Sevenoaks knocked back again in Local Plan dispute

Sevenoaks now wants to meet Housing Secretary Robert Jenrick

The latest attempt by Sevenoaks District Council to defend its Local Plan has fallen in the High Court.
The local authority in November failed in its judicial review of a planning inspector’s refusal to approve its Local Plan.
The local authority had brought the review of inspector Karen Baker’s conclusion that it had failed to comply with the required duty to cooperate when preparing its Plan.
But in the Planning Court, Mr Justice Dove rejected the council’s challenge, saying Sevenoaks had engaged fully with neighbouring local authorities only when it became clear at the Reg 18 stage that housing need could not be met, rather than as part of the whole process.
Sevenoaks went on to contest that verdict, but on Friday, April 9, a High Court judge dismissed the challenge.
Peter Fleming, council leader, said Sevenoaks would now seek a meeting with Robert Jenrick, Secretary of State for Housing, Communities and Local Government, in a bid to agree a strategy on developing a new Local Plan.
Until that happens, it is feared the district could be vulnerable to speculative development proposals. Nigel Britten, CPRE Kent’s Sevenoaks chairman, said: “We are in a slightly difficult position as we do not have a set five-year land housing supply.”

Sunday, April 18, 2021

Credit to Dartford council as it prepares a genuine brownfield-first strategy

Let’s hope Dartford Borough Council’s good work is not undone on the Swanscombe peninsula, which is threatened by the proposed London Resort theme park (pic Paul Buckley)

Consultation on Dartford Borough Council’s pre-submission version of its Local Plan closed today (Friday, April 9, 2021) and CPRE Kent feels this has been largely a positive example of Plan-making within the constraints of the planning system. 
By focusing development on well-connected brownfield sites within the town of Dartford and at Ebbsfleet Garden City, the Plan is essentially a genuine example of a brownfield-first strategy. Coupled with strong Green Belt protection policies and policies responding to the climate-change emergency, there is a lot to commend.
Of course, there remains areas where things could be better. We have taken exception to the continued support of roadbuilding within a borough that has some the worst air quality in the South East and the council’s continued support for the Lower Thames Crossing.
We have called on the authority to be bolder with measures to truly respond to our biodiversity crisis, along with further strengthening of active-travel measures.
We were disappointed not to see a policy protecting intrinsically dark landscapes. We have reminded it about the implications of Natural England’s designation of Swanscombe Marshes and land to the south as a Site of Special Scientific Interest.
Overall, though, there was certainly as much good as there was bad. We now must just hope that this good work is not undone should the proposed London Resort theme park be consented. 

  • You can read our comments here

Friday, April 9, 2021

Swale consultation extended but councillors won’t be getting a report back before Local Plan is submitted

Swale Borough Council has agreed to extend its current Local Plan consultation until Friday, April 30.
The decision was made at a meeting of full council on Wednesday, February 24, and all residents in the borough will receive letters telling them about the state of the Plan.
However, councillors did not agree to have the outcome of the consultation reported back to them before submitting the Plan for examination. This was contrary to what CPRE Kent had suggested.
An amendment supporting such a report was rejected by 24 votes to 18 – a disappointing outcome, we believe.

  • To read more about the Swale Local Plan, see here

Monday, March 8, 2021

Swale says it’s a listening council. Now it has the chance to prove it

CPRE Kent and others have raised deep concerns regarding the lack of consultation undertaken by Swale Borough Council on its Local Plan. 
We therefore welcome the recommendation to councillors to extend the current consultation until Friday, April 30. This is to be considered by all council members tomorrow evening (Wednesday, February 24).
However, as it stands, there is no formal requirement for the outcome of the consultation to be reported to councillors prior to the Plan being submitted for independent examination.
This is why we have today written to Swale councillors urging they consider the consultation responses before making a final decision that the Plan is ready for formal submission.
In the report to members accompanying tomorrow evening’s recommendation, Swale describes itself as a listening council.
This simple positive step is the least that they can do to demonstrate this.

  • For more on the Swale Local Plan, see here

Tuesday, February 23, 2021

Swale Local Plan: have your say now!

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

Swale Local Plan: consultation begins within days

Further to yesterday’s story on discussions over the Swale Local Plan, borough councillors voted 30-17 last night (Wednesday, February 3) that pre-submission draft consultation should begin on Monday (February 8) for a statutory six-week period.
An amendment to the Plan was agreed to permit inclusion of the Quinn Estates scheme for 675 new houses at Wises Lane, Borden, should it be granted at appeal.

