resource for building permanent structures. If this is only by way of bat and bird boxes and other trivial mitigation, there is a strong danger of tick-box tokenism as already sometimes seems to occur in other contexts within the planning system.

§6.131 We strongly support the following statement: “Loss or damage to irreplaceable habitats cannot be offset to achieve a net gain...” However, we would like to see therefore a commitment that this loss or damage will not be permitted.

Biodiversity outside designated sites §6.145 We believe the words “The Council will encourage and promote the positive management of designated sites or habitats as well as their conservation and enhancement.” should be imported into Policy EN12 as its opening words.

Trees, Woodland, Hedges, and Development §6.160 We argue that under no circumstances permission should be given to developments in Ancient Semi-Natural Woodland.

§6.162 We believe the words: “Where development does take place, there will be a presumption in favour of increasing tree cover, with planting specification, species selection, size, diversity, and connectivity being important considerations.” should be incorporated into Policy EN14 as we believe it is of great significance.

Local Green Space §6.172 It would be useful to have specified what ‘special circumstances’ are.

§6.174 We support the application of the provisions to LGS within the Green Belt as this is particularly relevant to designated spaces on the edge of the urban settlement of Royal Tunbridge Wells. We agree it is important for neighbouring residents to identify areas which are important to them for health and recreation.

Areas of Landscape Importance §6.187 We would like to have flood mitigation and air quality included in this paragraph as these are important eco services delivered by trees in urban areas.

Neighbourhood Edges §6.192 We agree it is important to maintain the integrity of villages by protecting trees and shrubs that form natural barriers.

Important Landscape Approaches §6.198 It would be useful to have specified what ‘limited circumstances’ are.

Landscape Policy for the rural areas of the borough and the High Weald Area of Outstanding Natural Beauty (AONB) §6.211 and §6.223 We support the concept of applying rural landscape policy to land inside, adjacent to or in close proximity to the boundary of LBDs where there is a strong relationship to the countryside. This is relevant to Royal Tunbridge Wells where, on a number of boundaries, the town ‘melts’ almost imperceptibly into a semi-rural and then fully rural state and the semi-rural areas are very vulnerable to suburbanisation without adequate development control. For the same reason we support the concept of regarding AONB policies as relevant to adjacent or close land buffers.

§6.219 We strongly support the intention to view the landscape as a resource that will be protected as a whole.

§6.224 We assume that this paragraph implies there will be no major building works allowed within The High Weald AONB given it enjoys the “highest status of protection nationally.”

Agricultural Land


§6.230 Is there more recent documentation available to identify the grade of farmland?

Air, Water, Noise, and Land

Air Quality §6.237 Is there any intention of adhering to stricter, recent WHO limits?

Air Quality Management Areas (AQMA) §6.240 We welcome the statement that even if NO2 levels drop on the A26 AQMA, an Air Quality Protection Zone would be introduced. We believe that such a zone should be considered for a wider network of residential streets which are subject to excessive traffic movements. It is especially important to include roads around schools and where large numbers of children walk to and from school during rush hour.

Biomass Technology: Please, see document on biomass research attached.

We suggest deleting all recommendations and referrals to biomass technology in the Local Draft Plan as a clean renewable energy source based on recent research and increasing reports on the damaging consequences of biomass burning to public health and through increased CO2 emissions.

§6.242 We maintain that if the aim of Policy EN 25 is to improve and maintain good air quality, then biomass technology is the opposite of what the LPA should be promoting.

§6.243 We strongly disagree with biomass burning being presented as low carbon technology. Regardless of what is stated in the NPPF, biomass burning is subject to serious contrary expert opinion and the notices mentioned in §6.245 about the significant dangers to health of residents of wood burning stoves is evidence that the NPPF may be regarded as flawed.

§6.245 The adverse consequences of biomass burning on a small scale should be considered a warning to expanding the scope of biomass burning.

Water §6.247 It may be useful to mention Sustainable drainage systems (SuDS) in this paragraph.

§6.250 Is it merely accepted that at times extra effluent discharged into the environment will not be sufficiently clean? What solutions can be proposed? Or if no solution is possible, development in those specific locations should not be permitted.

§6.260 - §6.261 It appears that despite TWBC being subject to ‘serious water stress’ and admitting this will only be exacerbated by climate change (§6.256), water conservation is not regarded of primary importance. We are very sceptical as to whether the water consumption targets for new developments can be practically enforced against this background.

Development and Flood Risk We would not allow any development in any areas identified as prone to flooding.

§6.264 We disagree any building should take place in flood areas under any circumstances.

