District chairmen’s reports… in their entirety!

Maidstone’s Gary Thomas is one of the district chairmen who contribute so much to CPRE Kent

In the Autumn/Winter 2019/20 edition of Kent Voice, we carried reports from our district and committee chairmen from around the county. Space restrictions meant we couldn’t bring you them in their entirety, so here they are…

Ashford – Christine Drury

  • CPRE Ashford would love to have more volunteers bringing their local knowledge to help us make relevant and constructive comments on planning applications, large and small. We also now have a separate meeting looking at wider issues that may help us make early suggestions for the next Local Plan, as well as immediate issues. If you are interested in either, please contact the office on 01233 714540.
  • Since the 38-minute high-speed train service to St Pancras started in 2009, the Ashford area has become a developers’ honeypot. That has been good for the long-awaited regeneration of the town centre, although it has lost its M&S and will lose its Debenhams. Flats are being built, a cinema and brewery have arrived and restaurants, leisure and culture are the next priorities for the town centre. We support this brownfield regeneration.
  • The Local Plan includes the development of large swathes of countryside to the south of the town, adjacent to the now-emerging Chilmington Green urban extension. Together these are now designated as South Ashford Garden Community. We have commented formally and are engaging to ensure these are well-planned developments including provision for cycling and walking, with 10-minute bus provision assured. Outline plans are too car-dependent.
  • The pressures outside Ashford town are now huge. The borough is one of the largest in the county and, like most of Kent, is more than 75 per cent countryside. Houses in villages sell at a premium. If developments comprise fewer than 10 properties and are in a small plot they avoid the 40 per cent affordable requirement. Cumulative impacts are being ignored. In the absence of buses, shops and local school places, they are car- and delivery-dependent, putting huge pressures on rural roads as well as being against the direction in which we need to move to be climate-behaviour-compliant. Ashford CPRE generally supports small infill development, but in combination with allocated sites the cumulative strain on parishes is destructive. Some are outrageously opportunistic: Wates’s proposal for a further 250 homes in Tenterden is not in the Local Plan and would destroy the character of a small town where the green spaces reach deep into its heart from the surrounding AONB. Tenterden already has a lot of approved development and an inadequate bus service.
  • We collaborate wherever we can in the borough – currently with Rural Means Rural and the Limes Land Protection Group in Tenterden. Do contact us if you are part of a group not yet working with CPRE.

    Canterbury – Nick Blake
  • After Barrie Gore’s report in the previous edition of Kent Voice featuring the city council’s own application for a park-and-ride at Wincheap, it has reacted to a huge amount of objection but only by moving the edge back a few metres from the River Stour. This fails to recognise the impact on the Stour’s setting in this edge-of-city location. The floodplain is fairly narrow at this point, but the presence of trees means the river setting survives the proximity of Wincheap Industrial Estate. It seems our city council has no passion or eye for detail. Members of the planning committee will be in the difficult position of voting on their own council’s application. It is possible many might feel unhappy about the application but be compromised by the situation.
  • The so-called heritage champion is now also the leader of the council, which we feel is a potential conflict of interest. He has not championed any heritage cause – all we get are meetings and strategies but no positive action. The city has what look like effective policies to protect the environment, but they are not implemented. We focus so much on well-written documents, driven by hours at the desktop rather than going out and seeing.
  • Housing developments are stalled because of stakeholders not meshing together. At Sturry the council’s ‘green gap’ highlighted in the Local Plan is ridiculously narrow and will not prevent the visual merging of that village with Canterbury. The adjacent woodland that is to be retained has wedges of housing thrust into it and no plan for its maintenance. No countryside protection there!
  • The A28 Sturry relief road is short of finance and is set between planned housing developments. Have you noticed how much new housing is sited next to busy roads yet such locations have been shown to be bad for health? The nearby development at Hersden looks just like any other estate. Why do we have policies asking for local distinctiveness when we get the same mediocre housing all over the country? So not a jot of cheer from our city, I’m afraid.

Dartford and Gravesham – Alex Hills

  • The Bean interchange public inquiry began at the start of October. The Highways England proposals will not achieve their objectives, having a greater impact on the environment and residents than they should. Creating an additional eastbound slip road at Bean on to the A2 will have a negative impact on the strategic road network. It is concerning that no peak-flow forecasting work was done for the project or analysis of what the impact would be if the new Thames crossing was built and one of the crossings was closed.
  • It seems the only thing that will stop the new Thames crossing going ahead now is funding. This is totally wrong; however, now is the time to stop fighting the proposals and focus on making the project as good as we can. Getting as much of the road underground and minimising the impact on Kent roads must be our objectives. The crossing will have a large impact on Dartford, Gravesham, Maidstone, Tonbridge & Malling and even Dover.
  • It is not possible for the crossing to include a rail link due to topography on the Kent side and the required larger tunnel bore would cause the tunnel to rise.
  • There is a viable £3 billion project being developed that would see a new railway line linking HS1 with the London Gateway deepwater port in Essex. Having witnessed the problems CPRE has had over HS2 and how evidence has come to light showing the project is not in the national interest, I would urge caution with this scheme.
  • I would like to make a plea to not support any cycle lanes that are just painted lines in the road as research in this country and in Australia has proved it makes the road more dangerous for cyclists. The reason is that cars drive closer to cyclists when there is a painted cycle lane than when there is no road marking. Pedestrians, cyclists and motorists should be separated by some form of physical barrier.

Dover – Derek Wanstall

  • Dover District Council is progressing with its Local Plan review. At a recent meeting, concerns were expressed about infrastructure and the amount of traffic exiting Deal at peak times, which is causing frequent hold-ups at upper Deal roundabout and on the Dover, Deal and Sandwich bypasses towards Thanet. Of course, development on the edge of these towns exacerbates the problem.
  • Lydden Hill racing circuit will soon be up for discussion, with new plans for expansion being submitted. Noise and access is a serious problem, in conjunction with the proposed increase in race days, along with concerns relating to the AONB.
  • We await further news on Farthingloe and Western Heights. Nearby, The Citadel is up for sale as it is not being used for immigration detainees. With heritage refurbishment also on the agenda, perhaps the future of the whole area should be reviewed. It is good to see progress being made.
  • CPRE both nationally and locally is discussing ways of increasing membership, helping to keep our countryside for the future. Developers who try any way possible to achieve their ambitions by ignoring AONB and Green Belt designations must not be supported. CPRE has always stated its support for development but in the right places. Proposed developments should always consider properties for low-paid workers and people who wish to downsize.
  • Air pollution is a great concern, with more vehicles on the roads, engines left running in hold-ups and so on. Developers should plant more trees and retain them on development sites, improving the health of the nation. Sadly, the continual increase in the population only means an increase in the number of properties required.
  • Members and non-members alike are invited to the Dover AGM on Tuesday, November 5 (11am), at The Royal Hotel, Beach Street, Deal CT14 6JD. Refreshments and nibbles will be available.
  • Finally, at the Dover AGM I shall not be seeking re-election as chairman. With important issues in the area, hopefully a good turn-out will bring forth both a new chairman and a minutes secretary.

Maidstone – Gary Thomas

  • The review of the Maidstone Local Plan is taking place, due to be in place for 2022. The responses to the recent Call for Sites are due to be publicised very soon. We have responded extensively to the review, both in writing and through meetings. The increased annual rate of building from 882 dwellings to 1,236 from the start of the new Plan in 2022 presents huge problems and is due largely to the government’s ‘adjustment factor’ imposed on local authorities. This appears to just make a bad situation worse by concentrating development so heavily in the South East. The failure to match the need for improved infrastructure alongside the increasing population is obvious, but Maidstone Borough Council has no responsibility for most of what is needed (for example traffic, roads, health, education, waste disposal and public transport) so this severe mismatch is set to continue.
  • Three proposals for large ‘garden communities’ are causing great concern. Two are from developers – one just north of the county showground, the other alongside Marden – and one apparently organised by the borough council (secretly!) for Lenham Heath. We will be responding more as the plans develop.
  • There are other planning applications in Lenham that are not in the Local Plan. Lenham Neighbourhood Plan appears to be being seriously delayed.
  • Two new Gypsy and Traveller applications feature large built ‘dayrooms’ on each pitch. Gypsies and Travellers have policies not available to the rest of the population due to their culture of living in caravans in the countryside, allowing them to continue in this way. Building ‘dayrooms’ appears contrary to the reason for this policy and is a development we think should be challenged.
  • The Glover review into national landscapes has, disappointingly, ruled out expansion of the Kent Downs AONB, at least for the time being.

