A scheme for 440 homes in Otham has been backed at appeal by a planning inspector. The greenfield site had been allocated in Maidstone Borough Council’s 2017 Local Plan “as a strategic development location for housing growth with supporting infrastructure”. However, in July the local authority’s policy and resources committee voted to reject the project, west of Church Road next to St Nicholas Church, after it had already twice been rejected by the planning committee. Council officers had recommended the development be approved, fearing that, with the site included in the Local Plan, developer Bellway would win an appeal. And last week the Planning Inspectorate announced that inspector Stephen Normington had allowed Bellway’s two appeals, which he had considered jointly. The first related to non-determination of an outline planning application for 440 homes, with the second coming after MBC had refused an application for a revised project of 421 units. Mr Normington’s report concluded there was “no demonstrable evidence” supporting one of the council’s reasons for refusal on highways grounds. The council had cited the impact of the development on traffic congestion in Willington Street and highway safety at Church Road. The county council had also raised highways objections. Although he said there was “no doubt in my mind that the appeal proposals will contribute to the congestion already experienced on Willington Street to a degree”, the inspector continued: “Whilst this would undoubtedly cause driver inconvenience, I have no substantive evidence to suggest that this would cause a highway safety problem.” Further, he did “not consider that the proposed developments would demonstrably cause worsening safety issues on Church Road to the south of the site to the extent that both these appeals should be dismissed”. He also added “significant weight” to the fact the development would “include affordable housing to meet a demonstrable housing need on an allocated housing site”. Mr Normington made a partial costs award against MBC, concluding it had “behaved unreasonably” in reaching its decision on its first reason for refusal. CPRE Kent was represented at the appeal, arguing that Bellway had failed to demonstrate how Church Road could be modified safely and that the impact of the proposed development on the Grade I-listed church and nearby Grade II-listed buildings was unacceptable.
There is enough brownfield land for 1.3 million new homes, while more than half a million already have planning permission, a report from CPRE, the countryside charity, reveals. The figures demonstrate that there is already enough available and suitable land in the planning system to meet the government’s ambition to build 300,000 homes per year for the next five years (this Parliament), calling into question the hugely controversial plans to deregulate the planning system that has been proposed by ministers. Brownfield land – land that has previously been built on and now sits derelict or vacant – provides a valuable resource in the protection of greenfield land from development. The State of Brownfield report 2020 is the latest in a series of CPRE reports on the brownfield register, which catalogues the number of brownfield sites available for development. The analysis clearly shows that the planning system is not slowing building rates. There is currently planning permission for more than half a million (565,564) units on brownfield land. In February 2020, the Local Government Association found that more than one million homes in total had been granted planning permission but not yet built. This means that brownfield sites and other unbuilt sites with planning permission could provide more than 1.5 million new homes – in short, we need not suffer the staggering loss of countryside that recent government proposals could bring about. Crispin Truman, chief executive of CPRE, said: “These figures clearly show that the planning system is not what is ailing our housing market. “If there is enough land in the planning system to meet the government’s own housing targets, what will an overhaul of the planning system, with rushed and untested changes, really achieve? It’s clear the government has gravely misdiagnosed the problem – slow build-out rates and market-led housing are blocking the quality affordable housing that rural communities are crying out for. “But there is a real prize in brownfield – what says ‘build back better’ more than adopting a truly ‘brownfield first’ approach that will breathe new life into the long-forgotten and derelict areas in our towns, cities and villages? This approach will deliver huge benefits, building the affordable homes in areas where communities want to live, providing access to better transport links and amenities and services they need. “As things stand, the government’s proposed changes will result in a free-for-all, allowing big housebuilders to build what they like, where they like and when they like. Now more than ever is it vital that the government listens to local communities, promotes a genuinely ‘brownfield first’ policy and brings forward more brownfield sites for development so we can build more affordable, well-designed homes.” Many areas across England with high housing need also have a large amount of brownfield land ready for redevelopment. London, Manchester, Birmingham, Leeds and Sheffield have identified land available for regeneration that would provide almost half a million homes (458,587). To make best use of suitable brownfield land, CPRE is urging the government to introduce a genuine ‘brownfield first’ policy that ensures suitable previously developed or under-used land is prioritised for redevelopment over green spaces and countryside. Clearer definitions and guidelines must be given so that the registers act as a true pipeline, identifying all possible brownfield sites and recording their suitability for uses other than housing, including uses that protect the biodiversity or heritage value of sites where applicable.