Thursday, February 4, 2021

Swale – why the rush?

Tonight (Wednesday, February 3), Swale councillors will be voting on where 22,814 houses are going to built in the borough. They also need to find 56 hectares of employment space, which includes 15 hectares of office space, and the infrastructure to support this. As part of the package, a new relief road for the section of the A2 through Teynham is in the frame.
With such a monumental decision to be made, you would rightly expect this to be the cumulation of an iterative process informed by robust community engagement.
Well, the only meaningful community engagement occurred back in the spring of 2018 and simply involved a high-level discussion on the issues and options facing Swale.
In any event, it appears these comments were ignored, with the chairman of the Local Plan Panel informing the panel on January 19, 2021:
“I think it is fair to say that when the new administration took over in 2019 the Local Plan team had to work to a radically different strategy. Meaning that much of the work they had done for the previous year didn’t really contribute much to this, to the direction that the new administration went.”
More significantly, a promised further consultation to include the council’s preferred sites to inform the final version of the Plan to be submitted has conveniently been sidestepped. Instead, Swale residents are to be presented with this final version as a fait accompli. It is being left to the Planning Inspectorate to make any changes.
As it is, Swale councillors have been given less than a week to familiarise themselves with this Plan, along with 12 separate reports totalling some 1,193 pages. No mean feat, though arguably impossible when you realise much of the evidence to back up the “radically different strategy” (as the Local Plan Panel’s chairman called it) is incomplete or still a work in progress.
This incomplete work includes concept diagrams yet to be provided and, crucially, vital transport modelling that is not anticipated until “Spring 2021”.
This urgency was blamed on a proposed increase in the numbers of houses the government might require Swale to build. This increase is now not happening. There are, however, likely to be changes to the National Planning Policy Framework, currently out to consultation, that this Plan is likely to need to take account of.
Swale councillors are reminded that the Local Plan must be prepared in accordance with the council’s latest Local Development Scheme and that consultation must be carried out in accordance with the council’s Statement of Community Involvement.
It is CPRE Kent’s view that the 2018 versions of these documents created a legitimate expectation that there would be a Regulation 18 Draft Preferred Option Public consultation stage on which to comment – not least as this is what the council said would happen.
To be voting to approve a Plan without this additional consultation is at best foolhardy.
To be voting on a Plan without this additional consultation and that is not yet finished is positively irrational.

Wednesday, February 3, 2021

A message to the people of Gravesham…

Attractive countryside could be lost forever if Local Plan proposals come to fruition

Stop the Gravesham Green Belt Grab

If you care about the quality of life of your family, it is important that you make your voice heard in the Local Plan consultation currently taking place.
If you don’t know what to say or how to respond, then you could use this standard wording, so long as you include your name and address, and send it to: 

Planning Consultation, Gravesham Borough Council, Civic Centre, Windmill Street, Gravesend DA12 1AG

Dear Sir/Madam,

Re: Gravesham Local Plan Consultation

I strongly object to the building of 3,790 houses on 21 sites in Meopham, Higham, Istead Rise and Sole Street for the following reasons:

  • Even longer waiting times for doctor and dental appointments
    Longer hospital waiting lists
  • The roads linking the rural areas could not take the increased traffic
  • There are no safe walking and cycling routes between rural communities, and residents are reliant on a limited bus service or their own vehicles
  • The A227 and A226 are already congested – car journeys will take even longer
  • There will be massive impact on rural lanes caused by the Lower Thames Crossing and the Paramount Theme Park at Swanscombe, increasing traffic on the already congested A2
  • The impact on traffic by these huge projects must be considered
  • An extensive build will put more pressure on our schools, which could result in children being allocated spaces in schools they neither want to attend nor are local
  • Trains will be overcrowded
  • Impact on broadband services – often weak in the rural areas
  • Rural development will cause air, noise and light pollution
  • There is already a severe water shortage in the South East
  • Agricultural land should be protected for food production
  • Huge impact on wildlife, which now, more than ever, needs protecting
  • Our villages will become merged and their unique identities lost

Yours faithfully,

Signed:     
Name:     
Address:     
Date:

  • For more on this story, see here

Thursday, December 10, 2020

No brownfield survey, no idea where the jobs will come from, no protection for farmland… is there anything good about Thanet’s draft Local Plan?

Light at the end of the Thanet tunnel? Not really…

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.”