Medway – David Mairs

  • A petition with hundreds of names was sent to Medway Council urging it to reject applications for large-scale development in and around “the important green lung” of Lower Rainham and Lower Twydall, including a proposal for 1,250 dwellings in the Pump Lane area and housing plans to the north of Rainham. If the proposals are accepted, they will remove a significant part of the greenfield buffer preventing a continuous urban sprawl between Lower Rainham, Twydall and Gillingham.
  • As with the rest of the county, Medway faces huge challenges if it is to retain substantial areas of countryside. CPRE Kent is, however, under-represented in the district, so we are keen to hear from anyone who lives in Medway and would like to get further involved with what we do. Please feel free to call the office on 01233 714540.

Sevenoaks – Nigel Britten

  • We have embarked on the final stage of the Local Plan, the examination in public. The central question for the inspector is whether the plan is ‘sound’, meaning whether it complies with policy requirements in all respects. Within that, the key issue is housing. The government’s formula for calculating housing need stipulates that 13,960 dwellings should be built during the 20-year Plan period, 2015-2035. Instead, the Plan proposes a total of 10,600, with the justification that in a district that is almost entirely Green Belt and two-thirds AONB there is nowhere to put so many houses. We have commented at all stages of the process and are grateful to our two professional planners at the CPRE Kent office, Paul Buckley and Julie Davies, who have given us invaluable support and been presenting evidence at the examination. One major purpose will be to challenge the intention at some future date to build some 2,500 dwellings on what is now Pedham Place golf course. Committee members have been attending on as many days as possible over the four-week period, commenting in particular on proposed sites at Edenbridge and Fort Halstead.
  • Threats to the countryside are everywhere. The committee is always ready to welcome new members, so we hope anyone reading this will think about giving a little time to help protect the district’s wonderful countryside.

Shepway – Graham Horner

  • Folkestone & Hythe District Council planners have published an initial response to Folkestone & Hythe’s planning application for Otterpool Park. It echoes many of the concerns we have raised, including requesting the applicant to provide more information on and/or reconsider:

• strategy for dealing with a major road (A20) cutting through the middle of the town

• more detailed proposals for the town centre (‘Tier 2’ design) and how it will integrate with the proposed public park, Westenhanger station, Westenhanger Castle and the A20

• the rationale for the ‘overarching spacial concept’ (for example, heights, legibility and key views)

• a ‘21st-century transport vision’ as opposed to ‘predict and provide’

• better non-motorised transport links within the development and to Sellindge and Folkestone

• merging of neighbourhoods planned south of the A20

• clarity on strategy for delivery: definition of ‘master developer’ and long-term stewardship/governance

• a more joined-up approach to green infrastructure and provision for leisure

• the level of detail to be agreed at this stage, especially for later phases

FHDC has bought Westenhanger Castle after a long negotiation. Objectors have branded this a waste of money, but it will open opportunities to integrate it better into the public realm.

  • I have, wearing my parish councillor’s hat, toured new developments in the Cambridge area (Alconbury to Saffron Walden) at FHDC’s invitation. The economy around Cambridge is significantly different to that in Shepway. We saw some high-quality housing but learned it comes at a price unlikely to be sustainable in our area. Letchworth is a model for what is now called ‘land value capture’; the town owns almost all the land and takes in £12 million a year from rents and other sources to be used for maintenance and community projects. FHDC will not own all the land at Otterpool Park. At all projects visited, there was a design code that could be enforced by mechanisms with more teeth than planning conditions (such as financial penalties).
  • There is no news on the examination of the draft Core Strategy review, without which Otterpool Park should fail at the first jump.
  • FHDC has just published for consultation a draft Gypsy and Traveller Strategy to address a shortcoming of the Places and Policies part of the Local Plan.
  • Development of Princes Parade was formally given consent, despite a vote in full council to abandon the project.

Swale – Peter Blandon

  • Swale’s administration changed after May’s local elections and a new alliance is now in control. Several of its members have a track record of opposing large-scale developments and, true to form, they have now refused planning permission for two large schemes. These are:

• up to 675 homes at Wises Lane in Borden, with associated schools, surgeries and transport links. This is a deeply unpopular development that goes a long way to merging Borden with Sittingbourne.

• up to 700 homes at Barton Hill Drive, Minster, on the Isle of Sheppey

Both these proposals are on land allocated for housing in the adopted Local Plan and both had been recommended for approval by planning officers. In January, the previous administration had resolved to grant planning permission to the Borden development subject to a satisfactory S.106 agreement. However, when the new committee considered the scheme, it voted 13-2 to refuse permission. The developers agreed to a short extension to the application (it was originally submitted in October 2017) and, when that expired, immediately appealed on the grounds of non-determination. The appeal is to be decided by the Secretary of State rather than a planning inspector. The Barton Hill development had almost been refused in February with an 11-4 vote against it. But, as happens in Swale, the head planning officer called in the application, effectively nullifying the vote. The proposal returned to the committee in July with a recommendation to approve but was refused. The grounds given were harm to landscape; the setting of Parsonage Farm, a listed building; insufficient affordable housing; and transport.
The developer has said there will be an appeal, but so far none has been lodged.
So, developments totalling almost 1,400 dwellings have been refused since the change of administration. This is about two years’ housing under the adopted Local Plan and against a background of Swale failing the government’s Housing Delivery Test, meaning it must now apply a 20 per cent buffer to its housing land supply. So more sites will need to be allocated for housing. As both planning applications seem likely to go through on appeal, Swale’s new administration might be playing a dangerous game.

Thanet – David Morrish

  • Lots of valuable work done has been done for us by the team at Charing over the past six months; I and the committee thank them for their professionalism and dedication – we are fortunate to have such a good team to back us up.
  • The last days of our two big inquiries (Local Plan and Manston airport) were enlivened by the shock news from RiverOak, the applicant for the Manston Development Consent Order, that Stone Hill Park Ltd had agreed to the Acquisition by Agreement by RiverOak MSE Ltd on July 2 for the purchase of all the land SHP had owned at the airport site. This effectively means that the largest obstacle to the potential reopening of the airport (the opposition of SHP to RiverOak’s bid for a compulsory purchase order) has apparently been overcome. However, at the DCO inquiry, it was apparent that little progress had been made with regard to the acquisition of the many parcels of Ministry of Defence-owned land covered by the DCO, including the navigational apparatus. There is also the question of who are the RiverOak backers, which will not be answered in public until Grant Shapps, Secretary of State for Transport, has made his decision. Apparently, neither the counsel for SHP nor for RiverOak had been informed of any details of the purchase other than the price and the associated provision for SHP to retain all income from the ‘temporary’ lorry park at Manston should Brexit necessitate its use, so we await Mr Shapps’s considered judgement in the new year.
  • In the meantime, Thanet District Council planners need to decide how to revamp the draft Local Plan now that the housing land originally planned by SHP has been taken out of the equation. Meanwhile, housebuilding flatlines in Thanet (and newly-built houses await buyers) as, presumably, building operatives flock to more profitable pastures elsewhere in Kent.

