On 29 September 2018 the Neighbourhood Planning Team updated the parish through a second exhibition, held at Iden Green Pavilion and attended by 97 people, including residents, landowners and a senior member of Tunbridge Wells Borough Council’s planning team.
One question raised there covered a rather important issue concerning future housing developments: why are the Steering Group looking only at the sites suggested by TWBC? Surely we should be proposing the sites the village wants (i.e. small) rather than being led by TWBC.
This is a complex matter and we are still struggling to make sure the approach we take in our plan achieves the best balance. I will try here to set out differing aspects.
First, as explained at the exhibition, the 2017 Neighbourhood Planning Act builds upon the Localism Act of 2012 and gives Neighbourhood Plans influence and some power. But we are obliged to fall in line with national and borough policies. So it is impossible to ignore TWBC policy, although we can influence how that policy is applied.
Secondly, the size and number of sites made available. We can look only at sites that landowners have offered. The TWBC Call for Sites yielded 20 potential locations, of which 15 were larger than one hectare, and five smaller. Of the five smaller sites only two are deemed suitable for development (and these offer space for just eight dwellings in total). The others would have a significant impact on the character and views across the High Weald.
Thirdly, TWBC are obliged by the 2012 Act to develop a plan with commercially viable sites that will enable developers to deliver each scheme within the plan timeframe. Sites with very few houses will not be regarded as commercially viable.
During our early workshops it became clear residents would like scattered development across the parish, although the Parish Plan 2015 actually suggested clusters of development in enclaves within village envelopes.
Residents also wanted to retain the existing village feel. Housing density in the parish varies but the average density in Benenden ‘core village’ is currently ten dwellings per hectare. Our ambition is to target an average density of 12.5 dph in new sites; this would avoid an urban feel to the housing, and provide green spaces and sufficient off-street parking.
At workshops, residents wanted a good proportion of affordable housing, which also featured in the Parish Plan. To deliver affordable housing, each site must provide a minimum of 12 dwellings, 35% of which will then be ‘affordable’. To put this into context, the Rydon Homes site in Walkhurst Road was approved for 12 dwellings, including four affordable homes at a density of 17 dph, the higher density being a compromise so the developer could deliver 25% affordable on a site with space for only 12 homes. So to meet our target of 100 new dwellings and ensure we provide a proportion of affordable houses we would need eight sites each with around 12-14 units; but we do not have 8 small sites available, we have 2 and a number of larger sites.
We could scatter development using the 2 small sites, and partly develop at least 7 others, but partial development will reduce the commercial viability of each site, risking rejection of our plan by TWBC on grounds with which the independent examiner would agree. Part development also presents a significant risk that the rest of the site will be developed in future years. Without clear and robust boundaries, any undeveloped part of the site will present the developer/owner with an opportunity to extend, bypassing our plan via an appeals process.
So we are also considering a few medium sized sites, containing 20-50 dwellings but at a density that allows room for new residents to enjoy their rural location, providing adequate off-street parking and, through good landscaping, making sure the impact is as sympathetic as possible. The two smallest sites could be supported, as a way of providing a degree of dispersal and reducing the dwellings targeted on the medium-sized sites.
This is a difficult problem, one where there is no perfect answer and which requires compromise and cooperation across the board. We would be very keen to hear alternate suggestions or constructive solutions.
Chair Benenden NDP Steering Committee