CHAPTER 10: COMMUNITY SERVICES - Residents · hospital not an upgrading; the retention and expansion of the existing Kent and Sussex Hospital; the provision of a new hospital on a

Tunbridge Wells Borough Local Plan Review

Inspector’s Report 2005 341

CHAPTER 10: COMMUNITY SERVICES

Paras 10.1 - 10.6 Introduction Community Services Chapter

D1/418/27/1 KCC Directors of Education and PropertyD1/446/1/1 HM Prison Service

Main Points Raised by Objectors

10.1 The list of community services in para 10.5 should beexpanded to include “Adult Education”, “Youth Services” and“Social Services” which are community services that usecommunity buildings and facilities. KCC seeks developmentcontributions for the expansion of this range of services tomeet increased demand as housing is built. The Plan shouldcontain a policy allocating or allowing for identification of a sitefor a new prison.

Inspector’s Considerations and Conclusions

10.2 KCC has not identified any specific need for additional provisionfor adult education, youth services and social services, orsought any allocation or criteria-based policy relating to theseservices in the Plan. Whilst it may be correct that theseservices use community buildings and facilities, as no provisionis made for the needs of these services in the remainder of theChapter, I consider that a reference to them here isunnecessary.

10.3 Available information relating to population forecasts indicatesthat the provision made for new housing development in thePlan is likely to have relatively little impact on overallpopulation numbers. For this reason it appears unlikely thatthe new development provided for in the Second Deposit Copywould lead to any significant increased demand for the serviceslisted by the objector during the Plan period, or would warrantany developer contributions towards the costs of thoseservices. I have dealt with an objection seeking a generalpolicy relating to development contributions in Chapter 2.

10.4 Circular 3/98 (CD 2.35) advises that the ongoing programme ofprison development is a matter of national importance, andthat wherever possible sites for new prisons should beidentified as part of the process by which development plansare adopted. It is clear that there is an immediate problem ofprison overcrowding and a need to identify sites for newprisons now. The Prison Service has identified the West Kentarea, including the Plan area, as a priority area of search for anew prison to meet the pressing need for additional places.However, no specific site has been put forward forconsideration through the local plan review process, and it isnot therefore possible to consider allocating a site in this Plan.

10.5 There is no evidence that, in identifying the Borough as apriority area of search for a new prison, a detailedconsideration of the Borough’s characteristics has been carried


Inspector’s Report 2005342

out, or that due account has been taken of the significantpolicy and environmental constraints that exist in the area. Italso seems to me that it would be difficult to identify a site inthe Plan area meeting the size and other search criteriaidentified in Circular 3/98, although I appreciate that nothorough search has been carried out. Despite the economicbenefits for the local area from a prison development, Iconsider that any locational advantages of the area may havebeen overplayed somewhat, given the significant congestionexperienced in the some areas of the Borough and the lack ofinter-connection between roads in others.

10.6 However, if a proposal for a prison were to come forward infuture, other criteria-based policies in the Plan would providethe context within which to assess the proposal. Circular 3/98also provides advice as to site selection, and notes thepossibility of sites coming forward outside the timetable forlocal plan review. In such circumstances it notes thatproposals may need to be treated as a departure from thecurrent Plan. I therefore consider that there is an adequatepolicy framework for considering any future prison proposals,and that a criteria-based policy would be unnecessary. But asthe Prison Service is in urgent need of suitable sites in the areaincluding the Plan area, the Council should re-examine thismatter in consultation with the Prison Service when it ispreparing its spatial planning strategy.

RECOMMENDATIONS

10.7 I recommend that no modifications be made. I alsorecommend that, in preparing its DPDs, the Council investigatein consultation with the Prison Service whether there might beany suitable site for a prison in the Plan area.

Para 10.10 Hospital provision

D1/3/1/10 PPP Healthcare

Main Points Raised by Objector

10.8 The crèche planned at the new hospital should be enlarged toaccommodate the children of other workers.


10.9 Whilst a crèche may well be an acceptable form of ancillarydevelopment at the hospital site, it would not be appropriatefor this Plan either to require such a facility or to dictate its sizeor those who might be permitted to use it.

RECOMMENDATIONS

10.10 I recommend that no modifications be made.

Policy CS1 Allocation for New District General Hospital

D1/234/37/1 Southborough Town Council



D1/361/1/1 KibblewhiteD1/395/1/3 MacyD1/460/2/2 Maidstone & Tunbridge Wells NHS TrustD1/494/1/16 Cranbrook Business AssociationD1/523/1/2 SlackD1/943/1/7 Norman MPD1/954/1/10 LohmannD1/958/8/17 Kilmartin Properties (TW) LtdD1/1029/5/1 Southern Water


10.11 Objections to the principle of the policy seek a purpose builthospital not an upgrading; the retention and expansion of theexisting Kent and Sussex Hospital; the provision of a newhospital on a site outside the Plan area at Tonbridge; theoption of a site at Knights Park. One objection seeks thedeletion of the policy in its present form and its replacementwith a criteria-based policy that allows for consideration ofalternative sites.

10.12 Objections to the detail of the policy seek good and affordablepublic transport provision throughout the week; affordableaccommodation on the site to address staff shortages; areference to the proposed Acute Mental Health Unit; anextension of the allocated site; and the provision of adequateadditional sewerage and wastewater treatment capacity.


10.13 Outline planning permission has now been granted for theredevelopment of this site for a new hospital (CD 1.75), andthat grant of planning permission was upheld by the High Courtin December 2003 (CD 1.78). This will be a completeredevelopment with new purpose-built facilities, rather than anextension of the existing hospital. The approved schemeincludes associated staff accommodation. Information beforethe Inquiry indicates that the Maidstone & Tunbridge Wells NHSTrust is moving forward to procure the new hospital on theallocated site through the Private Finance Initiative (PFI).Therefore, objections to the allocation of this site to provide anew District Hospital have largely been overtaken by events.

10.14 There is no clear evidence to indicate that the Pembury sitewould not be suitable for the new hospital, or that investigationas part of the PFI procurement process would lead to areconsideration of its suitability. There is therefore nojustification for replacing policy CS1 with a criteria-basedpolicy, which in any event would fail to give sufficient certaintyas to the location of this major land use. The First Secretary ofState has dismissed an appeal against non-determination ofproposals for a new hospital at Knights Park, one of thealternative suggested sites (CD 1.77), and it appears that theKent and Sussex Hospital site and the site at Tonbridge are toosmall. The Tonbridge site also has significant policyconstraints.



10.15 The question of the extent of the site appears to have beenresolved through the granting of planning permission, andthere is no need to alter the boundary of the allocation. Thereasoned justification already refers to the provision of acutepsychiatric services and nurses’ accommodation, and I do notrecommend any alteration to the policy in this regard. Thequestion of accessibility by public transport has been addressedas part of the development control process. The disposal offoul and surface water is a detailed development controlmatter, and is addressed by conditions attached to theplanning permission.

RECOMMENDATIONS


Para 10.19 Education Aims

D1/418/28/1 KCC Directors of Education and Property


10.17 After paragraph 10.19, in Aim 1 replace "increasing numbers"with "projected numbers". Aim 5 should also refer to theprovision of safe setting down/pick up facilities for car bornejourneys.


10.18 The Council has proposed a further change to Aim 1 (FPA 16)to meet the first part of this objection. In view of the forecastnumbers of primary school children, I agree that this changewould represent the position more accurately.

10.19 Policy CS4 of the TWBLP requires proposals for schools andextensions to schools to provide areas for the safe settingdown and collection of pupils off the highway. However thishas not been carried forward into the Local Plan Review as theCouncil's Transport Strategy (CD 1.44.1) seeks to encouragenon-car based transport as a means of travel to school. Underpolicy TP1 of the TWBLPR, proposals for new or significantlyexpanded schools would be required to provide transportassessments and travel plans under which these matters wouldbe addressed. It would be contrary to the strategy the Councilis seeking to pursue to make a specific reference to theprovision of safe setting down areas here.

RECOMMENDATIONS

10.20 I recommend that Aim 1 after paragraph 10.19 be modified inaccordance with FPA 16.

Para 10.20 Pre school education





10.21 The paragraph should be amended to reflect KCC's policy toprovide school places for 4-year olds.


10.22 The Council proposes a change to this paragraph (FPA 20) tomeet this objection. I support the change, as it moreaccurately represents the KCC policy in this matter.

RECOMMENDATIONS

10.23 I recommend that paragraph 10.20 be modified in accordancewith FPA 20.

Paras 10.21 - 10.27 Primary Schools

D1/418/30/1, /31/1, /32/1, FPA/418/1/3 KCC Directors ofEducation and Property


10.24 Amendments are sought to paragraph 10.21 to indicate thatthe primary schools referred to are at rather than serving therelevant areas. Paragraph 10.23 should be changed to notethat the need for new schools in the Borough will be largelydependent on needs arising from new housing development, aswell as the availability of funds. The reference in paragraph10.26 to St Paul's Church of England Infant School and StPaul's Church of England (Voluntary Aided) Junior School atRusthall should be removed, as planning permission would notbe needed for playing field use and the site is not allocated inthe Plan. FPA 17 would not meet the objection relating toRusthall.


