Gagging orders on borough councillors and landowners, the threat of compulsory purchase orders, secretive meetings in Ebbsfleet, non-consultation with parish councils and communities… Maidstone Borough Council was accused of all these and more during a heated meeting last night (Tuesday, October 15) on proposals for a Lenham ‘garden town’. The hall at Lenham Heath was not large enough to accommodate everyone who had come to this first protest meeting against the potential new town. People stood outside and listened to claims of misbehaviour by the council in relation to the plans. None of the parish councils of Egerton, Charing, Boughton Malherbe, Harrietsham or Lenham had been consulted on the garden-town proposal. County councillor Shellina Prendergast and a representative for local MP Helen Whateley confirmed they too had only learnt from the media what was ‘planned for’ Lenham. Tom Sams and Janetta Sams, who had organised the meeting, stated that they could disclose everything they knew on Monday, November 4, but not before. They and fellow independent councillor Eddy Powell were challenged over supporting the proposals from the council, where the Liberal Democrats rely on the support of the independents for their controlling administration. Much emphasis was put on whether MBC was within its rights to behave in the way it had done, while it was accused of predetermining a process that should be decided democratically. Henny Shotter, a CPRE Kent member, said at the meeting: “The whole proposal is bonkers. No roads, no sewage infrastructure, this proposed development is the furthest possible from any employment centre in Maidstone, Ashford, the Medway Towns or Tonbridge and Malling. “The suggestions to build a high-speed railway station so close to Ashford or a motorway interchange are financially unrealistic. They just cloud the fact that the proposal, as far as we know it, is completely and irredeemably unsustainable.” If you want to support the action group, please get in touch with Kate Hammond on 07925 607336.
It’s been described as “the biggest threat to Tonbridge and our Green Belt in a generation” and indeed plans from Tunbridge Wells Borough Council for mass housebuilding seem set to change landscape and life in west Kent in an almost unimaginable way. The proposals for 2,800 new houses at Tudeley and another 1,500 at East Capel sparked the creation of Save Capel and last month John Wotton, CPRE Kent chairman, gave a speech to the campaign group pledging this organisation’s support in the bid to halt a policy destined to ruin the quality of life for so many. Here is that speech, made on Wednesday, September 18, in full: “CPRE is the countryside charity. It exists to protect the English countryside, to make sure it is valued and accessible to all and that it supports a viable and sustainable rural economy. “Here in Tunbridge Wells, we are privileged to live in the beautiful and historic farmed and wooded landscape of the Weald of Kent. We are all custodians of the countryside, none more so, I would suggest, than our local planning authority. “So, how does the draft Tunbridge Wells Local Plan measure up in terms of protecting our cherished countryside? Not well, in my estimation. “The plan is, of course, the product of a broken planning system, driven by political and commercial interests that are wholly divorced from the needs of the population as a whole and wishes of local communities, including this one. “It is inconceivable that Tunbridge Wells Borough Council would have come up with a plan of this nature in the absence of the housing and other targets imposed by national planning policy. “There is now no pretence that the targets are based on genuine predictions of household growth and housing need, for the most up-to date Office of National Statistics data on population growth and household formation have been ignored by national government, in order to adhere to a totally arbitrary and unachievable target of building 300,000 homes a year (that is homes built anywhere and of any type, regardless of housing need). “The rationale for this target has been challenged in recent research by Ian Mulheirn, published by the UK Collaborative Centre for Housing Evidence, which concludes that no more than 160,000 homes per year need to be built to cater for housing need. “This topic is highly controversial, but for us in Tunbridge Wells, the key point is that the right homes for the people in this borough are built in the right places. “The homes which are built should be affordable to those in need of a home and built in the most environmentally sustainable places, not simply the sites that yield the highest profit to developers. “This means that houses should preferably be built on brownfield or urban infill sites, or as limited urban extensions, always making the most efficient use of land, rather than in new settlements on greenfield sites, and especially not in protected landscapes. “The