Tonbridge Line Commuters has responded to the “Regulation 18” consultation on the Tunbridge Wells Borough Draft Local Plan. This envisages significant housing developments in Paddock Wood and Capel areas. We are concerned about the impact these developments would have users of rail services and public transport in the local area, and have set out the key issues in our response. The full text of our response is below.
Response from Tonbridge Line Commuters to the “Regulation 18” consultation on the Tunbridge Wells Borough Draft Local Plan
As a rail user group, our comments are strictly limited to the impact of this development on the transport infrastructure in the area. Tonbridge Line Commuters (TLC) is a recognised rail user group, representing the interests of rail passengers from Tonbridge, Paddock Wood and Hildenborough. We have three main areas of concern around the draft plan.
In proposing the volume of housing and the concentration of residential development in the Paddock Wood and Capel areas Tunbridge Wells Borough Council does not address adequately the impacts of an inevitably large increase in rail commuting that would result.
Access to Stations. TWBC proposes prioritising development in the Paddock Wood and Capel areas of the borough, partly because these areas have convenient access to local railway stations (Paddock Wood and Tonbridge). However, none of the allocated sites are within reasonable walking distance of those stations, and realistically, cycling is going to remain a minority choice. Without a very significant provision of high frequency (minimum 15 minute intervals) shuttle bus services running from 06.00 to at least 21.00 on weekdays, the majority of trips to and from stations are going to be by car, either as drop-off/pick-up journeys, or with associated parking around the stations.
We note that bus provision is outside the remit of TWBC, and is Kent County Council’s responsibility. We therefore have very low confidence that TWBC would be able to adequately ensure that suitable bus services will be introduced as developments take place.
Existing road access to both Paddock Wood and Tonbridge stations is via congested and relatively narrow town centre roads. Especially in Tonbridge, traffic at peak times is already heavy and slow moving and there is limited opportunity for improvement (and in the case of Tonbridge, not in the remit of TWBC). TLC is of the opinion that any local development that is likely to increase car traffic to and from these stations is unsustainable.
Station Parking. On the assumption that the proposed developments go ahead without mitigation of the station access issues noted above, once passengers reach the station there is very limited capacity for additional parking at existing facilities in either Tonbridge or Paddock Wood. In theory, it would be possible to provide more parking by converting the existing surface car parks in both locations to multi-deck parking, as has already been partially implemented at Tonbridge. This, however is a very expensive option and it is not clear where any funding would come from, especially as the existing parking infrastructure is not under the control of TWBC (being owned by Network Rail or Tonbridge and Malling Borough Council). Our analysis, supported by Tonbridge and Malling Borough Council, suggests that the majority of people would drive to Tonbridge station (not going back on yourself and much greater choice of services). TLC believes that the significant increase in parking that would be required would not be achievable.
Passenger Capacity. The existing train services from Paddock Wood and Tonbridge into London are already nearly full at peak times, and there are housing developments underway further down the line from Ashford to Tonbridge. The vast majority of rush hour trains in this area are already 11 or 12 cars and so extending the remaining services would add very few seats and not nearly enough to cope with the influx of commuters this development will bring. The trend towards part-time commuting may provide some respite but is not, in TLC’s opinion, sufficient to offset the likely extra demand that some 9,000 homes in the Paddock Wood and Capel area would generate.
Looking to the medium term, Network Rail’s Kent Area Route Study states (paragraphs 6.9.4 and 6.9.5) that routes via Tonbridge are most in need of extra capacity but providing any extra capacity between 2024-2044 is “challenging” and there are no practical or fundable schemes for doing so. Such capacity improvements would require expensive and innovative solutions such doubling 2 track section between Tonbridge and Orpington to 4 tracks. Other issues include power supply limitations and lack of capacity at the Charing Cross terminus, which could not be addressed without a major rebuild of the station. The Kent Area Route Study makes clear that the rail industry simply has no plans to solve these issues. To do would require huge investment from Central Government and is certainly beyond the 15 year horizon covered by the draft TWBC Local Plan.
All of the likely train overcrowding mitigation measures are outside TWBC’s capability to directly influence. Realistically, should these proposals go ahead in their current form then commuting from this area into London will become an intolerable experience.
As a result of the concerns above, we cannot support these proposals.