10.25 Given that pupils at the schools referred to in paragraph 10.21may not all come from the specified villages, I consider thatthe amendment sought by the objector, in making reference tothe geographical location of the schools rather than theirfunction, represents the position more accurately and neutrally.I therefore support it.

10.26 The question of what gives rise to the need for new schools isaddressed in paragraph 10.22. Paragraph 10.23 seems to meto be explaining why it is prudent to safeguard land for schoolsites, and is not addressing the question of need. Theamendment to this paragraph sought by the objector would beconfusing in linking need with funding, would not add anythingsignificant to the preceding paragraph and would be out ofcontext. I do not therefore support it.

10.27 Paragraph 10.26 of the Plan explains the reasons for allocatingnew sites for a number of primary schools in the district. Thereis no allocation of a site at Rusthall in the Plan, and thereference to the two schools here is therefore inappropriate.



Furthermore, the reference in the plan to a playing fieldextension on land adjacent to Middlefield is confusing as thereare two distinct parcels of land lying to the south of Edward Stand Middlefield, and the parcel adjoining Middlefield is alreadyused as a school playing field. As it stands, it is not clearexactly how much land is being referred to.

10.28 There is no playing field available to either school within theirexisting sites. The requirement for the provision of a playingfield for schools for children aged eight and over is thereforenot being met. Both the parcel of land lying betweenMiddlefield and Rusthall Elms and the parcel adjoining it to thesouth of Edward St would be conveniently sited to remedy this.

10.29 Although the schools lie close to Rusthall Common, that isclearly not suitable for the provision of formal playing fields,even if any part of it were available. In view of the apparentabsence of other convenient sites that could be used by theschools, the Council's concern that this land should not bedeveloped other than for playing field use is understandable,particularly as there appears to be developer interest in them.

10.30 However, the Council has acknowledged that the absence ofany reference to the land in the reasoned justification wouldnot alter the way it dealt with any application to develop eitherparcel. Under these circumstances, I am not satisfied that it isnecessary to make any reference to them at all.

10.31 The Council has proposed a change to paragraph 10.26 (FPA17) to advise on how any development proposal for theseareas would be considered. However, as there is no need forany reference to them in the Plan I do not recommend that FPA17 is adopted.

RECOMMENDATIONS

10.32 I recommend that paragraph 10.21 be modified so that thesecond sentence reads as follows: There is at least oneprimary school serving each of the Parishes in the Planarea with three in Cranbrook Parish (at Cranbrook,Sissinghurst and Colliers Green), and two in SpeldhurstParish (at Speldhurst and Langton Green).

10.33 I also recommend that para 10.26 be modified by the deletionof the second bullet point.

Policy CS2 Allocations for New Primary School Provision

D1/394/1/1 WeaverD1/1034/1/17 Sandhurst Parish Council


10.34 St Barnabas’ school needs a new site and St Matthews’ schoolmay not be able to cope with any additional pupils; secondaryschool places are also limited. Sandhurst’s need for a newprimary school should be addressed in the Plan. A site is



suggested to the south of land designated for the new villagehall.


10.35 There is no indication from KCC of any need for a new site forSt Barnabas’ school, or to cater for additional spaces at StMatthews’ school, that would warrant an allocation of land inthe Plan. Nor has any need for additional secondary schoolplaces been identified that would require additional land. Inthese circumstances, I see no need for any modification to thePlan in these respects.

10.36 Similarly, according to the information available to me thereappears to have been no indication from KCC of any need for anew school at Sandhurst that would warrant an allocation of asite in the Plan. As no significant new housing is proposed inSandhurst, the provision of a school larger than the existingschool roll, as originally proposed in objection D1/1034/1/17,would be likely to attract pupils from further afield, thusincreasing the need to travel by private car. In the light of theinformation before me, I do not support an allocation of aschool site in Sandhurst.

RECOMMENDATIONS


Policy CS2 (1) Land at Hawkenbury Farm, South ofHawkenbury Road, Royal Tunbridge Wells

Please see Appendix 10.1


10.38 The removal of the allocation is sought on the grounds thatthere is no need for a school site here if the policy H8 housingallocation is deleted. The school would be a replacement, notan additional school. The site is unsuitable and better sites areavailable elsewhere. There are also objections to the relocationof St Peter’s Church of England Primary School to this site.Should the Hawkenbury housing proposal be resurrected, KCCwould have to consider how it could fulfil its statutory duty toprovide school places, and would seek support from the Councilshould it be necessary to consider relocating St Peter’s School.


10.39 The Council has proposed a number of pre-inquiry changes tothe Second Deposit Copy, one of which (PPC/10/2) wouldremove the allocation in policy CS2(1). The changes areconsequential on the proposed changes relating to Policy H8,which are dealt with in the Housing Chapter of this report. Ihave recommended in Chapter 6 of this report that policy H8should be deleted, and as a consequence I also support theremoval of this allocation. However, I have also indicated that



it would be appropriate to consider the Hawkenbury Farm sitealong with others in the event that additional greenfield land isrequired for housing in the future. Because of this, I shallconsider here the main points raised concerning the suitabilityof this site for a school.

10.40 Policy CS2(1) was intended to cater partly for the anticipatedneed to relocate the existing St Peter’s School. Both KCC andthe Governors of St Peter’s School originally supported theproposal to move the school to the policy CS2(1) site. But KCCand the Governors have now changed their views, and KCC isnot at present seeking to relocate St. Peter’s or to identify anyalternative site for the school in this Plan. There is likely to besome demand for additional school places arising from thePlan’s housing provisions regardless of the deletion of theHawkenbury Farm allocation, as this will not affect the totalnumber of new dwellings sought by the Plan. However, KCC isnot asking for this allocation to be retained, and as there areno other firm proposals for the relocation of St. Peter’s Schoolit would not be appropriate to make any provision for that inthe Plan.

10.41 I now turn to the detailed objections to the suitability of thissite for a school. The proposed site would be well located toserve the existing urban area as well as the Hawkenbury Farmsite, and to encourage walking to school. A Travel Plan to berequired under policy TP1 would allow the Council to encouragenon-private car means of getting to school, thus seeking toaddress any highway or parking issues arising from school runtraffic. Forest Road is no longer proposed as a designated“southern access route” and despite the amount of traffic usingit I see no greater difficulty for children having to cross theroad to access the school than exists at present for childrengoing in the other direction.

10.42 The site’s location close to the Hawkenbury Recreation Ground,which has additional land allocated in the Plan for its extension,would be an advantage as it would permit dual use of facilities.I see no reason why noise from activities at the recreationground should be overly intrusive for the school, particularly ifthe closest part of the school grounds to the Recreation Groundwas the school playing field. The need for children to crossHawkenbury Road to reach the recreation ground could beaddressed through the provision of appropriate crossingfacilities.

10.43 Locating the school buildings on the lower part of the site couldmitigate the visual impact of development on the site in distantviews. However, other policies of the Plan would controldetailed matters such as external appearance, access andlayout. School buildings can be attractive and although clearlythere would be a change in the appearance of the area I amnot satisfied that a well-designed building on this site would bevisually harmful.



10.44 The investigation into ground conditions commissioned by theCouncil does not appear to identify any unusual contaminationproblems that could not be addressed through appropriateremediation. Nor is there any evidence that covered cesspitson part of the site would represent an insurmountable obstacleto development. There is also no evidence to support thesuggestion that building costs here, either because ofremediation or for other site-specific reasons, would beprohibitive. That part of the site currently in use as allotmentsis classified by DEFRA as urban land, and the land to the southis classified as agricultural land of moderate quality, so thedevelopment of this land would not lead to the loss of asignificant amount of high grade agricultural land.

10.45 If development in this area went ahead, then it is likely thatthere would be some loss of trees or hedgerows. But in myview an adequately-sized school building with associatedfacilities and playing field could be provided on the site whilstretaining significant landscape features, as required by otherpolicies in the Plan. I do not regard the east-west orientationthat might be necessary for the school’s pitch as an overridingobjection to the allocation, given the possibility of dual use bythe school of existing and proposed recreational facilities atHawkenbury Recreation Ground.

10.46 There is no statutory minimum size for primary schools.Government advice suggests around 1.6 - 2.1 hectares for atwo-form entry primary school, but the advice also indicatesthat these figures can be variable. The area allocated is 1.5hectares, and with efficient use of land even a two-form entryschool could be accommodated here. KCC has not objected tothe size of the site.