To read Recycling Our Land: The State of Brownfield 2020, click here
Consultation on the second major tranche of proposed changes to the planning regime closed yesterday (Thursday, October 29). Despite the government’s stated aims of ‘levelling up’ the country and prioritising brownfield redevelopment, we see little within the proposals that would actually achieve that. Along with so many others in the wider CPRE network, we raised our concerns over the proposals, which would see a significant increase in the amount of rural land that would have to be allocated for housing, and would mean people would see a dramatic reduction in their ability to have a say about how their communities develop.
It was heartening to see so many MPs echo CPRE’s concerns in a parliamentary debate on Thursday, October 8. We hope our concerns will be heeded and we can maintain a planning system that has communities, nature and the climate at its heart.
CPRE Kent has submitted its response to the government’s Changes to the Current Planning System consultation (click here). The process could have an ultimately devastating impact on much of Kent, with almost all the county’s district authorities facing housebuilding hikes of up to 125 per cent. If the consultation figures are accepted as part of planning policy, Kent will need to build an extra 2,835 homes a year on top of current targets, which are already frighteningly high.
Plans for 900 new homes in Herne Bay have been turned down by councillors despite officers recommending they be approved. The 136-acre site at Sweechbridge Road had been allocated for development in Canterbury City Council’s Local Plan, but concerns over open space and density saw Taylor Wimpey’s application for hybrid consent refused. Consent was being sought by the developer for an initial 193 homes of the scheme, together with access works, drainage infrastructure, open space, landscaping and street-lighting. Outline consent was also sought for up to 707 further homes, up to 27,000 square metres of employment space, a care home, shops, a community centre, a school, open space and infrastructure works. Planning officers had recommended the scheme be approved, a planning report saying the site “forms the major part of a strategic allocated site for a mixed-use development in the Canterbury District Local Plan”. It continued: “The application site will provide a significant amount of the homes that are required to meet the district’s need, as well as providing employment opportunities for local people. This application is therefore acceptable in principle.” However, the proposals were refused at a planning committee meeting on Tuesday, September 1. A council spokesman said members had concluded the scheme would not provide for “sufficient high-quality open space for active and continual use due to the amount of that space which contains attenuation ponds/features”, making it contrary to national planning policy. Further, the development “at 40 dwellings per hectare is over-dense and would amount to an overdevelopment of the site given the location of the site”, while its proposed 22.5 per cent affordable-housing provision failed to meet the 30 per cent sought by local planning policy. Members also found a “lack of sustainable infrastructure such as solar panels and electric vehicle-charging points”, against Local Plan policy, and “highways arrangements proposed would not provide safe movement within and around the proposed development”.
CPRE Kent, the countryside charity, has given a cool response to “once-in-a-generation reforms” to the country’s planning system proposed by the government today (Thursday, August 6). Described as “landmark reforms to speed up and modernise the planning system and get the country building”, the changes proposed in the Planning for the Future White Paper are unlikely to benefit our countryside, John Wotton, chairman of CPRE Kent, said. Mr Wotton was responding to a statement from the Ministry of Housing, Communities & Local Government and Housing Secretary Robert Jenrick saying “an overhaul of the country’s outdated planning system that will deliver the high-quality, sustainable homes communities need will be at the heart of the most significant reforms to housing policy in decades”. According to the statement, core reforms will mean:
Local communities will be consulted from the very beginning of the planning process. By harnessing the latest technology through online maps and data, the whole system will be made more accessible
Valued green spaces will be protected for future generations by allowing for more building on brownfield land and all new streets to be tree-lined
Much-needed homes will be built quicker by ensuring local housing plans are developed and agreed in 30 months – down from the current seven years
Every area is to have a Local Plan in place – currently only 50 per cent of local areas have a plan to build more homes
The planning process is to be overhauled and replaced with a clearer, rules-based system. Currently around a third of planning cases that go to appeal are overturned at appeal
A new simpler national levy to replace the current system of developer contributions, which often causes delay
The creation of a fast-track system for beautiful buildings and establishing local design guidance for developers to build and preserve beautiful communities