Tonbridge and Malling – Mike Taylor

  • It has been a troubling time, largely due to Tonbridge & Malling Borough Council’s deeply flawed draft Local Plan. It has fragmented the borough into areas that support parts of it but who are terrified that any revision will fall on them and areas that have been unfairly loaded with housing proposals. Despite lodging the Plan in January, there is no sign of the appointed inspectors accepting it, which has left the door open to the usual suspects like Gladman to attempt ‘windfall’ applications because of the swiftly diminishing housing land supply.
  • The latest bombshell for TMBC is that the inspectors will split the examination into two phases, if it ever happens. Phase 1 will examine three issues – procedures, Green Belt and selection – while Phase 2 will not proceed until the inspectors are satisfied with Phase 1. We have long said that TMBC’s selection process was deeply flawed, allocating some 4,000 homes in the Green Belt while ignoring plots in the Call for Sites that were deemed ‘suitable and achievable’ and non-Green Belt, which could have provided 11,700 homes. This tends to explain the inspectors’ requirements for the Phase 1 examination.
  • It has been difficult here because traditionally we have been composed largely of parishes in the north-west of the borough, one of the areas hit hardest by the Local Plan proposals, but we are aware it would be desperately unfair to use our position on the committee to push through an official CPRE response that has a strictly local benefit, and so we have limited the number of meetings held in recent months.
  • While the government continues to swear it will protect the Green Belt, many refusals for Green Belt development are being overturned after higher intervention and so we have supported parishes in drafting a petition that demands the government properly defend Green Belt nationally: see here

Tunbridge Wells – Liz Akenhead

  • The draft Local Plan has at last been published, with Regulation 18 consultation to run to Friday, November 1. We are struggling to get to grips with its 518 pages, along with the 217 pages of almost unintelligible Sustainability Appraisal (in which the economic and social elements are generally held to outweigh the environmental) and hundreds of pages of other supporting documents such as the final Strategic Housing and Economic Land Availability Assessment (SHELAA), the Distribution of Development Topic Paper and the Draft Infrastructure Delivery Plan.
  • The Plan states that overall some 5.35 per cent of the Green Belt within the borough is to be de-designated and that “in accordance with the NPPF the Plan does not designate other land as ‘replacement’ Green Belt to replace that to be removed, but rather sets out how compensatory improvements to the environmental quality and accessibility of remaining Green Belt land can be made”. On a first reading, I have not noticed much evidence in the Plan that these improvements will materialise.
  • In a borough where 70 per cent of the land is AONB, 22 per cent (some of which overlaps with the AONB) is Green Belt, 16 per cent is ancient woodland, 7 per cent is floodplain, almost all ‘rural fringe’ land has already been allocated, brownfield opportunities are limited. With a reluctance to build high-rise in historic town centres, there are no painless ways of accommodating the housing numbers required under the government formula together with their associated development. Surely if there is anywhere the government’s policy exception to the requirement to provide for the full Objectively Assessed Need (OAN) for housing should apply, it ought to be Tunbridge Wells, with its protected areas such as Green Belt and AONBs. However, not only does the draft Local Plan aim to meet the full OAN, it proposes to exceed it by 9 per cent!
  • As well as massive development at Paddock Wood (4,000 dwellings in addition to the 1,000 already allocated there but construction reported to be halted because of problems with foul drainage) and 2,500-2,800 dwellings proposed at Tudeley, up to 800 dwellings will be allocated in the AONB at Cranbrook and some 700 in the AONB at Hawkhurst. New secondary schools are planned on AONB and Green Belt land at Spratsbrook Farm/Ramslye Farm south of Tunbridge Wells (with more than 200 dwellings as well) and on Green Belt land containing ancient woodland on the edge of Tonbridge. The villages have smaller allocations.
  • In addition to safeguarding land for the dualling of the A21 from Kippings Cross to Lamberhurst, three new roads are proposed to serve the proposed new developments, which will partly pay for them: an offline A228 Colts Hill bypass; a partly new, partly upgraded road (whose alignment remains to be decided) between Tonbridge and the new A228 bypass to serve the proposed Tudeley settlement; and a new road at Hawkhurst to partially bypass the Highgate crossroads. Very little information has been provided about the environmental effects of or justification for these new roads.
  • We shall be responding robustly to these issues, but the draft Plan is not all bad: many of the proposed Development Management Policies deserve support and where this is the case we shall give it.

Environment – Hilary Newport

  • The environment committee has a new chairman in David Wood, who took on the role after Graham Warren stood down after 16 years in the position. Graham was given a gift as a sign of appreciation for his contribution to CPRE Kent and, in particular, this committee.
  • The main topic has been the proposed Cleve Hill solar farm and committee members have made a range of contributions to the ongoing CPRE Kent submission to the public examination.
  • Graham Warren prepared a report for the campaign group at Dunsfold, Surrey, contesting plans for shale-gas exploration there.
  • Other issues covered by the committee have included land use, food security, waste and water resources.

Historic Buildings – John Wotton

  • The Historic Buildings Committee again partnered with the Kent School of Architecture and Planning to make the annual Gravett Award for Architectural Drawing. From a large field of entries on the theme of Norman architecture, the judges, chaired by architect Ptolemy Dean, chose Ayako Seki as the winner for her drawings of Dover Castle. She was presented with the award at the school’s end-of-year show and prize-giving.
  • The proposed development at Prince Parade, Hythe, between the Royal Military Canal and the sea remains a concern to the committee. We objected to the application and the council’s granting of planning permission to itself remains controversial, especially after May’s local elections. The branch will be supporting a campaign to save Princes Parade.

Read the full reports from our district chairmen

Christine Drury… no longer CPRE Kent chairman but carrying on the fine work as Ashford chairman

In the Autumn/Winter edition of Kent Voice, we carried reports from our district and committee chairmen from around the county.
They were comprehensive and entailed a lot of work on their part, but space restrictions meant we couldn’t bring you them in their entirety, so here they are…

Ashford – Christine Drury
Ashford has a five-year housing land supply. That was the advice of the Local Plan inspectors at the end of June. In Ashford’s case it is six years as the borough council carries a 20 per cent buffer for non-delivery against previous high housing targets as a growth area. At more than 1,400 dwellings per year, the target is still high. Will developers build, and could they sell that many? The next hurdle will be when the government publishes the first housing delivery results in November. This is a new test in the revised National Planning Policy Framework published in July.
Three appeals by Gladman Developments Ltd were withdrawn at the time the inspectors’ advice was published, less than a week before the Brabourne Lees appeal was to be reconvened, before the Charing appeal was due to report and as Biddenden was in preparation. It was a relief to see those three appeals abandoned, but the much larger one in the countryside beyond Kennington remains a threat. None of these sites are in the Local Plan. Gladman’s predatory business model causes a great deal of anger and stress for communities and cost for councils.
Outline planning applications are being submitted for sites that are in the Plan.  The one dubbed Large Burton Farm will be difficult to absorb next to Kennington on the edge of Ashford unless it is very well designed and phased. Local engagement is proving difficult when so many people find it so wrong.
Where sites are smaller, they can be cumulatively disproportionate for villages. Rural Means Rural is campaigning strongly on precisely this point. The inspectors listened and the modifications requested reflect that they can only be effective if we are all vigilant in monitoring what is being proposed and whether it is in character in terms of its scale and design. Cumulative effect must also be considered.
CPRE Kent is advocating that the highly successful green corridors plan for urban Ashford be adapted for rural areas, too. It is needed because this Local Plan includes more development in and around the borough’s villages. In urban areas the corridor is the Stour riverbank and floodable areas alongside the river. It is a popular non-motorised route with commuters and children cycling to school, forming part of the Sustrans National Cycle Network (Route 18).
Charing and Hamstreet are two villages that appear to score well on sustainability criteria as they each have a railway station, school and doctors’ surgery, together with a modest high street. However, they both have sensitive drainage and run-off risks that are not being recognised.
Construction of junction 10A on the M20 is proceeding to plan, although it should have been built 14 years ago. The ‘shaving away’ of trees to make way for the bulldozers and pile-drivers was a visual shock, but planting and time will heal after the junction opens in the summer. The new junction will help realise more brownfield housing development on the old Ashford railway works.