  • For more on this story, see here

Thursday, May 21, 2020

We support council in its Local Plan challenge, says Sevenoaks chairman

‘If the judicial review goes ahead, many councils will be hoping Sevenoaks succeeds’

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”

  • For more on this story, click here

Monday, May 11, 2020

Thanet finally sees a Local Plan on the horizon… and an awful lot more housing

Manston airport is to be safeguarded for aviation-related uses

Thanet might be close to having a Local Plan.
A seemingly interminable saga (see here, herehere, herehere 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 are:

  • 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.

  • Read the 63-page inspectors’ report here
  • See the recommended main modifications (to make the Plan sound) here

Wednesday, April 15, 2020

Sevenoaks sticks to its guns and refuses to withdraw draft Local Plan from examination

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.”

  • For more on this story, see here

Monday, January 20, 2020

Sevenoaks leader savages ‘huge abuse of the process’ after council advised to withdraw Local Plan from examination

Sevenoaks District Council has responded fiercely to the recommendation from a government inspector that it should withdraw its Local Plan from examination.
Inspector Karen Baker wrote to the local authority on Thursday, October 17, saying: “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…
“I am currently preparing a short letter setting out my concerns which will be with you shortly. I will not reach any final conclusions on the way forward for the examination until I have had the opportunity to consider your response to that letter…
“… I consider it is necessary for me to advise you that, at this point, I consider the most appropriate way forward for the Sevenoaks District Local Plan would be for the council to withdraw it from examination.”
Unsurprisingly, the missive has not been met with unbridled joy by the local authority.
A stinging statement on its website from council leader Peter Fleming says: “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.
“The inspector had our submission for six months and asked over 500 questions. What’s more, the draft Plan was independently verified and found sound by three external parties including the government’s own Planning Advisory Service.
“Had there been a fundamental problem, I would have expected the examination not to have gone ahead from the start.
“As a council we decided early on that we would follow an evidence-led approach, not prejudging any site and going where our Plan-making policy and the evidence took us.
“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.
“But the most damning comment has to be left for the inspector’s approach to publish her brief note before allowing the council to either see her full reasoning or have a chance to respond. This suggests her mind is far from open and she and her masters have made their minds up.
“Sevenoaks District Council will stand up for its residents and the district’s environment against what we believe is a huge abuse of the process by the Planning Inspectorate and the government department responsible.
“We will not allow them to run roughshod over the huge weight of evidence we have amassed, community views we have collated and the few powers we have left as a planning authority.”

Monday, October 21, 2019

Tunbridge Wells Local Plan chops Green Belt to allow for housing development

Tunbridge Wells countryside (pic Gabrielle Ludlow)

To a mixture of horror at what it includes and relief that it has finally seen the light of day, the Tunbridge Wells draft Local Plan has finally been published.
Covering the period 2016-2036, the Plan is aimed at replacing the local authority’s 2010 core strategy, 2016 site allocations plan and saved policies from its 2006 Local Plan.
Most contentiously, the draft looks to axe more than 5 per cent of the borough’s Green Belt, primarily to accommodate 14,776 new homes, a figure that includes a 9 per cent buffer above the government’s Objectively Assessed Need total of 13,560.
The homes are apparently going to be built at a rate of 678 a year, a target substantially more than double the 300-a-year featured in the 2010 core strategy, produced in line with the former South East Plan.
Disappointingly, the draft does not designate any land to compensate for the Green Belt that is set to be lost, which, as it stands, amounts to 5.35 per cent of the current total.
The largest housing allocations are at Paddock Wood (4,000 dwellings in addition to the 1,000 already allocated) and Tudeley (2,500-2,800, with some 1,900 to be built during the Plan period), as well as some 800 dwellings in the AONB at Cranbrook and 700, also in the AONB, at Hawkhurst.    
Liz Akenhead, chairman of CPRE Kent’s Tunbridge Wells committee, said: “The Plan states that, overall, some 5.35 per cent of the Green Belt within the borough is to be de-designated and that ‘in accordance with the NPPF the Plan does not designate other land as “replacement” Green Belt to replace that to be removed, but rather sets out how compensatory improvements to the environmental quality and accessibility of remaining Green Belt land can be made’. 
“On a first reading, I have not noticed any evidence in the Plan that these improvements will actually materialise.”
Consultation on the draft Plan begins on Friday, September 20, and is scheduled to end on Friday, November 1. It is anticipated that the Plan will be adopted in December next year.

  • For more on the Tunbridge Wells Local Plan, see here

Monday, September 9, 2019

Massive increase in housebuilding: a developing tragedy for the Tunbridge Wells countryside

Countryside at Brenchley (pic Gabrielle Ludlow)

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.

Monday, July 22, 2019