Proposed Submission Development and Site Allocations (DaSA) Local Plan

I am unable to get access (coming up as a restricted access alert) to your online submission form for submission by email to make a representation by letter on behalf of Tunbridge Wells Borough Council in respect of the above consultation.

TWBC does not wish to make comments on individual sections of the DaSA Local Plan or policies, so the other option of an online submission through the portal is not applicable.

I would be grateful if you could acknowledge that you will accept the attached letter as a representation.

Many thanks and best wishes

(letter included in attachments)



Rother District Council Development and Site Allocations Local Plan Regulation 19 Pre-Submission Publication Consultation

I refer to your communications dated 26 October 2018, in respect of the current Regulation 19 Consultation for the Rother District Council (RDC) Development and Site Allocations (DaSA) Local Plan. Thank you for the opportunity comment.

DaSA Local Plan

The headline needs of 7274 homes (Core Strategy 2014 and updated 2018 residual requirement combined) and 10 hectares of employment land are noted.

The constraints of Rother district at 82% AONB, a number of nature conservation areas, as well as flood risk issues are also recognised.

It is noted that most of the proposed economic and housing growth in the DaSA Local Plan is directed towards the southern parts of the district in Bexhill, Rye, Battle and the outskirts of Hastings, and so is less connected to Tunbridge Wells borough geographically.

Also, it is noted that the DaSA does not include housing allocations in designated Neighbourhood Plan Areas. Tunbridge Wells Borough Council (TWBC) is currently reviewing the Neighbourhood Plan for the Parish of Ticehurst, which is located in close proximity to the southern boundary of Tunbridge Wells borough, under a separate Regulation 16 consultation.

Overall, based on the strategy presented in the consultation document and most particularly RDC's identified housing and employment development needs, as well as the suggested location and distribution of development, it is considered there would be no overall significant or direct effect on the area comprising Tunbridge Wells borough.

Duty to Cooperate

RDC and TWBC have previously engaged in joint discussion relating to cross boundary issues such as housing, employment, transport, infrastructure, water resource and supply (Bewl Water), landscape, AONB, the Ashdown Forest and other needs under the Duty to Cooperate (DtC).

One issue that has formed part of these discussions relates to the A21/A268 crossroads at Flimwell. It is known that HGVs currently have problems turning left from Hawkhurst onto the A21 at the crossroads, causing serious detriment to highway safety. TWBC considers that highway improvements are required to rectify this problem. Given this and the fact that there may possibly be further development at Hawkhurst, as indicated by a current submission which TWBC is considering for an Environmental Impact Assessment Scoping Opinion (18/03008/EIASCO) for residential led development of around 400 dwellings including a relief road and associated infrastructure on the site of Hawkhurst Golf Club (High Street at Hawkhurst); this warrants further the need for highway improvements at the crossroads. TWBC would welcome further discussion with RDC on this matter.

It is recognised that the main urban area of Royal Tunbridge Wells (RTW) acts as a service centre for parts of the rural north of Rother District where residents are likely to travel to RTW for work, medical needs (including the hospital at Pembury), shopping and leisure. As agreed in previous DtC discussions, TWBC will keep Rother informed in future engagement of any developments or changes which may affect the provision of such services. It is also known that Rother residents use other facilities, such as medical facilities and educational facilities in nearby settlements such as Hawkhurst and Sandhurst located in close proximity to the southern borough boundary of Tunbridge Wells. It is anticipated that where the expansion or new provision of such facilities is required, financial contributions may be sought from development within Rother district towards the funding of such provision.

It is noted that the Rother DaSA Local Plan document does not make any reference to the DtC or the possibility of RDC asking for assistance to meet any unmet needs (housing/economic) from an adjoining authority area or vice versa. We can confirm that TWBC would be happy to continue regular liaison and DtC meetings with RDC as the RDC DaSA Local Plan progresses to examination, and in relation to the progression of the new TWBC Local Plan, and allocations within this - please see below. However, without prejudging the outcome of the TWBC local plan work there should be no presumption that there is capacity within the borough of Tunbridge Wells to accommodate unmet development needs from another authority area. We would ask that account is taken of this when considering the representations made to the Regulation 19 consultation.

As you will be aware from previous engagement and DtC meetings, TWBC is also undertaking preparation of a new Local Plan, which is intended to have a plan period of 2013-2033. Having completed the Issues and Options consultation process last year, TWBC is currently preparing the Draft Local Plan document ready for consultation (Regulation 18) next year and will formally consult RDC when the plan progresses to this stage.

We hope this information and response is of assistance and clarifies TWBC's position.