§6.266 Partly agree, but we would replace ‘discourage inappropriate’ with ‘reject any’

Sustainable Drainage Systems We welcome to use of SUDs in new developments.§6.275 could be worded more strongly to reflect the intention of the previous paragraphs and not use words such as ‘normally’ if ‘practical’ as this gives too much scope for not using SUDs.

Noise


§6.283 We support the reference to areas of tranquillity which should generally be protected from noise-generating developments.

Land contamination§6.291 We welcome the advice by NPPF on this matter.

Transport Policies §6.506 to §6.540

We support the General Observations made by the Tunbridge Wells Town Forum in their response to the draft local plan

§6.506 - §6.509 We welcome the mention of “focus on sustainable transport” options, yet little is actually said in these paragraphs about truly sustainable travel that can be facilitated by improving and/or creating infrastructure for active travel and by expanding clean public transport options and services. Instead, it seems LPA is resigned to accept increased car traffic and admits that with the current plans for development in rural areas, they will be contributing to this increase. As long as LPA accommodates and prioritises private car use over sustainable transport, we are unlikely to deal with future congestion, air pollution (and its negative health impacts) and effects of climate change. It also does not tally with the Climate Emergency Declaration by TWBC in July 2019. It certainly will not encourage residents to change their mode of transport to more sustainable ones. Sustainable travel should not just be in focus; it should be the main focus.

COMMENTS ON A POLICYBelow are comments on Development Management Policies (Section 6): Environment

COMMENT BOX 2A

Object , Support with conditions and General Observation

COMMENT BOX 2B

Policy Number: EN 1 Design and other development management criteria

In general, we support the criteria and key questions as they seem to provide a good tool to developers seeking planning permission. However, we have the following questions/comments:

1.1 How is it determined that an area will be “demonstrably improved overall” and thus loss of assets mentioned here justified?

2.2 No permission should be granted for new development in areas at risk from flooding.

4.2 We are not clear what constitutes a ‘net gain’ in biodiversity in case of potential harm to existing biodiversity, geodiversity, and blue/green infrastructure of a site. Policy EN 11, which is referred to here, provides much scope for developers who are given the opportunity to ‘compensate’ for loss of biodiversity. This does not safeguard the site itself, nor does it enhance the biodiversity on the site itself. The accompanying key questions again seem to make the ‘net gain’ optional rather than compulsory.

5.1-3 Whereas ‘parking’ is mentioned in all three criteria, cycle infrastructure is not. Key question d. refers to enabling of active travel; therefore, it seems appropriate and desirable that cycle infrastructure is included as part of the design criteria under #5 here.


COMMENT BOX 2A

Object and Support with conditions

COMMENT BOX 2B

Policy Number: EN 2 Sustainable Design and Construction

Given our comments made in section 1 on individual paragraphs, it should be clear that we strongly object to a policy for sustainable design that promotes biomass burning. With regards to §6.18 we again emphasise biomass burning is highly polluting and will contribute to CO2 emissions, which is contradictory to the general objective of truly sustainable development as you set out to achieve in step 5 of this policy. Biomass burning causes significant harm to the environment and should be opposed instead of promoted, and certainly not be presented as on a par with clean, renewable means of generating energy, such as solar, wind or tide. [Please, see document on biomass research attached].

We support the inclusion of a 12-step process for design and all steps are clearly geared towards making sure developers implement sustainable practices from the start. Step 2 could be much stronger though on the provision of links between cycle routes. A joined-up network for cycling seems highly desirable if one expects people to shift to cycling for day-to-day transport.

COMMENT BOX 2A

Support with conditions

COMMENT BOX 2B

Policy Number: EN 3 Sustainable Design Standards

We would like to argue that all new development is done to minimum design standards of HQM 4 stars from 2021 and not make an exception for ‘10-150 residential dwellings’ until 2026. If we want to achieve net zero carbon emissions in Tunbridge Wells Borough (as stated in the Council’s Climate Emergency Declaration) by 2030, we need to set the highest possible standards for all new developments to cope with effects of climate change, reduce their environmental impact and support biodiversity now. Houses must be well insulated and move away from gas to eco heating (such as heat pumps) for example.

COMMENT BOX 2A

Object, Support with conditions


COMMENT BOX 2B

Policy Number: EN 4 Energy Reduction in New Buildings

As TWBC is set to progress towards the zero-carbon target by 2030, is a 10% reduction over the TER (point 1) and 15% reduction from use of renewable energy (point 2) sufficient to achieve this? We are concerned this is not ambitious enough and will be impossible to achieve if biomass technology is permitted as renewable energy generation.