council seems to agree with this in principle, but not in practice. CPRE naturally wishes to see Tunbridge Wells adopt a sound Local Plan as this will give the local authority a measure of control over future development and better defences against inappropriate, speculative development proposals. “However, a sound Plan is not a panacea. Factors beyond the council’s control may (and probably will) undermine the Plan during its 15-year life, probably sooner rather than later. “These factors include changes in the deliverability of individual sites, failure to build out planning applications which have been granted and, in these febrile political times, changing requirements of national policy. “As soon as the council’s housing policies are shown to be out of date, the developers will again have the whip hand. “A ‘Sound Plan’ is therefore not to be bought at any price and the price of this draft Plan is, in CPRE’s view, far too high. “Tudeley Village is just the most egregious example of the sacrifice of greenfield sites for substantial housing development in the Green Belt, in the High Weald Area of Outstanding Natural Beauty and elsewhere in the borough. “This sacrifice is made in pursuit of housebuilding objectives that, even in the unlikely event of their being achieved, would do little to meet the genuine local need for housing, at prices local people can afford. “The council say that they place the highest priority on protecting the AONB and then the Green Belt, but this is not the impression I gain from the proposed site allocations throughout the borough. “If Tudeley Village is intended to relieve the pressure on the rest of the borough, it does not achieve this, even in protected areas. In my own parish of Cranbrook and Sissinghurst in the AONB, for example, the housing allocation exceeds assessed local needs by about 50 per cent. “What can the council do, though, in the face of seemingly implacable national policy requirements? “In our view, national planning policy does allow Tunbridge Wells to provide for less than the so-called objectively assessed housing need, in view of the high proportion of the land in the borough which is protected as Green Belt or AONB. “This ability is fundamental to the effective protection of the Green Belt and AONBs. If it were not there, the Green Belt and AONB would be less protected in those districts in which they form a large proportion of the land area than in those where only small areas are protected. “This is not the law, or the policy of government. “The council say that they have not even considered the possibility of providing for less than assessed housing need, because their Strategic Housing Land Assessment shows that the borough can accommodate this need. However, it is hard to see how they have reached this conclusion. “Their Sustainability Assessment shows that the council’s housing objective is compatible with only five of the 19 sustainability objectives they have set themselves and incompatible with nine of them. “It is the only objective in the Plan which fails the council’s sustainability tests in this way. This is a fundamental contradiction in the Plan. It does not provide for sustainable development in Tunbridge Wells on the council’s own terms, and it must be changed. “I haven’t said much about how the technicalities of planning policy apply to the overarching subject of the climate emergency, which rightly moves ever higher up the political agenda, including the planning agenda. “It is far from clear to me that the council gives adequate weight to mitigating climate change in this Plan. That is a wider topic than we can embark upon today, but an aspect of it is specifically relevant to the Tudeley Village proposal. “Under the government’s climate change guidance, planning authorities are advised that the distribution and design of new settlements and sustainable transport solutions are particularly important considerations that affect transport emissions. “The planning inspectors have within the past week rejected the draft West of England Spatial Plan, saying that high levels of dispersed development across the West of England, unguided by any strategy, would not be sustainable. I understand that this Plan included a number of so-called ‘garden settlements’ on greenfield sites. “It would seem that garden settlements are going to be looked at closely by inspectors and this should make Tunbridge Wells Borough Council think twice before trying to meet its housing objectives in this way. “Tudeley Village is the poster child for the unsustainability of this draft Plan. It represents unsustainable, environmentally harmful destruction of the countryside, replacing a beautiful, unspoilt and protected site with a dormitory for City commuters and their families, heavily reliant on their private cars for transport. “It will destroy local communities and ruin local residents’ lives. It must be stopped and CPRE Kent will support you in your campaign.”
