Memorandum - Statement of Case by The Telephone House Neighbours Association

Appeal - Telephone House, Tunbridge Wells - Public Inquiry to be held in May 2001

Crest Nicholson Plc and BT's Southgate Developments Ltd versus Tunbridge Wells Borough Council

Officers made the evidence of the Telephone House Neighbours Association not available to Junior Counsel, Peter Miller (Chambers of Anthony Scrivener QC), representing TWBC at the Public Inquiry 01.05.2001. The document was sent to him by the chairman of the Western Area Planning Committee on 20.04.2001. At the Inquiry it came to light that one of the TWBC witnesses had not even bothered to look at the statement of case of THNA.


    The opinions of residents were ignored right from the beginning, when Crest Homes and Southgate Developments filed a planning application for the first time in December 99.

    The planning notice for the first application was not even displayed in York Road.

    Two residents met Mr. Ken Munday of Crest Homes together with their architects Flanagan and Briscoe on 19th January 2000. They put forward their concerns and those of neighbours.
    At the meeting, openness and involvement was confirmed by Mr. Munday as the right step forward.

    Correspondence from Crest Homes (South East)

    The intention to be open with residents was mere rhetoric and not supported by fact.
    Their Feasibility Study to the second application reversed their promises:

    (Part C Site analysis 7.0 Planning Constraints - text: Design Analysis)
    To achieve a workable scheme it is clear that either, buildings to site frontages must be of unreasonable (!!) depth and potentially height (!!) to provide an adequate overall envelope.
    [ similar to the previous scheme rejected for this very reason ]

    With the second application, the information process within the TWBC improved somewhat.
    Interested parties were informed individually and on time of the application and revision.

    Criticism however remains, that the agenda and appraisal for the Western Area Planning Committee Meeting was available only on Friday 13 October, produced just 3 days prior to the meeting.
    This left little time to the residents to prepare their documents, let alone prepare a presentation in the way the case officer Ruth Chamber managed to do for the applicants.

    Analysis of the officers' report to the 2nd application
    for the meeting of the Western Area Planning Committee (18.10.00)

    For the appeal we request that § 3.10 of the Urban White Paper should be applied:

    people have a right to determine their future and be involved in deciding how their town or city develops. A clear message from the regeneration initiatives of the last 30 years is that real sustainable change will not be achieved unless local people are in the driving seat. It is not enough to consult people about decisions that will impact on their lives: they must be fully engaged in the process from the start; and everybody must be included.



      A development in such a sensitive area needs to be judged not just on design, but on the impact it will have on its neighbourhood as it needs to fit into the existing fabric.
      It is true that at present the property is left to deteriorate and is an intolerable eyesore.

      The Telephone House site left to deteriorate by BT within the Conservation Area

      The proposed unsophisticated clutter of 4 blocks scattered over the site, straddling the area between Church Road and York Road, is seen by the residents as being a far worse proposition than the present building.
      There is a severe lack of imagination in the layout which attempts to link incorrectly applied density standards to design quality. Increasing the density of development in urban areas should not be at the expense of green space provision.

      York Road is a road of great character and diversity, and its population reflects this. It is not and should not become an inconsequential community dominated by one strata of society, because a developer in his own words wants to build "luxury apartments and . . . . . the nature of the intended occupants is not likely to include those with young children, or families."

      The Select Committee on Environment, Transport and Regional Affairs Eleventh Report and the Urban White Paper believe that our cities and towns can only be sustainable if they have a mixed community.

      The proposed buildings do not take into consideration:

      DETR - PPG3 § 56

      New housing development of whatever scale should not be viewed in isolation. Considerations of design and layout must be informed by the wider context, having regard not just to any immediate neighbouring buildings but the townscape and landscape of the wider locality. The local pattern of streets and spaces, building traditions, materials and ecology should all help to determine the character and identity of a development. . . .
      Create places and spaces with the needs of people in mind, which are attractive, have their own distinctive identity but respect and enhance local character.

      Urban White Paper

      - Better planning and design

      4.12 Where there is a need or opportunity for new development in towns and cities we must ensure that it is of the highest quality. In particular we must ensure that it:

      • makes the best use of the land we have available; and
      • is built in a sustainable way that is sensitive to the needs of people and the impact urban living has on the environment.

      Kent Design

      - 6. Locality

      6.3: New development should respect local architectural heritage, make optimum use of existing buildings and recognise landmark buildings and features.

      6.6: New design should avoid a confused application of architectural styles or inappropriate historic imitation

      Vision for Kent

      - 8. Nurturing the Identity of Kent

      Our committment
      We encourage new developments to reflect Kent’s history and character.

