Tunbridge Wells Local Plan 2033: Issues & Options consultation

Strategic Planning, Sustainability and Transportation Committee

13 June 2017

Is the final decision on the recommendations in this report to be made at this meeting?



Tunbridge Wells Borough Local Plan: Issues & Options consultation


Final Decision-Maker

Strategic Planning, Sustainability and Transportation Committee

Lead Head of Service

Rob Jarman, Head of Planning and Development

Lead Officer and Report Author

Sarah Anderton, Principal Planning Officer (Spatial Policy)



Wards affected




This report makes the following recommendations to this Committee:

1.   That the Committee approves the response to Tunbridge Wells Borough Local Plan Issues and Options consultation set out in Appendix A.




This report relates to the following corporate priorities:

·         Keeping Maidstone Borough an attractive place for all

·         Securing a successful economy for Maidstone Borough


This report has regard to strategic proposals of an adjoining authority which could have infrastructure, environmental and development implications for this borough.







Strategic Planning, Sustainability and Transportation Committee.

13 June 2017

Tunbridge Wells Borough Local Plan: Issues & Options consultation





1.1     Tunbridge Wells Borough Council (TWBC) is preparing a new, comprehensive Local Plan to cover the period 2013-2033. The Plan, once adopted, will replace the saved policies in the 2006 Tunbridge Wells Borough Local Plan, the 2011 Core Strategy and the 2016 Site Allocations Local Plan.


1.2     The plan is at a relatively early stage in the preparation process. As a first stage of consultation (Regulation 18), TWBC has published an Issues & Options consultation document and associated Interim Sustainability Appraisal.  It is undertaking a second ‘call for sites’ exercise at the same time and TWBC is also consulting on a draft landscape Character Assessment Supplementary Planning Document (SPD).


1.3     As Tunbridge Wells is a neighbouring authority and the content of its Local Plan could have implications for this borough, it is recommended that this Council register a formal response to the consultation. The response set out in Appendix A has already been submitted to TWBC as an officer-level response to meet the consultation deadline of Monday 12th June.  It has been agreed with TWBC officers that they will be sent the resolution of this Committee to confirm any additional or amended comments that the Committee requires to be made.





2.1     The Issues & Option document is attached in Appendix B.  The document provides an overview of the key issues which will impact on the content of the new Local Plan and invites comments on the issues identified. This aspect of the document is relatively ‘high level’ and focuses on identifying relevant issues rather than proposing potential policy approaches at this stage. The document also sets out 5 potential strategic options for how development could be distributed across the borough.


2.2     Tunbridge Wells’ Strategic Housing Market Assessment identifies a need for some 648 new homes/year in the borough over the 20 year plan period, equating to a total of 12,960 dwellings (2013-33).  Over the same period there is an evidenced need for 11-15ha of additional employment land.


2.3     The Issues & Options consultation document states that “the Council [TWBC] may face significant challenges in seeking to provide for the borough's relevant level of development need in the light of very significant landscape, environmental and infrastructure constraints”.  The document goes on to identify such potential constraints as including infrastructure capacity, highway capacity and congestion, landscape sensitivity (70% of the borough is in the High Weald AONB), flooding and the nature of the existing built environment.  The borough also has 22% Green Belt coverage.


2.4     Councillors may recall that in his December 2016 Interim Findings, the Maidstone Local Plan Inspector made reference to the constrained nature of Sevenoaks and Tunbridge Wells Boroughs.  He observed that if these areas do not plan to meet their own needs, there could be additional development pressure on boroughs such as Maidstone.  He concluded  “whilst it is not impossible that increased migration from West Kent or London would place pressure on areas such as Maidstone with transport links to those areas, this is a matter which would be best considered at the first Review of the Local Plan when policy provisions for London and west Kent will be clearer” (paragraph 23).


2.5     In this context it is important that officers closely appraise the progress of the Tunbridge Wells Local Plan, consider any implications for this borough and provide relevant input to TWBC at key stages. Particular attention will be paid to the evidence and approach which TWBC follows in determining the overall development capacity of the borough, recognising that much important evidence that will inform the content of the Plan is yet to be completed. At this stage, it is prudent for this Council’s response to highlight matters which this Council considers are likely to be particularly pertinent.


2.6     The response letter in Appendix A highlights that the extent to which TWBC acts to try to overcome identified constraints (consistent with the NPPF) is likely to be an important factor in them achieving a sound Local Plan. A pro-active and iterative approach which explicitly tries to address constraints is likely to be strongly linked to TWBC being able to demonstrate that the Local Plan has been positively prepared. 


2.7     Also, the response letter notes that Tunbridge Wells borough shares a housing market area with Tonbridge & Malling, Sevenoaks, Rother and Wealden districts and not with Maidstone.  Similarly, its economic links are strongest with Sevenoaks and Tonbridge & Malling boroughs. On first inspection these authorities would be the priority locations should TWBC be unable to accommodate it development needs in full.


