If you thought the planning system was already loaded in favour of developers, things might be about to get a whole lot worse. The government is reportedly considering a ‘zonal planning system’ in which “key decisions will be taken from local councils and handed to development corporations”. Dominic Cummings, the Prime Minister’s chief adviser, is said to be influencing the government’s approach to planning and working with Robert Jenrick, Secretary of State for Housing, Communities and Local Government, on a plan to “kick-start housebuilding and infrastructure spending”. The Sunday Times reported that a “committee of experts assembled by the duo” has met to “think about very substantive changes” to planning regulations. The panel includes Bridget Rosewell, a commissioner for the National Infrastructure Commission, property developer Sir Stuart Lipton and planning barrister Christopher Katkowski QC. The newspaper said one of the proposed measures would allow high-street businesses to change their use “with complete flexibility”. Further, there would be a “move to a zonal planning system where key decisions will be taken from local councils and handed to development corporations — though building on the Green Belt will not be permitted”. In what appears part of an ominous trend, a document was published in March alongside the policy paper Planning for the Future, saying the government’s forthcoming Planning White Paper would “propose measures to accelerate planning”. It added that the government would “trial the use of templates for drafting local development orders and other zonal tools to create simpler models and financial incentives to support more effective use”. The Sunday Times has also reported that “Cummings and Jenrick are backing a new fast-track system for developers of high-quality, well-designed buildings”. Asked about the media reports, a Ministry of Housing, Communities and Local Government Planning spokesman said: “The government has already set out an ambitious programme to modernise our planning system. “Our Planning for the Future reforms will support the delivery of homes that local people need and create greener communities with more beautiful homes”. While some local authorities in Kent can often appear less than sympathetic towards our natural environment, moves to take away their responsibility for “key decisions” and hand it to development corporations surely detract from the principle of democracy. Whatever happened to localism?
Thanet CPRE has given a damning response to the news that the district’s draft Local Plan has an ‘appropriate basis’ to be adopted. Two government inspectors included a list of modifications, and a requirement that the Plan be reviewed within six months of adoption, but indicated that Thanet had a Plan that could finally be taken forward. One of its most contentious features was the provision for at least 17,140 new homes up to 2031. Geoff Orton, Thanet CPRE secretary, said: “We remain concerned that there has been no survey of the potential for utilising brownfield opportunities, especially now that the current crisis has underlined the ‘online march’ even more emphatically to the detriment of retail premises, including car parks. “Thanet District Council did tell the inspector that ‘invading the green’ was a last resort. “We remain unconvinced that there will be sufficient employment to justify the housing figures and remain concerned that the Plan is oblivious to the real needs of the population for affordable social renting. “And of course we are surprised that the highest accord is not given to the preservation of first-class agricultural land as a national food security resource. “The Local Plan is hardly local and completely out of date, and will only compound traffic congestion if it ever gets implemented.”
CPRE Kent has backed Sevenoaks District Council’s decision to begin judicial review proceedings in its challenge to the Planning Inspectorate. The council’s move had been in response to a government-appointed inspector’s refusal to endorse its new Local Plan. Nigel Britten, the countryside charity’s district chairman, said: “CPRE Kent supports the action being taken by Sevenoaks District Council to resolve the impasse over its Local Plan. “The main argument about technical procedure exposes the crude and uncompromising system that is forcing councils like Sevenoaks to give priority to development over protection of the countryside. “Sevenoaks district is almost entirely Green Belt and largely within two Areas of Outstanding Natural Beauty. “The planning system does quite clearly give the council the right not to sacrifice these areas of national importance, yet the inspector seems unwilling to recognise that fact and to wish to impose impractically high thresholds for any deviation from the government’s artificial and unrealistic housing targets. “If the judicial review goes ahead, many councils – and CPRE – will be hoping that Sevenoaks District Council succeeds”
Thanet might be close to having a Local Plan. A seemingly interminable saga (see here, here, here,here, here and here) appears to be nearing a conclusion, with the two inspectors examining the draft Local Plan informing Thanet District Council on March 23 that the document has an ‘appropriate basis’ to be adopted as long as a list of modifications is included. There is also a requirement that the Plan be reviewed within six months of adoption. The inspectors’ report has now to be considered by full council, with adoption anticipated by summer, depending in part on the Covid-19 lockdown. The Plan, which covers the period to 2031, was submitted for examination on October 30, 2018, with public hearings held between April 2 and July 18 last year. The Report and the recommended Main Modifications to make the Plan ‘sound’ can be viewed on the council’s website. Social-distancing restrictions mean no paper copies of the document are available for inspection at Thanet Gateway, but it can be viewed online. One of the most contentious features of the draft Plan has been housing numbers and this makes provision for at least 17,140 new homes up to 2031. Manston airport is to be safeguarded for airport-related uses, with future use and development at the site to be determined through early review of the Plan. The recommended main modifications all concern matters discussed at the examination hearings. After the hearings, the council prepared a schedule of the proposed main modifications and where necessary carried out a sustainability appraisal of them. The main modifications were subject to public consultation from December 11 last year to January 27, 2020. After considering the representations made on the proposed main modifications, the inspectors have recommended that these be included.