Canterbury – Barrie Gore
Canterbury City Council has bought a former student block for conversion to social housing. It has also announced it will build more social housing elsewhere. So, although rather late, these are welcome steps to redress the imbalance between private and genuinely affordable housing. We don’t yet know if housing associations will be involved.
The council has applied for a judicial review of the decision by the Secretary of State for Housing, Communities and Local Government (James Brokenshire – how apt) to overrule the refusal of planning permission for housing at Strode Farm, Herne. We don’t yet have the grounds for the review but, as the site was allocated for housing in the Local Plan, we are intrigued, especially as the council has announced an AQMA [Air Quality Management Area] for Herne as other massive developments along the Thanet Way and at Sturry will cause serious traffic and air pollution problems in the village. We have supported the determined and excellent Herne and Broomfield Parish Council throughout. We are all disappointed at the minister’s decision and welcome the review.
The long-threatened application for an enormous development in the Kent Downs AONB at Highland Court Farm, Bridge, has now been lodged. It is for a large leisure complex for tourists and includes upmarket housing, proposed new grounds for Canterbury football and rugby clubs, plus tennis courts and other holiday facilities. There has been a growing trend to win support for unsuitable developments from sports and health organisations by offering them new facilities.   We, together with the Kent Downs joint advisory committee, the Barham Downs Action Group and many others, will be opposing the application. It is another glaring example of attacks by developers on valuable open spaces in the countryside. The government is doing nothing to stop this, leaving under-funded local authorities to cope as best they can.
There are increasing attempts by applicants to deface conservation areas in the city by applying for unsuitable advertising material and shop fronts despite the protection given, but sadly not always applied, by the Local Plan. Unfortunately, the councillor who was appointed Canterbury’s heritage champion wears two hats as he is also on the planning committee, when most of us believe he should only be involved in heritage issues and not be part of planning decisions.
Although years too late, the council is in the process of preparing a draft heritage strategy for public consultation. The consultation process has been good, but still no draft has appeared, so it seems we have little or no protection for our heritage assets even though we are a cathedral city with three World Heritage Sites.
Gradually the threat to public health from air pollution seem to be appearing in the council’s consciousness, although we still do not have enough monitors, sited where pollution and traffic jams are greatest, to provide technical information in everyday terms to residents, many of whom are subjected daily to diesel particulates and petrol fumes.
Particulate Matter 2.5 remains in the body for ever, unlike the larger particulates, which can eventually be discharged. Even the government now accepts that 40,000 deaths a year are caused, or contributed to, by traffic pollution. Why, then, isn’t a moratorium ordered to prevent large developments in already overcrowded and polluted areas? Contrast this with steps taken nationally to reduce road deaths, which are less than one-tenth of deaths attributable to pollution. Although there is, at last, some tinkering with travel methods, we need something more drastic than that.
On the subject of air pollution, two residents have issued a judicial review in respect of a 4,000-dwelling development in south Canterbury – the Mountfield Park site – most of which would be on high-quality agricultural land. The main ground is that the air would become even more polluted in the city, as well as within the development itself. There was a two-day hearing in the Court of Appeal and judgement has been reserved. Meanwhile, the development has been put on hold.   We and many others supported this review, but we wonder, with government emphasis on more and more houses, whether the court may be minded to allow the original decision to stand.
[Note: A judicial review is not a re-run of the merits of the original planning decision, but a challenge to the lawfulness of that decision]  

Dartford and Gravesham – Alex Hills
The first phase of the consultation on the Green Belt boundary review has ended and we are waiting on the response from Gravesham Borough Council. CPRE Kent was part of the Gravesham Rural Residents Group (GRRG), which ran a very effective campaign using social media, public meetings (the council had refused to hold any) and hard facts to galvanise support for the Green Belt. Special thanks to Richard Knox-Johnston for some brilliant speeches.
The complete lack of any thought to sustainability or air quality in the government’s housing target came up at all the public meetings. Kent’s health services, transport infrastructure, water supply, social care and much else are all struggling now – there is no way they can cope with the ridiculous housing targets the government is pushing.
The controlling Conservative group in Gravesham has been in a state of flux after the leader and deputy leader were rejected as candidates for May’s council elections. This has resulted in 10 councillors quitting the party, although not all were going to stand in May anyway. I have made clear that CPRE Kent and GRRG are non-political and thus neither organisation would comment on what was happening. Time will tell how this will affect the fight to protect the Green Belt.
There has been encouraging progress on improving NMU (non-motorised user) routes and establishing new ones in the area. There is a growing trend for dual-use NMU routes, which I have grave concerns over as many are not wide enough and there is a lack of understanding by many on how to behave on them:

  • Dog-walkers, please keep your dogs on a short lead
  • Walkers, please keep to one side
  • Cyclists, please be aware pedestrians may not be able to hear you coming and may not be expecting you to be travelling so fast
  • All users need to be aware that people with a range of disabilities use the routes

We need more journeys to be done via walking and cycling as this improves people’s physical and mental health, reduces congestion and cuts pollution. For this to happen, walking and cycling must be made safer.

Dover – Derek Wanstall
There are still discussions relating to Operation Stack, although a recent backlog of lorries parked along the left side of the road into Dover kept traffic moving smoothly. However, when lorries come from the Jubilee roundabout at Whitfield they can cause drivers annoyance when joining the entrance into the docks.
Port alterations are progressing and can now be viewed. Visiting cruise ships have been quite frequent, but it seems visitors do not stay in Dover, preferring destinations such as Leeds Castle, Canterbury Cathedral and London.
On August 29 a well-attended area meeting was held, with Farthingloe and Western Heights dominating the agenda, which I attended along with Christine Drury. Three residents from Western Heights also attended and brought some updated information on the land owned by China Gateway and the bridge over the moat on Military Hill, as well as details on a proposed open day. Attempts will be made to hold a meeting for residents in the Maxton area, close to Farthingloe.
Work at Connaught Barracks seems to be progressing at last, unlike at Eastry hospital, where developers seem to be still dragging their feet.
Developers have started putting in planning applications where property demolition is required to gain access to neighbouring land. However, some good news is that Greenlight Developers had an application for a care home and 48 properties turned down by Dover District Council due to highway issues. We await an appeal.
With so much development in the Deal area and with more approved, traffic jams have become more frequent at peak times, causing long queues towards Dover and on the A256 to Sandwich. Residents now need to leave 10-15 minutes earlier to get to work or appointments on time, with parking spaces in Deal being at a premium. This highlights how infrastructure must be considered alongside new developments.

Maidstone – Henny Shotter
Maidstone Borough Council has withdrawn £10,000 funding for the Kent Downs AONB but has allocated a similar figure for the creation of a new ‘Greensand’ AONB. Although it is desirable to protect the Greensand Ridge, such a move throws up the question as to where the next ‘lot of houses’ will go.
Councillor Patrick Garten (North Downs ward) wrote in his newsletter: “In order to deal with the increasing housing demand, members across the political spectrum expressed a preference for a garden village or town for achieving the housing need. The council should take an active role as master planner for new communities.”
I wonder whether these decisions by MBC are strategically connected and will have an impact on other districts.
The head of planning at MBC said during the inquiry into the last Local Plan that development in front of the AONB should not be a problem as “the whole of Maidstone is in front of the AONB”.
I am concerned the creation of a new AONB will undermine the status of the Kent Downs AONB. The Kent Downs are important not only because of their AONB status but because the downs aquifer stores, as far as I know, 75 per cent of our water supplies.
The immediate area in front of the AONB is not only a traffic corridor (A20/M20/ High Speed Rail Link), it also includes the line of springs that are the source of the Rivers Len and Stour.
Recent developments in Lenham are on the spring line and it seems that groundwater and surface water is joining the Upper Stour, which can lead to flooding elsewhere. The county council’s flood-management management team and the internal drainage board are both reportedly concerned.
Major development at the foot of the downs would increase traffic across the downs and could lead to urbanisation along these routes.
An example of such potential urbanisation is a planned large development in the AONB immediately north of the Kent Showground. It was raised at the Local Plan hearings in November 2016 but taken no further.
The site, which is partly brownfield, is still being heavily promoted. There was a presentation in July, where much support was shown alongside the objections.
It includes several thousand houses plus claimed benefits in road improvements, school space, open space and so on.

Medway – Hilary Newport
Publication of the next draft of the Medway Local Plan is expected in December, followed by a final stage of consultation prior to submission for examination in March. It remains to be seen whether Medway will maintain its commitment to delivering homes at Lodge Hill, a Site of Special Scientific Interest and home to one of the largest populations of nightingales in the UK.