10.47 My conclusion, on the basis of the information before me, isthat the site shown in the Second Deposit Draft would be anappropriate location for a school if land at Hawkenbury Farmwere to be allocated for housing in the future. It has beensuggested that better sites are available elsewhere, but theonly other sites referred to the Inquiry would be unsuitable asthey are either within the Green Belt or form part of land usedor identified for recreation.

10.48 Some objections have made reference to the need forsecondary school places in the area. This is an issue for KCC,which has not sought an allocation of land in the Plan for a newschool. However, paragraph 10.28 of the Plan acknowledgesthe possibility of expansion of existing schools and policy CS4requires developers to contribute towards the cost of anysecondary school places required as a result of theirdevelopment. I do not recommend any additional provision inthe Plan in this respect.



RECOMMENDATIONS

10.49 I recommend that paragraph 10.26 of the Plan be modified inaccordance with PPC/10/1, and policy CS2(1) be deleted andthe proposals map amended in accordance with PPC/10/2.

Policy CS2 (2) Land at The Ridgewaye, SouthboroughDELETED FROM 2ND DEPOSIT

D1/111/2/1 LuetchfordD1/141/1/2 ClarkeD1/154/2/1 De La BedoyereD1/155/1/1 FlanaganD1/234/26/1 Southborough Town CouncilD1/256/1/2 AdamsD1/418/33/1 KCC Directors of Education and PropertyD1/441/1/1 DevonshireD1/502/1/3 HendersonD1/533/1/3 CooperD1/647/1/1 BuckwellD1/658/8/1 Southborough SocietyD1/861/2/1 HancockD1/879/1/2 ClarkeD1/880/1/2 KnowlesD1/891/2/1 WillsD1/943/1/4 Norman MPD1/1010/1/1 Ridgewaye Sweepers Junior Football Club


10.50 Objections to the principle of the allocation centre around theloss of open space, recreation and allotment land, the effects ofadditional traffic and the suitability of a location next to asupermarket and car park. The need for a new school and theloss of other school sites in the area to housing developmentare also questioned. There are concerns that the new schoolwould have a less mixed intake than existing schools, andwould give rise to unacceptable noise levels. There are alsoobjections to the possible loss of trees and to the proposedaccess onto Yew Tree Road. A general, less specific allocationis sought to retain flexibility. A more efficiently shaped site isalso proposed.


10.51 In the Second Deposit Copy this policy has been deleted andreplaced with policy CR7, which allocates a site for a mixed-usedevelopment including a new primary school in the centre ofSouthborough. I deal with objections to the principle of themixed-use allocation and the supermarket proposal and to theprinciple of developing on open space land in Chapter 5 of thisreport. The allocation in the Second Deposit Copy of anunspecified site within the larger allocation meets thoseobjections seeking flexibility and related to the shape of thesite. I deal here with the remaining objections raised at FirstDeposit stage.



10.52 According to KCC it is essential that additional primary schoolcapacity be provided in Southborough, which at present has asignificant shortfall of school places. No other suitably locatedsites have been identified, and according to the Council theextension of existing schools is not a feasible alternative. Inmy view the pressing need for this facility justifies the use ofpart of a greenfield site at present in a variety of outdoorrecreation uses. I support the Council’s desire to make themost efficient use of the allocated site, whilst preserving theopenness of much of the land outside the school buildings.Other policies in the Recreation Chapter of the Local PlanReview make provision for the protection and extension ofoutdoor recreation land in this location, and dual school andcommunity use of some of this land is proposed. Changes atSecond Deposit stage have also reduced the effect of the widerallocation on existing allotment land.

10.53 This part of Southborough suffers from significant congestion.However, the site has the advantage of being in the centre ofthe town and the community, giving opportunities for travelthere by means other than the private car, and encouraginglinked trips to the school and to town centre facilities. Policiesin the Transport Chapter of the Local Plan Review will alsorequire any proposal for development on the site to beaccompanied by Transport Assessments and Travel Plansaimed at achieving reductions in car usage and increased useof public transport, walking and cycling.

10.54 Whatever the history of other former school sites in the area, itappears that they are no longer available to meet the identifiedneed for a primary school here. The site is in the centre of itscommunity, and there is no convincing evidence that it wouldnot be available to the whole of the community it is intended toserve. Nor is there any convincing evidence that a new schoolin this location would have a harmful effect on other schoolspresently serving the area. Although the school would be closeto commercial premises and car parking there is nothingparticularly unusual in such an arrangement, and school sitescan be secured and separated from vehicle circulation areas.Use of the site for school purposes would not take place duringunsocial hours, and any noise resulting should not, therefore,give rise to significant amenity problems.

10.55 Important trees would be protected under other policies of thePlan. There is no evidence that the proposed access into thesite would lead to insurmountable traffic difficulties.

RECOMMENDATIONS


Policy CS2 (2) Land off Carriers Road, Cranbrook (formerlyCS2 (3))

D1/418/33/2 KCC Directors of Education and Property (part)D1/73/6/1 Weald of Kent Preservation Society



D1/169/1/1 DykesD1/372/1/1 AllenD1/386/1/1 Sanders


10.57 Policy CS(2) should refer to an extension to the playing field atCranbrook Church of England Primary School, and should beamended to give the correct name of the school. The schoolalready has an unusual amount of land, and the further loss ofgreen field public land is not justified. The proposal wouldmean the possible closure of two well-used public footpaths.Any extension of school use into open countryside should notaffect the public footpaths and should be restricted to playingfield use.


10.58 FPA 14, which would also correct the name of the school, moreaccurately identifies the purpose of the allocation as a playingfield extension and I support it. In my view, the change of useof this land to playing field use would not be unduly harmful tothe character and appearance of the area, given that theallocation is not for the construction of new buildings. Anyfootpath diversion that was necessary would only involve arelatively short additional length for pedestrians to walk, andthis would not warrant removing the allocation.

RECOMMENDATIONS

10.59 I recommend that the Plan be modified in accordance with FPA14.

Policy CS2 (4) Land off Rye Road, Hawkhurst DELETEDFROM 2ND DEPOSIT

D1/1019/1/2 Weatherly


10.60 The school allocation, together with additional housing inHawkhurst, will lead to increased traffic and congestion.


10.61 This allocation was removed from the Second Deposit Copy asthe construction of the school had, by that stage, begun.

RECOMMENDATIONS


Policy CS2 (3) Land off Pearse Place, Lamberhurst(formerly CS2 (5))

D1/532/1/1, /1/2 BrownD1/581/1/1 TibbsD1/997/1/1, /1/2 Honnyhill




10.63 The site is unsuitable for a school because of its slope, its size,its access and its proximity to residential properties. A moreappropriate site for the school at Lamberhurst is available atFurnace Lane. The site should be enlarged by adding theVicarage.


10.64 There is no information before the Inquiry to suggest that KCCis dissatisfied with the allocated site, and indeed it appears thatKCC has set in train the process of obtaining a deemedplanning consent to construct a new school here. There is noevidence to suggest that it is necessary to extend the site.

10.65 The alternative site suggested lies well outside the LBD, remotefrom the centre of the village, and is not easily accessible onfoot from the main areas of housing. It is also in a prominentposition within the AONB, and a building in this location wouldhave an unacceptable visual impact on the landscape. Forthese reasons I consider that it would be unsuitable as a sitefor a school.

RECOMMENDATIONS


Policy CS2 (4) Land off Common Road, Sissinghurst(formerly CS (6))

D1/267/1/1, /2/1 DuellD1/418/33/2 KCC Directors of Education and Property


10.67 The notations shown on the First Deposit Copy proposals mapsare inconsistent. A larger area of land should be allocated forthe school at Sissinghurst, in order to provide sufficient roomfor the required buildings and ancillary facilities and a betterlayout of development, and to allow for future expansion ifneeded. Policy CS(2) should be amended to give the correctname of the school.


10.68 There is no dispute over the principle of the allocation of landat Sissinghurst for a new school site, or over the generallocation of the allocation. The Second Deposit Copy, which nolonger has the notational inconsistencies present in the FirstDeposit version, allocates 1.8 ha, a significantly larger areathan the size range for a one-form entry school recommendedin draft Building Bulletin 82 (CD 2.37) and larger than the sizethat KCC would normally seek for a one-form entry school.The size of site sought by KCC is above the top end of therange for two form entry schools, according to this document.



10.69 The number of pupils currently attending the school is someway below the maximum number in a one-form entry school.Although I sympathise with KCC’s desire to make provision forfuture needs, it has acknowledged that there are no proposalsto expand during the present Plan period, and that it is possiblethat the school may not expand during the next 40 - 50 years.In view of this and given that the birth rate is falling and thenumbers of primary aged children are predicted to fall duringthe Plan period, pupil numbers alone would not justify theallocation of such a large site here. There is clearly noprospect of the school requiring extension during the Planperiod or for many years to come, and the allocation of anoverlarge site would result in an inefficient use of land,contrary to the advice in CD 2.37 and conflicting with the aimsof Strategic Objective 2 of the Local Plan Review.