In summary they
Introduce new Policy SP01a, which supports the principle of development in the urban area and designated villages
Introduce new Policy SP01b, which requires the council to complete a review of the Plan within six months of adoption
Modify the stepped housing requirement in Policy SP11
Clarify which sites are allocated for residential development in the urban Area (Policy HO1) and the rural settlements (Policy HO11)
Modify the development principles for strategic housing sites and include land at Shottendane Road as a strategic housing allocation (Policy SP18A)
Amend Policies SP19 and SP20 to provide clarity regarding the type and size of dwellings and the thresholds for the provision of affordable housing
Include a requirement in Policy HO22 to identify and allocate sites for gypsy and travelling communities as part of an update to the Plan
Introduce a new policy (Policy SP05) concerning development at Manston airport
Modify Policies SP02, SP03 and E01 to support new economic development within settlement boundaries, clarify how much land is allocated for employment uses and provide criteria to assess proposals for the reuse of employment land and buildings
Modify Policy SP21 to support economic growth in rural areas
Delete unjustified and undeliverable transport routes from Policy SP47
Modify Policies SP22, SP25 and SP26 to provide effective criteria for development in Green Wedges, and for proposals likely to lead to increased recreational pressure on the Thanet Coast and Sandwich Bay SPA and Ramsar Site
Modify the town-centre policies (SP06-SP10 and E04-E06) for clarity and effectiveness
Support the extension of the Queen Elizabeth The Queen Mother Hospital through Policy SP37
Clarify how new medical facilities will be provided at Westwood and where new primary and secondary schools will be located through changes to Policies SP38 and SP40
Provide effective criteria to consider proposals for foster homes and childcare facilities, and the retention of family homes in Policies HO24 and HO26
Delete Policy CM04 relating to the expansion of Minster cemetery
Update Appendix B to reflect the latest position concerning site delivery
Other main modifications are also recommended to ensure that the Plan is justified, effective and consistent with national planning policy. A striking feature is the proposed housing trajectory. The inspectors’ modification MM27 Table to Policy SP11 provides for the following average annual housing numbers: 2011/2012 – 2015/2016: 311 2016/2017 – 2020/2021: 600 2021/2022 – 2025/2026: 1,200 2026/2027 – 2030/2031: 1,317
The figure for 2011/2012 – 2015/2016 is based on actual completions averaged over the five-year period. The modification requires a doubling of completions for the next-five year period 2016/2027 – 2020/2021. This has not been achieved in the first three years. For the years 2016/2017 – 2018/2019 only 993 dwellings were built. That averages just 331 per annum. Little more than that was achieved in the first five-year period. So to average 600 dwellings per annum over the five-year period in the next two years, 2,007 dwellings will need to be built. That is an annual average of 1,004 and three times that which has been achieved in the previous three years. Given the Covid-19 lockdown and the predicted slowdown in the global economy, it is highly unlikely that these levels will be achieved this year or next year. This means that in the last two periods more homes will need to be completed than required by the trajectory, suggesting an increase in housebuilding not seen here before and only in recent years experienced in growth areas such as Dartford.
Sevenoaks Council District Council is on collision course with the Planning Inspectorate after refusing to withdraw its draft Local Plan from examination. Planning inspector Karen Baker in October last year warned the local authority that she would issue a report concluding its Plan was unsound if it was not withdrawn. Her letter, sent on Thursday, October 17, said: “I have significant concerns about a number of aspects of the Plan, both in terms of legal compliance and soundness. “My main concern relates to the lack of constructive engagement with neighbouring authorities to resolve the issue of unmet housing need and the absence of strategic cross-boundary planning to examine how the identified needs could be accommodated… “Furthermore, I have significant concerns about the soundness of the Plan in respect of a number of areas including the approach to sustainability appraisal, the chosen strategy for growth, the assessment of the Green Belt and housing supply and distribution.” Council leader Peter Fleming promptly gave a stinging response : “It is clear to me the way this has been handled calls into question the integrity of the whole Plan-making system in this country… “To call into question an evidence-led approach comes to the root of our concerns with the actions of the inspector. If we are not to follow the evidence to make our Plan then the government may just as well dictate how many homes an area should have and then pick sites, we need to put an end to the thinly veiled charade that Local Plans are in any way locally led.” The council has stuck to guns and on Wednesday, January 8, put a forthright statement on its website: “In the latest response to the planning inspector, Sevenoaks District Council has vowed not to withdraw its draft Local Plan, despite continued pressure to do so,” it read. “The council’s strategic planning manager, James Gleave, confirms in the response dated 3 January that the council will not voluntarily withdraw its Local Plan from examination and continues to disagree with the conclusions made by the planning inspector. “The government-appointed planning inspector, Karen Baker, wrote again to the council on 13 December 2019 urging it to withdraw the Local Plan from examination. “She repeating her belief that the council has not carried out its duty to co-operate with neighbouring councils to find sites for new homes that cannot be delivered due to constraints such as the Green Belt. “The inspector believes the council had not done enough to address the ‘unmet housing need’ despite the proposals achieving almost 90 per cent of the government’s housing target. “Mr Gleave goes on to say while the planning inspector highlights the council’s perceived failings, she does not provide a clear understanding of what constructive engagement with neighbours should be. “She fails to take the pragmatic approach expected in the legislation and ignores significant evidence, much of it from the council’s neighbours and independent experts.” The council statement is concluded by leader Cllr Fleming, who says: “I will be writing to the Secretary of State on this matter and urgently asking him to intervene. “It appears something is very wrong with the system if a council with its communities works hard for four years to produce an evidence-based Plan that delivers housing, jobs and infrastructure investment, whilst protecting the environment, only to be halted by a single individual. “We will not be withdrawing our Local Plan and the inspector will produce her report in due course. We will then take the strongest action open to us.”