      The massing of a development should respect the setting and spatial layout of historic buildings and structures. Trinity Church, the most prominent neighbouring building of Telephone House was the focus of the Calverley Estate and was judged as a main landmark for decades.
      Most local residents would be happy to accept a design reflecting the architecture of Decimus Burton.

    2. DENSITY

      Our main concern is that the high degree of density for the proposed development, is not suitable for this area.

      York Road is certainly not a street which needs to be revived. Due to its prime location it is a very popular street for professional and semi retired people leading an active live.
      The radical solution proposed for this development would maybe attract sufficient urban pioneers back into collapsing inner neighbourhoods of Manchester or Liverpool, but certainly not into York Road, where as a consequence present residents would be forced out of a closely knit community and would be likely to cause a downturn of the houses and road in general. This is not justifiable.

      The extreme density of the north side of York Road and the immediate vicinity of Dudley Road to the North, is only bearable because of the open spaces delivered on its front.
      Viewing it in the context with Dudley Road and Limehill Road, the area already has to cope with an inadequate density. The partially irresponsible conversions of older town houses in the past into 4 or more flats of small living areas even now bring with them the problems of an overcrowded area including noise, pollution and parking problems.

      Not enough jobs are created locally to accomplish the dream, that people can just walk to their workplace.
      This particular development with its high level entrance prices, is obviously targeting extremely well earning, single people only; assuming we can take Crest Homes’ statement, to avoid recreational open space, seriously (The nature of the intended occupants is not likely to include those with young children, or families.).
      Job opportunities for this group are rare in the town centre.
      It is likely that the target market therefore will be commuters, something Vision for Kent clearly aims to reduce.

      In an area where one knows that an inadequate density is presently causing problems why would one squeeze an even bigger population into it ?

      Clearly quality is more important than mere quantity, yet the application by Crest Homes and Southgate Developments ignores this fact.

      The following policies are relevant:

      DETR - PPG3 § 58

      Local planning authorities should therefore:

      • avoid developments which make inefficient use of land (those of less than 30 dwellings per hectare net )
      • encourage housing development which makes more efficient use of land (between 30 and 50 dwellings per hectare net); and
      • seek greater intensity of development at places with good public transport accessibility such as city, town, district and local centres or around major nodes along good quality public transport corridors.

      The interpretation of this specific paragraph by the residents is:
      that greater intensity is 50 dwellings per hectare, which would interprete into 16 dwellings in the case in study. Concerning the third point one imagines that the authors of the Planning Policy Guidance meant by stating "seek greater intensity" that the higher level of the recommendation at 50 units per hectare net would be the absolute limit, but certainly not 140 per hectare net as proposed.

      e-mails to the residents: re: PPG3
      • (paul martin)
      • (dan clay)

      DETR - Housing in the South East:
                  The Inter-relationship between Supply, Demand and Land Use Policy

      - Housing supply

      18. The largest single source of potential re-used urban sites is land which is in employment use (or zoned for that purpose) yet there is a strong reluctance on the part of many local authorities to release employment land for housing development. Furthermore, the local economic consequences of losing potential employment land to housing are little understood and need to be demonstrated.

      - Housing demand

      38. We found evidence from both local authorities and house builders that there is a market for an alternative product, built to higher density in urban areas. What is not clear is how big that market is, or whether it reflects consumer preference or consumer resources (i.e. whether the main constraint is affordability). What must be recognised, however, is the need to establish more clearly consumer preferences, the depth of demand, market viability and mechanisms for actually translating the potential into reality.

      Urban White Paper

      - Using space well

      4.15 We also build at very low densities and, in the past, have squandered land. Recent housing development in England has been built at an average of 25 dwellings per hectare. That compares unfavourably with the 35-40 dwellings per hectare of many of our older suburbs – made up of semi-detached and terraced houses with gardens – and with current development densities in many other countries.

      - The way forward

      4.21 This does not mean cramming people closer and closer together. It means development at reasonable densities which protect open spaces and respect the need for privacy. We know from experience in this country and abroad that, with good design, it is possible to create places which fulfill all these ambitions and which people want to live in.

      Kent Design

      The density of a development should respect local character and respond to existing densities in different locations such as brownfield, greenfield, central, peripheral, town and village. This does not mean simply replicating surrounding layouts but drawing clues form these surroundings as to the range of new densities that may be appropriate. This range should be defined for each locality. An appropriate mixture of densities to increase legibility and create choices in an expanding housing market should be encouraged.
      The UK Strategy for Sustainable Development comments on density as, ‘a dynamic process, but the limits and thresholds must be understood . . . ‘

      Vision for Kent

      "The Vision for Kent" foresees revitalised town centres in order to increase the housing and employment capacity of towns and not "town cramming"

      (UWP 53) Select Committee on Environment, Transport and Regional Affairs

      In seeking to undertake successful urban regeneration there must be recognition that the quality of the environment is an important component in the quality of life of existing and potential residents. There must not be a headlong rush into "town cramming" with high-density development, which does not respect the existing historic and environmental fabric of an area. Opportunities should be taken to improve the quality and extent of open space provision.