Sevenoaks – Nigel Britten
My last report said “a technical exercise has indicated that the district needs 12,400 new dwellings over the next 20 years”. The government then introduced a new formula, adding almost 1,600 to that impossible figure and increasing the so-called ‘housing need’ to 13,960 over that period.
The draft Sevenoaks Local Plan says this is the number of dwellings for which the district must find room in an area that is 93 per cent Green Belt and two-thirds AONB.
Once all the brownfield sites have been redeveloped, including some in the Green Belt, the only place to build would be in the Green Belt. The Plan proposes 12 major ‘exceptional circumstances’ sites, from fewer than a hundred dwellings per site to 2,500, all requiring changes to the Green Belt boundary. Public opposition has been fierce.
The Local Plan consultation, including 19 policies and more than 100 development sites, has been the focus of the committee’s work. It is not for us to make the choices now facing the council; our job is to protect the countryside, not to choose between the unacceptable, so we have not supported any of the 12 sites for housing. National policy says clearly that Green Belt and AONB protection can override the requirement to meet the full ‘housing need’. We want the council to test that to the limit.

Shepway – Graham Horner
Otterpool Park Garden Town grinds through a design phase and we are promised a planning application by the end of the year. There are still no clear answers to questions of sustainability:

  • Where will the water come from and where will it drain?
  • How can the roads cope with 30,000 new residents?
  • Where will all these people work?

Outline permission for 150 dwellings and a hotel at Princes Parade, Hythe, was granted by Folkestone & Hythe District Council’s planning and licencing committee in August. The plans include an ugly leisure centre on open ground that offers valuable unstructured recreational space and is vital to the setting of the Royal Military Canal.
We are supporting campaigners considering a legal challenge.A ‘listening exercise’ by Highways England to gather views on lorry parks didn’t tell us more than we already knew and probably didn’t tell HE officials more than they knew (or should have known three years ago).
The good news is that the prospect of a mega lorry park does seem to be receding and facilities for overnight parking, not just in Kent, seem to be higher up HE’s agenda.

Swale – Peter Blandon
Swale Borough Council is in the process of developing its next Local Plan. The idea seems to be the development of separate ‘garden villages’, rather than incremental development over a wide area – it is apparently better to really upset a relatively small number of people rather than slightly upset a large number.
The housing requirement is likely to be more than 1,000 dwelling per annum, and this raises issues of infrastructure. The report for the council from Peter Brett Associates contains ‘An Important Reminder for Developers and Landowners’. In a larger font than the rest of the report, it is stated:
“We can expect that each home built in Swale on strategic sites will be likely to need between £30,000-£50,000-worth of supporting infrastructure spend. In the absence of a master developer or similar structure, this is likely to be collected by either CIL [Community Infrastructure Levy] or S106 [agreement between local authority and developer with an obligation concerning use of the land or developer contribution towards infrastructure and facilities].
“Without this infrastructure spend, no planning permissions can be granted, meaning that there is no development opportunity.
“It is important to bear in mind that CIL and S106 are ultimately paid out of land values. This means that land with residential planning permission may be worth much less than landowners currently anticipate. It is critically important that this point is well understood by landowners, so that they do not have unrealistic expectations about the value of their land.
“Equally, developers should be careful to ensure that these costs are factored into their bids for land. The council will be unsympathetic to claims that development on greenfield sites is unviable.”
While we can support these sentiments, exactly how unsympathetic the council will be when the inevitable requests from developers come in asking to be relieved of requirements to provide a certain level of CIL funding, or to reduce the number of affordable/small houses in a development, remains to be seen.
Two applications for sites in the Local Plan are under consideration. A site at Teynham for 130 dwellings brought this response from the parish council:
“Teynham is identified in the current Local Plan as a ‘sustainable location for development for its good range of local services, facilities and rail link’. Having had our rail services halved, our medical surgery facilities halved, the loss of Sure Start children’s facilities, no tangible improvement in bus public transport and no evidence that schooling facilities are to be improved to meet the forthcoming influx of new residents, we question what is now left that is ‘sustainable’.”
At the same time, the council’s head of environmental protection is recommending refusal on air-quality grounds.
The plan for Cleve Hill solar farm is expected to be submitted to the Planning Inspectorate by the end of October. Swale Borough Council does not seem to have involved itself with the application.
A development in Newington High Street, an AQMA [Air Quality Management Area], has been completed. The original permission required non-opening front windows to reduce pollution and noise inside. An application in February to allow opening front windows was refused. The buildings have been completed and have opening front windows. The houses are now on sale.

Thanet – David Morrish
“August is that last flicker of fun and heat before everything fades and dies…” the  line from author Rasmenia Massoud was particularly apposite for my report after a glorious sun-kissed summer on Thanet’s gorgeous coastline.
But the clouds are gathering and, urged on by the government’s Chief Planner, Thanet District Council has lumbered into action by deciding to publish and be damned its latest daft [sic] Local Plan.
Thankfully, the council listened to common sense (and CPRE Thanet) and opted for a six-week final consultation stretching into October, thankfully, we hope, encapsulating September’s publication of population forecasts just to ensure there is a substantial basis for the likely initial challenge to the predicted household forecasts.
The consultation will also, most importantly and very belatedly, be the first official opportunity for the public to comment on the county council’s long-awaited transport study. Why has it not been published until now?
This complicated process appears to have been already predetermined, hence the planning application (a lovely case study of the county council acting as advocate, judge and jury in considering its own application) for the latest Thanet White Elephant: Thanet Parkway station.
Thanet CPRE has duly opposed this scheme despite its supporting documents and the expectation is a planning decision by November.
Our committee is still very keen, active and meeting monthly – it is hoped that in the run-up to the Local Plan Examination in Public we may attract more members as many do not appear enamoured with ‘local planning’ in Thanet.

Tonbridge and Malling – Mike Taylor
Tonbridge and Malling Borough Council’s Planning and Transportation Advisory Board is the body charged with drafting the Local Plan, and I am a member. On July 24 the PTAB met with the sole task of recommending the draft Local Plan to cabinet and full council in September. Thirteen members of the board were present, as were 18 non-member councillors and some 50 members of the public, one of whom videoed proceedings.
There was two and half hours of intense debate, with strong opposition to much of the Plan, culminating at 10pm with the chairman asking for agreement to recommend the Plan but, instead of the normal chorus of “Agreed”, there was a deathly hush. He then asked for a show of hands, which was all a bit confused, but resulted in the chairman declaring 5-5 with three abstentions. His casting vote carried the recommendation.
Many members voiced concerns about the vote but were assured it was correct.
However, analysis of the video showed one board member leaving before the vote. A month later, the council agreed there was a “miscount” and declared the recommendation refused. It then decided it didn’t matter anyway – the PTAB is only an “advisory board” – and so our vote would be noted but would not prevent the non-recommendation going to the cabinet and full council.
On September 12, the full council agreed the draft Local Plan with a 39-6 vote.
Democracy is alive and well at Tonbridge and Malling Borough Council…

Tunbridge Wells – Liz Akenhead
We have objected (mostly successfully) to several planning applications that have come forward on unallocated sites in the High Weald AONB. These sites are vulnerable to speculative applications for development because the borough council cannot demonstrate a five-year supply of housing land. We continue to await publication of the draft Local Plan, which now seems to be scheduled for early next year.
Until a new Local Plan is adopted, and perhaps even after that if the government keeps moving the goalposts, our countryside will remain vulnerable to speculative applications.
Rumours abound as to how much housing will be proposed for each settlement, though we understand parish councillors and neighbourhood plan steering groups have been given some indications confidentially. The council is reviewing the Green Belt and we fear a considerable amount of building in the Green Belt and AONB will be proposed.
A recent paper on park-and-ride, produced as part of the evidence base for the new Local Plan, seems to show that a new park-and-ride service will neither give value for money nor resolve the traffic problems in Tunbridge Wells, yet alarmingly it seems the council may still want to press ahead with the proposals, some of which will needlessly cover green fields with tarmac.