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
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.
We are indebted to the local media for two stories highlighting some of the many issues affecting Thanet. The district is usually at the wrong end of socio-economic statistics, so it comes as no surprise to learn it has the highest proportion of children living in poverty in the county, even taking into account a 4 per cent fall on the previous year (2017-18). The figure of 35 per cent equates to a staggering one child in three (some 11,500) living below the breadline in Thanet, the Kent Messenger Group reports. This compares with a Kent average of 28 per cent and figures from the ‘right’ end of the table: Tunbridge Wells (22 per cent) and Sevenoaks (23 per cent). Now consider the issue of rising property prices in Thanet – indeed the entire Kent coast, where it costs an average of £150,000 more to buy a home than it did 10 years ago. House prices across Thanet rose by an average of 48 per cent over the past decade; in apparently trendy Margate, the hike was 55 per cent, from £151,520 to £235,012. The spiralling increase is, of course, fired largely by London and puts the prospect of local people buying their first home ever-further out of reach. It is against such a backdrop that the government’s much-criticised housing methodology is anticipated to produce an Objectively Assessed Need (OAN) of 17,140 new homes in Thanet between 2016 and 2031. It is a number that is highly unlikely to be fulfilled; in the region of 8,500 homes were built in the past 20 years, so the rate would need to more than double for the OAN to be achieved. And when such a shortfall occurs, a local authority is unable to demonstrate a five-year housing supply, leaving the door wide open for speculative developers to try their luck at just about anything, no matter how inappropriate or undesirable. There is a growing belief among some commentators that the ludicrous housing targets being imposed on some (but by no means all) local authorities are designed to do just that: effectively put planning powers in the hands of developers. Or is that a conspiracy theory too far? CPRE Kent has long advocated the building of social housing for local people, highlighting the fact that developers’ keenness to put up four- and five-bedroom houses at prices beyond the wildest dreams of many is going to do precious little to ease the much-reported ‘housing crisis’. Thanet residents concerned at the manner in which property prices are being skewed are often told of the ‘trickle-down effect’: the notion that an influx of cash-rich newcomers shares the posterity far and wide. The idea would in truth seem to hold little truth, at least if those child poverty figures are anything to go by.
The saga of Thanet planning rarely makes uplifting reading, but for more see here, here, here, here and here
The government’s backing of proposals to target the Thames estuary for massive development flies in the face of wider calls to tackle climate change, says Hilary Newport, director of CPRE Kent. In June last year the Thames Estuary 2050 Growth Commission published a report calling for the building of more than a million homes and the creation of 1.3 million new jobs in east London, Essex and Kent. The commission, an advisory body to the government that was announced in the 2016 Budget and tasked to “develop an ambitious vision and delivery plan for north Kent, south Essex and east London up to 2050”, had also urged that ‘joint spatial plans’ be created in both Essex and Kent, which it said should take more of London’s housing need. It also called for greater strategic planning and the creation of development corporations “with planning, and compulsory purchase powers to drive the delivery of homes and jobs aligned to major infrastructure investment”. Responding in March this year, James Brokenshire, Secretary of State for Housing, Communities and Local Government, stressed his support for the commission’s recommendations. “The Thames estuary has long been a gateway to the UK economy and has enormous untapped potential, which has the power to benefit those that live and work in the area,” he announced. “Having considered the recommendations of the Thames Estuary 2050 Growth Commission, I have announced a number of steps we are taking to unlock an even brighter future for the estuary’s economy, marking the beginning of a new and bolder approach by this government to support the area.” He said government “expects all local authorities to plan for the number of homes required to meet need in their area” and “would encourage cooperation between the London boroughs and neighbouring authorities in Kent and Essex and welcome further engagement with those places, including with groups of London boroughs, in exploring how we might support them to plan for and deliver significant increases in the provision of homes”. The government is also “committed to exploring the potential for at least two new locally-led development corporations in the Thames estuary”, “subject to suitable housing ambition from local authorities, and we encourage local areas in the estuary to come forward with such proposals”. The response included a commitment of £1 million to establish a Thames Estuary Growth Board to “oversee and drive economic growth plans for the area” and £4.85 million “to support local partners to develop low-cost proposals for enhancing transport services” between Abbey Wood and Ebbsfleet. The wish to impose high levels of growth on an already desperately overcrowded part of the country is alarming and of course would entail substantially expanded infrastructure, most contentiously a Lower Thames Crossing, a road that would exacerbate traffic congestion in north-west Kent, according to Alex Hills, chairman of Dartford and Gravesham CPRE. “The A227 section that runs from the A20 to the A2 and that paces through Vigo, Culverstone, Meopham and Istead Rise is facing a massive increase in