      (UWP 78) Select Committee on Environment, Transport and Regional Affairs

      The Government's concern to increase densities in urban areas may have the effect of making them less attractive to certain parts of the population. It was unfortunate that KPMG did not consult with mortgage lenders about the types of options that might stimulate, and more importantly, sustain property values in urban areas.

      Nowhere can we find any reference that the proposed density level of 140 per hectare is desirable and worthy of promotion in historical town areas.

    3. TREES

      In a letter Daniel Docker of TWBC, dealing with arboreal issues, writes to us that: "the benefit of the retention (of the trees) is weighted against the potential benefits of the proposed development."

      He did not provide any clue to what he thought are the "potential benefits".

      He continues in his letter: "on balance the potential contribution of the development to the surrounding area was felt to outweigh the benefit that would be gained by their (the trees) retention."

      Daniel Docker confirms to us that one of the grounds of refusal for the first application was:
      "The proposal would involve the removal of significant trees which would be contrary to Policy EN1(3) of the Tunbridge Wells Borough Local Plan 1996."

      All the more surprising then that the reasons why the trees should not be retained are omitted. The layout of the second application is the same in terms of streetline as the first application.

      Study: The group of trees on the Telephone House site
      Study: The street and building line of York Road south side

      The relevant guidelines are:

      DETR - PPG3 § 52

      The Government attaches particular importance to the 'greening' of residential environments:
      . . . . . Landscaping should be an integral part of new development and opportunities should be taken for the retention of existing trees and shrubs

      Kent Design

      10.2. New development should respond to site characteristics . . . . . and minimising any impacts.
      10.2.1 . . . conserve or enhance existing natural features.
      10.2.2 Features of landscape importance or nature conservation value should be retained . .

      Tunbridge Wells Borough Local Plan

      EN5(6) The proposal would not result in the loss of trees, shrubs, hedges or other features important to the character of that part of the Conservation Area in which the proposal would be situated.

      Royal Tunbridge Wells Conservation Area Appraisal

      Contribution of green spaces, trees and hedges

      (9.7.14) The town centre is densely developed, and trees and planting are much less widespread than in surrounding areas. However, this can even focus the importance of planting and landscape where it forms part of the townscape. The avenue tree planting in lower Mount Pleasant Road is a prime example, and it lends the quality of a pleasant promenade to the street that perhaps reflects that of the Pantiles, and certainly is a model that might be extended elsewhere in the main town centre streets. In Church Road, some street planting survives in front of Clarence Terrace (Nos. 16-22), and further trees could be re-introduced into the street.
      (9.7.15): Mature planting behind the main streets is also of importance in the town centre. . . .
      . . . . . but there is a noticeable lack of planting otherwise.


      Study: Parking Spaces in the Vicinity of the Telephone House
      Study: Traffic Flow around the Church Road / York Road Block

      The dependency of cars not being promoted nowadays by the government is nevertheless prominent.

      The relevant governmental notes are:

      DETR - Housing in the South East:
                  The Inter-relationship between Supply, Demand and Land Use Policy

      - 18. . . . . . issues related to urban housing land

      In the south east there is a strong car culture and it is not axiomatic [obvious] that either customers or local authorities are prepared to accept the reduction in car parking and access standards that would be required to achieve dramatic increases in density in urban areas without very substantial improvements in public transport provision.

      - 37. Demand for housing . . . . .

      For the affluent majority, quality of life appears to encapsulate both the space and safety traditionally associated with suburban living and the freedom to use and store their car.


      The demolition being expensive to the developer, will become a real problem to the environment if strict conditions and controls by local authorities are not imposed. The residents request to participate in the process to find a solution for this impact on their neighbourhood.

      We understand that the planning application No. TW/00/01480 for the demolition was withdrawn.


    The suspicion is that proposals from potential developers / applicants are always passed at appeal stage.
    We hope however that you will consider this matter objectively, giving due regard to the well-founded objections by the residents and that the material return for the applicant is not the overruling consideration.

    Should this appeal be upheld, this would mean that John Prescott’s Urban White Paper with its provision to put local people in the driving seat would be completely ignored.

15 January 2001

The Appeal - Crest Nicholson Plc / Southgate Developments versus TWBC

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, Kent, TN1