Environment – Graham Warren
The recurring theme for most of the summer (while keeping our fingers crossed for an end to the drought) was Brexit and what it could mean for the future management and protection of Kent’s increasingly vulnerable environment.
We learn that the roles played by the European Commission and the European Court of Justice – bodies that have powers to enforce compliance with environmental legislation – will, post-Brexit, be taken up in the UK by a new body, the Environmental Enforcement and Audit Office (EEAO), heralded by the government as a “world-leading body to protect the environment”.
Unfortunately, its remit will be confined to monitoring and advice only ─ a watchdog that will simply watch. A poor legacy, this, for a nation that was the first to put climate change on the UN agenda and the first G7 member to phase out coal-based power, last year generating more than half of our energy from renewable sources.
As if that wasn’t enough bad news, we now have government proposals to review the legislation controlling shale gas exploration and development, effectively moving planning control from local authorities to central government and denying local communities any means of making representation (a move CPRE Kent has challenged with a 175,000-signature petition).
This action reflects a determination by the government to force through the permitting of invasive development of fossil fuels, ignoring the implications for our commitment to the Paris Agreement in the increasingly urgent programme for climate-change control.
But now some good news and congratulations to Surrey CPRE for the victory at the Battle of Leith Hill ─ another shale-gas exploration site where Kent provided technical support in opposing permission. The oil company has been seen off and has withdrawn its application.

Historic Buildings – John Wotton
Kent Historic Buildings Committee was pleased to partner Kent School of Architecture again this year for the Gravett Award for Architectural Drawing, named in honour of Kenneth Gravett, an author on historic buildings in Kent and a former chairman of the committee. The judging panel was again chaired by Ptolemy Dean and the award was made to Jake Obichere.
The committee has participated in a campaign to save from demolition Hextable Heritage Centre, the former botany laboratory of Swanley Horticultural College, the first institution in England to admit women horticultural students. Swanley was taken over by Wye College after the Second World War and the botany laboratory is the only surviving college building.
The committee visited Queen Court at Ospringe, an outstanding Wealden hall house with fine barns and outbuildings, largely unmodernised and with much deferred maintenance required to the structure and fabric. The house is empty after the ending of an agricultural tenancy and it is possible that development will be proposed on the site. The committee will monitor the situation.

Monday, November 19, 2018

Word from our chairmen

Westbere (pic Richard Brooks)

In the Spring/Summer edition of Kent Voice, we carried reports from our district and committee chairmen from around the county.
They were comprehensive and entailed a lot of work on their part, but space restrictions meant we couldn’t bring you them in their entirety, so here they are…

Ashford – Christine Drury
The new draft Local Plan will be examined by two inspectors between April and June and, with whatever amendments that result from their Examination in Public, is likely to become the adopted Local Plan before the end of 2018.
It will replace the old Local Plan approved in 2008, when Ashford was still designed as a Growth Area and had very high housing targets but with a compact strategy focusing development in and around the town of Ashford.
Since the NPPF came in in March 2012, the district has been under increasing pressure to accept less constrained development. Recently, when Ashford could not demonstrate a five-year housing land supply, many villages in the district were besieged with housing proposals not in the Plan and at an entirely unsympathetic urban scale.
The planning inquiries that follow are a huge diversion for the borough council and for CPRE, but at Brabourne and Charing CPRE has been there as a participant to fight alongside the council against this wrong development.
The engagement the committee has with the council and the clarity of CPRE’s campaigning owes a great deal to the work of Hilary Moorby so many years. We shall miss her very greatly.

Canterbury – Barrie Gore
Canterbury City Council has invited us to join its new District Heritage Forum, which has been tasked with producing a heritage strategy for public consultation.
Other amenity organisations (including our Historic Buildings Committee) have also been invited. The forum is chaired by Cllr Robert Thomas, who has been appointed Canterbury’s heritage champion.
We certainly need one, and the forum will hopefully alter planners’ perception of the pecking order for heritage.
In our view, that should be a prime, not secondary, consideration to economics. It is amazing to me that, since Canterbury’s senior conservation officer left the council, the issue of conservation has been so poorly served.
For example, the list of Locally Listed buildings has not been updated since 2012 and the council refuses our requests to list buildings on an ad hoc basis, as was the case. This means that local, undesignated, heritage assets have been at risk for six years.
Also, an independent volunteer Clean Air Action Group has been formed and, subject to formal approval by the council’s policy and resources committee, the director of transport has agreed to invite Professor Stephen Peckham from that group on to the council’s transport forum. Stephen has expertise and practical experience that is invaluable in connection with transport and air pollution.
We have commented on the proposed change of use of a lovely pub to residential, accompanied by three houses, a micro pub and some tourist “pods” all in the open countryside on unallocated land near the hamlet of Chartham Hatch (designated as such in the Local Plan).
There is an application for umpteen more houses, highways proposals and sundry development at Cockering Road, Canterbury. We are concerned that the cumulative effect of the Thanington changes is not being considered as the effect on already polluted Wincheap will be great. It seems Kent Highways still has concerns, but whether that will suffice to defer or improve the application remains to be seen.
We have been asking the council for many years to take account of the cumulative effects of the developments in and around Canterbury, without any response. However, recent news suggests such effects must form part of the planning process.
I must mention the quality of our committee, which puts in a great deal of hard work, with skill and expertise, and with valuable links with other amenity organisations, including the Canterbury Heritage Design Forum (independent to the council).
I am delighted Branch has contributed towards their funding as they operate on a shoestring.

Dartford and Gravesham – Alex Hills
Green Belt boundary review papers were due to go to the Gravesham Borough Council cabinet on February 26, with consultation due to start in April. Gravesham Rural Residents Group (of which CPRE is a member) have been gearing up for this campaign; the plan is to use social media extensively. We are confident we can reach at least 26,000 people directly.
GBC is looking to build 2,000 homes in the Green Belt, so it is going to be a big fight. All the area’s services are under massive strain, so sustainability should come up a lot in the consultation. We believe GBC should do much more to get the housing-number target reduced and increase housing density in the urban area.
Two test-case applications were due to go to the council’s regulatory board on March 7; one was for a two-bedroom house and the other for two two-bedroom bungalows.
Both are in an Istead Rise estate extension built in early 1970s; in soft landscape areas that are a community amenity asset; an integral design feature of the estate; and classed as part of the highway, which is something I had not come across before.
The cases are important as they should define what GBC means by “infill” development, how much weight GBC gives to the importance of soft landscape features and how much GBC values community amenity assets.
There are 18 such sites in Istead Rise alone, although most are not big enough to be built on. There were more than 170 objections after a campaign including social media, targeted leafleting and two meetings. A big thank-you to local residents Frank Booker, Terry Annable and Rachael Westlake, who worked so hard on the campaign.
Consultation on the Bean interchange started on February 26.
Consultation is under way on a new cycle route between the Cyclopark and Gravesend train station. Overall I support the scheme, but there are a few areas where I will be suggesting improvements: it is unnecessarily long for a commuter route and it crosses a busy road twice in a very short distance.
As CPRE Kent representative on the Gravesend and Dartford Cycling Forum, and its chairman, I have meetings coming up with the Bluewater community body and consultants working for EDC on developing new cycling routes. EDC is working on routes within the garden city and leisure routes out of it.
The forum has been pressing both EDC and Bluewater to look at where people want to travel to and make sure cycle routes are joined up.

Dover – Derek Wanstall
With the Supreme Court ruling on Farthingloe and Western Heights going in CPRE Kent’s favour just before Christmas, the year ended on a high. Many thanks to our legal team and those at CPRE Kent who worked so hard… well done!
There is the ongoing issue of the Lydden Hill race circuit and its proposed expansion, which can only bring more noise and traffic problems to the village, plus the site is in an AONB.
Residents’ tranquility and quality of life can only deteriorate if the expansion is approved.
What an excellent idea to have a war memorial on the Western Heights! It should encourage tourism. Across Europe there are several such memorials, one in particular looked after by village children to a very high standard.
Developers at Connaught Barracks and the Eastry hospital site are still dragging their heels with regard to any progress.
The massive development at Whitfield is taking shape and some infrastructure has been agreed.
The St James shopping area in Dover is nearing opening. This will improve the area; however, much work is needed in raising the environmental standard at Tower Hamlets and Buckland.
With developers putting in planning applications around the villages, parish councils are frequently endeavouring to retain their open spaces and village status.
Our MP has constantly made irresponsible comments in the local media regarding Farthingloe, claiming young people are being stopped from getting on the housing ladder.
CPRE Kent supports housing – but in the right places. At Farthingloe, very few, if any, of our younger generation could have afforded the proposed homes.
Perhaps our MP should place in the local paper the letter he wrote to the Secretary of State requesting that the Farthingloe development not be called in. If it had been, the people of Dover might have avoided the hefty costs of the subsequent court cases.
CPRE Dover committee meetings take place every two or three months from 10.30am to midday. If any parish councils would like to send representatives who are CPRE members, they would be welcome. I can be contacted on 01304 363610.