All new homes are to be ‘zero carbon ready’, with no new homes delivered under the new system needed to be retrofitted as we achieve our commitment to net zero carbon emissions by 2050
One of the more contentious aspects of the proposals is the concept of zonal planning, with land designated in one of three categories: growth, renewal or protection. It is also stated that “valued green spaces and Green Belt will continue to be protected for future generations, with the reforms allowing for more building on brownfield land”, while “local community agreement will be at the centre of the proposals”. However, Mr Wotton said: “We find hard to see how the planning reform proposals, unveiled by the government this morning, will benefit the Kent countryside. “The policy driving the proposals, of building more homes, more quickly, appears to override the safeguards in the present system ensuring that local communities’ needs are taken into account and that harm to the environment and landscape from building new homes is prevented. “If local authorities are to lose their ability to approve the details of new developments, by what means can the views of local communities continue to have real force? “We support the efficient provision of sufficient sustainable, affordable homes in Kent, in the places where they are most needed and where they will not harm the countryside, especially our much-valued Green Belt and two Areas of Outstanding Natural Beauty, and we support, as a general principle, the use of brownfield sites first. “We are concerned that a standard infrastructure levy for housing developments, in place of Section 106 Agreements, will hand over the responsibility for the provision of both the additional infrastructure required as a result of new development and the provision of affordable housing from developers to local authorities, who may not have the resources to make these things happen. “We will be studying these proposals in detail, in conjunction with the wider CPRE network and will participate actively in the coming public debate.” Echoing Mr Wotton’s concerns, Tom Fyans, CPRE’s deputy chief executive, said: “The key acid test for the planning reforms is community involvement and on first reading, it’s still not clear how this will work under a zoning system. “Although we welcome the government’s commitment to all areas having a Local Plan in place, we also need robust legal guarantees that the public are consulted regarding new development. “Red lines on a map are not going to build trust in the planning system. As things stand, the government seems to have conflated digitalising planning with democratic planning – they’re not the same thing. “The government’s aim to deliver carbon-neutral new homes by 2050 is pitiful and represents 34 lost years given that the Code for Sustainable Homes aimed to achieve the same thing by 2016 and was dropped by government. “If this government is serious about tackling the climate emergency, it needs to be much, much more ambitious on new-build. “On affordable homes, our concern is how this approach might play out in the countryside. In many rural areas, house prices are often more than 10 times average earnings, and so the 30 per cent discount won’t cut it. Local authorities should be able to provide the sorts of homes needed in their area – homes that local people can afford. “We have long advocated for a genuinely brownfield-first approach and on this aspect, the government seems to have listened. But if a brownfield-first approach is to work, local authorities need to be able to prioritise the building of those sites and reject unnecessary losses of greenfield land.”
The London Green Belt Council, of which CPRE Kent is an associate member, has described government proposals for reform of the planning system as “a mixed bag”. It applauds the provision of some countryside protection in the Green Belt and Areas of Outstanding Natural Beauty but is disheartened by the threat to local democracy and restriction of community involvement in the planning process. Responding to today’s (Thursday, August 6) publication of Planning for the Future by the Ministry of Housing, Communities and Local Government (MHCLG), Andy Smith, secretary of the London Green Belt Council, said: “We welcome the government’s pledge to protect Green Belt and AONB countryside from development, but we are disappointed that ministers have missed this opportunity to strengthen local democracy and have instead opted for policies that circumvent local communities. “We are also concerned about potential reductions in building standards resulting from the government’s intention to ‘fast-track’ developments at the expense of quality and the environment.” The LGBC will be participating in the government’s consultation on the White Paper and is urging communities throughout London and the South East to “have their say, and to bring pressure to bear on ministers to ‘think again’ about planning”. Mr Smith adds: “The priority for any reforms to the planning system in England should be to increase public participation and to improve the quality and environmental sustainability of new developments. “While the White Paper’s reaffirmation of the important role of the Green Belt is very welcome, there is a danger that the current proposals from ministers will lead to a massive reduction in local democracy and accountability, which will harm the environment and will benefit only the developers and their profits.”
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