traffic,” he said. “With 3,000 houses planned for Borough Green and Gravesham Borough Council pressing to build on Green Belt in the area, this road already faces a huge hike in traffic. A new Thames crossing would drastically increase it yet further. Highways England has admitted that the new crossing will increase the traffic using the A227.” Hilary Newport, CPRE Kent director, concurred: “A new crossing, should it be built, is projected to reduce traffic flows at Dartford by a pitifully low 22 per cent. That is a minuscule benefit, but the environmental and community harm caused by the biggest UK road project since the building of the M25 would be substantial. “A new crossing would be all about intensifying overcrowding in the South East and opening up countryside development. It is now beyond dispute that increasing road capacity results in more vehicle journeys – we cannot build our way out of congestion. “The Intergovernmental Panel on Climate Change has warned that we need to take immediate action to curb catastrophic climate change, yet here we are stuck with the government’s obsession with a new Thames crossing to help pave the way for colossal levels of business-as-usual development. “To say the government’s focus on new road capacity is out of date is to hugely understate the problem. Rather than investing solely in new roads, it should be promoting better public transport links, rationalising the over-reliance on road-based freight movement and supporting planning policies that support walking and cycling.” The revised focus on the estuary comes after the previously mooted Thames Gateway project stalled, partly through a downturn in the economy and partly through the ditching by the coalition government, which came to power in 2010, of regional planning. Now, perhaps ironically, there are concerns among some in the planning world that local authorities in north Kent have not engaged in joint strategic planning in the same manner as their counterparts in south Essex and the capital. Six local authorities in south Essex have come together with their county council to form the Association of South Essex Local Authorities and pledged to prepare a joint plan. Catriona Riddell, of the Planning Officers Society, which represents local-authority planners, said: “I think the south Essex part of the Thames estuary is way ahead of the game in terms of what it’s doing on strategic planning. “The London Plan will cover the London bit of the estuary and you’ve got the south Essex joint plan being prepared. You’re going to have to have something in north Kent. You can’t have two out of three areas doing formal joint strategic planning without north Kent doing the same. That is a big hole at the moment.” She says north Kent authorities have not worked together partly because of lack of agreement about whether a strategic plan should cover the whole of the county or just the northern part focused on the estuary. “I suspect they will have to think quite quickly now because of the government’s response,” she said. “I don’t think they will have much leeway in terms of not doing something.” Stuart Irvine, of planning consultancy Turley, added that the growth board would have influence with government, which could sway spending decisions. “It does potentially have the ear of government, which could be useful from a financial and infrastructure perspective,” he said. “That could have a big influence on how Kent’s planning authorities choose to behave. If funding is channelled through the growth board, I think north Kent will have no choice but to change direction towards the Thames estuary.” Some see the introduction of a growth board and emphasis on strategic plans as a renewed willingness by government to embrace regional planning again. “We’ve got a similar approach being taken on the Cambridge-Oxford corridor,” said Thames Estuary Commission chairman John Armitt. “You need to look at it on that regional level.” And at last year’s Conservative Party conference, planning minister Kit Malthouse said government wanted local authorities to come together in “regional groupings” and prepare strategic plans in return for Whitehall infrastructure cash. Ms Riddell is not convinced, however, stressing that fewer than half of the councils in the Thames estuary would be represented on the new growth board. “I find it really ironic that they abolished regional strategies and assembles because they were apparently unaccountable,” she says. “They’re reinventing regional planning but with less accountability and political representation than we had in 2010.” Similarly, CPRE Kent’s Hilary Newport believes the future of the Thames estuary needs broader consideration. “Sustainable transport should be prioritised over new road-building,” she said. “If growth in the estuary is to continue, we need significant investment in the area’s public transport, walking and cycling options. “As CPRE’s policy on transport makes clear, we need to manage our existing road network better, rather than expand it. As such, we would prefer investment in the estuary’s railway network, such as an extension to Crossrail, to be prioritised over the building of a Lower Thames road crossing.” As for the push to focus development on the estuary, Mrs Newport said: “There needs to be wide-scale public engagement and consultation on the overall growth proposals, allowing alternative options to be considered before policy decisions are made. “We believe that there should urgently be a full Parliamentary Select Committee Inquiry into the proposals, to look at the potential impact on both the local environment and on the economies of more deprived regions in England.”
Many of us are aware that our natural environment is threatened like never before. We experience it through the constant grind of cement-mixers and bulldozers, but sometimes the bureaucratic process is not so clear. Here planning expert and CPRE supporter Michael Hand casts some light on what is driving the current onslaught.