We strongly object to ‘biomass boilers’ being included in the list of recommended renewable energy generating technology, whereas we do support the other technologies mentioned. In addition, we would like to point out that combined air/ground source heat pumps are preferable to mere ground source heat pumps as the latter can negatively impact on the quality of the soil.[Please, see document on biomass research attached].

COMMENT BOX 2A


COMMENT BOX 2B

Policy Number: Policy EN 5 Climate Change Adaptation

The overall policy has our full support with the exception of 5f. Active cooling constitutes a considerable contributing factor to climate change as air conditioners contain “chemical refrigerants that absorb and release heat to enable chilling. Refrigerants [...] have 1,000 to 9,000 times greater capacity to warm the atmosphere than carbon dioxide.” See: Project Drawdown.

COMMENT BOX 2A

Support

COMMENT BOX 2B

Policy Number: EN 6 Historic Environment

Support

COMMENT BOX 2A

Support with conditions, General Observation


https://www.drawdown.org/solutions/materials/refrigerant-management

COMMENT BOX 2B

Policy Number: EN 7 Heritage Assets

We generally support this policy. However, the last paragraph mentions ‘removal’ and ‘replacement’ of heritage assets, which seems to contradict the statement in the preceding §6.54 which states: “heritage assets are an irreplaceable resource that should be conserved or enhanced in a manner appropriate to their significance.”

COMMENT BOX 2A

Support

COMMENT BOX 2B

Policy Number: EN 10 Outdoor Lighting and Dark Skies

Support

COMMENT BOX 2A

Object , Support with conditions

COMMENT BOX 2B

Policy Number: EN 11 Net Gains for Nature: biodiversity

The policy is not clear enough in supporting net gain for biodiversity. Although point 1 states development must result in “measurable long-term net gain for biodiversity” (support) it then negates this in point 2 by indicating one can ‘compensate’ for and “justify all unavoidable impacts on biodiversity” (object).

COMMENT BOX 2A


COMMENT BOX 2B

Policy Number: EN 12 Protection of Designated Sites and Habitats

We do not think any adverse effect on the nature conservation or geological interest of a designated site should be permitted as this defeats the purpose of designating a site as a


(statutory) protected site. However, in adjusted form, we of course welcome the inclusion of a policy that is aimed at protecting designated sites and habitats. As stated in section 1 above referring to §6.145, we believe the words “The Council will encourage and promote the positive management of designated sites or habitats as well as their conservation and enhancement.” should be imported into Policy EN12 as its opening words.

COMMENT BOX 2A


COMMENT BOX 2B

Policy Number: EN 14 Trees, Woodlands, Hedges, and Development

As stated in section 1 above referring to §6.162, we believe the words: “Where development does take place, there will be a presumption in favour of increasing tree cover, with planting specification, species selection, size, diversity, and connectivity being important considerations.” should be incorporated into Policy EN14 as we believe it is of great significance.

In point b. we would like to know how exactly it is determined that ‘desirability’ for development outweighs trees’ value.

COMMENT BOX 2A


COMMENT BOX 2B

Policy Number: EN 15 Ancient Woodland and Veteran Trees

We are satisfied that loss or deterioration of irreplaceable ancient woodland and veteran trees will not normally be allowed but would like the policy to make explicit that TWBC would initially seek to object to any development.

We would like the seven guiding principles to be redefined as ‘criteria to be met’.

COMMENT BOX 2A

Support

COMMENT BOX 2B


Policy Number: EN 16 Green, Grey, and Blue Infrastructure

We strongly support this policy and hope it will lead to an increase of green infrastructure (trees and wildflower verges) also in urban areas.

COMMENT BOX 2A

Support

COMMENT BOX 2B

Policy Number: EN 17 Local Green Space

Support

COMMENT BOX 2A

Support

COMMENT BOX 2B

Policy Number: EN 18 Landscape within the Built Environment

Support

COMMENT BOX 2A

Support

COMMENT BOX 2B

Policy Number: EN 19 Arcadian Areas

Support

COMMENT BOX 2A

Support


COMMENT BOX 2B

Policy Number: EN 20 Rural Landscape

Support

COMMENT BOX 2A


COMMENT BOX 2B

Policy Number: EN 21 High Weald Area of Outstanding Natural Beauty (AONB)

We support the policy in that it seems to offer strong protection to safeguard the AONB from inappropriate development. However, we do not see how ‘major development’ could be done without causing harm to the status of the AONB and it should be made abundantly clear that this would be wholly exceptional. We believe that all proposals should equally comply with the seven stipulations as set out in this policy to protect the AONB.