You can read the latest Save Capel newsletter here
Members, partners and supporters of CPRE Kent pulled on their gloves and grabbed their litter-pickers as they joined other branches, community groups and volunteers to tidy up green spaces and countryside in a collective assault on rubbish. Evidence from CPRE’s Green Clean will be used to highlight the urgent need for a deposit return system that includes drinks cans, plastic and glass bottles, cartons and pouches. Last year, hundreds of bags of litter and more than 11,000 drinks bottles and cans were collected, demonstrating the need for an ‘all-in’ deposit return system (DRS). This evidence helped make the case to former environment secretary Michael Gove, who gave his backing to an all-in system, stating it would give consumers “the greatest possible incentive to recycle”. CPRE will use this year’s Green Clean to demonstrate that the problem persists and urge current environment secretary Theresa Villiers to pick up where her predecessor had left off, introducing the best scheme as swiftly as possible. In Kent, litter-picks were held at Graveney and Folkestone. Volunteers at Graveney were joined by Sarah Merrington, CPRE’s deputy director of volunteering who has just moved to the county, and her sons Oliver and Billy. Sarah told Kent Voice: “Oliver and Billy are brand-new litter-pickers – and they absolutely loved it. It’s one of the relatively few occasions I have kept them engaged in one activity for more than about 20 minutes! “They love being active in the countryside and litter-picking really helps bring to life learning about environmental issues and their own role in looking after our countryside. They worked really well together as a team – it was lovely to see.” Welcome to Kent, Sarah!
The Stop Gatwick Expansion Roadshow heads to a venue just over the county border this month – and you are warmly invited to go along. Groombridge village hall is hosting the roadshow on Saturday, October 12, from 2pm-5pm; the event has been organised by the Campaign Against Gatwick Noise Emissions (CAGNE), helped by the Tunbridge Wells and Wealden Green Party. A CAGNE committee member will be on hand to talk to visitors about the issue of noise pollution relating to Gatwick airport. To learn more about CAGNE, click here
Staff members and volunteers from CPRE Kent travelled to Westminster on Monday (September 9) to support campaigners against proposals for the country’s largest solar farm, at Cleve Hill, near Faversham. They were among a group of some people 50 who travelled to Parliament to listen to a debate on the impact of the plant on Graveney Marshes. It had been secured by Faversham and Mid Kent MP Helen Whately, but unfortunately the chaos of the day, which saw Parliament suspended by the Prime Minister, meant it didn’t get to be held. The adjournment debate, whereby the House of Commons is adjourned for a debate on a topic without a substantive motion being considered, is now due to held next month (October). The campaigners’ trip was organised by Graveney Rural Environment Action Team (GREAT), who brought a to-scale model of one of the raised platforms needed to support the solar panels, demonstrating the height of the development.
For more on the Cleve Hill proposals, see here, hereand here
To a mixture of horror at what it
includes and relief that it has finally seen the light of day, the Tunbridge
Wells draft Local Plan has finally been published.
Covering the period 2016-2036, the Plan is aimed at replacing the local authority’s
2010 core strategy, 2016 site allocations plan and saved policies from its 2006
Most contentiously, the draft looks to axe more than 5 per cent of the
borough’s Green Belt, primarily to accommodate 14,776 new homes, a figure that
includes a 9 per cent buffer above the government’s Objectively Assessed Need
total of 13,560.
The homes are apparently going to be built at a rate of 678 a year, a target
substantially more than double the 300-a-year featured in the 2010 core
strategy, produced in line with the former South East Plan.
Disappointingly, the draft does not designate any land to compensate for the
Green Belt that is set to be lost, which, as it stands, amounts to 5.35 per
cent of the current total.
The largest housing allocations are at Paddock Wood (4,000 dwellings in addition to the 1,000
already allocated) and Tudeley (2,500-2,800, with some 1,900 to be built
during the Plan period), as well as some 800 dwellings in the AONB at Cranbrook and 700, also in
the AONB, at Hawkhurst.
Liz Akenhead, chairman of CPRE Kent’s Tunbridge Wells committee, said: “The Plan states that, overall, some
5.35 per cent of the Green Belt within the borough is to be de-designated and
that ‘in accordance with the NPPF the Plan does not designate other land as
“replacement” Green Belt to replace that to be removed, but rather sets out how
compensatory improvements to the environmental quality and accessibility of
remaining Green Belt land can be made’.
“On a first reading, I have not noticed any evidence in the Plan that these
improvements will actually materialise.”