Maidstone – Gary Thomas
We are extremely disappointed at the dismissal of our attempt to get a judicial review of the inclusion in the Local Plan of industrial and commercial development at junction 8 of the M20, otherwise known as Woodcut Farm.
The review was not allowed to go forward on the basis that there were no significant procedural errors made by the examiner in approving the Local Plan. The planning issues were not seen as relevant in this context. This was despite the information given to the Examiner often being less than satisfactory. The key point was that he felt able to accept the borough’s statements and included this site in the Local Plan.
We regret that a planning application for a 13-house estate in the Conservation Area of Linton, which was not identified for development in the Local Plan, was approved. The site comprises a field that is half in the Conservation Area and the other half in the process of being included.
The case officer made a strong case against the development, but the planning committee took a different view based on grounds we find difficult to support. These were:
1. It would not harm the Conservation Area, although it was clearly contrary to the 1990 (Listed Buildings and Conservation Areas) Act
2. It would assist in getting a pedestrian crossing in the northern part of the village – already ruled out by the county council
3. It would be a windfall site. In our opinion this argument doesn’t make any sense: all land not identified in the Local Plan for develop
A very large house in the AONB on the site of a modest Edwardian dwelling (to be demolished) was approved in 2015 in Lenham. The design is for a massive house with very large windows that make use of solar gain. During daylight this area of glass sometimes reflects light like a mirror and at night allows much light to illuminate the otherwise dark escarpment. This application was approved and nothing can be done about it, but the applicant has now submitted an outside lighting scheme that includes 87 lamp positions, either on the house or its immediate surrounds. We have submitted objections.
A huge warehouse and packing shed in the countryside, not in the Local Plan but allowed anyway, is under construction in Linton and as damaging as we feared. The promised studies of traffic movements have not been carried out and the road improvements, including Linton crossroads, appear not to have been progressed.
A landowner has applied to build eight large barns in the AONB in Lenham, to which we have objected. A response has been submitted on our behalf.
Maidstone Borough Council is looking to introduce charges for the park-and-ride (currently free), while greatly increasing charges for parking in town. We object to these changes as they will deter people from outside the urban area visiting town and affect the elderly disproportionally.
Maidstone CPRE is looking to involve more people in monitoring planning applications and in preparing for the review of the Local Plan, on which the borough council is already working.

Medway – Hilary Newport
Medway Council’s cabinet met on March 6 to agree the publication of the draft Medway Local Plan Development Strategy, which is open for consultation until 11 May this year. This document sets out the options for the most sustainable strategy for managing Medway’s growth up to 2035.
These options include consideration of the government’s proposed new housing trajectory for Medway, which would see the already challenging housing targets escalate considerably. It also includes consideration of a new ‘rural town’ at Hoo or a return to the plans for development at Lodge Hill – despite its designation as a Site of Special Scientific Interest and an internationally important breeding site for nightingales. Difficult decisions will have to be made.
Plans for Lodge Hill continue to evolve. Earlier development proposals from Land Securities and, more recently, the Ministry of Defence, were withdrawn, with the site has been passed to Homes England, a government agency charged with delivering the country’s housing needs.

Sevenoaks – Nigel Britten
These are tense days for all who care about the Sevenoaks countryside.
A technical exercise has indicated the district needs 12,400 new dwellings over the next 20 years – almost four times the target of the previous period – and the question is where they can be built without covering our beautiful landscape with bricks and concrete. Last summer the district council consulted on the ‘issues and options’ for the next Local Plan, showing possible approaches to meeting housing demand. Brownfield land in the urban areas is always the first choice. Then one ‘option’ is to use previously developed Green Belt land. Another, and very contentious, would be using Green Belt land for large-scale housing development in “exceptional circumstances”. Examples would be 600 houses under the Which Way Westerham plan, 600 on the Tarmac site north of Sevenoaks, an 800-house ‘garden village’ on the former Broke Hill golf course at Halstead and several smaller sites around Edenbridge.
The draft Plan will be published in June and it will be keeping the Sevenoaks committee busy.

Shepway – Val Loseby
Shepway District Council has published A Charter for Otterpool Park Garden Town. It builds on the Development Principles for Otterpool Park published in the Expression of Interest submitted by SDC to the government in June 2016. The charter was published in draft in September and now incorporates revisions after public consultation and consideration by the council’s cabinet.
The Framework Masterplan for Otterpool Park is being worked on by council officers with consultants. We understand that plans have stalled due to some land being withheld by the landowner. We await the next stage of public consultation.
A councillor, residents and other interested parties, including CPRE Kent, have met Affinity Water officials to discuss their plans for providing water in an already water-stressed area. Aside from supply to the 12,500 dwellings planned for Otterpool Park, there are other major developments in the area. The meeting was informative and there are plans for another one this year.
Princes Parade, Hythe, is a planned development of 150 dwellings, a leisure centre and swimming pool next to the Royal Military Canal, which is a Scheduled Monument. Historic England has come out strongly against this development, citing the harm it will cause the RMC, which dates back to Napoleonic times.
The Shepway district committee has also objected to the development, which would mean the loss of an open space much used by the local community and wildlife. Vicky Ellis of CPRE Kent submitted an excellent critique of the environmental report submitted to SDC by its consultants, pointing out that the methodology was flawed and the data unreliable.
SDC has published the submission draft of the Places and Policies Local Plan, which will be submitted to a planning inspector at an Examination in Public. The district committee submitted comments on several sites, including Princes Parade, which is still in the Local Plan despite strong local opposition. The planning application for this site was not expected to be determined by the local authority until after the consultation.
The Kent Minerals & Waste LP 2013-2030 consultation concluded at the end of March. The district committee commented, particularly the already extensive Lydd quarry at Dengemarsh and Allen Banks, which is proposed to extend even further into the surrounding SSSI. We are objecting due to the loss of agricultural land as well as harm to the SSSI and have suggested there are alternatives for extracting gravel without leaving deep-water ponds that turn saline over time.

Swale – Peter Blandon
There was relief when Swale Borough Council adopted its Local Plan.  The feeling was that it would be possible to combat more easily speculative planning applications.
However, it seems such relief was misplaced. An EIA Screening Opinion has appeared for a development of 11,250 dwellings with new junctions on to the M2 and A2 to the south and east of Sittingbourne. The junctions are near Kent Science Park and the development would effectively engulf Bapchild and Rodmersham.
This ‘ticks all the boxes’ for SBC as it is keen on a southern relief road and development of the science park. Cynics might argue the houses are needed to pay for the roads that are needed to mitigate the effects of the housing… and so on.
The Inspector had only qualified support for the adopted Local Plan and required an early review. So Swale CPRE produced a study for consideration by SBC as part of its preparations for the next planning review.
It states: “This study is needed because the Inspector had concerns that the current adopted Plan might not be able to support sufficient homes over the Plan period. Emerging numbers suggest that Swale needs to provide more housing permissions – equivalent to around 35% more every year, on top of the number already in the plan.
“In our view the prudent approach would see Swale preparing to plan for around another 7,500 homes over the new Plan period to 2037/38 in addition to the number already identified through the current Plan.”
The report proposes a number of scenarios:

  • Incremental growth on the periphery of existing settlemen
  • Two new villages or one new town – a total of 10,000 houses –around Kent Science Park.
  • An extension of Faversham with new villages or a town to the south, containing 5,000 to 10,000 dwellings.
  • Building around Upchurch and/or Newington

The emphasis seems to be on ‘garden villages/towns’ as it states early in the report that “pressing sequential development into and up against existing communities drives high densities and low quality”.
At the meeting of the Local Development Panel in Swale it was decided “the scope of options identified in the report are appropriate for initial stakeholder engagement workshops be agreed”.