We are under relentless and unparalleled pressure to accommodate significant growth, in particular to meet the demand for new housing.
However, many developments are concentrating on three- and four-bedroom executive homes and not enough ‘affordable’ housing is being delivered.
Much of the South East is experiencing pressure for this unprecedented growth in housing, driven by the ‘housing crisis’ and associated government policy to increase the delivery of new homes by setting higher targets for local authorities to meet.
As guardians of the countryside, local members of CPRE Kent have a key responsibility in upholding the core values of the organisation and defending the beauty of the county against poor-quality and inappropriate new developments.
There are 13 Local Planning Authorities (LPAs) in Kent and in many Local Plans have not been adopted.
This void in the planning framework has resulted in opportunistic and speculative applications (by companies such as Gladman Developments Ltd) seeking to exploit councils’ inability to demonstrate a five-year supply of housing land.
The effect, already adverse, has been exacerbated by a recent change by the government to the National Planning Policy Framework (NPPF) through publication of a revised version on February 19.
Key changes include an amendment to specify that 2014-based population projections will provide the demographic baseline for the standard method of calculating local housing need rather than the lower 2016-based household projections, which could be used as a reason to justify lower housing need.
This clarification followed the publication of a major revision of the NPPF on July 24, 2018, which, inter alia, clarified the definition of ‘deliverable’.
To be considered deliverable, sites for housing should be available now, offer a suitable location for development now and be achievable with a realistic prospect that housing will be delivered on the site within five years.
As a consequence, it may be harder for LPAs to provide a five-year housing-land supply, as for example Local Plan allocations cannot generally be used in the calculation, except where “clear evidence that housing completions will begin on site within five years” exists.
The 2018 revision also introduced the Housing Delivery Test for LPAs, a failure in delivery of which kick-starts the “presumption in favour of sustainable development”.
The first round of Housing Delivery Test results was published in February this year, with 108 councils falling short and 86 required to add more land for housing to Local Plans as a result.
For a number of authorities, this confirms the need to apply a 20 per cent buffer to their housing requirement, with potential ramifications for their ability to demonstrate a five-year housing land supply.
A result of these changes is that speculative applications will still be common practice in the future – and that is why CPRE Kent needs to keep building a strong presence to monitor and respond to inappropriate development proposals.
Richard Bate, planning professional and long-time CPRE Kent supporter, delivers a withering analysis of government housing policy
How often have you heard it said that if only the planning authorities would release more land for housing, then the builders would build more houses and prices would come down?
This is the fundamental belief across the government at present. To the Treasury this is the simple law of supply and demand. Furthermore, given that the market knows best and the planning system gets in the way of the market, it must be right to pull the teeth of the planning system. This is what the government has been doing.
The inconvenient reality is that housebuilders do not wish to reduce house prices discernibly.
At the site level they anticipate particular sale prices for particular products, subtract construction costs, financing and profit, and bid for the land as a residual cost.
If house prices come down, profits erode and enthusiasm to build deteriorates. That’s what happens in recessions. Strategically, businesses do not deliberately flood their own market with the objective of reducing their own sale price.
Release more land for housing? Giving builders more land may help them to supply more houses, but only up to a point.
Firstly, there has to be a market at their chosen sale price. The government has generously aided this process through Help to Buy and other mechanisms, enabling purchasers to pay inflated prices.
The Chartered Institute of Housing has shown recently that more government subsidy is being ploughed into home ownership than into ‘affordable’ (sub-market) housing to rent. It’s hardly surprising house prices don’t come down.
Secondly, ‘more land’ has ceased to be the solution, because builders can’t use it fast enough. Data commissioned by the Local Government Association shows that planning permissions each year far outstrip completions, that unimplemented permissions are rising, and the period from permission to completion is lengthening.
Third, the greater the choice of sites available to builders, the more they can cherry-pick the financially attractive ones – often greenfield sites rather than recycling the urban sites the planning system would largely prefer. So planning is already less effective.
How many houses? Despite plenty of planning permissions, annual completions in all tenures are below the estimated growth of some 230,000 a year in numbers of households in England.
Government policy is for the completion of 300,000 dwellings annually, almost twice the number achieved in 2017. You can guess its preferred means of achieving this aspiration: release more land!
To arm-twist planning authorities, the government changed the rules on housing need and supply in February this year.
Housing need is to be calculated by a new ‘standard method’. This is based on the well-established (but still volatile) household projections prepared by the Office for National Statistics every two years.
The 2016-based projections were generally lower than the 2014-based projections, so the government has decreed that the older set will be used. Never mind not using the most up-to-date information if it is inconvenient to the outcome…
The housing need figure for each authority is then adjusted to take account of affordability (a specific ratio of house prices to incomes). All but about five local authorities in the country have affordability ratios above the threshold at which, under the government’s method, their housing need figures will be raised. (The local housing need figure is capped at 40 per cent above the average annual housing requirement set out in existing Local Plans.)
The policy therefore builds into planning practice the government’s belief that releasing more land will bring down house prices.