Consultation on the draft Plan begins on Friday, September 20, and is scheduled
to end on Friday, November 1. It is anticipated that the Plan will be adopted
in December next year.
For more on the Tunbridge Wells Local Plan, see here
A staggering total of almost 29,000 responses to the public consultation has caused Highways England to delay its planning application for the Lower Thames Crossing. The second tranche of consultation on the £6.8 billion road scheme pulled in 28,493 responses, meaning HE needs more time to analyse any new information and views. Chris Taylor, HE director of complex infrastructure, wrote in a project update: “We’re now considering the consultation responses in detail as we continue to improve the design of the project. “We’ll also be using the information gathered from our ground investigations programme to ensure that our project is delivered in a way that has the smallest possible impact on the nearby communities and environment. “To do this effectively, we will need more time to develop our planning application (Development Consent Order application), which we now plan to submit in summer 2020. “This, however, does not impact the target road-opening in 2027 as we’ve done more work to our schedule to speed up the construction programme.” Almost 15,000 people are reported to have visited some 60 LTC consultation events, while many thousands more got involved with the scheme online. Work began in July on more than 700 tests in Kent and Essex aimed at identifying what the 14.5-mile road, including tunnelling, will be built on and through. Project director Tim Jones said: “The complex programme of tests and surveys we’re embarking on here will enable us to better understand the ground conditions, and help us build it safely, in a way that protects the environment while keeping costs down. “This preliminary work will help us to give the clearest possible picture of what will be involved in building the new crossing when we apply for planning consent and help ensure our construction programme can get the new road open for 2027. “Our priority right now is to carry out the ground investigations in a way that will have the smallest possible impact on the environment and nearby communities.”
For more on the Lower Thames Crossing, see here, here and here
A village in Swale that has already hosted substantial numbers of new houses in recent years is likely to see almost 500 more. The latest plans come from local operation G H Dean and Co, which is seeking outline permission to build up to 466 houses and a village hall in Iwade; the scheme also includes a nursery, along with a bid for full planning permission for a country park. The properties would range from one-bedroom flats to five-bedroom houses. The proposed sites, which would be accessed primarily from Grovehurst Road as well as The Street, have been allocated for development in the borough council’s 2017 Local Plan. Agent Hume Planning Consultancy said in its document: “The development proposed in this application would add a further 466 dwellings to the east of the village, where the land is considered most appropriate for new housing, as set out in the 2017 Local Plan. “The village of Iwade has expanded considerably since it was first identified as a growth point in the 1990s, with some 1,200 new homes completed since.”
To see the plans, visit swale.gov.uk/planning and search for 19/503974/HYBRID
A record 2,300 people took part in this year’s Star Count. The count, held over the first three weeks of February, revealed that just 2% of participants experienced the wonders of a truly dark sky full of stars, due to the impact of light pollution caused by street lighting and other artificial lights, even in the countryside. CPRE is calling for action to tackle light pollution and enable more people to enjoy the beauty of a starry sky. The cosmic census, which was supported by the British Astronomical Association, aimed to promote dark skies and engage people in the wonders of stargazing. Star-spotters submitted the number of stars they could see within the constellation of Orion and the results used to create an interactive map displaying people’s view of the night sky. But it also demonstrated the impact that light pollution is having on people’s view of the stars. Well over half of all participants (57%) failed to see more than 10 stars, meaning they are severely impacted by light pollution. In contrast, only 9% of people experienced ‘dark skies’, counting between 21 and 30 stars, while just 2% experienced ‘truly dark skies’ and were able to count more than 30 stars – half the proportion of people able to do so during the previous Star Count, in 2014. CPRE suggests the results show we can do more to combat light pollution. Given its detrimental impact – not just on people’s view of the night sky but also the behaviour of nature and wildlife, as well as human health – we are urging the government, local councils and general public to do more to limit the impact of artificial light from streets and buildings. Emma Marrington, dark skies campaigner at CPRE, said: “We’re hugely grateful to the many people who took the time to get out and take part in our Star Count. But it’s deeply disappointing that the vast majority were unable to experience the natural wonder of a truly dark sky, blanketed with stars. Without intervention, our night sky will continue to be lost under a veil of artificial light, to the detriment of our own health, and the health of the natural world. “The Star Count results show just how far-reaching the glow from streetlights and buildings can be seen. Light doesn’t respect boundaries, and careless use can see it spread for miles from towns, cities, businesses and motorways, resulting in the loss of one of the countryside’s most magical sights – a dark, starry night sky. “By using well-designed lighting only when and where it is needed, investing in street light dimming schemes and considering part-night lighting – which should of course be done in consultation with the local community and police – councils have a fantastic opportunity to limit the damage caused by light pollution, reduce carbon emissions and save money.”