10.70 The allocated site is irregularly shaped, but there appears to besufficient room to the east of the public footpath crossing thesite to allow for the construction of buildings, car parking,access and playground. What KCC envisage, on the otherhand, would result in buildings being constructed to the west ofthe footpath, further away by foot from the centre of thevillage and requiring the construction of a footway extensionalong Common Road and a longer access road. In this schemethe buildings would be sited in the presently open areabetween Cleavers and Mill Lane, forming a significantly greatervisual intrusion into countryside than if the buildings wereconfined to the area of the Second Deposit Draft allocationadjoining Common Road.

10.71 Not only would the site layout as envisaged by KCC be aninefficient use of the site, but it would also leave a piece ofundeveloped land fronting Common Road with development onthree sides and no direct link to other agricultural land. Itcould be difficult to find a workable agricultural use for thisland, and it seems to me that there would be likely, as a result,to be significant pressure for this land to be developed, whichthe Council may find difficult to resist.

10.72 I fully understand KCC’s concerns that the playing field shouldbe open to adequate supervision. But it seems to me that itwould be possible to site the buildings to allow for a reasonabledegree of supervision, notwithstanding the presence of thepublic footpath running across the site. I acknowledge that itwould be preferable to provide a pitch on a north-southorientation to avoid sun affecting the players’ vision on sunnydays. But in view of the possibility of dual use being made ofthe nearby recreation ground, and of providing two mini-pitches orientated north-south within the school site, thatconsideration is not overriding. I have noted that negotiationsfor the acquisition of the site have been on the basis of thelarger site promoted by KCC, and I acknowledge that theboundary of the site might present a greater maintenanceburden for KCC. But none of these matters appear to me to



outweigh the clear disadvantages of the larger allocation, and Ido not therefore support it.

10.73 The Council has proposed a further amendment (FPA 14), torepresent correctly the full name of the school at Sissinghurst.This change would add clarity to the Plan, and I consider that itshould be adopted.

RECOMMENDATIONS

10.74 I recommend that policy CS2(4) be modified as proposed inFPA 14.

Paras 10.28 - 10.29 Secondary schools



10.75 The first sentence of Paragraph 10.29 should be changed toreflect the possibility of opportunities for minor expansion ofsecondary schools onto adjoining land or by acquisition ofadjoining buildings.


10.76 No need has been identified for additional secondary schoolprovision, but paragraph 10.29 recognises the possibility thatthere may be some expansion of existing schools. There isnothing in policy CS3 that restricts secondary school expansionto the existing school grounds, and the suggestion of such arestriction in the reasoned justification is therefore at odds withthe wording of the policy. It does not seem to me that such arestriction within the LBD would be justified, although outsidethe LBD it would not be inconsistent with the overall strategy ofthe Plan. If it is intended that outside the LBD any schoolextension should be within the existing school grounds, thenthis should be made clear in the policy. In any event, Irecommend that the Council should clarify what it intends.

RECOMMENDATIONS

10.77 I recommend that the Council modify the Plan to remove theinconsistency between para 10.29 and policy CS3 and to clarifythe intent of the policy.

Para 10.30 Special schools



10.78 Paragraph 10.30 should be amended to reflect more accuratelythe number of special schools within the Plan area.




10.79 The Borough Council agrees that there are only two specialschools within the Borough, and has proposed a furtheramendment (FPA 15) to amend paragraph 10.30 accordingly.

RECOMMENDATIONS

10.80 I recommend that paragraph 10.30 be modified in accordancewith FPA 15.

Paras 10.31 - 10.32 Independent Schools

D1/1007/2/1 Kent College Pembury


10.81 The objector wishes to see the inclusion of a new policy whichwould allow for the expansion of Kent College in accordancewith the development limits identified by the SchoolMasterplan, subject to being acceptable in terms of scale,design, siting, traffic generation, landscape and natureconservation interests.


10.82 Kent College lies within the Green Belt. The Plan identifies thecore of the built area of the school as a Major Developed Site(MDS) in the Green Belt, and I deal with the College’sobjections to the boundary identified on the Proposals Map inChapter 3 of this report.

10.83 I recognise that the school has aspirations to extend theeducational opportunities it offers. However, I find nothing incurrent government guidance to suggest that the expansion ofschools is not inappropriate development in the Green Belt,other than such development as complies with the criteriarelating to identified MDS.

10.84 I consider that the wording of the suggested policy, asoriginally proposed, would be unacceptable. It would, in effect,allow development in the Green Belt, in an area to be definedin another document (the School Masterplan). At the inquiry,the objector’s proposed policy wording was refined. However, Iconsider that the revised policy is unnecessary, as Policy MGB2provides an adequate framework for the consideration ofproposals in the MDS. From the evidence before me at theinquiry, I formed the view that the School Masterplan is at arelatively early stage of development and that a reference to itin the development plan would not serve any useful purpose.

RECOMMENDATIONS




Policy CS4 Development Contributions to School Provisionfor Developments over 15 Bedspaces

See Appendix 10.2


10.86 Developments on allocated sites should not be required tomake contributions, as the provision of schools to servehousing allocated in response to the Structure Plan housingrequirement is the responsibility of KCC. Catchment distancesin the policy are unrealistic and many house moves are localand do not require a school change. The policy threshold is toolow; use of bedspaces will overestimate the numbers ofchildren that will live in developments; affordable housing unitsshould be excluded from the requirement. Contributionsshould not be required towards facilities at significant distancesfrom the development. Any contribution must relate directly tothe demand for school places generated by the development,and contributions should be directed specifically to the newfacilities required.

10.87 The housing development at Hawkenbury Farm will generate aneed for a new primary school and the development should berequired to fund this, as there is no assurance that KCC will beable to. There are already insufficient school places in thearea. Account should also be taken of policy CS5, which willincrease pressure on school places. The housing allocation atHawkhurst will lead to problems for the local school.

10.88 KCC is the appropriate authority to determine the level andnature of contributions towards education facilities, and thisshould be recognised in the TWBLPR. The Plan should alsomake reference to the Kent Planning Officers’ Group GoodPractice Guide on development contributions. There should beno minimum threshold and the exception in the policy relatingto secondary schools should also apply to rural primaryschools. Amendments to the reasoned justification aresuggested. KSP policy S9 could be recognised in the reasonedjustification.


10.89 PPG12 (CD 2.23) requires the capacity of existinginfrastructure, including services like education, and the needfor additional facilities, to be taken into account in thepreparation of all development plans. It notes that theadequacy of infrastructure can be a material consideration indeciding whether planning permission for development shouldbe granted. It also advises that planning obligations can beused to address the need for infrastructure improvements thatare not firmly programmed, arising from development, andthat where a local planning authority expects planningobligations from developers on a regular basis their policyshould be set out in their local plan. Policy S9 of the KSP alsorequires local planning authorities in preparing their local plans



to have regard to the need for community facilities, includingeducation.

10.90 In the Council’s area it appears that many schools areoperating at or near capacity. Under those circumstancesadditional housing development, whether on allocated orwindfall sites and whether affordable or general market, mayplace demands on schools that could not be met by existinginfrastructure. If no provision is made for this eventuality theresult could be that children would have to travel longdistances to school, which would be highly unsatisfactory fromthe point of view of their welfare. It would also be likely toincrease the number and length of private car trips.

10.91 In these circumstances the principle of a policy seekingdeveloper contributions towards educational facilities wouldaccord with both PPG12 advice and with KSP policy S9. Thepolicy would address the effects of development on existingschool provision, both primary and secondary. Those effectswould not differ significantly whether the development site isallocated in the Plan or not, and the fact that a site is allocatedis therefore no reason to exclude it from the policyrequirement. Although affordable housing may already besubsidised by developers, the available evidence indicates thatit generates a similar demand for school places as, and in thecase of secondary places a greater demand than, generalmarket housing. If affordable housing were to be excludedfrom any obligation to contribute towards education provisionthe result could be a significant increase in the pressure onexisting school places. In the context of this Plan area, there istherefore no justification for excluding affordable housing fromthe operation of the policy.

10.92 Annex B of Circular 1/97 (CD 2.4), which is relevant herebecause the mechanism for securing development contributionswould involve the use of planning obligations, advises thatplanning obligations should be directly related to individualproposals. The policy would only apply where a residentialdevelopment would generate demand that cannot be met byexisting facilities, and would therefore broadly accord with thisadvice. Research commissioned by KCC suggests that manyhouse moves in Kent are within the same district to avoiddisruption to schooling. But it seems highly likely that theprovision of additional housing in the Council’s area willgenerate demand for additional school spaces, if not throughdemand from the new properties then through demand fromthe families moving into vacated properties. That researchdoes not, therefore, justify the removal of the policy.