COMMENT BOX 2A

Support, General Observation

COMMENT BOX 2B

Policy Number: EN 22 Agricultural Land

Is it possible to mention specifically the eco services provided by soils as you set out in §6.227 above (“...soils are considered a finite resource that provide other important ‘ecosystem services’, for example, as a store for carbon and water, as a reservoir of biodiversity and as a buffer against pollution.”)

COMMENT BOX 2A


COMMENT BOX 2B

Policy Number: EN 23 Air Quality


Support but would like to see that peak time emissions are given greater consideration. Too often yearly averages of measurements of air pollution are used to justify not taking more stringent measures. Current measurements include traffic movement at non-peak times such as at night, weekends and holidays. What is therefore allowed in this scenario, for example, is school children walking to and from schools being exposed to illegally high pollution based on those peak time emissions. Hence, the policy as it is does nothing to protect vulnerable people from being exposed to damaging air pollution.

COMMENT BOX 2A


COMMENT BOX 2B

Policy Number: EN 24 Air Quality Management Areas (AQMA)

Following on from our comments on policy EN 23 above, we would like to see many more zones designated as AQMAs with the implementation of (ultra) low emissions zones to reduce traffic, especially at peak times.

COMMENT BOX 2A

Object

COMMENT BOX 2B

Policy Number: EN 25 Biomass Technology

We very strongly object to biomass technology being promoted as a low carbon technology, which it is not. It is wrong to talk about “potential air quality impacts” as it gives the false impression that it is only ‘potential’, whereas in actual fact air pollution will always occur with biomass burning. In addition, it is highly unlikely that biofuel can be locally sourced to provide enough capacity.

Altogether, it is clear that biomass technology cannot be considered ‘sustainable’ in any sense of the word. Emissions from biomass burning negatively impact on people’s health and contribute to increased CO2 emissions, which exacerbates existing problems of climate change. It goes directly against the commitment to reaching carbon neutrality by 2030 as made by TWBC in their Climate Emergency Declaration. [For further details, please see document on biomass research attached].

COMMENT BOX 2A



COMMENT BOX 2B

Policy Number: EN 26 Water Quality, Supply, and Treatment

Given the serious concerns expressed in the preceding paragraphs: “Constraints in existing available technology mean that it will not always be possible to carry out the improvements needed to ensure that the extra effluent discharged into the environment is sufficiently clean.” (§6.250) and “... water bodies were under pressure from agriculture, water industry, and rural land management activities, and many were not achieving ‘good’ status for ecology. Furthermore, the ground water quality was defined as failing in Tunbridge Wells borough.” (§6.252) how will this policy guarantee that (major) new development will not further exacerbate these problems?

It is one of the reasons we would discourage TWBC to comply with the required number of new houses / large developments

COMMENT BOX 2A


COMMENT BOX 2B

Policy Number: EN 27 Conservation of Water Resources

We are concerned that this policy is not strong enough to protect water resources in the borough given that “the supply for much of Kent, and all of Tunbridge Wells borough, was classified as being under ‘Serious Water Stress’ [and] that consumption rates within the borough are higher than both the national and regional averages.” (§6.260).

The policy does not make sufficiently clear how water use will be minimised. For example, it does not require consumers to have water meters installed, which is generally an incentive for consumers to reduce water use.

COMMENT BOX 2A

Object, Support with conditions

COMMENT BOX 2B

Policy Number: EN 28 Flood Risk

We are concerned about how the following sentence is formulated: “... development will only be permitted where it would not be at an unacceptable risk of flooding on the site itself...” (underlining mine). We cannot think of a situation where development is at an acceptable risk of flooding. Therefore, we would suggest removing the word ‘unacceptable’ so that new development will not be built on flood plains.


COMMENT BOX 2A

If you are commenting on a Policy, it would be helpful if you could mark the most appropriate answer.

Support

COMMENT BOX 2B

Please enter your comments in the box below. Please state which Policy you are commenting on.

Policy Number: EN 29 Sustainable Drainage

Support

COMMENT BOX 2A

Support

COMMENT BOX 2B

Policy Number: EN 30 Noise

Support

COMMENT BOX 2A

Support

COMMENT BOX 2B

Policy Number: EN 31 Land Contamination

Support

COMMENTS ON A POLICYBelow are comments on the Development Strategy and Strategic Policies (Section 4)


COMMENT BOX 2A


COMMENT BOX 2B

Policy Number: STR 1 The Development Strategy

We request a new calculation is made of the net “Minimum additional allocations to meet housing need” as set out in §4.12 above, as we have been made aware that these are likely too high an estimate and that when one applies the revised and updated 2016 ONS methodology, only 67% of total new development (i.e. 13,560 indicated in row 1 of table 1, §4.12) is required. This would bring down the net number of houses needed from 7,593 to 3,118.