See the interactive map showing people’s view of the night sky here
The new ‘villages’ of Ashmere and Alkerden in north Kent have moved a step closer with the approval of their masterplans and design codes. Some 4,600 homes are planned for the area of Ebbsfleet known historically as Eastern Quarry but that has since been renamed Whitecliffe. The approval by Ebbsfleet Development Corporation’s planning committee backs an urban park running through the middle of it. The 667-acre site is owned by Henley Camland. Michael Cassidy, chairman of the Ebbsfleet Development Corporation board, said: “The process of giving planning permission for the ‘look and feel’ of the main next phase of housing at Ebbsfleet Garden City marks a historic turning point in the ambitions for this flagship enterprise. “It shows how intelligent use of planning powers and cooperation from landowners and developers can bring matters to a speedy conclusion and a quality outcome that befits a garden city.” Alkerden is intended to host a new ‘market centre’, with commercial, retail and community facilities and new homes. There will be a primary and secondary education campus, library, sports facilities and mixed-use centre with shops and cafes, business space, a doctors’ surgery and gym. Ashmere will reportedly contrast Alkerden with its “Kentish-influenced” design and commitment to garden city principles. Social-housing provider Clarion and developer Countryside have agreed to build up to 2,600 homes there. At nearby Castle Hill, work has already on a planned community of 1,600 properties.
In another blow to Canterbury’s rapidly diminishing
countryside, a High Court judge has dismissed an attempt to stop the building
of hundreds of homes to the east of the city.
The A28 Environmental Crisis Group had sought judicial reviews of the city
council’s approval of two neighbouring developments, one for 250 homes at
Hoplands Farm, Hersden, and the other for 370 at Chislet Colliery, a site that
had not been allocated in the Local Plan for housing.
The group’s case was based primarily on the argument that the local authority
had not taken into account the joint impact of the two schemes, especially in
relation to nearby Stodmarsh National Nature Reserve.
However, on Wednesday last week (July 24) Mrs Justice Lang ruled against the
challenges, concluding that the council had made the decisions lawfully.
The judge also denied the campaigners permission to appeal. However, Antonie
van den Broek told KentOnline that his campaign group would indeed be trying to
take the case to the Court of Appeal.
“Favourable rulings would potentially have set significant precedents for local
authorities and developers throughout the UK,” he said.
“But this is not the end of the story. We think errors have been made by
Canterbury City Council and the developers.
“This particular judge has said otherwise and also refused our applications for
permission to appeal her decisions, but we are going to take this to the Court
“These things are never about whether something is a good idea or not. It’s
about whether the law was followed.
“It’s an unusual situation in that there are two developments side by side and
by two different companies.
“Therefore, the law deems them as separate. We’ve been arguing you can’t do
that with the impact on the environment. The environment doesn’t care whether
it’s one developer or two.”
A Canterbury City Council statement read: “Between them, the two developments
will provide up to 620 much-needed homes for local people, together with
medical outlets, shops, open space and other benefits.”
Ian Thomas, chairman of the council’s planning committee, added: “We are
naturally pleased to have won both of these cases, which will allow these
important housing developments to go ahead.
“It is becoming increasingly common for opponents to new homes to launch these
types of legal proceedings. We are always very careful to ensure we follow all
the right procedures, so that if we do end up in court, we have a good chance
The decision follows a failed attempt to overturn planning permission for more
than 1,000 new homes in the Thanington area of south Canterbury.