Thanet – David Morrish
Thanet has a CPRE district committee again, with the first meeting held on November 27.
As a relative newcomer to Thanet, I have been bemused by the complex planning situation here, where the district council was one of 15 local authorities without an up-to-date Local Plan. In January many councillors revolted against officers’ proposals for 17,000 houses unaccompanied by new employment; the proposals were thrown out by the full council.
Sajid Javid, Secretary of State for Communities and Local Government, subsequently stepped in to speed up production of the Plan, with chief planner Steve Quartermain and team being sent to the isle to decide whether it will be taken of Thanet council control. Mr Quartermain will report back to Mr Javid, who will make a final decision on formal intervention. The council has seen a change of leader and change in administration.
Plans for a Development Consent Order for a ‘freight-only’ airport on the Manston Airport site went to public consultation. After thumbing through the 3,000 pages of documentation, the CPRE Thanet committee concluded the proposals were generally aligned with Thanet’s 2006 Local Plan. We await central government’s response to the GDO proposal and the supply of further information as part of the next stage of consultation.
One peculiarity of the Local Plan policy was that TDC officers appeared to have prepared their own £80 million transport plan for a circular updated country-lane system not supported by Kent Highways, which is itself awaiting a final result from the Local Plan process before committing scarce resources.
Anxious eyes look fearfully to the reopening of ‘Operation Super Stack’ if and when Transport Minister Chris Grayling has to deal with the local consequences of us leaving Europe without a plan!
Our working committee started work in earnest in January and February, considering the potential work ahead on an ill-prepared  Draft Local Plan.
We have resolved to press the incoming TDC administration to adopt the principle of the Community Infrastructure Level as a way to secure speedier delivery and sounder infrastructure provision and payment.
I would like to thank my 11 new colleagues for stepping forward to help secure a better approach to planning in Thanet. Also, thanks to my new colleagues on the CPRE Kent chairmen’s group and to the trustees for welcoming me aboard.

Tonbridge and Malling – Mike Taylor
Tonbridge and Malling Borough Council has deferred publication of its Draft Local Plan for the third time, still assembling the evidence base. Our next district meeting will discuss the issues detailed below. Because the district has large tracts of Green Belt that have been ‘temporarily’ released for mineral extraction, we have constant battles to stop the local planning authority treating this land as ‘brownfield’. We will engage in the Local Plan process, not just on specific site issues but also to ensure it contains unequivocal rules and not the vague suggestions contained in the Local Development Framework. Some of this engagement shift towards the end of the final consultation, if not completely deferred until it can be put directly to the inspector.
While TMBC keeps a register of employment sites, it pays as much notice to this as it does to air quality and Green Belt protection. It is too simple for developers to advertise in such a way as to make sites unviable for employment use and getting them released for housing.
Contaminated land: on sites with known contamination there must be a clear and unequivocal distinction between remediation and construction, with a conditioned requirement for validation that the site is clean and safe before permission for construction is given. Many of the problems we have experienced are caused by builders treading on the heels of the remediation team, or, worse, a site where the two processes are mixed. The simple process of earth-moving can mix high levels of contamination with clean soil, creating the statistical illusion that the site is now clean.
On sites of known contamination, the developer must provide a comprehensive contamination survey prior to application, and any permission conditioned to ensure the developer cannot later claim lack of viability due to ‘new-found’ contamination, particularly if that loss of viability results in any loss of affordable housing or other benefit.
While validation of the remediation is principally the responsibility of the developer, that does not let the planning authority off the hook entirely. There must be a clear oversight of the process, incorporating occasional independent assessment of developers’ sampling, random sampling of the site by officers and rigorous checking of the developer’s processes to ensure they are complying with the remediation plan, and random site visits to ensure the paper complies with what is allegedly happening on the ground.
We must have assurance that the sites approved are safe for residents.
Landfill sites: TMBC has allowed two housing developments on general waste landfill sites (176 and 43 houses), but in recent weeks Joco Pit, where 48 houses were built in the 1970s, has produced an alarming increase in landfill gas, including methane. TMBC largely dismisses concerns that the same will happen at the new sites, claiming houses have gas-proof membranes and that methane coming up in gardens will simply disperse in the air.
This stance neglects two important facts:
1. Methane is a greenhouse gas of an order of magnitude worse than CO2
2. Methane is generated when oxygen ingress allows buried organic matter to rot. That putrescence will leave a void, leading to subsidence.
The fact that these sites are deep-piled and use vertical band drains to manage drainage and release methane also provides new pathways for oxygen to reach buried organic matter.

Tunbridge Wells – Liz Akenhead
Tunbridge Wells Borough Council is continuing to work on producing a new Local Plan. We had expected to see the first draft of this published by now, but the latest information we have is that the Preferred Local Plan will be consulted on this summer, with pre-submission consultation from November 2018 to January 2019 and Examination in Public from April to June 2019, leading to adoption in October 2019.
The two Calls for Sites conducted by the council have resulted in a range of submissions, including some for ‘garden villages’ of about 6,000 houses. Many of these are in the Green Belt and/or the Area of Outstanding Natural Beauty. The council tells us it is engaged in analysing sites and options for the development strategy; we feel this is a better way forward than choosing a strategy without first analysing available sites.
The borough’s Brownfield Register shows room on Previously Developed Land for some 900 homes (a little more than one year’s worth of the housing requirement for the new Local Plan period), which appears to leave a very large housing requirement to be filled via greenfield sites.
If as little as possible of our precious countryside is to be lost, it is essential that where new housing goes on greenfield sites, its density should be increased from the relatively low densities currently being achieved.
High-density housing does not have to be poor or unattractive: Cranbrook’s historic centre, for example, is widely recognised as a beautiful and desirable place to live yet has a density of 70 or more dwellings per hectare (DPH).
The recently approved site at Mascalls Farm, Paddock Wood, will have a density of less than 12 DPH and the major site at Hawkenbury Farm on the outskirts of Tunbridge Wells less than 21 DPH.
The borough’s first Neighbourhood Development Plan (NDP), for Hawkhurst, passed its referendum on February 8 and will soon be adopted by the borough council. Other parishes are at early stages of producing NDPs.
We need more committee members. If you want to help protect our environment and can spare a few hours a month to help monitor planning matters in your parish, please contact me, Elizabeth Akenhead, on 01892 723920 or at liz@akenhead.plus.com

Environment – Graham Warren
A winter of below-average rainfall and higher-than-average temperatures has left Kent with water table levels in the North Downs (our major public supply resource) still relatively low, and a warm dry spring could see groundwater levels falling back into the ‘red’.
The water companies have produced their public consultation documents for the next 5- to 25-year Water Resource Management Plans, this time with an emphasis on more flexible strategies to meet the increasingly fragile balance of supply and demand, and the challenges of climate change, population growth and pressures on the environment. And who knows what, post-Brexit?
2018 looks like being the year that produces the first UK land-based shale gas/oil operation, most probably in northern England but Surrey and Sussex are also looking to us to support their opposition to the granting of licences for fracking operations. Expert opinion is that the UK already has twice the hydrocarbon reserves it will ever need, assuming we stay within the 1° global temperature increment adopted under the Paris Agreement.
It is a good time, we think, to make clear our support for local community initiatives for small-scale solar and windpower generation schemes, so long, of course, that due regard is also given to the equally important challenge to conserve reserves of productive agricultural land.

Historic Buildings – John Wotton
The Kent Historic Buildings Committee has supported the Tunbridge Wells committee in relation to the continuing deterioration in the condition of the partially demolished, listed Blue Boys Inn near Matfield.
We have advised residents in Nonington about a possible residential development that would involve the demolition of a 19th-century cottage of historic interest.
We have been approached by residents in the Ightham Court area who have made an application for judicial review of a decision by Historic England in 2015 to de-list part of a historic park and garden.
We have endorsed a donation of £250 by the branch to Canterbury Heritage Forum.
We have objected to a major proposed development in the setting of the Royal Military Canal at Hythe, as has Historic England.
We have recently been consulted about plans for redeveloping the Hextable Heritage Centre and the proposed demolition of a toll-gate cottage at Brenchley.
We will again sponsor the Gravett Award for Architectural Drawing in 2018 in partnership with the Kent School of Architecture. We next meet on Friday, April 20, and continue to seek additional members to cover Maidstone and Ashford districts.

Wednesday, April 25