10.93 Some objections have queried the appropriateness of the 15-bedspace threshold, or of using bedspaces to set the thresholdat all. The reasoned justification indicates that contributionsshould only be sought where the impact on school provision ismeasurable and significant, and I support the principle of that



approach. But it is not clear either from the reasonedjustification or from the SPG Education Facilities andDevelopment Contributions (CD 1.19) why developments ofless than 15 bedspaces are considered unlikely to generatesufficient demand for school places to merit the collection ofcontributions. Nor has it been clearly explained why thethreshold is set at 15, or expressed in terms of bedspacesrather than dwellings. Indeed, bearing in mind that anycontribution would, according to the SPG, be assessed on thebasis of dwelling numbers the relevance of bedspaces is notclear at all.

10.94 There is a danger, in setting an arbitrary threshold in this typeof policy, that smaller developments that would generate ademand for school places may be allowed to proceed withoutmaking appropriate contributions. The cumulative effect of anumber of small developments on existing school provisioncould be significant, and may need to be taken into account.This is particularly important in the Council’s area, where alarge number of unidentified sites are anticipated to comeforward, many of which are likely to be small developments.On the other hand, contributions may be sought fromdevelopments above the threshold as a matter of coursewithout proper examination of the merits of individualproposals. For these reasons I do not support the inclusion ofa threshold in the policy. However, it would be appropriate togive guidance in the reasoned justification as to the size ofdevelopment the Council considers likely to have a measurableand significant impact and why, whilst making it clear that eachdevelopment will be assessed on its own merits. If bedspacesare chosen as the guiding measure, the reason for this shouldalso be explained.

10.95 The policy would take effect where the demand generated by adevelopment for school places could not be met within a twomile radius of the development in the case of primary schools,and a three mile radius in the case of secondary schools.These distances are based on what is considered nationally tobe a reasonable walking distance for pupils to be expected totravel to school. I consider therefore that they form a soundbasis on which to determine whether additional school facilitiesmay be needed, bearing in mind the need to provide adequateeducational facilities close to the populations they serve.

10.96 The SPG indicates that, where there is no school that can beextended or is to be built within the specified radius of thedevelopment, no contribution will be sought. But the policyitself is expressed in terms of demand being unable to be metwithin the specified radius. In a case where there is no schoolwithin the radius, then it follows that any demand for schoolplaces generated by the development could not be met withinthe radius, and so the policy would apply. For this reason thelast sentence of policy CS4(2) adds nothing to the policy. Inote the Council’s view that general residential development



more than two miles from a primary school is likely to beunacceptable in principle, but in my view, given the shortage ofschool places in the Plan area, the policy ought to address sucha possibility. It also follows from these comments that theamendment sought by KCC relating to rural primary schools isunnecessary.

10.97 Many of the objections to this policy relate to the housingallocation under policy H8 of the Second Deposit Copy atHawkenbury Farm, and the consequent need for additionalschool places. I have dealt above with the allocation in policyCS2 for a school site at Hawkenbury, but it should be notedthat Policy CS4 would allow contributions to be collected fromall developers of housing land in order to provide the schoolplaces generated by their development. Similarly, the policywould allow for the collection of contributions in respect of newhousing at Hawkhurst, should a need for more spaces begenerated by that housing. Policy CS5 deals with situationswhere existing schools are to be replaced and enlarged. Thatpolicy will not lead to any reduction in school capacity.

10.98 The Council has chosen not to adopt the Good Practice Guideon Development Contributions, and as that document does notappear to have been subject to public consultation within thePlan area, unlike the Council’s SPG, I attach little weight to it.It is for the local planning authority to make the final decisionon the assessment of any contribution. But it would beappropriate for the reasoned justification to acknowledge therole of KCC, so that developers are aware that KCC will beproviding the information required to justify contributionssought under the policy. The addition to the policy of wordssuggested by KCC specifying the rate at which contributionswill be sought, and indicating how those contributions might beapplied in certain circumstances, would make the policy undulyinflexible and unable to respond to future changes incircumstances. I do not, therefore, support them.

10.99 A reference to the KSP in the reasoned justification isunnecessary as this forms part of the development plan for thepurposes of the relevant legislation. The reference will in anyevent become out of date when the K&MSP is adopted.Inserting “forecast” into paragraph 10.35 of the Plan would addnothing, as the policy itself does not rule out the use offorecasts of capacity in assessing whether any generateddemand for school places could be met. However, I supportthe deletion of “previously-used” in paragraph 10.35, becauseof the implication in the phrase that only clean-up costs mightjustify a negotiation on the question of viability. The Planshould not rule out the possibility of permitting a developmentwithout seeking contributions under policy CS4 if they wouldrender the development unviable for reasons other than clean-up costs, even though such an eventuality is likely to beexceptional. The other changes suggested to this paragraphadd nothing to the Plan and I do not support them.



10.100 I consider that paragraph 10.36 of the Plan should be deletedas it suggests undue inflexibility. It seems to me that what isdone with the contribution is a matter for negotiation inconsultation with KCC in the light of circumstances pertainingat the time, including current Government advice on developercontributions. There may be circumstances, even ifexceptional, where it would be appropriate to applycontributions outside the two or three mile radius, and the Planshould not rule this out. I do not support the alternativewording suggested by KCC, as that too would be unnecessarilyinflexible. Instead, I suggest that a form of words should beadopted acknowledging the mechanism needed to secure thecontribution. The amendment to paragraph 10.37 suggestedby KCC does not appear to reflect how the SPG was actuallyproduced, and I do not therefore support it.

10.101 The Council clearly considers from past experience that thesituation envisaged in paragraph 10.38 of the Plan may arise inthe future. Other policies in the Plan presume against housingoutside the LBD, and I see no objection to this Plan recordingthe Council’s view that at the time of adoption of the Plan thereis no need for rural schools that would justify an exception tothose policies. I do not, therefore, support the deletion ofparagraph 10.38.

10.102 Objections to this policy have also been directed at the contentof the SPG (CD 1.19). This document has already beenadopted by the Council, and it is not for me to comment on itsdetail. The Council will, of course, wish to keep the documentunder review to ensure that it is up to date and accords withnational, regional and local policy guidance.

10.103 The Council has proposed a further amendment, FPA 27, toreplace “commuted sums” in paragraph 10.36 with“contributions”. I am recommending that this paragraph bereplaced with an alternative wording, and I do not thereforesupport this FPA.

RECOMMENDATIONS

10.104 I recommend that Policy CS4 be amended to read as follows:

POLICY CS4

Where a residential development proposal wouldgenerate a demand for primary school places whichcould not be met within a two-mile radius of thedevelopment, or for secondary school places which couldnot be met within a three-mile radius of thedevelopment, the Local Planning Authority will seek adevelopment contribution towards school provision.

10.105 In the reasoned justification I recommend that the phrase“previously-used” be deleted from paragraph 10.35.Paragraph 10.35 should also be amended to indicate thethreshold below which the Council considers it unlikely that the



policy would apply, and explain why it has chosen thatparticular threshold. I recommend that paragraph 10.36 bedeleted and replaced with the following:

A planning obligation will be required to securecontributions required under this policy, which will becalculated on the basis of information provided by theLocal Education Authority. The planning obligationshould indicate when any contribution should be madeand the broad location where the contribution will beused.

Paras 10.39 - 10.40 Dual use of schools



10.106 Paragraph 10.40 should be amended to reflect the need foradditional funding sources to cover the extra costs of providingdual use facilities.


10.107 As I have noted in Chapter 9, during the lifetime of the TWBLPdual use facilities have been achieved with funding from avariety of sources. To seek to identify the Borough Council asa particular source of funding, as the proposed amendmentappears to do, would not be appropriate in this Plan. There isnothing in the Plan to preclude the multi-sourcing of fundingfor dual use facilities, and I consider that no change isnecessary.

RECOMMENDATIONS


Paras 10.41 - 10.44 Redundant Schools

D1/418/4/1, PPC/418/12 KCC Directors of Education and Property


10.109 The second sentence of paragraph 10.41 would moreaccurately reflect the statutory process leading to schoolclosures if it referred to schools "likely to be closed" rather thanschools "proposed to be closed". Should the Hawkenburyhousing proposal be resurrected, the KCC would have toconsider how it could fulfil its statutory duty to provide schoolplaces, and would seek support from the Council should it benecessary to consider relocating St Peter’s School.


10.110 The words "proposed to be closed" do not convey that closureis a certainty, and do not in any way derogate from thestatutory closure procedure. For that reason, no amendmentto paragraph 10.41 is necessary.