The city council had, in July 2016, given Pentland Properties permission to
build up to 750 properties on a 73-hectare site at Cockering Farm, while in
November last year Quinn Estates was granted outline consent for up to 400
homes on a neighbouring site off Cockering Road.
Campaigner Camilla Swire then won permission to seek a judicial of the Quinn
planning permission and the council’s approval of variations to the Pentland
Properties consent, arguing that the two developments should have been
considered as a “combined masterplan”.
By the time the case came before a High Court judge, however, building had already
started on the first phase of the Pentland development, following the council’s
approval of reserved matters.
Both sites, which lie close to the Larkey Valley Wood Site of Special
Scientific Interest and in a designated Area of High Landscape Value, are
treated as a single unit in Canterbury’s Local Plan, but, with them in
different ownership and being developed separately, it was argued by Ms Swire
that the local authority had breached its own policy through failing to have
the combined masterplan.
In response, the council claimed any potential breach was merely a technicality
and that, in reality, the impact of both developments had been considered
Mr Justice Stuart-Smith appeared to concur, saying all that was missing was “a
single piece of paper” showing the two planning applications had been
considered alongside each other.
He refused the judicial review, concluding that a combined masterplan “would
have made no difference whatsoever” to the outcome of the planning
Manston airport: the very name raises more than the odd eyebrow and elicits any number of sighs, but this month’s twist in a seemingly never-ending story caught out just about everyone. Just as the Planning Inspectorate’s examination into its application for a Development Consent Order was nearing its end, RiverOak Strategic Partners agreed to buy the airport site for £16.5 million from Stone Hill Park Ltd, which had its own plans to build some 4,000 homes, business units and sporting facilities there. Three representatives from CPRE Kent (director Hilary Newport, Thanet chairman David Morrish and environment committee member Chris Lowe) had been present at various stages of the inquiry, which was led by a four-strong Examining Authority. The Planning Inspectorate gave public notice that it had completed its examination on Tuesday, July 9, confirming that its findings, conclusions and recommendations would be sent to the Secretary of State for Transport, Grant Shapps, no later than Wednesday, October 9. Mr Shapps will then decide whether the airport scheme should be regarded as a Nationally Significant Infrastructure Project and a Development Consent Order approved; it is unlikely that the recommendations of the Examining Authority will be made public until after that decision is made. Contracts were exchanged between RSP and SHP on Wednesday, July 3, but the deal could only be completed a week later (July 10) once permission had been given by then-Secretary of State Chris Grayling. That permission was necessary due to a Special Development Order designating Manston’s use as a lorry park to cope with potential post-Brexit congestion at Dover – the contract for that runs until December 31, 2020. SHP has withdrawn its objection to the DCO and will no longer take part in the Local Plan inquiry. However, it keeps its DfT contract (and payments) in relation to the Brexit lorry-park plan, while it will be responsible for providing equipment should HGVs need to use the site. The deal leaves RSP subsidiary RiverOak MSE owning more than 95 per cent of the site required for its airport plans; the compulsory-purchase provisions of the DCO are now not essential for the reopening of the airport. SHP reportedly owned 742 acres of the 770-acre site, with some plots belonging to other parties. Mr Morrish, of Thanet CPRE, said: “These events have emphasised the need for Manston to be resolved before the draft Local Plan can be properly considered – a view that we at CPRE have consistently put forward. “Manston airport has been the elephant in the room throughout the Local Plan inquiry and there is still no real point in the Local Plan deliberations continuing until the Secretary of State for Transport has made a binding decision on the DCO.” It is understood that RSP will only be able to progress its airport plans if the Transport Secretary approves the DCO application, a Planning Inspectorate spokesman telling KentOnline: “In order to construct and operate a Nationally Significant Infrastructure Project, development consent is required in the form of a Development Consent Order.”
This is something most of us would surely like to see more often: housing development on brownfield sites. Proposals for 185 new homes in two such locations have been approved by Dover District Council’s planning committee. Planning permission was granted for 150 homes at the former Buckland Hospital site, with backing for another 35 at the former Stalco engineering works in Great Mongeham. Both brownfield sites were allocated for housing development in DDC’s Allocations Local Plan. Nick Kenton, DDC’s portfolio holder for planning, said: “I welcome the committee’s decision to approve these sites for housing development, which will go some considerable way towards meeting the target set by the government to build 629 new homes in the district every year. “The development of brownfield sites is challenging but one that we need to embrace if we are to reduce the pressure to build on greenfield sites.”
