After last week’s full council vote, the Swale Local Plan is now out for consultation.
Residents and other interested parties have until Tuesday, March 23, to submit their comments.
CPRE Kent and others have cautioned against going to this formal stage of consultation without undertaking the Draft Issues and Options consultation that had previously been promised.
It remains an overriding concern that this decision may inadvertently delay the Plan, either by hostile third-party challenge or through failure of the legal and procedural test at the Local Plan examination. The latter happened recently with the Tonbridge and Malling and Sevenoaks Local Plans.
Of course, a delayed Plan means a greater risk of speculative applications in the meantime.
These fears are compounded by the lack of the necessary evidence base to inform this consultation, most notably the absence of the required Sustainability Appraisal.
It is extremely concerning that a decision to go to consultation has been made before this important work has been finalised. We would urge Swale Borough Council to ensure the required six weeks is available to consider this evidence once it is completed.
More generally, CPRE Kent will be considering the detail of Swale’s Plan and supporting evidence over the coming weeks. Our early concerns, however, include:
- The lack of meaningful consultation undertaken so far. This is particularly the case for the development now being proposed at Teynham and Lynsted
- The lack of traffic modelling. This is a significant evidential requirement that goes to the heart of the soundness of the Plan and runs across many separate issues. The need and importance of such evidence is clearly set out in planning guidance
- The uncertainty as to what infrastructure is required to deliver the Plan. Most notably, this includes whether a bypass at Teynham is required and the extent of improvement at junctions 5 and 7 of the M2
- The chosen distribution of development leading to a worsening of air quality in the borough’s Air Quality Management Areas (AQMAs)
- The coalescence of the two contrasting parish settlements of rural Lynsted and more urbanised Teynham.
This list is not exhaustive and represents our initial views only. We would, however, strongly encourage all of you who care for the future of Swale to consider carefully the proposals and make your opinions known.
The consultation document can be found here
Tuesday, February 9, 2021