Unsurprisingly, there is no mention of the degree to which affordability ratios are expected to fall for a given stimulus of land supply. The number of plots that must be provided will generally be well above the number of dwellings needed to match the household projections, so land must be made available for households that are not projected to exist.
Each authority must supply land for at least five years’ worth of building at the required rate.
The government wants ‘concealed’ households to obtain more readily their own homes and households to form that have allegedly been deterred from forming by the shortage of dwellings.
This is more economic gibberish.
The concealed and unformed households are in that position because they cannot afford to buy or rent on the open market and would be unable to obtain subsidised housing, so their needs will only be met by greatly increasing the provision of sub-market housing, ideally traditional social housing.
That is irrespective of the volume of land release. The extra sub-market housing planned is far short of real needs.
Is it all planning’s fault? The government’s coup de grâce is on housing delivery. Instead of being assessed for their land supply, local authorities will be assessed on the number of dwellings built in their areas. This is despite local authorities barely building any houses these days: that’s the task of builders.
When housebuilding rates in a local authority fall below 85 per cent of its assessed requirement, the government assumes (again) that this is for want of land. The authority will then be obliged to find a 20 per cent extra ‘buffer’ of additional deliverable housing sites.
On current figures, that affects 86 councils in England: in Kent – Gravesham, Medway, Swale and especially Thanet. The instruction to release more land for housing at repeated stages in the process inevitably threatens more countryside, with builders likely to play the system to achieve that result.
The government is setting up requirements that it must know are wholly undeliverable for many local authorities. When housing supply falls short of the new proposed ‘needs’, the government will berate the authorities and claim it’s all the fault of their planning practices.
That will make it easier to impose yet another round of significant weakening of planning powers – which are obviously getting in the way of housing the nation.
Meanwhile, the original culprit, high house prices, which could be tackled by policies on the ‘demand’ side rather than the ‘supply’ side, will go unchecked. Further, the government has announced its intention to fuel the fire with yet another extension of Help to Buy, beyond 2021.
Plans for Westwood Village were approved in February (pic Greenacre (Thanet))
Some of our Thanet readers might already be delighted by the decision to approve plans for the 900-home Westwood Village. After all, the substantial loss of farmland combined with potential traffic gridlock should be enough to gladden the stoniest of hearts.
Such joy can surely only be heightened by the news that the scheme is one of the largest to have been approved across the entire country this year.
Planning magazine has listed the largest planning consents to be granted during the first six months of 2019 – and Westwood Village, which lies essentially at the joining point of Margate, Ramsgate and Broadstairs – comes in at an impressive sixth place.
The plans, from Greenacre (Thanet) Ltd, were approved, with conditions, by Thanet District Council’s planning committee on Tuesday, February 26. The final agreement, incorporating legal provisions, will be concluded by officers.
As well as the 900 homes (of which 30 per cent are scheduled to be ‘affordable’), Westwood Village will include a 4,900 square-metre commercial centre, a local centre and a primary school.
As for what all those new households are going to do for work, answers on a postcard, please… PS: The largest application to be approved in the Planning survey?
The intriguingly named Margarine Works development in Southall, west London, incorporating more than 2,000 homes, up to 10,076 sq m of flexible office/community space and 2,688 sq m of flexible retail space.
Fly away! There won’t be much space left for wildlife in the Thames estuary if mass development proposals come to pass (pic GREAT)
Back in September, we wrote: “If you thought development pressure on Kent could not get any worse, there is some sobering reading from the Thames Estuary Growth Commission.
“This advisory body to the government is urging ‘joint spatial plans’ to be created in both Essex and Kent to support the building of more than a million homes.
“The two counties should take more of London’s housing need, says a commission report.”
And last week (Monday, March 26) the government published its response to the Thames Estuary 2050 Growth Commission report. Unsurprisingly, it is not an attractive read, either in style or substance.
The commission had been announced in the 2016 Budget and was tasked by government to “develop an ambitious vision and delivery plan for north Kent, south Essex and east London up to 2050”.
Sadly, the word ‘ambitious’ rarely spells good news… and, sure enough, a sift through the bureaucratic spiel reveals that the intention to target the estuary for mass housing development shines as bright (or as dark) as ever for this government.
You might recall that the 2050 Vision report, published in June last year, said “a minimum” of one million homes would be needed to support economic growth in the Thames estuary by 2050, equating to 31,250 homes a year.
It also called for greater strategic planning and the creation of development corporations “with planning, and compulsory purchase powers to drive the delivery of homes and jobs aligned to major infrastructure investment”.
Responding, the government has committed to “striking housing deals with groups of local authorities in order to support ambitious and innovative plans for additional homes in high demand areas”.
It says: “Through these deals, we are seeking to support greater collaboration between councils, a more strategic approach to decision-making on housing and infrastructure, more innovation and high-quality design in new homes and creating the right conditions for new private investment.
“We are encouraged by early discussions with authorities in Kent and Medway on how government can support this ambitious plan, and how we can best work together to secure the infrastructure it needs to plan for and deliver more homes.”