Christine Drury, who CPRE Kent members will know through her time as branch chairman, was presented with a Lifetime Achievement Award at this year’s national conference in Birmingham. Christine stood down from her five-year Kent role at last year’s AGM, held at Lenham in November, while her time on the national trustee board came to an end this year. She is now a CPRE national vice-president. The Lifetime Achievement Award “recognises some truly exceptional individuals who have helped CPRE in extraordinary ways over long periods of time and made an indelible mark on their colleagues and friends who have nominated them”. Christine was one of three people handed the award by national chair Su Sayer, the others being Leslie Ashworth from CPRE Northumberland and Ben Nash from CPRE Herefordshire. Warm congratulations to all from CPRE Kent!
To read more about Christine’s achievements, please click here
Tunbridge Wells Borough Council is in the process of completing its Local Plan, a key part of which is meeting a housing target in line with government methodology. This will mean a huge increase in housebuilding. Under the new formula imposed by the government, the borough will be required to build 13,500 dwellings by 2036 more than double the number required under the previous Core Strategy. Many housing developments have already been permitted on valuable Area of Outstanding Natural Beauty (AONB) and Green Belt land, such as at Brick Kiln Farm, Cranbrook, resulting in the loss of part of one of the finest remaining medieval landscapes in Europe. The proposed new ‘garden village’ (or new town) at Capel has already been announced, but this is the tip of the iceberg: smaller developments will happen across our rural areas.
A chance to protect the AONB and Green Belt missed The planning system allows TWBC to protect the Green Belt, but in the case of Capel it appears it has chosen not to do so. This is despite the council’s Green Belt Study identifying “release” of this broad area from the Green Belt as causing a very high level of harm to the Green Belt (Tunbridge Wells Green Belt Study Stage 2, Land Use Consultants, 2017). Paragraph 11b and Footnote 6 of the National Planning Policy Framework (NPPF) 2019 provide an exception to the requirement to meet housing ‘needs’ where the application of policies in the NPPF protecting Green Belt, AONB, irreplaceable habitats, heritage assets and areas at risk of flooding provide a strong reason for restricting development. Some 70 per cent of the borough is designated as AONB and 22 per cent as Green Belt, while Flood Zone 3 covers almost 7 per cent. This compares with some 25 per cent of England that is National Park or AONB, and 12.5 per cent of England that is Green Belt.
Land lost based on incorrect housing need forecasts There is a prevailing false assumption that simply building more homes, of any kind, will bring down prices. Councils are placed under ever-increasing pressure to meet unrealisable housing targets, compelled to release more land for development and grant more planning permissions, even while many sites (such as the brownfield cinema site in Tunbridge Wells) that already have permission are not built out. Last year, the final report of Sir Oliver Letwin’s review of build-out rates found that the largest housebuilders were consistently delivering expensive homogenous homes only as fast as the open market could absorb them without lowering prices. This business model deliberately and explicitly fails to result in the reduction in house prices assumed by those who advocate unconstrained market housebuilding as a solution to the affordability crisis. It does not and cannot deliver the kind of homes that communities need; rather, it will continue to cover the countryside in poor-quality, piecemeal development. Worse still, because the ‘standard method’ for estimating local housing need is based on the relationship between house prices and incomes, building more expensive homes, especially in rural areas, leads to an increase in the apparent demand for housing calculated using this method and the cycle of unaffordable speculative housebuilding continues. The most recent figures from the Office for National Statistics on housing affordability in England and Wales show worsening levels of affordability over a five-year period across most of the country, despite the consistent weakening of the planning system. At present, the planning system actively reinforces market trends. The standardised method for calculating ‘objectively assessed need’ for housing in each local planning authority area, which takes household growth projections as a baseline and adjusts them according to market signals, concentrates growth and investment in areas that are already economically buoyant and have overheated housing markets. In the long run, this simply stokes more demand, further inflating rents and house prices, straining local services and exacerbating the oppositional nature of the planning process. Moreover, it further unbalances the national economy. Government planning policy, as set out in the