We object to point 7 as we object to the release of Green Belt land for development. If a recalculation is done of housing needs and brownfield sites are actively located and developed as a priority, one should not need to build in the Green Belt. Even if there is no recalculation, we would still object to new development in the Green Belt.

COMMENT BOX 2A


COMMENT BOX 2B

Policy Number: STR 4 Green Belt

We strongly object to any further new development in the Green Belt. All efforts should be made to safeguard substantial green spaces to help combat climate change, protect wildlife and nature, and enhance physical and mental wellbeing of people. Enhancing instead of reducing the Green Belt would also be in keeping with TWBC’s Climate Emergency Declaration last July.

The NPPF (2019) guidelines follow Government policy on protecting the Green Belt to prevent urban sprawl by keeping land permanently open and it urges LPAs to maximise the use of suitable brownfield sites before considering changes to Green Belt boundaries. It also sets out the conditions that must be fulfilled for justifying ‘exceptional circumstances.’ It is our view that ‘exceptional circumstances’ are not demonstrated by the LPA in the draft Local Plan and that not enough has been done to prioritise future development on previously developed (brownfield) land.

COMMENTS ON A POLICYBelow are comments on the Place Shaping Policies (Section 5)

COMMENT BOX 2A


Object , General Observation

COMMENT BOX 2B

Policy Number: AL/RTW 1

Now that plans have been cancelled for the ‘Civic Complex’ or ‘Calverley Square’ project, this policy needs to be reconsidered.

We object to altering the boundaries, landscape and treescape of Calverley Grounds and would like to see a retraction of the intention to develop the area that is inside Calverley Grounds as shown on your Map 1 Policy AL/RTW 1.

COMMENT BOX 2A

Object

COMMENT BOX 2B

Policy Number: AL/RTW 18

Object to new development in the Green Belt.

COMMENT BOX 2A

Object

COMMENT BOX 2B

Policy Number: AL/SO 3


COMMENT BOX 2A

Object

COMMENT BOX 2B


Policy Number: AL/SO 4


COMMENT BOX 2A

Object

COMMENT BOX 2B

Policy Number: STR/CA 1 The Strategy for Capel Parish

Object to point 9 “Tudeley Village and land at Capel and Paddock Wood will both require the release of Green Belt land.”

General objection to all new development in Green Belt.

COMMENT BOX 2A

Object

COMMENT BOX 2B

Policy Number: AL/CA 1 Tudeley Village

We object to the suggestion in point 6 that “design quality [is] one of the justifications for the release of Green Belt land” as this does not constitute an ‘exceptional circumstance.’

General objection to all new development in Green Belt.

COMMENT BOX 2A

Object

COMMENT BOX 2B

Policy Number: AL/CA 3 Land at Capel and Paddock Wood

General objection to the release of Green Belt land for new development.


COMMENTS ON THE STRATEGIC OBJECTIVES (SECTION 3)

COMMENT BOX 4

Please enter your comments on the Strategic Objectives in the box below.

With respect to the 10 “Strategic Objectives” you set out we like to comment as follows:

Travel:To prioritise active travel, but where necessary to plan appropriately for use by private motor vehicle, in particular embracing new technology.

Increasing support for infrastructure for private vehicle use directly conflicts with your intention to “prioritise” active travel. The easier private car travel is made—whilst simultaneously not creating safe alternatives in the form of segregated, safe cycle paths, linked up in an extensive network of cycle paths—the less likely it is people will choose active travel. Though we have seen instances in the LDP where you say you want to implement active travel—it is by no means treated as a ‘priority’. Quite the opposite: private car use is still best catered for.

Green Belt:To strategically release appropriate land from the Green Belt through a plan-led approach, and to increase public accessibility, and to protect the openness of remaining Green Belt land.

We strongly object to releasing land for the Green Belt for new housing development.We also feel it contradicts your following other two objectives:

The borough's distinctive environment:To protect the valued heritage, and built and natural environments of the borough, including the AONB and to achieve net gains for nature.

Climate ChangeTo tackle climate change and minimise the impact of development on communities, the economy and the environment with carefully considered design and by embracing technology such as renewable energy generation.

You cannot tackle climate change by reducing green land. We also want to emphasise again (as we have in our comments on the LDP) that Biomass technology does not provide clean renewable energy generation and all recommendations for biomass burning should be scrapped from the LDP.


END OF COMMENT BOXES

We have also made comments on the Draft Sustainability Appraisal, please see the separate Sustainability Appraisal comment form


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