10.111 The KCC is not seeking an allocation of a new site for St.Peter’s School. It is not therefore correct to identify theexisting St. Peter’s as being proposed for closure. The Councilhas proposed a change to paragraph 10.41 to delete thereference to St Peter’s School, which I support.

RECOMMENDATIONS

10.112 I recommend that paragraph 10.41 be modified in accordancewith PPC/10/3.

Policy CS5 Redundant Schools

D1/112/4/1 Cranbrook Conservation Area Advisory CommitteeD1/418/5/1,PPC/418/1/13 KCC Directors of Education and PropertyD1/890/1/19 Hawkhurst Parish Council


10.113 There should be a more detailed recommendation forSissinghurst primary school in view of its location in the CA.Policy CS5(1) should be modified to reflect that both parts ofthe existing St. Peter’s site are suitable for housing. TheHawkhurst school site should be reused only for residentialdevelopment. Should the Hawkenbury housing proposal beresurrected, the KCC would have to address its statutory dutyto provide school places and would seek the Council’s support ifSt Peter’s School needed relocating.


10.114 The policy identifies what are considered the most appropriateuses for the Sissinghurst school site. Other policies in Chapter4 of the Plan will allow proper consideration of the effect of theappearance of any proposal on the CA, and there is no need forany further change to the Plan. In respect of the Hawkhurstschool site, the policy as drafted envisages either residential orbusiness use (Class B1). Class B1 uses are by definition usesappropriate in residential areas. For this reason, to precludeClass B1 uses on the site at this stage would be unreasonablyinflexible.

10.115 KCC is not seeking an allocation of a new site for St. Peter’sSchool, and there is, therefore, no need for provision to bemade for the existing St. Peter’s school site in policy CS5. If,notwithstanding what has been said by KCC and the schoolgovernors, this site did become redundant during the Planperiod, other policies of the Plan would provide sufficientguidance to allow any proposals for redevelopment to beproperly considered. The Council has proposed a change topolicy CS5 to delete the reference to St Peter’s School, and Isupport that change.

RECOMMENDATIONS

10.116 I recommend that the Plan be modified in accordance withPPC/10/4.



Paras 10.45 - 10.47 Community Buildings



10.117 Paragraph 10.45 should make it clear that an operationalschool or part thereof should not be regarded as a communitybuilding, even if used by community groups. Adult Education,Youth Services and Social Services are all community servicesthat use community buildings, and KCC seeks developmentcontributions to meet the increased demand for these services.


10.118 The aims of this part of Chapter 10 are to ensure a satisfactorydistribution of community building facilities, and to seek theirretention, improvement or replacement to meet local needs.In order to achieve these aims and to avoid unnecessaryduplication of facilities, I consider that the Council is correct tohave regard to all buildings available for use by the communityfor community activities, whether or not those buildings areprimarily fulfilling a different function, such as a school. Thisappears to accord with the KCC’s current practice ofencouraging dual use, and it also reflects Strategic Objective 3of the Local Plan Review. Both Strategic Objective 3 and theaims of this part of Chapter 10 seek well-distributed facilitiesclose to the populations they serve, and in principle meritsupport. To ignore the role played by schools in providingfacilities for the wider community would not accord with thoseaims and objectives. However, to continue to recognise thisrole would not in any way lessen the control each school hasover the nature and timing of any community use.

10.119 Paragraph 10.45 defines a community building as one availablefor use by the local community for community activities. Thelist that follows is indicative and not exclusive. Not all of theactivities carried out by the services listed by KCC are“community activities”, and for that reason it is not appropriateto refer to those services in this part of the Plan. I have dealtwith the question of development contributions for the servicesreferred to by KCC above in considering an objection to para10.5, and I have dealt with the question of a general policyrelating to development contributions in Chapter 2.

RECOMMENDATIONS


Paras 10.48 - 10.52 Provision of Community Buildings inRoyal Tunbridge Wells

D1/474/2/1 CopusD1/501/1/3, /1/4, /1/5 Tunbridge Wells Branch Labour PartyD1/609/5/1, /6/1 CattD1/652/1/1 StockD1/694/4/2, /4/3 Lewis



D1/862/23/1 Royal Tunbridge Wells Civic SocietyD1/946/3/1, /3/2 Women's Forum


10.121 Existing community facilities are not easily accessible for theresidents of the Oak Road area. The site allocation for OakRoad community hall in the adopted Plan should be retainedand the hall at Grosvenor Recreation Ground replaced.Paragraph 10.51 should require the possibility of linking acommunity facility to the existing library at Rusthall to beinvestigated. The Plan should make reference to potentialfuture use of the Middlefield and Rusthall Elms sites.

10.122 There is not an adequate supply of accessible communitybuildings in the Plan area. The Local Plan Review shouldrecognise the positive benefits of providing communitybuildings, specifically designate sites for community use andmake new provision in identified areas of deficiency. Para10.50 should be redrafted to reflect the serious shortage ofsuitable venues for cultural activities in Royal Tunbridge Wellstown centre. A cultural and community facility notation shouldbe added to the Proposals Map to include the Civic Centrecomplex and adjoining buildings.


10.123 The Plan contains policies to protect existing communitybuildings, but only limited proposals for new facilities, in RoyalTunbridge Wells town centre, Southborough and PaddockWood. The Council’s Community Buildings Study 2000 (CD1.42.1) has informed policy preparation for the TWBLPR. Thisstudy identified five areas in the Borough that are poorlyprovided for in terms of facilities appropriate to the needs ofthe local community. Other than in Southborough town centre,no proposals for community buildings are included in the Planfor these areas, although further investigation isrecommended. However, I note here that the Community Plan(CD 1.52.1) identifies as one of its actions the support andfacilitation of the provision of appropriate community buildings,and that the improvement of existing facilities would beunlikely to require provision to be made in the Plan.

10.124 CD 1.42.1 is helpful in identifying current numbers ofcommunity buildings, but there is only limited analysis of theirfacilities, whether the buildings are fully accessible, theiravailability and capacity or the cost of hire. In addition, nosurvey appears to have been undertaken of users or potentialusers, and so there is no analysis of demand for buildings forcommunity or cultural uses, either satisfied or otherwise. As aresult, it is not, in my view, possible to use the study as a basisfor concluding, as paragraph 10.48 does, that in most areas ofthe Borough the provision of community buildings issatisfactory. For this reason I consider that the wording of thisparagraph should be reconsidered.



10.125 However, PPG12 (CD 2.23) requires the provisions made indevelopment plans to be realistic and likely to be implementedwithin the Plan period. There is no information to indicate thateither the Council or any other body has any intention ofmaking provision for additional community or cultural facilitieswithin the Plan period that would require the allocation of land,other than those already provided for. Furthermore, on thebasis of the information currently available, it is not possible toidentify with certainty what, if any, provision ought to be madein the Plan. For these reasons, there is no case for modifyingthe Plan to make further provision for community or culturalbuildings. However, I do recommend that the Council carry outfuller investigations and consultations, including surveys ofusers, in the course of preparing its spatial planning strategy.

10.126 One objection sought the introduction of a cultural andcommunity facility notation covering land between MountPleasant Road, Crescent Road and Monson Way. This area iscurrently occupied by a number of public buildings includingthe Town Hall, the museum and library, the Assembly Hall andother public buildings, and I deal with objections to the primaryshopping area notation in this location in Chapter 5. Of thebuildings proposed to be included within a new notation, allappear to be fully in use apart from the Magistrates’ Court, andthere is no evidence of any proposals for their re-use. Nopolicy is suggested in connection with the notation, and I amnot therefore satisfied that it would achieve any useful purposein this Plan. However, the Council may wish to examine inmore detail whether the area’s civic and cultural function is inneed of protection in preparing its DPDs.

10.127 In the case of Rusthall, any linking of a community facility withthe library would be a matter for the appropriate authorities toinvestigate. Nothing would be gained by amending thereasoned justification as suggested. In preparing the Plan theCouncil was advised by KCC that the Middlefield and RusthallElms sites might be required for operational purposes. Whilstthat may no longer be the case, there are no proposals fromeither Council for the use of these sites that would justify anallocation in this Plan.

10.128 The TWBLP allocates land at Oak Road, Royal Tunbridge Wellsfor community purposes. This allocation has not been carriedforward into the Local Plan Review. The Council’s explanationfor this is that its research shows that Sherwood Ward hasadequate community hall provision, but as I have indicatedabove there is not at present any firm basis for such a finding.It appears from paragraph 10.52 of the Plan that there areplans for rationalising and improving existing facilities inSherwood Ward. Judging by the objections to this Plan thosefacilities may not be particularly accessible for some of thecommunity in the Oak Road area.



10.129 But as there appears to be no proposal or funds identified for anew community building in the Oak Road area, it would not beappropriate to make any allocation of land for such purposes.For the same reasons I do not recommend any allocation inrespect of the Grosvenor Recreation Ground or the other areasof deficiency identified in the Community Buildings Study. Ideal with the Kent and Sussex Hospital site in Chapter 5.