revised and updated 2019 National Planning Policy Framework (NPPF), prioritises driving up the overall quantum of homes delivered over other considerations, including tenure mix. It also holds local authorities to account for things outside their control, such as the failure of the volume housebuilders to build out sites quickly. The introduction of the Housing Delivery Test (recently failed by 108 authorities) places councils under such pressure to deliver more homes that it is difficult for them to reject proposals for inappropriate developments, including those that do not comply with local affordable housing policies. Moreover, many applications that initially propose to meet local affordable housing requirements are later renegotiated by developers on the grounds of viability. CPRE’s 2018 research with Shelter found that rural sites where a viability assessment was used saw a 48 per cent drop in the number of affordable homes delivered. CPRE’s report on the State of the Green Belt 2018 demonstrated that building on the Green Belt was not solving the affordable housing crisis and would not do so. Last year, 72 per cent of homes built on greenfield land within the Green Belt were unaffordable by the government’s own definition. Of the 460,000 homes that were planned at the time of the report to be built on land released from the Green Belt (a figure that doesn’t include the 4,500 additional houses now planned for Capel and Paddock Wood), the percentage of unaffordable homes would increase to 78 per cent. Local authorities with Green Belt land have enough brownfield land for more than 720,000 homes, the report found, much of which was in areas with a high need for housing and existing infrastructure.
Land lost due to low-density housebuilding TWBC may do its best to put homes on ‘brownfield’ sites, and on areas outside the Green Belt or AONB, but the target is so high that many houses will have to be on Green Belt or AONB land. An important way to reduce the amount of land required is to maximise the density of each development. There are two reasons this is difficult in practice. The first is that it is more profitable for developers to build big houses with plenty of land. Secondly, neighbours, faced with a planning application, often ask for the number of homes to be built on a site to be reduced, minimising the impact. We all need to realise the result of that: another piece of land will need to be sacrificed to take the houses not built here. The Campaign to Protect Rural England and TWBC both recognise 30 homes per hectare as a fair target for new developments. Many of the planning applications received are for 15-20 homes per hectare. This means that up to twice as much land is needed for the same number of homes. Somewhere else? No, your village will have to provide some of the land. Future generations will ask why we sacrificed land in this way – land that might still be green. There is another reason density is important. The borough desperately needs more affordable housing. Many parish councils have heard from residents that their children are being priced out of the area, and the supply of new affordable homes in the villages is way below the need. Low density simply means more expensive housing. Higher-density housing does not need to be ugly. Some of the most desirable properties in our area are terraced cottages on village streets: the high-density housing of the past. There are clusters of homes in converted buildings around old farmyards that use land very efficiently. Even in modern developments a village atmosphere can be created with terraces, while maisonettes and other three-storey developments can be an attractive part of the development. Higher-density development makes public transport more viable. Some sites are not suitable for higher-density housing. The answer in most cases is not to accept the low density but to leave the land green. Over the planning period, the amount of land sacrificed by low-density development could be up to 1,000 hectares – 1,400 football pitches. We suggest that an opportunity cost should be applied to proposals for low- density development: the land to be sacrificed in the future. A five-hectare plot built at 15 to the hectare has sacrificed 2.5 hectares of land that might still be green. Meanwhile, despite clear government guidance that “where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities, and ensure that developments make optimal use of the potential of each site” (NPPF para 123), TWBC has been granting planning permission on many sites at low densities. For example, on a partially brownfield site in the Green Belt at Five Oak Green the borough council is applying to grant itself permission for three four-bedroom and two five-bedroom market houses on a half-hectare plot, a rate of a mere 10 dwellings per hectare, with no affordable housing (19/01586/OUT Land West Of Sychem Place Five Oak Green). Future generations will ask why we both sacrificed land in this way – including some of our most precious landscapes – and failed to build the homes our young people need.