We are told the government “supports joint planning arrangements as defined by local partners and stands ready to offer support to places seeking to engage in developing compelling proposals which support housing growth over the longer term.
“These proposals or joint working arrangements should not be limited by the geography of the Estuary and we would encourage cross boundary working.”
Further, the commission “also recognised the importance of housing delivery both in East London and within the wider Estuary”.
It response says government “expects all local authorities to plan for the number of homes required to meet need in their area” and “would encourage cooperation between the London boroughs and neighbouring authorities in Kent and Essex and welcome further engagement with those places, including with groups of London boroughs, in exploring how we might support them to plan for and deliver significant increases in the provision of homes”.
The government is “committed to exploring the potential for at least two new locally-led development corporations in the Thames Estuary”, “subject to suitable housing ambition from local authorities, and we encourage local areas in the Estuary to come forward with such proposals”.
The government response also includes:
a commitment of £1 million to establish a new Thames Estuary Growth Board to “oversee and drive economic growth plans for the area”
a commitment of £4.85 million “to support local partners to develop low-cost proposals for enhancing transport services” between Abbey Wood and Ebbsfleet. The response says that any decision on future transport enhancements “would require a detailed evidence base that demonstrates that the scheme would be both technically feasible, offer value for money … and deliver ambitious new housing in the area.”
a commitment to create a Cabinet-level “ministerial champion” to act “as an advocate and critical friend for the region within government”.
The much-heralded revival of Margate has helped increase demand for second homes in Thanet
The ridiculous housebuilding targets imposed by Whitehall on our local authorities have been well charted, but few places highlight some of the inherent issues as much as Thanet.
Always something of a law unto itself, the district suffers a low-income, low-skills economy, with socio-economic stats that compare to the worst in the country, let alone the South East.
Alongside this, however, are property prices that, while still low in a regional context, are in truth eye-wateringly high. Many local people are not able to even consider buying a home.
This, of course, is presented by the government as a central tenet of its increased housing targets; it is saying house prices are too high for local people so we must build more.
It’s a simplistic argument that might be better suited to a school playground than the national political arena: houses are not tins of baked beans and simply putting up more of them is not going to bring a fall in prices.
A range of variable factors determines house prices.
Of course, in Kent one of those is proximity to London (another law unto itself, indeed almost another country in some regards).
Much of this county (widely regarded as the poor sister of the South East) has similar issues to Thanet, if to a lesser degree, in that local wages are never going to compete with those of London.
Even allowing for workers who commute to the capital for employment, too many Kent residents are priced out of housing by incoming Londoners. Building more houses isn’t going to affect prices if they’re simply going to be bought by people from the capital.
In Thanet, the situation is exacerbated by the number of properties bought as second homes.
Staggeringly, HM Revenues and Customs figures reveal that in 2017-18 more than a quarter (28 per cent) of residential properties bought in Thanet were procured as second homes.
The second-highest figure came from Canterbury, at 24 per cent, followed by Dover and Folkestone & Hythe (each 22 per cent). The least-affected district was Tonbridge & Malling at 15 per cent.
Increased stamp duty was expected to reduce the demand for second homes, but instead Kent saw a rise of 16 per cent in their purchase from 1916-17.
Most South East local authorities will struggle to meet their housebuilding targets, which in itself will herald a tranche of other issues, but it is clear that housing policy and its attendant methodology are missing the target when it comes to providing local homes for local people.
Second-home purchase is just one factor in that mismatch.
A kestrel hovers over the marshes… how much long longer will wildlife have a future in the area? (pic GREAT)
We recently detailed the threat posed by plans for the UK’s largest solar farm on the North Kent Marshes, near Faversham.
Then the plans covered 890 acres of Graveney, Nagden and Cleve Marshes – that figure has since expanded to 1,000 acres, to allow, according to developer Cleve Hill Solar Park Ltd, for “expanded habitat management areas” dedicated to wildlife.
The increased acreage would also allow the developer to work with the Environment Agency on maintaining flood defences, the extension covering “the area where any maintenance might be needed”.
A second public consultation ended in July and drew more than 700 “pieces of feedback”, resulting in the anticipated application to the Planning Inspectorate for a Development Consent Order being delayed from August to October 31, 2018.
CPRE Kent is vehemently opposed to Cleve Hill Solar Park due to its scale, its position within the North Kent Marshes, which are internationally important for birds, and the drastic effect on the landscape.
“If I was to think of the worst possible place to put a solar farm, it would be here,” director Hilary Newport had said when the proposal was announced.
“We absolutely support the provision of renewable energy, but solar panels should be on roofs, not trashing landscapes in an astonishingly beautiful part of the North Kent Marshes.”
Dr Newport’s view strikes a chord in this part of the world. As a Faversham resident noted on social media: “If we are to lose Nagden Marshes, Graveney Marshes and Cleve Marshes to the biggest solar farm in the UK, why are the hundreds of new houses being built in Faversham not having solar rooftops?”
If that is possibly the definition of a rhetorical question, the destruction of such a huge expanse of land in an area so important for wildlife and people alike is anything but a light-hearted matter.