10.130 A number of points were raised in submissions supportingObjections D1/946/3/1 and 3/2 that go beyond the function ofthis Review and I make no recommendations in respect ofthem.

RECOMMENDATIONS

10.131 I recommend that paragraph 10.48 be modified to reflect theshortcomings that I have identified in the Community BuildingsStudy. I also recommend that the Council carries out a fullerinvestigation of the need for community and cultural facilitiesincluding consultation with users and potential users during thecourse of preparing its spatial planning strategy.

Para 10.53 Community Building provision in Southborough

D1/34/1/1 Age Concern (Southborough & High Brooms)D1/418/8/1 KCC Directors of Education and Property


10.132 The Plan should refer to existing use of Southborough TownCouncil offices by Age Concern. Paragraph 10.53 should notassume that the new primary school at Southborough can"double up" to provide a community hall, as the school hall willbe needed for the operation of the school during normal hours.


10.133 Paragraph 10.53 is not exclusive as to the uses to which thecommunity building should be put, but refers to the need forpremises for a number of uses, including functions for olderpeople. In my view, the addition of a reference to Age Concernwould add nothing of substance to the Plan.

10.134 The paragraph as worded makes no assumption that dual usewill take place, but retains a degree of flexibility as to how theneed for a community building at Southborough could be met.The reference to the potential for dual use accords with theaims of this Chapter. In seeking to make the best use of landit also accords with the thrust of strategic objective 2 of theLocal Plan Review. It is not appropriate to make reference to a"primary school site", as no specific site for a school has beenidentified within the larger mixed-use allocation under policyCR7.

RECOMMENDATIONS




Policy CS6 Allocations for Community Buildings DELETEDFROM 2ND DEPOSIT

D1/234/27/1 Southborough Town CouncilD1/658/19/1 Southborough SocietyD1/533/1/4 CooperD1/703/1/31 RusbridgeD1/954/1/19 Lohmann


10.136 The question of access to the site should be resolved beforethere is further development. The policy should not be specificas to the location of the community building, in order to ensurea flexible approach. The Town Council must have its ownoffices and meeting chamber in the community building. Thescheme should involve enhancing and extending the RoyalVictoria Hall, and should include a library.


10.137 This policy has been removed from the Second Deposit Copy.The community building proposal is now incorporated in themixed-use site in Southborough allocated under policy CR7.That policy is flexible in the location of the various elements ofthe proposal. The precise mix of uses will be determined atplanning application stage, and details of facilities to beprovided will, in any event, be partly dependant onnegotiations between the interested parties. To be overlyspecific now would render the policy unduly inflexible. I dealwith the detail of the proposal including access, and thequestion of the library, in Chapter 5.

RECOMMENDATIONS


Para 10.55 Community Building Provision in Paddock WoodD1/717/11/1 Berkeley Strategic Land Ltd


10.139 Any additional community facilities in Paddock Wood can onlybe provided through developer contributions funded bysignificant development proposals. A mixed-use developmentat Mascalls Farm is ideally positioned to contribute to this.


10.140 This paragraph relates to the provision within Paddock Woodtown centre of facilities to meet the needs of existing residents.There is no evidence that these can only come forward throughfunding from new housing development. The question of newhousing at Paddock Wood is dealt with in Chapter 6.

RECOMMENDATIONS




Para 10.56 Community Building Provision in CranbrookD1/112/5/1 Cranbrook Conservation Area Advisory CommitteeD1/418/9/1, FPA/418/1/2 KCC Directors of Education and PropertyD1/494/1/17 Cranbrook Business AssociationFPA/603/1/1 Cranbrook Parish Council


10.142 Alternative community hall sites are suggested either withinthe policy CR10 (now CR11) site or closer to housing in eastCranbrook. There are no plans to close the library, so althoughthe Carriers Road site may have redevelopment potential,library services will need to continue to be provided there. Thefinal sentence should be deleted, as it is not clear that librariesand community centres always fall within the same use class.The wording of FPA 22 should be altered.


10.143 The policy CR11 site is dealt with in Chapter 5 of this report. Itwould meet an identified need for additional retail floorspacethat cannot easily be met elsewhere in the town centre, as wellas providing for housing and office development in a highlysustainable location. Whilst policy CR11 does not rule out theprovision of other uses in addition to those specificallymentioned, that site appears not to be large enough toaccommodate a community hall with appropriate facilities aswell as the uses identified in that policy. The availableinformation does not indicate that there are any suitable sitesin east Cranbrook.

10.144 The Council has proposed a further amendment (FPA 22) tomake it clear that library services would continue to beprovided from the library site. Although Cranbrook ParishCouncil has asked for this wording to be amended to refer tothe continued provision of library services “within the town”,KCC, which is the library authority, has made no proposal tomove the library. I therefore support the proposedamendment. It would not be unusual for a community hall toprovide for both Class D1 and Class D2 uses, and a referencehere to Class D1 only seems to me to be unnecessarilyrestrictive. I therefore support the deletion of the finalsentence of the paragraph.

RECOMMENDATIONS

10.145 I recommend that the Plan be modified in accordance with FPA22, and that the final sentence of para 10.56 be deleted.

Para 10.58 - 10.65 Community hall provision in villages(formerly paras 10.57 - 10.64)

D1/890/1/20 Hawkhurst Parish Council


10.146 Para 10.58 should mention Hawkhurst as requiring moreappropriate hall provision.




10.147 There appear to be several halls in Hawkhurst available forsome form of community use. There is no detailed evidence ofneed for additional facilities, or any analysis of available sites,that might justify a specific allocation in the TWBLPR.However, the Second Deposit Copy contains a reference in para10.57 to ongoing feasibility work into a site and specificationfor a village community centre. In the light of the availableinformation, I do not recommend any modification to the Planin this regard, although the Council will wish to review thesituation prior to adoption to ensure that the Plan is up to date.

RECOMMENDATIONS

10.148 I recommend that no modifications be made. I alsorecommend that the Council should review the situation priorto adoption to ensure that the Plan reflects the up-to-dateposition at that time.

Para 10.61 Pembury Village Hall (formerly 10.60) andPolicy CS6 Retention of Community Buildings (formerlyCS7)

D1/15/1/22 CloadD1/439/1/1, /1/2 NewmanD1/484/5/1 Pembury SocietyD1/595/2/2 LynesD1/875/32/1, D2/875/1/4 Pembury Parish CouncilD1/1000/1/34 Mills


10.149 Land at Woodsgate Corner, Pembury should continue to beallocated for the provision of a community building, as there isstill a need for community facilities which has not been met bythe new village hall on the existing site. The land designationshould be “community use” and not “village hall” as in theextant permission. The land performs a useful role as a bufferzone and should be made amenity land, to protect nearbyresidents from the retail development and the proposed Parkand Ride and hold in check any creeping retail development.


10.150 In the TWBLP a site is allocated for community buildingpurposes on land south of High Street and west of CornfordLane, Pembury. That designation has not been carried forwardinto the TWBLPR, but the site now has planning permission fora village hall. It appears that the reason for the deletion of theallocation is that the Pembury Village Hall has now been rebuilton its existing site.

10.151 Any need for additional village hall facilities could be metthrough the implementation of the extant permission, althoughthe permission would not provide the safeguarding given by an



allocation in the Plan. But there is no clear evidence of theextent of any need either for village hall facilities or for“community use” facilities, although the statement in theCommunity Building Study (CD 1.42.1) concerning the need forfacilities in the rural area is somewhat at odds with objectionsmade to the Plan. Nor is there clear evidence that there areany firm proposals to implement such a development on thesite within the Plan period, or that proposals for other uses ofthe site are likely to come forward, although that appears to bea fear of some objectors. On balance, I consider that becauseof the absence of evidence that any proposal for communityuses on this site is likely to come forward within the Planperiod, the allocation in the adopted Plan should not be carriedforward into this Plan. However, I recommend that the Councilexamines this matter further in preparing its DPDs.

10.152 There is no suggestion, in the appeal decision grantingplanning permission for the foodstore and park and ride facilityat Woodsgate Corner (ref. T/APP/M2270/A/97/277893/P4),that the site referred to in these objections would be needed asa buffer to protect nearby residents from those developments.Nor is there any actual evidence before the Inquiry showing theneed for a buffer. The acceptability of any future proposals foralternative uses on the site would need to be assessed in thelight of other criteria-based policies in the Plan, and anyrelevant regional or Government guidance. However, bearingin mind that the site lies within the LBD and has the benefit ofan extant permission for built development, there wouldappear to be no justification for requiring it to remainundeveloped in this Plan.

RECOMMENDATIONS

10.153 I recommend that no modifications be made. I alsorecommend that the Council examines whether there is anyjustification for reinstating the allocation of this site for villagehall or other community uses when preparing its DPDs.

