e-mail to GOSE, Government Office for the South East - clarification of PPG3 § 58 and RPG9 Policy Q3 (Density)

Subject: Clarification of RPG9 Policy Q3 and §58 PPG3 (Planning Policy Guidance Note 3)
Date: 11/02/01
To: SRPG.GOSE@go-regions.gsi.gov.uk (RPG RPG)

attention Jim Ward

We sent the Summary of our comments back via fax.

As we have a serious interest in Policy Q3, could you please do an exception and comment, or point us into the direction where we could get assistance for the following :


We note that you fully adopt § 58 of PPG3 to promote higher density developments.

You confirm this as well in Policy H2 b) to which you may accept this memorandum as comment.

The interpretation of this specific paragraph which you want to adopt and refine under Policy Q3:
"b) Within London and many urban areas across ROSE, there are significant opportunities to provide high quality housing development in excess of 50 dwellings per hectare net. Local authorities should take a positive approach to developing proposals for these areas to assist in meeting housing need and improve the quality of the urban environment.",

seems to confirm that PPG3 § 58 line 3: (integrated in Policy Q3 a iii)

"seek greater intensity of development in places with good public transport accessibility, such as town, district and local centres or at major nodes along good quality public transport corridors and major cities"

meant seek 50 units per hectare.

Could you please confirm or comment on this?

A guidance, in our opinion, should not leave room for diverse interpretations.

When we approached the Planning Policy department of DETR to clarify what they meant with "seek greater intensity" (we interpreted this as 50 - being the higher recommendation), we were told that :
"Successive Governments have decided that the day-to-day planning functions, such as formulating development plan policies, determining planning applications and enforcing planning controls are best carried out by the democratically elected local councils.
The interpretation of planning guidance notes is also ultimately a matter for the courts, and it would therefore also not be appropriate for me to comment on the wordings you have highlighted."

Here in Tunbridge Wells, residents living in the neighbourhood of British Telecom’s Telephone House, a monstrous office building built in the 60’s (even featured in "Private Eye" at that time), are confronted with the redevelopment of the site seeking a density of 140 units per hectare (triple the higher level of the recommendation).
Some of the latest planning applications to TWBC were approved with densities of 20 (!) per hectare and 90 per hectare, all in the town centre, all about the same net size around 0.3 hectare.
Our case in point, The Telephone House redevelopment, was refused twice by the Local Planning Authorities, once at Planning Officers level and the second time against the advice of the officers by the members of Planning Committee. Now the developers have appealed and a Public Inquiry has been set for 1.5.01.

The residents' main concern is the extreme high density (140 unites per hectare) proposed by this developer.
The development is an abrupt change from an office building (which was known to provide jobs for the local community in walking distance) to blocks of flats for commuters.
- It lies in an area of extreme high density and cannot cope with new traffic and parking generation.
- Utility companies do not want to comment on the impact.
- Jobs "in walking distance" for the targeted buying groups are not prominent.

As long as such a dominant Policy as Q3 is interpretable at will, one surely finds a developer neglecting all amenities and trying "to pull a fast one" at the cost of others.

The case is documented on the residents’ Internet sites:
http://uk.geocities.com/telephonehouse - and

As the developers [Crest Nicholson / Southgate Developments - agent: Barton Willmore, West Malling] already quote the draft of RPG9 as documentation in their appeal statement [for the Public Inquiry May 2001], we would be glad if you could clarify this extremely relevant Policy.

signing off: Daniel Bech for
The Telephonehouse Neighbours Association
37 Church Road, Tunbridge Wells, TN1 1JT

DENSITY - cramming ? lifestyle ?
The high density development of Telephone House, Tunbridge Wells

The Telephone House Neighbours Association, Tunbridge Wells
The aims are to heighten peoples' awareness and concern for the controversial high density development on Telephone House site, Church Road / York Road, Tunbridge Wells.