2.8     Should there be any future request from TWBC, or any other authority, to this authority to accommodate any unmet needs, this must be considered seriously and objectively.  The assessment of the request will need to draw on evidence (MBC’s and the other authority’s) and take account of the current planning position in this borough.


2.9     The response in Appendix A also makes specific points regarding the proposed wording of the Plan’s Vision and Strategic Objectives and the need for Gypsy and Traveller needs to be accommodated through the Plan.  The consultation document lists ‘transport connections to Maidstone’ as a specific cross-boundary issue.  In the response it is noted that the rail connection between the boroughs’ two principal towns is indirect and it is as yet unclear what TWBC may be envisaging by the reference to transport connections to Maidstone. Clarification on this matter will be sought as part of the on-going dialogue between the authorities.  


2.10 Strategic options: The consultation document identifies 5 possible scenarios for how development could be distributed across the borough.  The options are;


1.   Focused growth: majority of development at Tunbridge Wells/Southborough with lesser growth at Paddock Wood, Cranbrook, Hawkhurst and limited development in the villages/rural areas

2.   Semi-dispersed growth: as option 1 with a higher percentage of growth at the some of the larger villages

3.   Dispersed growth: proportional growth across all the borough’s settlements

4.   Growth corridor: growth around A21 close to Tunbridge Wells and Pembury

5.   New settlement: new garden village at a yet to be determined location


2.11 These scenarios are put forward before the completion of TWBC’s assessment of the development capacity of the borough or the completion of its Strategic Housing Land Availability Assessment (SHLAA).  It is recommended that MBC does not express a preference for a particular strategy at this early stage, pending the completion of more detailed work by TWBC by which any implications for Maidstone borough can be more clearly ascertained.


Draft Landscape Character Assessment Supplementary Planning Document (SPD)


2.12 This draft document comprises as Landscape Character Assessment which TWBC is proposing to approve as SPD. Section 7 of the document identifies that landscape character does not stop at administrative boundaries and that the assessment aims to join up with the equivalent studies in neighbouring areas. The response from MBC in Appendix A highlights that for Maidstone borough it is the Maidstone Landscape Character Assessment completed in March 2012 to which the assessment’s authors should have regard.





3.1     There are two options available to the Committee.  The first is that the Committee decides to submit a response to the Tunbridge Wells Borough Local Plan consultation.  The second, alternative option is that the officer response which has been sent is withdrawn


3.2     Electing to submit a response will ensure that MBC’s position and interests are brought to the attention of TWBC at an early stage in the Plan’s preparation.  To not make such a submission would be a missed opportunity for MBC to engage positively with the preparation of a neighbouring authority’s primary land use planning document.





4.1     It is recommended that the Committee agrees a response to this first consultation on the new Tunbridge Wells Borough Local Plan for the reasons outlined elsewhere in this report.





5.1     The timetable for the preparation of the Tunbridge Wells Borough Local Plan is as follows;


Regulation 19 consultation       2017-18

Submission                               2018

Examination                             2018

Adoption                                   2019


5.2     Officers will use for further engagement opportunities, both formal and informal,  with Tunbridge Wells Borough Council as its Local Plan evolves to ensure that MBC’s position is clearly communicated.  The Committee will be kept updated as TWBC’s proposals develop and more details emerge.








Impact on Corporate Priorities

This report has regard to strategic proposals of an adjoining authority which could have infrastructure, environmental and development implications for this borough.

Rob Jarman, Head of Planning & Development

Risk Management

The Council is managing potential risks by actively engaging with TWBC in the preparation of its Local Plan at an early stage. 

Rob Jarman, Head of Planning & Development


The financial costs of contributing to the development of TWBC’s Local Plan can be accommodated within existing service budgets.

[Section 151 Officer &] Finance Team


There are no specific staffing implications arising from this report.

Rob Jarman, Head of Planning & Development


There is a statutory duty to cooperate on cross-boundary planning matters relating to adjoining authorities which might affect both (or more) authorities. By providing an accurate and informed response to the consultation, MBC are, prima facie, acting in compliance with its statutory duty in relation to this consultation stage.

[MKLS Planning Team]

Equality Impact Needs Assessment

The consultation proposals are not detailed enough to raise any specific concerns.

[Equalities and Corporate Policy Officer]

Environmental/Sustainable Development

The preparation of Local Plans, whether it be this Council’s Local Plan or another authority’s Local Plan, is fundamentally concerned with delivering sustainable development.

Rob Jarman, Head of Planning & Development

Community Safety

No implications

Rob Jarman, Head of Planning & Development

Human Rights Act

The consultation proposals are not detailed enough to raise any specific concerns.

Rob Jarman, Head of Planning & Development


No implications.

Rob Jarman, Head of Planning & Development [& Mark Green, Section 151 Officer]

Asset Management

No implications

Rob Jarman, Head of Planning & Development




The following documents are to be published with this report and form part of the report:

·         Appendix A: MBC response to Tunbridge Wells Local Plan (2013-33) Issues & Options consultation

·         Appendix B: Tunbridge Wells Local Plan (2013-33) Issues & Options consultation





There are none.