Paras 10.67 - 10.68 Libraries (formerly paras 10.66 -10.67)



10.154 Whilst there are currently no plans for any change in thenumber and distribution of libraries, it is impossible to predictwhat might happen over the 10 year Local Plan period.Furthermore the policy CR14 designation should not be used toprotect library services, as this is not a statutory function ofthe Borough Council. Paragraph 10.68 should be amended toreflect these points.




10.155 Paragraph 10.68 purports to record the opinion of KCCconcerning changes in the number and distribution of librariesduring the Plan period. However, the first sentence does notreflect the KCC view as expressed to this Inquiry. Because it isKCC’s view on the likelihood of changes that is being recorded,I consider that the wording preferred by KCC should appear inthe first sentence.

10.156 Objections to policy CR14 are dealt with in Chapter Five, and Ihave indicated there that it is appropriate for this policy torefer to libraries as well as shops and other facilities. However,the cross-reference in this paragraph adds little to the Plan andin the interests of brevity should be deleted. I do not supportthe final amendment proposed by the objector, as this merelyreflects the current practice of the KCC Library Service andappears to me to add little of value to the plan.

10.157 I say more about the inclusion of this and other paragraphs inthe Plan below.

RECOMMENDATIONS

10.158 I recommend that, if it is to be retained in the Plan, the firstsentence of paragraph 10.68 be modified to read as follows:Kent County Council are of the opinion that the numberand distribution of libraries are likely to be maintainedat the current level during the Plan period.

10.159 I also recommend that the second sentence of paragraph 10.68be deleted.

Para 10.69 Emergency Services (formerly 10.68)

D1/890/1/21 Hawkhurst Parish Council


10.160 The paragraph should either be expanded or deleted.


10.161 This paragraph deals with services not provided by the Council,and records that the relevant service providers have no plansto expand or relocate their services within the Plan period. Ido not support any expansion of the paragraph. Indeed I havesome sympathy with the suggestion that the paragraph shouldbe deleted, as it does not provide an explanation for any of thepolicies of the Plan, and so merely adds to its length. Thesame is true of the whole of paragraphs 10.66 to 10.75, andthe Council should consider removing them.

RECOMMENDATIONS

10.162 I recommend that the Council considers removing paragraphs10.66 – 10.75 from the Plan.



Paras 10.71 - 10.73 Waste Disposal (formerly paras 10.70 -10.72)

D1/439/1/22 Newman


10.163 There should be more about waste disposal as there areimportant implications for planning.


10.164 Waste disposal is not a matter that may be dealt with in a LocalPlan policy. Although the paragraphs might have some minorbenefit in directing readers to further guidance, most readersare unlikely to seek information from this Plan as to mattersbeyond its remit. This part of the reasoned justification is notnecessary in a local plan, and I have suggested above thatthese paragraphs should be deleted. For this reason I do notsupport the inclusion of additional information on this subject.

RECOMMENDATIONS

10.165 See my recommendation in paragraph 10.162 above.

Para 10.75 Waste recycling (formerly 10.74)

D1/494/1/18 Cranbrook Business AssociationD1/890/1/22 Hawkhurst Parish Council


10.166 An increase is required in land available for recycling, in view ofCentral Government requirements. This paragraph should beexpanded, as recycling is an important aspect of development.


10.167 KCC has not identified any specific need for additional land forrecycling points that would warrant the allocation of landspecifically for that purpose. Often recycling facilities can besited in car parks or similar public spaces without the need fora specific land allocation.

10.168 Waste management policies are not matters that can beincluded in a local plan. The provision of recycling facilitiesmay be part of the Council’s waste collection responsibilities,but it is not appropriate for the TWBLPR to go further into thismatter than it has here. As I have indicated above, I considerthat this paragraph is unnecessary and the Council shouldconsider removing it.

RECOMMENDATIONS

10.169 See my recommendation in paragraph 10.162 above.



APPENDIX 10.1

Policy CS2 (1) Land at Hawkenbury Farm, South of Hawkenbury Road,Royal Tunbridge Wells

1/61/7/1 The Fairfield PartnershipD1/62/2/1 CullingtonD1/213/16/1 PayneD1/229/2/1 AkehurstD1/242/1/2 ParsonsD1/260/2/1 ExallD1/363/1/2 AndrewsD1/385/1/2 ChewD1/439/1/19 NewmanD1/450/1/1 WardropD1/509/1/2 SibbeyD1/531/1/5 GambellD1/557/1/5 GambellD1/562/1/2 Poole

D1/562/1/3 PooleD1/758/2/1 YoungD1/791/2/1 NashD1/842/2/1 ForbesD1/892/2/1 GemmillD1/920/1/2 FenlonD1/922/1/2 FenlonD1/934/1/9 Persimmon Homes(South East) LimitedD1/1038/1/2 SibbeyPPC/418/1/10, /1/11 KCC Directorsof Education and PropertyPPC/1136/1/1 St Peter’s CE PrimarySchool

APPENDIX 10.2

Policy CS4 Development Contributions to School Provision forDevelopments over 15 Bedspaces

D1/14/2/1 BurkeD1/22/1/1 HibbardD1/23/1/1 HibbardD1/49/2/1 HarkerD1/53/2/1 LeeD1/54/1/1 HuntD1/55/1/1 MartenD1/56/1/1 MartenD1/57/1/1 WalkerD1/58/1/1 WalkerD1/81/2/1 BachelorD1/85/2/1 PonsfordD1/88/1/1 LeeD1/99/1/1 GoodfellowD1/100/1/1 GoodfellowD1/118/2/1 HuntD1/119/2/1 NikerD1/121/1/1 OsborneD1/122/1/1 NikerD1/124/1/1 OsborneD1/126/1/1 SmithD1/127/1/1 SmithD1/128/1/1 CrossD1/131/1/1 CrossD1/132/1/1 KingstonD1/133/1/1 KingstonD1/134/1/1 BakerD1/135/1/1 TuttonD1/136/2/1 BurkeD1/143/2/1 MulveyD1/146/1/1 MulveyD1/149/1/1 Hillerton

D1/158/2/1 PonsfordD1/165/1/1 CooperD1/167/2/1 CooperD1/197/2/1 JohnsonD1/198/1/1 KittleD1/199/1/1 KittleD1/215/2/1 KingD1/258/1/1 UsherD1/259/1/1 UsherD1/261/1/1 LambieD1/262/1/1 LambieD1/265/1/1 EdgingtonD1/266/1/1 EdgingtonD1/268/1/1 AndersonD1/269/1/1 AndersonD1/270/1/1 MillingtonD1/271/1/1 MillingtonD1/335/2/1 WhibleyD1/336/2/1 WhibleyD1/390/8/1 NolanD1/418/1/1 KCC Directors ofEducation and PropertyD1/443/2/1 PepperD1/445/2/1 PepperD1/477/2/1 GreenD1/480/2/1 DonohueD1/496/1/13 House BuildersFederationD1/519/2/1 HawkesD1/521/2/1 HawkesD1/530/6/1 BRB (Residuary) LtdD1/551/1/1 Knowles



D1/552/2/1 KnowlesD1/553/1/1 DaveyD1/554/2/1 DaveyD1/559/2/1 KnowlesD1/591/2/1 RuizD1/596/2/1 MorganD1/600/1/1 MorganD1/601/1/1 KCC Land Use andTransport UnitD1/623/1/1 ScottD1/640/1/1 UsherD1/651/7/1 BritishTelecommunications PlcD1/675/2/1 SmythD1/676/2/1 SmythD1/700/1/1 HillD1/706/2/1 BardenD1/735/2/1 SeddonD1/738/2/1 SeddonD1/756/1/1 DevineD1/757/1/1 DevineD1/764/2/1 BuddD1/766/2/1 LambourneD1/770/2/1 Hill

D1/787/1/1 Van Der LindenD1/788/2/1 BuddD1/790/2/1 BuddD1/794/1/2 DowlingD1/796/1/2 DowlingD1/797/2/1 GossD1/801/1/1 MullisD1/806/1/1 MullisD1/825/1/1 ClaxtonD1/826/2/1 ClaxtonD1/827/1/1 ClaxtonD1/830/2/1 Van GilsD1/831/2/1 AshD1/833/2/1 ColemanD1/837/2/1 MulhollandD1/845/2/1 StorkeyD1/848/2/1 StorkeyD1/898/1/1 MulhollandD1/933/36/1 Countryside PropertiesplcD1/934/1/10 Persimmon Homes(South East) LimitedD1/1036/2/1 Ruiz

Documents

CHAPTER 10: COMMUNITY SERVICES - Residents · hospital not an upgrading; the retention and expansion of the existing Kent and Sussex Hospital; the provision of a new hospital on a