CPRE Kent’s response to the second public consultation totalled almost 1,700 words, our primary concerns focusing on the following areas (more may be added after scrutiny of the DCO application):
Damage to landscape, including tranquillity and dark skies
Inadequate assessment of flood risk and potential conflict with the Environment Agency’s ‘managed retreat’ strategy
Impacts on soil microclimate and hydrology
Damage to heritage assets caused by construction traffic
Loss of agricultural land
Threats to animal welfare
With government offering little or no incentive for solar energy to become an integral requirement for housing development – the export tariff, the money given to householders with solar panels for the electricity they provide to the national grid, ends on March 31, while it has announced that it will not be subsidising any renewable-energy projects until at least 2025 – can such an environmentally damaging proposal as Cleve Hill be justified?
CPRE Kent recognises the challenges of climate change and the government’s commitment to meeting carbon-emission targets but does not consider that the renewable-energy benefits of Cleve Hill outweigh the damage it would cause the North Kent Marshes.
We also question the sustainability of reliance on lithium-ion battery technology, with its own remote but concerning ecological impacts.
More broadly, Kent could not be accused of failing to contribute to the country’s renewable-energy needs. The website MyGridGB’s UK Renewable Energy Map shows that, in October 2017, this county had 36 solar farms either active, in construction or awaiting construction. Neighbouring Surrey, by comparison, had just two… and one of those floats on a reservoir.
Further, Kent hosts five wind farms, including, in London Array, the second-largest offshore site in the world. A sixth is planned.
Cleve Hill lies on the boundary of Swale and Canterbury districts, and two councillors from the latter local authority have pointed out in the local press that, in terms of providing ‘green energy’, “the Canterbury area alone is punching six times its weight against the national average”.
Michael Wilcox is chairman of GREAT (Graveney Rural Environment Action Team), which has been fighting the solar park plans at Cleve Hill and has been encouraged by the response to the consultation.
“I think they’ve been overwhelmed by the feedback, which has led to the delayed application,” he said.
“We haven’t really seen any changes from the developers since the consultation, so we don’t really know what’s going on, but both Kent Wildlife Trust and our local MP Helen Whately have openly come out against the scheme.”
There is a belief among some that the Cleve Hill application is a ‘done deal’, that conversations behind closed doors have secured a decision in the developer’s favour, but Mr Wilcox does not see it that way:
“I think opposition is building. I thought it might have been a done deal, a tick in the box for the carbon targets they’re chasing, but as the months have gone past it’s become glaringly obvious that it’s not green energy if you’re destroying countryside and harming wildlife. “This looks and feels like a dense industrial development and I think people question if this is the answer.
“I want to be clear: we are not against solar energy, but this kind of thing is dirty solar. Why new homes are not incorporating solar panels is a mystery – when a house is being built is the easiest time to put in solar.”
The loss of wildlife is one of the most distressing aspects of the Cleve Hill project for Mr Wilcox, who lives in Nagden.
“It’s this little pocket of land that somehow missed being designated as worthy of protection. If it’s solely down to land management, then there’s the lovely story of Elmley over on the Isle of Sheppey, where 40-odd years ago some of the site was farmed for arable and the production of barley or corn but has now been converted back and forms part of a nature reserve.
“The land here has been identified for managed retreat and conversion towards intertidal saltmarsh, but under this scheme it would be killed by a whole load of steel.
“Apparently the developer has described it as just muddy fields, but on those muddy fields there are nesting lapwings, skylarks and reed buntings, while they form part of a wider expanse necessary for birds of prey such as marsh and hen harriers.”
When considering how Cleve Hill Solar Park would look, you need to disregard anything you might already have seen elsewhere.
“It would entail about a million panels packed very densely. Rather than the familiar south-facing setting, they would have an east-west orientation and look like a factory,” said Mr Wilcox.
“The normal appearance of a solar farm is quite benign, but this design made me question the whole proposal as it’s so dense and has panels up to 4.3 metres high – as high as a London double-decker bus.
“South-facing panels have substantial space between them so they don’t shade each other, whereas east-west ones are about blanket coverage that can absorb more radiation early and late in the day.
“These would be angled at about 12 degrees – almost flat – whereas south-facing panels are 30-40 degrees.
“The panels planned for Cleve Hill would be 24 metres across with just three 30-centimetre gaps to let the rain drip off. The rows would be up to half a kilometre in length and there would need to be 2.5-metre spaces between the rows to allow for maintenance.
“In short, the ground would be receiving barely any sunlight and effectively die.”
The developer says it is looking to include “battery storage technology” in its scheme although it has not decided on the details.
“It’s likely the battery would need about nine hectares, together with a new bund around it,” said Mr Wilcox.
“The battery storage could make this more about price speculation than energy production – a similar installation in Australia is reported to earn huge profits by selling energy when it’s more expensive.”
A verdict on the proposed Cleve Hill Solar Park could be expected from the Secretary of State for the Department of Business, Energy and Strategy in late 2019. For the wildlife that depends on this special place and for the people who love it, there can only be one acceptable answer.